FOCUSED FEASIBILITY STUDY (FS) Focused Feasibility Study has been prepared on behalf of the...
Transcript of FOCUSED FEASIBILITY STUDY (FS) Focused Feasibility Study has been prepared on behalf of the...
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FOCUSED FEASIBILITY STUDYFOR THE
MALVERN TCE SUPERFUND SITEWHITELAND TOWNSHIP, PA
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Golder Associates Inc.1951 Old Cuthbert Road, Suite 301 •Cherry Hill. NJ 08034 1Telephone (856) 6 1 6-8 1 66 "Fax (856) 6 16- 1874
FOCUSED FEASIBILITY STUDYFOR THE
MALVERN TCE SUPERTUND SITEWHITELAND TOWNSHIP, PA
Prepared for:
Chemclene Site Defense Group
Prepared by:
Golder Associates Inc.1951 Old Cuthbert Road, Suite 301
Cherry Hill, New Jersey 08034
DISTRIBUTION.
5 Copies U.S. Environmental Protection Agency2 Copies PA Department of Environmental Protection1 Copy CSDG Technical Committee2 Copies Golder Associates
May 2002
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JtJ Golder/̂Associates
Project No: 003-6000
A R O Q 0 6 6 UOFFICES ACROSS ASIA, AUSTRALASIA, EUROPE, NORTH AMERICA, SOUTH AMERICA
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Golder Associates Inc.
1951 Old Cuthbert Road, Suite 301
Telephone (856) 6 1 6-8 1 66Fax (856) 6 16- 1874
May 17, 2002 Project No.: 003-6000
USEPA Region III1850 Arch StreetPhiladelphia, PA 19103-2029
Attn: Mr. Charlie Root
RE: FOCUSED FEASIBILITY STUDYMALVERN TCE SUPERPUND SITEEAST WHITELAND TOWNSHIP, CHESTER COUNTY, PENNSYLVANIA
Dear Mr. Root:
On behalf of the Chemclene Site Defense Group, Golder Associates Inc. is pleased to submit tothe USEPA three copies of the Focused Feasibility Study (FFS) for the Malvern TCE SuperfundSite. The FFS provides an evaluation of an Alternative Soil Remedy for the FDA/MA portion ofthe Site. As requested, two copies of the FFS have been sent to Ms. April Flipse of PADEP andMs. Mary Jo Apakian of CDM Federal. Additional copies have been submitted to the partieslisted below.
We would be glad to discuss any questions or comments that may arise during your or yourcolleagues' review of the FFS. Please contact either Mr. Chris Young at de maximis, inc. (610-435-1 151) or me if you would like to discuss any aspect of the FFS.
Very truly yours,
GOLDER ASSOCIATES INC.
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Randolph S. White, P.E.Principal
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cc: April Flipse, PADEPMary Jo Apakian, CDM FederalCSDG Technical CommitteeChris Young, de maximis, inc.Paul Boni, Esq.
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TABLE OF CONTENTS '
Cover Letter
Table of Contents i
SECTION PAGE
1.0 INTRODUCTION 11.1 General Site Description 11.2 Background 2
2.0 BASIS FOR CONSIDERATION OF AN ALTERNATIVE SOIL REMEDY 42.1 Remedial Design Contingency Plan (Appendix C to RDWP) 52.2 USEPA Remedy Update Directive 52.3 USEPA Superfund Reforms 62.4 Refined USEPA ROD Remedy Cost Estimate 6
3.0 CONCEPTUAL SITE MODEL - FDA/MA SOILS 73.1 Surrounding Area 73.2 Site Geology 73.3 Nature and Extent of Constituents in Subsurface Soil 73.4 Summary of FDA/MA Soil Exposure Risks 9
4.0 DESCRIPTION AND TECHNICAL EVALUATION OF THE ALTERNATIVESOIL REMEDY 114.1 Remedial Action Objectives 114.2 Description of Alternative Soil Remedy 11
4.2.1 Site Preparation 124.2.2 SVE Well Installation 134.2.3 Collection and Treatment Systems Installation 144.2.4 System Operation and Performance Evaluation 144.2.5 Closure Activities 154.2.6 Alternative Soil Remedy Summary 15
4.3 Alternative Soil Remedy Performance Assessment 154.3.1 Summary of On-Site SVE Pilot Study Results 164.3.2 SVE as a USEPA Presumptive Remedy 174.3.3 Previous Evaluation of SVE by USEPA 184.3.4 Summary of Performance Assessment 19
5.0 DETAILED ANALYSIS OF THE ALTERNATIVE SOIL REMEDY 205.1 Protection of Human Health and the Environment 205.2 Compliance with ARARs 205.3 Long-Term Effectiveness and Permanence 215.4 Reduction of Toxicity, Mobility, or Volume 225.5 Short-Term Effectiveness 225.6 Implementability 235.7 Cost 245.8 State and Community Acceptance 24
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6.0 DETAILED COMPARISON OF THE ALTERNATIVE SOIL REMEDY TO THEUSEPA ROD REMEDY 256.1 Comparison of Potential VOC Mass Removal 25
6.1.1 Alternative Soil Remedy 256.1.2 USEPA ROD Soil Remedy 26
6.2 Threshold Requirements 266.2.1 Overall Protection of Human Health and the Environment 266.2.2 Compliance with ARARs 27
6.3 Balancing Criteria 276.3.1 Long-Term Effectiveness and Permanence 276.3.2 Reduction of Toxicity, Mobility or Volume 286.3.3 Short-Term Effectiveness 296.3.4 Implementability 316.3.5 Cost 31
6.4 State and Community Acceptance 33
7.0 SUMMARY 34
8.0 REFERENCES 35
In OrderFollowing
Page 35LIST OF TABLES
Table 1 Alternative Soil Remedy Cost EstimateTable 2 Revised Cost Estimate for USEPA ROD FDA/MA Soil Remedy Expanded to
Address the Extent of VOCs Identified During the Pre-Design Investigation
LIST OF FIGURES
Figure 1 Site Location MapFigure 2 Site LayoutFigure 3 Generalized Fence DiagramFigure 4 FDA/MA Subsurface Soil Characterization (Phase I)Figure 5 FDA/MA Subsurface Soil Characterization (Phase II)Figure 6 Interpreted Zones of VOC Exceedances of ROD SCSFigure 7 Conceptual Layout of SVE for FDA/MA Soils
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1.0 INTRODUCTION
This Focused Feasibility Study has been prepared on behalf of the Chemclene Site Defense
Group (CSDG) for the Malvem TCE Superfund Site (Site) located in East Whiteland Township,
Chester County, Pennsylvania. The primary objective of the Focused Feasibility Study is to
provide a technical evaluation of an Alternative Soil Remedy within the Former Disposal
Area/Mounded Area portion of the Site and to compare the Alternative Soil Remedy to the
remedy selected by USEPA as presented in the 1997 Record of Decision (USEPA ROD). The
evaluation of the alternative remedy and comparison to the USEPA ROD remedy has been
conducted in accordance with the nine National Contingency Plan (NCP) criteria.
1.1 General Site Description
The Site is located in East Whiteland Township, Chester County, Pennsylvania as shown on
Figure 1. The Site is owned and operated by Chemclene Corporation (Chemclene), which
currently operates a hauling operation and stores, repackages and sells hydrogen peroxide at the
258 North Phoenixville Pike location. Former operations at the Site have primarily included the
storage and sale of new solvents and the distillation recycling of used chlorinated solvents for
resale of the purified materials. The entire Site encompasses approximately five acres along the
southeast side of Bacton Hill, and consists of a Main Plant Area (MPA), located at the 258 North
Phoenixville Pike address, and a Former Disposal Area (FDA) and Mounded Area (MA) that are
connected to the MPA by a long narrow meadow corridor that coincides with the Williams
Transcontinental Natural Gas Pipeline right-of-way, as shown on Figure 2.
This Focused Feasibility Study addresses soils within the FDA/MA portion of the Site, which is
located approximately 1,900 feet southwest of the MPA, and consists of a partially wooded area
covering approximately 2 acres surrounded by forested land, as shown on Figure 2. As stated in
the Final Data Summary Report prepared by CH2MHill on behalf of USEPA (CH2MHU1, April
1995), borrow pits (approximate 15 feet in depth) were excavated in the FDA portion of the Site
in 1952 to supply construction materials for the gas pipeline that is currently operated by
Williams Transcontinental. These pits were reportedly filled by Chemclene over time with
discarded drums, equipment, rubbish, and soil. Subsequently, the drums and debris were
removed by Chemclene over several episodes from 1981 through 1984. Approximately 300
drums and impacted soil/debris were removed from two excavations to a depth of about 15 feet.
The FDA currently contains two partially water-filled excavations surrounded by remnant soil
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piles generated during the previous drum removal activities and is surrounded by an 8-foot-high
chain-link security fence.
The MA portion of the area is located directly west of the FDA. Previously, earth mounds
existed as the ground surface expression of drums buried in shallow excavations and/or natural
depressions. The drums were removed in the early 1990's and the removed soils returned to the
excavation leaving the mounded area in its current essentially flat ground surface condition
(CH2MH111, 1997a).
1.2 Background
The Site was placed on the National Priorities List (NPL) in September 1983, after concentrations
of TCE exceeding USEPA maximum contaminant levels (MCLs) were detected in nearby
domestic groundwater wells (located in Hillbrook Circle, south of the FDA/MA) as shown on
Figure 2. In 1987 Chemclene Corporation, as an operating facility, entered into a Resource
Conservation and Recovery Act (RCRA) Corrective Action Order with the USEPA. A RCRA
Facilities Investigation (RFI) Work Plan was approved for the Site in 1989. However, in July
1992, Chemclene withdrew its RCRA Part B Application as a treatment, storage, and/or disposal
facility, did not fully implement the RFI Work Plan, stopped accepting used solvents for
reclamation and halted its distillation process. As a result of Chemclene's failure to complete the
RFI and implement interim corrective measures, USEPA placed the Site under the
Comprehensive Environmental Response and Liability Act (CERCLA) remedial program in
November 1993.
The USEPA completed a Remedial Investigation of the Site, including the FDA/MA, in January
1997 and a Feasibility Study in June 1997. The Proposed Remedial Action Plan for the Site was
published in June 1997. USEPA issued a ROD presenting the selected remedial action for the
Site in November 1997. As described in the 1997 USEPA ROD, the selected remedy for
FDA/MA soils is excavation (to a depth of 15 feet, as assumed in the USEPA Feasibility Study),
off-site treatment and disposal of soils impacted by volatile organic compounds (VOCs). The
overall objective of the remedy as stated in the USEPA ROD is to reduce the potential for
continued migration of contaminants from impacted soils to the groundwater.
Golder Associates, on behalf of the CSDG, conducted a Pre-Design Investigation of the FDA/MA
soils, along with other areas and media at the Site in accordance with a Remedial Design Work
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Plan (RDWP) approved by USEPA on October 31, 2000. During the course of conducting the
Pre-Design Investigation, it became readily apparent that subsurface conditions in the FDA/MA
differed considerably from what was described in the USEPA Feasibility Study and ROD, and as
a result, the effectiveness of the USEPA ROD remedy to address the newly identified conditions
was questioned. Consequently, Golder Associates, on behalf of the CSDG, proposed to USEPA
to conduct an on-site Soil Vapor Extraction (SVE) pilot study to confirm the effectiveness of
SVE as an alternative for the removal of VOCs from impacted soils within the FDA/MA. The
SVE pilot study was completed between November 2001 and January 2002 and the results were
presented to USEPA at a meeting on March 5, 2001. During that meeting, USEPA requested that
the CSDG prepare and submit a Focused Feasibility Study that formally evaluates an Alternative
Soil Remedy for FDA/MA soils based on SVE and compares that alternative remedy to the
USEPA ROD remedy in accordance with the nine NCP criteria. This Focused Feasibility Study
is being submitted to USEPA to fulfill this requirement.
