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APPENDIX A
RI/FS CORRESPONDENCE
GERAGHTY & MILLER, INC.
Corporation
Hillcrcst Towers Donald S. Bunin-" r- •••.-• ?.-.- ' •=•::•:• 71 3 v.,.n.. .....
..... ..i. ino:::n..". »>r.u> •oij / en,,-:?-.,.,.-.", j- !;••5i3 5SI -4>C
August 1, 1991
Mr. Abraham FerdasDirector, Superfund OfficeU.S. EPA - Region III841 Chestnut BuildingPhiladelphia, PA 19107
Re: Dublin TCE NPL Site Administrative Order on Consentfor Remedial Investigation/Feasibility Study
Dear Mr. Ferdas:
This is to confirm the understandings reached between SequaCorporation ("Sequa") and the United States EnvironmentalProtection Agency ("EPA") at the meetings held betweenrepresentatives of EPA and Sequa on July 11, 1991 and July 31,1991, regarding the above captioned Order ("ACO") and theRemedial Investigation/Feasibility Study ("RI/FS") for theDublin TCE NPL Site.
1. EPA has determined that the Work Plan ("DER Work Plan")attached to and incorporated into the Consent Order andAgreement executed between Sequa and the Commonwealth ofPennsylvania Department of Environmental Resources ("COA") isnot inconsistent with the National Contingency Plan ("NCP") , 40C.F.R. Part 300, although it does not fully comply with allrequirements of the NCP.
i
2. Sequa will develop the Work Plan required by the ACO toprovide for an interim or phased RI/FS.
3. As the first phase of the RI/FS, Sequa will performthose tasks required by the DER Work Plan in accordance with theNCP and will provide EPA with a field sampling plan, health andsafety plan, and quality assurance project plan.
4. The EPA agrees that the Report which is required byTask 8 of the DER Work Plan for the groundwater RI phase of theRI/FS will be submitted by Sequa as the interim RI and agrees toexpedite review of this Report.
Sequa Corporation
Mr. Abraham FerdasAugust 1, .M991Page two
5. The EPA agrees that the Recommended Remedial Actionwhich is required, pursuant to Paragraph 3, p. 4 of the COA willbe submitted by Sequa as the interim FS for the groundwater FSphase of the RI/FS. and agrees to expedite review of theRecommended Remedial Action.
6. EPA will utilize the interim RI and interim FS indeveloping the interim Record of Decision for the groundwater.
7. Sequa will continue on with all other phases of theRI/FS and shall deliver a final RI and final FS in accordancewith the Work Plan required by the ACO.
8 . EPA will meet with representatives of Sequa to discusstheir comments, if any, to EPA's Risk Assessment.
It is our understanding that EPA will provide Sequa aletter acknowledging its agreement with the content of thisletter: Since both Mr. Galiszewski and I will be out of thecountry on business the week of. August 5th, if you have anyquestions or comments regarding this letter, please contact JohnP. Judge. Upon receipt of the EPA's acknowledgement letter,Sequa will deliver to EPA the executed ACO.
We look forward to working cooperatively on this projectwith the EPA.
Very truly yours,
- - n- -vs --v_
DONALD S. BUNIN
bet/91.101
cc: Andrew Duchovnay, Esq.Charles GaliszewskiJohn P. Judge, Esq.Judah I. Labovitz, Esq.Jeffrey Teitel, Esq.Dianne Walker, U.S. EPA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION Hi
841 Chestnut BuildingPhiladelphia, Pennsylvania 19107
Mr. Donald BuninSequa CorporationHillcrest Towers .7162 Reading Road- Suite 713 AuS 6 ~ |99lCincinnati, Ohio 45237
Re: Dublin TCE Superfund Site
Dear Mr. Bunin:
The Environmental Protection Agency (EPA) is in receipt ofyour letter dated August 1, 1991. EPA acknowledges SequaCorporation's summary of the discussions conducted in themeetings held between EPA and Sequa on July 11, 1991 and July 31,1991.
If you have any questions concerning the Dublin TCE Site,please do not hesitate to contact me at (215) 597-8240.
Sincerely,
Jianne J. WalkerRemedial Project ManagerSE PA Remedial Section
cc: John P. Judge, Cohen, ShapiroCharle Galiszewski, Sequa CorporationAbraham Ferdas, EPAAndrew Duchovnay, EPA
AR3G0595
UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION ni
841 Chestnut BuflcfingPhiladelphia, Pennsylvania 19107
4UG15I99JVIA OVERNIGHT DELIVERY
Mr. Donald Bunin, Vice PresidentSequa CorporationHillcrest Towers71S2 Reading Road-Suits 713Cincinnati, Ohio 45237
Dear Mr. Bunin:
Please find enclosed a fully executed true and correct copyof the Consent Order and Agreement (COA) for the RemedialInvestigation/ Feasibility Study (RI/FS) for the Dublin TCESuperfund Site. The effective date of this order is August.22,1991. Notification of the identity and qualifications of SequaCorporation's primary contractor is due to the EnvironmentalProtection Agency (SPA) on September 1, 1391.
• EPA looks forward to working with Sequa Corporation incompleting this RI/FS in a timely and efficient manner.
If you have any questions concerning this COA, pleasecontact Andrew Ducanovay, Escr. / at (215) 597-3252 or me at(215) 597-8240.
Sinoerely,
Dianne J. WalxerRemedial Project ManagerSE PA Remedial Section
cc: John P. Judge, Esq., Cohen, Shapiro /Jeffrey H. Teitel, Esq., Sequa Corporation-Charles Galiszewski, Sequa Corporation _•Andrew Duchovnay, Esq., EPA
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Setjua Corporation
Certified MailReturn Receipt RequestedCertificate No.: P-609 413 817
August 30, 1991
Ms. Dianne Walker (3HW21)Environmental EngineerU.S. EPA - Region IIIHazardous Waste Management Division.841 Chestnut BuildingPhiladelphia, PA 19107
Andrew Duchovnay, Esq.U.S. EPA - Region III841 Chester BuildingPhiladelphia, PA 19107
Re: Dublin TCE NPL Site
Dear Ms. Walker and Mr. Duchovnay:
In accordance with the requirements of Paragraph VTII B. 1 ofthe Consent Order and Agreement (COA) in the matter of DublinTCE Site, Sequa herewith provides notice that Geraghty & Miller,Inc. (G & M) has bean selected as Primary Contractor. G & M'squalifications and the qualifications of their Senior ProjectAdvisor and Project Manager assigned to this matter areincluded.
A copy of the transmittal of the COA to G & M in accordance withParagraph VI D is enclosed.
Very truly yours,
Charles GalaszewskiDirector Engineering Project ManagementProject Manager
cc: D.S. Bunin, SequaJ.H. Teitel, SequaJ.P. Judge, CSPSCJ.I. Labovitz, CSPSCBarbara Dolce, G & MFile
AR3U0597
\
UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION III
. 841 Chestnut BuildingPhiladelphia, Pennsylvania 19107
CERTIFIED MAIL QI-Q rRZTU7LN" RECEIPT REQUESTED Otr J
Mr. Charles GaliszewskiDirector, Engineering Project ManagesentSequa CorporationThree University PlazaEackansack, New Jersey 07601
Re: Dublin TCE Superfund Site
Dear Mr. Galiszewski:
Pursuant to Section VIII, B. 4 of the Dublin TCE Site RI/FSConsent Order and Agreement, the United States EnvironmentalProtection Agency (EPA) accepts Garaghty & Killer as theRespondents' primary contractor for the work to be conductedunder this Consent Order and Agreaaant.
Please note 'that all primary contractor and subcontractorpersonnel must have the 40-hour OSEA Health and Safety trainingand the required refresher courses prior to conducting work atthe Dublin TCS Superfund Site (Site) .
Upon your receipt of this acceptance, Respondents will havs60 days to forward the RI/FS Work Plan to EPA,
Also, by this letter, EPA is requesting that a copy of ar.yfuture correspondence sent to EPA by Saqua Corporation orGaraghty & Miller regarding the Site be forwarded to thefollowing project officers from the Pennsylvania Department ofEnvironmental Resources (PADER):
Thomas Hartnett, Bureau of Solid Waste ManagementSteve O'Neill, Bureau of Water QualityPennsylvania Department of Environmental ResourcesLee Park, Suite 6010555 North LaneConshohocken, Pennsylvania 19428
If you have any questions, please call me at (215) 597-8240 or Andrew Duchovnay at (215)597-3252.r\
Sincerely,
m ¥ ML&I .D'iarme J. Wa/LkerRemedial Project Manager
cc: Andrew Duchovnay, Esquire, EPAD. S. Bunin, SequaJ. K. Teitel, SequaJ. P. Judge, CSPSCJ. I. Labovitz, CSPSCBarbara Dolce, G & MThomas Kartnett, FADES,Steve O'Neill, PADE3.
AR300599
Sequa Corporation
Via Federal Express
November 7, 1991
*Ms. Dianne Walker Thomas HartnettEnvironmental Engineer Bureau of Solid Waste Mgmt.U.S. EPA - Region III PA Department of Envir. Res.Hazardous Waste Mgmt. Lee Park, Suite 6010841 Chestnut Building 555 North LanePhiladelphia, PA 19107 Conshohocken, PA 19428
Andrew Duchovnay, Esquire Steve O'NeillU.S. EPA - Region III Bureau of Water Quality841 Chestnut Building PA Department of Envir. Res.Philadelphia, PA 19107 Lee Park, Suite 6010
555 North LaneConshohocken, PA 19428
Dear Ms. Walker, Messrs. Duchovnay, Hartnett and O'Neill:
Enclosed is the RI/FS Workplan, Field Sampling Plan, Health & SafetyPlan and Quality Assurance Project Plan for the Boro of Dublin TCESite, in accordance with the requirements of Section VIII(C) of theAdministrative Order On Consent dated August 15, 1991.
Also enclosed are the following:
Certification required under Section VIII(Q) (3) of the Order.
Designation of C. Galiszewski as the authorized representative inaccordance with Section VIII(Q) (1) of the Order.
Transmittal of the RI/FS Documents by Geraghty & Miller to Sequadated November 6, 1991.
Please note the eight additional copies will be delivered to the U.S.EPA on Tuesday, November 12, 1991
Charles R. GaliszewskiDirector 'v-Project Management
cc: D.S. Bunin (without RI/FS Workplans)J. Judge -(without RI/FS Workplans)J. Teitel (without RI/FS Workplans)B. Dolce. (without RI/FS Workplans)
..•"""v,, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY*J \ REGION III^ 841 Cfiestnut Building
Philadelphia, Pennsylvania 19107
OVERNIGHT DELIVERY " "" ———"" ". ; i ; - • « - s
'"', , ' ' . - ! - .
Mr. Donald Bunin, V.P;Sequa CorporationHillcrest Towers ~ " . - „7162 Reading Road _...._ ..._._.._.. ._ .--Suite 713 .Cincinnati, OH 45237V
RO: Dublin TCE Superfund Site
;-1oar Mr. Bunin:
nnder Section VIII CD) of the Dublin TCE Site RI/FSV<ninistrative Consent Order .(AGO) , EPA is notifying Sequa
1 'orporation (Sequa) of EPA's disapproval of... Gexaghty & Miller's•"J -s M) Draft ,?1 RI/FS "work" plan for the referenced site. The-nclosed attachment presents EPA's comments."to this work plan.specific locations in the work plan (page or section number) arenoted, where appropriate."
i.'nder the ACO Section Vlir(E) , Sequa Corporation has 30 days;" rom receipt of these comments (March 2, 1991) to resubmit an•:i...ended work plan to address the enclosed comments. A meeting•:an be arranged between Sequa, G & M and EPA to discuss thesecomments in greater detail.
If you have a"ny~questionsa,_cpricerjiing these comments or youwish to arrange a meeting with EPA, please do not hesitate tocall me at (215) 597-8240.
Sincerely,
• ™,Diaffne J. Walk'erRemedial Project ManagerSE PA Remedial Section
cc: Thomas Hartnett, PADER cc: Jeffrey Teitel, Esq.Dawn loven,EPA Charles Galiszewski, SeguaDave Kargbo, EPA Barbara Dolce, G&M £--""'""Bob Davis, EPA John Judge, Esq.Diann Simrns,EPA Andy Duchovnay, Esq.Andy Hopton, COM Steve O'Neill, PADERBob Day-Lewis, PADER
Attachment - - —_
I_. GENERAL . . . . .. = •
1. The. work plan lac}::; detail ..vith regard to the fieldinvestigation activities. The work, plan briefly describes., whatwi'll be done under specific tasks but does not describe in detailhow the work will be accomplished, or in some cases, whether itwLLL.be done at all.
In most cases, details concerning specific tasks are leftout pending the gathering of additional information from priortasks. Geraghty and Miller (G & M) must provide a work planaddendum that provides the new information and a rationale forhow specific tasks will be completed. For example, G & M mustreview the well records, analyze fracture traces and perform thegeophysical survey prior to locating and constructing test wells.Once the review has .been performed, G & M must provide detailsregarding the location and construction of test and observationwells, to EPA. EPA approval of the proposed approaches will berequired prior to. commencement of fJLeld activities.
',j. The schedule for the RI/FS is unacceptable. The proposedschedule should .not exceed 18 months. Although EPA has agreed toaccept the work performed under the PADER agreement as part ofthe RI/FS, many of the "additional investigations required by EPAare not dependent of .the completion of the PADER tasks and,therefore, these additional tasks should be performed earlier inthe process. For example, the Phase II geological andhydrogeological tasks are proposed in a completely separate .geographical location than the Phase I geological andhydrogeological tasks and, therefore, some of the Phase II workcan be performed concurrently with the Phase I work. G & M'sPhase II geophysical survey does not appear to be dependent onthe"results of the Phase II work and, therefore, should beperformed either concurrently with the Phase I geophysical studyor shortly thereafter. It is unclear why Task 3-15 does notbegin until two months after the PADER report is submitted. Thistask should begin based on the results of the Phase I data asthey are generated. The PADER report does not need to befinalized to begin Phase 2 work. Because G & M will besubmitting monthly progress reports to EPA which should containan analysis of the data collected to-date, Task 3-15 and allsubsequent hydrogeological tasks should begin much earlier thanproposed.
Also, the soil, sediment, ecological, and air monitoringwork can be performed concurrently with the Phase I work. Thefeasibility study (FS) schedule is too long. Much of the FS canbe performed concurrently with the Remedial. Investigation (RI)and Risk Assessment (RA). Also, treatability studies can beidentified early in the RI and conducted concurrently with thefinal RI phases. If necessary, additional manpower may berequired to meet a schedule acceptable to EPA.
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Also, the entire .schedule (both chc RI and FSi should -be anz^.one timeline Ci.e please combine ?.iguren 3 A and 9B) .
J . The groundwater system is a very complex, 3-diinensional,fractured rock system, and is most likely nonhomogeneous andanisotropic horizontally and vertically. Although G •& M has —-planned several useful field activities to characterize thiscomplex groundwater system, a more extensive field program isneeded to adequately evaluate contaminant transport within the.system, and develop a 3-dimensional model which can be used toevaluate various remedial alternatives. In addition, the RI wallneed to have a section on Contaminant Fate and Transport at theDublin site. The necessary revisions to the field investigationare described, in detail, below.
4. It is not necessary to duplicate the protocol descriptions inthe Field Sampling Plan and the work plan. One set of allprotocols (sampling, well construction, logging, etc.) can be ;;provided in the FSP, The duplicate appendices currently providedin the work plan can be removed.
