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August 21, 1985
Edward C. Lain/, Esq. Archer & Greiner One Centennial Square _ Haddonfield, New Jersey 08033
RE: Initial comments on Goose Farm RI/FS
Dear Ed:
consultant, TRIA. r f ,u. RT/FS is its failure to diligently search out
tr M S^iai 3&rS*£-« sca'dd UP to detailed technical scrutiny.
The attached report also """ins ©os^ Far*1 site!"8 Development of these appropriate remedial options f nn»liminarv at this juncture, yet even at alternative remedial options is on y p • . these containment-based this level of evaluation, it is clear unau alternatives are worthy of further consideration. If you have any donations on the attached report, please do not hesitate to contact us.
Very truly yours,
AWARE Incorporated
Robert D. Mutch, Jr., P.HG., P.E. Vice President
TABLE OF CONTENTS
Letter of Transmittal
1.0 INTRODUCTION
2.0 GENERAL COMMENTS ON THE RI/FS
3.0 SPECIFIC COMMENTS ON THE RI
4.0 SPECIFIC COMMENTS ON THE FS 4.1 Absence of Quantitative Remedial Objectives
4.2 Evaluation of Recommended Remedial Alternative #4
Page
1
2 4
7
7
8
16
8 4.2.1 Technical Evaluation !5 4.2.2 Cost Evaluation
4 3 Evaluation of Remaining TRIA Remedial Alternatives 16
4.3.1 Technical Evaluation 18 4.3.2 Cost Evaluation
5.0 Preliminary assessment of Other Remedial Options
5.1 Description of Additional Alternatives
5.2 In-Situ Biological Treatment Applications
6.0 Conclusions LIST OF TABLES
Table 1 - Esti»ated Retardation factors (R) for Principal Goose Far. Contaminants
21
23
26
27
Following Page
12
4 15 Table 2 - Estimated Construction Cost of Alternative No.
19
24 Table 3 - Cost Estimate, RCRA On-Site Landfill
Table 4 - Alternative No. 9, Construction Costs
Table 5 - Alternative No. 10, Construction Costs . 1 .leaf Elected Goose Farm Remedial Options Table 6 - Comparative Analysis of 5electea wow
25
27
1
l.o INTRODUCTION * remedial investigation/feasibility stud, <RI/FS> Goose Farm, site in Plumsted Township, N<J* tQ the New Jersey Department a consortium of three consultants und Waste Management, Hazardous Site of Environmental Protection, Division _orfnrraino the work is termed TRIA Mitigation Administration. The consortium theInc° (OT)# Geomet and consists of Elson T KilanVash«rs and cJaham, Inc. (LBC). Technology, Inc. (GTI), and Leggette, rect. The work of TRIA is Elson T. Killam acts as prime contractor for the project. embodied in three documents: 1. Draft II. Task Medial Investigation. Volume 1 : Main Report. Jul, 12.
1985 2. Draft II, Task 2-Remedial Investigation, Volume 2 - Appendix A, June 1985
3. Draft II, Feasibility Study, July 12, 1985
AWARE incorporated has been retained "°r»"-Thiokol to re,ie: th^Goose Farm RI/FS and to comment on its ^'performing this, """"a number3 o" documents have also been consulted. These include the following: 1. Wehran Engineering. Supplemental Investigation of the Goose Far. Site, May
1985 _ . inalvtieal Results, Groundwater Monitoring Wells, 2. Wehran Engineering, Analytical
Goose Farm Site, March 1985. 3. Wehran Engineering. Analytical Results. Soil Samples - Volume 1. Goose
Farm Site, March 1985 A. Wehran Engineering. Analytical Results. Soil Samples - Volume 2. Goose
Farm Site, March 1985 5. Wehran Engineering. Analytical Results. Soil Samples - Volume 3. Goose
Farm Site, March 1985 6. Wehran Engineering. Analytical Results. Soil Samples - Volume A, Goose
Farm Site, March 1985. y. FMC A,uifer Remediation Systems. Site Assessment Report for the Goose
Farms Hazardous Waste Site, June 27, 1985
In addition to the above-referenced^reports^AWAREphas the earlier information develop ocLsions and has participated as a subcontractor t'oWtrTn Earing in the proration of the above-referenced Wehran Engineering documents.
2
2.0 GENERAL CCWENTS ON THE Rl/rS
Without question, the most striking feature of the ^"^^gyremedy for the failure to mount ~£h £01- ""Si r,, like a thread Goose Farm site. It is this lack or aii g reaardins the remedial through most of the comments - site. The feasibility study investigation/feasibility study of the Goos _ ^ gite> Qnly twQ looks at only eight remedial alternati es National Contingency more than the minimum six alternatives ndated by Che »•£>«• i Plan. Further, the alternative remedial programs are 8lven ' evaluation and are developed in a purely conceptual manner.
Remedial objectives or performance goals are se^performance conceptual terms. No effort has been made to obj;ctives are standards and objectives for the reme p ^ feasibility study the starting point for a feasibility \st y. most cost-effective way becomes an engineering evaluation and seat erandards a feasibility study of attaining those goals. Without quantitative standards a feasi^ ^ flounders for lack of direction. The Goose Farm failure to set performance objectives
The remedial investigation is similarly unquantitative. iSoconcentration generate enough new data or to site! "o estimates are made contour maps depicting contaminant nlume of contamination. No of the amount of contaminated groundwater in the plume or conta estimates are mad. of the amount of 8™undwat.r 'low '0, t impact on stratigraphy of the site has been largely ignored in terms or ^ ^ groundwater flow. Illustrative o t is permeability tests regardless stratigraphy is the indiscriminate 8™"p g differentiace between true soil of formation. The consultants . u0 estimates were made of contamination and groundwater-borne con contaminants in the groundwater the degree of retardation of ^'/"""^^""^"lycritica! since the system. This ls«er deficiency^o^^ contamination flushing and plume r.r, and creatmenc. The retardation factor (*> -ill dictate the rate of
flushing of contamination from the plume.
It is also perplexing that in . site where soi 1 recovery are recommended why a tives< gven a relatively simple development of feasible remedi , . . immenSeiy helpful in conceptualizing two-dimensional hydrologie mode w The olace for computer modeling of and testing various remedial strategies. Th«• « p 5tad,f not the groundwater-related re™®^ opt .° conputer model can hot only -test out and subsequent engineering design. The comp _ _ recovery and recharge evaluate the effectiveness of various \0 unusually options, but can often lead one bJlieved that the absence of computer ^feling'fn'the'Goose Farm feasibility study has been a serious omission.
sr™.r».M:r';rrsr:;s -a 2
3
of a remedial alternative which seems time fr|me projected in the of performance objectives and certainly an tg.month period of soil RI/FS. The remedial plan after which presumably the aquifer flushing and plume recovery and treatme , demonstrated ind sit. would be sufficiently r«o.a"."^will £l^ £or ,u but subsequently, it is our belief that this p ^ the fact that the the most relaxed of performance standard. groundwater contaminants will consultants have assumed that the soil and the 18-month either be flushed relatively rapidly fro»thesystem.^i u„realistic period, or will be permanently bound up in he sot . ^ Farm soils and and. in fact, a dangerous assumption. -1" d inorganic contaminants groundwater contain a complex suite ? times of flushing span the Shone retardation factors and. consequently, times ° source, TRIA has mobility spectrum. By underestimating th« "J" on relatively rapid
srssu srsSf^^sr ^ -ot months but many years, even
decades. TRIA also assumes that treatment can be e»ected b, means of a Related activated carbon syst». It a s Pp,.r t rthiSn»s^ptM_ »
inadequacies3" a simple GAC plant wlil be addressed in later sections of this document.