The PDI Report is being submitted to USEPA concurrent with this Focused Feasibility Study and
provides detailed information with respect to Site and regulatory background, the results of
USEPA's Remedial Investigation and the activities and results of the Pre-Design Investigation.
Summaries of the results from the Pre-Design Investigation and the USEPA Remedial
Investigation conducted for FDA/MA soils are also presented in this Focused Feasibility Study.
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2.0 BASIS FOR CONSIDERATION OF AN ALTERNATIVE SOIL REMEDY
In reviewing the new information, which is the primary basis for consideration of an Alternative
Soil Remedy for the FDA/MA portion of the Site, it is recognized that the USEPA Feasibility
Study (CH2MHill, 1997) originally evaluated SVE as a potential remedy for the FDA/MA. The
review concluded that in situ SVE-based remediation of the FDA/MA soils "would attain risk-
based remedial action levels for soil and subsurface sources" pending verification by a pilot
study. The Remedial Design Contingency Plan, included as Appendix C in the USEPA approved
Remedial Design Work Plan (RDWP), also allowed for consideration of alternative approaches
should subsurface soil conditions in the FDA/MA vary from what was described in the USEPA
Feasibility Study and ROD. Finally, SVE is a USEPA presumptive remedy for VOC-impacted
subsurface soils and provides protection of human health and the environment by permanently
removing VOCs from the soil, complies with applicable or relevant and appropriate requirements
(ARARs), and provides both long- and short-term effectiveness.
Significant new site-specific information, including a comprehensive subsurface soil investigation
and an on-site SVE pilot study, has been conducted and presented to the USEPA and PADEP
since the execution of the USEPA ROD and affect the basis of the former remedy selection. This
significant new information is consistent with the requirements for re-evaluation of the selected
remedy in accordance with 40 CFR §300.825(c). This new information is not in the
Administrative Record for the Site and was not available for consideration in the public comment
process on the Proposed Remedial Action Plan. Because this new information has materially
altered the previous remedy selection basis, it warrants re-consideration of the FDA/MA soil
component of the USEPA ROD Remedy.
The Alternative Soil Remedy presented herein is protective of human health and the environment
and is more readily implemented than the USEPA ROD remedy. Furthermore, a pilot study has
been completed confirming its effectiveness. The Alternative Soil Remedy will also result in
substantially less adverse impacts to the surrounding community, site workers, and local ecology,
and is more cost effective. Therefore, Golder Associates strongly believes that if this new site-
specific information had been available at the time of remedy selection, an Alternative Soil
Remedy of the type recommended herein would have been selected by USEPA consistent with
the NCP criteria and the statutory requirements of CERCLA.
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The following discusses specific issues relating to the basis for considering an Alternative Soil
Remedy for FDA/MA soils.
2.1 Remedial Design Contingency Plan (Appendix C to RDWP)
The Remedial Design Contingency Plan, included as Appendix C of the USEPA approved
RDWP, presents an approach for revising the USEPA ROD remedy should information obtained
during the Pre-Design Investigation substantially change the technical basis for selection and
design of the soil remedy, and/or should the re-evaluation of the assumptions made during the
USEPA Feasibility Study indicate that other remedial approaches would more effectively meet
the USEPA ROD performance standards. Based on the results of the Pre-Design Investigation, it
was determined that subsurface conditions vary considerably from those considered during the
USEPA ROD remedy selection process and that implementation of the Alternative Remedy will
more effectively meet the USEPA ROD objectives. Therefore, the Remedial Design Contingency
Plan, which discusses the possibility of SVE removal of VOCs as an alternative approach for
FDA/MA soils supports this evaluation of the Alternative Soil Remedy.
2.2 USEPA Remedy Update Directive
An additional basis for considering a change to the USEPA ROD remedy for FDA/MA soils is
presented in Superfund Reforms: Updating Remedy Decisions (OSWER Directive 9200.0-22).
Although intended to be applied to RODs existing at the time of publication, the concepts may be
applied to the consideration of the Alternative Soil Remedy. This directive states that:
"The purpose of this Superfund Reform is to encourage appropriate changesToremedies selected in existing Superfund Records of Decision (RODs). Theseupdates are intended to bring past decisions into line with the current state ofknowledge with respect to remediation science and technology and by doing so,improve the cost effectiveness of site remediation while ensuring reliable shortand long term protection of human health and the environment."
The directive goes on to say that "Modification of RODs generally is appropriate where
significant new information has become available (i.e., the information was not available at the
time the USEPA ROD was signed) that substantially supports the need to alter the remedy."
Further, the directive states that "In cases where a change in remedial technology or approach is
proposed, remedy updates should be based on site-specific information gathered or developed
after the USEPA ROD was signed." The directive also provides that updates are appropriate
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when new information indicates another remediation technology would perform as well as the
selected remedy for a significantly lower cost.
The significant new information obtained during the Pre-Design Investigation (including the SVE
Pilot Study) clearly meets the above USEPA criteria for significant new information. This new
information has a direct bearing on the evaluation of a more cost-effective remedial technology
for subsurface soils at the Site.
Moreover, the project schedule related criteria of the directive are also met because the project is
at the beginning of the design phase of the remedial process. Thus, USEPA's selection of the
Alternative Soil Remedy will not impact the design and construction schedule.
2.3 USEPA Superfund Reforms
In October 1995, the USEPA issued the Superfund Administrative Reforms (USEPA, 1995)
which provide a basis for re-evaluating remedy decisions, especially when new technical
information becomes available or when applicable regulatory policy changes occur after remedy
decisions have been made. The reforms allow for revising remedy decisions at specific sites
where new technical information or technological advancements become available that can
achieve the same level of protectiveness to human health and the environment and will comply
with ARARs at a lower cost. Clearly, the new information and analyses presented in this Focused
Feasibility Study indicate that the Alternative Soil Remedy is in line with these reform initiatives
and is the appropriate remedy to address the remedial action objectives for FDA/MA soil.
2.4 Refined USEPA ROD Remedy Cost Estimate
A revised cost estimate for implementing the USEPA ROD remedy for FDA/MA soils has been
developed by Golder Associates based upon the information provided in this Focused Feasibility
Study (see Section 6.3.5). The revised cost for the USEPA ROD remedy for FDA/MA soils is
$17.8 million, which is more than two times greater than the cost estimate of $7.0 million
presented in the USEPA ROD. Because USEPA has stated in The Rule of Cost in the Superfund
Remedy Selection Process (USEPA, 1996) that cost-effectiveness is an important criterion for
remedy selection, this revised cost estimate has modified the basis for the previous remedy
selection.
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3.0 CONCEPTUAL SITE MODEL - FDA/MA SOILS
Section 1.1 presented a general description of the FDA/MA portion of the Site. The following
presents a description of the surrounding area and the subsurface conditions identified during the
Pre-Design Investigation.
3.1 Surrounding Area
Adjacent to the Site are residential areas and areas with natural forestation and vegetation to the
west, north and east. A natural gas pipeline right-of-way and abandoned railroad extend along
the southern boundary of the area. The closest residential dwellings are within 400 feet of the
FDA/MA and are part of the Hillbrook Circle Subdivision. The Spring Mill Farms residential
development lies approximately 500 feet to the northeast. The Great Valley Senior High School
is located on Phoenixville Pike, approximately 1,800 feet southeast of the Site. Phoenixville
Pike, the main access route to the Site, is a busy, two-lane road.
3.2 Site Geology
The overburden soils within the FDA/MA can be categorized into three general vertical horizons:
• Upper clay - consisting of a locally disturbed surficial mostly silty clay unit with anaverage thickness of about 5 feet extending to depths of about 10 feet in places;
• Interbedded zone - consisting of silty sands, silts and clays interbedded with thin,discontinuous layers of sands and gravels lying about 20 to 25 feet below the upper clay;and,
• Lower clay - consisting of suffer and more homogeneous silty clays lying below theinterbedded zone and on top of the underlying carbonate bedrock that variably liesbetween about 45 to 60 feet bgs.
Figure 3 presents a generalized fence diagram illustrating the general lithology of the FDA/MA
overburden.
3.3 Nature and Extent of Constituents in Subsurface Soil
Significant new technical data has been gathered since the USEPA ROD was issued in November
1997 that has refined the understanding of the lateral and vertical distribution of subsurface
impacts. Data collected during the Pre-Design Investigation are presented and described in detail
in the PDI Report (Golder, 2002b). As described in the PDI Report, the actual lateral and vertical
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distribution of VOC impacts differed from the assumptions presented in USEPA's Feasibility
Study and adopted by the USEPA ROD. The predominant VOC mass lies within the interbedded
zone and extends to roughly 30 to 35 feet at concentrations exceeding the ROD SCS.
Conversely, the USEPA ROD assumed a limited aerial extent and maximum depth of
approximately 15 feet. Figures 4 and 5 provide a summary of the subsurface soil sample analyses
results obtained during the USEPA Remedial Investigation and Pre-Design Investigation.
The subsurface data were interpreted by the Environmental Visualization System Version 5.51
(EVS) to identify areas where VOC levels exceed the ROD SCS in the FDA/MA. A three-
dimensional simulation of the extent of VOC exceedances is shown on Figure 6.
The lateral and vertical extent of VOCs has been well defined for the purpose of the design and
implementation of an effective soil remedy. The majority of the subsurface soil VOC impacts are
contained within the lower portions of the upper clay and throughout the interbedded zone.
Smaller amounts were found in the upper portions of the lower clay. The VOCs of interest are
PCE, TCE, and 1,1,1-TCA and their natural breakdown products. Concentrations of VOCs
within the lower portion of the upper clay and the interbedded zone are variable, with limited
samples exceeding 1,000 mg/kg at depths approaching 25 feet (e.g., GB-2-B2 in the MA and GB-
39 in the FDA). Further, VOC concentrations in the lower portion of the interbedded zone and
upper portion of the lower clay have a substantially smaller aerial extent and lower concentrations
that quickly diminish with depth generally below about 30 to 35 feet in the upper portion of the
lower clay. These data are consistent with the extent and magnitude of VOCs detected in
groundwater, as described in the PDI Report, which are not indicative of a substantial source in
the vadose zone, but are more reflective of impacts from a diffuse source with the overburden
material. The depth to groundwater measured during the Pre-Design Investigation has ranged
from approximately 60 to 70 feet bgs below the FDA/MA.
The PCB results from the Pre-Design Investigation indicate limited detections of PCBs. None of
the PCB detections in the MA exceeded the ROD SCS of 1 mg/kg. Therefore, the final remedy
will not need to directly address PCBs in the MA. Within the FDA, PCB concentrations are low
and sporadically exist in shallow soils and soil piles and in a few localized deeper locations. Of
the PCB detections exceeding the ROD SCS, the highest is 14.44 mg/kg at GB-18 (a northern
excavation sidewall sample), the lowest value is 1.26 mg/kg at GB-11 (northern excavation base
sample). The average of the sample results that exceed the ROD SCS is approximately 6 mg/kg.