II. SITE BACKGROUND A*?D PHYSICAL SETTING
Sits Background
1. page 5, paragraph 1: The "...several other organics..."detected in ground water at this site need to be specified.
2, page 10, last paragraph: This paragraph should alsosummarize the problems associated with the 2/9/90 soil gas surveysuch as water in the wells. Other problems such as depth ofsampling (!' from surface) could have also plagued the soilsurvey efforts.
Also the statement was made that given the soilconcentrations, no sources of ground water contamination weredelineated. The statement should not be made without an analysisof the minimum soil contamination that could be expected tocontribute to ground water contamination.
III. INITIAL EVALUATION
A. Conceptual Site Model
1. page 17, paragraph 1: Groundwater is not the only knowncontaminated media. From the data presented in this work plan,soil contamination is also present. The nature and extent ofthis soil contamination and its possible impact on groundwaterneeds to be determined prior before it can be eliminated as apathway of concern. Surface water contamination also needs to beaddressed. Reasons should be provided why surface waters, and
SR3QQ603
bioconcentration of food transfer, are not significant pathways,i. t applicable.
According to this paragraph, if groundwater is determined to bethe only medium of concern at the Site, potential risksassociated with vapor inhalation can be eliminated. However, asacknowledged on page 13 of the workplan, potable water use, whichinvolves ingestion, dermal contact and inhalation of VOCs,appears to be the dominant exposure pathway for site-relatedcontaminants. Since the statement presented on page 17 can bemisleading (by inferring that vapor inhalation is notsignificant), this paragraph should be amended to more accuratelyreflect exposure pathways at the Site.
2. page 17: It is stated that the presence of GAC treatment unitsat all affected residential and business wells in the vicinity ofthe site serves to .control exposure to VOCs. The apparentimplication of this statement is that contamination at the Sitehas been adequately addressed. The following points should benoted, however:
a. The presence of GAC treatment units on contaminated wellsis not a permanent solution to the groundwater contaminationassociated with the Site. If not remediated, contaminatedgroundwater could ultimately impact downgradient public andprivate wells, resulting in a greater problem than alreadyexists.
b. If the GAC filters currently in place are not maintainedfor an indefinite period of time, unacceptable exposure toVOCs could occur.
c. Perhaps of greater concern that the presence of TCE ingroundwater is the potential presence of vinyl chloride,which is a natural degradation product of TCE. Vinylchloride is classified as a Group A- Human Carcinogen by theEPA and, therefore, elicits much more concern with regard topotential health impacts related to exposure.
d. Aquifers are considered to be public assets. As such,the EPA strives to restore contaminated aquifers to theiroriginal beneficial use.
3. page 17, paragraph 3: Although natural recharge is importantfor the-users of the aquifer in Dublin, the selected remedyshould not be contingent on aquifer recharge. Extracted ground'can be treated, stored and provided for use while the aquifernaturally recharges itself.
4. page 17, paragraph 3: The use of existing wells inimplementing the chosen remedial alternative is always apossibility. However, the suitability of these wells will need
to be closely examined. The paragraph should be rewordedaccordingly.
6 . L'he boring logs for the on-site monitoring wells that supportthe conceptual model of Fig. 8 should be provided.
6. A map that shows the current extent of soil and groundwategcontamination is needed in the workplan. This map should supportthe conceptual site model.
7 . The current ground v/ater monitoring wells will need to beput into groups with respect to differences in monitoring wellconstruction, eg. -cased v. open, deep v. shallow, wells screened.ac the top of the water table v. wells screened way below the —'.;;iter table, etc. ~ "
•":, Potential Migration and Exposure Pathways
1. page 13, paragraph i: Although TCE is the principalconstituent of concern, other chemicals detected as a result of-.-:ite activities and the degradation of TCE should also be - =~ct Lscussed (e.g. vinyl chloride, PCE, etc.).
2. page 18, last paragraph, third sentence: Althoughvolatilization and biodegradation will reduce the concentrationsof TCE as the groundwater discharges to surface water, it doesnot necessarily eliminate the TCE, especially at the point ofdischarge. There are sites where VOCs emanating from groundwaterhave been measured in surface water. This paragraph should be ~~ vamended accordingly.
3. page 19, first sentence: The "affected area" needs to bedefined as contaminants in fractured rock can flow greatdistances in short periods of time. Please provide the criteriawhich have been used to define the present affected area.
C. Preliminary Assessment of Human Health and EnvironmentalImpacts
1. It is stated on page 20 that protection of public health "isusually associated with limiting exposure to potentialcarcinogens to concentrations that would result in cancer risksof less that 10~05 or 1Q~04. It should be clearly acknowledged inthe workplan that the EPA recognizes 10~06 to 10 to be anacceptable carcinogenic risk range, with 10~06 being the point ofdeparture.
2. Also, on page 20, the concentrations of TCE in water (3.2ug/1, .32 ug/1, and 320 ug/1) that are equivalent to specifiedcancer risk levels are presented. The parameters (or exposureroute) associated with, the derivation of these concentrationsshould be clearly stated in the report. It should also be noted
that inhalation exposure to TCE vapors during household water:.isage will more than, double the risk nosed by ingestion alone.(The respective 10~°°, 10~C'D, and 10~°' carcinogenic riskconcentrations associated with ingestion and inhalation of. TCEar.e 0.89 ug/1, 3.9 ug/1 and 39 ug/1.) The verbiage on page 20regarding inhalation exposure to TCE should be revisedaccordingly.
D. Data Gaps
1. page '21, paragraph is It is uncertain whether ground waterflow .directions and areal TCE plume distribution can beadequately mapped as claimed given current data. If thegroundwater flow direction can be mapped and the areal TCE plumein the bedrock aquifer can be plotted, it should be included inthis work plan along with the supporting information.
The reported ground water divide may have resulted inseveral flow directions. Additionally, continued on-site pumpingmay have complicated the issue of determining ground water flowdirections. Some wells in which water levels were measured arehydrologically connected to the pumping wells while others arenot. Depending on whether wells are pumping or not during thetime of water level measurements, flow directions may vary.
Secondly, the accurate plotting of the TCE plume is unlikelygiven the limited monitoring points and uncertainties in flowdirections. These issues should be reflected in the work plan.
2. The following data gaps that need to be included in thissection:
a. adequate determination of preferential fracture zones;
b. investigation of stratigraphic correlations including thecorrelations of major fracture zones;
c. measurement of vertical distribution of hydraulic heads;
d. the nature and extent of soil contamination including anassessment of the potential contribution of soils to groundwater contamination;
e. delineation of bedrock surface topography to determine flowdirections of potential sinking and nonaqueous phase ofcontaminants, and the presence of potential sinkholes whereDNAPLs may reside;
f. . performance of flow and transport modeling to determineextent of the plume;
^300606
g. performance of ground water sampling not just within the .^7site boundaries but also outside the property and township ~in the perceived direction of ground water flow;
h. determination of the effects of off-site .and on-site pumpingon the distribution of the plume; and
i. assessment of potential impacts from off-site sources.
j. the nature and extent of surface water contamination,including the extent of the storm drainage systems andseptic system at the plant.
3. In addition to wells in place, new monitoring wells willneed to be constructed since the current suite of wells isinadequate,
Specifically, several wells are needed downgradient of theplume- including wells in Bedminster Twp. Consideration should begiven to the recent information indicating that TCE was founddowngradient at the St. Luke's Church and at a residence 1-2miles north of the Dublin Borough- Hilltown Township border onRoute 313. . . . . . . . . . .
A suggested ground water divide (Rooney, 1986) is close to ~and almost parallel to Main St. Several wells, on either side ofthe divide are currently contaminated. The one TCE monitoringwell which was installed as part of the permit agreement forBorough Well No. 3 is inadequate to monitor the plume.
An appropriate background well should also be constructed(see comments to Field Investigations, belo'w) .
IV. WORK PLAN RATIONALE
Data Quality Objectives, page 22: The identification of majorcontaminant-bearing fracture zones may not be adequate for theassessment of migration rate and extent of the plume. Rather,knowledge of these fracture zones onsite will aid in implementingsource removal and control measures. A thorough evaluation ofthe extent of the plume may require offsite investigationsincluding monitoring.
V. ELEMENTS OF THE REMEDIAL INVESTIGATION/FEASIBILITY STUDY
A. TASK 2-COMMUNITY RELATIONS
page 24: The community relations plan for the Site has alreadybeen developed by EPA.
flR300607
3. TASK 3- FIELD INVESTIGATIONS
i. page 25: Change Sub-cask 3-11 to "Performance of SurTa.ce andBorehole Geophysics"
2. page 27, paragraph 3: The analytical quantitation limits fromthe existing analytical data for samples collected from watersupply wells and monitoring wells, if available, should beprovided in the summary tables of the RI report.
3. page 28, subtask 3-2, third paragraph, first sentence: If thepreliminary fracture trace analysis has been completed, it shouldbe included in this work plan.
page 29, Subtask 3-3, paragraph 2; The area for the surfacegeophysical•study (Fig. 11) should also include the-contaminatedground water area east of Elephant Rd., to determine:
i, if the reported ground water divide mirrors not only soilsurface topography but also bedrock surface topography; and
ii. the distribution and orientation of fractures east ofElephant Rd.
•5. The results and conclusions of the magnetometer surveyconducted at this site under the PADER consent agreement shouldbe described in this workplan. Specifically, an explanation ofthe anomalies identified in that study is necessary to rule outthe presence of any buried drums that may or may not have leakedcontaminants. The potential contribution of contaminants by theunderground storage tanks (USTs) east of buildings 1 & 3 (Fig. 5)should be investigated.
6. page 29,. last paragraph, fourth sentence: The transects shownin Figure 11 are approximately 500 feet apart. Because thecharacteristics of fractured rock can change dramatically inshort distances, this spacing may be too large to serve theintended purpose. A smaller spacing of approximately 100 feet isrecommended.
7. page 29, last paragraph, fourth sentence: Geophysicalsurveying of the area has been divided into two areas which areto be. done in separate phases. Therefore, the results of Phase Ido not cover the "full area of investigation" as stated on page30. EPA realizes that the Phase I survey is being performed aspart of the PADER study, but the Phase II survey is not dependenton the results of the Phase I survey. Therefore, it would bebetter to provide, geophysical surveying of the entire area duringPhase I, so that subsequent decisions regarding well placementand testing can be made more efficiently.
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S. page 30, paragraph 2: The seismic survey should be performecrnor. ^ust to clarify areas identified as anomalous by the EMsurvey, but als o to complement and verify the EM data. —
9. page 30, second paragraph, second sentence: Provide details ofthe seismic surveying (what, where, and how). Without thisdetail the usefulness of this activity can not be fullyevaluated.
10. page 30, Subtask 3-4: Water level measurements should also —provide data on vertical head distributions.
11. page 30, SubtasX 3-4: Continuous water level-monitoring ofthe wells as they exist now may be useful for identifying generalgroundwater flow directions and fluctuations, but this datacannot be used to characterize the three-dimensional aspects ofthe aquifer system. The existing wells are all open boreholes -which monitor a very large interval. Therefore, what the water .level measured in these wells represents is unknown.Contaminant concentrations measured in samples taken from thesewells also have little value because of the large zone beingmonitored. The workplan should be modified to reflect theseunknowns.
12. page 30, last paragraph, first sentence: It is difficult to__evaluate the usefulness of a continuous water-level monitoringscheme without knowing what wells will be monitored. When thelist of wells for this task is finalized, this list along withwell construction descriptions, and justification for theirselection must be submitted to EPA for EPA approval. Inaddition, more information could be gained by collecting handmeasurements from all the other wells .at some point during thecontinuous monitoring period, to facilitate development of thegeneral groundwater flow map.
13. page 31, paragraph 2: The final selection of wells forcontinuous water level measurements should be made followinganalysis of the pump test data when wells that are hydrologicallyconnected to the water supply wells have been identified.
14. page 31, Subtask 3-5: This paragraph should be modified toreflect the fact that contaminant capture zone analysis isconducted not by using just a flow model as proposed but atransport model that also incorporates the ground water flowcomponent. The use of a flow model alone assumes thatcontaminant transport is influenced only by the advective forcesof ground water flow. The following should be incorporated intothe workplan:
a. a 3- dimensional transport model rather than the proposedtwo-dimensional flow model should be used (see Comment 15,below);
AR300609
b. the final model ..selected should be . approved by EPA;
::. the selected model should also incorporate field data fromSubtasks 3-7, 3-20, 3-23, & Task 4;
d. the model should use as boundary concentrations, eitherbackground, MCL and/or health based concentrations;
e. . current and potential future stresses on the aquifer shouldbe included in the modeling ef.forts; and
f. ... .all_ model input and output data should be provided forreview both as hard copy and as computerized data onfloppies.
15. page 31, Subtask 3-5: Attempting to evaluate the capturezones at this point in the investigation may be premature due toa lack of data,""and attempting to model this fractured rockaquifer with a two-dimensional analytical flow model may bedifficult due.to its complexity. If any model can be developedto adequately simulate flow in this aquifer system, it would haveto be a 3-dimensional numerical model. But until some 3-dimensional aquifer testing is performed at this site, no modelcan reliably predict the capture zones. The water level datacollected will not be of much use in developing the model andpublished estimates of transmissivity assume that the aquifer is '2-dimensional and isotropic, which it is most likely not. Itwould be better to use well record, fracture trace andgeophysical data to plan the aquifer test, as the 2-dimensionalmodel results may be misleading.
16. page 32, Subtask 3-6, 1st. - 3rd. paragraphs. While pumpingtest wells could be open, it is recommended that the constructionof these wells be such that major fracture zones will eventuallybe isolated and monitored especially if found to be contaminatedfrom samples collected during packer testing. G & M should notethat if DNAPLs are present at this site, then based on theirconceptual model (Fig. 8) of the site, DNAPL migration intodeeper zones in the N-NW direction may be influenced not just bydensity effects but by orientation of bedding planes andfractures across bedding planes. Hence the need to .isolate thesezones for monitoring.
It is later indicated in Subtask 3-19 that any newlyinstalled wells will be considered for logging. However, it isalso noted from statements made in the workplan, that:
i. no commitment of constructing new wells is made until thePhase I data is reviewed even though current well network isinadequate to characterize the problem; and
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10
ii. any newly installed wells will be installed in a manner that-will "...permit them to serve as permanent recoverywells..." without any provisions for new monitoring wells.
Consequently, a commitment to constructing new monitoringwells that will appropriately monitor major fractures that may beconducting contaminants should be made.
17. Page 31-32, Subtask 3-6: Without knowing where the testwells will be located, or how many will be constructed, this taskcannot be evaluated. When decisions on the design andconstruction of test wells are finalized, this information mustbe provided to EPA in the form of a work plan addendum. Thisaddendum should provide well construction details and criteriafor selecting test well locations. Details on observation welllocations and construction must be provided. All of thisinformation will be subject to EPA approval.
18. pags 33, Subtask 3-7
i. paragraph l: Previous pump test data should be usedto design the 72-hour pump test.
ii. paragraph 2: Given the close proximity of the Dublinsupply well #1 to the source of the TCE contamination, it issuggested that a well that is not influenced by siteactivities be chosen as a background well. See Appendix Ecomments for more details.
19. page 33, Subtask 3-7: When decisions on how the pump testwill be run are made, this information must be provided to EPAfor EPA approval. This information must include how the length(short or long term) of the pump test will be determined andwhich wells will be used to measure the aquifer response to thepumping. Information must be provided on whether the selectedobservation wells will monitor water level at various depths atthe same time during the test. Information from this test alongwith the packer test data collected in Task 3-20 should be usedto calibrate the 3-dimensional groundwater flow and transportmodel.