4
3.0 SPECIFIC GOWffiNTS ON THE RI
EtSfrShS 2X 3^52.s3s ™i""°" another to the unquantitative nature of the remedial investigate .
1. The RI fails to present an isoconcentration contour map of the plume of groundwater contamination. An isoconcentration con ou xtie RI deoicts the distribution of contaminant levels within the plum . 2 s not ev delineate the full spatial -tent of the plume TRIA states "The areal limits of contaminated groundwater cannot be a y defined because of the limited number of samples. (Appendix A, page ij. It difficult to fathom why in a remedial investigation of a National anting"; List sit. sufficient ss.pl*i csnnot be ^.nu^define at
riot a .tut of budgetary
the plume and more specific analyses to define tne se er y (Clarke, 1984).
2 • Nowhere in the RI is^ the total volume of groundwater within the plume 2" estimated" L indirect reference to ,1« 1; - "^Htau
the feasibility study although it appears to be in -ror. TRIADS
gallons^Our'estimate 3 2
the actual volume of groundwater since the two numbers differ by of approximately 0.25.
gradient, it appears that the flow in the plume is approximately B.ouu gallons per day.
4. The stratigraphy of the site has been |'ag8®^1g8"°r®Jisnisrthertav0TRIA
~urrnracr„/
HS JTSiS SSbiS. -S&-SS. " permeabilities.
5 TRIA failed to differentiate between true soil contamination and groundwater contamination. In a plume of groundwater contamination.
5 A
certain amount of contaminant Pa"^the*'resultant aquifer skeleton invariably take p eomoared to areas of true contamination of the aquifer s^et°" "J"°ectly contacted soils, often coating°thMiwith°pellicularafilm of non-aqueous phase liquid (NAPL).
The remedial investigation did not co^®^er Rewrdation'factofs for the Farm contaminants in the groundwater sys • j h se of organic Goose Farm contaminants were not JJl Sasis of organic compounds, retardation factors can b« es"ma"d °n the # content of the aquifer. ^terfflina^°" 2Sh in !ur judgment should relatively simple and inexpensive retardation of the have been included in the RI. U e'nabled the remedial principal Goes. Farm »"»»»»« pt l l.r.mli.g of sss^r-Sii^'iriSSi its? sl w -soil flushing is being considered.
TRIA fails to utilize the «ehran_ "^"compKhend^ TRIA hydrogeologic data for reasons w ic orovided for the soil borings states. "First, the geologic information provided for ^ was insufficient to allow correlation of• J"JlcuJJr J^Jt known analytical results to sp«ific geologic f or whether soil or wa w, aa"Plaa f chis staCement is difficult to Vincentown formations. The "as . H loos clearly define the understand since the Uehran Engineering boring £«.Jl«rir description geologic formation and provide not on y geologic information such of the lithology but also, where appropriate, g s as the presence and type of shell fragments encountered.
TRIA also states that "Second, information uas^not Ptovided ^ab
above^information* "t c^Sd " «•» boring^log^clearly5" tM'leUr". the doling t«h„i,ue and the specific nature of the well construction.
screened^rl'unknownt'^Cleerlybas t^ls^t
TRIA also states that "Third, »««»£«£.«.£« onlyjor indicator parameters and are'. identified by TRIA." It should be correlated with specific Jo define the western noted that the objective of t e e r . ical protocol consisting of boundary of the plume. Therefor , • , h n t0 j,e appropriate, indicator parameters was judged b? andJ"?,correlated "with
- I E ? : I f a i S n anal y t i c a l UrZriL'ZIZ V «To?\™£s? Farm plums would be hetter defined within the TRIA RI.
6
TRIA also states that "Lastly, there was no ^escr^if ..0!M!!TPthiS
issued by Wehran Engineering, Wehran states that samp in accordance with established NJDEP approved procedures.
On page 36 of Appendix A of the TRIA RI they state "Th® baekgr°und s°il sample collected by Wehran was found to contain a significa uhirh contamination. HcUr, no location for tha samp a -s prov da v eliminates the formulation of any useful conclusions. Once again, tnis statement is inaccurate since the location of the J^round soil samp e is shown on Figure 1 of Wehran Engineering s Supplemental Investigate of the Goose Farm Site" report dated May 1985.
8. The State has analyzed for many compounds ("+40") ich are p^or^ nnilutants As in previous efforts undertaken by DEP. many or tne nonpriority pollutants detected may not be anthropogenic " These analyses only further complicate the selection of pp P ^rformance standards. We beliele the priority pollutant list is an adequate analytical base for this site.
/
7
4 o SPECIFIC catmrrs ON THE FS TL following more specific co-eocs are offeree in connection with the TRIA Feasibility Study.
4.1 Absence of Quantitative Remedial Objectives.
The RI/FS fails to set SSS su?^ feasibility study, remedial action objecti follows:
"1. Remove, treat, or contain contaminants.
2. Control general migration pathways.
3. Control release of volatile compounds in air.
4. Control water infiltration.
5. Control soil erosion.
6. Control direct contact." A rSo RI/FS states that "the
Insofar as management of migration is concerne . . ate contamination of
2* Suu^t^e^TThe environment through direct or indirect
contact." These remedial action objectives do not speak objectives are not required at the Goose Farm site. In fa ^ any waste disposai specific to the Goose Farm site at all. ontrol over "general migration site. Remedial objective #2 calls for# control^ e^g^ quantitatively pathways . Nowhere in the R / oubiic health and the environment or, as evaluated as to their current risk to level, of risk for each pathway, important, as to what would be an acceptab typical Goose Farm Table 1-2 of the TRIA RI Present^ ^ EPA SNARLS for water and contaminants. It P"«»" f o r a i r . The information in this table does not permissable exposure levels _0__jiai obiective must address not only the represent remedial goals. Yuf "here inthe system the permissable permissable concentra5lon' For example, one remedial objective might concentration fnust not be exceeded. _ stream below some prescribed level be to maintain water SNARLS or the 10"^ cancer risk. Another of contamination such as the EPA . aroundwater quality at certain points remedial objective might be game leveis. Remedial objectives of this in the aquifer system below feasibility study to home in on. Given a quantifiable* target^'remedial engineers can then evaluate the myriad n
8
remedial technologies capable of attaining liability '.ItS?
absence of such quantifiable remedia J * thg case tn the Goose
flounders for lack of direction. This a. develooed along with associated
Farm RI/FS. Remedial alternatives have been 18they are expected
cost estimates without any definition o month aquifer renovation period
to remediate site conditions. How degree of aquifer be estimated without some concept of the acceptabi
remediation which will be required? In short, it can t.