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The deepest PCB detection above ROD SCS occurred north of the northern excavation in boring
GB-35V (4.6 mg/kg at 16 feet bgs). The majority of the PCB Aroclors detected (1260 and 1254)
are some of the least mobile PCB Aroclors. Figures 4 and 5 show the locations and
concentrations of PCBs detected in the FDA/MA.
3.4 Summary of FDA/MA Soil Exposure Risks
The following summarizes the USEPA Baseline Risk Assessment results presented in the USEPA
Remedial Investigation Report and summarized in the USEPA ROD.
USEPA evaluated potential residential, industrial and trespasser direct contact exposures
(inhalation, ingestion and dermal) to FDA/MA soils. Except for the residential child soil
ingestion pathway, the potential risk estimates for all other direct contact exposure pathways to
FDA/MA soils were calculated to be within or less than the acceptable risk range established by
USEPA. The residential child exposure hazard index (4.0 for FDA soils and 2.5 for MA soils), as
stated in the USEPA Baseline Risk Assessment, only "slightly exceeds USEPA's benchmark"
and that "this hazard is associated with iron and manganese." All potential carcinogenic risks
associated with FDA/MA soil exposures are within USEPA's acceptable range.
The Uncertainty Analysis section of the Baseline Risk Assessment further discussed the estimated
hazard associated with potential future child resident exposure to soil as being mainly due to iron
detected in soil. The discussion further stated that:
• The reference dose for iron is provisional and possesses only a moderate level ofconfidence
• Iron is considered a human nutrient; and,
• The presence of iron is not necessarily due to historical activities.
Thus, the only soil direct contact exposure risk estimates that exceed the USEPA acceptable
range is attributable to natural background levels of iron and manganese. In summary, the
USEPA risk assessment concluded that there are no unacceptable risks from residential,
industrial, or trespasser direct contact exposures to site related constituents in FDA/MA soils.
The USEPA risk assessment did identify unacceptable risks from drinking untreated groundwater
at the FDA/MA portion of the Site. However, the nearby residents have been connected to a
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public water supply system1, thereby eliminating the current potential exposure pathway and thus,
the associated risks. The only remaining exposure pathway of concern is the potential future
residential use of groundwater should the FDA/MA be developed for residential purposes and not
connected to the public water supply system, which is an unlikely hypothetical scenario.
The results of the ecological portion of the USEPA Baseline Risk Assessment are based on two
evaluation approaches, direct toxicity and food chain accumulation. The direct toxicity
evaluation determined that neither metals nor volatiles pose a risk to ecological receptors in
FDA/MA soils. PCBs were determined to pose a potential ecological risk based on the food
chain evaluation. Similar to the human health assessment, the potential ecological risk associated
with metals was determined to be due to natural background conditions.
1 The USEPA ROD remedy required providing a public water supply to the Hillbrook Circle development residents.The CSDG have completed this aspect of the USEPA ROD and all the Hillbrook Circle residents are now connected toa public water supply.
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4.0 DESCRIPTION AND TECHNICAL EVALUATION OF THE ALTERNATIVESOIL REMEDY
This section provides a description of the Alternative Soil Remedy, including a technical
evaluation of the effectiveness of the SVE technology applied to FDA/MA soils.
4.1 Remedial Action Objectives
Given the results of the Baseline Risk Assessment presented in Section 3.4 of this Focused
Feasibility Study, the principal objective for remediation of subsurface soil in the FDA/MA, as
stated in the USEPA ROD, is "to reduce the potential for continued migration of contaminants in
these soils to the groundwater." USEPA developed the ROD SCS for VOCs based on the
groundwater protection objective as presented in the USEPA Technical Memorandum dated
December 20, 1996. The SCS were presented in the USEPA ROD as conservative standards to
guide the excavation remedy toward achieving the overall groundwater protection objective.
Notably, the concern for PCBs raised in the USEPA ROD focused on potential ecological
impacts, not potential impacts to groundwater. Therefore, the remedial action objective for PCB
remediation is to minimize ecological receptor exposures to PCBs in soils.
4.2 Description of Alternative Soil Remedy
Based on the results of the Pre-Design Investigation, VOCs are the primary constituents of
concern in FDA/MA soils and extend at concentrations exceeding the ROD SCS across the
FDA/MA to depths of about 30 to 35 feet bgs. PCBs are not a remedial concern in the MA. In
the FDA, PCBs marginally exceeding the ROD SCS were sporadically detected, primarily at
shallow depths. The deepest detection of PCBs exceeding the ROD SCS was at boring location
GB-35 (4.6 mg/kg at 16 feet bgs).
An Alternative Soil Remedy has been developed to address the above soil impacts and to achieve
the remedial action objectives for FDA/MA soils in a reliable and cost-effect manner. An SVE
system will accomplish the primary remedial action objective, namely, protection of groundwater
from future VOC impacts. Excavation of the limited shallow PCB impacted soils and adequate
cover over the remaining few isolated areas of deeper PCB impacts will accomplish the
ecological receptor protection objective.
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The Alternative Soil Remedy involves five major stages of implementation: site preparation
(which will accomplish the required PCB remediation), SVE well installation, VOC collection
and treatment systems installation, SVE system operation and performance evaluation (which will
accomplish the required VOC remediation), and closure.
4.2.1 Site Preparation
During typical site preparation for SVE systems, grading operations are performed to create a
generally flat working surface. Limited excavation of shallow PCB impacted soils is also
necessary to minimize ecological exposures and thus will be accomplished as part of site
preparation. As discussed previously, PCB impacts to MA soils are not a remedial concern.
Soils in the FDA impacted with PCBs at concentrations above the SCS will be excavated to a
depth of 2 feet and re-filled and graded with clean soil (18 inches of general fill covered with 6
inches of topsoil) as determined during remedial design to maintain proper grades.
The soil piles in the FDA area will also be removed or regraded as necessary based on the overall
grading plan prepared during detailed design and the results of sample analyses to be conducted
during remedial action. Soil piles, surface soil, and the remnant roll-off contents with
constituents at levels that exceed the ROD SCS will be removed and disposed of off-site. Soil
piles having PCB (and VOC) concentrations below the SCS will be used as grading material to
help fill in the surficial PCB excavation areas and other low lying areas.
The two partially water-filled excavations in the FDA are intended to be used as SVE extraction
galleries. Initially, the accumulated water will be removed from the two excavations during the
site preparation stage. The water will be tested and disposed of accordingly. To improve
pneumatic connection between the extraction galleries and surrounding subsurface soils, 2 feet of
sidewall and base materials (which have likely clogged with fine particles and vegetative debris
over the years) will be removed from the excavations and disposed of along with other impacted
soils removed from the FDA. The excavations will then be filled with a material having a higher
pneumatic permeability than the surrounding soils and covered with a low permeability layer to
mimic the upper clay low permeability cover over the interbedded zone that lies across the
remainder of the FDA/MA. The removal of this 2-foot soil/sediment layer from the sides and
bottom of the excavations will result in the removal of additional PCBs.
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'>Completion of the Site preparation work will leave only two measured PCB exceedances of the
ROD SCS. These two exceedances occur at depths between 10 and 16 feet bgs, which are
inaccessible to ecological receptors.
Grading will also be performed in the MA. When completed, site preparation will provide a
relatively clear and flat working surface to build and operate the SVE system and will have
accomplished the USEPA ROD objective for PCBs by providing protection of ecological
receptors.
Preparation activities also include improving the access road along the railroad right-of-way;
building a road crossing of the pipeline right-of-way; removing the fence around the FDA (where
needed to implement the remedial action in the area); installing a temporary fence around the
working area; and removing an old roll-off container and other debris if encountered and
characterizing and disposing of such items as appropriate. A contingency plan will also be
developed for the handling and removal of drum carcasses, if any are uncovered during the Site
preparation work.,
4.2.2 SVE Well Installation
As shown on Figure 7, the SVE wells designed to remove VOCs from the lower portion of the
upper clay and throughout the interbedded zone will be installed at a 35-foot lateral spacing with
screens extending from about 5 feet below ground surface (feet bgs) to approximately 25 to 35
feet bgs. The results from the SVE pilot study demonstrated a 25-foot radius of influence.
Therefore, the 35-foot spacing provides more than 30% overlap of influence from adjacent SVE
wells. The specific screen interval and depth at each well will be based on the Pre-Design
Investigation results (e.g., boring logs and subsurface soil sample analyses results) and will be
finalized during design. Additional SVE well(s) may be constructed to confirm that the SVE
system addresses the extent of VOC impacts.
The deep wells used to extract VOCs from the lower clay below the interbedded zone will also be
installed at a 35-foot lateral spacing, as shown on Figure 7. Fewer wells are installed in this zone
as the lateral distribution of VOC impacts at depth are substantially less. The length and depth of
screens will be based on the Pre-Design Investigation boring results, which provided an overall
vertical delineation of VOC impacts and top of bedrock. Refinements to the screen settings, if
necessary, will be accomplished using borings installed during SVE well installation.
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4.2.3 Collection and Treatment Systems Installation
A series of wellhead assemblies, piping (underground and/or aboveground, heat-traced as
necessary), condensate collection traps (if needed); knock-out pot, blower system,
valves/controls; monitoring equipment; and other appurtenances will be installed. A temporary
fence will be installed around exposed equipment associated with the SVE system. Electrical
power will be brought to the FDA/MA. The SVE air emissions treatment system will likely
consist of vapor phase activated carbon units constructed in series2. The type, size, and details of
the SVE collection and treatment systems will be defined during detailed design.
4.2.4 System Operation and Performance Evaluation
During start-up operations, the SVE system will be balanced to optimize extraction flow rates,
VOC mass removal, and energy use. Long-term operation of the SVE system will be conducted
on a routine basis and will include monitoring of flow rate, VOC concentrations and system
vacuums. Ongoing adjustments of the system operation will be made as needed to optimize VOC
mass removal until the SVE system begins to reach the limits of the technology. This occurs
when the rate of mass removal begins to become diffusion limited and further continuous SVE
operation does not efficiently remove VOCs, i.e., the system begins to reach its asymptotic
endpoint.
It is anticipated that different portions of the system will begin to reach their asymptotic
endpoints at different times. To maximize the efficiency of SVE performance in these portions,
the operation of the effected wells will be switched to a cycling mode (singly or in clusters).
Cycled operation maximizes the rate of VOC mass removal by allowing sufficient time for
remaining low levels of VOCs to diffuse from the soil matrix to the vapor phase where they can
be extracted in a pulsed manner. Cycling operations will be adjusted as needed and continued
until the removal of the rebounding mass is negligible.
Ultimately, the operational effectiveness of the SVE system will reach the limits of the
technology where, after cycling operation, the rate of VOC mass removal asymptotically levels
off to a point that is negligible as compared to the energy expenditure needed to continue
2 For the purpose of this Focused Feasibility Study, the vapor phase treatment component of the Alternative SoilRemedy is assumed to be activated carbon. Other vapor phase treatment technologies may be considered duringdetailed design. Further, it may not be necessary to treat extracted VOC vapors during the entire period of operation,particularly in the later stages when potential VOC emissions will be substantially reduced. In any case, vapor phasetreatment will be provided to the extent necessary to comply with federal and state air emission regulations.
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operation of the SVE system. This point is commonly referred to as the asymptotic endpoint of
an SVE system. Specific criteria for defining the asymptotic endpoint (i.e., the SVE operation
performance objectives) will be developed during detailed design. Once the VOC removal
reaches asymptotic conditions, system operation will be discontinued.
4.2.5 Closure Activities
Once the SVE system reaches its performance objectives, and following USEPA's system shut-
down approval, the SVE system and wells will be decommissioned and removed from the Site.