20. p. 34, Subtask 3-8: The use of test wells constructedduring the Phase I activities should be consistent with theRecord of Decision (ROD) for the Early Action Alternate WaterSupply which was signed in December 1991.
21. p. 35, Subtask 3-9.
i. paragraphs 1 and 2: It is suggested that the finallocations and depths of test pits and/or trenches be madeafter results are analyzed from the previously conductedmagnetometer survey and any surveys which may be required by
AR3006I I
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EPA, based on the analysis of the previous magnetometersurvey. Details concerning where test pits will beexcavated and selection criteria for whether additional testpits will be completed must be provided to EPA.Justification for soil boring locations must also beprovided.
ii. paragraph 3: G & M should indicate the interval forcontinuous sample collection. A continuous spJ.it spoonsampling at 1' intervals is suggested. It is suggested alsothat irrespective of the PID scan data, all soil sampleswith discoloration and/or odor should be collected foranalysis.
22. 'page 35, Subtask 3-9: Because of the leak from the watertower which occurred last year, soil or soil gas sampling shouldbe performed in the area around the fire tower,
Also,- several areas where elevated readings were detected duringthe soil vapor study and previous soil sampling work are notincluded as areas where soil sampling will be done (see Comment24, below).
23. page 36, second paragraph, first sentence: At least three orfour background soil samples are needed to adequately evaluatebackground conditions.
24. G & M should be aware that if test pitting, trenching,and/or soil boring indicates the presence of significant soilcontamination, an assessment of the chemical concentrations insoils that will not continue to contribute to ground watercontamination will need to be made.
25. page 36, Subtask 3-10.
i. paragraph 1: The proposed sediment sampling locations (asindicated in Fig. 14) should also include areas east of N.Main Street especially in areas where ground water iscurrently known to be contaminated.
ii. paragraph 3: The proposed background sediment samplelocation (between Maple Ave. and Mill St.) may not beappropriate given its proximity to source locations. Asample from the end of S. Main Street may be moreappropriate.
Criteria for sample depth selection must be provided.
26. page 36, Subtask 3-10, paragraph 2: The sediment samplingdepth contained within this paragraph is inconsistent with thatof Appendix G of the workplan and Appendix D of the FieldSampling Plan.
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27. page 37, Subtask 3-11. Refer to comments on Subtask 3-3.
23. page 37, Subtask 3-11: The Phase II survey does not appearto be dependent on the results of the Phase I survey. Thisinformation would be more helpful if collected all at. once (see."general comments regarding schedule). In addition, the secondphase geophysical survey seems to be southeast and upgradient ofthe Phase I area, not southwest and downgradient.
29. page 38, Subtask 3-12: More detail must be provided on air ,quality monitoring. A background air sample, plus on-site anddowngradient samples should be collected for non-intrusive, andintrusive site work, specifically during test pit excavations.Information should also be provided on the nearest meteorologicalstation.
30. page 39, SubtasJc 3-13 - The ecological investigation shouldlook at impacts to areas off-site and should be concerned v/ith •the effects of contaminants migrating off-site, not just the —effect of field investigation activities at the site.
Justification for why aquatic resources will not be affected bythe migration of'contaminants from the site should be provided.This task description only discusses aquatic resources at .thesite and does not consider the impact of contaminated groundwateror surface water on offsite communities. The receiving stream(s)of Site runoff should be identified. If movement of contaminantsis possible, then these streams should be included in the extentof contamination. The streams should be characterized withregard to chemical and biological quality.
Any groundwater contamination should be identified and describedand discharges to local receiving streams also identified andanalyzed.
Because volatiles appear to be the primary contaminant at theSite, impacts to off-site organisms may be important. Smallmammal and bird populations as well as soil organisms and off-site receptors which use the ditch as a habitat are some of thereceptors to consider.
Review of the National Wetland Inventory maps, soil maps andaerial photographs should be review to determine the presence ofwetlands. If identified, a wetland delineation may be necessary.
The US Fish and Wildlife Service and/or the Natural HeritageProgram should be contacted to ascertain the presence or absenceof threatened or endangered species. Documentation of thesefindings should be included in the final RI/FS report.
13 "": ~ ':1. page 40, Subtask 3-14: In order to comply with the NationalEnvironmental Policy Act of 1969, the following"investigationsshould be conducted:
a. Stage IA cultural resources survey to determine thesensitivity of the area for historical/archaeological sites. TheState Historic Preservation Officer should be contacted todetermine the presence of known cultural resources.
b. Identification of Prime farmland. This would require contactwith the Soil Conservation Service's soil scientist to obtaininformation regarding significant agricultural land. This landdoes not have to be in agricultural production to qualify.
c. Identification of wildlife refuges, recreational areas,wilderness, etc. which are on or near the Site and may bepotentially impacted by the Site or its remediation
d. Identification of 1-00-yr and 500-yr floodplains and a. briefdescription of floodplains associated with the Site, ifappropriate.
e. Identification of any community services/land use plans whichwould be affected by the Site or its remediation.
32. page 40, subtask 3-15: As bedrock aquifers are highlyvariable over short distances, and geophysical logging is a goodinexpensive way to characterize this variability, all existingand future boreholes at the site should be logged fully by TV andother .instruments, not just selected boreholes at selectedintervals. In addition, preliminary selection of wells based ondownhole TV could be misleading due to bacterial growth orturbidity hiding certain features. . TV and geophysical loggingshould be used on all wells.
33. page 42, subtask 3-16: Concerns about groundwater monitoringin open boreholes again applies to this second phase of waterlevel monitoring. A detailed description of how this task is tobe conducted must be submitted to EPA as a work plan addendum.This addendum should provide selection criteria for how wellswill be chosen for the network, the actual well locations, andconstruction details for the chosen wells.
34. page 42, Subtask 3-16. The monitoring of water levelsshould include the determination of vertical distribution ofhydraulic heads.
35. page 42, Subtask 3-17, paragraph 1: In addition to thecomments on Subtask 3-5, "...may be conducted..." in the 1st'sentence should be changed to "...will be conducted."
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36. page 42, subtask 3-17: This task should be performed after ._the packer testing (Subtask 3-20) is completed. A 3-dimensionalnumerical flow model will be needed to perform this task.
This subtask and.various subtasks throughout this document implythat only one recovery well would be utilized to remediate thegroundwater. It is too early to speculate how many wells wouldbe needed to achieve groundwater remediation and contaminantcontainment.
37. page 43, Subtask 3-18: As discussed previously, details _concerning locations, design and construction of test wells mustbe provided to EPA in the form of a work plan addendum for EPAapproval.
38. page 43, Subtask 3-19: Geophysical logging should beperformed on all new wells.
39. page 43, Subtask 3-20: Again, as bedrock aquifers are highlyvariable over short distances, and packer testing is aninexpensive way to characterize this variability, all existingand future boreholes should be packer tested, not just selectwells. The packer test should provide data on the static head ofthe zone, the hydraulic conductivity and the water quality.Details on the type of packer test to be performed and thelocation and construction details for the wells should beprovided to EPA for EPA approval.
40. page 44, Subtask 3-21: Wells should not be abandoned orretrofitted without EPA approval.
41. page 44, Subtask 3-22: Details on what existing wells willbe used as observation wells and their location and constructionmust be provided to EPA prior to the pump test for EPA approval.If additional observation wells are to be installed, informationconcerning their placement and construction should be provided.
42. page 45, Subtask 3-22: Details of the pump test such ascriteria for determining the length of the test and details onthe location and construction of observation wells must beprovided to EPA in a Work Plan addendum.
C. TASK 4- SAMPLE ANALYSIS/VALIDATION
page 46, clearly state that for metals, both filtered andunfiltered monitoring well samples will be analyzed.
D. TASK 6- ASSESSMENT OF RISKS
1. The final determination of how the human health riskassessment will be handled has not been determined. In allprobability, 'the risk'assessment for this Site will be conducted
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in-house, by EPA personnel.. Task 6 should be amended, asnecessary.
2. Data should be supplied to EPA for the risk assessment in acomputer-readable file which is compatible with Lotus, ifpossible.
E. TASK 7- TREATABILITY STUDY/ PILOT TESTING
page 49, .paragraph 2: Innovative treatment technologies shouldnot be ruled out at this Site. Possible innovative technologiesinclude vacuum extraction and dual vacuum extraction (see HazMatWorld November 1991) if the vadose zone is determined to becontaminated. Also, the use of bioremediation should beconsidered.
Several of the results presented are for liquid drum samples andthe concentration terms for these samples should be either mg/1or.ug/1 (not ug/kg). The table should be amended accordingly.
G. TABLS 9
PADER's ARAR concerning the purge water discharge (25 PA CodeChapter 91, 92) should be included with this table as well as inAppendix L of the Field Sampling Plan.
H. TABLE 10
Clean Water Act Water Quality Criteria for the protection ofhuman health are inappropriate for application to contaminatedgroundwater. (These criteria consider two types of exposures: 1)exposure via ingestion of contaminated water and fish, and 2)exposure to contaminated fish only). Suitable risk-basecalculations should be derived by evaluating ingestion andinhalation of contaminants in groundwater under exposurescenarios delineated in the Risk Assessment .Guidance forSuperfund. (Although dermal exposure may contribute to theoverall risk associated with groundwater usage, the contributionvia this route is-negligible compared to ingestion andinhalation.) Table 10 should be amended accordingly.
I. TABLE 12
The human health criteria presented in this table should beelaborated upon, i.e. exposure scenarios, risk levels, etc.should be provided.
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J. APPENDIX D
1. page D-2, Overburden Advancement.
i. The use of air-rotary to advance through the overburden maybe acceptable if soil samples are not to be collected todetermine the presence or absence of volatiles (eg. TCE).The hollow stem auger is suggested for the overburden to befollowed by air rotary for bedrock penetration.
ii. Bedrock coring should be carried out for all newly drilledwells to provide added visual data on fracture intensity andorientation.
2, page D-3, Procedure for Construction of Bedrock MonitoringWells
i. paragraph 1: Refer to Comments on Subtask 3-6.
ii. paragraph 2: In addition to the collection of samples at 5'intervals and at changes in lithology, observations of soilcontamination (discoloration, odor, etc.) should also beused as a guide. Preferably, continuous split spoon samples(at 1' interval) should be collected especially in suspectedsource areas.
3. page D-5, Development: The'proposed air lift system is notsuggested for well development. This is because such a techniquecan result in chemical alteration of ground water both as aresult of reaction with air and as a result of impurities --—introduced with the air stream.
4. page D-5, Development: Wells should be developed until pH,specific conductivity, temperature and turbidity readingsstabilize in the development water, not just turbidity readings.
K. APPENDIX E
1.' page E-l, paragraph 1: Given the complexities at this site,conducting the pump test should not be contingent on informationfrom earlier tasks. Rather, information from earlier tasks canbe used to develop a pretest conceptual model that will be run topredict drawdowns. The calculated drawdowns should then becompared with well construction features and test duration. Ifunreasonable, the pretest model should be modified and drawdowndistributions recalculated until satisfactory results areobtained that can then be used to design the detailed pumpingtest.
Also as part of the pretest design, potential effects ofinterference from other production wells should be evaluated.
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2. page E-2, Pump Test Procedure, paragraph l: The stepdrawdown test should also be used to calculate well loss due toturbulent, flow'.
3. page E-3, paragraph 4: Decisions on the length of the testshould also consider the potential presence of boundary impactssuch as the proposed ground water divide. Consequently,calculations of pumping test duration which must be exceeded ifboundary impacts are to be negligible should be carried out.
4. The specific aquifer hydraulic characteristics to beevaluated during the pump test should be provided. As regardshydraulic conductivity (K), data on both vertical K andhorizontal K will, need to be collected.
L. APPENDIX.F
1, Some soil samples from each test pit should be analyzed by thelaboratory even if no elevated PID readings are detected.Depending on weather conditions, or the length of time soil sitsin the backhoe bucket prior to scanning, elevated VGA readingsmay not be detected even though some soil contamination mayexist.
VI. FIELD SAMPLING PLAN
1. page A-9, Filtration. For metal analysis, both filtered andunfiltered samples will need to be analyzed during at least oneround of sampling.
2. page B-l: The collection of samples from residential andpublic supply wells will have to be carried out.
3. • The protocol for Well Construction including Well Developmentwill need to be provided in the FSP.
4. Appendix A - General reference is made to groundwatersampling, however clarification should be made as to exactly howmany sampling rounds will occur, whether sampling will only occurduring pump and packer tests or whether additional samples willbe collected. Table 1 provides rough estimates of the totalnumber of samples, but the text in the work plan and the FSP doesnot clarify how many sampling rounds will occur.
5. Appendix A, Page A-3 - pH, specific conductivity, andtemperature readings should be taken of the purge water toconfirm that groundwater conditions are stable or consistent.
6. Appendix A, Page A-13 - Decontamination protocols for EPARegion III include a solvent rinse (methanol) and a 10% nitricacid rinse after the soap and water rinse and prior to the finalrinse with DI water.
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7. Appendix D, Page D-l - This sediment sampling sectiondescribes collecting the sample from the 0 to 1 foot intervals .instead of 12 to 18 inches as described in the work plan.Selection of sa'mpling depth needs to be clarified and justified.Additionally, a description of how and why the sample is beingcomposited should be provided. Samples for VOC analysis shouldnot be composited, and should be placed in the sample jar as soonas possible.
VII. QUALITY ASSURANCE PROJECT PLAN
1. The plan states that only selected subsets of data will be .validated. There is no criteria or rationale given. G & M mustprovide this information because this constitutes a majordeficiency.
2. Conditional approval is given for the analytical and samplingprocedure elements of the QUAPP. This allows sampling andanalysis to begin while the necessary corrections are made to thePlan.
3. QUAPPs must be in document control format per the requirementsof QAMS 005/80.
4. Section 2 - Provide information on the key personneldesignated to perform audits and perform the review of andconfirm any tentatively identified organic compounds.
Provide personnel qualifications including training, experienceand resumes.
5. Section 3.3: Completeness objectives should be based on theamount of valid data needed to address project objectives. It isnot solely related to the amount of sample or the processesinvolving sample shipment. A routine assessment of the datashould be used to evaluate the completeness throughout theproject rather that addressing it in the RI report
6. Section 4: Test pits soils are to be analyzed by PID. Theplan indicates that elevated readings will result in laboratoryanalysis of the sample. Define the concentration range whichindicates an elevated reading. • Make the corresponding changes tothe field sampling plan.
7. Section 5: Include document source of reagents and supplies.Address final evidence files.
8. Section 6: Include the concentration range of standards forthe portable GC. Also make the corresponding changes to the'field sampling plan.
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Calibration procedures should reference specific instruments andtheir manuals or, alternatively, the actual procedure should beprovided. Method 524.2 should be referenced as a CLP procedure.
9. Section 7 and Table 4-2: Provide rationale for using 8240 foranalysis of drill cuttings rather than CLP-RAS methodology.
10. Section 8: Provide a reporting scheme form the collection ofraw data through document storage. Reporting units,equation/procedures, record maintenance and storage, andprocedures for checking transcription errors should be given orreferenced. The identity of the independent validator(s) shouldalso be stated. Include examples of forms and reports.
The plan states that only a subset of the data will be validated.Provide the criteria for determining which data will bevalidated. This is a major deficiency which must be corrected.
11. Section 9: Provide field and lab acceptance or controllimits for each internal QC check.
12. Section 10: Identify who will conduct the audits (seecomments to Section 2). .
13. Section ii: Identify a source of spare parts, if a spareparts list is available and a source of repair and a schedule for.specific preventive maintenance.