9
4.2 Evaluation of Recommended Remedial Alternative #4
The following comments are offered regarding the technical merits and projected costs of TRIA's recommended remedial program.
4.2.1 Technical Evaluation As stated earlier, the technical merits of TRIA's Alternative #4 seem questionable. Its success hinges on what can best e ^ optimistic belief that the Goose Farm contaminants will fall into one of t o categories: those which will be rapidly flushed from the soils, and chose which will remain permanently bound to the soil matrix. The plan J 18-month period of soil flushing and plume treatment, after which presumably the highly mobile contaminants will have been flushed from the soil and t aquifer and the remaining contaminants will remain bound to the aqu skeleton. Although the effectiveness of this option hinges on the rates of taminant flushing and aquifer remediation, the RI/FS does not contain ev p estimates of these mechanisms. The sole reference t0 *luj!^n8 .""J8 "J""to achieving a ten-pore volume exchange of groundwater. The RI made no ®ffo" measure ?he aquifer's natural organic content from which contaminant mobility can be drawn. TSIA has apparently simply " jj* amount of flushing, required to remove contaminants. As the fucceedi g evaluation will indicate, it appears that their unsupported flushing times is seriouslv in error. As a result, the aquifer and soil flushing project would not be completed in the 18 moinths "nc*^e* * TRIA. Rather, in all likelihood, it would be forced "_perate for many years, even decades, before adequately remediating the aquifer and the soil contamination. Naturallv, the performance standards established for the aquifer remediation project will to a large degree dictate how long the system must run. It is evident that in the absence of concrete performance standards and a "asona estimate of contaminant mobility in the Goose Farm *011. of the soil flushing and remedial project are indeterminate. Similarly, t costs of this remedial alternative could correspondingly escalate to the poi of placing it in an unfavorable position with respect to other remedial alternatives as illustrated in Section 6.0 of this report.
In the following section of this report, a preliminary assessment of the likely flushing times for various contaminants is undertaken.
Estimates of Flushing Time
Numerous field and laboratory studies have demonstrated the importance of adsorption in the transport of organic contaminants through soil and groundwater systems. Adsorption of a contaminant to soil can occur through a variety of processes including physical adsorption, chemisorption C of chemical bonds between the material and the soil), hydrogen bonding.
10
ion . change. The degree to which a^ P^rticu1 ^^^^nt'itseirinfche soil or in an aquifer depends on the na ^ contaminants are retarded m properties of the formation. The deg critical factor in the evaluation their migration in groundwate:• systems „ critical fact ^ and design of aquifer remediation affor essentiany immobile. Others tenaciously held by the soli through the aquifer, moving at only will be strongly retarded in their passag ^ g StiH other contaminants, a small fraction of the rate of Srounduater flo-. Still • concam„a„ts Bove oarticularly the lower molecular weight, volatile og nearlv as fast as the relatively rapidly through the ""^""^^"organics themselves exhibit a groundwater, itself. However, even ^""^uifer systems, substantial degree of variation in their mobility in aq
The degree to which a chemical or nJJ^^^t^RetarStion Factor, R, of groundwater in an aquifer system is defined as its a
groundwater velocity R »
solute velocity
The retardation factor can he from aquifers. It can be considered as being roughl^t^ contaminant from of pore volume exchanges necessa y noted tnac the Retardation Factor (R) the groundwater system. It shoul , of dissolved groundwater refers to the r«.r<«io" ether factors also come contamination. In areas ot severe into play which will be subsequently discussed.
It can be shown that: ( 1 )
R s 1 +(p/n)K^
Where: p * bulk solids density
n • porosity K = soil/water distribution coefficient
The ratio of the bulk solids *enslZV p^ges^of thi^ evaluation can be the range from A to 10, and f distrPbution coefficient which provides a m0eaSsudreereodf the SSSt'wwhifa a material partitions between a soil matrix and the groundwater.
Karickhoff. et al (1919) have sh<
s SSci, s:ic«; s?; ganirconttn 'Urhlr Ih'an "i" ?o»I ««. Karickhoff and his coworkers have developed the following relationship.
11
„ Kd (2) N « — oc f oc
The fact that the retardation c°«f£icxenc for orgaitic cav^unda correlated to a soil s organic content is £etween K and several authors have been able to demonstrate c0"ela"°^la*et ®ater°Solubility (S) commonly known properties of chemicals. In P®"1"1"' h t0 correlate and octanol/water partition coefficient ( ) ®v . 1979. Chiou, et well with K . (Kenaga and Goring. 1978; Kanckhoff et al., 1979. uniou, _l 107Q\ OC al., 1979).
I. consideration of the preliminary tS'oug^l empirical relationship developed by Kanckhoff will be utmzeu tor » analysis:
(3) K » 0.63 K OC ow 1 T 7 ir is oossible to estimate the retardation
Utilizing equations 1, 2. and 3, it is possiDie to ,g factors for the organic compounds found at the Goose farm 51 .1nr.jrfa illustrated in the following sample calculations for. methylene chloride.
Sample Calculation Chemical contaminant: Methylene Chloride
Octanol/water partition coefficient (KQW) » 18 Using equation (3)
KOC-°-63KOW K o 0.63(18) » 11 OC
From equation (2)
Kd - foc Koc Where: f » 0.5! or 0.005 (estimated) OC
K. - 0.005 (11) - 0.055 d
and from equation (1)
R » 1 + p/n K
Where: p/n « 5
R a 1 + 5 (0.055)
12
1.28
Retardation Factor (R) of Methylene Chloride is 1.28.
Table 1 presents the estimated fet^da^°" FarTsite*5 In°thehcalculatiSn!
through which the plume is migrating is 0.5 percent.
Th. above analysis reflects the mobility of individual groundwater system. In evaluating these situations one must also *er synergistic effects of "^has"^.'.! «11 documented, for system, such as is the case at Goose Farm. It has oeen « relatively instance, that the solubility and hence the „nce Jf dissolved insoluble compounds can be greatly etlhan"d « * h concentrations of concentrations of organic solvents in groundwater. The high^concent organic solvents m the Goose Farm an f ively immobile base neutral the mobility of many of the otherwise irelati J to quantify the impact extractables, and acid extractables. I ^ significant factor of this mechanism of contaminant migration, y . extractables, in the observed presence of base neutral extractables, and acid extractaoie well beyond the confines of the disposal pit.