Site restoration activities such as vegetating disturbed areas will be completed and the fence will
be removed. It is estimated that closure activities may commence within 2 to 5 years following
start-up of the SVE system.
4.2.6 Alternative Soil Remedy Summary
The Alternative Soil Remedy contains an excavation component similar to the USEPA ROD
Remedy for FDA/MA soils albeit at a much smaller scale. However, unlike the USEPA ROD
remedy, the Alternative Soil Remedy removes the majority of the VOCs from soil via SVE rather
than excavation, thus facilitating the removal of deeper VOC impacts identified in the Pre-Design
Investigation. The SVE system will not only effectively extract VOC from shallow subsurface
soil as contemplated by the USEPA ROD Remedy, it will also remove VOCs from deeper, less
accessible locations not considered in the USEPA Feasibility Study or ROD. Treatment of VOCs
will be accomplished off-site as part of the vapor phase carbon treatment/regeneration. Operation
and maintenance activities and performance monitoring will be conducted to ensure the long-term
effectiveness of the Alternative Soil Remedy for meeting the principle objective of the USEPA
ROD, namely groundwater protection.
4.3 Alternative Soil Remedy Performance Assessment
Since the signing of the USEPA ROD, significant new, site-specific technical information has been
developed that has allowed a more refined and conclusive evaluation of the performance of the SVE
technology applied to FDA/MA soils. In particular, an on-site SVE pilot study was performed. This
section discusses the evaluation of the performance of SVE in FDA/MA soils for meeting the overall
groundwater protection objective.
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4J.I Summary of On-Site SVE Pilot Study Results
Golder Associates conducted a program of full-scale field testing to assess the potential performance
of SVE and to satisfy the concern identified in the USEPA ROD, namely that there was insufficient
information to adequately evaluate the SVE technologies' effectiveness in site-specific conditions.
Notably, USEPA's Feasibility Study also identified the need to conduct a pilot study.
Success Criteria
The SVE pilot study was completed in the MA portion of the Site in accordance with the
USEPA-approved SVE Pilot Study Work Plan (PSWP; Colder, 2001b). In the PSWP, Golder
Associates specified the following operational criteria to be used to determine "success" of the
SVE system:
• Remove and sustain the removal of significant quantities of VOC mass with initialrecovery rates in excess of 1 pound per day;
• Achieve adequate air flow through the impacted soil zones, defined as an air flow rategreater than 20 standard cubic feet per minute (scfm) at vacuum levels less than 16 inchesof mercury (in Hg);
• Achieve a 30-day time interval radius of influence (ROI30) of 10 feet or greater;
• Soil air-phase permeabilities should be greater than IxlO"9 cm2;
• Chemicals should be volatile and exhibit appropriate Henry's Law constants and vaporpressures for effective removal by SVE;
• Depth to water table should exceed 10 feet; and,
• Highly permeable fill or man-made passageways (i.e., sewers or pipe ways) should beabsent to minimize airflow short circuiting or preferential flow.
SVE Pilot Study Results
Results of the pilot study indicate that the SVE pilot system has met or exceeded the performance
criteria defined in the USEPA approved SVE PSWP for the FDA/MA as evidenced by the
following observations:
• Mass removal rates of approximately 18 pounds per day were attained (PSWP criteria - >1 Ib/day), indicating that SVE can remove substantial VOCs at a sustainable rate. Thepilot study results showed an increasing area of influence around the extraction well andhence, increasing concentrations extracted with time;
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• Air flow rates for the three SVE test cluster wells combined were Over 20 scfm (PSWPcriteria - > 20 scfm);
• The ROIjo was estimated to be 25 feet (PSWP criteria - > 10 feet);
• Air permeability was estimated to be 3x10~9 cm2 to IxlO"8 cm2 (PSWP criteria - > IxlO"9
cm2);
• The VOCs of interest all exhibit Henry's Law Constants amenable to effective removalby SVE; and,
• The depth to groundwater ranges between 60 to 70 feet bgs (PSWP criteria is 10 feet).
The Pilot Study also indicated that the zones of potentially higher permeable material (i.e., the
thin, discontinuous layers of sands and gravel within the interbedded zone) did not result in short-
circuiting the performance of the system. In fact, the results indicate that the interbedded unit
(which contains the majority of the VOC mass) responded uniformly as a sandy/silty material.
This homogeneous domain (as observed during the pilot study) is more favorable than a domain
having preferential flow paths within highly permeability areas. The uniform vertical and
horizontal performance results observed during the test will also reduce the need for the
installation and operation of a system with targeted intervals in a full-scale SVE system, i.e.,
fewer wells with longer screens can be used. In addition, the upper clay provides a natural low
permeability cover over the system, minimizing ambient air infiltration and maximizing vapor
extraction from the most impacted unit, the interbedded zone, that lies directly beneath the upper
clay.
In summary, the results of the SVE Pilot Study indicate that removing substantial quantities of
VOC mass from the impacted soil zones in the FDA/MA is achievable and that SVE is a viable
alternative technology to consider for remediating VOC impacted soils in the FDA/MA.
4.3.2 SVE as a USEPA Presumptive Remedy
The SVE technology has been identified by USEPA as a presumptive remedy for sites with soils
contaminated by VOCs in the technical guidance entitled: "Presumptive Remedies: Site
Characterization and Technology Selection for CERCLA Sites with Volatile Organic Compounds in
Soils" (USEPA 540-F-93-048, 1993). In 1997, USEPA published supplemental technical guidance
that addresses and recommends SVE for removal of VOCs in low to moderate permeability soils,
such as those at the FDA/MA. In particular, the conditions within the FDA/MA meet the
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requirements for successful remediation presented in the 1993 and 1997 USEPA technical guidance
and the U.S. Army Corps of Engineers Design Manual (USACOE, 1995) as follows:
• The vast majority of the constituents present in the soil are halogenated volatile organicsthat are listed by the USEPA as amenable to SVE removal. Removal of the PCBs, doesnot interfere with the effectiveness of SVE;
• The constituents of primary concern have Henry's Law Constants >0.00024 (atm-mVmol) @ 20°C and vapor pressures >1.0 mm Hg @ 20°C, as shown below:
ConstituentPCETCE
1,1,1-TCA1,1 -DCE1,1 -DCA
Methylene chloride
Henry's Law Constant(atm-m3/mol)
0.0230.01030.0130.023
0.00590.00131
Vapor Pressure(mm Hg)
18.560100500180349
The moisture content of the soil above the water table is well below 50 percent (5 to 18percent); and,
The soil was found to exhibit less heterogeneity than predicted by the original conceptualmodel of the FDA/MA, and no high permeability preferential pathways negatively effectingsystem performance were identified during the pilot study.
The USACOE recommends pilot testing to confirm the feasibility of SVE in low to moderate
permeability soils, such as at the FDA/MA. A pilot study was performed that confirms SVE as a
feasible remedial technology for VOC removal under site -specific conditions. Moreover, the new
USEPA presumptive remedy guidance identifies ten case studies where SVE has been successfully
employed in low permeability soils impacted with VOCs. The mass removal rates and vapor flow
rates observed during the on-site SVE pilot study are within the ranges observed in these case
studies. In fact, the pilot study data presented for the FDA/MA Site predicts performance well in
comparison to the case studies presented by USEPA as successful applications of the technology.
4.3.3 Previous Evaluation of SVE by USEPA
SVE was investigated as a possible remedy for the soils in the FDA/MA in the USEPA
Feasibility Study. It was favorably recognized in the USEPA Feasibility Study to protect human
health and the environment; provide long-term effectiveness and permanence; reduce toxicity,
mobility, and volume of contaminants; and be implementable. The USEPA ROD states that the
SVE alternative remedy "will greatly accelerate the rate at which the clean up levels can be
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attained. VOC contaminants will be removed from the subsurface soils." However, the USEPA
ROD states that the effectiveness of SVE needs to be demonstrated for site-specific conditions
through a treatability study, which, while not conducted as part of the USEPA Feasibility Study
or ROD remedy decision process, was conducted during the Pre-Design Investigation as
described above.
4.3.4 Summary of Performance Assessment
In addition to 1) its designation by the USEPA as a presumptive remedy for VOCs; 2) the
identified Site conditions being amenable to successful SVE remediation as shown by
USEPA/ACOE studies and documents; and 3) positive review of the application of SVE to
FDA/MA soils by the USEPA in the Feasibility Study and ROD, the performance of SVE for
effectively removing VOCs from FDA/MA soils was confirmed by the results of the SVE pilot
study conducted at the Site. The limited PCB impacts will be addressed by excavation and off-
site disposal of PCB impacted soil within the first 2 feet of ground surface soil piles and the
sidewalls and base of the excavations. For the minor PCB impacts at depth (only two remaining
locations), ecological receptors will be protected by limiting exposure through the remaining
cover material.
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^5.0 DETAILED ANALYSIS OF THE ALTERNATIVE SOIL REMEDY
This section provides a detailed analysis of the Alternative Soil Remedy in accordance with the
same NCP criteria that were used to evaluate the alternatives considered in the USEPA ROD.
This evaluation demonstrates that the Alternative Soil Remedy meets the requirements of the
NCP and the statutory criteria in Section 121 of CERCLA.
5.1 Protection of Human Health and the Environment
The Alternative Soil Remedy provides a high degree of long-term protection of human health and the
environment by removing VOCs from the soil through SVE, thus meeting the USEPA groundwater
protection objectives. SVE, identified by USEPA as a presumptive remedy for the remediation of
VOCs in subsurface soils, has been well documented by USEPA and the USACOE to be effective in
the subsurface conditions similar to those that exist in the FDA/MA. Importantly, the effectiveness
of SVE has been confirmed by an on-site SVE pilot study as a method that can effectively remove
large quantities of VOC from subsurface soils. This substantial removal of VOC mass will provide
effective source control and treatment mitigating future impacts of VOC leaching from unsarurated
zone soils to groundwater in support of the USEPA ROD MNA remedy for FDA/MA groundwater.
In fact, the USEPA ROD concurs that SVE will provide overall protection of human health and the
environment (see Section IV, Comparative Analysis of Alternatives). The removal of surficial PCB
impacts and the remaining cover over the few minor, localized PCB impacts at depth will minimize
potential future ecological receptor exposures to PCBs. Therefore, the Alternative Soil Remedy
provides protection of human health and the environment.
5.2 Compliance with ARARs
The Alternative Soil Remedy will comply with ARARs as follows:
• If the residuals generated during the implementation of the Alternative Soil Remedy(excavated soil, spent carbon, etc.) are determined to be hazardous as defined in RCRA, theremedy can easily be implemented consistent with RCRA and Pennsylvania hazardouswaste regulations related to pre-transport, transport, treatment, and disposal of hazardouswastes. Otherwise, the residuals will be handled in compliance with applicable non-hazardous solid waste regulations;
• Fugitive dust and VOCs that may be generated during remedial activities will be controlledto comply with federal and state air regulations such as those contained in the federally-approved State Implementation Plan and the National Ambient Air Quality Standards forParticulate Matter and VOCs;
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• Because VOCs may be released into the air during remedial activities, particularly duringlimited excavation activities, air monitoring will be performed in accordance with applicableOSHA regulations and guidance;
• The installation of wells will be conducted in accordance with Chester County and otherapplicable drilling regulations; and,
• Air emissions from the SVE system will be controlled by an on-site treatment systemdesigned for the VOCs of interest. Specifics of the VOC capture system will be determinedduring the detailed design phase. The air emissions control system will be designed andoperated in compliance with the State and Federal air regulations, including Air EmissionsStandards for Equipment Leaks (40 CFR §264.1030-1063), national Emission Standards forHazardous Air Pollutants (if applicable), Best Available Technology regulations (25 PACode §127.12), air permitting requirements, and Pennsylvania guidelines for remediationprojects, as necessary.