14. Section 12: The purpose of this section is to detail the dataassessment procedures for the project. Include data assessmentprotocols (i.e. how do you know that the quality of the data isadequate for it's intended purpose?), statistical treatments, andthe appropriate arithmetic equations used in the assessmentprocess.
15. Section 13: Include predetermined limits for dataacceptability beyond which corrective action is required.
16. Section 14: Address the status of the project (time table)and the final summary report and distribution and the finalstorage and security of data files.
& MILLER, INC.nvironmental Services
Ground Water Engineering Hydrocarbon Remediation
February 14, 1992
/!/O )/l
VIA FACSIMILE
Dianne J. Walker (3HW21)U.S. Environmental Protection Agency - Region HIHazardous Waste Management Division841 Chestnut BuildingPhiladelphia, Pennsylvania 19107
Re: Dublin TCE Site
Dear Ms. Walker:
Thank you for the opportunity to discuss the USEPA Comments Document datedJanuary 29, 1992. As agreed to at the meeting held on February 11, 1992 we are providinga Memorandum of Understanding covering the issues which were discussed and agreed uponat the meeting. We would appreciate a written confirmation of your concurrence with whatis set forth herein.
Please feel free to contact us if you have any questions or require additionalinformation.
Sincerely,
GERAGHTY & MILLER, INC.
Jarbara A. DolceSenior Scientist
Joseph MinsterSenior Project Advisor
c: Charles Galiszewski
Enclosure
BAD:cmw#NJ14301-wp3/021492.1tr
201 West Passaic Street, 3rd Floor • Rochelle Park, New Jersey 07662 • (201) 9> . _ " -0567/0568AR30062/
MEMORANDUM OF UNDERSTANDING
TO: Dianne J. Walker - USEPA Region HI
c: Charles Galiszewski - Sequa Corporation
FROM: Barbara A. DolceJoseph Minster
DATE: February 14, 1992
RE: Meeting on February 11, 1992, 1:00 p.m.Dublin TCE Site
The meeting, requested by Sequa Corporation (Sequa), was held at the offices of theU.S. Environmental Protection Agency in Philadelphia (USEPA) on February 11,1992. Thefollowing persons were in attendance:
USEPA Geraghty & Miller. Inc.
Dianne J. Walker Joseph MinsterDave Kargbo Barbara A. Dolce
Kevin McGuinnessSequa Corporation Bob Mozer
Glenn DuffieldCharles Galiszewski
The purpose of the meeting was to discuss the USEPA letter of disapproval andComments Document dated January 29, 1992 on the Remedial Investigation/FeasibilityStudy (RI/FS) Work Plan and associated documents (Quality Assurance Project Plan, FieldSampling Plan, and Health and Safety Plan) and to obtain clarification on certain items.This memorandum reflects our understanding of the resolution of the USEPA comments.For reference, a copy of the meeting agenda, which was provided to all attendees, isattached. In a separate transmittal hand-delivered during the meeting on February 11,1992,the USEPA also received an expanded outline of the major issues for discussion along with
GERAGHTY & MILLER. INC.
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a separate attachment titled "Items Which Require Clarification." The expanded outline andlist of items requiring clarification are also attached to this memorandum.
The discussions regarding the topics listed in the agenda are summarized below inthe order in which they were discussed.
Three-Dimensional Solute Transport Model
The intent of the modeling proposed in the RI/FS Work Plan was clarified. It wasagreed that, as requested for Subtask 3-5, a three-dimensional model will be prepared. Inlieu of a three-dimensional solute transport model however, a three-dimensional, numericalground-water flow model and particle tracking computer code will be used to' evaluatevarious remedial pumping scenarios for the site. The U.S. Geological Survey (USGS)Modular Three-Dimensional Finite Difference Ground Water Model (MODFLOW)(McDonald and Harbaugh 1984) will be used to simulate ground-water flow at the site andthe USGS particle tracking post-processor will be used to simulate three-dimensionalground-water flow pathlines for the site. Because of the inherent complexities associatedwith this fractured bedrock system, the model will be used to simulate the transport of aconservative solute species under the influence of advective forces. The preliminary
modeling conducted under Subtask 3-5 will form the basis for collection of additional fielddata as needed and for subsequent modeling efforts (Subtasks 3-17 and 3-24).
Installation of Additional Monitoring Wells Downgradient of the Site
It was agreed that expansion of the existing monitoring well network would bedeferred in the investigation schedule until additional data (based on completion ofpreliminary field activities in Task 3, including the surface geophysical survey, packer testing,and borehole logging) can be developed. The additional data would be used to identifysuitable well locations and appropriate monitoring zones. If selected existing wells aresuitably located and are determined to be useable with modifications as appropriate, the
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existing wells will be given preference for incorporation into the monitoring network. Ifsuitable existing wells are unavailable, then additional monitoring wells will be constructed.
The location of thes'e wells will be selected and the design of these wells will be developedbased on data developed in earlier subtasks of Task 3.
Expansion of Investigation Area
It was agreed that sampling will be performed at St. Luke's Church in Hilltown.Trichloroethene (TCE) was detected in the church supply well. The well is located next to
the septic tank and, on several recent reconnaissance trips, the leach field was overflowing.Leachate was visible at the ground surface. The proposal to sample the church's septic tank,supply well, and leachate for TCE analysis before the investigation area is expanded wasaccepted by the USEPA. If the results indicate that TCE in the well results from the septictank, then the church septic tank may represent an additional and separate TCE sourcefrom the Dublin TCE Site.
Additional, water quality data from sampling and analysis of residential wells alongRickerts Road will be used to evaluate the need for expansion of the investigation area. Anumber of these wells will be sampled for volatile organic compounds on a quarterly basisas part of the implementation of the Record of Decision for Operable Unit 1 (AlternateWater Supply). It was agreed that selected wells hi the Rickerts Road area would besampled as part of Task 3 of the RI.
Schedule
The USEPA scope of work agreed to at this meeting can be implemented in 24months from the date of the USEPA approval of the RI/FS Work Plan. An additional 6-month period will be required if a solute transport model is deemed necessary. The 24-month investigation schedule provides for three periods of 30-days each for USEPA reviewof the pending major work items, such as water-level monitoring, test well installation, and
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aquifer pumping tests. Should the USEPA review require more than 30 days, then the 24-month period will have to be expanded accordingly.
The following USEPA comments will be reflected in the schedule:
(a) In regard to access negotiations which continue to remain a problem, forcemajeure may be granted under the provision that "best efforts" to obtain accessare exerted. Sequa has already sent out (December 1991) access requests to18 Dublin residents whose property is included in the Phase II geophysicalsurvey area. As of the meeting date, only four of the residents haveresponded.
(b) The complications related to conducting packer tests and aquifer pumpingtests under existing conditions where there are numerous intermittentlypumping private wells was acknowledged. Based on the review of a pumpingtest performed by Mercuri and Associates on the Rosanelli Well and on theevaluation of recent water-level data generated by Geraghty & Miller, any
water-level data obtained from packer tests and aquifer pumping tests underexisting conditions with numerous pumping wells may be difficult to interpret.However, the investigation schedule should not be based on conducting
aquifer pumping tests and other related activities under controlled conditionssuch as may be attainable when the alternate water supply system is on-line.
(c) The USEPA required that scope items to be developed during the RI/FS besubmitted for approval prior to implementation. It was agreed that theinformation required by the USEPA would be provided in the regular monthlyprogress report preceding the scheduled work. This would be followed by
. expedient review by the USEPA. As indicated above, contingencies related
to the USEPA review procedures have been provided for in the schedule.
GERAGHTY c? MILLER. INC. .
DNAPLs
Data collected as part of the source investigation and during installation of the eightexisting monitoring wells did not provide any evidence of DNAPLs. It was agreed that wewill expand the proposed work scope at and immediately near the site to include packertesting of selected monitoring and supply wells such as MW-3, MW-4, and PW-2. Inaddition to the packer testing, an oil/water interface probe will be used to determinewhether DNAPLs are present at the bottom of each well. If the data developed indicatesthat DNAPLs are present, then the investigation scope will be modified appropriately. Anymodifications will be submitted to USEPA for approval prior to implementation.
Plume Remediation and Aquifer Recharge
The USEPA acknowledged that there are limitations to the amount of water that canbe pumped for any purpose from the aquifer underlying Dublin Borough. These limitationsinclude the safe yield of the aquifer and the actual consumption of the water within theborough. If pumping and treatment of ground water is determined to be the appropriateremedy, these considerations will be taken into account. A reduction in pumpage toaccommodate these limitations may lengthen the TCE plume remediation time.
Phase I Geophysical Survey
The USEPA acknowledged that the Phase I surface geophysical survey is alreadycompleted, making it impossible to complete the Phase I and Phase II surveys at the sametime. The electromagnetic (EM) ground-conductivity survey portion of the Phase Iinvestigation area was completed using a 400 by 400-foot grid. It was agreed that theproposed approach for the EM portion of the Phase II survey is acceptable. This approachentails the survey being completed on a 400 by 400-foot grid. Results are processed andevaluated while the field survey is being conducted. If anomalies representative of fracturesor fracture zones are detected, then additional EM survey transects are completed to
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determine the extent of the anomalous features. For the Phase I survey, offset transectswere completed parallel and perpendicular to the detected anomaly. It was agreed that asimilar approach would be followed for the Phase II EM survey.
Background Monitoring Well
It was agreed that the proposed background monitoring well, Borough Well No. 1,is acceptable. This well is sampled by the Borough and analyzed for water-qualityparameters on a frequent basis. If TCE is detected in the well, then an alternatebackground well will be required.
Bedrock Coring
It was agreed that the first new well installed will be continuously cored. Additionalselected wells will also be cored. Qualitative information on fracture orientation will beobtained from the cores. The cores will be compared to the results from TV and boreholegeophysical logging. If the correlation is satisfactory, then coring of additional wells will notbe required.
Logging of Existing and Future Boreholes
It was agreed that the existing monitoring wells (MW-1 through MW-8) and all futureboreholes drilled for the RI (test/recovery wells, observation wells, and monitoring wells)will be logged by TV and borehole geophysical methods.
Vertical Distribution of Head
Geraghty & Miller proposed to determine the vertical distribution of head frommeasurements obtained prior to and during the packer testing. It was agreed that additionalinformation on the program would be provided to the USEPA (Dave Kargbo). Based on
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this information, the USEPA would render a decision on the suitability of the program priorto submittal of the revised Work Plan. This information will be prepared and transmittedto the USEPA shortly.
Packer Testing of Wells
It was agreed that all the existing monitoring wells installed by Geraghty & Miller
(MW-1 through MW-8) would be packer tested. Packer testing may also be conducted onother selected wells, as deemed necessary. For example, as discussed earlier, thedetermination of which existing residential or supply wells are appropriate for use asmonitoring wells may require packer testing. Future boreholes drilled for the RI(test/recovery wells, observation wells, and monitoring wells) will be selectively packertested.
Residential and Public Supply Well Sampling
It was agreed that the selected wells at or near the 120 Mill Street property will besampled and analyzed for a complete suite of parameters, including volatile organiccompounds (VOCs), base neutral and acid extractable organic compounds, metals, andpesticides/PCBs. In addition, other selected residential and/or public supply wells may besampled for VOCs. These selected wells will be determined based on results generatedfrom the surface geophysical survey, borehole logging and packer testing, a review of thewell inventory database, and other data developed during Task 3 of the RI.
Items Which Require Clarification
Several items in the USEPA comments required clarification as to the intent orappropriate technique. Some of the items were clarified during discussion of the major.issues. However, in most cases they are repeated in this section for consistency.
GERAGHTY & MILLER, INC. AR300628
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p. 3 Item 3 This item was clarified in the earlier section on "Plume Remediation andAquifer Recharge".
p. 6 Item h "On-site" in the work plan refers to the 120 Mill Street Property.
p. 6 Item i "Off-site" refers to the area outside of the borough.
p. 6 Section IV "Off-site" refers to the area outside of the 120 Mill Street Property.
p. 10 Item 18 (ii) "Site" refers to the 120 Mill Street Property.
p. 10 Item 20 USEPA's comment was based on a misunderstanding of the intent of thereferenced passage. The USEPA agrees to accept the intent in the work plan and there isno action required.
p. 11 Item 21 As long as continuous sampling of the specified interval is performed, thestandard 2-foot split-spoon sampler is acceptable to the USEPA.
p. 11 Item 25 We will attempt to collect a sediment sample in the requested area.However, it may not be feasible because the storm-water drainage system is buried in thatarea. A field reconnaissance will be performed to determine whether a suitable samplinglocation exists. If a location is identified, then a sample will be collected.
p. 13 Item 32 This item was clarified in earlier section "Logging of Existing and FutureBoreholes".
p. 14 Items 37 and 39 It was agreed that additional information or requested notificationswould be provided by Geraghty & Miller in the monthly progress reports.
p. 16 Item J (ii) Qualitative data on fracture orientation will be collected from the cores.
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p. 16 item J (4) As requested by the USEPA, we will attempt to develop the wells until pH,
specific conductivity, temperature, and turbidity readings stabilize. It was acknowledged bythe USEPA that stabilization of all of these parameters may not be achieved within areasonable time period or that there may be other factors (such as storage capacity) whichpractically control the maximum amount of water which can be pumped for welldevelopment.
p. 16 Section K Item 4 We will attempt to determine the horizontal and verticalcomponents of the hydraulic conductivity of the bedrock during the aquifer pumping test.We will also attempt to verify these values during modeling.
p. 19 Item 8 The USEPA will check with appropriate laboratory personnel to determinewhether Method 524.2 is a CLP procedure.
Conclusion
The meeting was concluded at approximately 6:00 p.m. At the conclusion of themeeting it was agreed that Sequa would submit to the USEPA for its approval amemorandum of understanding which reflects the items agreed upon during the meeting.
Attachments
BAD:cmw#NJ14301-wpl/021292a.mem
GERAGHTY & MILLER. INC. $R30Q63Q
EPA MEETING AGENDARI/FS WORK PLANDUBLIN TCE SITE
FEBRUARY 11, 1992
MAJOR ISSUES FOR DISCUSSION
p. 6 Item 3 • Expansion of investigation area.
p. 3 Item 3 • Plume remediation and aquifer recharge.
p. 8 Item 14 • Three-dimensional solute transport model.
p. 9 Item 16 • DNAPLs.
p. 7 Item 4 • Phase I Geophysical Survey.p. 8 Item 8
p. 6 Item 3 • Background Monitoring Well.p. 9 Item 16 (i, ii)
p. 6 Item 3 • Installation of Additional Monitoring WellsDowngradient of Site.
p. 16 Section J • Bedrock Coring.Item 1 (ii)
p. 13 Item 32 • Logging of Existing and Future Boreholes.
p. 1 • Schedule.
p. 8 Item 10 • Vertical Distribution of Head.
p. 14 Item 39 • Packer Testing of Wells.
p. 10 Item 19 • Work Plan Addendumsp. 13 Item 33p. 14 Item 37
p. 17 Section VI • Residential and Public Supply Well SamplingItem 2
<WJU301 -wp3/020392b.agd
GERAGHTY & MILLER, INC. 3 R 3 0 0 6 3 |
EPA MEETING AGENDARI/FS WORK PLANDUBLIN TCB SITE
FEBRUARY 11, 1992
MAJOR ISSUES FOR DISCUSSION
p. 6 Item 3 • Expansion of investigation area.