It must also ba amphasiaed that th. precedingI »»ly£» of "'"^"^soWed
contamination? S ^y « pit th. >P-rrtr„Csalb:r,as°ethhrsoas h". been overwhelmed df/he Organic comJoSSs^d are often coated with « "p-llicul-r Mta of rh«
mobile compounds from the soil.
siasrs.^'s rsy; sspys-s ^ fit,eh an aauifer free of contaminants. In tnis case, exchanges necessary to flush an aguifertr grounduater „ithin the plume. T^is^estimated that the Goose Farm plume contains approximately It million It is estima estimate is based upon the areal dimensions of gallons of groundwater. This estimate is oa p ^ Qf the plume which are roughly 50U reet oy therefore be
rSHSB s &ss sss rrsiffain°"thl progressive release of contaminants having successively higher
the contaminants totally immobile, a tremendous amount of groundwater will
TABLE 1
Estimated Retardation Factors (R) for Principal Goose Farm Contaminants
Calculated Using Karickhoff, et al Empirical Correlations
Chemicals ov oc
Volatile Priority Pollutants Acrylonitrile Acrolein Methylene Chloride 1,2-Trans-Dichloroethylene 1,2-Dichloroethane 1.1-Dichloroethane Benzene 1,1,1,-Trichloroethane 1.2-Dichloropropane Trichloroethylene Toluene Ethylbenzene
Base Neutral Extractables Bis(2-Chloroethoxy) Methane Bis(2-Chloroethy1) Ether Bis(2-Chloroisopropyl) Ether Naphthalene Fluorene Acenaphthene Phenanthrene Anthracene Chrysene Di-N-Butyl Phthalate Pyrene Fluoranthene Butyl Benzyl Phthalate Benzo (A) Anthracene Benzo (A) Pyrene Benzo (B) Fluoroanthene Benzo (K) Fluoroanthene Benzo (GHI) Perylene Indeno (l,l,2-c,d) Pyrene Bis(2-EthyIhexy1) Phthalate
Acid Extractables Phenol
63
0.7244 1
18 30 30 62
89-135 150 190 195 490
1,410
"18 38 380
2,340 15,100 21,380 28,000 28.200 407,000 158,489 209,000 214,000
,100-631,000 408,000
1,100,000 3,715.352 6,918,310 17,000,000 45,700,000
29
0.46 0.0023 1.01 0.63 0.0032 1.02
11 0.055 1.28 19 0.095 1.47 19 0.095 1.475 39 0.20 2.0 71* 0.36* 2.8* 95 0.48 3.4 120 0.6 4.0 123 0.61 4.1 309 1.54 8.7 888 4.44 23.2
11.34 23.95 239.5 1,474 9,513 13,469 17.640 17.766 25.641 99,848 131,670 134,820 218,641* 257,040 693,000
2,340,672 4,358,535 10,710,000 28,791,000
18.3
0.057 0.12 1.2 7.37 47.6 67.4 88.2 88.83 128 499
658.4 674
1,093* 1,285 3,465 11,703 21,793 53,550 143,955
0.09
1.3 1.6 7.0 37.9 239 338 442 445 642
2,497 3,293 3.372 5,467* 6,426 17,326 58,518 108,964 267,751 719,776
1.457
Chemicals K K K d R 3C
Pesticides 380,000
1,070,000 1,300,000
239,400 1,197 674,100 3,370 819,000 4,095
5,986 16,851 20,476
PCB-1242 PCB-1254 PCB-1248
Note: K - Octanol/Water Partition Coefficient Kow > Soil/Water Partition Coefficient Referenced to Organic Content KJC» Soil/Water Partition Coefficient R o Retardation Factor * • Mean Value
13
have to be pumped to purge the ; e'detail^^nalysis of quantitative performance standards (and na"r® with any degree of of contaminant flushing) it is £®P°SS* »roundwater recovery and treatment accuracy the time period over which • «™*d£^er^t a ypumping rate of system would operate at the Goose F ---hanae could be realized every 140 100,000 gallons per day, one pore volume excha g . e< Comparing this days provided induced stream water infilt Table 1 indicates that a figure with the retardation factors P«vid«d ^VuJd run for ny groundwater recovery and treatment fa y performance standards decades, possibly even 100 years, depending upon the pertormanc established. AS noted earlier, too other factors must be kept in min<of of otherwise relatively compounds to be organic solvents. This will cause these re y rates of flushing in flushed more rapidly from the soil system* b' oredicted by retardation the areas of severe soil contamination cannot ha prjdicMfl^yr ^ factors alone. The shear mass of contaminants in t i P ^ important role in dictating flushing times. The "°^"®minants flushed from phenomena is to increase the number and ^ofhJ!K^bil. contaminants appearing^later tSS".f#^r.S?i^ 1-blle compounds being leached more rapidly.
The TRIA groundwater recovery -system j^lnfs ire™™bl wellpoint system as indicated m Figure - * , . plume adjaCent to the aligned along the eastern and northern boundaries of the plumad3 ^ creeks into which the plume discharges. Because « «- J, recovery creeks, induced infiltration of stream *flow. This induced system will make up a significant portion of that syste b 30 and 70 surface water infiltration couild ^Snd upon the percent of the total flow of the ""P"" stream bed and flow system's geometry and flow rates, aquifer Pr®£"ie*' ' in_flow of
Sss-^-sr Sill serve to throw the remedial project out of „nyarot .
Feasibility &£ *££$£££££
rtyrttmTir.
cou 1 d serv. o expand the plum, laterally beyond its present boundaries. The concept of recharging at the rear of the plumi to accelerate aquifer
14
renovation is quite good. However, where surface ""r^et.^induced to flow into the groundwater collection y . bg the »ciosed loop" discharge a comparable .amount of « a hydrologic balance. Once ^ir^Snrsn "*£«»* —i e""mely use£ul in conceptualizing the groundwater recovery remedial options.
The TRIA-recommended remedial °pcion «nvisxons accel«rat«<lt*01Jhe groundwater means to enhance the migration of laacha"a "J" chieve this soil flushing recovery system. However, the means P£°P sed that a wellpoint system will be at best partially effective. I is J'0*^te™ter back- into the consisting of 80 wellpoints be disDOsal pits. A sketch of the contaminated soil zone in the vicinity •feasibility study. A proposed system is presented » Figura on[y those soils in its wellpoint system of this type will .ttecti^y £u.h on # immediate vicinity. Such a rechargi g JLierate flushing only within potentiometric ridge along its alignm . underlying saturated zone, the confines of the POtentlome"lcnor1^® ® J™d Jot feet from the Contaminants in the unsaturated zo farted Even contaminants in recharge system will likely br "^^fof the wellpoint recharge the unsaturated zone in the immediate Y ltant height of the system may be ""af^^^^^/F^provides no quantification of the impact potentiometric ridge. The TRIA Ki/rs p ornundwater table or with regard
°d ITS "fusibility* U.Tp'r«-" ™ thfcomputer ti"ness o£ various soil flushing systems could be quantitatively evaluated.
k e.« enii flushing would be some form of surface A more effective approach to soil f J irrigation. In this way, contact^between^the^recha-rging^water and the soil contaminants can be maximized through the region of soil contamination.
Groundwater Treatment Gonsideraticns
In Alternative #4, it is proPos®d.tJaL0®r3dgorption^e TRl" assumes that ten clarification and granular activate d bg treated during an pore volumes of the contamin;a"d p1™* *ons (approximately 260,000 gpd) 18-month period. A total, of 1 0 • » f he previusly described of groundwater "J6-" ~"«1 concerns arise with respect to the problems of contaminant ilusning, treatment method as well.
1. Gravity Clarification
Gravity clarification with a hr is effective in r.»vi„g auspe,,ded so:Lids.^ H°^' J,. gravity have very low suspended sol . ;rlnore. „ost of tht chemical constituents'1 (at g. h^y hardness, etc.) contained in groundwater
15
are in soluble forms which are not susceptible to gra. _.y the[e ms Aspect, therefore, gravity clarification is emfcal . u a need to remove heavy «lB}a ir^P to remove the
precipitation, then gravity clarifioation is req ^ #Q95 precipitated metals. But, heavy metal con"""® standards (e.g. and #107 are either lower than primary "^Un" . mercury) or not regulated (e.g. 2inc'; clarification is not needed under Alternative #4.
;. Granular Activated Carbon (GAC) Adsorption
Although most of the organics in the plume water are GAC aline is not cost-effective in removing 400-500 which is characteristic of the core P 560,000 ppb methylene the high concentration of many <"J™1" ^J;'would be very expensive chloride, 9500 ppb benzene, etc,)* 50 ppb 6ach V0C and total if stringent effluent limitations of feasibility studv is V0C < 100 ppb are to be met. (Once again, the feasibility haunted by lack of performance standards.)
3. Air Stripping
Air Stripping is not proposed in organics found in the plume water are highl, volatil^ie^ ben2ene, chloride, dichloroethylene, tr^chl°[°®^y^s' tiony would significantly etc.), air stripping prior to to carbon o.ption o * wQuld reduce the V0C loading to the carbon treatment, ana tnere considerably lower treatment Cost.
Based upon the above critique, a be considered. -1.
standards would have to be confirmed.
a series of treatability studies on the actual plume water.
4.2.2 Cost Evaluation nf TRTA's Alternative #4 modified to reflect
The estimated construction costs of TRIA s >iter ted _n Table 2< The the suggested alternative differ appreciably from those estimated by"™1Ci0Sow0eSvter.aiPnaretnhe TRIA cost estimates no differentiation was made between'construction costs and operational and maintenance costs.
It is estimated that the annual °P^^10J/napp™^-^ely%394!oOO. This groundwate OO^^a^ear^general^O & M for the treatment plant, 5139,000 per «Iri" sludge disposal, and $55,000 for groundwater monitoring.
Item
TABLE 2 Estimated Cost of Alternative No. 4
Units Quantity Unit Price Estimated Cost
Groundwater Recovery & Recharge System
Soil Flushing & Recovery System
Groundwater Treatment Plant (AS, PACT)
LS
LS
LS
S 349,000
383,000
1,350,000
SUBTOTAL Engineering, Permitting, & Contingencies 9 30%
TOTAL
S 349,000
383,000
1,350,000
$2,022,000 607,000
S2,629,000
- )
16
4 3 Evaluation of Remaining TRIA Alternatives We following brief counts are offered regarding the regaining seven TRIA alternatives. 4,3.1 Technical Evaluation
Alternative #1 The National Contingency Plan rLoval wodld total removal option. In the case of UcmrnMive^ disposal pit. but encompass not only the contaminated soils in the this apparently much of the instruction of the aquifer with clean alternative would involve removal "^ ""^oediation. "This alternative has
negative^aspects which remove it from serious consideration. These
are: 1. The extreme cost.
f ianHfill caoacity for the 62,000 cubic yards of 2 The nationwide shortage of landfill capacity waste resulting from this alternative.
3. The current regulatory reluctfotf-srte to sites whic may potentially become future Superfund sites.
Alternative #2 Alternative *2 shares the same disadvantageous aspects as Alternative 1. although to a lesser degree.
Alternative #3 This alternative calU ^the^on-site &
feasibiet^Jhiralternative is s^on^^of^his^eport. In in-situ management alternativ p failure which could prompt addition, there would «in • the future. The risk of another remedial investigation/fe • alwavs remain since RCRA failure, that is leakage from •-h.^KiU^^- co„struction o£ the landfill guidelines and site consideratv uentlv there would always be an outward above the groundwater table. U3n®®J • difficulty in obtaining the hydraulic gradient across • facility in the coastal plain of New necessary permits to construct such a facility Jersey should also not be overlooked.
Alternative ?5
Alternative « involving in situ ^ Alternative **• Ji the stimulated bacteria to degrade the treatment depends upon the aoim-y
17
Bfe situ without need for their extraction and above-ground contaminants in situ vitnout neeu i« mnlAoir-i treatment appears very treatment. The technology of in situ soecific conditions of the Goose promising. Whether it is applicable to the s^ific conditio Farm site would have to await a more detailed treatabil y
In situ biological treatment could be tJatCp"oposed°inWAlternative flushing and groundwater recovery system such as that p p^ de#cribed within #4 by TRIA or in conjunction with the containment p Section 5 of this document.
Alternative #6 Alternative *6 is the only containment-based alternative evaluated by TRIA. it involves a rather.unusual approach to in "<u manaswent.jp.cria application of "base grouting' . Base S«uting is Subsurface horizontal low-permeability horizon beneath a waste disposal site. ^ cutoff walls are then keyed into this l°w;P*™e*a a yhighly questionable containment "vessel". Base grouting, wfina£ pro<juct is concerned. No procedure insofar as the integrity o soecific nature of the base specification is given within the RI/FS as to the specific nature grouting technology considered.
Apparently no consideration was given .^utilization ^"fbe^evtS' .quitard as a strata into ,^ »ub.urf.« cuto.. -el:L.f cou^
SEELS Sand°aquitard ."Xlng sdvant.,.^
iTTh UFI/Kgl"! n^consideration to this advantageous feature of the let, the TRIA FI/FS g _ ^ ence of the Hornerstown Aquitard Site. In fact, TRIA seems t g biU t dy thev state in connection altogether. On page III-2 of the fusibility Jirei< however, by th, uith """atrv. #6 that tbv Uou o ^g g ^ vincentown formations at permeability of the lower lir . reasoning for this oversight rS."n:; only is - erstoun Sand aquitard a well-recognized.uitard in the New Jersey coastal plain, but at tnis sice conventional slurry trench construction methods.
Alternatives #7 and #8
Alternatives #7 and M ^^^Usr"10#" Sus'To'eddr"! contaminants^ithin the plume and Alternative « is the no-action alternative.
18
4.3.2 Cost Evaluation The following general comments are offered regarding certain characteristics of the TRIA remedial alternatives.
1. As has been previously described, it is our uiJer^a^th^Goose time required to flush the soils and remediate the aquifer " n,ioles Farm site have been seriously underestimated. Employing times and previously described, it is our contention that ^il flushing times and aquifer remediation times are likely to take anywhere from a decade to mo?ethin a hundred years, depending upon the performance standards established for the project.
2. Aside from being unrealisticaUy low. the projected cost of plume pumping and treatment is the same in Alternatives 1, 2, 3, A an o, j; . substantial differences in the amount of aquifer the same a„h alternative How could the aquifer remediation costs De "e swe when inAlternatives 1 end 3. 62^000 cubic yards of the most tgh y contaminated material will be removed from the ^ulfer. while i Alternative 4, the recommended solution, no source control is contemplated. Similarly, in Alternative 2. 10.000 cubic yards of highly contaminated soils, representing the disposal pic, are 8 altarnacive off-site disposal. Yet, the cost for plume management in this alternati is aeain tie same as Alternative 4, which involves no source control. In Alternative 6 a slurry trench cutoff wall and bottom grouting is proposed "" "a Lum^y Ihe most on plume cleanup costs is projected. Surely some benefit is to be accrued from these hiehly capitally-intensive source control efforts msotar as the duration and costs of the aquifer remediation program is concerned.
3 The cost of contaminated soil excavation and disposal is estimated at 55 0 oei iubic yard. The derivation of this figure is not provided in the RI/FS. This figure seems rather high in light of similar waste excav and disposal efforts in New Jersey and elsewhere.
4. The RI/FS report provides very little technical C°"C^ni"8f eight evaluated remedial programs. The estimated pumping :rates or tne soil flushing or groundwater recovery systems are not provided. The cos. of the groundwatlr treatment plant is not broken out and separated from the cost of the groundwater recovery system or the operational costs associated with the system. The depths and proposed/J18""®"'. slurry trench cutoff wall in Alternative 6 is not provided. Nor is ther anv explanation of the base grouting technique. In reading the report one does not know whether "base grouting refers to the technique" or some other form of pressure grouting. The derivation of tne immense 512,500,000 cost of base grouting is also not provided within RI/FS.
Specific Consents
19
Alterative #1 Althouah the unit cost of excavation and disposal ($540 per cubic yard) hiah it is not clear whether TRIA has included in their estimate provisio fo? management of groundwater during the excavation °Pe""°J*inGr°he ®ost
disposal.
Alternative #2 The general comments and specific comments made in regard to Alternative #1 also apply with respect to Alternative #2.
Alternative #3
It appears that TRIA's estimates of the cost to construct an may be low. Table 3 contains an approximate cost estimate for a 67,000 yard hazardous waste secure landfill conforming with EPA s guidelines published following the 1984 reauthorization of the Resource Jonaervat:io^ Recovery Act. In accordance with those guidelines, the landfill design includes a primary and secondary liner, a primary leachate collection system above the primary liner, and a leachate collection/ detection system between the two liners. In further compliance with the referenced EPA guidelines, the base liner has been assumed to be constructed of 3 feet of compacted c ay with a maximum permeability of 1X10-7 centimeters per second. The P"»ry liner has been assumed to be a composite liner consisting of 8 8-TolylZl.nl (HDPE) atop a two-foot IXIO^ lioer of landfill's final cover would consist of a composite cap of 20 mil P\C atop one foot of 1X10-7 centimeters per second compacted clay overlain by sand drainage layer and one and one-half feet of top soil. TRIA s e"-^es of annual operating costs, presumably consisting of leachate treatment, final cover maintenance, and environmental monitoring, appear reasonable.
Alternative #4 Sine. Alternative #4 1, the recommended remedial °P"on, thetos" of this option have been evaluated in greater detail in Section 4.2.2 of this report.
Alternative #5 Insufficient information existed at the time of this report to estimate the costs associated with in situ biological treatment. Additional studies b> FMC are under consideration by Morton-Thiokol.
Alternative #6 Alternative #6 is the only TRIA alternative which gives consideration to containment of contaminated source areas. Unfortunately, . contemplates base grouting of 5 acres. Base grouting is not only enormously
TABLE 3 COST ESTIMATE ON-SITE RCRA LANDFILL
1 . 2. 3. 4.
6.
7. 8.
ITEM UNITS AAAAAAASSSSSASANAS LASSES SITE PREPARATION L.S. BERMS C.Y. SECONDARY LINER C.Y. LEAK DET. SYSTEM -SAND C.Y. -COLLECT. PIPES L.F. -GEOTEXTILE S.F. -COLLECTION SUMP L.S. PRIMARY LINER -CLAY C.Y. -80 HOPE S.F. LEACHATE C.S. -SAND C.Y. -COLL. PIPES L.F. -GEOTEXTILE S.F. -COLL/STORAGE L.S. MONITORING WELLS UNIT FINAL CAP -CLAY C.Y. -20 MIL PVC S.F. -SAND C.Y. -DRAIN. PIPE L.F. -TOPSOIL C.Y. -HYDROSEED S.F.
QUANTITY
i 26,200 40,400 7,000 4,150 172,000
1
17,500 187,500 7,400 4,270
186,000 1 4
10,200 210,000 8,300 4,500 14,700 222,000
UNIT PRICE
$50,000.00 $12.65 $12.65 $7.00 $0.75 $0.15
$20,000.00 $12.65
$1.00
$7.00 $0.75 $0.15 $75,000.00 $2,500.00 $ 12.65 $0.27 $7.00 $0.75 $9.00 $0.08
ESTIMATED COST
$50,000 $331,430 $511,060 $49,000 $3,113 $25,800 $20,000
$221,375 $187,500 $51,800 $3,203 $27,900 $75,000 $10,000
$129,030 $56,700 $58,100 $3,375 $132,300 $17,760
SUBTOTAL ENGINEERING,PERMITTING, AND CONTINGENCIES
$1,964,445 30.00* $589,334
TOTAL $2,553,779
20
an inherently difficult undertaking. Because of the expensive, 1- remains an inherently . it 0f a base-grouted zone unseen subterranean nature of the work, the ^egri y utilizing the is always in question. Apparently no consideration was gi « subsurface Hornerstown Sand aquitard as a confining layer into which to key subsurtace SrSll,: Exploitation of th. Hornorstovn tad situ management approach for the Go°se Farm s"e is questionable base in Section 5 of this report. The inclusion of the racner ques grouting technique in Alternative #6 increases the co in-place |l6,250^000. As a result, I.?"?? *11l l dScrSrfi» encapsulation beyond the range of reason. , alternatives for the Section , there are numerous other in situ management Goose Farm site which are in fact more cost effectl hieher dearee of presented within the TRIA RI/FS and, moreover, possess a higher deg reliability
Alternatives #7 and #8
Neither Alternative #7 or #8 are in of Alternative #7 the plume is left #8 no remedial efforts are involved.
serious consideration because in the case unmanaged and in the case of Alternative
21
5.0 PRELIMINARY ASSESSMENT OF OTHEL REMEDIAL OPTIONS The fact that the soil flushing and aquifer remediation remedial alternatives proposed by TRIA will be a»ore time consuming and therefore more costly undertaking than estimated, demands that containment options be given a closer examination. A closer look at containment options la a);a° ^"^se Farm observed properties of the Homerstown Sand aquitard beneath the Goose Farm site. The TRIA RI/FS makes little effort to consider the maay options available. The single containment option TRIA considered #6) involved the highly questionable and costly practice of base 8™"" 8- ' consideration was given in the TRIA RI/FS to utilization o ^nine it Sand aquitard as part of an in-situ management approach. In so doing, l appears they have overlooked some very attractive and cost-effective remedial alternatives. Subsurface cutoff walls can play a variety of roles in the remediation of hazardous waste sites (Mutch, 198A). In the case of waste disposal sites, cutoff walls can be used to hydraulically isolate the waste dlspoaa* s"*ls ot the same manner cutoff walls have been used to isolate subterranean zones of soil contamination. In groundwater recovery and treatment .P^MS, cutoff walls have also been used to minimize or prevent induced iafj1"a" . adjacent surface water bodies. Cutoff walls have also been «sed to Pa"ially or completely enclose a plume of groundwater contamination, thus halting its spread and allowing groundwater recovery and treatment efforts to proceed at more relaxed pace. Each of the above-described common usages of subsurface cu"ff walls has potential application at the Goose Farm site. A subsurface cutoff wall could be employed to encircle the former disposal pit and the highly contaminated soils in its immediate vicinity. Alternatively, a subsurface cutoff wall could be utilized to completely enclose both the waste disposal pit and t e plume of groundwater contamination. Finally a subsurface c"c°ff all» jssibly even a relatively shallow cutoff wall penetrating to che "a"aaJua" Formation rather than the Homerstown Sand aquitard, could be utilized to minimize induced infiltration from the adjacent stream.
It must be emphasized at this point that cutoff walls do not form completely impermeable barriers to groundwater flow. Rather, m the proper setting and under the proper design and construction conditions, they can very effectively minimize groundwater flow. This is not to suggest, however, that leakage from a waste disposal site encircled by subsurface cutoff "a*ls °eed be inevitable. Many waste disposal sites have been remediated by combination of circumferential subsurface cutoff walls and collection systems to reverse hydraulic gradients acrossthe <'U " HJ[LsIi other words, bv lowering the potentiometric surface within the waste disposal site to elevations less than the potentiometric levels in the surrounding and underlying aquifers, seepage will be induced to flow into the waste disposal site rather than vice versa. This remedial concept has been employed in the remediation of numerous waste disposal sites including several sites on the National Priority List. Several of the National Priority List sites employing this technique include the Monroe Township Landfill m Middlesex County, NJ
22
(Mutch 1983): . the South Brunsu.,k Landfill 'n CounCy- Wi "" Hooker "S" Area Landfill in Niagara Falls, NY (Amos, 1985).
In the containment options for the 'tSSSSly 100 is this concept which is e"ployed* from thl! site. A properly undertaken percent abatement of contaminant rel ^ of abatement is not risk assessment may demonstrate that such ® 8 hydraulic gradient required. In which case, it may be pos,ilave the reversal and allow some nominal amount of *e®*®8 g med the site's confining envelope. However, at this juncture, more conservative remedial approach. Since in every epplicetion of subsurface cutoff vails there will be some groundwater I'OV through the cutoff wall itself
^iUca°w°evalIlationUand design of a subsurf.L outoff^ll^I-ach^f^he subsequently discussed additional remedial options, groundwater inflow has been estimated.
The following additional remedial options seem worthy of
SSSSRI: SR RAR-SM with Alternative #9..
23
5.1 Inscription of Additional Remedial Alternatives
Alternative #9 Alternative #9 would include the following elements:
1. A circumferential cutoff -all around the vast. «£>~1 ^^^h groundwater contamination. The approximately 2« . northern sides Ltoff -all would lie along the "e.ksonthe easten and norther,>r.^ of the plume, along the western edge of ry trench cutoff wall southern edge of the waste disposal pit. The slurry trenc would key into the Hornerstown aquitard at an average aept approximately 65 feet.
2. An interior laachate/groundwater collection »r"» ™ lower the potentiometric surface within the cutof ir.iri.wft0d/vincentown level below the potentiometric levels in the adjacent K and the underlying Mt. Laurel Aquifer.
3 Collected leachate would be managed either truck»"® tersev facility wastLater treatment *•»»«£» = ^P-ater Ne^Jars.y^factlit, or by an on-site treatment plant. This decision wouiu findings of a treatability study and economic analysis.
It is crucial in any containment-based remedial action that the amount of
^eSld^beboutwardinatit'is^necessarv^o^knov^he^mount '"leakage in order to Tape 3J. ;.
the cutoff wall enclosure can be expected from three mechanisms.
(a) Infiltration of precipitation creo1f (b) Inflow of groundwater through the cutoff wall, itself (c) Upward leakage through the Hornerstown Sand aquitard.
Infiltration of Precipitation
s.n.r rsrs.ss.1 =s;.r ggg
the order of 15 inches per year. Over the lof ooo "lions of groundwater
fluctuations.
Leakage Through the Cutoff Walls Under natural conditions, it has been assumed that there is a five foot
24
differential in the Pot™ti«"ic,/^*^0LSf,^bi^refOT/iri«d2^S aquifer in the deeper Ht. Laurei/Wenonah Aquifer#ncl8aur# t0 a lcval lower the potentiometric surface wi , level in the Mt. Laurel/Wenonah at least two foot below the P°«ntioa«triC l.vel in surface Aquifer, it will he necessary t craata a seven foot head differential approximately seven feet. wllL"*?"auUc gradient would therefore he
MS£V»«h cutoff wall Seepag, through the 130,000 s'quare foot cutoff wall having a p.r^brlity of 1 x 10 cm/sec would therefore be approximately 645 gallons per day.
Leakage Upward Through Hornerstown Sand Aquitard
The uoper shell layer of the Hornerstown Sand aquifer is approximately eight thickness. ..Wehran Engineering estimates "
approximately 1 x 10"7 cm/sec. Conser.atively assuming that v uUc
ssst sss. » - —d would therefore be approximately 140 gallons per day.
The total leakage into the cutoff wall enclosure will be the sum of the above three mechanisms or approximately 7,600 gallons per day.
SSTRSSS RAI-U can assume that the annual operating costs would be approximately w.uu P year.
Alternative #10 Alternative #10 would include the following elements:
1. A circumferential cutoff well around the •"« sUrr^rench
IS-rg;-rth would key into the Hornerstown aquitard at an a erag p approximately 65 feet.
2 A cap would be constructed over the cutoff wall enclosure area to minimire 2- infUtration of precipitation. The cap would consist ,M2 inches o
rTmU wM* would he-constructed
drainage'layer'woul^be''covered'with^ \l i^hlTSf'to^oa'SS h^roUeded
25
to minimize erosion. 3 An interior leachate/groundwater collection system would be constructed to
lower the potentiometric surface within the cutoff ^/Vincentown level below the potentiometric levels in the adjacent and the underlying Mt. Laurel Aquifer.
A. Collected leachate would be managed either by trucking " wastewater treatment plant such as DuPont s Deepwater, await the or by an on-site treatment plant. This decision would have to await the findings of a treatability study.
Leakage Estimate Leakase into the cutoff wall enclosure under Alternative #10 would be the same irSK burring in Alternative # 9 with the exception of °
option would therefore be approximately 885 gallons per day.
The costs of Alternative #10 are presented in Table 5. The annual operating Ssts for Alternative #10 are lower, since infiltration of precipitation is essentially eliminated. Annual costs for leachate treatment would be approximately $25,000 per year. Adding in costs for site *he routine maintenance, the total annual operating costs are probab y order of $80,000.
26
5.2 In-Situ Biolv;ical Treatment Applications « iiromatives #9 and #10 would involve the application
Possible variations of Altemati ®® treat the contaminants within the of in-situ biological TfferThe advtntag. of allowing the cutoff wall enclosure. The cutot relaxed pace since plume in-situ biological treatment to Pr0«® closed loop in-situ biodegradation migration would be controlled. induced surface water infiltration processes could operate without concern of featment zone. It is or loss of partially traated e _ ue" in-situ biological treatment difficult to say at this juncture how effect r.anic compounds found at
the'coose Farm other areas " ct".
f n^ r:hicS"«rSo rUn
lubsurfaceUwithout°n!thehneed0of^bringing5rSthe conM^nants to the surface conventional treatment.
standards would permit a determination of the ti...e requirea point.
27
6.0 CONCLUSIONS It is our contention that the most ®®^sf^®fgC^®gtyeffectiveRrLedial option failure to mount a truly <^*8®" ,se®;rc^ntions which are looked at are few in for the Goose Farm site. The remedial P BOrtions of the document are number and poorly developed Both e RI and ^portionsjr strikingly unquantitative. Remedial obj 0iume of groundwater in the most conceptual er i fn l t i s Qf the RI/FS— is not even mapped, contamination—essentially the entire distribution of contaminants either in terms of its spatial extent the distributio ^ contaminated within the plume. No estimate J-* P™v wag made tQ estimate the retardation groundwater within the plume. No effo , system. The influence of of the principal contaminants in the groundwater sys largely site stratigraphy on the Jrog«logi= con ittons o
2 brx pmr Ti rre1yLr"\Sr,rtin5 |S considering containment-based options.
It is our suggestion that in light of tk£"£2 the contaminants from the aquifer m the time p h Pfurther evaluated, remedial options, specifically containment options, be further evaiuatea.
Table 6 contains a comparative analysis of selected Goose options. Specifically the table »">»"•»'different durations of and 10. Alternative #4 has been evaluated for several diner, 5vsceM. the groundwater recovery and ^""enc^sy ^ bee„ utllir«d in the assessment? to 'ito'sn estimat;. of th,- initial'"ft
2 appropriate durttion of^ opration?"'^e last column of^d
costs. #/ he. a relatively high annual operation and maintenance
Since Alternative »4 *UerJtivl is sensitive to the duration cost.i the total cn-n fiushinfl orogranu The present wor*-h of the groundwater recovery a a iftW Qf S702 000 in the event the value of th, annual 0 * M /^t^ears ™|i!oi?oSo f« a ' 30 year recovery program only °P""°?e #4 ls J,!, competitive with Alternatives 9 AISIRRSIIT system operates no longer y*fS;he gr0Undwater recovery and soil escalates rapid y should that system have to operate for five years, flushing system increases. Should that sys Ooerated for 10 years, the total cost ""rnative £-££ » million JiUty the costs exceed $5 million. The preceding a y ^ f8rte.., 2. 22tS 25 1take «mny years? probably decades, to adequately re- .ate
Comparative TABLE 6
Analysis of Selecteu joose Farm Remedial ption
Alternative
Alternative No. 9 Alternative No. 10
Alternative No. 4 Alternative No. 4 Alternative No. 4 Alternative No. 4 Alternative No. 4 Alternative No. 4 Alternative No. 4
Construction Cost
52,242,500
2,412,085
2,629,000
2,629,000
2,629,000
2,629,000
2,629,000
2,629,000
2,629,000
Annual 0 & M Costs
$95,000
80.000
394,000
394,000
394,000
394,000
394,000
394,000
394,000
Duration 0 & M Costs
(yrs.)
30
30
Present Worth of Total Annual 0 & M Costs
SI,068,750
900,000
Total Cost
$3,311,250
3,312,085
2 702,000 3,331,000
3 1,017,000 3,646,000
4 1,304,000 3,933,000
5 1,572,000 4,201,000
10 2,644,000 5,273,000
20 3,869,000 6,498,000
30 4,433,000 7,062,000
TABLE 4
Alternative No. 9 Construction Cost
Units
Slurry Cutoff Wall
Leachate CS
- well points
- piping
- pumps
- installation
- storage facility
Groundwater Treatment Plant
EA
LF
LS
LF
LS
LS
120
1,300
3
1,300
1
1
SUBTOTAL
Engineering, Permitting, and Contingencies 30.0%
25
5
4,000
45
150,000
325,000
3,000
6,500
12,000
58,500
150,000
325,000
$1,725,000
517.500
TOTAL S2,242,500
28
2ssra.%:s respect to Alternatives 9 and 10.
s-3S- •"™ set-"=12';,, groundwater contamination problems a . situ biological treatment
need for long-term maintenance and monitoring of the reme p
BIBLIOGRAPHY
A V u • Freed "A Physical Concept of Soil-Water Chiou, C.T., L.J. Peters, and V.H. Freed, A rny Equilibria For Nonionic Organic Compounds , Science zu_,
Kenaga. E. £.. and C.A.I. Coring, "^"ionahip Batwean 0f^a^cjla Soil-Sorption, Octanol-Water Partitioning. and Btocontentration^^ in Biota", ASTM Third Aquatic Toxicology Symposium
Karickhoff, D. S. Broun, and T. A. Scott. Water Res., 13 , 241. 1979•
Lyman, W. J.. «. F. Reehl, and D. H. Rosenblatt, jan^ of Chemical Property Estimation Methods. McGrav Hill Book Company, 1982.
Mutch. Jr.,. R. D.. "Subsurface CutoffUalls: ^^rTlnternattonal
Pittsburgh, Pennsylvania. ^ f TS-O- -*~A t Heartv "Environmental Cleanup of the
Monroe Township Landfill", Proceedings^ o£ ik 2B1SDH ConUrence on Fnvironmencal Eneineerine. Atlanta, Georgia, July 1-31.
- i c,»« „f ioq =-ioritv Pollutants,USEPA Water Related F.nvironmental Fate of. ^ • — ZZ574-79-029a, b., December 1979. FMC Aquifer Remediation Systems. Site Assessment Report for the Goose Farms Hazardous Waste Site, June 27, 1985. Wehran Engineering. Supplemental Investigation of the Goose Farm Site. May 1985 Wehran Engineering. Analytical Results. Groundwater Monitoring Wells. Goose Farm Site, March 1985 Wehran Engineering Analytical Results. Soil Samples - Volume 1. Goose Farm Site, March 1985 Wehran Engineering Analytical Results. Soil Samples - Volume 2, Goose Farm Site, March 1985 Wehran Engineering Analytical Results. Soil Samples - Volume 3. Goose Farm Site, March 1985 Wehran Engineering Analytical Results. Soil Samples - Volume 4. Goose Farm Site, March 1985.