In addition, the USEPA ROD and Feasibility Study indicate that the SVE remedy can be
implemented in compliance with chemical-, location-, and action-specific ARARs that were
identified in these documents. In summary, the Alternative Soil Remedy can be constructed,
operated, and decommissioned in compliance with ARARs.
5.3 Long-Term Effectiveness and Permanence
As discussed in Section 4.3, SVE is a highly effective technology for removing substantial
quantities of VOCs from subsurface soils. In fact, USEPA has identified SVE as a preferred
technology for conditions such as those that exist at the Site. The high degree of effectiveness of
SVE has been demonstrated via the on-site pilot study and is well-documented in USEPA and
USACOE guidance and published literature. The SVE system will permanently remove VOCs
from subsurface soil, thus providing long-term effectiveness for meeting the groundwater
protection objective.
The extracted VOCs in the vapors will be treated. Therefore, the Alternative Soil Remedy meets the
CERCLA statutory goal of permanence, not only from the perspective of permanently removing the
VOC from the Site but also because the VOCs will be permanently destroyed through treatment. In
fact, the USEPA Feasibility Study describes the SVE alternative as:
"a permanent treatment solution. By-products from the SVE process consist ofspent carbon used for off-gas treatment and condensate water collected in thewater/vapor separator. The spent carbon would be sent off-site for regenerationand re-use...The condensate would be sent off-site for treatment and disposal.After remedial action, all on-site risks would be below risk-based levels.Following implementation of this alternative, the site could be returned to normaluse with few restrictions."
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Potential ecological receptors will be protected through excavation of PCB exceedances within the
first 2 feet of the ground surface. Adequate cover materials will remain over the limited deeper PCB
detections to ensure ecological protection.
Altogether, the Alternative Soil Remedy provides a reliable, long-term remedy for meeting the
remedial action objectives of protection of groundwater and ecological receptors. In addition, the
Alternative Soil Remedy provides a high degree of permanence through permanent removal of
VOCs and PCBs from soil, as well as destruction of VOCs through off-site treatment of spent
carbon.
5.4 Reduction of Toxicity, Mobility, or Volume
The Alternative Soil Remedy will provide a high level of reduction of toxicity and volume of VOCs
through on-site removal and off-site treatment. As discussed in the preceding section, the extracted
VOCs will be captured in carbon units and destroyed via off-site treatment. While already minimal,
the volume of PCBs will be further reduced through shallow soil excavation and other Site
preparation activities. Altogether, the Alternative Soil Remedy will provide a high degree of
reduction of toxicity, mobility, and volume of constituents contributing to the principal threats at the
Site.
5.5 Short-Term Effectiveness
The Alternative Soil Remedy, which is predominantly an in situ technology, is expected to have
minimal short-term impacts to the surrounding public, surrounding land, and remedial contractor
workers. The limited excavation and regrading activities performed during site preparation will
minimize the potential for VOC emissions and vehicle traffic noise due to its shallow depth and
limited extent. Soil excavations will be small and shallow, quickly completed and backfilled and
no construction personnel will need to routinely enter and work within the excavations. While
the Alternative Soil Remedy includes some off-site transportation, the amount of truck round trips
(estimated to be between 50 and 100) transporting the impacted soil and spent carbon through the
surrounding area is minimal (as compared to the USEPA ROD remedy), and is not expected to
substantially impact the local community and traffic. The limited extent of the shallow PCB
excavation activities and minimal land disturbance associated with construction of the SVE
system will preserve much of the existing forested area surrounding the FDA/MA.
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Given the small size and shallow depth of the excavations and short duration of excavation
activities, and the small amount of SVE well drill cuttings that will become exposed at the
surface, engineering controls can effectively reduce VOC emissions to protect workers and
potential downwind receptors. During the shallow PCB excavations, the installation of SVE
extraction wells and installation of subsurface piping may require limited use of personnel
protection equipment and air monitoring, which is standard in the industry. Soil erosion that
could potentially occur during construction (grading of surface material, construction of surface
water controls, limited small scale excavations, etc.) can be easily and effectively controlled by
standard engineering practices.
Operation of the SVE blower can potentially increase background noise levels at nearby residences.
However, background noise can be effectively controlled by enclosing the blower in a building, thus
muffling ambient noise. A diesel-powered electrical generator will not be required as permanent
electrical power will be supplied via power lines. Notably, Golder Associates was not notified of any
residential noise complaints when both a blower and unenclosed diesel generator were employed
during the Pilot Study.
Typical operating periods for SVE systems range between 2 and 5 years. During this time, the
system will require minimal operational and maintenance activities, including the periodic exchange
of carbon. Fencing installed during the site preparation phase will discourage trespassing during the
Alternative Soil Remedy implementation and operation.
The Alternative Soil Remedy is expected to be effective in the short-term. Potential short-term
impacts associated with construction and/or operation and maintenance of the Alternative Remedy
can be readily addressed. In fact, USEPA's Risk Reduction Engineering Laboratory in Cincinnati,
Ohio has stated that SVE is an in situ process that minimizes exposure to the public, personnel,
and the surrounding environment (Frank & Barkley, 1994).
5.6 Implementability
The Alternative Soil Remedy can be easily implemented. The installation of SVE wells and
associated piping and appurtenances is relatively straightforward. The SVE collection and treatment
systems utilize standard, off-the-shelf equipment that can readily be installed and operated. Agency
approvals for air emissions are expected to be easily obtained. By limiting the area and depth of
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excavation, the Alternative Remedy minimizes potential implementability issues associated with
larger scale excavations, including potential VOC emissions, truck traffic, etc.
Overall, no technical problems are envisioned which would adversely affect the schedule,
implementation or operation of the Alternative Soil Remedy. Services, materials and equipment
needed to design, install, operate and maintain the Alternative Soil Remedy are standard and widely
available.
5.7 Cost
Table 1 provides a breakdown of the cost estimate associated with the Alternative Soil Remedy and
includes total operation and maintenance costs over a 5-year period as well as administrative design
and contingency costs. The 5-year period is used solely for costing of the Alternative Soil Remedy.
The period of operation for SVE typically ranges between 2 to 5 years. The estimated construction
cost, O&M cost, and system decommissioning cost are $1.8 million, $1.6 million, and $100,000
respectively, resulting in the total estimated cost for the Alternative Soil Remedy of $3.5 million.
5.8 State and Community Acceptance
These criteria are used to evaluate technical and administrative issues or concerns that the
Commonwealth of Pennsylvania or local community may have regarding the Alternative Soil
Remedy. Neither the Commonwealth of Pennsylvania nor the local community are expected to
raise technical or administrative concerns that cannot be adequately addressed, particularly since
SVE is a presumptive remedy. The results of the SVE pilot study and the Alternative Soil
Remedy concepts were presented to both USEPA and the Pennsylvania Department of
Environmental Protection (PADEP) representatives during a meeting on March 5, 2002. PADEP
representatives did not voice opposition to consideration of the Alternative Soil Remedy. While
some public opposition may be realized as a result of the limited transport of impacted soil
through the community and possibly noise, these issues are minor when compared to the USEPA
ROD remedy, which would result in a far greater level of adverse community impacts. In
accordance with the USEPA Guidance for Conducting Remedial Investigations and Feasibility
Studies Under CERCLA (USEPA, 1988), these two criteria will be more fully addressed during
the final remedy selection process, i.e., public comment on a ROD modification.
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6.0 DETAILED COMPARISON OF THE ALTERNATIVE SOIL REMEDY TO THEUSEPA ROD REMEDY
The following provides a comparison of the proposed Alternative Soil Remedy to the USEPA ROD
remedy using the NCP criteria as the basis for comparison. This comparison demonstrates that not
only is the Alternative Soil Remedy consistent with the NCP (as discussed in Section 5.0), the
Alternative Soil Remedy is at least equal to and in several ways surpasses the USEPA ROD remedy
with respect to the NCP criteria.
One of the advantages of the Alternative Soil Remedy over the USEPA ROD remedy involves the
extent of VOC mass removal that can be accomplished by the Alternative Soil Remedy. Mass
removal of VOCs is a critical component of several of the NCP criteria and therefore needs to be
considered for both the Alternative Soil Remedy and the USEPA ROD remedy prior to the detailed
comparison to the NCP criteria.
6.1 Comparison of Potential VOC Mass Removal
As shown on Figure 6, the extent of VOC impacts ascertained during the Pre-Design Investigation
was simulated by EVS. The EVS simulation provides a 3-D representation of VOC impacts in
relation to the geologic zones and water table within the FDA/MA. As stated previously, VOC
impacts are concentrated in the lower portion of the upper clay and interbedded zone (highest
concentrations were detected roughly between 10 and 25 feet) and extend to approximately 30 to 35
feet bgs within the upper portion of the lower clay.
6.1.1 Alternative Soil Remedy
The Alternative Soil Remedy includes the installation of at least 35 SVE wells at 35-foot spacing
across the lateral extent of VOC-impacted areas of the FDA/MA. The wells would be screened (20
to 30 feet in length) within the upper clay and interbedded zone. An additional eleven wells will be
installed at 35-foot spacings and screened within the lower clay to extract deeper VOC impacts as
determined during the Pre-Design Investigation. The 35-foot well spacing provides for a 30%
overlap of SVE well influence.
The SVE system therefore will extract VOC mass from all impacted areas, including those at depth.
The SVE pilot study confirmed the effectiveness for achieving substantial mass removal rates, not in
only the more impacted areas of the interbedded zone, but from deeper VOC impacts as well.
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6.1.2 USEPA ROD Soil Remedy
As discussed in the USEPA Feasibility Study, the USEPA ROD contemplated excavation of soil
in the FDA/MA to a maximum depth of 15 feet bgs and from a much smaller lateral extent than
identified during the Pre-Design Investigation. Section 4.3.3.4, pg. 4-50 of the USEPA
Feasibility Study states that "The maximum depth of excavation was assumed to be 15 feet based
on a review of characterization data from the Remedial Investigation," and "Approximately 5,700
cubic yards of contaminated surface and subsurface soil would be excavated and shipped off-site
for treatment and disposed of in a landfill." Based on the results of the Pre-Design Investigation,
the amount of soil requiring excavation to meet the ROD SCS is approximately 92,000 tons, or
over twelve times the amount of soil considered by the USEPA ROD remedy. This excavation
would also require the removal of an additional approximately 70,000 tons of unimpacted soil to
achieve the necessary safe cutback angles. Furthermore, approximately 5 acres of forested land
beyond the excavation will need to be cleared to provide space for slope cutbacks, stockpiles, and
equipment staging/traffic.
Therefore, the extent of soil excavation contemplated in the USEPA ROD remedy would not
address a large majority of the VOC impacted soil exceeding the ROD SCS. In order to meet the
excavation performance standards stated in the USEPA ROD, the excavation would need to be
expanded over twelve times in size. Clearly, the technical challenges of such an expansion were
not considered in the USEPA ROD and the Alternative Soil Remedy can more effectively remove
VOC mass under the given conditions.
6.2 Threshold Requirements
6.2.1 Overall Protection of Human Health and the Environment
The only potential risks identified in the USEPA Risk Assessment and ROD associated with Site
related chemicals of concern are attributable to the potable use of groundwater impacted by VOCs at
the Site and ecological risks associated with direct contact to PCBs.