- With regard to the St. Luke's Church wellsampling results, we propose that samplingof the church's leachate and septic tankcontents be performed prior to expansion ofthe investigation area.
p. 3 Item 3 • Plume remediation and aquifer recharge. '
- We will evaluate whether the amount ofwater that can be pumped is related to thesafe yield of the aquifer and to the amountof water that can be consumed in theborough. These considerations are apractical reality for any remedial scheme,especially since there are no viable meansof artificial recharge in this type ofsetting.
p. 8 Item 14 • Three-dimensional solute transport model.
- The applicability of the solute transportmodel is unknown. Development of such amodel is limited by the ability to obtainrepresentative data from a fractured rockaquifer. The fractured rock system is notuniform. Even with a flow model, anypredictions of required pumpage will needto be tempered by practical aquiferlimitations (safe yield) and water disposalconsiderations.
p. 9 Item 16 • Presence of DNAPLs.
- Data collected as part of the sourceinvestigation and during installation ^ofthe eight monitoring wells did not provideany evidence of DNAPLs.
GERAGHTY & MILLER, INC ^300632
- A rough estimate of the amount of TCEthe entire plume is 40 gallons. Inearly action Record of Decision (ROD)issued on December 31, 1991 the EPA hasestimated TCE use of 15 gallons per weekover a 12-year period. It is uncertainwhat this estimate is based on. Availableevidence indicates that only a small amountof TCE was released. Based upon thisinformation and the soil, soil vapor andground-water sampling data we do not expectthat significant quantities of DNAPL arepresent. If DNAPL is encountered theinvestigation will be tailoredappropriately.
p. 7 Item 4 • Phase I Geophysical Survey.p. 8 Item 8
- The Phase I geophysical survey has alreadybeen completed.
- The 400- by 400-foot grid upon which thePhase II geophysical survey will beconducted is believed to be adequate. Thegeophysical data will be interpreted in thefield and additional survey lines will berun accordingly. The additional lines willbe run as offsets to grid locations thatare interpreted as anomalous and will beused to refine the subject anomalies.
p. 6 Item 3 • Background Monitoring Well.p. 9 Item 16 (i, ii)
- Close proximity of Borough Well No. 1 doesnot mean it is under the influence of thesite. The fact that TCE has not beendetected in this well would indicate thatit is a suitable background location.
p. 6 Item 3 • Installation of Additional Monitoring WellsDowngradient of Site.
- Several residential/commercial wells at thenorthern plume perimeter have had none orvery low concentrations of TCE.
- A number of wells will continue to besampled on a frequent basis pursuant to theThompson Consent Order until the alternatewater supply is installed. After thealternate water supply system is installed
GERAGHTY & .MILLER, INC. ^300633
all private wells may be available formonitoring.
- In addition, a number of wells will besampled on a quarterly basis as part of theROD. These wells are designated as thosepotentially affected by the TCE plume; theyare listed in Table 2 of the ROD.
- The monitoring network should be adequateuntil additional results are developedduring the ongoing investigation.
p. 16 Section J • Bedrock Coring.Item 1 (ii)
- We propose coring of selected wells insteadof all wells. A great deal of informationwill be obtained from detailed loggingduring well installation. Coring willlengthen the field program.
p. 13 Item 32 • Logging of Existing and Future Boreholes.
- We accept the logging requirement ifexisting boreholes are limited to the 8existing monitoring wells and futureboreholes are limited to test/recovery welland observation wells installed as part ofthe RI.
p. 1 • Schedule.
- Substantive additional work will requireadditional time for the investigation. Itwould be advantageous to proceed at thepresent schedule or a modified schedule, sothat packer testing, pumping tests, andother tasks involving water-levelmonitoring, can be performed after thealternate water supply (AWS) is installed.At this time, the influence of numerous,intermittent pumping centers -will beeliminated. Conduct of these tests priorto the installation of the AWS could leadto the generation of errant data.
p. 8 Item' 10 • Vertical Distribution of Head.
- Vertical heads will be measured during thepacker tests.
p. 14 Item 39 • Packer Testing of Wells.
3830063^GERAGHTY & MILLER. INC.
- Existing boreholes should be defined as MW-1 through MW-8. Some wells may not meritpacker testing.
p. 10 Item 19 • Work Plan Addendumsp. 13 Item 33p. 14 Item 37 - Work plan addendums are required for
pumping tests, ground-water monitoring, andtest well construction. Time will have tobe provided in the investigation schedulefor USEPA review of these addendums.
p. 17 Section VI • Residential and Public Supply Well SamplingItem 2
- The USEPA states that sampling ofresidential and public wells will have tobe carried out. We had proposed samplingof selected wells. It is unclear why thissampling has to be conducted and what wellsthe USEPA envisions being included. Underthe Thompson Consent Order, 54 wells willcontinue to be sampled until the alternatewater supply is installed. According tothe ROD, 56 additional, different wellswill be sampled on a quarterly basis andanalyzed for VOCs by Method 524.2.
-wp3/020392.agd
GERAGHTY & MILLER. INC. ^300635
PRELIMINARY ANALYSIS OFUSEPA COMMENTS ON THE
DUBLIN TCE SITE RI/FS WORK PLANS
ITEMS WHICH REQUIRE CLARIFICATION
p. 3 Item 3 Clarify how the extracted water can be "stored and provided for usewhile the aquifer recharges itself.
p. 6 Items h and i Clarify the meanings of "onsite" and "offsite".
p. 6 Item 3, "An appropriate background well should be constructed." This statementlast sentence conflicts with statement on page 10 item 18 ii which refers to choosing
a background well. Does this mean that the background well may bean existing supply well?
p. 6 Item IV Again clarify "off and "onsite".
p. 10 Item 18 (ii) Clarify "site".
p. 10 Item 20 Clarify statement regarding consistency with ROD.
p. 11 Item 21 Split-spoon samplers are typically 2 feet in length. Applicable standardspertain to the 2-foot length sampler.
p. 11 Item 25 Sediment sampling east of Main Street may not be feasible.
p. 13 Item 32 This comment requests that all existing and future boreholes at the siteshould be logged fully. Please clarify. This should not include thesupply wells.
p. 14 Items 37 and 39 Refer to providing details to EPA in later submittals. Item 46 calls fordetails to be provided in a "Work Plan Addendum". What is thedifference, if any between these submittals?
p. 16 Item J (ii) Clarify "orientation" as used in relation to fractures hi bedrock cores.
p. 16 Item J (4) Well development protocol.
p. 16 Section K The purpose of the vertical and horizontal conductivity measurementsItem 4 is unclear.
p. 19 Item 8 Clarify last line which requests that Method 524.2 be referenced as aCLP procedure.
#NJ14301-wp3/020392a.agd
GERAGHTYtf MILLER, INC. $R300636
-if -_,, I •
& MILLER. INC.Environmental Services
Ground Water Engineering Hydrocarbon Remediation it t
February 20, 1992
Dianne J. Walker (3HW21)U.S. Environmental Protection Agency - Region IIIHazardous Waste Management Division841 Chestnut BuildingPhiladelphia, Pennsylvania 19107
Re: Dublin TCE SiteDublin, Pennsylvania
Dear Ms. Walker:
As agreed at the meeting held on February 11, 1992 between the U.S. EnvironmentalProtection Agency (USEPA), Sequa Corporation, and Geraghty & Miller, Inc., we aresubmitting information on the proposed technical approach for measurement of the verticaldistribution of ground-water head in the bedrock. It was agreed that we would provideadditional details on the proposed measurement technique for review by the USEPA priorto submittal of a revised RI/FS work plan for the Dublin TCE Site. The technical approachis described below.
TECHNICAL APPROACH
Double packers will be used to isolate selected fractures or fracture zones which havebeen identified from drilling logs and borehole surveys. The pressure within the isolatedinterval and in the zone above and below will be measured. These measurements willprovide the information requested by the USEPA on vertical distribution of head.
The double packer unit will consist of two inflatable sliding rubber packers set up ona hollow support rod. The packer depth settings will be selected to monitor a specific
201 West Passaic Street, 3rd Floor • Rochelle Park, New Jersey 07662-(201) 909-0700* FAX (201) '. fl R 3 0 0 6 3 7
GERAGHTY & MILLER. INC.
2
fracture or fracture zone. Once the packers are seated at the proper depth, an inert gas(such as nitrogen) will be used to inflate the packers.
Pressure transducers will be incorporated into the packer unit to measure changesin head. One pressure transducer will be located below the lower packer, one within theisolated zone, and one above the upper packer. The pressure transducers will be connectedto a data logger which will record and store pressure measurements before and during thepacker test.
Pressure measurements will be monitored approximately every 5 minutes until staticconditions are achieved. The measurements of static conditions will be considered thepressure head within the monitored zone. The pressure measurement will be coordinatedwith the hydraulic conductivity testing of specific fractures or fracture zones.
As we discussed at the meeting, we would appreciate your expedient review of thisapproach prior to work plan submittal. Please feel free to contact us if you have anyquestions or require additional information.
Sincerely,
GERAGHTY & MILLER, INC.
Barbara A. DolceSenior Scientist/Project Manager
Joseph Minster, C.P.G.Senior Project Advisor/Project Officer
c: Dave Kargbo - USEPACharles Galiszewski - Sequa Corporation
BAD/JM/mtb:cmw#NJ14301-wp3/021892.!tr
AR300638
UNFTED STATES ENVIRONMENTAL PROTECTION «m=r«-,«i ^ r >»v v»» • --*•, . _,.,.REGION III •' -v ' ^ 1 — — » •'••• '-A
841 Chestnut BuildingPhiladelphia, Pennsylvania 19107
Barbara A. DolceGeraghty & Miller, Inc.201 West Passaic Street3rd FloorRochelle Park, New Jersey 07662
Re: Dublin TCE Superfund Site
Dear Ms. Dolce:
The Environmental Protection Agency (EPA) has reviewed theMemorandum of Understanding in which Geraghty & Miller summarizedthe meeting held between EPA and G&M on February 11, 1992. Ingeneral, EPA concurs with the summary, although, we would like toclarify a few points which were made during the meeting. Pleaseincorporate these clarifications into the revised workplan due toEPA on March 9, 1992.
EPA agrees that the MODFLOW groundwater flow model can beused to model groundwater flow and to analyze the capture zonesof groundwater. This model cannot, however, be used to analyzecapture zones of contaminants when contaminant dispersion issignificant. If G&M intends to model the capture zones ofcontaminants, a transport model which incorporates both advectiveand dispersive forces should be used. Determination ofcontaminant capture zones is typically necessary during thedesign phase of a remedial action. EPA also requests that G&Mspecify the USGS particle tracking model which they intend onusing.
Although EPA has agreed to evaluate the incorporation ofexisting wells into the monitoring well network, G&M should beaware (as noted in the 2/11/92 meeting) that use of existingwells may be inappropriate due to several potential unknowns,especially with respect to well construction. EPA isparticularly sensitive to the lack of the existence of well logsthat show well depth, water flow zones, fracture size, intensityand orientation and potential mineral growth in these fractures.EPA is requesting that G&M provide information on how theexisting wells will be modified so that they can serve asmonitoring wells.
EPA believes that there may be a lack of existing wells insome areas and/or an inadequate number of existing wellsnecessary to adequately characterize the extent of contamination.Therefore, G&M should be aware that new monitoring wells willhave to be installed in locations and at depths to be determinedfollowing the results of the existing well retrofitting. G&Mshould indicate potential locations for monitoring wells (eitherexisting and/or new) in the areas specified in EPA's comments to
AR30063S
G&M's RI/FS workplan (i.e. downgradient of the site outside ofthe Borough, between the 120 Mill Street property and theRosenelli well, and on the eastern side of the groundwaterdivide) . . . .... .
EPA agrees that investigation of the St. Luke's churchproperty may provide additional information on other possiblesources of contamination in the Dublin Borough area. G&M shouldbe aware that, if contamination at this facility is present,enough information will need to be provided to EPA to indicatethat the groundwater contamination is not due to the Dublin TCESite.
EPA agrees that selected wells along Rickerts Road should besampled as part of Task 3. EPA is requesting that G&M identifythe wells to be monitored. Please note that EPA does not believethat the vertical and horizontal extent of groundwatercontamination can be determined by analyzing one sample of waterin an open hole well that encounters several fracture zones. Anopen hole may encounter many water-bearing fractures(contaminated and uncontaminated). The uncontaminated fracturesmay dilute the contamination entering the well. This dilutionmay result in a sampling event which indicates a "clean" well,even though contamination is present. Therefore, EPA isrequiring that the background well (Dublin Borough Well #1) bepacker-tested if it is to be used as a "monitoring" well.
It is important that G&M identify the manor contaminant-bearing fractures during this investigation so that the verticaland horizontal extent of contamination can be determined. Pleaseincorporate these ideas into the revised workplan.
EPA will need to review the proposed timelime before we canconcur on the 24 month schedule. EPA believes the work can becompleted within an 18 month timeframe, although we will reviewG&M proposal before finalizing our decision.
In regard to your February 20, 1992 proposal to monitorvertical distribution of head, EPA concurs with the methodologyproposed; although, EPA will require that the packer zones beisolated and monitored every 20 feet or when major water bearingzones are encountered, whichever distance is shorter.
If you have any questions regarding our comments, pleasecall me at (215) 597-8240.
mne J.Remedial Project ManagerSE PA Remedial Section
cc: Charles Galiszewski, Sequa CorporationDave Kargbo, EPA
^GERAGHTY'& MILLER, INC.Environmental Services
Ground Water Engineering Hydrocarbon Remediation Education
March 6, 1992
Dianne J. Walker (3HW21)U.S. -Environmental Protection Agency - Region IIIHazardous Waste Management Division841 Chestnut BuildingPhiladelphia, Pennsylvania 19107
Re: Dublin TCE Site
Dear Ms. Walker:
Enclosed please find four copies of the following revised documents for the DublinTCE Site in Dublin, Pennsylvania: Remedial Investigation and Feasibility Study Work Plan,Health and Safety Plan, Quality Assurance Project Plan, and Field Sampling Plan. We areproviding these documents on behalf of Sequa Corporation (Sequa). The requiredcertification from Sequa is also enclosed.
The documents have been revised in accordance with the U.S. EnvironmentalProtection Agency (USEPA) comments dated January 29, 1992, discussions at the meetingheld between Sequa, the USEPA, and Geraghty & Miller, Inc. on February 11, 1992,USEPA comments dated March 3, 1992, and pertinent telephone conversations betweenGeraghty & Miller and the USEPA (Walker, pers. comm. 1992a,b). During theseconversations several issues were clarified and revisions to the work plan, in response to thecomments, were agreed upon. These issues and their resolutions are discussed inAttachment A of this transmittal.
Each of the documents shows the substantive revisions from the previous versionsubmitted to the USEPA (November 1991). Additions and revisions to the text are shown
201 West Passaic Street, 3rd Floor• Rochelle Park, New Jersey 07662*(201) 909-0700-FA" '""1N ™Q-fiS67/0568
AR3006M
GERAGHTY & MILLER. INC.
2
in bold-face type. Deletions have been shown with a strikeout. Revisions to typographicalerrors and minor editorial changes are not shown in boldface nor with strikeouts.
Please feel free to contact us if you have any questions or require additionalinformation.
Sincerely,
GERAGHTY & MILLER, INC.
Barbara A. DolceSenior Scientist/Project Manager
. Joseph MinsterProject Director/Project Officer
Attachmentcc: Charles Galiszewski - Sequa Corporation
John P. Judge, Esq. - Cohen, ShapiroAndy Hopton - CDM Federal Programs CorporationJoseph Feola - PADERSteve O'Neill/Thomas Hartnett - PADER
Walker, D. J. 1992a. U.S. Environmental Protection Agency. Telephone conversation withB. A. Dolce, Geraghty & Miller, Inc., March 3, 1992.
Walker, D. J. 1992b. U.S. Environmental Protection Agency. Telephone conversation withB. A. Dolce, Geraghty & Miller, Inc., March 4, 1992.
BAD:cmw/amk#NJ14301-wp4/030592.1tr
ATTACHMENT A
It was agreed that three-dimensional, numerical ground-water flow modeling using particle tracking would besuitable for the RI/FS. A solute transport model, ifrequired, would be part of the remedial design stage ofthe project.
The evaluation of existing wells for incorporation intothe monitoring well network shall consist of a depthdetermination, TV, and geophysical logging, and possibly,packer testing. As much information as possible will beobtained from the well owner. Redevelopment will beimplemented if necessary. Prior to modification of theexisting wells which would occur in Subtask 3-23, theUSEPA would be notified.
A figure (Figure 18) has been included in the work planwhich indicates potential locations for monitoring wells.
We have incorporated sampling of the St. Luke's Churchsupply well, septic tank and leachate breakout todetermine whether there may be another TCE source. Thesedata will be reviewed along with other results todetermine whether the septic field may be another source.
A figure has been added to the work plan (Figure 17)which shows the locations of properties along RickertsRoad where we intend to do well sampling.
Dublin Well No. 1, our proposed background monitoringwell, will be packer tested subject to obtaining access.
The RI/FS will attempt to provide sufficient data toidentify major TCE bearing fractures for the purpose ofdetermining the vertical and horizontal extent ofcontamination.
GERAGHTY & MILLER. INC.
The RI/FS schedule has been reduced from two figures toone (Figure 11) , and depicts a 24-month project schedulefor USEPA review.
The requirement for packer testing at 20-foot intervalsor when major water bearing zones are encounteredpertains to the measurement of vertical ground-water headdistribution. It was agreed that one well, for whichborelogging data has been generated, will be packertested every 20-feet for obtaining ground-water headmeasurements. The resultant data will be reviewed, inconjunction with borehole logging, to determine theapproach for additional testing. Selection of intervalsfor future testing will be based on borehole loggingdata.
GERAGHTY & MILLER. INC.
<i UNfTED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 111
SS£,/ 841 Chestnut Building RECEIVED BYu -X Philadelphia, Pennsylvania 19107 JOHN P. JUDG""
MAR 18 1992 "«20fi92John Judge, EsquireCohen,Shapiro,Polisher,Sheikman and CohenPSFS Building12 South 12th StreetPhiladelphia,PA 19107-3961
RE: Dublin TCE Site
Dear John:
EPA is in receipt of your letter of March 6,1992. Please be
advised that EPA does not consider Sequa's response to the EPA's
Special Notice Letter to be a Good Faith Offer since Sequa did
not agree to negotiate a Consent Decree for the RD/RA for GUI at
the Dublin Site. During our prior meeting I advised you that in
the event that Sequa did not submit a Good Faith Offer EPA had a
number of options available to it other than the issuance of a
Section 106 order. EPA is currently considering its options. If
you have any questions please contact me.
Very truly yours,
Andrew DuchovmAssistant R e i o l Counsel
UNfTED STATES ENVIRONMENTAL PROTECTION AGENCYREGION III
841 Chestnut BundingPhiladelphia, PennsylvanJa 19107
Mr. Donald Bunin, V.P.Sequa Corporation rt Hillcrest Towers APR 2 2 13927162 Reading RoadSuite 713Cincinnati, OH 45237
Re: Dublin TCE Superfund Site
Dear Mr. Bunin:
Although Sequa Corporation has responded to many of the.issues raised in the Environmental Protection Agency's (EPA)letters of January 29, 1992 and March 3, 1992, severalsignificant issues still must be addressed prior to EPA approvalof the workplan. Some of the issues agreed upon in our 2/11/92meeting were not addressed. Failure to address EPA'srequirements will only delay the RI/FS process further. Addressthe comments described in the attachment to this letter andsubmit the Final RI/FS workplan to EPA within 15 days of receiptof this letter.
If you have any questions, please call me at (215) 597-8240.
Sincerely,
Dianne J. WalkerRemedial Project ManagerSE PA Remedial Section
Enclosure
cc: Thomas Hartnett, PADER cc: Charles Galiszewski, SequaDawn loven, EPA Barbara Dolce, G&M -- ^Dave Kargbo, EPA John Judge, Esq.Bob Davis, EPA Andy Duchovnay, Esq.Andy Hopton, CDM Steve O'Neill, PADERBob Day-Lewis, PADER
ATTACHMENT
I. St. Luke's Church Investigation
Geraghty & Miller's (G&M) 2/14/92 summary of the 2/11/92meeting indicated that samples would be taken from the septictank, leachate and the supply well. The revised workplanindicates that the supply well will be tested. It is not clearif the leachate and septic tank are still planned for testing.If G&M intends to prove that this location is a possible sourceof TCE in the area, additional sampling is necessary.
II. DNAPLs testing
G&M's 2/14/92 summary memo indicated that DNAPL testingwould possibly be performed in PW-2 located at the 120 MillStreet property. DNAPL monitoring of this well was not proposedin the revised workplan. EPA believes that because of thelocation of this well with respect to the suspect area ofdisposal, it should be monitored for DNAPLs. In addition, theBCM monitoring wells should also be tested for DNAPLs. Ifpossible, G&M should consider monitoring the Fire Tower well(located at the 120 Mill Street Property), the Farm Bureau welland Whistlewood complex well for DNAPLs because of their depthand location relative to the source.
III. Logging of Existing and Future Boreholes
In G&M's 2/14/92 memo, G&M stated that all future boreholeswould be logged. This was not incorporated into the workplan.The text in Subtasks 3-15 and 3-21 should be modified to statethat all future boreholes will be logged, not just considered forlogging.Logging should be conducted in as many wells as possible.
Because of the problems sometimes associated with downholeTV camera pictures, especially in old holes, it is suggested thatall approved geophysical methods be conducted first and resultsconfirmed with subsequent downhole TV camera pictures.
IV.. Groundwater Sampling
On page 56, it is stated that existing monitoring wells ator near the 120 Mill Street property will be tested for waterquality analysis. It is not clear which specific wells will bemonitored. Because the risk assessor will need information onthe most highly contaminated area, a well close to the suspectedsource (such as the BCM wells or the 120 Mill Street productionwells) should be monitored for the full TCL/TAL. Clarify whichwells are to be sampled.
EPA requested in its March 3, 1992 memo that residentialwells along Rickerts Road, which will be sampled and used during
Task 3, be identified. This was not incorporated into theworkplan.
On page 63, a statement that "Only the background wellsample will be analyzed for both filtered and unfiltered metals."is made. However, all monitoring well samples collected for thepurpose of inorganic analysis should be evaluated for bothfiltered and unfiltered metals.
V.'Packer Testing
' . The term "existing Monitoring Wells" is not adequatelydefined in this Subtask (nor is it defined adequately in othersubtasks- see GENERAL comments, below) . During our 2/11/92meeting, EPA agreed that the 8 G&M monitoring wells be packertested. It is recommended that packer tests also be performed onmonitoring Veils, BCM-1 and BCM-2. In addition, for the reasonslisted in Section II, above, consider packer testing of PW-1, PW-2, the Fire Tower well, the Farm Bureau well and the Whistlewood •complex well.
Provide a contingency in the workplan for installation of abackground well if access to Dublin Well #1 is not obtained.Also, provide a contingency for additional monitoring wells ifaccess to residential wells cannot be obtained. If, by using"best efforts", access to any of these wells can not be obtainedwithin a reasonable timeframe, G&M should be prepared to installthe required background and monitoring wells.
VI. Soil/Sediment Investigation
Since a GC is proposed for use during other portions of theRI (well construction, packer testing, etc.), EPA is recommendingthat the GC, rather than the PID, be used as a scanning deviceduring the soil boring and test pit programs. Provide therationale for using 10 ppm as a cut-off for which samples will besent to the lab.
VII. Use of GC
Appendix E states that the GC will be used during certaintasks during the RI. The appendices in the FSP are not clear onhow the GC will be used during these tasks. Modify the text inthese appendices,
VIII. Groundwater Modelling/ Determination of Extent ofContamination
EPA would like to clarify its position on the use of modelsas the Dublin TCE Site. Although EPA has agreed that theproposed modelling may provide general information on groundwaterflow at the Site, use of MODFLOW and MODPATH at a Site with such
complex hydrogeology as the Dublin TCE Site will not provideinformation to show that:
1. the extent of contaminant migration is not widespreadand is contained within the borough boundaries,
2. the current monitoring well configuration is adequateto detect and monitor any and all contamination at theSite,
3. the horizontal and vertical extent of contamination canbe fully defined, and, hence, the lack of the need toinstall deep wells, and
4. the current well configuration is adequate to captureall contamination in the implementation of an aquiferpump & treat remedy.
The model cannot be used in lieu of collecting adequate datato characterize the Site and answer the issues addressed above.Since MODPATH uses the output of MODFLOW, and is applicable onlyfor steady state conditions, it cannot be applied at this site tosimulate particle tracking. If G&M intends on using the model toaddress the issues listed above, G&M should consider a moreappropriate model.
In the absence of an appropriate model, G&M should directtheir resources towards generating adequate data to characterizethe site rather than model it. Particularly, EPA is interestedin constructing a monitoring well network which will fully definethe horizontal and vertical extent of contamination. G&M shouldindicate the locations of residential and public supply wellswhich could possibly serve as monitoring wells in Figure 18. Ifthere are no appropriate existing wells in these locations, G&Mshould make a firm commitment in Subtask 3-20 to installmonitoring wells in the shaded areas. EPA believes monitoringwells in the areas located on Figure 18 are necessary for thecompletion of the RI/FS.
IX. Schedule
It was EPA's understanding that the proposed 24-monthschedule included the Phase I work. Therefore, EPA believes theproposed work for Phase II can be performed in significantly lesstime than 24 months. EPA will accept a proposed schedule of 18-22 months or less in the final workplan. G&M should considerperforming the groundwater sampling much sooner than proposed.It is not clear why this work will not commence until the 30thweek of the RI. This data can be forwarded to EPA's riskassessor early in the process so that the risk assessment can becompleted in a timely manner. Performance of this samplingshould move the other groundwater investigations up significantly
AR3G06i*9
in the schedule. It is not clear why Task 3*-25 was increased bythree weeks. , ",
Because G&M is performing the soil and air investigationsearly in the process, the need for treatability studies for thesemedia can be assessed early in the RI. Also, since G&M will beperforming aquifer pump tests in Phase I and Phase II, thescreening and detailed analysis of alternatives should be startedearly in the RI/FS process. Beginning this work early shouldreduce the time necessary for completion of the FS report.
X. GENERAL
1. The term "existing monitoring wells" is used throughout therevised RI/FS workplan. Does that refer only to MW-1 through MW-8? What about BCM-1 and BCM-2? These wells should be includedin the monitoring program given their proximity to the probablesource location. Clarification of this term is necessarythroughout the workplan.
2. page 5, last sentence: This sentence should be revised toread: "In addition to TCE, only 1,2-dichloroethene, which wasdetected in two samples at...".
3. page 11, paragraph 1: The rationale for investigating onlythree out of the seven anomalies is inadequate and needs to beexamined further.
4. page 12, paragraph 1: The low TCE readings in B-3 and B-4borings may not mean the absence of a source (or a potentialsource) since boring depths may not have been deep enough.
5. page 14: The Final Record of Decision was signed on December30, 1992.
6. page 19, .paragraph 1: One statement indicates that contaminantconcentrations in surface waters are always lower than those ingroundwater and, therefore, bioaccumulation would not be ofconcern. This premise is not accurate since it implies thatcontaminant migration to surface water is only throughgroundwater neglecting overland (surface) runoff of contaminantsto surface waters. The statement, including conclusions madeform such statement, should be modified. It is premature toconclude that the VOCs in the surface water would not beconcentrated in the biota.
7. page 19: It is stated that "...it is likely that potable useof ground water downgradient of the site will be identified asthe principal exposure pathway of concern." Please note,however, that potential exposure to ground water underlying thesite (under a future residential-use scenario) is also likely tobe a major concern at the site.
3R300650
8. page 32, Subtask 3-1: This task is reported to be completedfor the water supply wells and the monitoring well. EPArequested in its January 29, 1992 memo that G&M collect allavailable well.records and group them according to differences inwell construction and completion. This should be completed atleast after Phase II of the RI.
9. page 65: A description of the process that will be employedin the generation of a final baseline risk assessment ispresented. It should be acknowledged, however, that the exactapproach for producing the baseline risk assessment is stilltentative at this point in time.
The Risk Assessment Guidance for Superfund: Volume I, PartB is listed as "current guidance for the preparation of baselinerisk assessments". This statement is not completely accurate,however. The actual intent of the referenced document is toprovide guidance for calculating risk-based concentrations thatcan be used during the development of preliminary remediationgoals.
It is stated that "Current guidance for the preparation ofremedial risks is the USEPA Risk Assessment Guidance forSuperfund: Volume 1 - Human Health Evaluation Manual (Part C -Risk Evaluation of Remedial Alternatives).11 This statementshould be amended to read: "Current guidance for evaluatingremedial alternatives is the USEPA Risk...".
12. Appendix K (Aquifer Testing Protocol): It is implied that,based on prior data, aquifer testing may not be required. Dataon hydraulic parameters may not be needed until the design stage,however, if G&M intends to model the aquifer during the RI, long-term pump test data will be required.
13. Appendix P (Well Abandonment): Every attempt should be madeto remove well casing prior to abandonment. However, when itbecomes impossible to remove such casings, then all attemptsshould be made to ensure that, in addition to grouting the insideof the well, a complete and permanent seal is created in theannulus between the borehole and the casing.
flR30065|
> GERAGHTY& MILLER, INC.Environmental Services
Ground Water Engineering Hydrocarbon Remediation Education
April 29, 1992
VIA FACSIMILE
Dianne J. WalkerU.S. Environmental Protection AgencyRegion III841 Chestnut BuildingPhiladelphia, Pennsylvania 19107
Re: Dublin TCE SiteDublin, Pennsylvania
Dear Ms. Walker:
We are in receipt of your letter and attachment dated April 22, 1992 regarding thedraft Remedial Investigation/Feasibility Study (RI/FS) work plan dated March 6, 1992 forthe above-referenced site. Based on review of the U.S. Environmental Protection Agency(USEPA) comments and recommendations, we propose the approach discussed below. Thepage and section citations are from the USEPA letter.
p. 1 St. Luke's Church InvestigationSection I. The draft RI/FS work plan text did not state that the sampling would be
performed. However, the samples were included in tables. The finalwork plan text will be revised accordingly.
p. 1 DNAPL TestingSection II. The testing referred to involves monitoring for the presence and thickness
of DNAPLs using a product-water interface probe. In the Memorandumof Understanding to the USEPA dated February 14, 1992, we hadsuggested Production Well PW-2 for monitoring. However, based on afurther review of data, the highest trichloroethene (TCE) concentrationshave been reported for Production Well PW-1. This well (as opposed to
&R300652
201 West Passaic Street, 3rd Floor • Rochelle Park, New Jersey 07662-(201) 909-0700 • 8
2
PW-2) is conveniently out of service and is easily accessible. Accordingly,we have proposed in the revised work plan that PW-1 be substituted forPW-2. The wells proposed for DNAPL monitoring will be explicitlyspecified in the work plan and are as follows: MW-3, MW-4, BCM-1,BCM-2, the Fire Tower Well, PW-1, and the Farm Bureau Well.Monitoring at several of these wells depends on obtaining access fromwell owners. The Whistlewood Supply Well will not be monitored forDNAPLs because it is an active supply well serving the apartmentcomplex. We anticipate that access to this well will be denied.
p. 1 Logging of Existing and Future BoreholesSection III. Subtask 3-15 of the RI/FS work plan provided for borehole geophysical
logging of the eight existing Geraghty & Miller monitoring wells andpossibly selected supply wells. Subtask 3-21 stated that boreholegeophysical logging of any existing wells added to the monitoring network,or newly installed wells will be considered. In response to the USEPA'srequest, the final work plan will be amended to provide for geophysicallogging of all newly installed wells.