The Alternative Soil Remedy will provide greater overall protection of human health and the
environment as it will result in the removal of substantially more VOC impacted soil, particularly
from depths greater than 15 feet, i.e., the maximum excavation depth contemplated in the USEPA
ROD remedy and thus will result in a higher degree of groundwater protection, which is the principle
remedial action objective. Furthermore, if the USEPA ROD remedy were expanded to provide an
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equivalent degree of protection as the Alternative Soil Remedy, it would result in substantial
negative impacts to the short-term protectiveness of the remedy. Both remedies provide adequate
protection of ecological receptors. The Alternative Soil Remedy provides greater short-term
protectiveness, i.e., will result in much less adverse effects from VOC emissions, truck traffic, etc., as
discussed below.
6.2.2 Compliance with ARARs
Both alternatives contain an excavation component and both alternatives can comply with applicable
Federal and Pennsylvania Solid and Hazardous Waste Regulations. Further, the Alternative Soil
Remedy will be able to comply with air emission control requirements and other ARARs listed in
Section 5. 3.
There is some question as to whether or not the USEPA ROD remedy or even more so, an expanded
excavation remedy will be able to control VOC emissions from excavations, stockpiles, loading
activities, etc., to the extent necessary, to provide safe ambient air quality and protect nearby
residents and on-site workers. Impacted soil faces exposed during excavations and stockpiles and
soil handling, loading, and unloading activities will emit substantial quantities of VOCs to the
atmosphere. While there are potential means to control these VOC releases, at the scale of the
excavation required, it is questionable whether these controls will be effective. It is quite possible
that air quality and OSHA ARARs could not be complied with unless the excavation were conducted
within an enclosure; such an approach presents an entirely new set of technical challenges that are
not discussed in this Focused Feasibility Study.
In summary, it is anticipated that the Alternative Soil Remedy will comply with ARARs. While the
USEPA ROD shallow excavation might also be able to comply with ARARs, expanding the USEPA
ROD excavation remedy would raise concerns for being able to meet OSHA and USEPA/PADEP air
quality requirements.
6.3 Balancing Criteria
6.3.1 Long-Term Effectiveness and Permanence
Section 4.2 and 5.3 demonstrate that the Alternative Soil Remedy will provide a high level of
long-term effectiveness and permanence for remediating VOCs to the full depth and extent of
impacts and for achieving the principle remedial action objective, namely, the protection of
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groundwater, as well as the protection of potential ecological receptors. Unless substantially
expanded, the USEPA ROD Remedy will not be effective as considerable quantities of VOCs
would not be addressed. Expanding the excavation to address deeper VOCs that potentially could
impact groundwater quality presents additional challenges. Consequently, the Alternative Soil
Remedy provides a much higher degree of long-term effectiveness than the excavation remedy
contemplated in the USEPA ROD.
Both alternatives provide for the permanent removal of VOCs from the Site. However, the
Alternative Soil Remedy provides a higher degree of permanence than the USEPA ROD Remedy
because it permanently removes more VOCs from the subsurface.
Permanent removal of PCBs from the FDA/MA will be accomplished by both alternatives. Even
though the USEPA ROD remedy will remove a greater amount of PCBs, the removal of these
PCBs is not necessary to meet the ecological protection objectives of the USEPA ROD. Thus,
both alternatives provide an equivalent degree of effectiveness and permanence for meeting the
remedial action objectives associated with PCB remediation.
Altogether, the Alternative Soil Remedy provides a higher degree of long-term effectiveness and
permanence than the USEPA ROD remedy.
6.3.2 Reduction of Toxicity, Mobility or Volume
The Alternative Soil Remedy provides a high degree of reduction of toxicity and volume through
the removal and treatment of substantial quantities of VOCs. The USEPA ROD remedy will also
provide reduction of toxicity and volume as the excavated soil is removed from the Site and
treated using off-site thermal treatment. However, as discussed in preceding sections, the USEPA
ROD remedy will not address a large quantity of VOC impacted soil and thus will achieve less
reduction of toxicity and volume as compared to the Alternative Soil Remedy. Only if the
USEPA ROD remedy excavation was substantially widened and deepened, conditions that were
not contemplated in the USEPA ROD, would it achieve an equivalent reduction of toxicity and
volume.
While the total volume of PCB impacted soil is minimal, both remedies provide for the reduction
of a volume of PCBs necessary to satisfy the remedial action objective for the protection of
ecological receptors.
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')hi summary, the Alternative Soil Remedy provides a much greater reduction of toxicity and
volume of site-related impacts than the USEPA ROD remedy as it will remove a much larger
quantity of VOCs. Altogether, the Alternative Soil Remedy provides a greater degree of
reduction of toxicity, mobility, or volume necessary to meet the remedial action objectives.
6.3.3 Short-Term Effectiveness
Section 5.5 discusses the short-term effectiveness associated with the Alternative Soil Remedy.
In summary, while it was shown that the Alternative Soil Remedy had limited potential short-
term impact concerns, there are substantial potential short-term effectiveness concerns associated
with the expanded USEPA ROD remedy (which would be required to address VOC exceedances
of the ROD SCS). These concerns result from the need to control VOC/dust7odors during
excavation and soil handling activities, health and safety concerns for remediation workers, the
large volume of associated off-site truck traffic, and impacts to potential off-site receptors such as
the nearby residential developments and school.
A summary of some of the major short-term effectiveness concerns posed by the USEPA ROD
remedy and magnified by an expanded excavation remedy is presented below.
Potential Risks to Off-Site Residents and Workers
Prior to conducting a large-scale excavation of VOC impacted soil, a short-term health riskevaluation should be conducted to assess potential effects of VOC released from theexcavation and soil handling activities on workers and the general public via the inhalationexposure pathway. This assessment would allow a determination of whether the excavationneeds to be conducted within an enclosure, the degree of temporary covers needed, andlogistically how much active face and exposed soil surface can be exposed at any one time,thus reducing the efficiency and increasing the cost of the excavation remedy.
Site Worker Health and Safety
The VOC impacted soil excavation and handling activities required to implement the USEPAROD remedy will likely need to be performed in Level B personnel protection. Site workerswho are already performing high construction safety risk excavation activities will experienceeven higher risks as a result of having to operate heavy equipment and perform other work incumbersome Level B protection.
VOC Impacted Soil Transportation
• The expanded USEPA ROD remedy will require the off-site transportation and disposalof approximately 92,000 tons of VOC impacted soil. This large-scale transportationproject will involve approximately 3,000 truck round-trips through residentialneighborhoods and by public schools. Notably, a public school is located directly across
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'\Phoenixville Pike from the Site entrance. Besides creating a considerable disturbance tothe community via noise and dust, this type and magnitude of truck traffic will also:
• Increase the risk of further human exposures to VOCs via ambient/fugitive releases ofVOCs to the surrounding residential communities and along route to thetreatment/disposal facility, in addition to the potential for accidental spills;
• Increased traffic, physical damage to local roads, and heightened potential for automobileaccidents; and,
• Loss of VOCs to the atmosphere and potential worker safety risks due to loading andunloading operations.
Loss of Forested Areas
It is estimated that 5 acres of forested land surrounding the FDA/MA will result in order toprovide space for slope cutbacks, stockpiles, equipment staging, roadways, and constructionmanagement facilities necessary to complete the expanded excavation. Only minimal, if any,loss of the surrounding forested land would result from implementation of the AlternativeSoil Remedy.
As stated previously, an SVE system should be able to complete the remediation of the VOC
impacts in about 2 to 5 years. Most of the adverse short-term impacts (which are limited in
nature and are manageable) would occur during site preparation and system installation, which
can easily be completed in a single construction season. As stated by representatives from the
USEPA Risk Reduction Engineering Laboratory, SVE is a process that minimizes exposure to
site personnel, the public, and surrounding environment and, once installed, will result in minimal
disruptions. Only limited, if any, short-term effectiveness concerns will result from the
installation of the SVE wells and piping system.
In summary, the Alternative Soil Remedy is expected to result in considerably less adverse short-
term effects than the USEPA ROD remedy and all of these short-term effectiveness concerns are
manageable. Both the USEPA ROD remedy and the Alternative Soil Remedy can be constructed
in one construction season. Subsequently, the Alternative Soil Remedy is expected to require
operation for about 2 to 5 years to complete the remediation. During this period, there are no
anticipated significant short-term effects. Conversely, the substantial adverse short-term effects
associated with an expanded USEPA ROD remedy severely questions the feasibility and
appropriateness of its use. Altogether, the Alternative Soil Remedy will result in much less
adverse short-term effectiveness concerns than the USEPA ROD remedy.
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6.3.4 Implementability
The Alternative Soil Remedy is expected to be much more easily implemented than the USEPA
ROD remedy, particularly if the USEPA ROD remedy were to be expanded to include a laterally
broader and deeper excavation. The pilot study demonstrated that not only is SVE an effective
method for removing VOCs from FDA/MA soil, but SVE wells can easily be installed in the
FDA/MA. In addition, the equipment and services needed to implement the SVE system are
routine and widely available. The USEPA presumptive remedy guidance for SVE (USEPA,
1993) concurs with this assessment and concludes:
• There are few administrative difficulties and the technology is readily available frommany sources;
• SVE has been used successfully at numerous Superfund sites to address VOC impacts;and,
• Installing and operating SVE wells requires fewer engineering controls than excavation.
The limited shallow soil excavation for PCBs associated with the Alternative Soil Remedy, is
readily implementable. Conversely, the excavation needed to address the currently defined limits
of VOC impacts is not readily implementable. Therefore, the USEPA ROD remedy is expected
to be extremely difficult to implement, particularly if it were to be expanded to a laterally broader
and deeper excavation. While the equipment and services required to implement routine
excavation/disposal operations are conventional and widely available, for the numerous reasons
discussed above, which included controlling VOC emissions, controlling odors and dust,
managing high volume of truck traffic, and minimizing community disturbance will make an
expanded USEPA ROD remedy extremely difficult to implement.
6.3.5 Cost
Revised USEPA ROD Remedy Cost Estimate
New and significant technical information obtained during the Pre-Design Investigation
necessitates revision of the USEPA ROD remedy cost estimate. The revised cost of the USEPA
ROD remedy for FDA/MA soils has substantially increased from approximately $7.0 million (as
stated in the USEPA ROD) to $17.8 million as shown in Table 2, primarily as a result of the
findings of the additional delineation work performed during the Pre-Design Investigation. The
major assumptions utilized in the revised USEPA ROD remedy cost estimate include:
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The cost estimate assumes expansion of the USEPA ROD remedy to address the fullextent of VOC impacts. Based on the lateral and vertical extent of impacts determinedduring the Pre-Design Investigation as shown on Figure 5, and considering the typicalconstruction practice of "squaring off," the volume of soil exceeding the ROD SCS isestimated to be 92,000 tons, or over 12 times the volume estimated in the USEPAFeasibility Study (7,400 tons) and considered in the USEPA ROD. This volume does notinclude the volume of "clean" soil surrounding the excavation that would need to beremoved to provide safe slope cutbacks;
Approximately 50 percent of the excavated soil is assumed to exceed USEPA's LandDisposal Restrictions and thus require off-site thermal treatment prior to disposal at aSubtitle C Landfill. The USEPA Feasibility Study and ROD assumed that all excavatedsoil would require treatment prior to land disposal; and,
The transportation and disposal rates USEPA utilized in the USEPA ROD remedy costestimate were substantially reduced based on current remediation contractor estimates.