As requested by the USEPA, the logging program will be revised toreflect performance of borehole geophysical logging prior to the downholeTV survey.
p. 1-2 Ground-Water SamplingSection IV. The wells "at or near the 120 Mill Street property" proposed for sampling
will be listed in a table. These wells include MW-3, MW-4, BCM-1, theFire Tower Well, the Farm Bureau Well, and Dublin Well No. 1.Sampling of several wells depends on obtaining access from well owners.The Step 1 wells will be sampled and analyzed for a complete parameter
GERAGHTY & MILLER. INC. AR300653
3
suite including metals, pesticides, PCBs, volatile organic compounds, andbase neutral and acid extractable organic compounds.
Figure 17 was provided in the RI/FS work plan in response to the
USEPA's request of March 3, 1992 to identify residential wells alongRickerts Road proposed for sampling. The figure depicted the locationof properties where we propose to do well sampling. In response to theUSEPA's request of April 22, 1992, we will provide in the final work planadditional details, including the name of the property owner and theproperty address. The Townships of Hilltown and Bedminster do notmaintain well records. Records for selected wells are available from othersources, including the U.S. Geological Survey and the Delaware RiverBasin Commission. However, these records are incomplete and aretypically for higher yielding wells. Therefore, we will need to completea survey of the property owners in an attempt to obtain well constructiondetails. The survey will be performed prior to or at the time of sampling.
As requested, all monitoring well samples will be analyzed for bothfiltered and unfiltered samples.
p. 2 Packer TestingSection V. The USEPA has recommended that packer tests be performed on
Monitoring Wells BCM-1 and BCM-2 and that tests be considered forPW-1, PW-2, the Fire Tower Well, the Farm Bureau Well, and theWhistlewood Complex Well (Whistlewood Supply Well), in addition to theeight existing monitoring wells (MW-1 through MW-8) installed byGeraghty & Miller. We have developed an approach based on theUSEPA's recommendations. Packer tests will be performed on BCM-1but not on BCM-2. Detailed drilling logs available for these wellsindicate that both are the same depth with a major fracture ftlRi3f&8si 5 4
GERAGHTY & MILLER. INC.
4
BCM-1. Water-quality results also indicate that the TCE concentrationin BCM-1 (17,500 parts per billion [ppb]) was significantly higher than inBCM-2 (313 ppb). We propose to extrapolate the results of packertesting on BCM-1 to BCM-2. It will not be possible to perform packertests on PW-1 and PW-2 because they are located inside a building andthere is insufficient access for the necessary testing equipment. Also, itwill not be possible to packer test the Whistlewood Supply Well, becauseit is in service and supplies 144 dwelling units. The Fire Tower or theFarm Bureau well will be packer tested pending necessary accessagreements. The well selection (Fire Tower or Farm Bureau) will initiallybe based on results of DNAPL monitoring and water-level monitoring.If the preferred well cannot be tested because access is denied, thealternate well will be pursued. In summary, the wells for packer testinginclude, in addition to the eight existing Geraghty & Miller monitoringwells (MW-1 through MW-8), BCM-1, the Fire Tower or Farm Bureauwell, and Dublin Well No. 1. As with other aspects of the RI, if resultsindicate that additional investigation may be useful, the RI will be tailoredaccordingly, with the concurrence of the USEPA. The RI must retainsome flexibility because subsequent tasks/subtasks build upon earliergenerated data.
The work plan tasks must also retain flexibility in the scope of work in the
background monitoring well and other monitoring wells. Subtask 3-19 ofthe RI/FS work plan stated that "If there are insufficient suitable existingwells, or if access to potential wells is not possible, additional wells willbe installed". Upon failure to gain access to existing wells suitable for themonitoring, the USEPA would be promptly notified and a contingencyplan will be provided. The selection of the monitoring network dependsupon access and data generated in earlier subtasks. Therefore, it ispremature to develop such a contingency plan at present. However, the
GERAGHTY & MILLER. INC.
5
criteria used in selecting the wells will be the same throughout theprocess. The RI/FS is flexible and the exact monitoring network will be*
developed as the program progresses.
p. 2 Soil/Sediment InvestigationSection VI. The portable gas chromatograph (GC) will be included as a soil screening
tool in the Subsurface Investigation subtask. While a more detaileddescription of its use will be provided in the revised work plan documents,a brief description is included here.
During the excavation of on-site test pits, each backhoe bucket of
excavated material will be scanned with a photoionization detector (PID).Samples will be taken for GC analysis if a PID reading of 10 parts per
. million (ppm) or greater is registered from material within the bucket; orexcavated material exhibits unusual odors and/or coloration. If no.sampling is triggered by PID readings or other observations, one samplefor approximately 10 cubic yards will be analyzed.
During drilling of soil borings, samples from the 12 to 18-inch depthinterval, the greatest depth split-spoon sample of each boring, anymaterial exhibiting unusual odors or coloration, and any materialregistering 10 ppm or greater on the PID will be retained for GC analysis.The 10 ppm level for sample collection has been chosen to account forthe variability of detector readings. The PID can be affected by highhumidity, soil moisture and naturally occurring compounds. The 10 ppmlevel may be adjusted as the program progresses and PID results can becompared to GC-generated results.
The selection of samples for confirmatory laboratory analysis will bebased on PID readings, GC results, and field observations.
4R300656GERAGHTY & MILLER. INC.
p. 2 Use of GCSection VII. Additional explanation will be provided in the FSP appendices.
p. 2-3 Ground Water Modeling/Determination of Extent of ContaminationSection VIII. Geraghty & Miller, Inc. would like to clarify its position with regard to the
modeling approach and the objectives that we plan to accomplish. TheUSEPA lists four objectives of the proposed modeling effort that are notan accurate reflection of our position. We do not intend, and did notstate, that the model would delineate the extent of contamination norprovide a method to substantiate the suitability of the water-qualitymonitoring network through the use of model simulations. Furthermore,we have not stated that the model is capable of providing information toshow that "the extent of contaminant migration is not widespread and iscontained within the borough boundaries." Nor did we state that themodel would provide results to show that "the current well configurationis adequate to capture all contamination in the implementation of anaquifer pump and treat remedy."
Geraghty & Miller, Inc. recognizes the fact that the use of MODFLOWand MODPATH to simulate steady-state ground-water flow patterns isonly an approximation of real-world conditions. However, in ourjudgement, MODFLOW and MODPATH are the most appropriate codesto apply to the fractured bedrock system underlying Dublin Borough forthe purposes of 1) assisting the field investigation to delineate the plumeextent, and 2) evaluating the effectiveness of various extraction-wellcontaminant recovery scenarios. The modeling strategy outlined in theRI/FS work plan has the following strengths:
• MODFLOW can simulate the three-dimensionalDarcian flow features that previous studies
GERAGHTY # MILLER, INC
(International Exploration Inc. 19851, Rooney 19862)have documented on a basin-wide scale (beneath theDeep Run and Morris Run Watershed).
• Advective movement of dissolved TCE in groundwater becomes the dominant transport processbeneath Dublin due to the drawdown induced bymajor supply wells.
• MODPATH simulates the "real world" contaminantmigration along flowpaths that converge on thesepumping wells.
• Capture zone analyses are the most appropriate.•technique to determine the number and location of• recovery wells, and the optimum pumping rate of
these wells.
• The modeling provides a technique to test several pumpingscenarios in an efficient manner that would not be feasiblesolely through the use of field techniques.
• MODPATH and capture zone analysis provide adequatesupport in determining which existing wells could be used forremediation and whether new wells need to be installed.
International Exploration, Inc. 1985. Analysis of Hydrologic Data gathered in 1984 forthe Dublin Study Area. February 12, 1985.
2Rooney, J.G. 1986. Development of Water Supplies from Triassic Rocks in DublinBorough and Adjacent Area. Bucks County, Pennsylvania. August 24, 1986.
GERAGHTY & MILLER. INC.
8Any recovery-well scheme will utilize model results, with an appropriatesafety factor. This would account for uncertainty in model assumptionsand results.
We recognize the USEPA's interest in constructing a monitoring wellnetwork which will fully define the horizontal and vertical extent of TCEcontamination. We share the USEPA's interest in defining the extent ofTCE contamination to the extent practicable. However, due to thecomplexities of the bedrock aquifer, and potential limited access toexisting private wells and new drilling sites, full definition of the TCEplume may not be feasible.
p. 3 . ScheduleSection DC. In response to the USEPA request to compress the RI/FS schedule, the
schedule will be revised to a 22-month duration. As the USEPArequested, the ground-water sampling subtask will be accordingly movedto an earlier part of the investigation. The need for any ground-watertreatability studies will be assessed earlier in the investigation. Thedetailed analysis of remedial alternatives will be similarly initiated earlierin the RI/FS. In response to the USEPA's statement regarding Subtask3-25, the duration of the subtask was increased to provide for preparationof a pumping test plan for submittal to the USEPA as part of the requirednotification.
p. 4 GeneralSection X.Item 1 . For each subtask where monitoring wells are referred to as being
investigated, the proposed wells will be listed.
Item 2 The sentence referred to on page 5 will be revised as requested.
GERAGHTY # MILLER. INC.
9
Item 3 The text of the work plan stated that four of the seven geophysicalanomalies resulted from close proximity to buildings and/or surficialmetal objects. In the report, "Results of Source Investigation, 120 MillStreet Site, Dublin Borough, Pennsylvania1" by Geraghty & Miller, Inc.,June 1990, these anomalies were attributed to interference by knownstructures (buildings, underground storage tank). Additional discussionwith regard to this investigation is included in the above-referencedreport.
Item 4 We would like to clarify that we did not state that the low TCEconcentrations in borings B-3 and B-4 reflected the absence of a source.
Item 5 The date of signing of the ROD will be changed to December 30, 1991,rather than December 30, 1992 as stated by the USEPA.
Item 6 The statement on bioaccumulation will be reworded as follows: "TheVOCs detected in the ground water have relatively low bioconcentrationfactors (less than 100 L/kg) which is an indication that higherconcentrations of these VOCs in the biota are unlikely. Therefore, anyVOCs potentially seeping into the surface water are not expected to bemagnified in aquatic organisms".
p.5 The statement will be modified by adding "beneath or" between the wordsItem 7 "ground water" and "downgradient".
Item 8 The USEPA requested in their correspondence to Sequa dated January29, 1992 that "the current ground water monitoring wells will need to be
xGeraghty & Miller, Inc. 1990. Results of Source Investigation, 120 Mill Street Site,Dublin Borough, Pennsylvania. June 1990.
GERAGHTY & MILLER, INC. ' ^^300660
10
.put into groups with respect to differences in monitoring wellconstruction..." The USEPA correspondence to Sequa dated April 22,1992 states that all available well records be so grouped at least afterPhase II of the RI. The well grouping will be completed as USEPArequested and included in the RI report.
Item 9 The discussion on page 65 identifies standard guidance documents and1st Paragraph does not identify a rigid process that will be followed. No necessary
modification to the work plan could be identified.
Item 9 The statement will be revised by removing the reference to the Part B2nd Paragraph guidance manual from the existing statement and following that revised
statement with this new sentence: "The manual "Risk AssessmentGuidance for Superfund: Volume I Part B - Development of Risk-basedPreliminary Remediation Goals" (USEPA 1991c) will provide guidance forcalculating risk-based concentrations that can be used during thedevelopment of preliminary remediation goals".
Item 9 The statement will be amended as requested to read "Current guidance3rd Paragraph for evaluating remedial alternatives is the USEPA Risk...".
Items 10 and 11 There were no comments identified by 10 and 11.
Item 12 We acknowledge that aquifer testing will be required as part of theRI/FS. The text will be revised to reflect our intent.
Item 13 Prior to well abandonment, we will attempt to remove the well casings.The text will be revised accordingly.
GERAGHTY & MILLER, INC.
11We understand that the Quality Assurance Project Plan and the Health and Safety
Plan have been approved. Due to the changes in the RI/FS work plan these documents willrequire technical and typographical changes. Accordingly, on the date of submittal of theRI/FS work plan we plan to provide revised, final copies of these documents.
Please advise us immediately upon review whether there are any outstanding issuesresulting from this letter so that we may finalize the work plan due on May 8, 1992. If youhave any questions or require additional information, please contact us.
Sincerely,
GERAGHTY & MILLER, INC.
Barbara A. DolceSenior Scientist
Joseph Minster, C.P.G.Project Director
c: Charles R. Galiszewski - SequaJohn P. Judge, Esq. - Cohen, Shapiro
BAD:emw/mtb#NJ14301-wp5/042492.1tr
GERAGHTY # MILLER, INC. 3(30662
^BTGERAGHTY# MILLER, INC.Environmental Services
Ground Water Engineering Hydrocarbon Remediation
May 1, 1992
VIA FACSIMILE
Dianne J. WalkerU.S. Environmental Protection AgencyRegion III841 Chestnut BuildingPhiladelphia, Pennsylvania 19107
Re: Dublin TCE SiteDublin, Pennsylvania
Dear Ms. Walker:
We are writing to confirm details of your telephone conversation with Barbara Dolceon April 30, 1992. The conversation was in regard to our letter to you dated April 29, 1992.The letter described our proposed revisions to the Remedial Investigation/Feasibility Study(RI/FS) Work Plan and Field Sampling Plan based on the U.S. Environmental ProtectionAgency's (USEPA) recommendations of April 22, 1992. It was agreed that the approachwe described will be acceptable to the USEPA for the final RI/FS Work Plan and FieldSampling Plan with one exception. You requested that we clarify the objectives of themodeling.
As we discussed, a proposed revision to the RI/FS Work Plan text on the modelingis provided with this letter for your review. The proposed revision to the existing text isshown in boldface type. It was agreed that the USEPA would contact Geraghty & Miller,Inc. on Monday, May 4 with their approval or comments on the revised modeling text. Theproposed revision to Subtask 3-5. Ground-Water Modeling appears below.
201 West Passaic Street, 3rd Floor • Rochelle Park, New Jersey 07662-(201) 909-0700 > g(Q Q C C o
GERAGHTY & MILLER, INC.
"Following an evaluation of Subtasks 3-1 through 3-4, a three-dimensional numerical ground-water flow model and particle trackingcomputer codes will be used to evaluate various remedial pumping scenariosfor the site. The USGS Modular Three-Dimensional Finite DifferenceGround Water Flow Model (MODFLOW) (McDonald and Harbaugh 1984)will be used to simulate ground-water flow and the USGS particle trackingpost-processor (MODPATH) (Pollock 1989) to simulate three-dimensionalground-water flow paths at the site.. Because of the inherent complexitiesassociated with this fractured bedrock system and the assumptions that will bemade regarding aquifer parameters, boundary conditions, and diffuse.(Darcian) aquifer flow, the goal of the modeling effort will be to generallyreproduce the observed ground-water hydraulic gradients and flow directions
. which have been observed at the site. Lack' of site-specific data and acomplete understanding of the hydrogeologic nature of the aquifer precludea formal calibration. Use of MODPATH provides a method of conceptuallysimulating the transport of a conservative solute species solely under theinfluence of advection. The model input will rely on available hydrogeologicdata including ground-water elevation contour maps developed from water-
V
level measurements collected during the investigation and published aquiferproperties developed from aquifer tests conducted by previous investigatorsat and near the site.
These simulations will provide insight into the aquifer response topotential recovery well schemes, and can be used along with aquifer testresults to help evaluate remedial strategies. Although the modeling resultswill only be an approximate representation of real world conditions, they canbe a useful aid in performing the limited objective of evaluating severalpumping scenarios in an efficient manner. The results can be used as onecomponent of the overall investigation to progress toward a morecomprehensive understanding of the aquifer response and advective
GERAGHTY & MILLER, INC.
3
movement of contaminants induced by hydraulic stresses imposed bypotential supply/recovery wells.
The model output will be a series of representations illustrating theextent of hydraulic control imposed on the ground-water system resulting frompumping at various well locations and discharge rates. The preliminarymodeling conducted under this task will form the basis for collection ofadditional field data as needed and will be improved as new hydrogeologicdata become available during the RI process. In addition to the standardhard copy report, a computer disk containing all input and output data will beprovided to PADER and the USEPA.
., We look forward to hearing from you on Monday.
Sincerely,
GERAGHTY & MILLER, INC.
Barbara A. DolceSenior Scientist/Project Manager
Joseph Minster, C.P.G.Project Director/Project Officer
c: Charles R. Galiszewski - SequaJohn P. Judge, Esq. - Cohen, ShapiroDave Kargbo - USEPA
BAD/mtb#NJ14301-wp5/OS0192.1tr
(c
APPENDIX B
CONSTRUCTION DIAGRAMS AND GEOLOGIC LOGSOF MONITORING WELLS
GERAGHTY & MILLER, INC.
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• 8-INCH DIAMETEROPEN HOLE
MONITORING WELLARGILLITE
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WATER-BEARING FRACTURE ZONE
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BCM WELL DRILLING LOG
PROJECT: Thompson Properties
WELL NO: MW-1
SHEET 1 OF:
PROJECT NO: 56
WELL LOCATION: Behind Building 1 DRILLED 5/20/88
DRILLING CONTRACTOR: Empire Soil Investigations METHOD RotaryBORINGDIAMETER:
cJ
SAMPLINGMETHOD: NA SAMPLE NAINTERVAL:
LOGGED BY: Robert Wyatt TOTALDEPTH: 100
SCREEN SIZEAND MATERIAL: NA
SCREENEDINTERVAL:
CASING SIZEAND MATERIAL: NA
CASEDINTERVAL: 20' -0'
GRAVELPACK SIZE:
PACKEDINTERVAL: NA
GROUT TYPE: NA GROUTEDINTERVAL:
GROUTINGMETHOD: NA
BENTONITESEAL: NA
DEVELOPMENT TIME:METHOD:
ESTIMATEDYIELD:
STATICWATER DEPTH: DATE: REFERENCE:
REMARKS:
LITHOLOGICINTERVAL
SAMPLEINTERVAL SPOON BLOWS RECOV-
ERYfIN.)
CLASSIFICATION OF MATERIALS
0-5
5-9
9-10
10-11
11-17
17-20
SILT AND CLAY; some fine to medium sand sizepieces of shale, red, dry.
FINE TO COARSE SAND SIZE PIECES OF SHALE; somefine angular gravel size shale pieces, somesilt and clay, red.
FINE TO MEDIUM GRAVEL SIZE SHALE FRAGMENTS;weathered bedrock zone, trace silt, darkgreenishgray/red.
GRAVEL SIZE SHALE FRAGMENTS; gray, bedrock.
FINE SAND TO MEDIUM GRAVEL SIZE SHALE FRAGMENTSgray, Wet at 12.5'.SAND AND GRAVEL SIZE SHALE FRAGMENTS: lesround, harder rock, dark gray/black.
AR300675
MW-1 r 2 3
LITHOLOGICINTERVAL
20-22
22-23.5
• 23.5-34
34-34.5
34.5-35
35-37
37-38
38-39.5
39.5-43
43-44.5
44.5-45
45-48
48-55
55-59
59-61
61-61.5
61.5-66
66-72
72-75
75-76
76-
76-76.1
76.1-79
79-88
88-90
. SAMPLEINTERVAL
.
SPOON BLOWS
i
oni=[-. i i if:
RECOV-ERY(in.)
<
<
CLASSIFICATION
SHALE; soft, dark gray.
SHALE; slightly weathered, soft, light gray/ta
SHALE; hard, light medium gray.
SHALE; soft, light gray. , __SHALE; hard, red.
SHALE; hard, red and gray.
SHALE; hard, gray, trace red.
SHALE; hard, gray.
SHALE; soft, gray/tan. "
SHALE,; weathered appearance, soft, tan/yellow/gray.
SHALE; soft, dark gray/black.
SHALE; soft, gray.
SHALE; hard, gray.
SHALE; very hard, red.
SHALE; hard, gray.
SHALE; very hard, red.
SHALE; hard, gray.
SHALE; hard, red and gray.
SHALE; hard, red.
SHALE; hard, red and gray.
MAJOR PRODUCING FRACTURE, black shale on top,red shale beneath.
SHALE; hard, red.
SHALE; soft black and hard red.
5HALE; very hard, red, little black.
5HALE; hard, red, little soft black shale.
^300676
HW'1 SHHET-LOF
LITHOLOGICINTERVAL
90-97
97-100
SAMPLEINTERVAL
-
SPOON BLOWS RECOV-ERY(irt)
CLASSIFICATION ^^
SHALE; very hard, red.
SHALE; soft, red.
•
•
AR3G0677
BCM WELL DRILLING LOG
PROJECT: Thompson properties
WELL LOCATION: Driveway, NE of Building 1
DRILLING CONTRACTOR: Emp1>e Soil InvestigationSBORING , SAMPLINGDIAMETER: 5 3/4" METHOD: NALOGGED BY: Robert WyattSCREEN SIZEAND MATERIAL: NACASING SIZEAND MATERIAL: NAGRAVEL ...PACK SIZE: NAGROUT TYPE: - . N£
GROUTING ...METHOD: NADEVELOPMENT TIMP.METHOD: MM '
WELL NO: Mw_2SHEET i OF: 2 .
PROJECT NO: 5fifl1_n?
DATE(S) 5/20/88DRILLED b/^u/B8DRILLINGMETHOD Air RotarySAMPLEINTERVAL: NATOTALDEPTH: 100SCREENEDINTERVAL: NACASEDINTERVAL: 20'-0IPACKEDINTERVAL: NA .GROUTEDINTERVAL: 20 -0'BENTONITESEAL: NAESTIMATEDYIELD:
STATIC oATC. HPPPRFNTP.'WATER DEPTH: DATE* REFERENCE:.REMARKS: . ' ;
LITHOLOGICINTERVAL
0-8
8-12
12-13
13-14.5
14.5-16.5
16.5-17
17-20
SAMPLEINTERVAL SPOON BLOWS RECOV-
ERYfIN.)
CLASSIFICATION OF MATERIALS
SILT AND CLAY; some sand and gravel size shal?fragments, red.
SAND AND GRAVEL SIZE SHALE FRAGMENTS; some sf"
SAND AND GRAVEL SIZE SHALE FRAGEMTS; bedrock,tan/gray.
COMPETENT BEDROCK; sand and gravel size frag-ments, gray.
SHALE; hard, fissile, gray/blue.
SHALE; soft, some silt, greenish/tan to reddisbrown.
SHALE; hard, fissile, light gray, wet at 19feet.
4R30Q678
MW-2 ' -WELL NO. ________ SHEET _£_OF:__L
LITHOLOGICINTERVAL
20-34
34-38
38-42
42-45.5
45.5-46.5
48.5-52
52-55
55-57
57-60 .
60-60.5
60.5-61
61-62.5
62.5-65
65-73
73-74
74-83
83-84.5
,84.5-100
SAMPLEINTERVAL SPOON BLOWS
••
RECOV-ERY(in.)
CLASSIFICATION ^^
SHALE; hard, gray, dry.
SHALE; soft, gray, wet at 37 feet.
SHALE; hard, gray/light gray, dry.
SHALE; soft, gray/yellow, dry.
SHALE; soft, weathered appearance, some silt,brown/red/gray, wet.
SHALE; hard, red and gray, wet.
SHALE; soft, dark gray, wet.
SHALE; soft, red, wet.
SHALE; hard, red, wet.
SILTSTONE WITH MICA; hard, red, wet.
SHALE; hard, gray/dark gray, wet. ^^
SHALE; hard, red and gray, wet, ^^
SHALE; hard, gray/blue.
SHALE; hard, red, little gray shale, wet.
SHALE; soft, gray/dark gray, wet.
SHALE; hard, red, wet.
SHALE; soft, gray, wet.
SHALE; hard, red, few thin gray bands, wet.
flR3u0679
APPENDIX C
WASTE HANDLING PROTOCOLS
GERAGHTY & MILLER, INC. ^ H J 0 0 6 8 Q
APPENDIX CWASTE HANDLING PROTOCOLS
INTRODUCTION
The field investigation activities may generate potentially contaminated andcontaminated materials. This appendix describes the various waste materials and outlinesthe plans for their management.
SOURCES OF WASTE MATERIALS
During all phases of the field investigation, proper procedures will be followed inmanaging any wastes that are suspected or are known to be contaminated. These wasteswill include decontamination solutions, disposable personal protective equipment, drillcuttings, well-drilling water, well-development water, well-purging water, and aquiferpumping test discharge water.
DECONTAMINATION FLUIDS
Fluids generated from the decontamination of drilling and sampling equipment,downhole geophysics and packer testing equipment, well casings, personnel, backhoes, anddrilling rigs will be transferred to and stored in 55-gallon drums or a storage tank(s) locatedat or near the 120 Mill Street property. Any solids generated during decontaminationprocedures will be placed in 55-gallon drums for storage.
DISPOSABLE EQUIPMENT
Any potentially contaminated disposable equipment will be stored in 55-gallon drumsequipped with removable lids. Disposable equipment includes rubber gloves, boots, brokensample containers, and chemically resistant clothing.
GERAGHTY & MILLER, INC. flR3G068f
C-2
DRILL CUTTINGS
A plastic tarp will be placed around the location of any test/observation wells beforedrilling is initiated. The tarp will be adequately sized and bermed so as to contain anycuttings or fluids generated during advancement of the well. The area surrounding the wellwill be contoured so that ground water that is forced out of the well during drilling will becentralized and directed away from the drilling location. This design will include a channelwithin which the volume of water may be measured and through which it may be directedto a collection location. As necessary, collected drill cuttings will be placed in drums orcovered piles.
WATER FROM WELL DRILLING, WELL DEVELOPMENT, WELL PURGING, ANDAQUIFER PUMPING TESTS
All fluids pumped from a well during drilling development, purging, and aquifertesting will be properly contained. During these tasks, the fluids will be pumped directly
from the well to a containment tank for transport to the 120 Mill Street property. If the testwell is proximal to the 120 Mill Street property, the feasibility of pumping the dischargedirectly will be assessed. All water from well drilling, well development, well purging, andaquifer tests will be managed in accordance with Tile 25, Pennsylvania Code, Chapters 91and 92.
WASTE STORAGE AND MANAGEMENT
The field investigation is understood to be an on-site response action being conductedpursuant to Sections 104 and 122 of the Comprehensive Environmental Response,Compensation and Liability Act (CERCLA) of 1980, as amended. As such, all wastes willbe managed in accordance with 40 CFR 300.400, subparagraph E.
GERAGHTY & MILLER, INC. " "
The site for which this response action is being conducted is understood to bebounded by the areal extent of the trichloroethene plume. All wastes generated within thesite will be placed into appropriate receptacles and labeled. Labels will contain informationwith regard to the type and source of waste, generator, and date of collection.Containerized wastes will be transported to the storage facility at the 120 Mill Streetproperty at the end of each working day. The storage facility will conform to all ResourceConservation and Recovery Act (RCRA) regulations.
WASTE DISPOSAL
Samples of drummed drill cuttings will be collected and analyzed for volatile organiccompounds (VOCs). One composite sample will be collected for every 100 cubic yards ofmaterial. The composite will consist of 5 aliquots, each of which will represent no greaterthan 20 cubic yards. The drill cuttings will be disposed in a manner consistent with theanalytical results.
The drummed disposable equipment will be disposed according to its hazard. Oncea drum is filled, a sample of the material will be collected for classification analysis. Iflaboratory analysis determines the drummed waste to be hazardous, it will be handled assuch, and disposed at a licensed hazardous waste disposal facility. If deemed non-hazardous,the drummed waste will be appropriately handled and disposed as an industrial waste.
The well drilling, well development, and well purging water, as well as the pumpingtest effluent will be treated by the granular activated carbon (GAC) system at the 120 MillStreet property. Following treatment, the effluent will be handled in a manner consistentwith Pennsylvania Department of Environmental Resources (PADER) regulations. Anattempt will be made to gain approval for the discharge of the treated effluent into themunicipal sanitary sewer. If such approval is not granted, approval will be sought todischarge the treated effluent to the storm-water drainage system, which is part of thesurface discharge of the area, The method of treatment for the pumping test effluent will
GERAGHTY & MILLER, INC. ^ n J Ll Q 6 8 3
C-3 .
C-4
be contingent upon the location of the test well. If the test well is proximal to the 120 MillStreet property, the pumping test effluent will be pumped directly through a hose or othertemporary conveyance. At the 120 Mill Street properly, the effluent will be pumped throughthe existing GAC treatment system.
If the test well is too far from the 120 Mill Street property to feasibly pump to on-sitetreatment, one of the following two alternatives will be carried out: (1) pump the effluentinto tanker trucks and transport the water back to the 120 Mill Street property fortreatment, or (2) construct a temporary treatment system (air stripping tower or GACsystem) near the test well for effluent treatment. The selection of an alternative, ifnecessary, will be based upon such factors as the pumping rate, the distance of the test wellto a paved roadway, or the distance of the test well to a storm-water ditch or sewer.
The treatability of the pumping test effluent will be studied, based upon datacollected during the step-drawdown (step) pumping test conducted prior to the constant-ratepumping test. During the step test, a representative volume of the discharge will be runthrough the chosen treatment system. Samples of the influent and effluent will be collectedand analyzed to confirm adequate treatment.
*
If a GAC system is used, an analysis of carbon usage will be conducted once thedischarge rate for the pumping test is established. By using the established pumping rateand anticipated or possible volatile concentrations, the factor of safety provided by thecurrent GAC system will be established. If the present system is deemed inadequate, it willbe sufficiently upgraded. As an added safety factor, confirmatory sampling and analysis willbe conducted during the test. The treatment system effluent will be sampled and analyzedon-site with a portable gas chromatograph (GC). If the GC indicates breakthrough ofVOCs, the system will be shut down for immediate carbon replacement. The GC samplingfrequency will be determined based upon pumping rate and contaminant concentrations.
GERAGHTY & MILLER, INC.
If air stripping is used, an appropriately sized tower will be erected. The tower willbe sized according to the pumping rate and expected volatile concentrations. Confirmatorysampling and analysis will be conducted during the pumping test. The treatment systemeffluent will be sampled prior to discharge to the storm-water ditch or sewer. The sampleswill be analyzed on-site with a portable GC. If the GC results indicate a breakthrough ofVOCs, the system will be shut down or replaced with a standby unit. The GC samplingfrequency will be based upon pumping rate and contaminant concentrations.
#NJ14301-WP2/WastHandApp
GERAGHTY & MILLER, INC. 'IR300685