Notably, the estimated revised cost of the USEPA ROD remedy did not increase proportionally
with the twelve-fold increase in soil volumes. This disproportionate revision is a result of the
revised cost estimate utilizing lower unit costs for transportation and disposal based on recent
contractor updates and assuming less soil will require off-site treatment prior to disposal.
Alternative Soil Remedy Cost Estimate
The estimated cost for the Alternative Soil Remedy is about $3.5 million (see Section 5.8 and
Table 1) assuming a 5-year period for SVE operation.
Comparison of Remedial Cost
As discussed in the USEPA document "The Role of Cost in the Superfund Remedy Selection
Process," (USEPA, 1996):
"Cost is a critical factor in the process of identifying a preferred remedy. In fact,CERCLA and the NCP require that every remedy selected must be costeffective."
The document continues to discuss that "A remedial alternative is cost-effective if its costs are
proportional to its overall effectiveness." "Effectiveness" is further defined by the evaluation of
three of the five balancing criteria: long-term effectiveness, reduction in toxicity, mobility and
volume through treatment, and short-term effectiveness. In addition, the preamble to the NCP
further provides that where two alternatives have similar levels of effectiveness and
implementability but their costs vary significantly, cost can be used to eliminate the more costly
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alternative (55 Fed. Register §715, March 8, 1990). Clearly, the Alternative Soil Remedy is the
most cost-effective remedial alternative.
On the basis of the evidence presented in this Focused Feasibility Study, the Alternative Soil
Remedy is concluded to be more protective, effective, and implementable than the USEPA ROD
remedy, particularly, considering some of the potential short-term concerns associated with an
expanded excavation program in the FDA/MA. Therefore, given the large cost difference
between the two alternatives, the Alternative Soil Remedy is clearly the more cost-effective
alternative. Accordingly, the Alternative Soil Remedy is the preferable choice for remediation of
the VOC and PCB impacted soil in the FDA/MA.
6.4 State and Community Acceptance
The state and community acceptance criteria are used to evaluate the technical and administrative
issues and concerns the Commonwealth of Pennsylvania and the local community may have
regarding the Alternative Soil Remedy. Neither the Commonwealth of Pennsylvania nor the local
community is expected to raise technical or administrative concerns regarding the Alternative
Soil Remedy that cannot be adequately addressed. The results of the SVE pilot study and the
Alternative Soil Remedy concepts were presented to both USEPA and PADEP representatives
during a meeting on March 5, 2002. While some public opposition may be realized as a result of
the limited transport of impacted soil through the community and possibly noise, these issues are
expected to be easily overcome, especially given the choice between the Alternative Soil Remedy
and the USEPA ROD remedy, which would result in a far greater level of adverse community
impacts. In accordance with the USEPA Guidance for Conducting Remedial Investigations and
Feasibility Studies Under CERCLA (USEPA, 1988), these two criteria will be more fully
addressed during the final remedy selection process, i.e., public comment on a ROD modification.
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7.0 SUMMARY
As previously stated, the Alternative Soil Remedy provides a superior level of long-term
protection for reducing future VOC impacts to groundwater and performs at least as well and
surpasses the USEPA ROD remedy in many respects considering all of the NCP threshold and
balancing criteria. The Alternative Soil Remedy will result in less adverse short-term effects and
will be easier to implement at a much lower cost. Therefore, based on the USEPA definition of
cost-effectiveness, and the NCP, the Alternative Soil Remedy is a much more cost-effective
alternative than the USEPA ROD remedy for FDA/MA soils, even considering expansion of the
USEPA ROD remedy excavation. Consequently, Golder Associates suggests that the Alternative
Soil Remedy is preferable in accordance with the NCP, the statutory requirements of CERCLA,
and the Superfund Reforms. All of the factors presented in this document, and as summarized
above, provide a strong administrative and technical basis to allow USEPA to consider the
Alternative Soil Remedy presented herein and to modify the USEPA ROD remedy for FDA/MA
soils accordingly.
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8.0 REFERENCES
CH2MHill, 1997. Final Feasibility Study Report, June 1997.
Frank, V., and N. Barkley, 1994. Remediation of Low Permeability Subsurface Formations byFracturing Enhancement of Soil Vapor Extraction, USEPA, Risk Reduction Laboratory,Cincinnati, Ohio, April 1994.
Golder Associates Inc., 2000. Remedial Design Work Plan, May 2000.
Golder Associates Inc., 2001 a. Pre-Design Investigation Data Report Summary Report. July 2001.
Golder Associates Inc., 2001b. Soil Vapor Extraction Pilot Study Work Plan, September 2001.
Golder Associates Inc., 2002a. SVE Pilot Study Report, April 2002.
Golder Associates Inc., 2002b. Pre-Design Investigation Report, April 2002.
High Vacuum System Accelerates Remediation of Low Permeability Soils and Aquifers, TheHazardous Waste Consultant, July/August 1995
PADEP, 1995. Pennsylvania Land Recycling and Remediation Standards Act, July 1995.
PADEP 1997. Administration of the Land Recycling Program (Title 25, Chapter 250), August 1997.
Sirtler, S.P. and M.D. Slavin, 1994. Use of High Vacuum Technology to Remediate Soils andGroundwater in Low-Permeability Formations, AAPG Bulletin, Volume 78, No. 8, August1994.
USEPA, 1993. Presumptive Remedy, Site Characterization and Technology Selection for CERCLASites with Volatile Organic Compounds in Soil, OSWER Directive 9355.0-48FS, September1993.
USEPA, 1995. Engineering and Design: Soil Vapor Extraction and Bioventing, Engineer Manual1110-1 -4001, November 1995.
USEPA, 1995. Administrative Reforms to Superfund, October 1995.
USEPA 1996. The Role of Cost in the Superfund Remedy Selection Process, EPA540/F-96/018,September 1996.
USEPA, Superfund Reforms: Updating Remedy Decisions, OSWER Directive 9200.0-22.
USEPA, 1997a. Presumptive Remedy: Supplemental Bulletin Multi-Phase Extraction Technologyfor VOCs in Soil and Groundwater, OSWER Directive 9355.0-68FS, April 1997.
USEPA, 1997b. Record of Decision for the Malvern TCE Superfund Site, November 1997.
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May 2002Table 1
Alternative Soil Remedy Cost EstimateFocused Feasibility Study
Malvem TCE Superfund Site
003-6000
Lint .
'• -Vf*VSVE 01 01SVE 01.02SVE 01.03SVE 01.04SVE 01.05
SVE 02.01SVE 02.02SVE 02.03SVE 02.04SVE 02.05
SVE 03.01SVE 03.02SVE 03.03SVE 03.04SVE 03.05
SVE 04.01SVE 04.02SVE 04.03SVE 04.04SVE 04.05SVE 04.06SVE 04.07SVE 04.08SVE 04.09SVE 04.09
SVE 05.01SVE 05.02SVE 05.03SVE 05.04SVE 05.05SVE 05.06SVE 05.07SVE 05.08SVE 05.09SVE 05.10SVE 05.11SVE 05.12SVE 05.13SVE 05.14
SVE 06.01SVE 06.02SVE 06.03SVE 06.04SVE 06.05SVE 06.06
SVE 07.01SVE 07.02SVE 07.03SVE 07.04
SVE 08.01SVE 08.02
Construction PhaseItem Description
Site PreparationClearing & GrubbingAccess Road - DaylightingAccess Road • DGA SurfaceGas Pipeline CrossingFence Removal
SUBTOTAL
Site ManagementMobilizationOffice Trailer CompoundUtilitiesGeneral Conditions ( Contractor Superintendent. Supplies, and Health and Safety)Project Surveying
SUBTOTAL
PCB soil Removal and SoH CapPCB ExcavationBackfill for Soil CoverCover Grading and CompactionImport and Place Aggregate Backfill in ExcavationsSoil Sampling
SUBTOTAL
SVE Wells and TrenchingShallow SVE WellsDeep SVE WellsVapor Monitoring ProbesWell VaultsControl VaultsUnderground PipingTrench Excavation, Bedding/, and BackfillImport Additional BackfillControl Valving. Flow Sensors. Sampling PortsAdditional Borings. Soil Sampling, and SVE Well Installation
SUBTOTAL
SVE SystemFoundation and SlabPre-Engmeered BuildingBlower UnitsHeat ExchangerBuilding PipingVapor Phase Carbon Vessels Assembly (8.000 Lb)Initial Carbon (16, 000 Lbs)Carbon Vessel Valve Tree. Piping and SlackCondensate Sump and pump (secondary containment)Building Eleclncal (Class 1. Division II)Instrumentation and ControlCondensate TankUtilities! 3 Phase 4160 Volt Service, plus telephone)Perimeter Fence (Temporary)
SUBTOTAL
DisposalPCB Soil Waste CharaclenzationPCB Soil - Loadout. Transport and Disposal (Assume Treatment required)PCB Soil - Loadout. Transport and Disposal (Assume Landfill)Soil Cuttings.Liquids DisposalTrenching Spoils
SUBTOTAL
System StartupLabor /EquipmentLaboratory Analytical (TO-14 Modified)OversightVendor Inspection and Certification
SUBTOTAL
Site RestorationTopsoilSeeding
SUBTOTAL
Subtotal
20% Contingency
TOTAL CONSTRUCTION PHASE TOTAL
Quant
1.00
1 004667350700
16661
200020001667
7501 00
1225
6052404615
3500250017546
1.00
1600
6002112
16000111111
1000
2010001000
801200
175
10040605
1546
125
Units
AcreLSSYSYLF
LSMonthsMonthsMonths
LS
TonsTonsSY
TonsLS
VLFVLFVLFEAEALFLF
TonEALS
SFSFEAEALS
EA
LBSEALSEALF
EALSLF
AnalyticalTonTonTon
GallonsTon
MrsEAMrsEA
SFMSF
Unit Cost
$15.000.00$8.000.00
$11.10$75.00$450
$25,000.00$2.500.00$2.000.00$30.000.00$5,00000
$11.65$15.50$3.24$2800
$5,00000
$95.00$95.00$55.00$250.00
$2,50000$7.75$2400$860
$21500$20,00000
$4.50$60.00
$30.00000$15,000.00$20.000.00$15.000.00
$1.39$27.000.00$8.50000$25,000.00$18.000.00$5.000.00$40.00000
$22.50
$500.00$205.00$48.00
$205.00$0.85
$205.00
$75.00$20000$100.00$40000
$1550$50.00
Cost
15.0008.000
51.80026.250
3.150
$ 25.000$ 15.000$ 12.000$ 180,000$ 5.000
23,30931.000
5.40021.0005.000
116.37557.47513.20011.50037.50027.12560,000
1,5059,890
$ 20.000
$ 7.20036.00060.00015.00020.00030.00022.18427.0008.500
25,00018.0005.000
40.00022,500
$ 10.000$ 205.000$ 48.000$ 16,400$ 1.020$ 35.875
$ 7,500$ 8,000$ 6.000$ 2,000
$ 23.968$ 6.250
Subtotal Cost
~-~- - : V
$ 104.200
$ 237,000
$ 85.709
$ 354.570
$ 336.384
$ 316.295
$ 23.500
$ 30.218
$ 1.487.875
$ 297.575
$ 1 ,785.450
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May 2002Tablet
Alternative Soil Remedy Cost EstimateFocused Feasibility Study
Malvern TCE Superfund Site
003-6000
LineRsforoncv
SVE 0901
SVE 09.02SVE 09.03SVE 0904SVE 0905SVE 09.06SVE 09.07
SVE 10.01SVE 10.02SVE 10.03SVE 10.04SVE 10.05SVE 10.06
SVE 11.01SVE 11.02
SVE 12.01SVE 12.02SVE 1203SVE 12.04
SVE 13.01SVE 13.02SVE 13.03SVE 13.04SVE 13.05
SVE 14.01SVE 1402
SVE 1403
SVE 1404
SVE 14.05SVE 14.06SVE 14.07
Operational PhaseItem Description
Performance MonitoringWeekly Site Visits (1 months)Monthly Site Visits (7 - 60 Months)Laboratory Analytical (TO-14 Modified)ReportingSoil Confirmation Sampling BoringSoil AnalyticalSoil Confirmation Sampling Reporting
SUBTOTAL
Preventative MaintenanceOrf 4 Filler ChangesBell ReplacementInstrumentation CalibrationBlower OverhaulBuildingHeat Exchanger Motor Replacement
SUBTOTAL
UtilitiesElectric (90.000 kwh)Data / Telephone
SUBTOTAL
Site MaintenanceLandscaping cuttingAccess Road RepairSnow RemovalFence
SUBTOTAL
Carbon UsageVapor Phase Carbon Supply and DisposalCarbon Hazardous Profile ApprovalCarbon Change oul LaborCondensate DisposalCondensate Wasle Slream Approval
SUBTOTAL
System RevisionsField and Laboratory Analysis o( SVE syslem performanceAdditional SVE WellsUnderground Piping RevisionsTrench Excavation. Bedding/, and BackfillControl Valving. Flow Sensors. Sampling PortsSoil Cuttings DisposalPiping Modification
SUBTOTAL
Subtotal
20% ContingencyOPERATIONAL PHASE TOTAL
Quant
4.00
59001285
25251
6065255
6060
205155
10OOOO1
131800
1
15251500
1500
15331
Unto
EAEAEA
AnnualSamplesSamples
LS
MlhEventAnnualEvent
AnnualAnnual
MonthsMonths
QuarterlyAnnualMonthAnnual
LBSLS
EventsGallon
LS
LSVLFLFLFEA
TonsLS
Unit Cost
$2.80000$2.80000$200.00
$22.000.00$1,100.00$16500
$12.00000
$12500$1.00000$5.00000$8.000.00$2.60000$2.500.00
$8.250.00$8333
$50000$750.00$200.00
S1. 500.00
$1.39$4.500.00$1.100.00
$4.00$4.50000
$50.000.00$95.00$6.50$2400
$215.00$208.00
$4.500.00
Cost
11.200165.20025.600
110.00027.500
4.125$ 12.000
$ 7.500$ 6.000$ 25.000$ 16.000$ 13,000$ 12,500
$ 495.000$ 5.000
$ 10.000$ 3.750$ 3.000$ 7.500
$ 138.700$ 4.500$ 14.300$ 7.200$ 4.500V
$ 50.000$ 49,875$ 9.750$ 36.000$ 3.225$ 6.825$ 4.500
Subtotal Cost
$ 355,625
$ 80.000
$ 500.000
$ 24,250
$ 169.200
$ 160,175
$ 1.289.250$ 257.850
$ 1,547.099
G.W03-«XMFFS\DRAFT ROD ConKIUCtioo Estimate xBTABLE 1 Colder Associates A R 0 0 0 7 0 0 Page 2 of 3
IIIIIIIIIIIIIIIIIII
May 2002Table 1
Alternative Soil Remedy Cost EstimateFocused Feasibility Study
Malvern TCE Superfund Site
003-6000
System DecommissioningLine
SVE 15.01SVE 15.02SVE 15.03SVE 15.04
SVE 16.01SVE 16.02SVE 16.03SVE 16.04
SVE 17.01SVE 17.02
SVE 18.01SVE 1802SVE 18.03SVE 18.04
Item Description
BiddingRemoval of EquipmentBuilding DemolitionConcrete Foundation RemovalSupply and Place Backfill
SUBTOTAL
SVE Wells and Underground PipingExcavation and Backfill TrenchesAbandon Wells and Monitoring Vapor ProbesGrade SiteSeeding
SUBTOTAL
UtilitiesElectricData / Telephone
SUBTOTAL
Site RestorationPerimeter Fence RemovalAccess Road Removal © Pipe CrossingTopsoilSeeding
SUBTOTAL
Quant
111
56
1667
26056950
63
11
10001
80011
Subtotal
20% Contingency
SYSTEM DECOMMISSIONING PHASE TOTAL
Units
LSLSLS
Ton
CYLFSY
MSF
LSLS
LFLSSY
MSF
Unit Cost
$10.000.00$8,000.00$4.50000
$15.50
$4.50$10.00$0.60$50.00
$3.000.00$1.000.00
$4.50$2.500.00
$1.55$50.00
Cost
$ 10,000$ 8.000$ 4.500$ 863
$ 7.500$ 26,050$ 4,170$ 3,125
$ 3,000$ 1.000
$ 4.500$ 2.500$ 1.238$ 550
Subtotal Cost
$ 23.363
$ 40.845
$ 4.000
$ 8.788
$ 76.996
$ 15.399
$ 92.395
SUMMARY OF ESTIMATED SOIL VAPOR EXTRACTION COSTS
PhaseConstruction Phase
Operational PhaseSystem Decommissioning
SVE TOTAL
Estimated Cost
$ 1,487,875$ 1,289,250$ 76,996
$ 2,854.409
Contingency20%
$ 297.575$ 257.850$ 15,399
$ 568.882
Total tsnmMMCost
$ 1.785,450$ 1.547.099$ 92.395
$ 3,423,291
G:\003-600WFFS\DRAFT ROD Constructor) Eswn*e >lsTABLE 1 GokJer Associates A R 0 0 0 7 0 I Page 3 0(3
IIIIIIIIIIIIIIIIIII
May 2002Table 2
Revised Cost Estimate for USEPA ROD FDA/MA Soil RemedyExpanded to Address the Extent of VOCs Identified During the Pre-Design Investigation
Focused Feasibility StudyMalvern TCE Superfund Site
003-6000
LineReference
EXC 01.01EXC 01.02EXC 01.03EXC 01.04EXC 01.05EXC 01.06EXC 01.07EXC 01.08
EXC 02.01EXC 02.02EXC 02.03EXC 02.04EXC 02.05EXC 02.06
EXC 03.01EXC 03.02EXC 03.03EXC 03.04EXC 03.05EXC 03.06
EXC 04.01EXC 04.02EXC 04.03EXC 04.04EXC 04.05
EXC 05.01EXC 05.02EXC 05.03EXC 05.04EXC 05.05
Item Description•-•
'• ; Site PreparationClearing & GrubbingAccess Road - ClearingAccess Road - Earthwork / Drainage SwaleAccess Road - CulvertAccess Road - DGA SurfaceGas Pipeline CrossingStrip Topsoil in Support AreaFence Removal
SUBTOTAL
MobilizationMobilizationOffice Trailer CompoundUtilities) Single Phase, plus monthly cost)General Conditions (Contractor Supervision, Supplies, and Health and Safety)Project SurveyingPerimeter Air Monitoring
SUBTOTAL
Excavation and BackfillPrepare Soil Staging AreaSoil ExcavationVapor Suppressant (Foam)Place and Compact BackfillImport Clean FillProvide and Place Topsoil
SUBTOTAL
Disposal (loadout and Transportation)Soil Classification AnalyticalLandfill Disposal ( PCE <5.6 ppm; TCE < 54 ppm)Soil Treatment and Landfill DisposalPCB Soils and VOC - Soil Treatment and Landfill DisposalManagement of wastes
SUBTOTAL
Site RestorationRemove Access Road (including Pipeline Crossing)Remove Laydown AreaTopsoil (Place Stockpile)SeedingTree Replacement
SUBTOTAL
Quant
52.0
466790
150009006667700
1151
1518
2160000800069000910008820
20046000460002000
1
16667780028380
Subtotal20% Contingency
Remedial Action Total
Units
AcreAcreSYLFSYSYSYLF
LSMonths
LSMonths
LSMonths
AcreTon
GallonTonTonTon
AnalyticalTonTonTonLS
LSSYSY
MSFEA
Unit Cost
$15.000.00$15,000.00
$1.75$60.00$11.10$100.00$1.60$4.50
$90,000.00$4.000.00$45.000.00$40,000.00$12,000.00$11,000.00
$12,000.00$1.75$3.50$1 15$8.60
$15.50
$500.00$50.00$205.00$205.00
$20,000.00
$7,500.00$1.50$3.12$50.00$85.00
Cost
$ 75,000$ 30,223$ 8,167$ 5,400$ 166,505$ 90,000$ 10.684$ 3,150
$ 90.000$ 60.000$ 45.000$ 600,000$ 12,000$ 88,000
$ 24,000$ 280,000$ 28.000$ 79.350$ 782,600$ 136,703
$ 100,000$2.300.000$9,430,000$ 410,000$ 20,000
$ 7,500$ 10,000$ 24,336$ 14.157$ 6.800
SubtotalCost
$ 389.128
$ 895,000
$ 1,193,950
$12,260,000
$ 62,793
$14,800,871$ 2,970,174
$17,771,045
G:\003-6000\FFS\DFtAFT ROD Construction Estimate.xlsrev est Golder Associates
A R 0 0 0 7 0 2Page 1 of 1
>fc;-V
1.) BASE MAP TAKEN FROM U.S.G.S. 15 MINUTEQUADRANGLE OF MALVERN, P.A..
PENNSYLVANIA
QUADRANGLE LOCATION
2000
.—SCALE
CO200QCD
r—FEET CD
Philadelphia USA
FILE No. 0036000H001PROJECT Ho. 003-6000 •** 0
SCAl£ AS SHOWN
DATE 05/16/02DESGN AMCADO AM
CHECK DSLREVIEW RSW
TITLE
SITE LOCATION MAPCDcc«=c
MALVERN TCE SUPERFUND SITEFIGURE
Urit-1 Upper CloyUnit-2 Interbedded zoneUnit-3 Lower Ctay
JOB No.: 003-6QOOOR BY: DSLCHKBY: DSL
REV BY: RSW
SCALE: AS SHOWN
DATE: 5/17/02FILE No.: fence_Dlag.doc
DIRECTORY: 003-6000VFFS
Golder Associates
GENERALIZED FENCE DIAGRAM
MALVERN PDI REPORT
CDCDCDor•or
FIGURE:
Legendfa I Interpreted Zone of Total Exceedances of the ROD Soil Clean-up Standards.• Sample location
Notes• Interpreted Zone of Exceedances generated using EVS™ (Environmental
Visualization System).
JOB No.:
DRBY:
CHKBY:
REV BY:
003-6000
ACK
ACK
THR
SCALE: AS SHOWNDATE: 5/17/02FILE No.: Soil Data EVS 2.doc
DIRECTORY: /(:DA SVE/PTReport
Interpreted Zones of VOC Exceedancesof ROD SCS - FDA/MA Area
Gold cr Associates Malvern SVE Pilot Study j^ff ft* fiQ 7 05
Shallow/IntermediateWells
Deep Wells
ShallowWells
Deep Wells
JOB No.: 003-6000DRBY ACK
CHK BY: ACK
REV BY
SCALE
DATE:
FILE No
AS SHOWN
5/17/02
Concept layout.docDIRECTORY 003-6000/FFS
Conceptual Layout of SVEfor FDA/MA
Golder Associates Malvern Focused Feasibility Study a { > ft H ft 7 Q £FIGURE: