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REMEDIAL ACTION CONTRACT 2 FOR REMEDIAL, ENFORCEMENT OVERSIGHT, AND NON-TIME CRITICAL REMOVAL ACTIVITIES

IN REGION 5

FINAL FEASIBILTY STUDY REPORT

LANE STREET GROUND WATER CONTAMINATION SITE ELKHART, ELKHART COUNTY, INDIANA

Prepared for United States Environmental Protection Agency

Region 5 77 West Jackson Boulevard

Chicago, IL 60604

Work Assignment No: 159-RICO-B5LH Contract No: EP-S5-06-02 Date Submitted: March 2016 Prepared by: SulTRAC SulTRAC Project Manager: William Earle Telephone No: (312) 658-1141 ext. 12 EPA Work Assignment Manager: Leslie Blake Telephone No: (312) 353-7921

Lane Street Ground Water Contamination Site March 2016 Feasibility Study Final

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EXECUTIVE SUMMARY Under United States Environmental Protection Agency (EPA) Remedial Action Contract (RAC) 2 for

Region 5, Contract No. EP-S5-06-02, Work Assignment (WA) No. 159-RICO-B5LH (EPA 2011 and

2014), SulTRAC has prepared this Feasibility Study (FS) report for the Lane Street Ground Water

Contamination Site (Site) in Elkhart, Indiana. The purpose of the WA is to conduct a Remedial

Investigation (RI) and FS (RI/FS) at the Site to allow EPA to select a remedy that eliminates, reduces, or

controls risks to human health and the environment. This FS report presents information needed to

support an informed risk-management decision regarding which remedy appears most appropriate for the

Site. The use of brand names within this report is for reference purposes only and does not represent an

endorsement of the item by SulTRAC or EPA.

Purpose and Methodology

The FS process is defined in the National Oil and Hazardous Substance Contingency Plan (NCP); the

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 guidance;

and, most specifically, in EPA’s “Guidance for Conducting Remedial Investigations and Feasibility

Studies under CERCLA” (EPA 1988). The FS process was developed to gather sufficient information to

support an informed risk-management decision regarding which remedy appears most appropriate for a

given site. The RI phase included data collection and risk assessment efforts (SulTRAC 2015).

Information from the RI forms the basis from which an FS is developed. First, potential applicable or

relevant and appropriate requirements (ARARs) are identified. This is a list of federal, state, and local

requirements which need to be met by the selected remedial alternative. Next, Remedial Action

Objectives (RAOs) are identified. RAOs are statements which describe the overall objective(s) of the

remedy. Closely related to the RAOs, Remedial Action Levels (RALs) are proposed. RALs are based, in

part, on ARARs. RALs are numerical goals for the identified constituents of concern (COCs) above

which action is necessary. The final selected RALs will be established in the Record of Decision (ROD).

Once the requirements are identified, the process of developing alternatives can begin. General Response

Actions (GRAs) are identified which will achieve, either alone or with other GRAs, the RAOs. Within the

GRAs, several technology and process options are identified. The identified technology and process

options are then screened for effectiveness, implementability, and cost. The technology and process

options which pass the screening are then assembled singly or in combination with one another into

alternatives. The alternatives are then screened against seven of the nine criteria:


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• Overall protection of human health and the environment

• Compliance with ARARs

• Long-term effectiveness and permanence

• Reduction of mobility, toxicity, or volume

• Short-term effectiveness

• Implementability

• Cost

State and community acceptance criteria are not included in the FS. These will be evaluated during the

preparation of the proposed plan and ROD.

Site Description

The Site, in Elkhart, Elkhart County, Indiana, occupies approximately 65 acres. The Site consists of both

active and inactive industrial, commercial, and residential properties, located above a groundwater plume

of unknown source(s). The Site is divided into two areas by County Road 106. The northern portion of

the Site consists of industrial and commercial properties; the southern portion of the Site contains 29

residential properties and undeveloped land. There are no schools, parks, or churches within the Site

boundaries; the closest school is located approximately 500 feet (ft) west of the Site. Three additional

schools are located within 1 mile of the center of the Site. Most of the residential properties and

industrial/commercial facilities within the approximate Site boundary do not now use private wells except

for one residence and five industrial/commercial locations; however, none of the industrial/commercial

facilities use groundwater as a source of potable water. All of the schools are reported to use municipal

water. The depth to groundwater at the Site has been recorded at approximately 6 to 12 ft below ground

surface (bgs), and the aquifer consists of unconsolidated sand and gravel materials.

Site Characterization

Based on both historical and remedial investigations, along with an independent environmental

investigation at the Site, one co-mingled groundwater contaminant plume has been identified consisting

primarily of tetrachloroethene (PCE), trichloroethene (TCE), cis-1,2-dichloroethene (cis-1,2-DCE), and

1,1-dichloroethane (1,1-DCA). Contamination in groundwater generally migrates in the direction of

groundwater flow. The groundwater at the Site flows from the northeast industrial/commercial portion of

the Site to the southwest residential portion of the Site. Contamination has been identified in the


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following groundwater zones: super shallow (0-10 ft bgs), shallow (10-20 ft bgs), intermediate (20-35 ft

bgs), and deep (more than 35 ft bgs). Limited contamination has been identified in the super shallow

groundwater zone; as such, the potential to volatilize into soil vapor is limited. Therefore, vapor intrusion

(VI) concerns are limited to the portion of the Site located north of County Road 106.

Risk Assessment Summary

The Lane Street Site human health risk assessment (HHRA) evaluated risks for the following receptors:

current and future residents; current and future industrial/commercial workers, current and future

construction workers, and current and future utility workers. The HHRA identified risks above the upper

end of EPA’s potentially acceptable risk range of 1 × 10-4 to 1 × 10-6 (one in ten thousand to one in one

million) only for future residents in both the industrial/commercial and residential areas (current residents

in the residential area are not exposed contaminated groundwater). This risk was driven by TCE. Risks for

all other receptors are within EPA’s potentially acceptable risk range. Ecological risks were also

evaluated; however, due to the subsurface nature of the contamination and lack of groundwater

discharging to surface water at or near the Site, no complete exposure pathways for ecological receptors

were identified.

Remedial Action Objectives and Remedial Action Levels

The RI identified contaminated groundwater and four Site-related contaminants requiring further

assessment in the FS: PCE, TCE, cis-1,2-DCE, and 1,1-DCA. The RAOs to address these contaminants

are identified below:

• RAO 1: Protection of human health from chemical risks and hazards by preventing actual or potential direct exposure to or potable use of groundwater containing COCs at levels resulting in unacceptable risk for current and future Site users, specifically current and future residents, industrial/commercial workers, utility workers, and construction workers.

• RAO 2: Protection of human health from chemical risks and hazards posed by VI associated with groundwater contamination for future Site users.

• RAO 3: Restoration of the aquifer to its beneficial use (including potentially as a community water supply).


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RALs were selected based on a review of the ARARs. The RALs are identified below:

• cis-1,2-DCE; 70 micrograms per liter (µg/L), based on the Maximum Contaminant Level (MCL)

• 1,1-DCA; 2.8 µg/L, based on the Regional Screening Level (RSL)

• TCE; 5 µg/L based on the MCL

• PCE; 5 µg/L based on the MCL

General Response Actions

The FS identifies the following GRAs as being applicable to the Site:

• No action

• Institutional controls (ICs)

• Monitored natural attenuation (MNA)

• Removal

• Discharge

• Containment

• In-situ treatment

• Ex-situ treatment

• Direct exposure pathway restriction

The following GRAs and technologies were retained:

• No action

o No action

• ICs

o Groundwater use restrictions

o Property access and land use restrictions

• MNA

o MNA


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• Discharge

o Discharge to Puterbaugh Creek


o Enhanced bioremediation


o Groundwater removal

o Activated carbon adsorption

o Air stripping

Assembly of Remedial Alternatives

The following remedial alternatives were developed for the Lane Street Site to address the groundwater

contamination:

Alternative 1: No Action

For Alternative 1, No Action, nothing would be done to mitigate risk and any reduction in toxicity or

volume of contaminants would occur as a result of natural processes. No monitoring of groundwater

would occur and therefore, no assessment of any reduction or potential expansion of groundwater

contamination would occur. No five-year reviews to assess protectiveness would be performed and no

monitoring of ICs would occur. Evaluation of this alternative is required under the NCP, as a baseline

from which the other alternatives can be compared.

Alternative 2: Minimal Action with Institutional Controls and Monitored Natural Attenuation

Under Alternative 2, Minimal Action with Institutional Controls and Monitored Natural Attenuation,

minimal action would be taken to mitigate risk. The ICs would be implemented to (1) limit groundwater

use and (2) prohibit residential use in the portion of the Site north of County Road 106. MNA would be

used to address the groundwater contamination within the plume. ICs include groundwater and land use

restrictions, which would be obtained through agreements with property owners, local (city or county)

ordinances, or registered deed restrictions. As part of the monitoring component of this remedy,

groundwater samples would be collected periodically, along with the associated reporting. Five-year

reviews would be required. The ICs and associated monitoring and reporting would have to remain in

place until the RAOs are achieved. For this alternative, it is estimated that it would take 20 to 35 years to

reach the RAOs. A period of 30 years was selected for cost estimating purposes.


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Alternative 3: In-Situ Groundwater Treatment through Bioremediation

Alternative 3, In-Situ Groundwater Treatment through Bioremediation, would combine ICs with in-situ

treatment using bioremediation to remediate the contaminated groundwater. The ICs would be similar to

those in Alternative 2, but would not be required for the same period of time. In-situ treatment using

bioremediation includes treatment of the groundwater using naturally occurring organisms to break down

hazardous substances into less toxic or non-toxic substances. The neighboring Geocel Corporation

(Geocel) facility is currently using a similar in-situ groundwater treatment remedy, and although remedial

activities have not yet reached final objectives, there has been success reducing concentrations throughout

most, but not all, of the Geocel plume. Following system design, microbes and a soluble substrate

(nutrients and an electron acceptor or energy source [“food”]) would be injected into the groundwater

aquifer to create conditions favorable for bioremediation. These injections would occur in at least three

well area locations within the industrial/commercial area of the Site, where the highest concentrations of

contaminants are found, and would address contamination in the shallow, intermediate, and deep

groundwater zones of the aquifer. There would be periodic monitoring during the remediation process,

which is estimated to require 10 years to reach the RAOs. Some flexibility is assumed in the design, so

that the final design could adequately address the contamination. The design would include measures to

minimize the potential for degradation to stall at cis-1,2-DCE or vinyl chloride. Several approaches are

discussed in the FS; the final decisions would be made during the design phase.

Alternative 4: Ex-Situ Groundwater Treatment by Extraction, Treatment, and Discharge

Alternative 4, Ex-Situ Groundwater Treatment by Extraction, Treatment, and Discharge (also referred to

as “pump and treat”), would combine ICs similar to Alternatives 2 and 3, with remediation of the

groundwater by pumping the groundwater out of the ground, treating the extracted water, and then

discharging the treated water to nearby surface water. This alternative would include construction of an

estimated 10 extraction wells, a treatment plant, and the discharge line. It is anticipated that the treatment

plan would use air stripping and carbon adsorption as the treatment mechanisms. Conceptually, the

treatment plant would be located within the industrial/commercial area of the Site. The proposed system

would utilize an estimated 10 extraction wells and would be tailored to site-specific conditions and

remediation goals. The exact number of extraction wells, their locations, and rate of extraction would be

determined during system design. The extracted water would be pumped to a treatment building where

the water would be treated prior to discharge to a nearby creek. Puterbaugh Creek is anticipated to be the

discharge location. This alternative is estimated to take 20 years to reach the RAOs.


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Comparative Analysis of Alternatives

Alternative 1 (No Action) did not pass the first two threshold criteria (overall protection of human health

and the environment and compliance with ARARs), and therefore cannot be selected. Alternatives 2, 3,

and 4 all passed the threshold criteria. Alternative 3 was ranked higher than Alternatives 2 and 4 on four

of the remaining criteria. Alternative 2 was ranked higher than Alternative 3 for cost, due to its lower

cost. Overall, Alternative 3 is the highest ranking alternative. The final ranking of the alternatives, before

state and community acceptance is factored in, is below:

1. Alternative 3 – In-Situ Groundwater Treatment through Bioremediation

2. Alternative 2 – Minimal Action with Institutional Controls and Monitored Natural Attenuation

3. Alternative 4 – Ex-Situ Groundwater Treatment by Extraction, Treatment, and Discharge


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TABLE OF CONTENTS Table of Contents ........................................................................................................................................... i

Acronyms and Abbreviations ...................................................................................................................... iii

1.0 Introduction ....................................................................................................................................... 1

1.3 Purpose and Scope ........................................................................................................................ 1

1.2 Report Organization ...................................................................................................................... 3

1.3 Site Description and History ......................................................................................................... 3

1.3.1 Site Description ..................................................................................................................... 3

1.3.2 Site History ........................................................................................................................... 4

1.3.3 Previous Site Investigations .................................................................................................. 6

1.3.4 Regional and Site Geology ................................................................................................... 9

1.3.5 Regional Hydrogeology ...................................................................................................... 10

1.3.6 Conceptual Site Model ........................................................................................................ 10

1.3.7 Nature and Extent of Contamination................................................................................... 11

1.3.8 Contaminant Risk Assessment ............................................................................................ 13

2.0 Identification and Screening of Technologies................................................................................. 15

2.1 Remedial Objectives ................................................................................................................... 15

2.2 Applicable or Relevant and Appropriate Requirements ............................................................. 15

2.3 Remedial Action Objectives ....................................................................................................... 17

2.4 Proposed Remedial Action Levels .............................................................................................. 18

2.5 General Response Actions .......................................................................................................... 19

2.6 Identification and Screening of Remediation Technology Types and Process Options ............. 19

2.6.1 Candidate Technology Identification .................................................................................. 21

2.6.2 Candidate Technology Screening ....................................................................................... 22

2.6.3 Retained Candidate Technologies ....................................................................................... 23

3.0 Development of Remedial Alternatives .......................................................................................... 26

3.1 Alternative 1: No Action ............................................................................................................. 26

3.2 Alternative 2: Minimal Action with Institutional Controls and Monitored Natural Attenuation 26

3.3 Alternative 3: In-Situ Groundwater Treatment through Bioremediation ................................... 28

3.4 Alternative 4: Ex-Situ Groundwater Treatment by Extraction, Treatment, and Discharge ....... 31

4.0 Detailed Analysis of Alternatives ................................................................................................... 34

4.1 Screening Criteria ....................................................................................................................... 34

4.1.1 Threshold Criteria ............................................................................................................... 35


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4.1.2 Primary Balancing Criteria ................................................................................................. 35

4.1.3 Modifying Criteria .............................................................................................................. 36

4.2 Individual Alternative Analysis .................................................................................................. 36

4.2.1 Alternative 1: No Action ..................................................................................................... 36

4.2.2 Alternative 2: Minimal Action with Institutional Controls and Monitored Natural Attenuation .......................................................................................................................................... 38

4.2.3 Alternative 3: In-Situ Groundwater Treatment through Bioremediation ........................... 39

4.2.4 Alternative 4: Ex-Situ Groundwater Treatment by Extraction, Treatment, and Discharge 40

5.0 Comparative Analysis of Alternatives ............................................................................................ 42

5.1 Comparative Analysis ................................................................................................................. 42

5.1.1 Overall Protection of Human Health and the Environment ................................................ 42

5.1.2 Compliance with Applicable or Relevant and Appropriate Requirements ......................... 42

5.1.3 Long-Term Effectiveness and Permanence ........................................................................ 43

5.1.4 Reduction of Toxicity, Mobility, or Volume through Treatment ....................................... 43

5.1.5 Short-Term Effectiveness ................................................................................................... 43

5.1.6 Implementability ................................................................................................................. 44

5.1.7 Cost ..................................................................................................................................... 44

5.2 Summary ..................................................................................................................................... 45

6.0 REFERENCES ............................................................................................................................... 46

FIGURES

Figure 1-1 Site Location Figure 1-2 Site Detail Figure 1-3 Conceptual Site Model Figure 1-4 Aerial Extent of Co-Mingled Groundwater Plume

Figure 3-1 Conceptual Location of Treatment Areas for Alternative 3 Figure 3-2 Extraction and Ex-Situ Treatment Location of Extraction Well Areas

TABLES

Table 2-1 Potentially Applicable or Relevant and Appropriate Requirements Table 2-2 Remedial Action Levels for Groundwater Table 2-3 Groundwater General Response Actions Table 2-4 Groundwater Candidate Technologies for Risk Mitigation Table 2-5 Groundwater Candidate Technologies Screening

Table 5-1 Comparative Analysis of Groundwater Remedial Alternatives

APPENDICES

Appendix A Remedial Action Alternative Costs


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ACRONYMS AND ABBREVIATIONS μg/L microgram per liter 1,1-DCA 1,1-dichloroethane 1,1,1-TCA 1,1,1-trichloroethane 3DMe® REGENESIS 3-D Microemulsion

amsl above mean sea level ARAR applicable or relevant and appropriate requirement

bgs below ground surface

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations cis-1,2-DCE cis-1,2-dichloroethene cm/s centimeter per second CO2 carbon dioxide COC constituent of concern COI constituent of interest COPC constituent of potential concern CRS® REGENESIS Chemical Reducing Solution CSIA Compound Specific Isotope Analysis CSM conceptual site model CTE central tendency exposure CVOC chlorinated volatile organic compound

DPE dual phase extraction

EA exposure area EA 1 Industrial Exposure Area EA 2 Residential Exposure Area EAD enhanced anaerobic dechlorination EPA United States Environmental Protection Agency EPC exposure point concentration

Flexsteel Flexsteel Industries, Inc. FS Feasibility Study ft feet ft/day feet per day ft2/day square feet per day ft/s feet per second

GAC granular activated carbon Geocel Geocel Corporation GRA General Response Action

HHRA human health risk assessment HI hazard index HRC® REGENESIS Hydrogen Release Compound HRS Hazard Ranking System


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IC institutional control IDEM Indiana Department of Environmental Management IDNR Indiana Department of Natural Resources ISCO in-situ chemical oxidation

MCL Maximum Contaminant Level MNA monitored natural attenuation MW monitoring well

NCP National Oil and Hazardous Substance Contingency Plan NPDES National Pollutant Discharge Elimination System NPL National Priorities List

O&M operation and maintenance ORC® REGENESIS Oxygen Release Compound

Pace Pace Analytical Energy Services, LLC PCE tetrachloroethene POTW publicly-owned treatment works

RAC Remedial Action Contract RAL Remedial Action Level RAO Remedial Action Objective RI Remedial Investigation RI/FS Remedial Investigation and Feasibility Study RME reasonable maximum exposure Roberts Roberts Environmental Services, LLC. ROD Record of Decision RSL Regional Screening Level RSMeans RSMeans Building Construction Cost Data

Site Lane Street Ground Water Contamination Site SSL site screening level START Superfund Technical Assessment and Response Team SVE soil vapor extraction

TCE trichloroethene THM trihalomethane TPE two phase extraction

U.S. United States USGS United States Geological Survey

VAS vertical aquifer sampling VFD variable frequency drive VI vapor intrusion VOC volatile organic compound VRP Voluntary Remediation Program

WA Work Assignment WESTON Weston Solutions, Inc.

ZVI zero valent iron


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1.0 INTRODUCTION Under the United States Environmental Protection Agency (EPA) Remedial Action Contract (RAC) 2 for

Region 5, Contract No. EP-S5-06-02, Work Assignment (WA) No. 159-RICO-B5LH (EPA 2011 and

2014), SulTRAC has prepared this Feasibility Study (FS) report for the Lane Street Ground Water

Contamination Site (Site) in Elkhart, Indiana. The purpose of the WA is to conduct a Remedial

Investigation (RI) and FS (RI/FS) at the Site to select a remedy that eliminates, reduces, or controls risks

to human health and the environment. This FS report presents information needed to support an informed

risk-management decision regarding which remedy appears most appropriate for the Site. The use of

brand names within this report is for reference purposes only and does not represent an endorsement of

the item by SulTRAC or EPA.

1.3 PURPOSE AND SCOPE The FS process is defined in the National Oil and Hazardous Substance Contingency Plan (NCP); the

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 guidance;

and, most specifically, in EPA’s “Guidance for Conducting Remedial Investigations and Feasibility

Studies under CERCLA” (EPA 1988). The FS process was developed to gather sufficient information to

support an informed risk-management decision regarding which remedy appears most appropriate for a

given site. The RI phase included data collection and risk assessment efforts (SulTRAC 2015).

This FS report uses information gathered during the RI to develop, screen, and evaluate remedial

alternatives to reduce potential human-health risk posed by contamination in groundwater and a limited

vapor intrusion (VI) pathway at the Site. The Final Lane Street RI Report recommended that an FS be

conducted to develop and evaluate remedial alternatives to address risks from exposure to trichloroethene

(TCE), tetrachloroethene (PCE), and their degradation compounds (SulTRAC 2015).

EPA’s “Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA”

specifies that the FS process should be flexible. Therefore, each RI/FS process may vary in its specifics

(EPA 1988). The general steps of this FS are summarized below.

1. Identifying Applicable or Relevant and Appropriate Requirements (ARARs): Remedial actions performed under CERCLA must meet ARARs for selected remedies unless a specific ARAR waiver is requested. ARARs are federal, state, and local public health and environmental requirements used to (1) characterize the extent of Site cleanup, (2) identify sensitive land areas and land uses, (3) develop remedial alternatives, and (4) direct site remediation. CERCLA and the NCP require that remedial actions comply with federal ARARs and also with state and local


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ARARs that are more stringent than their federal counterparts as long as they are legally enforceable and consistently enforced. ARARs are evaluated early in the work planning process so that field work can be designed to collect data necessary to satisfy ARAR requirements and, if necessary, to identify and evaluate remedial alternatives relative to ARARs.

2. Establishing Remedial Action Objectives (RAOs): Site-specific RAOs that are protective of human health and the environment are identified. The RAOs specify the constituents of concern (COCs) based in the risk assessment, exposure routes, and receptors.

3. Establishing Remedial Action Levels (RALs): RALs are risk-based or ARAR-based chemical-specific concentrations that further define the RAOs. RALs are used to estimate the extent of contamination requiring remedial action.

4. Developing General Response Actions (GRAs): GRAs are developed by defining containment, treatment, excavation, or other actions, singly or in combination, to satisfy the RAOs. The GRAs take into account requirements for protectiveness as identified in the RAOs and based on the Site’s chemical and physical characteristics.

5. Identifying and Screening Remedial Technologies: Applicable remedial technologies are identified and screened against the developed GRAs. Treatment technologies are identified and screened so that the most applicable technologies are selected for the COCs present and the Site’s characteristics. Screening primarily is based on a technology’s ability to address the COCs effectively but also includes implementability and cost considerations.

6. Developing Remedial Alternatives: Representative remedial technologies are carried forward into the alternative development stage. The effort includes combining representative technologies and GRAs into alternatives, assessing the appropriateness of the suggested alternatives, and developing the alternatives in sufficient detail for identification of action-specific ARARs.

7. Screening Remedial Alternatives for Effectiveness, Implementability, and Cost: Potential remedial alternatives are screened with respect to effectiveness, implementability, and cost before they are considered for detailed evaluation.

8. Performing a Detailed Analysis of Remedial Alternatives: The detailed analysis of alternatives presents the relevant information needed to compare the remedial alternatives. Detailed analysis of alternatives consists of a detailed evaluation of each alternative against the evaluation criteria set forth in the NCP.

9. Performing a Comparative Analysis of Remedial Alternatives: Once the alternatives have been individually assessed against the evaluation criteria, a comparative analysis is conducted to evaluate the performance of each alternative in relation to each evaluation criterion. This process is in contrast to the analysis discussed in Step 8 above, in which each alternative is analyzed independently, without considering other alternatives. The purpose of the comparative analysis is to identify the advantages and disadvantages of each alternative relative to the others so that decision-makers can identify and balance the key advantages and disadvantages of each alternative.


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1.2 REPORT ORGANIZATION This report consists of the six sections summarized below.

• Section 1.0, Introduction: This section discusses the FS purpose and report organization, and includes the Site description and History.

• Section 2.0, Identification and Screening of Technologies: This section discusses the regulatory framework supporting this FS, including the remedial objectives, ARARs, RAOs, and RALs. The section then discusses the proposed remedial alternatives, the GRAs, and the identification and screening of technologies, including a summary of the retained technologies.

• Section 3.0, Development of Remedial Alternatives: This section describes the remedial alternatives developed based on the screening of technologies.

• Section 4.0, Detailed Analysis of Alternatives: This section discusses the screening criteria for the alternatives and presents a detailed analysis of each retained alternative, including a detailed description of the alternative and an evaluation against each screening criterion.

• Section 5.0, Comparative Analysis of Alternatives: This section presents a direct comparison of the selected alternatives based on the evaluation criteria.

• Section 6.0, References: This section lists the references used to prepare this report.

1.3 SITE DESCRIPTION AND HISTORY This section discusses the site description, site history, previous site investigations, regional and site

geology, and regional hydrogeology.

1.3.1 Site Description

The Site, in Elkhart, Elkhart County, Indiana, occupies approximately 65 acres (Figure 1-1). The Site

consists of both active and inactive industrial, commercial, and residential properties, located above a

groundwater contaminant plume of an unknown source(s). Most of the residential properties and

industrial/commercial facilities within the approximate Site boundary are connected to City of Elkhart

municipal water and do not use private wells except for one residence and five industrial/commercial

locations; however, none of the industrial/commercial facilities are using Site groundwater as a source of

potable water. The depth to groundwater at the Site has been recorded at approximately 6 to 12 feet (ft)

below ground surface (bgs), and the aquifer consists of unconsolidated sand and gravel materials. As

presently defined, the Site is bounded by Barley Street on the south, the eastern property boundary of the

private property on County Road 106 on the east, and an undeveloped property on the west. North of

County Road 106, the eastern boundary widens to include the industrial/commercial area bounded by

Marina Drive on the east, Ada Drive on the west, County Road 106 on the south, and Cooper Drive on the


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north. During the RI field activities, SulTRAC conducted investigations both within and outside these

originally established site boundaries to investigate the groundwater plume at the Site. The northern

boundary extends approximately 750 ft north of Cooper Drive to include some additional

industrial/commercial properties in the northeast corner (see Figure 1-2).

Within the presently defined Site boundaries there are approximately 29 residential properties along Lane

Street and County Road 106, and 17 parcels in the industrial/commercial park area to the north of Lane

Street, including both operating and vacant industrial and commercial buildings (see Figure 1-2). There

are no schools, parks, or churches within the Site boundaries. However, within a 1-mile radius from the

intersection of Lane Street and County Road 106, there are four schools and one child daycare center. Of

these four schools, the Michiana Christian Montessori School is the closest to the Site, located at 23830

County Road 106, approximately 500 ft west of the Site. SulTRAC verified with an employee of the

Michiana Christian Montessori School that the school is utilizing City of Elkhart municipal water. In

addition, SulTRAC verified with the City of Elkhart that all of the schools are utilizing City of Elkhart

municipal water. Drinking water is supplied by the City of Elkhart public water supply system from three

main well fields, Northwest, North Main, and South well fields, and private wells. The shallowest and

closest downgradient municipal well is within the North Main Street Well Field (itself a National

Priorities List [NPL] site), approximately 3 miles to the southwest, and extends to a depth of 46 ft bgs; the

deepest well is found within the South Well Field and extends to a depth of 111 ft bgs (Malcolm Pirnie

2011).

To the east of Lane Street is a separate contaminated groundwater plume along Kershner Lane that is

associated with the Geocel Corporation (Geocel) facility at 2502 Marina Drive in the

industrial/commercial park. The Geocel plume originated from a PCE release and appears to be separate

from the Site plume. Geocel is addressing this plume under the Indiana Department of Environmental

Management (IDEM) Voluntary Remediation Program (VRP) (EPA 2011). At the Geocel facility, a

combination of remedies is being used: soil vapor extraction (SVE) and air sparging (along with 1 round

of in-situ chemical oxidation [ISCO]) in the source area started in 2009, and enhanced bioremediation

away from the source area, with full scale injections taking place in 2012.

1.3.2 Site History

On August 22, 2007, IDEM was notified by the Elkhart County Health Department that a Lane Street

resident had drinking water from their private water-supply well tested because of known groundwater

contamination from volatile organic compounds (VOCs) in the residential area one street east of Lane


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Street (Kershner Lane). The resident’s drinking water sample was submitted to Water Quality Laboratory

at Heidelberg College in Tiffin, Ohio. The analysis revealed elevated levels of TCE, at 1,560 micrograms

per liter (μg/L), as well as other breakdown products of VOCs (IDEM 2007). The residential and

industrial properties along Lane Street used private wells for domestic water supply at the time in 2007.

In late August 2007, IDEM conducted a Preliminary Assessment of the Site, which consisted of a site

reconnaissance of the surrounding properties and sampling water from 39 private water supply wells for

VOC analysis. Sample results indicated that 11 residential wells and two business wells (north of County

Road 106) contained elevated levels of VOCs, mainly TCE (IDEM 2007).

IDEM provided bottled water to the residences that contained elevated levels of VOCs in their private

well water and alerted EPA to the concentrations above EPA Maximum Contaminant Levels (MCLs) in

the drinking water at the Site (IDEM and EPA 2009). EPA, under the Superfund Technical Assessment

and Response Team (START) contract with Weston Solutions, Inc. (WESTON), conducted confirmatory

groundwater sampling at the Site in September 2007. EPA sample results confirmed that some VOC

concentrations were above MCLs in the residential groundwater. Additionally, in December 2007, EPA

and WESTON conducted 24-hour indoor air sampling in two residences where elevated TCE

concentrations in groundwater had been documented. TCE, PCE, and vinyl chloride were not detected in

either air samples collected at the two residences (WESTON 2008).

EPA, under the Superfund Removal Program, authorized the installation of carbon filtration water

treatment systems for the affected residences as well as one year of maintenance on the systems until a

more permanent solution could be implemented. The treatment systems were installed in the fall of 2007

and winter of 2007 and 2008 for 13 residences located on Lane Street (WESTON 2008).

In November 2008, EPA (under the Superfund Removal Program) connected 26 residences (23 on Lane

Street, two on Barley Street, and one on County Road 106) to the City of Elkhart municipal water supply

system and abandoned the residential wells at those residences (EPA 2011). Because the groundwater

plume appears to be flowing in a south-southwesterly direction, several additional unaffected

downgradient residences were connected to the City of Elkhart municipal water supply system.

Residences further south of Barley Street were already connected to municipal water. One resident on

County Road 106 within the current Site is not connected to municipal water, having declined to be

connected.


6

IDEM conducted site visits at facilities in the industrial/commercial park to the north of Lane Street in

April and September 2008 and found at least three facilities that have stored or used hazardous

substances. However, there was insufficient information to evaluate whether releases from these facilities

contribute to the groundwater plume associated with the Site (IDEM and EPA 2009). As many as eight

other facilities are within the Site study area that was investigated. A review of historical records indicate

that many of these facilities contained septic systems prior to 2007. Many of the companies that exist or

once existed in the area, use or used the chemicals found in the contaminated groundwater plume.

1.3.3 Previous Site Investigations

As part of the Hazard Ranking System (HRS) process for including a site on the NPL, IDEM conducted a

Site Inspection from April 14 through April 17, 2008. IDEM collected 132 groundwater samples from

private residential wells and discrete locations in the industrial/commercial park to the north of County

Road 106 through direct-push methods. Groundwater samples were generally collected from depths of 8

ft bgs (corresponding to the position of the water table), 18 ft bgs, and 30 ft bgs, except when

groundwater was not encountered at 8 ft bgs or topographic concerns required modification of the

sampling plan (IDEM 2008). Additionally, nine soil samples were collected from depths ranging from

4 to 9 ft bgs in the industrial/commercial park in an attempt to identify a source area. It was concluded

during this investigation that the groundwater is likely flowing south to southwest towards the St. Joseph

River, which is located approximately 1.4 miles south of the Site. Twelve groundwater samples from

residential private wells contained concentrations of TCE and other VOCs during this sampling event,

and many of the direct-push discrete groundwater samples contained elevated concentrations of VOCs,

with a maximum TCE concentration of 770 μg/L collected from a direct-push discrete sample in the

industrial/commercial park to the north of Lane Street. No VOCs were detected in the soil samples

collected during IDEM’s 2008 Site Inspection (IDEM 2008). Section 6 of the Final Lane Street RI Report

presents IDEM vertical aquifer sampling (VAS) data on figures (SulTRAC 2015). On September 14,

2009, the Site was listed on the NPL and the process of investigation under the EPA Superfund Removal

Program began.

Prior to and during SulTRAC’s investigation at the Site, Roberts Environmental Services, LLC (Roberts)

was hired by Flexsteel Industries, Inc. (Flexsteel) to conduct an environmental investigation at 2503

Marina Drive and 3507 Cooper Drive properties, independent of EPA’s RI at the Site. Flexsteel is the

owner of the former Dygert Seating facility that previously conducted business at the aforementioned

locations. Between March 2011 and November 2013, Roberts collected grab groundwater and soil

samples and installed numerous groundwater monitoring wells on and surrounding the former Flexsteel


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property. In March 2011, Roberts advanced 19 borings along the northern right-of-way of Cooper Drive

and collected three to four VAS groundwater samples from each boring. In October 2011, Roberts

conducted additional VAS at 23 locations south of Cooper Drive near the former Flexsteel property. In

November and December 2011, Roberts installed nested monitoring wells, consisting of three to five

wells of varying depths per nest, at 13 locations surrounding the three facilities. Following well

development, these wells were sampled for a limited list of VOCs including but not limited to TCE, PCE,

and 1,1,1-trichloroethane (1,1,1-TCA) (Roberts 2013).

To address the concerns about possible “dumping” that was allegedly conducted on the southwestern

portion of the former Flexsteel property, Roberts advanced 94 shallow borings in a grid pattern in the

southwest corner in July 2012. Three subsurface soil samples were collected from 2.5 to 4 ft bgs from

each boring for limited VOC analysis, for a total of 282 soil samples. Roberts also collected soil samples

from the loading dock areas of the former Flexsteel property. There were no detectable concentrations of

the selected VOCs in the soil samples (Roberts 2013).

In July, September, and October 2012, Roberts collected additional VAS on the southern portion of

2503 Marina Drive, installed additional monitoring wells (MW) to better characterize the contamination

detected near the water table at monitoring wells MW-10 and MW-11, and installed additional nested

well sets (MW-14 and MW-15) at similar locations where IDEM had performed VAS in 2007. By this

time, a total of 54 monitoring wells had been installed at 15 locations ranging from just north of Cooper

Drive (MW-13) to approximately 300 ft north of County Road 106 (Henke Street) on the western

property boundary of 3506 Henke Street (MW-12) (Roberts 2012). The highest concentration of TCE

detected in the Roberts’ monitoring wells was 410 μg/L at R-MW-12i (screened from 21 to 26 ft bgs),

which corresponded to VAS sample location GW-N (or sample ID E2Q90) collected at 30 ft bgs where

IDEM had detected a high TCE concentration of 690 μg/L in groundwater (Roberts 2012). Well R-MW-

12i is located on the Riverside Tool property at 3504 Henke Street.

TCE and PCE were also detected in Roberts’ well MW-13, the northernmost monitoring well. Roberts

conducted additional VAS further north on the 2601 Marina Drive property in May 2013. Roberts

advanced an additional 16 VAS locations (identified as PB-1 through PB-16), which included collecting

four groundwater samples from each location. The maximum TCE and PCE concentrations were

120 μg/L and 380 μg/L, respectively, both detected at VAS location PB-9 at 2601 Marina Drive

(Roberts 2013).


8

Roberts continued further investigation on 2503 Marina Drive in September 2013 by conducting VAS

just north of the building on the property. Five additional VAS locations (identified as GW-26 through

GW-30) were advanced, which included collecting six groundwater samples from each location. At two

locations (GW-28 and GW-29), TCE was detected in the shallowest samples collected from 2 to 12 ft bgs.

The other three laterally (east to west) adjacent VAS sample results did not exhibit detectable TCE

concentrations from the same shallow sampling interval (Roberts 2013).

In addition to these five VAS locations, Roberts installed 17 monitoring wells at already established

nested well locations (identified as MW-1, MW-2, MW-3, MW-5, MW-7, MW-8, and MW-13). For

example, the nested monitoring wells at MW-1 had four pre-existing monitoring wells, and Roberts

installed a fifth well at that nested well location. The additional wells were installed in various depths not

previously sampled.

In October 2013, Roberts re-sampled two of their monitoring wells and installed an additional “super

shallow” well (designated as “-ss”) at the MW-7 nested well location. Subsequently, in November 2013,

Roberts installed four additional monitoring wells on the property north of Cooper Drive at 2601 Marina

Drive, near the area where previous investigation had detected high PCE and TCE concentrations, and

installed another “super shallow” shallow screening well at the MW-8 nested well location. The sample

results from monitoring wells installed on the 2601 Marina Drive property (MW-16 nested well location)

confirmed elevated TCE and PCE concentrations discovered during the VAS in May 2013. The

groundwater samples collected from the super shallow monitoring wells installed at MW-7 (MW-7ss) and

MW-8 (MW-08ss) on the 2503 Marina Drive property had TCE concentrations of 5.3 μg/L and 1.7 μg/L,

respectively (Roberts 2013). The Roberts’ groundwater sampling data were also incorporated into

SulTRAC’s Site database to generate tables and figures for Site-wide interpretation in the RI and this FS.

In August 2014, the current tenant at 2503 Marina Drive collected three sub-slab soil vapor samples and

one outdoor air ambient sample in the industrial/commercial area above the highest concentrations of the

TCE within the plume. No VOC concentrations exceeded screening levels.

In November 2015, Roberts collected additional groundwater samples at the Site. A total of 90

monitoring wells were sampled from 11 of 22 EPA wells and all of 79 Roberts’ wells. Samples were

submitted for a limited list of VOCs to include the COCs at the Site. The data is similar to the 2011-2013

results that were described in Roberts’ 2012 and 2013 letter reports to IDEM, and also provided to EPA.


9

Also in November 2015, Roberts submitted groundwater samples to Pace Analytical Energy Services,

LLC (Pace) for forensic analyses to investigate if the impacts of chlorinated ethenes to the groundwater

could be traced to similar sources. The main VOCs of concern were PCE, TCE, and cis-DCE. Compound

Specific Isotope Analysis (CSIA) was performed on 11 samples from the centerline of the Lane Street

Site plume (from one EPA well and 10 Roberts’ wells). Roberts concluded that there was a single source;

SulTRAC believes that the data shows there are multiple sources to the Lane Street Site.

The Roberts’ November 2015 VOC groundwater and CSIA sample results are discussed in a response

letter to EPA, titled “Public Comments to U.S. EPA August 2015 Final Remedial Investigation Report”

dated December 28, 2015. EPA and SulTRAC have prepared a response which will be added to the

administrative record for the site.

1.3.4 Regional and Site Geology

Regionally, Elkhart, Indiana, is part of the St. Joseph River basin whose surficial geology predominantly

is influenced by glacial and post-glacial activity. Quaternary glacial deposits in the St. Joseph River basin

have been documented to be up to 450 ft thick. In the vicinity of the Site, these deposits are reported to be

approximately 170 ft thick (United States Geological Survey [USGS] 1989). The Elkhart area is part of

the Kankakee Lowland, a broad, flat region that extends from Illinois across northwestern Indiana and

into southwestern Michigan. The St. Joseph River floodplain consists of Holocene alluvium underlain by

thick outwash sand and gravel. The St. Joseph River basin has been influenced by a complex glacial

history, including several glacial advancements and retreats that created layers of interbedded clayey till

and outwash sand and gravels (Indiana Department of Natural Resources [IDNR] 1987).

Bedrock underlying the St. Joseph River Basin deposits predominantly consists of horizontal layered

Paleozoic limestone, dolomite, sandstone, siltstone, and shale. Beneath the bedrock are Precambrian

igneous basement rock primarily composed of granite and basalt. Surficial bedrock in the northwestern

portion of the St. Joseph River Basin consists of alternating beds of black and gray-green Ellsworth Shale

located at approximately 600 ft above mean sea level (amsl); (IDNR 1987).

The site-specific geology was evaluated during the RI activities through the visual classification of

subsurface soil using the unified soil classification system for logging soils collected during the drilling

and logging of soil borings for VAS and monitoring well installation. SulTRAC confirmed the underlying

geology to be consistent with the unconsolidated Pleistocene glacial deposits, which primarily consist of


10

unstratified, fine- to coarse-grained sand, and sand and gravel outwash with discrete or discontinuous silt

and clay lenses overlying bedrock at approximately 155 ft bgs.

1.3.5 Regional Hydrogeology

The principal source of groundwater in Elkhart County is the unconsolidated outwash sand and gravel

deposits known as the St. Joseph Aquifer overlying the Paleozoic bedrock. It is within the St. Joseph

Aquifer that the groundwater contamination at the Lane Street Site is located. The St. Joseph Aquifer is

composed of fine- to medium-grained sand, with zones of coarse sand and gravel. Interspersed within

these deposits are thin clay units of limited areal extent. The St. Joseph Aquifer generally thickens from

south to north and varies from 20 ft thick near the southern boundary of the St. Joseph River Basin to

approximately 400 ft thick over the buried bedrock valley at the western edge of Elkhart County. The

horizontal hydraulic conductivity (K value) of the upper portion of the St. Joseph Aquifer is estimated to

be approximately 170 feet per day ([ft/day]; 6.0 × 10-2 centimeter per second [cm/s]) within 1 mile of the

St. Joseph River and approximately 370 ft/day (1.3 × 10-1 cm/s) at areas greater than 1 mile from the

river. Transmissivity is estimated as high as 57,000 square feet per day (ft2/day), with an average of

8,100 ft2/day (USGS 1998). The City of Elkhart obtains water from this aquifer. Drinking water for the

City of Elkhart public water supply system comes from three main well fields, Northwest, North Main,

and South well fields. Some properties within Elkhart, and the Lane Street Site, have private wells. The

shallowest well and closest downgradient municipal well is within the North Main Street Well Field

(itself an NPL site) and extends to a depth of 46 ft bgs; the deepest well is found within the South Well

Field and extends to a depth of 111 ft bgs (Malcolm Pirnie 2011). SulTRAC conducted site-specific

hydraulic conductivity aquifer tests at the Site and evaluated the hydraulic conductivity to be an average

of 140 ft/day (5 × 10-2 cm/s) in the intermediate and deep zones at the Lane Street Site. Details of the

results are presented in Section 4.6 of the Final Lane Street RI Report (SulTRAC 2015).

1.3.6 Conceptual Site Model

Figure 1-3 shows the conceptual site model (CSM) for the Site, including potential sources, release

mechanisms, exposure pathways and migration routes, and potential receptors. Analytical results have

identified one co-mingled groundwater contaminant plume from multiple sources consisting primarily of

PCE, TCE, one of their degradation products cis-1,2-dichloroethene (cis-1,2-DCE), and 1,1-

dichloroethane (1,1-DCA). Contamination in groundwater generally migrates in the direction of

groundwater flow. The groundwater at the Site flows from the northeast industrial/commercial portion of

the Site to the southwest residential portion of the Site. Contamination has been identified in both

historical and remedial investigations, along with an independent environmental investigation at the Site


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in the following groundwater zones: super shallow (0-10 ft bgs), shallow (10-20 ft bgs), intermediate (20-

35 ft bgs), and deep (more than 35 ft bgs). Limited contamination has been identified in the super shallow

groundwater zone; therefore, the potential to volatilize into soil vapor is limited. Therefore, any VI

concerns are limited to the portion of the Site located north of County Road 106, which is presently

industrial/commercial land use. Section 5.8 of the Final Lane Street RI Report discusses the lack of VI on

the Site in greater detail (SulTRAC 2015).

The CSM presents surface soil and groundwater as the primary affected medium transporting

contamination at the Site. The secondary affected medium includes subsurface soil due to sorption and

diffusion within groundwater in low-permeability subsurface soil zones.

The fate and transport of the following groundwater constituents of interest (COIs) were evaluated: PCE,

TCE, cis-1,2-DCE and 1,1-DCA. Generally, the water table lies at approximately 6 to 12 ft bgs, and

groundwater generally flows toward the southwest. These COIs are mobile in groundwater moving

through the industrial/commercial area into the residential area. Human and ecological receptors could be

exposed to these COIs primarily through direct ingestion of groundwater, dermal contact, and inhalation.

Direct exposure to groundwater is a potential concern for properties using private water wells as a potable

water source. Most, but not all, properties at the Site are now on a municipal water supply.

1.3.7 Nature and Extent of Contamination

This section briefly describes the nature and extent of contamination at the Lane Street Site. Detailed

descriptions and analyses of the nature and extent of contamination are presented in Section 5 of the Final

Lane Street RI Report (SulTRAC 2015). The following is a brief discussion of the nature and extent of

contamination based on the site characterization activities discussed in Section 1.3.3 above.

Based on historical information and information developed during the RI, VOCs were identified as the

primary COIs at the Site. COIs were based on the maximum detected concentration exceeding the site

screening level (SSL). The SSL is defined as the most stringent of EPA’s MCLs and tap water Regional

Screening Levels (RSLs), the IDEM’s Remediation Closure Guide, IDEM’s VI Guidance Supplement,

and EPA’s VI screening level calculator. The following ten constituents were identified at more than one

sampling location, and were considered to be COIs in groundwater:

• TCE

• PCE


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• cis-1,2-DCE

• 1,1-DCA

• Bromodichloromethane

• Chloroform

• Dibromochloromethane

• bis(2-ethylhexyl)phthalate

• Arsenic

• Manganese

The identified groundwater COIs were further evaluated with respect to relevance at the Lane Street Site.

Arsenic, manganese, and bis(2-ethylhexyl)phthalate were detected in groundwater above the SSL;

however, they are not considered site-related contaminants. Arsenic is likely present at background

concentrations, and in any event was present only at concentrations below the MCL. Manganese and

nis(2-ethylhexyl phthalate were considered to be artifacts and not related to site contamination.

Bromodichloromethane, chloroform, and dibromochloromethane are trihalomethanes (THMs), a group of

four chemicals that are formed when chlorine or other disinfectants react with naturally occurring organic

and inorganic matter in water. EPA has established an MCL for Total THM of 80 µg/L and none of these

constituents individually or when summed together had concentrations that exceeded this value. TCE,

PCE, cis-1,2-DCE, and 1,1-DCA were thus considered the primary COIs in groundwater for the Lane

Street Site and are further discussed in Sections 5.3 and 6.6 of the Final Lane Street RI Report (SulTRAC

2015).

The COIs were evaluated across the following depth-based groundwater zones:

• Super shallow groundwater generally based on data from monitoring wells or VAS screened between 0 and <10 ft bgs

• Shallow groundwater generally based on data from monitoring wells or VAS screened between >10 and <20 ft bgs

• Intermediate groundwater for wells or VAS screened between >20 and <35 ft bgs

• Deep groundwater for wells or VAS screened below 35 ft bgs


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COI contamination was primarily observed in the shallow and intermediate groundwater zones in the

northern (primarily PCE) and central portions (primarily TCE) of the industrial/commercial area flowing

with groundwater toward the residential area in the southwest. However, only TCE was found to present a

potentially unacceptable risk based on EPA criteria (SulTRAC 2015). Figure 1-4 shows the maximum

observed extent of the current groundwater plume, which is defined as areas where groundwater

contaminants exceed SSLs. Additional plume figures are shown in Section 6.6 of the Final Lane Street RI

Report (SulTRAC 2015). For the purpose of this FS, the groundwater plume was redrawn using more

recent (November 2015)data and plume limits based on RALs.

SulTRAC collected groundwater samples and performed a VI evaluation as part of the RI field activities.

As part of the VI evaluation, soil vapor samples were collected from 11 locations. Based on the results,

the main COI, TCE, was not detected at levels exceeding the soil vapor SSLs. Although chloroform,

dichlorodifluoromethane, and PCE were detected above soil vapor residential SSLs from sampling points

located in the industrial/commercial area, the concentrations are below industrial/commercial SSLs.

Chloroform and dichlorodifluoromethane, also known as Freon-12, a common refrigerant, are not

associated with Site groundwater contamination.

1.3.8 Contaminant Risk Assessment

The human health risk assessment (HHRA) evaluated current and potential future health risks and hazards

associated with exposure to site-related constituents of potential concern (COPCs, a term from the risk

assessment to indicate chemicals which will be further evaluated) at the Lane Street Site. Ecological risks

were also evaluated; however, due to the subsurface nature of the contamination and lack of groundwater

discharging to surface water at or near the site, no complete exposure pathways for ecological receptors

were identified. The primary objectives of the HHRA were as follows:

• Evaluate if site-related constituents detected in environmental media pose unacceptable risks to current and future human receptors under baseline (un-remediated) conditions.

• Provide information to support decisions regarding the need for further evaluation or action based on current and reasonably anticipated future land use.

The HHRA evaluated potential exposures of human receptors to constituents detected in environmental

media at the Lane Street Site. The Site was subdivided into exposure areas (EAs), primarily on the basis

of current and reasonably anticipated future land use and contaminant distribution. At the Lane Street

Site, these areas are designated as follows:


14

• EA 1 – Industrial/Commercial Exposure Area

• EA 2 – Residential Exposure Area

Based on the information presented in the Lane Street Site HHRA, the following conclusions were drawn:

• Total risks exceed 1 × 10-4, the upper end of EPA’s potentially acceptable risk range, only for potential future residents (there are presently no residents in EA-1) at EA 1 (7 × 10-4) and EA 2 (2 × 10-4). The primary COC, based on the risk assessment at both EAs is TCE (cumulative risk of 6.6 × 10-4 [EA 1] and 1.8 × 10-4 [EA 2]).

• Total risks for all other receptors (except as noted in the next bullet) are within EPA’s potentially acceptable risk range and are driven by TCE and other VOCs, including chloroform (both EAs and Property 1), PCE (EA 1 only), bromodichloromethane (both EAs and Property 1), and 1,1-DCA (EA 2 only).

• Total risk from COPCs for future industrial/commercial workers at Property 2 in EA 1 is 0.0E+00; no carcinogenic COPCs were identified at this property.

• Total hazards exceed 1 for all receptors at both EA 1 and EA 2 (except as noted in the next bullet). The only hazard-based COPCs are TCE (all receptors) and cis-1,2-DCE (industrial/commercial workers [EA 2 only] and residents [both EAs]).

• Total hazards for future industrial/commercial workers at Property 2 in EA 1 is 0.2 and considered insignificant.

• The increased amount of dermal exposure to groundwater related to specific work tasks at Property 1 in EA 1 increases dermal risk and hazard, but does not change the cumulative risk or hazard for future industrial/commercial workers.

• The EA- and property-specific exposure point concentrations (EPCs) for chloroform, bromodichloromethane, and dibromochloromethane are individually and as a sum less than the MCL for Total THM (80 µg/L). The presence of these three COPCs is not related to any potential degradation of either PCE or TCE. The presence of chloroform, bromodichloromethane, and dibromochloromethane has been attributed to the potential release of chlorinated drinking water at other sites. While it is not known if such a release has occurred at or near the Lane Street Site, the municipal water supply, which is treated with chlorine, is used at and in the vicinity of the Site and some of the properties near the Site use septic systems.

• The total risks and hazards calculated under central tendency exposure (CTE) conditions are approximately 1 to 4 times lower than those calculated under reasonable maximum exposure (RME) conditions, depending on the receptor considered.

• Potentially significant VI-related risks are limited to potential future residents at EA 1 in the Plume area. The cumulative VI-related risk of 3.7 × 10-6 is within EPA’s target risk range and is driven by potential exposure to PCE (3.2 × 10-6). No potentially significant (greater than 1) VI-related hazards were identified for any receptors in either EA 1 or EA 2.


15

2.0 IDENTIFICATION AND SCREENING OF TECHNOLOGIES This section presents the regulatory framework supporting this FS and discusses the remedial objectives

(Section 2.1); Applicable or Relevant and Appropriate Requirements (ARARs) at the federal, state, and

local levels (Section 2.2); Remedial Action Objectives (RAOs) to protect human health (Section 2.3);

proposed Remedial Action Levels (RALs) (Section 2.4); and General Response Actions (GRAs)

(Section 2.5).

2.1 REMEDIAL OBJECTIVES The process of identifying and screening technologies begins with the creation of the remedial objectives.

The remedial objectives of the FS process include the ARARs, RAOs, and RALs.

CERCLA specifies that Superfund remedial actions must meet any federal standards, requirements,

criteria, or limitations determined to be legally ARARs. Also included is the provision that state ARARs

must be met if they are more stringent than federal requirements (EPA 1988). For the Site, the RAOs

consist of goals for protecting human health from exposure to contaminated groundwater. The proposed

RALs were selected based on site-specific risks and hazards from the HHRA presented in the Final Lane

Street RI Report, along with a review of the ARARs, and are consistent with the NCP. Final RALs will be

provided in the Record of Decision (ROD). Together, the ARARs, RAOs, and RALs create the site-

specific “regulatory” framework for the remedial action and for the final remedy to achieve. The ARARs,

RAOs, and RALs are discussed in detail in the following sections.

2.2 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS Regulatory requirements, standards, and guidance are referred to as ARARs. ARARs depend on the

detected contaminants, site-specific characteristics, and particular remedial actions proposed for the Site.

This section discusses the identification of ARARs for the Site.

Under Section 121(d)(1) of CERCLA, remedial actions must be protective of human health and the

environment. Additionally, CERCLA remedial actions must meet a level and standard of control that

attains standards, requirements, limitations, or criteria that are “applicable or relevant and appropriate”

under the circumstances of the release. These requirements are derived from federal and state laws and

are known as ARARs. Federal, state, or local permits are not necessary for removal or remedial actions

implemented under a CERCLA remedial action, but applicable substantive requirements of the permits

must be met.


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The NCP (Title 40 of the Code of Federal Regulations [CFR] 300.5) defines “applicable requirements” as

“…those cleanup standards, standards of control, and other substantive environmental

protection requirements, criteria, or limitations promulgated under federal or state law that

specifically address a hazardous substance, pollutant, contaminant, remedial action, location, or

other circumstance at a CERCLA site.”

The NCP (40 CFR 300.5) defines “relevant and appropriate requirements” as

“…those cleanup standards, standards of control, and other substantive requirements, criteria,

or limitations promulgated under federal or state environmental or facility siting laws that,

while not applicable to a hazardous substance, pollutant, contaminant, remedial action,

location, or other circumstance at a CERCLA site, address problems or situations sufficiently

similar to those encountered at the CERCLA site that their use is well suited to the particular

site.”

State requirements identified in a timely manner and that are more stringent than corresponding federal

requirements may be applicable or relevant and appropriate. Three types of ARARs have been identified

on a site-specific basis for the Site: chemical-, location-, and action-specific ARARs. Each type of ARAR

is briefly described below.

Chemical-Specific ARARs are health- and risk-based numerical values and methodologies that, when

applied to site-specific conditions, result in the establishment of numerical values. These values and

methodologies (such as promulgated standards and risk assessments, respectively) establish acceptable

concentrations of a chemical contaminant that may remain in the environment.

Location-Specific ARARs are restrictions placed on the concentrations of hazardous substances or the

conduct of activities solely because the site-specific location is of environmental importance.

Action-Specific ARARs are technology- or activity-based requirements or limitations on actions to be

taken with respect to hazardous wastes. These requirements are triggered by the particular remedial

activities selected to accomplish a remedy.


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As part of the FS, potential federal, state, and local ARARs were identified. Table 2-1 summarizes the

specific ARARs identified as “to be considered,” “potentially applicable,” and “relevant and appropriate”

for groundwater at the Site.

2.3 REMEDIAL ACTION OBJECTIVES RAOs are goals specific to media or OUs for protecting human health and the environment. Risk can be

associated with current or potential future exposures. RAOs should be as specific as possible but not so

specific that the range of alternatives to be developed is unduly limited. Objectives aimed at protecting

human health and the environment should specify (1) COCs, (2) exposure routes and receptors, and (3) an

acceptable contaminant level or range of levels for each exposure route (that is, RALs) (EPA 1988).

The Final Lane Street RI Report and HHRA evaluated potential exposures of human receptors to

constituents detected in environmental media at the Site. The Site was subdivided into EAs, primarily on

the basis of current and reasonably anticipated future land use and contaminant distribution (EA 1 and

EA 2).

The Final Lane Street RI Report and HHRA identified the following receptors: current and future

residents, current and future industrial/commercial workers, and current and future utility and

construction workers. Section 7.1 of the Final Lane Street RI Report details the exposure routes for each

receptor (SulTRAC 2015). For the purposes of the HHRA, future land uses of all properties were

assumed to be the same as current land uses, with a mix of residential, vacant/agricultural, recreational,

and industrial/commercial properties. Note: in some instances, future land use scenarios not reasonably

anticipated were assumed and quantitatively evaluated in the HHRA to support the evaluation of risk

management measures during the FS. In addition to the primary types of receptors associated with each

property (for example, adult and child residents at residences), the risk assessment also considered

potential exposures of workers involved in utility installation and repair and construction activities at each

property (SulTRAC 2015).

The NCP requires that a range of excess lifetime cancer risks of 1 × 10-4 to 1 × 10-6 (one in ten thousand

to one in one million) excess lifetime cancer risk be evaluated, using 10-6 as a point of departure

(EPA 1994). Non-cancer risks are to be limited to levels to which human populations, including sensitive

sub-groups, may be exposed without adverse effect during a lifetime. This translates into a hazard index

(HI) not exceeding 1.


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The proposed RAOs for the Site are as follows:

• RAO 1: Protection of human health from chemical risks and hazards by preventing actual or potential direct exposure to or potable use of groundwater containing COCs at levels resulting in unacceptable risk for current and future Site users, specifically current and future residents, industrial/commercial workers, utility workers, and construction workers.

• RAO 2: Protection of human health from chemical risks and hazards posed by VI associated with groundwater contamination for future Site users.

• RAO 3: Restoration of the aquifer to its beneficial use (including potentially as a community water supply).

Future residents may potentially be exposed via inhalation of VOCs in indoor air via the VI migration

pathway. Currently, the EA 1 area is used entirely for industrial and commercial purposes. Therefore,

there are no current risks to residential receptors in this area. However, a potential VI issue does exist in

EA 1 if the area is redeveloped as a residential area. As for current residents, soil vapor concentrations

measured in EA 2 were all less than residential VI screening levels, therefore all individual and

cumulative VI risks for residents are less than 1 × 10-6 and considered insignificant.

2.4 PROPOSED REMEDIAL ACTION LEVELS RALs are COI concentrations used during the analysis and selection of remedial alternatives and during

the remedial design and remedial action processes. The RALs are used to estimate the extent of

contamination requiring remedial action. The residual risks (including both carcinogenic risks and non-

carcinogenic hazards) comply with the NCP requirements for protection of human health and the

environment. The RALs apply to residential and industrial/commercial property uses. During the RI and

this FS, residences, recreational parks, schools, and churches are assessed as residential areas.

Industrial/commercial areas include businesses, industrial properties, rights-of-way, and easements.

This FS provides proposed RALs. Final RALs will be provided in the ROD. The RALs will be selected

based on site-specific risks and hazards from the HHRA presented in the Final Lane Street RI Report,

along with a review of the ARARs, and will be consistent with the NCP. Table 2-2 provides a summary

of some of the key values which may be used in selecting the RALs for groundwater. The ROD will

establish the final RALs for the Site.


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2.5 GENERAL RESPONSE ACTIONS This section discusses the GRAs developed to achieve the RAOs identified in Section 2.3. GRAs are

broad categories of possible remedial actions, such as containment or removal. Technologies are

separated into GRA categories. The potential technologies identified may be capable of attaining the

RAOs, either alone or in conjunction with other technologies. The established performance of each

technology with regard to Site contaminants and conditions is considered during technology identification

and screening. The potential technologies are screened based on effectiveness, implementability, and

relative cost. The GRAs then are used to identify specific remedial technologies that may be implemented

at the Site as discussed in Section 4.0.

The GRAs are used to identify and group potential remedial technologies. Table 2-3 lists the following

GRAs and provides a description of what they typically entail:

• No action

• Institutional controls (ICs)

• Monitored natural attenuation (MNA)

• Removal

• Discharge

• Containment



• Direct exposure pathway restriction

2.6 IDENTIFICATION AND SCREENING OF REMEDIATION TECHNOLOGY TYPES AND PROCESS OPTIONS This section identifies and screens remedial technologies proposed for the remediation of the Lane Street

Site. The identification and screening were completed using the processes outlined in the EPA’s RI/FS

guidance (EPA 1988) and the NCP (EPA 1994). First, technologies are identified that could achieve the

RAOs listed in Section 2.3. During technology identification, the demonstrated performance of each

technology with regard to Site contaminants and conditions is considered. The result is a list of potential

remedial technologies that then are screened based on effectiveness, implementability, and relative cost.


20

The purpose of this screening is to produce an inventory of suitable technologies that can be assembled

into candidate remedial alternatives capable of mitigating actual or potential risks at the Lane Street Site.

Consistent with EPA guidance, an extensive list of potential technologies representing a range of GRAs

was considered to develop the candidate remedial alternatives.

Categories of remedial technologies were identified based on a review of literature, vendor information,

performance data, and experience in developing other FSs under CERCLA. Technologies considered

potentially applicable to achieving RAOs were selected for screening. The technology screening process

reduces the number of potentially applicable technologies by evaluating factors that may influence

process-option effectiveness and implementability. This overall screening is consistent with guidance for

performing FSs under CERCLA (EPA 1988).

The screening process assesses each technology for probable effectiveness, implementability, and relative

cost with regard to site-specific conditions, site-related contaminants, and affected environmental media.

The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated

areas or volumes of media and meeting the contaminant-reduction goals identified in the RAOs, (2) the

effectiveness of the technology in protecting human health and the environment during the construction

and implementation phases, and (3) how proven and reliable the technology is with respect to

contaminants and conditions at the site.

Implementability encompasses both the technical and administrative feasibility of implementing a

technology process. Technical implementability is used as an initial screening criterion for technology

types to eliminate technologies that are clearly ineffective or unworkable at a site. Technical

implementability is used as a check that the technology is applicable to the site. An additional, more

detailed evaluation of the technologies is conducted during the FS. The more detailed evaluation of

technologies places greater emphasis on the institutional aspects of implementability, such as the ability

to obtain necessary permits for off-site actions; the availability of treatment, storage, and disposal services

(including capacity); and the availability of necessary equipment and skilled workers to implement the

technology. For technology screening purposes, implementability is broken down into three levels: easy

to implement, implementable, and difficult to implement.

Cost plays a limited role in the screening of technologies. Relative capital and operation and maintenance

(O&M) costs, rather than detailed estimates, are considered. At this stage in the process, the cost analysis

is made on the basis of engineering judgment, and each technology is evaluated as to whether costs are


21

high, low, or moderate relative to other technology options for the same medium (EPA 1988). The

relative cost for each technology is evaluated in terms of general technology cost, not site-specific costs.

A two-step process was used in this effort. The initial step was to identify a wide range of potential

technologies based on past experience and general knowledge of remedial options. The second step was

to conduct the initial screening of these technologies as described above. The product of this effort is a list

of retained technologies to be considered when developing potential remedial alternatives to be carried

forward to the FS alternatives evaluation process.

The following sections identify the candidate remedial technologies for the Lane Street Site, the candidate

technology screening, and the retained candidate technologies.

2.6.1 Candidate Technology Identification

Table 2-4 lists the identified candidate technologies for risk mitigation. The table also includes a brief

description of each technology as well as specific comments on the application of the technology. Many

candidate technologies, if implemented, would have to be implemented in conjunction with another

technology as part of a treatment train. For example, if groundwater is removed by pumping, the water

would require treatment or disposal (such as discharge to a publicly-owned treatment works [POTW],

discharge or transportation to an off-site treatment facility, or treatment and discharge to an off-site

property). Table 2-4 lists the following candidate technologies separated by GRA:

• No action

o No action

• ICs



• MNA

o MNA

• Removal

o Extraction wells

o Interceptor trench

o Dual phase extraction (DPE) and two phase extraction (TPE)

• Discharge

o Puterbaugh Creek


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o POTW

o Reinjection or infiltration

o Offsite disposal

• Containment

o Containment with a barrier wall

o Containment with a barrier wall and low-permeability cap

o Hydraulic containment


o Bioremediation

o Reactive wall/funnel and gate

o Direct chemical treatment using ISCO or zero valent iron (ZVI)

o Air sparging

o SVE

o In-well air stripping


o Bioreactors


o Membrane filtration

o Air stripping

• Groundwater direct pathway restriction

o Whole house filtering

o Point of use filtering

o Alternate water supply – bottled water

o Alternate water supply – municipal water

2.6.2 Candidate Technology Screening

The candidate technologies identified in Table 2-4 were screened for effectiveness, implementability, and

relative cost as described above. The potential technologies were screened based on the COCs, primarily

for TCE for the Lane Street Site. Considerations for screening include availability of technologies at the

site, logistical arrangements, spatial requirements, and historical results for comparison properties.

Table 2-5 presents the results of the candidate technology screening effort, including the assessment of

effectiveness, implementability, and relative cost of each identified technology. The table also notes the

specific reason for elimination or retainage of the technology.


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The screening of the technology presented in Table 2-4 and eliminated or retained in Table 2-5 is the

screening of technologies as primary remedial mechanisms for the remedies. However, even if a

technology is eliminated as a primary remedial mechanism, it may still be a part of an overall approach

and thus was retained as a technology.

2.6.3 Retained Candidate Technologies

Table 2-5 details the potential remedial technologies still under consideration to mitigate identified risk at

the Lane Street Site. These retained technologies listed are the building blocks used to develop remedial

alternatives in Section 3.0 of this document.

The following GRAs and technologies were retained:

• No action

o No action

• ICs



• MNA

o MNA

• Discharge

o Discharge to Puterbaugh Creek


o Enhanced bioremediation


o Groundwater removal


o Air stripping

Below are brief descriptions and reasons for retaining the above listed technologies. For a detailed

explanation or for more information on the eliminated technologies, please see Table 2-5.

No Action. Under this alternative technology, no action would be taken to mitigate risk. Evaluation of

this alternative technology is required under the NCP and thus was retained as an alternative technology.


24

Institutional Controls. Under this alternative technology, ICs were identified as a retained technology.

ICs are legal and administrative mechanisms used to implement land use and access restrictions to limit

the exposure of future landowners or users of the property. ICs include agreements, local government

ordinances, or deed restrictions registered with a property title. ICs were considered to be effective,

implementable, and cost effective and were retained as an alternative technology. ICs, however, may be

considered more effective when combined with other alternative technologies rather than as a stand-alone

solution.

Monitored Natural Attenuation. Under this alternative technology, MNA was identified as a retained

technology. MNA relies on natural processes to decrease or “attenuate” concentrations of contaminants

within the Site groundwater plume. The natural processes can include: (1) transformation of contaminants

into less toxic form through destructive processes such as biodegradation or abiotic transformations, (2)

reduction of contaminant concentrations whereby exposure levels may be reduced, and (3) reduction of

chemical mobility and bioavailability through sorption onto the soil or rock matrix. As discussed in the

Final Lane Street RI Report, there is limited evidence that complete anaerobic biodegradation is occurring

(SulTRAC 2015). Anaerobic degradation means the breakdown of contaminants by microorganisms in

the absence of oxygen. MNA includes the installation of additional groundwater monitoring wells,

periodic sampling of wells, and reporting for 30 years. MNA was considered to be effective,

implementable and cost effective and was retained as an alternative technology. MNA, however, may best

be considered more effective when combined with other alternative technologies rather than as a stand-

alone solution.

Discharge. Discharge of treated groundwater to the Puterbaugh Creek includes constructing an

underground piping system that would convey the discharge water. Puterbaugh Creek, which is

approximately one mile east of the Site, was identified as a potential discharge location. Discharge was

considered to be effective, implementable and cost effective and was retained as an alternative

technology. Discharge, however, may best be considered more effective when combined with other

alternative technologies rather than as a stand-alone solution.

Bioremediation. Under this alternative technology, bioremediation was identified as a retained

technology. Bioremediation includes the preparation and inoculation of the aquifer media with treatment

that uses naturally occurring organisms to break down hazardous substances into less toxic or non-toxic

substances. Based on results of a current bioremediation remedy in progress at the nearby Geocel facility,


25

which had similar COCs and similar aquifer properties to the Lane Street Site, bioremediation may be

used as a stand-alone solution or in conjunction with other technologies.

Ex-Situ Treatment. Under this alternative technology, ex-situ treatment by groundwater removal, air

stripping, and activated carbon filtration was identified as a retained technology. Groundwater removal

includes pumping of contaminated groundwater from the plume through extraction wells and conveyance

of the extracted water to an onsite treatment facility. The treatments would include air stripping where

low pressure air is injected into the treatment water to facilitate the removal of VOCs through

volatilization. Activated carbon filtration includes passing the treatment water through a filtration unit

containing activated carbon which removes VOCs by absorption. Ex-situ treatment, however, may best be

considered more effective when combined with other alternative technologies rather than as a stand-alone

solution.


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3.0 DEVELOPMENT OF REMEDIAL ALTERNATIVES Technically feasible technologies retained after the screening discussed in Section 2.6 above were

combined to form remedial alternatives that may be applicable to the Site. In addition to the NCP-required

No Action alternative, a range of alternatives was developed, using different approaches to achieve the

RAOs. This section describes the alternatives, both in general terms and then in greater detail. SulTRAC

also evaluated the use of ICs in conjunction with each of the below alternatives, with the exception of

Alternative 1– No Action, to help prevent exposure to COCs until cleanup levels are achieved. A brief

description of the objective of the ICs is described as part of each alternative.

3.1 ALTERNATIVE 1: NO ACTION For Alternative 1, No Action, nothing would be done to mitigate risk and any reduction in toxicity or

volume of contaminants would occur as a result of natural processes similar to the MNA remedy. No

monitoring of groundwater would occur and therefore, no assessment of any reduction or potential

expansion of groundwater contamination would occur. No five-year reviews to assess protectiveness

would be performed and no monitoring of ICs would occur. Evaluation of this alternative is required

under the NCP, as a baseline from which the other alternatives can be compared.

3.2 ALTERNATIVE 2: MINIMAL ACTION WITH INSTITUTIONAL CONTROLS AND MONITORED NATURAL ATTENUATION Under Alternative 2, Minimal Action with Institutional Controls and Monitored Natural Attenuation,

minimal action would be taken to mitigate risk. The ICs would be implemented to (1) limit groundwater

use and (2) prohibit residential use in the portion of the Site north of County Road 106, which is presently

used for industrial and commercial purposes. MNA would be used to address the groundwater

contamination within the plume. ICs include groundwater and land use restrictions, which would be

obtained through a combination of agreements with property owners, local (city or county) ordinances, or

registered deed restrictions. Physical or mechanical barriers, such as remediation systems, ventilation

systems, and vapor barriers can be used or relied on to reduce VI. Groundwater use restrictions would

apply to potable water wells on the Site only and would not necessarily include restricting groundwater

use for industrial/commercial applications. As part of the monitoring component of this remedy,

groundwater samples would be collected periodically, along with the associated reporting. Five-year

reviews would be required. The ICs and associated monitoring and reporting would have to remain in

place until the RAOs are achieved.


27

During the remedial design phase, a sampling program, potentially including additional monitoring wells

would be developed. In developing the cost estimate for this alternative, it is assumed that 10 additional

monitoring wells would be installed to supplement the existing monitoring wells. It is anticipated that this

sampling program would include periodic sampling of COCs. The cost estimate assumes that quarterly

sampling would be conducted during the first 5 years; semi-annual sampling would be conducted during

years 6 through 10, and annual sampling from years 11 through 30. Sample results would be used to

evaluate the condition of the plume to evaluate if it is receding, stable, or expanding. Periodic reports

summarizing the sampling events and evaluating the results would be included for the life of this

alternative. Five-year reviews would also be included for the life of this alternative. For Alternative 2, it is

estimated that it would take 20 to 35 years to reach the RAOs. For the purpose of developing a cost

estimate, 30 years was used.

Institutional Controls

ICs are legal and administrative mechanisms used to implement land use and access restrictions to limit

the exposure of future landowners or users of the property to hazardous substances present on the

property and to maintain the integrity of the response action. ICs are required on a property where the

selected remedial goal allows contamination to remain at the property above levels that allow for

unlimited use and unrestricted exposure. Implementation of ICs includes requirements for monitoring,

inspections, and reporting to ensure compliance. IC’s are common elements to Alternatives 2, 3, and 4.

The ICs required for Alternatives 2, 3, and 4 differ primarily in how long they would need to be

maintained.

Legal mechanisms include proprietary controls such as restrictive covenants, negative easements,

equitable servitudes, lease restrictions, and deed notices. Administrative mechanisms include notices,

adopted local land use plans and ordinances, construction permitting, or other existing land use

management systems that are intended to ensure compliance with land use restrictions. Physical or

mechanical barriers, such as remediation systems, ventilation systems, and vapor barriers, can be used or

relied on to reduce VI. ICs are more effective if they are layered or implemented in series. Layering

means using several ICs at the same time to enhance the protectiveness of the remedy. ICs may be

implemented in series to enhance both the short- and long-term effectiveness of the remedy. Monitoring

and inspections would be conducted to ensure compliance.


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ICs would prohibit use of contaminated groundwater and prohibit residential land use in a portion of the

Site north of County Road 106 to help prevent potential VI hazards.

3.3 ALTERNATIVE 3: IN-SITU GROUNDWATER TREATMENT THROUGH BIOREMEDIATION Alternative 3, In-Situ Groundwater Treatment through Bioremediation, would combine ICs with in-situ

treatment using bioremediation to remediate the contaminated groundwater. The ICs and groundwater

monitoring would be similar to those in Alternative 2, but would not be needed as long. In-situ treatment,

using bioremediation, would be used to treat the groundwater. The neighboring Geocel facility is using a

similar in-situ groundwater treatment remedy, with apparent success. A new round of sampling would be

conducted, prior to design, so that the design would address current conditions. Following system design,

microbes and a soluble substrate (nutrients and an electron acceptor or energy source [“food”]) would be

injected into the groundwater aquifer to create conditions favorable for bioremediation. As envisioned for

the development of this alternative, these injections would occur in at least three well area locations

within the industrial/commercial area of the Site (see Figure 3-1), where the concentrations of

contaminants which exceed the RAOs are found, and would address contamination in the shallow,

intermediate, and deep groundwater zones of the aquifer. A series of recirculation and injection wells are

envisioned within each area. Recirculation wells would provide water with which the amendments would

be mixed. The resulting mixture would then be injected back into the ground through injection wells.

Within the residential area of the Site, oxygen would be injected into groundwater in one well area

location (see Figure 3-1) as a means of preventing vinyl chloride stall (see below). There would be

periodic monitoring during the remediation process, which is estimated to require 10 years. A single re-

injection event is assumed to occur in year 3. Two five-year reviews would be included. However, the

final design is expected to be adjusted in order to address current conditions at that time.

In-Situ Groundwater Treatment through Bioremediation, is also referred to as enhanced anaerobic

dechlorination (EAD) when applied biodegradation of chlorinated VOCs (CVOCs) such as PCE, TCE,

and cis-1,2-DCE. Anaerobic dechlorination occurs when bacteria utilize CVOCs for respiration as

alternate electron acceptors under anaerobic conditions in place of oxygen, a process called

halorespiration. The dechlorination process occurs naturally, if anaerobic conditions are present in the

subsurface, but the rate can be slow. The dechlorination rate can be increased or enhanced in the

subsurface by introduction of biologically degradable substrates, such as molasses, corn syrup, lactate,

whey, oil, or alcohol through number of injection wells. The substrates act as electron donors, and

biological degradation of these substrates requires electron acceptors. Electron acceptors typically are


29

utilized sequentially based on the energy they yield to the microbe as follows: oxygen, nitrate,

manganese, iron, sulfate, and carbon dioxide (CO2) until methanogenic conditions are established.

Dechlorination typically occurs under sulfate reducing and methanogenic conditions, when other electron

acceptors are scarce and the energy yielded by halorespiration of CVOCs is more favorable.

The complete reductive dechlorination of chlorinated ethenes yields non-toxic ethene as a final product,

however absent the right bacteria and conditions, there may be an accumulation of the degradation

products, such as cis-1,2-DCE or vinyl chloride. Because of its toxicity, vinyl chloride is a concern which

would need to be addressed in the design. The accumulation of vinyl chloride, also called vinyl chloride

stall, can be managed by any of several techniques, including verifying that the correct type of bacteria

are present and injecting other treatment compounds to stimulate aerobic degradation of the vinyl

chloride, or injecting other compounds which can capture and treat the vinyl chloride.

There are several potential ways to address vinyl chloride stall. Many of these approaches could also

work for a cis-1,2-DCE stall as well. The following paragraphs discuss several of these approaches; in

concept, the final design would select what is deemed to be an appropriate combination of remedies to

reflect the current site conditions at that time. Under this alternative, enhanced bioremediation is expected

to be the centerpiece of the remedy, but other technologies, such as those discussed below, may be used in

portions of the plume. Note: the use of a product name does not constitute an endorsement or

recommendation of the product, but instead is used as an example.

As presently envisioned, the FS calls for some air injections, in the residential area, to address potential

vinyl chloride stall. This could be enhanced by adding an ozone generator. Ozone is a powerful oxidant,

more reactive than oxygen alone, and works principally by chemically breaking down the contaminants. It

also increases the dissolved oxygen in the groundwater, and can therefore stimulate the aerobic

biodegradation of contaminants (vinyl chloride in this case).

There are a number of other possibilities. Within the REGENESIS product line, Oxygen Release

Compound (ORC®) or ORC Advanced® could be used to address vinyl chloride stall. In concept, the

ORC® would be used in the downgradient portion of the groundwater plume (likely within the residential

area), with Hydrogen Release Compound (HRC®), HRC-X®, HRC-Primer®, 3-D Microemulsion®

(3DMe®), and Bio-Dechlor Inoculum® Plus being used in some combination within the

industrial/commercial area near the highest concentrations to anaerobically degrade the contaminants.


30

Additional Bio-Dechlor Inoculum® Plus along with HRC®/HRC-X®/3DMe® away from the center of the

plume can also work by giving another boost to the anaerobic degradation process.

The addition of the REGENESIS Chemical Reducing Solution (CRS®) - an iron based product can be

made within the anaerobic area to further stimulate the biodegradation and stimulate geochemical

reduction (separate from the biodegradation) as a way of reducing the vinyl chloride stall. CRS® can also

be used in conjunction with other products.

PlumeStop® (an activated carbon-based REGENESIS product) - in conjunction with either ORC® or

HRC® can be used to stop and degrade the plume. With HRC®, this would enhance anaerobic

biodegradation and slow the movement of the contaminants; with ORC®, it could slow/stop the

movement of the vinyl chloride while it is being treated. The use of PlumeStop® allows for two

mechanisms (carbon adsorption plus enhanced (aerobic or anaerobic) biodegradation) to be used to

remediate the plume.

Remediation Products, Inc. has a product which could also work. BOS 100® is an activated carbon with

embedded iron. The carbon is used to "trap" the contaminants, the iron then chemically “treats” the

contaminants. BOS 100® works through two mechanisms (carbon absorption and chemical degradation)

at work.

Part of this alternative includes a sampling program. Samples collected would be analyzed for the COCs

and the presence of indicator compounds such as degradation daughter products. Sample results would be

used to evaluate the condition of the plume to evaluate if it is receding, stable, or expanding. Quarterly

reports detailing the enhanced bioremediation sampling events would be included for the life of this

alternative. Five-year reviews would also be included for the life of this alternative. For Alternative 3, it is

assumed that it would take 10 years to reach the RAOs.

For cost estimating purposes, three injection and recirculation well areas are proposed in the

industrial/commercial area of the Site and one oxygen injection well area is proposed in the residential

area of the Site (see Figure 3-1). The injection wells located in the industrial/commercial area of the Site

would be used to enhance anaerobic degradation and would treat contamination in the shallow,

intermediate, and deep groundwater zones of the aquifer. The recirculation wells would be used both as a

water source and to enhance the distribution of the treatment media within the aquifer. The one injection

well area in the residential area of the Site would be used to add oxygen to the groundwater. The use of


31

injection wells was selected, in part through consultations with a vendor of the technology and based on

existing data. Additionally, 10 new monitoring wells are included in the cost estimate; along with a partial

re-application of the treatment materials.

3.4 ALTERNATIVE 4: EX-SITU GROUNDWATER TREATMENT BY EXTRACTION, TREATMENT, AND DISCHARGE Alternative 4, Ex-Situ Groundwater Treatment by Extraction, Treatment, and Discharge (also referred to

as “pump and treat”), would combine ICs similar to Alternatives 2 and 3, with remediation of the

groundwater by pumping the groundwater out of the ground, treating the extracted water, and then

discharging the treated water to nearby surface water. Following system design, an estimated

10 extraction wells, a treatment plant, and the discharge line would be constructed. It is anticipated that

the treatment plan would use air stripping and carbon adsorption as the treatment mechanisms.

Conceptually, the treatment plant would be located within the industrial/commercial area of the Site.

The proposed system would utilize extraction wells and would be tailored to site-specific conditions and

remediation goals. Extraction wells would capture and remove contaminated groundwater and prevent its

migration. For the purposes of the FS, extraction wells are planned for three areas; one extraction area

within the industrial/commercial area, near where the highest concentrations of TCE are located, in the

vicinity of monitoring wells R-MW 14 and R-MW-12. The other two extraction areas would be in the

residential area. The exact number of extraction wells, their locations, and rate of extraction would be

determined during system design, based on results of a pre-design investigation/sampling event. The

preliminary location of three extraction areas is shown on Figure 3-2.

The extracted water would be pumped to a treatment building on-site where the water would be treated

prior to discharge. Since the concentration of contaminants relative to RALs in groundwater extracted

from the extraction area in the industrial/commercial area of the Site would be much higher than the five

extractions wells located in the residential area of the Site, two treatment trains would be used to optimize

the treatment system, lower the construction cost, provide added flexibility, and reduce the operating cost.

The extraction well diameter would be selected so that it is large enough to accommodate the extraction

pump and other downhole instrumentation. At present it is assumed that the wells would be screened

through the entire depth of the plume. In order to develop cost estimates it is assumed that the extraction

wells would be equipped with pumps driven by variable frequency drives (VFDs) to provide additional

flexibility in controlling drawdown and therefore migration of contaminants. VFD drive speed would be


32

continuously adjusted by a level control system which would increase or decrease the pump discharge

rate to maintain preset drawdown during changing groundwater level. The extraction wells would be

equipped with submersible pumps with electric motors capable of being driven by VFDs. The extraction

pumps would be installed in a blank section of casing to promote cooling of the pump motor; by forcing

the water to flow up around the motor to the pump intake. This also protects the filter pack from

impingement by the pump suction. Conceptually, a minimum of three piezometers would be installed at

each extraction well location to monitor drawdown and the radius of influence or capture zone for the

pumping well. Each well head would be installed in a vault which would house all valves, flow meter,

and controls required to operate the extraction pump.

For cost estimating purposes, stainless steel well screens and risers were selected, to reduce maintenance

costs for both the wells and the treatment system. Low-carbon steel is frequently used for extraction well

casings and well screens; however, it would not be used at the Site because iron flaking, caused by

oxidation, often is responsible for clogging of pump suctions and fouling the treatment system.

Additionally, low-carbon steel screens are more susceptible to corrosion failure. The well screen diameter

would be selected to provide sufficient open area so that the velocity of water entering the screen is less

than 0.1 feet per second (ft/s) to minimize friction losses, corrosion, and incrustation. The well diameter

would also be large enough to properly install the extraction pump and other downhole equipment.

Groundwater treatment technologies selected for the Site include air stripping and granular activated

carbon (GAC) polishing. The air stripping was selected as a main treatment followed by GAC adsorption

as the polishing step in a ‘treatment train’ to meet requirements for discharging treated water directly to

surface water. Two treatment trains are proposed. One of the trains would treat groundwater extracted

from the wells located within the highest COC concentration area. The other train would handle lower

concentration groundwater extracted from the wells located in the groundwater plume downstream.

The treated water would be discharged to Puterbaugh Creek located approximately one mile east of the

Site. Underground drainage piping would be constructed from the treatment building to the discharge

location. An agreement with the property owner of the land at Puterbaugh Creek would be required to

secure the location for the discharge outfall. A National Pollutant Discharge Elimination System

(NPDES) permit (or equivalent, since CERCLA sites do not need permits but must comply with the

substantial requirements as if they had a permit) is required to discharge the treated water. Compliance

with the permit would require routine sampling of the discharged water and reporting to the EPA and/or

local permitting authority.


33

Included with this alternative is quarterly monitoring of the monitoring wells for the first 5 years,

followed by semi-annual monitoring until RAOs are achieved, and continued O&M of the extraction,

ex-situ treatment, and discharge. Quarterly monitoring would include sampling of the monitoring wells,

extraction wells, extraction water, and discharge water for COCs, and NPDES-required sampling.

Quarterly monitoring results would be detailed in quarterly reports. Five-year reviews would also be

required for the life of this alternative. For Alternative 4, it is assumed that it would take 20 years to reach

the RAOs.


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4.0 DETAILED ANALYSIS OF ALTERNATIVES This section presents a detailed evaluation of the remedial alternatives, including an analysis of each

alternative using the nine criteria specified in the NCP. The detailed analysis is intended to provide

decision makers with information needed to select a remedial alternative that best meets the following

CERCLA requirements:

• Protects human health and the environment

• Attains ARARs (or provides grounds for invoking a waiver)

• Uses permanent solutions and alternative treatment technologies or resource-recovery technologies to the maximum extent practical

• Satisfies the preference for treatment that reduces toxicity, mobility, or volume of hazardous substances as a principal element

• Is cost-effective

The detailed analysis was performed in accordance with CERCLA Section 121 and EPA RI/FS Guidance

(EPA 1988). The detailed analysis contains the following:

• A detailed description of each candidate remedial alternative, emphasizing the application of various component technologies

• An assessment of each alternative compared to the first seven of the nine evaluation criteria described in the NCP

The detailed description of each alternative includes a discussion of limitations, assumptions, and

uncertainties for each component and provides a conceptual design for each alternative. Each remedial

alternative was then evaluated against the first seven of the nine NCP evaluation criteria.

This section discusses the screening criteria (Section 4.1), followed by the individual alternative analyses

(Section 4.2).

4.1 SCREENING CRITERIA The nine NCP evaluation criteria can be subdivided into three categories: threshold criteria, primary

balancing criteria, and modifying criteria, as discussed below.


35

4.1.1 Threshold Criteria

The threshold criteria relate to statutory requirements that each alternative must satisfy in order to be

eligible for selection and include overall protection of human health and the environment and compliance

with ARARs.

1. Overall Protection of Human Health and the Environment: This criterion assesses how well an alternative, as a whole, achieves and maintains protection of human health and the environment.

2. Compliance with Applicable or Relevant and Appropriate Requirements: This criterion assesses how an alternative complies with location-, chemical-, and action-specific ARARs and whether a waiver is required or justified.

4.1.2 Primary Balancing Criteria

The primary balancing criteria are the technical criteria upon which the detailed analysis primarily is

based and include long-term effectiveness and permanence; reduction of the toxicity, mobility, or volume

of contaminants through treatment; short-term effectiveness; implementability; and cost.

3. Long-Term Effectiveness and Permanence: This criterion evaluates the effectiveness of an alternative in protecting human health and the environment after RAOs have been achieved. It also considers the degree to which treatment is irreversible and the type and quantity of residual contamination remaining after treatment.

4. Reduction of Toxicity, Mobility, or Volume through Treatment: This criterion examines the effectiveness of an alternative in reducing the toxicity, mobility, or volume of the contamination or contaminants through treatment. The preference is to treat contaminants, preferably in an irreversible way, rather than just transfer contamination from one medium to another.

5. Short-Term Effectiveness: This criterion examines the effectiveness of an alternative in protecting human health and the environment during the construction and implementation of a remedy until RAOs have been achieved. It also considers protection of the community, workers, and the environment during the implementation of remedial actions. The detailed analysis of each alternative includes an estimate of the time necessary for completion of the alternative (the remedial duration). The timeframe estimates are based on published construction scheduling material and professional judgment.

6. Implementability: This criterion assesses the technical and administrative feasibility of an alternative and the availability of required goods and services. Technical feasibility considers the ability to construct and operate a remedy and its reliability, the ease of undertaking additional remedial actions, and the ability to monitor the effectiveness of a remedy. Administrative feasibility considers the ability to obtain approvals from other parties or agencies and the extent of required coordination with other parties or agencies.

7. Cost: This criterion evaluates the capital and O&M costs of each alternative. Under this criterion, the alternative is evaluated in terms of its total cost. This includes the capital costs (design, initial permitting, construction, administration, startup, and contingencies), annual O&M costs


36

(operating labor, maintenance labor, materials, energy, utilities, consumables, laboratory analysis, and other services), and net-present value (total cost in today’s dollars for capital and O&M costs, assuming a discount rate of 7 percent and a period of operation of 10, 20 or 30 years according to the alternative). Unit costs are based on experience at similar sites, published rates in RSMeans Building Construction Cost Data (RSMeans), and information provided by vendors. The actual cost for a given alternative is expected to be within the range of + 50 percent to - 30 percent of the cost estimate presented in this FS. Appendix A provides a breakdown of the cost estimates. Costs are included for five-year reviews until the remedy is assumed to achieve its objective. Cost estimates are reported to three significant figures.

4.1.3 Modifying Criteria

The modifying criteria include state acceptance and community acceptance, which are assessed formally

after receipt of state input on the FS report and proposed plan for the Site and after the public comment

period.

8. State Acceptance: This criterion considers the state’s preferences among or concerns about the alternatives, including comments on ARARs or proposed use of waivers. This criterion is addressed after receipt of state input on the FS report and proposed plan for the Site.

9. Community Acceptance: This criterion considers the community’s preferences or concerns about the alternatives. This criterion is addressed after community input on the FS report and proposed plan for the Site. State and community acceptance will be evaluated in the ROD after the proposed plan has been prepared and the public comment period has ended.

4.2 INDIVIDUAL ALTERNATIVE ANALYSIS As discussed in Section 2.3, the current and future land uses for the Site are the same, with a mix of

residential, vacant/agricultural, recreational, and industrial/commercial properties. The following sections

discuss the alternatives. Each subsection contains a brief description of the alternative (a more detailed

description is provided in Section 3.0) followed by a comparison of the alternative to the first seven

criteria.

4.2.1 Alternative 1: No Action

Alternative 1, No Action, was retained as a baseline against which to compare all other alternatives, as

required by the NCP. This alternative would not include remedial action components to contain or

eliminate exposure pathways by implementing ICs or environmental monitoring. As discussed in the

Final Lane Street RI Report, there is limited evidence that degradation is occurring. Therefore, the

primary mode of attenuation is expected to be dilution and groundwater movement (SulTRAC 2015).

With no monitoring, there would be no data to indicate if the RAOs have been achieved or if the

conditions no longer represent a threat to human health.


37

Overall Protection of Human Health and the Environment: The No Action alternative would not

include any administrative or engineered process options that would be protective of human health, and it

would allow contaminants greater than the RAL to remain at the Site without initiation of active remedial

activities. Eventually, through natural processes, the contamination would decrease. There is no

monitoring under the No Action alternative to provide data to indicate that conditions no longer represent

a threat to human health. Alternative 1 fails to meet this threshold criteria.

Compliance with Applicable or Relevant and Appropriate Requirements: Because no action would

be taken, location specific ARARs and action-specific ARARs do not apply. However, chemical-specific

ARARs would apply. Because no actions would be taken to prohibit groundwater from being used as a

public potable water source when there is contamination above the MCL, this alternative would fail to

comply with ARARs.

Long-Term Effectiveness and Permanence: Once the RAOs are achieved through natural processes,

estimated at 30 years, the effect would be permanent and long term. However, there is no monitoring

component to this alternative, and therefore no way to know when Alternative 1 achieves the RAOs.

Reduction of Toxicity, Mobility, or Volume through Treatment: Alternative 1 has no active treatment

process that would reduce toxicity, mobility, or volume of VOCs. Natural processes would be expected to

reduce contaminant concentrations over time.

Short-Term Effectiveness: No remedial actions would be taken with this alternative; therefore, there

would be no means to protect receptors from exposure to unacceptable levels of COCs until the RAOs are

achieved. Because no actions would be taken, there would be no short term risks to either workers or the

community from the implementation of the remedy.

Implementability: Alternative 1 would not involve any construction or remedial activities and would not

require approvals or coordination with regulatory agencies, and therefore is readily implementable.

Cost: Because no actions would be taken (not even five-year reviews) for Alternative 1, there would be

no costs associated with Alternative 1.


38

4.2.2 Alternative 2: Minimal Action with Institutional Controls and Monitored Natural Attenuation

Under this alternative, minimal actions would be taken to mitigate risk. Actions taken would include ICs

to prohibit residential development in the portion of the Site north of County Road 106, and to limit

groundwater use at the Site and monitoring (by periodic groundwater sampling) the natural attenuation

taking place. The cost estimate for this alternative assumes that 10 additional monitoring wells would be

installed as part of an enlarged monitoring network.

Overall Protection of Human Health and the Environment: The ICs which form part of this

alternative would be expected to provide protection of human health and would help prevent exposure to

contaminants in groundwater while attenuation is taking place. The monitoring component would provide

data to evaluate the attenuation of contaminants in groundwater. As a result, this alternative would be

overall protective of human health and the environment.

Compliance with Applicable or Relevant and Appropriate Requirements: This alternative would

comply with ARARs.

Long-Term Effectiveness and Permanence: Once the RAOs are achieved, this alternative would be

permanent.

Reduction of Toxicity, Mobility, or Volume through Treatment: This alternative would not actively

reduce the mobility, toxicity, or volume of the COCs in groundwater. However, natural attenuation

processes would eventually remediate the groundwater contamination.

Short-Term Effectiveness: ICs would be effective in reducing the possibility of human exposure to

groundwater contamination at the Site while contaminant levels are decreasing. Groundwater sampling

would effectively monitor attenuation. This alternative would thus be effective over the short term.

Implementability: This alternative would involve frequently used components (ICs and groundwater

monitoring).

Cost: Alternative 2 has an estimated present-value of $1,290,000 which includes $294,000 in capital

costs, $944,000 in present-value O&M costs, and $52,000 in present-value five-year review (remedy

review) costs for six five-year reviews. O&M costs are estimated at $137,000 per year for 5 years,

decreasing to $68,000 for years 6 through 9 and then $34,000 per year for years 11 through 30 (as


39

monitoring frequency is reduced) with an additional $24,000 every five years to conduct five-year

reviews, for an estimated 30 years used for costing purposes. The cost for Alternative 2 includes capital

cost for installation of 10 monitoring wells.

4.2.3 Alternative 3: In-Situ Groundwater Treatment through Bioremediation

Alternative 3 (enhanced bioremediation) would include the injection of substrate and nutrients, and

microorganisms if necessary, to establish a subsurface environment that would be conducive to

biodegradation of CVOCs such as TCE. In addition, long term monitoring, reporting, and maintenance of

the established and future land use controls/ICs would be a key component of this alternative. The

following sections present a conceptual design for evaluation, comparison, and costing purposes only. If

selected, the final design would be developed based upon additional data or site constraints identified

during pre-design activities.

Overall Protection of Human Health and the Environment: This alternative would be effective in

overall protection of human health and the environment at the treatment area. During the period of

treatment, ICs would reduce the likelihood of the public coming into contact with contaminated

groundwater.


comply with ARARs.

Long-Term Effectiveness and Permanence: The enhanced bioremediation component of this alternative

has successfully been used before at many sites, including other NPL sites, and provides a permanent

remedy. In some situations, the degradation of PCE and TCE can stall at vinyl chloride. This is a concern

because vinyl chloride is more toxic than either PCE or TCE. However, with proper design and

implementation, this could be prevented. Several different approaches to address potential vinyl chloride

stall, as discussed in Section 3.3 above, are available and could be implemented as part of the final design.

Reduction of Toxicity, Mobility, or Volume through Treatment: This alternative would achieve the

statutory preference for treatment. Active measures would be taken to treat the groundwater in-situ.

Short-Term Effectiveness: ICs would be effective in reducing the likelihood of human exposure during

remediation activities. It is anticipated that the implementation of this alternative would result in minimal

additional risk to either workers or the public.


40

Implementability: No technical or administrative difficulties are anticipated with this alternative. The

technologies that would be used for this alternative are widely available and fairly common; indeed, the

nearby Geocel facility with similar contaminants which is presently being remediated by enhanced

bioremediation under the IDEM VRP.

Cost: Alternative 3 has an estimated present-value of $3,550,000 which includes $2,500,000 in capital

costs, $1,020,000 in present-value O&M costs, and $29,000 in present-value five-year review costs for

two five-year reviews. A single re-injection event, costing $100,000, is assumed to occur in year 3. O&M

costs are estimated at $134,000 per year for 10 years, with an additional $24,000 to conduct two five-year

reviews.

4.2.4 Alternative 4: Ex-Situ Groundwater Treatment by Extraction, Treatment, and Discharge

Alternative 4 (extraction and ex-situ groundwater treatment), commonly referred to as “pump and treat,”

is a widely used remediation approach. This alternative would pump groundwater from the ground to a

treatment plant constructed on the Site where the contaminants would be removed. The treated

groundwater would then be discharged to Puterbaugh Creek, which is the nearest potential surface water

discharge body to the Site.

Overall Protection of Human Health and the Environment: Extraction and ex-situ groundwater

treatment would provide protection of human health and prevent exposure to contaminants in

groundwater while groundwater extraction and treatment is taking place. As extraction of contaminated

groundwater continues, the contaminant levels in the groundwater would decrease to concentrations less

than the RALs. This alternative would provide overall protection of human health and the environment.


comply with the appropriate ARARs.

Long-Term Effectiveness and Permanence: The remedy would be expected to achieve RAOs, however,

it is estimated that 20 years could be needed. This would be a permanent remedy.

Reduction of Toxicity, Mobility, or Volume through Treatment: This alternative would meet the

statutory preference for treatment. Groundwater would run through a treatment system to remove

contaminants, prior to being discharged.


41

Short-Term Effectiveness: ICs would be effective in reducing the likelihood of human exposure during

remediation activities. Construction activities would be more disruptive with this remedy than the other

remedies, and could result in some additional traffic at the Site.

Implementability: No technical or administrative difficulties are anticipated with this alternative. The

technologies used for this alternative are widely available and fairly common. There is a nearby NPL site

where a similar technology is being used.

Cost: Alternative 4 has an estimated present-value of $11,400,000 which includes $4,570,000 in capital

costs, $6,760,000 in present-value O&M costs, and $44,000 in present-value five-year review costs for

four five-year reviews. O&M costs are estimated at $542,000 per year for the treatment system, with an

additional $139,000 for quarterly sampling and monitoring for the first 5 years, reducing to $69,000 per

year for semi-annual monitoring years 6 through 20. Additionally, $24,000 every five years is included to

conduct five-year reviews over 20 years.


42

5.0 COMPARATIVE ANALYSIS OF ALTERNATIVES This section of the FS documents the comparative analysis of groundwater remedial alternatives for the

Site. This analysis evaluates the relative performance of each of the alternatives to one another. This

provides decision-makers with another tool by which to select an appropriate remedy.

The purpose of the comparative analysis is to identify the advantages and disadvantages of each

alternative relative to one another, focusing on the relative performance of each alternative against the

seven evaluation criteria identified above, to aid in the selection of the remedy. The remedy selected for

the Site must reflect the scope and purpose of the actions being undertaken and how these actions relate to

other actions and the long-term response at the Site. The identification of the preferred alternative and the

final remedy selection are based on an evaluation of the more significant trade-offs among the

alternatives. The comparative analysis of the groundwater remedial alternatives is presented in Table 5-1.

5.1 COMPARATIVE ANALYSIS This section provides a comparative analysis of the groundwater alternatives. Groundwater alternatives

are intended to achieve RAO 1 (Section 2.3). Table 5-1 summarizes the comparative analysis.

5.1.1 Overall Protection of Human Health and the Environment

This criterion assesses how well an alternative achieves and maintains protection of human health and the

environment.

Alternative 1 (No Action) would provide no improvement over current conditions and no risk reduction,

and would not be protective of human health or the environment. Alternatives 2, 3, and 4 would all be

overall protective of human health and the environment. All would use similar ICs to protect human

health until the groundwater contamination has been attenuated or remediated.

5.1.2 Compliance with Applicable or Relevant and Appropriate Requirements

This criterion assesses how an alternative complies with regulatory requirements. Federal and state

regulatory requirements that are either applicable or relevant and appropriate are known as ARARs. Only

state requirements that are more stringent than federal requirements are ARARs. The potential ARARs

include chemical-, action-, and location-specific ARARs, as summarized in Table 2-1.


43

Alternative 1 would not comply with applicable ARARs, as no action would be taken to prevent

contaminated groundwater from being used as a public water supply. Because Alternative 1 fails both

threshold criteria, it is not eligible to be selected as the remedy, and will not be discussed further in this

section. However, for comparison purposes, it is evaluated in Table 5-1. Alternatives 2, 3, and 4 would all

meet applicable ARARs.

5.1.3 Long-Term Effectiveness and Permanence

This criterion evaluates the effectiveness of an alternative in protecting human health and the environment

when the cleanup is complete. It also considers the effectiveness of the cleanup over the long term.

Alternatives 2, 3, and 4 would all provide a similar level of long-term effectiveness and permanence once

the RAOs have been achieved. However, because Alternative 3 would achieve the RAOs faster (10 years)

than Alternatives 4 (20 years) or 2 (30 years), it is ranked higher than Alternatives 2 and 4.

5.1.4 Reduction of Toxicity, Mobility, or Volume through Treatment

Alternative 2 would not provide for any active measures to allow for treatment. Alternatives 3 and 4 both

would meet the statutory preference for treatment; Alternative 3 would provide treatment in-situ;

Alternative 4 would provide treatment ex-situ. This criterion addresses the preference for selecting

remedial actions that use treatment technologies to permanently and significantly reduce the toxicity,

mobility, or volume of hazardous substances. This preference is satisfied when treatment reduces the

principal threats at a site through the destruction of toxic contaminants, reduction of the total mass of

toxic contaminants, irreversible encapsulation of contaminants, or reduction of the total volume of

contaminated media. Alternatives 3 and 4 would actively treat groundwater, and are therefore ranked

higher than Alternatives 1 and 2. Alternative 3 is ranked higher than 4 because due to process differences,

Alternative 4 would require management of more wastes (both water and process wastes) than

Alternative 3. Alternative 2 is ranked higher than Alternative 1 because it would include monitoring to

provide information that contaminant concentrations are decreasing.

5.1.5 Short-Term Effectiveness

This criterion examines the effectiveness of an alternative in protecting human health and the

environment during the cleanup until the cleanup is complete. It also considers protection of the

community, workers, and the environment during the cleanup.


44

Alternatives 2, 3, and 4 would use similar ICs to limit exposure to contaminants. However, Alternative 4

would have greater impact on the community due to the construction of the groundwater treatment plant

and the associated discharge line, and therefore would have more potential effects on the community. The

risks involved with all of these alternatives are well understood and could readily be mitigated.

5.1.6 Implementability

This criterion assesses the technical and administrative feasibility of an alternative and the availability of

required goods and services. Technical feasibility considers the ability to construct and operate a

technology and its reliability, the ease of undertaking additional remedial actions, and the ability to

monitor the effectiveness of a remedy. Administrative feasibility considers the ability to obtain approvals

from other parties or agencies and the extent of required coordination with other parties or agencies.

Technically, Alternatives 2, 3, and 4 would all be readily implementable. They would use well understood

technologies, and the skills needed would be available locally. Administratively, Alternatives 2 and 3

would both be readily implementable. Alternative 2 could encounter more administrative resistance to

implementation, due to the longer time to achieve RAOs when compared to Alternative 3 and the ongoing

success, although not yet complete, of enhanced bioremediation at the nearby Geocel facility.

Alternative 4, while implementable, would likely require more effort to get the access and permit-

equivalents necessary to construct the treatment plant (a permanent building likely requiring land

acquisition) and the discharge line.

5.1.7 Cost

This criterion evaluates the capital and O&M costs of each alternative. Section 4.2 and Appendix A

provide present-value costs to help compare costs among alternatives with different implementation

times.

Alternative 2 has an estimated present-value cost (rounded to three significant figures) of $1,290,000,

with a capital cost of $294,000 and annual O&M costs of $134,000 per year initially (years 1 through 5)

for quarterly monitoring, decreasing to $68,000 per year for semi-annual monitoring years 6 through 10

and $34,000 per year for annual monitoring years 11 through 30. Every 5 years, a five-year review would

be required at an estimated cost of $24,000. Alternative 2 is estimated to take 20 to 35 years to achieve

the RAOs, 30 years was used for cost estimating purposes.


45

Alternative 3 has an estimated present-value cost of $3,550,000, with a capital cost of $2,500,000 and

annual O&M costs of $134,000. Every 5 years, a five-year review would be required at an estimated cost

of $24,000. A single re-injection event is assumed to occur in year 3 at a cost of $100,000. Alternative 3

is estimated to take 10 years to achieve the RAOs.

Alternative 4 has an estimated present-value cost of $11,400,000. Total O&M costs (for treatment system

and sampling/monitoring) are estimated at $681,000 per year for years 1 through 5, decreasing to

$611,000 per year for years 6 through 20. Every 5 years, a five-year review would be required at an

estimated cost of $24,000. Alternative 4 is estimated to take 20 years to achieve the RAOs.

Alternative 4 is the most costly, with Alternatives 3 and 2 each costing less. The alternatives are ranked in

order of their costs (highest cost getting the fewest points).

5.2 SUMMARY The purpose of the comparative analysis was to identify the relative advantages and disadvantages of each

remedial action alternative. Table 5-1 provides the evaluation in tabular form and summarizes the

advantages and disadvantages of the different alternatives. The No-Action alternative failed to meet the

threshold criteria and therefore was not further considered for the primary balancing and modifying

criteria. The remaining alternatives passed the threshold criteria and were compared based on the primary

and modifying criteria. In order of highest- to lowest-ranked alternative, the alternatives ranked as

follows:

1. Alternative 3 – In-Situ Groundwater Treatment through Bioremediation

2. Alternative 2 – Minimal Action with Institutional Controls and Monitored Natural Attenuation

3. Alternative 4 – Ex-Situ Groundwater Treatment by Extraction, Treatment, and Discharge


46

6.0 REFERENCES Indiana Department of Environmental Management (IDEM). 2007. “Preliminary Assessment Report for

Lane Street Ground Water Contamination, Elkhart, Indiana, Elkhart County.” October 5.

IDEM. 2008. “Site Inspection Report for Lane Street Ground Water Contamination, Elkhart, Indiana, Elkhart County.” September 5.

IDEM and United States Environmental Protection Agency. 2009. “HRS Documentation Record, Lane Street Ground Water Contamination, EPA ID No. INN000510229.” April.

Indiana Department of Natural Resources (IDNR). 1987. “Water Resource Availability in the St. Joseph River Basin, Indiana.” Division of Water.

Malcolm Pirnie. 2011. “City of Elkhart, Indiana, Public Works and Utility Department, Water Master Plan Update (2011-2020).” June.

Roberts Environmental Services, LLC (Roberts). 2012. “Response to IDEM Letter Dated November 30, 2012, to U.S. EPA, Region V ‘Site Investigation Data Related to the Lane Street Groundwater Contamination Site, Elkhart, Indiana’ EPA I.D. # INN000510229.” December 20.

Roberts. 2013. “Hydrogeologic Study, Lane Street Groundwater Contamination Site, Elkhart, Indiana, EPA I.D. #INN000510229.” April 22.

Roberts. 2015. “Public Comments to U.S. EPA August 2015 Final Remedial Investigation Report.” December 28.

SulTRAC. 2015. “Final Remedial Investigation Report, Lane Street Groundwater Contamination Site, Elkhart, Elkhart County, Indiana.” August.

United States Environmental Protection Agency (EPA).1988. “Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA;” USEPA Office of Emergency and Remedial Response, EPA/540/G-89/004, OSWER Directive 9355.3-01; October.

EPA. 1994. National Oil and Hazardous Substances Pollution Contingency Plan; Final Rule. September 15.

EPA. 2011. “RAC 2, Statement of Work for Remedial Investigation/Feasibility Study (RI/FS), Lane Street Ground Water Contamination Site, Elkhart County, Indiana.” July 22.

EPA. 2014. “RAC 2, Statement of Work for Remedial Investigation/Feasibility Study (RI/FS), Lane Street Groundwater Contamination Site, Elkhart, Indiana.” June 9.

United States Geological Survey (USGS). 1989. “Ground Water Levels, Flow, and Quality in Northwestern Elkhart County, Indiana.” USGS Water Resources Investigation Report: 91-4053.

USGS. 1998. “Geohydrology and Simulated Ground-water Flow in Northwestern Elkhart County, Indiana.” USGS Water-Resources Investigations Report: 97-4204.


47

Weston Solutions, Inc. (WESTON). 2008. “Lane Street Groundwater Site, Elkhart, Elkhart County, Indiana, Technical Direction Document Number: S05-0002-0708-025, Document Control Number: 279-2A-ABOY.” March 19.


FIGURES

Ana

Dr

Timothy Ct

Cooper Dr

Ma

rina

Dr

Co Rd 106

Lan

e S

t

Barley St

Ker

shne

r Ln

Rye C

t

Naples Ct

Broadwood Dr

Wo

od

lan

d D

r

Alm

ond

Dr

Bedford Ct

Woodland Dr

Approximate site boundary

Northeastern City of Elkhart

0 100 200 300 400 500

feet

0 50

miles

0 1

mile

¹

Indiana Site Area

document path: D:\projects\Lane Street\_FS\FS figure 1‐1 site location.mxd author: ASchubert

Basemaps source: Esri

LANE STREET GROUND WATER CONTAMINATION SITEELKHART, ELKHART COUNTY, INDIANA

FINAL FEASIBILITY STUDY REPORT

SITE LOCATION

EPA REGION 5 RAC 2 | REVISION 2 | MARCH 2016

FIGURE 1-1

Elkhart

An

a D

r

Timothy Ct

Cooper Dr

Ma

rin

a D

r

Co Rd 106

La

ne

St

Barley St

Rye C

t

Ker

shne

r Ln

Alm

on

Industrial / Commercial Area

Residential Area ¹0 100 200 300 400 500 feet

1 inch = 400 feet

Geocel Corporation site boundary

Drainage ditch




SITE DETAIL


FIGURE 1-2

3501 Cooper Dr.3503 Cooper Dr.

3505 Cooper Dr.3507 Cooper Dr. 2505 Marina Dr.

2503 Marina Dr.

2501 Marina Dr.3506 Henke St.3504 Henke St.2500 Ada Dr.

2500 Ada Dr.

2506 Ada Dr.

3502 Cooper Dr.2600 Ada Dr. 3504 Cooper Dr. 2601 Marina Dr.

2602 Marina Dr.

2600 Marina Dr.

2504 Marina Dr.

2502 Marina Dr.

2500 Marina Dr.

document path: D:\projects\Lane Street\_FS\FS figure 1‐2 site detail.mxd author: ASchubert

Basemap source: Esri

PrimaryContaminant

Sources

PrimaryContaminant

R/T Mechanisms

PrimaryAffectedMedia

SecondaryContaminant

R/T Mechanisms

SecondaryAffectedMedia

TertiaryContaminant

R/T Mechanisms

TertiaryAffectedMedia

ExposureRoutes

Inhalation

Ingestion

Dermal Contact

Ingestion

Dermal Contact

Inhalation

Inhalation

Ingestion

Dermal ContactInhalation

Source(s) Unknown,Potential Sources Include (1):

SurfaceSoil (3)

Fugitive Emissions

2503 Marina Drive GroundwaterSpills/Leaks/Other (2)

2601 Marina Drive

3504 Henke Street

Volatilization

Ambient Air

Leaching/Percolation

SubsurfaceSoil (3)Adsorption

Indoor AirVapor Intrusion

Potentially Exposed Human Receptors

I/C

Wo

rker

Re

sid

ent

Co

nst

ruct

ion

Wor

ker

Util

ity W

orke

r

(4) (4) (5) (5)

EPA = U.S. Environmental Protection AgencyEPC = Exposure Point ConcentrationI/C = Industrial/CommercialRI = Remedial InvestigationR/T = Release/transportVISL = Vapor intrusion screening levelVOC = Volatile organic compound

= Potentially complete exposure pathway; retained for quantitative analysis= Potentially complete, but insignificant exposure pathway; was not retained= Incomplete exposure pathway; was not retained

Notes:

- -

- - - -

1. Potential sources all handle or handled hazardous substances.

2. "Other" includes releases to floor drains, dry wells, or septic systems.

3. Only arsenic has been detected at a concentration greater than its EPA residential Regional Screening Level (RSL). However, as discussed in Sections 1.5.1 and 1.5.3 of the Final Lane Street RI Report, based on site history and comparison to county-specific and national background levels, arsenic was determined to not be site-related. Therefore, no soil chemicals of potential concern were identified and receptor-specificsoil exposures were not evaluated in the risk assessment (SulTRAC 2015).

4. Exposures, risks, and hazards associated with vapor intrusion of VOCs from groundwater and soil gas are assessed qualitatively using EPAs VISL Calculator (EPA 2014).

5. EPCs for air in a construction or utility trench will be calculated using the methodology presented in Virginia Department of Environmental Quality's VoluntaryRemediation Program Risk Assessment Guidance dated August 2014.


CONCEPTUAL SITE MODEL

FIGURE 1-3

ELKHART, ELKHART COUNTY, INDIANA

LANE STREET GROUND WATER CONTAMINATION SITE


MW‐11

MW‐10

MW‐09

MW‐08

MW‐07

MW‐06

MW‐05

MW‐04

MW‐03

MW‐02

MW‐01

R‐MW‐7

R‐MW‐3

R‐MW‐11

R‐MW‐14

R‐MW‐13

R‐MW‐12

R‐MW‐10

VAS‐GW40

VAS‐GW47

VAS‐GW45VAS‐GW44

VAS‐GW46

VAS‐GW43

VAS‐GW42

VAS‐GW41

VAS‐GW38

VAS‐GW39

Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX,Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community, Esri, HERE, DeLorme,MapmyIndia, © OpenStreetMap contributors

¹0 100 200 300 400 500 feet

1 inch = 250 feet

2014 SulTRAC monitoring well network and VAS

Approximate plume footprint



document path: D:\projects\Lane Street\_FS\FS figure 1‐4 plume.mxd author: ASchubert



AERIAL EXTENT OF CO-MINGLEDGROUNDWATER PLUME

FIGURE 1-4

Notes:Plume footprint based on RI data (SulTRAC 2015) and November 2015 Roberts' data (Roberts 2015).Plume and descriptions based on exceedances of proposed RALs.

1,1 DCA = 1,1-dichloroethane1,1,1-TCA = 1,1,1-trichloroethanecis-1,2-DCE = cis-1,2-dichloroethenePCE = tetrachloroetheneRAL = Remedial Action LevelRI = Remedial InvestigationTCE = trichloroetheneVAS = vertical aquifer sampling


¹

0 100 200 300 400 500 feet

1 inch = 250 feet

Proposed well field area




document path: D:\projects\Lane Street\_FS\FS figure 3‐1 treatment areas.mxd author: ASchubert


CONCEPTUAL LOCATION OF TREATMENTAREAS FOR ALTERNATIVE 3

FIGURE 3-1

Location of injectionand recirculation wells

Location of oxygen injection wells



Residential Area

1,1 DCA = 1,1-dichloroethanecis-1,2-DCE = cis-1,2-dichloroethenePCE = tetrachloroetheneRAL = Remedial Action LevelRI = Remedial InvestigationTCE = trichloroethene

Notes:Plume footprint based on RI data (SulTRAC 2015) and November 2015 Roberts' data (Roberts 2015). Plume and descriptions based on exceedances of proposed RALs.


¹

0 100 200 300 400 500 feet

1 inch = 250 feet

Proposed well field area

Groundwater treatment building




document path: D:\projects\Lane Street\_FS\FS figure 3‐2 extraction wells.mxd author: ASchubert


EXTRACTION AND EX-SITU TREATMENTLOCATION OF EXTRACTION WELL AREAS

FIGURE 3-2FINAL FEASIBILITY STUDY REPORT

Treatment building


Residential Area

1,1 DCA = 1,1-dichloroethanecis-1,2-DCE = cis-1,2-dichloroethenePCE = tetrachloroetheneRAL = Remedial Action LevelRI = Remedial InvestigationTCE = trichloroethene

Notes:Plume footprint based on RI data (SulTRAC 2015) and November 2015 Roberts' data (Roberts 2015). Plume and descriptions based on exceedances of proposed RALs.

Proposed extractionwell areas


TABLES

TABLE 2-1 POTENTIALLY APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

Lane Street Ground Water Contamination Site Elkhart, Elkhart County, Indiana

Page 1 of 10

Potentially Applicable or Relevant and Appropriate Requirement (ARAR) Description Type of ARAR

Potentially Applicable or Relevant and Appropriate? Comment

SAFE DRINKING WATER ACT (SDWA) of 1996 40 CFR Parts 141.60 – 141.63 and 141/50 – 141.52

The National Primary Drinking Water Regulations establish Maximum Contaminant Levels (MCLs) and Maximum Contaminant Level Goals (MCLGs) for several common organic and inorganic contaminants for public drinking water systems. MCLs specify the maximum permissible concentrations of contaminants in public drinking water supplies. MCLs are federally enforceable standards based in part on the availability and cost of treatment techniques. MCLGs specify the maximum concentration at which no known or anticipated adverse effect on humans will occur. MCLGs are non-enforceable health-based goals set equal to or lower than MCLs.

Chemical-Specific

Relevant and Appropriate

Applies to all public water supplies (i.e., having more than 15 connections or serving more than 25 persons regularly). The MCLs are ARARs at the Site since the aquifer is currently used as a drinking water supply. At present, there is nothing to prohibit the use of groundwater at the Lane Street Site from being used as a public water supply (for instance, supplying an apartment building with 25 or more people living in it) or a small water system.

FLOODPLAIN MANAGEMENT EXECUTIVE ORDER 11988 AS AMENDED BY EXECUTIVE ORDER 12148, JULY 20, 1979 40 CFR Part 6, Appendix A Requires federal agencies to evaluate

the potential adverse effects associated with direct and indirect development of a floodplain. Alternatives that involve modification/construction within a floodplain may not be selected unless a determination is made that no practicable alternative exists. If no practicable alternative exists, potential harm must be minimized and action taken to restore and preserve the

Location-Specific Applicable Determined by St. Joseph River floodplain

TABLE 2-1 (Continued) POTENTIALLY APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS


Page 2 of 10



natural and beneficial values of the floodplain.

CLEAN WATER ACT (CWA) OF 1977, AMENDMENTS 1981, 1987 Protection of Wetlands Executive Order 11990 [40 CFR Part 6, Appendix A]

Under this Order, federal agencies are required to minimize the destruction, loss, or degradation of wetlands, and preserve and enhance natural and beneficial values of wetlands. If remediation is required within wetland areas and no practical alternative exists, potential harm must be minimized and action taken to restore natural and beneficial values.

Location-Specific To Be Considered Determined by location of wetlands, if any, along the surface water bodies. No wetlands currently exist along the Site boundaries.

National Pollutant Discharge Elimination System (NPDES) 33 U.S.C. § 1251-1387 #Clean Water Act National Pollution Discharge Elimination System (NPDES) Permit Program (40 CFR 122)

Regulates discharges of pollutants to navigable waters.

Action-Specific and may be Chemical-Specific

Potentially Applicable

This is potentially applicable depending upon the nature of remedial action chosen. Would apply to extracted groundwater if discharged to navigable waters.

#Federal Water Pollution Control Act Section 401: Water Quality Certification

Establishes a permit program to regulate a discharge into the navigable waters of the U.S., including wetlands.

Chemical-Specific


Depends upon the nature of remedial action chosen.

FISH AND WILDLIFE COORDINATION ACT



Page 3 of 10



Fish and Wildlife Coordination Act; 16 U.S.C. § 661 et seq. 16 USC 742a 16 USC 2901 40 CFR 6.302 50 CFR 402

Actions that affect species/habitat require consultation with U.S. Department of Interior, U.S. Fish and Wildlife Service, and National Marine Fisheries Service, and/or state agencies, as appropriate, to ensure that proposed actions do not jeopardize the continued existence of the species or adversely modify or destroy critical habitat. The effects of water-related projects on fish and wildlife resources must be considered. Action must be taken to prevent, mitigate, or compensate for project-related damages or losses to fish and wildlife resources. Consultation with the responsible agency is also strongly recommended for on-site actions. Under 40 CFR Part 300.38, these requirements apply to all response activities under the National Contingency Plan (NCP).

Location-Specific Potentially Applicable


RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 Resource Conservation and Recovery Act (40 CFR 260-268)

Regulations and requirements for generators, transporters, or owners, or operators of treatment, storage, or disposal facilities that use hazardous waste materials.

Chemical-Specific


Depends upon the nature of remedial action chosen. Would apply to potential disposal of investigation-derived waste (IDW). Would also potentially apply to remedies which generate waste, such as excavations performed as part of installing a remedial system.



Page 4 of 10



ENDANGERED SPECIES ACT Endangered Species Act [16 USC 1531; 50 CFR 200

Requires that federal agencies insure that any action authorized, funded, or carried out by the agency is not likely to jeopardize the continued existence of any threatened or endangered species or adversely modify critical habitat.


No endangered species are known to be present on the Site that would be affected by remedial actions.

NATURAL HISTORIC PRESERVATION ACT National Historic Preservation Act [16 USC 661 et seq] 36 CFR Part 65

Establishes procedures to provide for preservation of scientific, historical, and archaeological data that might be destroyed through alteration of terrain as a result of a federal construction project or a federally licensed activity or program. If scientific, historical, or archaeological artifacts are discovered at the site, work in the area of the site affected by such discovery will be halted pending a completion of any data recovery and preservation activities required pursuant to the act and any implementing regulations.


No part of the Lane Street Site is listed on the national register of historic places. Potentially applicable during remedial activities if scientific, historic, or archaeological artifacts are identified during implementation of the remedy.

DEPARTMENT OF TRANSPORTATION



Page 5 of 10



Requirements for the Transport of Hazardous Materials [40 CFR 172]

Transportation of hazardous materials on public roadways must comply with the requirements.

Action-Specific Potentially Applicable

If hazardous materials are offered for transportation, or transported to the Site as part of a remedial action, DOT regulations would apply. Depends upon the nature of remedial action chosen.

OTHER FEDERAL GUIDELINES TO BE CONSIDERED Integrated Risk Information System (IRIS) (www.epa.gov/iris)

Risk reference doses (RfDs) are estimates of daily exposure levels that are unlikely to cause significant adverse non-carcinogenic health effects over a lifetime. Cancer Slope Factors (CSFs) are used to compute the incremental cancer risk from exposure to site contaminants and represent the most up-to-date information on cancer risk from EPA’s Carcinogen Assessment Group.

Chemical-Specific

To be Considered IRIS is a source of risk-related information which is used in the risk assessment process. IRIS is updated from time to time. Information within IRIS can be used both for evaluating potential risks, and evaluating the potential effectiveness of remedies.

EPA Regional Screening Levels (https://www.epa.gov/risk/regional-screening-levels-rsls)

EPA Regional Screening Levels ([RSLs] and associated guidance necessary to calculate them) are risk-based tools for evaluating and cleaning up contaminated sites. The RSLs represent Agency guidelines and are not legally enforceable standards.

Chemical-Specific

To be Considered EPA RSLs are screening levels and can be used to assess if concentrations are potentially protective or not. The RSLs are typically updated twice per year.

Occupational Safety and Health Act (29 CFR 1910 and 29 CFR 1926)

The Act was passed in 1970 to ensure worker safety on the job. The U.S. Department of Labor oversees it. Worker safety at hazardous waste sites is addressed under 29 CFR 1910.120: Hazardous Waste Operations and


The Act is considered an ARAR for construction activities performed during the implementation of remedies. Depends upon the nature of remedial action chosen.



Page 6 of 10



Emergency Response. General worker safety is covered elsewhere within the law.

Underground Injection Control (40 CFR 144-147)

These regulations protect groundwater sources of drinking water by imposing restrictions to underground injections.


Groundwater remedial action may require injections, depending upon the remedial action chosen.

INDIANA ADMINISTRATIVE CODE (IAC) Indiana Drinking Water Standards (327 IAC 2-11, 327 IAC 8)

These rules establish MCLs in accordance with the SDWA (40 CFR 141.11), as well as groundwater classification methods and associated standards.

Chemical-Specific

Applicable Applicable to drinking water within the State of Indiana, and applicable to groundwater outside of established groundwater management zones. The Site is not presently located within a designated groundwater management zone.

Water Well Driller Licensing Requirements (IC 25-39-3 and 312 IAC 13)

This regulation provides for licensing of water well drillers.

Action-Specific Applicable Installation of water wells (such as extraction or monitoring wells) may be required, depending upon the remedial action chosen.

Regulation of Water Well Drilling (IC 25-39-4 and 312 IAC 13)

This regulation outlines the requirements for construction and abandonment of groundwater wells for non-personal use in Indiana.

Action-Specific Applicable Installation of water wells (such as extraction or monitoring wells) may be required, depending upon the remedial action chosen.

Indiana Solid Waste Rules (IAC Title 329)

This law applies to remedies that involve off-site disposal of materials typically involved with excavations. Contaminated soils or wastes that are excavated for off-site disposal would be tested for hazardous waste characteristics and, if soil or waste is found to be hazardous waste, the

Action-Specific Potentially Relevant and Appropriate




Page 7 of 10



requirements of the Rules would be followed.

Indiana Environmental Restrictive Covenants (Indiana Code 13-25-4-24

Provides requirements for sites to record Environmental Restrictive Covenants where the remedial action will not result in unrestricted land use.


Depends upon the nature of remedial action chosen. May be used as one type of IC.

Indiana Air Pollution Control Regulations (326 IAC 5-1-3).

This law applies to the regulation air emissions, for activities such as excavation that have the potential to create dust. Provides opacity limits.

Action-Specific Potentially Relevant and Appropriate

Depends upon the nature of remedial action chosen. Usually applies during construction.

Risk Integrated System of Closure (RISC)

RISC is IDEM’s method for developing remediation objectives (risk-based and site-specific) for contaminated soil and groundwater. These remediation objectives protect human health and take into account Site conditions and land use. This is a non-rule policy document.

Chemical-Specific

To be Considered The RISC document provides a methodology for establishing remedial goals and determining that remediation has been achieved. The RISC policy does not apply to Superfund sites, but does apply to remedial sites under several state programs, including the state version of RCRA, the state Leaking Underground Storage Tank program, the State Cleanup Program (state equivalent of the Federal Superfund Program) and the Voluntary Remediation Program.

Voluntary Remediation of Hazardous Substances and Petroleum (Indiana Code [IC] 13-25-5)

IC 13-25-5 established the Voluntary Remediation Program in 1993 and gave the IDEM the authority to establish guidelines for voluntary site closure. Under this authority IDEM developed a nonrule policy document, the RISC, to guide site closures within

Chemical-Specific

To be Considered The RISC document provides a methodology for establishing remedial goals and determining that remediation has been achieved. The RISC policy does not apply to Superfund sites, but does apply to remedial sites under several state programs, including the state



Page 8 of 10



the authority of IDEM’s remediation programs. This guidance document does not have the effect of law.

version of RCRA, the state Leaking Underground Storage Tank program, the State Cleanup Program (state equivalent of the Federal Superfund Program) and the Voluntary Remediation Program.

Contained in Policy Guidance for RCRA (NPRD Waste-0052)

Guidance document on management of remediation waste. This guidance document does not have the effect of law.

Action-Specific To be Considered Depends upon the nature of remedial action chosen.

Indiana Regulations for Establishing Emissions Levels for volatile organic compounds (VOCs) (326 IAC 2 and 326 IAC 8)

326 IAC 8 generally applies to facilities that have emissions greater than 15 pounds per day of VOCs.

Action-Specific Depends upon the nature of the remedial action chosen.

Indiana Regulations for Permitting of Air Strippers (326 IAC 2 and 326 IAC 8)

IAC 326 establishes permitting requirements for emissions of VOCs, requiring Best Available Control Technology (BACT) for new sources with potential emissions exceeding a specified threshold value.

Action-Specific Depends upon the nature of the remedial action chosen.

Indiana Regulations for Construction Permits for Water Treatment Facilities (327 IAC 3)

Regulations for the issuance of permits for the construction of water pollution treatment/control facilities.



Indiana NPDES Permit regulations (327 IAC 5 and 327 IAC 2)

Regulations for NPDES discharges and applicable permits. This is the Indiana implementation of the Federal NPDES permit program.



Indiana Wellhead Protection Program (327 IAC 8-4.1)

This rule establishes MCLs (40 CFR 141 and 327 IAC 8) as cleanup standards for impacted groundwater

Location-Specific To be Considered The Lane Street Site is not located within a current wellhead protection area.



Page 9 of 10



within established wellhead protection areas.

Water Quality Standards (327 IAC 2)

These regulations provide the standards for surface water quality in Indiana.

Chemical-Specific



Groundwater Quality Standards (327 IAC 2-11)

These regulations provide the standards for groundwater quality in Indiana. Provides groundwater classification plan.

Chemical-Specific


Provides a system of classification of groundwater, and procedures to reclassify groundwater. Includes a discussion on how approved Institutional Controls can affect groundwater classification.

Damage to Underground Utilities (IC 8-1 Chapter 26)

This is the underground utility location law. It requires that a notice via the Indiana one-call system be made seeking utility locations prior to excavation.


Potentially applicable depending upon the remedy selected. It would apply to all remedies involving any excavation.

ELKHART COUNTY AND CITY OF ELKHART Elkhart County Groundwater Protection Ordinance No. 09-172

Purpose of this Ordinance to enhance and preserve the public health, safety, and welfare of persons and property in Elkhart County by protecting the ground water of Elkhart County from degradation resulting from the spills of toxic or hazardous substances. Applies to facilities that use, store, or generate toxic or hazardous substances.


Use and/or storage of hazardous materials may be required, depending upon the remedial action chosen.

City of Elkhart - Drilling Permits The City of Elkhart requires that all excavations along city rights-of-way

Action Specific Depends upon the nature of remedial action chosen, and also depends on the final design.



Page 10 of 10



be permitted. Additional permits may be required for drilling.

Notes:

CFR Code of Federal Regulations DOT Department of Transportation EPA United States Environmental Protection Agency IC institutional control IDEM Indiana Department of Environmental Management RCRA Resource Conservation and Recovery Act U.S. United States USC United States Code

TABLE 2-2 REMEDIAL ACTION LEVELS FOR GROUNDWATER


Page 1 of 1

Analyte Name Preliminary Groundwater RAL (µg/L) Reference cis-1,2-dichloroethene 70 MCL 1,1-dichloroethane 2.8 RSL1 trichloroethene 5 MCL tetrachloroethene 5 MCL

Notes:

1 RSL from EPA Summary Table November 2015 (Source: http://www.epa.gov/region9/superfund/prg/)

µg/L microgram per liter EPA United States Environmental Protection Agency MCL Maximum Contaminant Level RAL Remedial Action Level RSL Regional Screening Level

TABLE 2-3 GROUNDWATER GENERAL RESPONSE ACTIONS


Page 1 of 2

General Response Action Description/Comment

No Action Under the CERCLA-mandated no-action alternative, no action will be taken at the Lane Street Site with respect to remediation.

Institutional Controls This GRA includes administrative mechanisms such as deed restrictions and use designations (e.g., water for non-potable use only) as well as physical actions such as posting and fencing to restrict Site access and use.

Monitored Natural Attenuation

MNA uses known, ongoing natural processes to contain, destroy, or otherwise reduce the bioavailability or toxicity of contaminants in groundwater. A key element of MNA is monitoring to ensure that risk reduction is progressing as anticipated. For MNA to be selected, a demonstration has to be made that MNA is occurring.

Removal This GRA involves the excavation of contaminated soils. The use of this GRA will have to include one or more other GRAs (such as transportation, ex-situ treatment, disposal, consolidation).

Disposal This GRA involves disposal of contaminated soils at an approved disposal facility. The use of this GRA will have to include one or more other GRAs (such as excavation).

Containment For soil, containment generally entails capping or some form of horizontal barrier to isolate impacted soil from human and ecological receptors. This GRA may require implementation of removal and ex-situ treatment to be effective. Containment may also include capping to reduce the infiltration of stormwater and surface water.

In-Situ Treatment This GRA includes remedies that involve implementing processes to contain, destroy, remove, or otherwise reduce the bioavailability or toxicity of contaminants in soil. This GRA may involve physical, chemical, biological, or combination of processes. Treatment to be conducted onsite, in-situ.

Ex-Situ Treatment This GRA includes remedies that involve implementing processes to contain, destroy, or otherwise reduce the bioavailability or toxicity of contaminants in soil. This GRA may involve physical, chemical, or

TABLE 2-3 (Continued) GROUNDWATER GENERAL RESPONSE ACTIONS


Page 2 of 2

General Response Action Description/Comment

biological processes. Treatment may be conducted at on- or off-site facilities. The use of this GRA will have to include one or more other GRAs (such as excavation).

In-Situ Stabilization This GRA includes remedies that involve implementing processes where contaminants are physically bound within a stabilized mass, or chemical reactions are induced between the stabilizing agent and contaminants to reduce their mobility. Stabilization to be conducted onsite, in-situ

Ex-Situ Stabilization This GRA includes remedies that involve implementing processes where contaminants are physically bound within a stabilized mass, or chemical reactions are induced between the stabilizing agent and contaminants to reduce their mobility. Stabilization to be conducted onsite, ex-situ. The use of this GRA will have to include one or more other GRAs (such as excavation).

Vapor Intrusion Pathway Restriction

This GRA includes remedies that implement processes to restrict the direct exposure pathway. Such remedies can include provision of alternate water supplies or treatment prior to use.

Notes:

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act GRA General Response Action IC institutional control MNA monitored natural attenuation

TABLE 2-4 GROUNDWATER CANDIDATE TECHNOLOGIES FOR RISK MITIGATION


Page 1 of 5

Candidate Technology Description Comment/Note

No Action

No action CERCLA-mandated alternative of no action taken to mitigate risk. • CERCLA-mandated. At this time, no action means that no further actions, beyond those already taken by EPA and IDEM, will occur.


Groundwater use restrictions Stipulated limits on groundwater use; through community ordinance, require a permit for installation of groundwater wells and prohibit installation of new wells within institutional control zone; prohibit groundwater for potable use (e.g., industrial process water only); require properties with private wells to be connected to the municipal water supply; may include deed restrictions.

• May also be used in conjunction with remedies that leave behind residual contamination for an extended period of time.

• Can be applied as an interim or permanent remedial action.

Property access restrictions Restriction to prevent property access; can be through posting or fencing. • May also be used in conjunction with remedies that leave behind residual contamination for an extended period of time.

• Can be applied as an interim or permanent remedial action. Land use restrictions Provides limits on how land can be used. For example, prohibiting

residential use of a property and / or requiring new construction take measures to reduce or prevent vapor intrusion.


• Can be applied as an interim or permanent remedial action.


MNA Relies on unenhanced natural processes to protect human and environmental receptors from unacceptable exposure to contaminants; relies on physical, chemical, and biological processes to isolate, destroy, dilute, or otherwise reduce the bioavailability or toxicity of contaminants in groundwater.


• Monitoring a key component of MNA, with periodic assessment of whether the remedy is progressing to achieving goals.

• Typically used as a permanent remedial action.

Removal

Extraction wells Removal of impacted groundwater using a series of wells and pumps. • May be used in conjunction with containment, ex-situ treatment, and/or discharge. • Due to the long timeframe (years) necessary to achieve remedial objectives, typically

used as a permanent remedy. • Requires another technology as part of a treatment train.

Interceptor trench Removal of impacted groundwater using interceptor trenches constructed with perforated pipe in trenches; trenches backfilled with porous media to collect impacted groundwater.

• May be used in conjunction with containment, ex-situ treatment, and/or discharge • Due to the long timeframe (years) necessary to achieve remedial objectives, typically


TABLE 2-4 (Continued) GROUNDWATER CANDIDATE TECHNOLOGIES FOR RISK MITIGATION


Page 2 of 5


DPE and TPE DPE, also known as multi-phase extraction, vacuum-enhanced extraction, or sometimes bioslurping, is a technology that uses a high vacuum system to remove various combinations of contaminated groundwater, NAPL, and vapor from the subsurface. Extracted liquids and vapor are treated and collected for disposal, or re-injected to the subsurface (where permissible under applicable state laws). TPE is similar, except that two separate phases (liquid/gas) are extracted separately, rather than together.

• Generally considered for VOCs. • Designed to address NAPL, as well as contaminated groundwater and soil. • Requires treatment or disposal of both water and vapor. • Due to the long timeframe (years) necessary to achieve remedial objectives, typically


Discharge

Puterbaugh Creek Discharge to Puterbaugh Creek. • May be used in conjunction with removal and ex-situ treatment. • Requires the most treatment of the discharge options. • Discharge required to meet NPDES permit program requirements. • Requires another technology as part of a treatment train.

POTW Discharge to local POTW.

• May be used in conjunction with removal and ex-situ treatment. • Requires discharge permits. • POTW may have capacity limitations based on contaminant loading or water volumes. • Requires another technology as part of a treatment train.

Reinjection or infiltration Discharge through reinjection or infiltration into aquifer.

• May be used in conjunction with removal and ex-situ treatment. • Permits to re-inject treated effluent can be problematic. • Requires another technology as part of a treatment train.

Off-site disposal Disposal at an off-site facility. • May be used in conjunction with removal. • Requires the least treatment of the removal and ex-situ treatment options. • Potentially very expensive due to transportation costs, particularly if the volumes

involved are large. Requires another technology as part of a treatment train.

Containment

Containment with a barrier wall Installation of low-permeability barrier wall such as slurry or sheet-pile wall to prevent migration to sensitive receptors.

• Provides isolation of contamination and sensitive receptors. • May require implementation of a removal and ex-situ treatment system to be effective. • Often a temporary solution pending further assessment of contamination levels.

Containment with a barrier wall and low-permeability cap

Installation of low-permeability barrier wall such as slurry or sheet-pile wall to prevent migration to sensitive receptors; also, installation of low-permeability cap such as synthetic liner, paving, or designed clay layer to minimize stormwater infiltration

• Provides isolation of contamination and sensitive receptors. • May require implementation of a removal and ex-situ treatment system to be effective. • Minimizes flow rate for groundwater treatment. • Not suitable for use in a residential area; can be difficult to implement at an active

industrial/commercial facility. • Not typically used at large multi-use sites such as the Lane Street Site.



Page 3 of 5


Hydraulic containment Installation of a groundwater extraction system, such as extraction wells or an interceptor trench, designed to hydraulically contain a contaminant plume by creating a cone of depression or groundwater elevation slope that directs groundwater flow away from sensitive receptors or preventing the spread of the contamination plume.

• Can be effective in some situations, but can be difficult to achieve containment in thick highly permeable aquifers.

• Is presently being used, with limited success, at the Conrail site. The system at the Conrail site is being modified after being determined to not be providing sufficient containment.

• Can require that large amounts of groundwater be treated and/or disposed. • Requires another technology as part of a treatment train.

In-Situ Treatment

Bioremediation A biologically enhanced treatment technology that includes the introduction of nutrients, microorganism inoculations, or alternatively chemicals to enhance the biological habitat of the aquifer, to mediate biological degradation of contaminants. The specific bioremediation technology used will be dependent upon site-specific conditions. Both anaerobic and aerobic environments may be used. Contaminants may be completely removed, depleted below maximum contaminant levels, or converted into less toxic forms.

• Generally considered for organic compounds. • Generally requires bench-scale and pilot testing. • May need to be used sequentially to achieve anaerobic and aerobic conditions to treat

different chemicals and their degradation products. • Treatment time varies depending upon the size of area to be treated and the other site-

specific conditions. Treatment is typically years to achieve remedial goals.

Reactive wall/funnel and gate Installation of a flow-through subsurface wall to intercept groundwater; wall constructed of adsorption media or compounds that will interact to reduce bioavailability or toxicity of contaminants in groundwater; funnel and gate walls constructed of lower permeability sections directing flow to higher permeability sections, where reactive materials treat water as it passes through the wall.

• Generally considered for organics but has been used for metals and inorganic compounds.

• Generally requires bench-scale and pilot testing. • May require installation of a SVE system to control air emissions or vapor migration. • Site configuration may require multiple installations to capture and treat plume. • Typically used as part of a permanent solution. Construction time can be months;

operation time can be years. ISCO Addition of reagents to chemically oxidize contaminants within an aquifer

or source area within the unsaturated (vadose) zone. Reagents used will depend on the specific compounds, concentrations, and aquifer and soil properties. Typically bench-scale and pilot testing of the contaminated media is required to design an effective treatment.

• Generally considered for organic compounds. • Requires distribution of reagents throughout treatment zone. • Generally requires bench-scale and pilot testing. • Typically used as a permanent solution. • May be difficult to implement at a large site with multiple occupied buildings.

Air sparging Air sparging involves the injection of air or oxygen through a contaminated aquifer. Injected air traverses horizontally and vertically in channels through the soil column, creating an underground stripper that removes VOCs and some SVOCs by volatilization.

• Can be implemented in conjunction with SVE or bioremediation. • Generally considered for VOCs. • Requires supplying air throughout treatment zone. • Generally requires bench-scale and pilot testing. • Typically used as part of a permanent solution. Construction time can be months;

operation time can be years.



Page 4 of 5


SVE SVE is used to remediate unsaturated (vadose) zone soil. A vacuum is applied to the soil to induce the controlled flow of air and remove VOCs and some SVOCs from the soil. SVE usually is performed in-situ; however, in some cases, it can be used as an ex-situ technology.

• Generally considered for VOCs. • System exhaust and residual liquids may require treatment or disposal. • Not effective in saturated zone. • Generally requires bench-scale and pilot testing. • May be used to control subsurface vapors (soil gas); typically used as part of a

permanent solution. Construction time can be months; operation time can be years. In-well air stripping Air is injected into a double-screened well, lifting the water in the well

and forcing it out the upper screen. Simultaneously, additional water is drawn in the lower screen. Once in the well, some of the VOCs in the contaminated groundwater are transferred from the dissolved phase to the vapor phase by air bubbles. The contaminated air rises in the well to the water surface where vapors are drawn off and treated by a SVE system.

• Generally considered for VOCs. • Most effective at sites with high concentrations of dissolved contaminants with high

Henry’s law constants and deep water tables. • Requires installation of a SVE system to capture vapor. Typically used as part of a

permanent solution. Construction time can be months; operation time can be years.

Ex-Situ Treatment

Bioreactors Contaminants in extracted groundwater put into contact with microorganisms in attached or suspended growth biological reactors; microorganisms capable of degrading organic compounds to less toxic materials such as carbon dioxide, methane, and water through aerobic and/or anaerobic degradation processes.

• Generally considered for organic compounds. • Requires implementation of a removal and discharge technologies. • Typically used as part of a permanent solution. Construction time can be months;

operation time can be years.

Activated carbon/adsorption Physical process that removes contaminants from groundwater through sorption onto available activated carbon sites; activated carbon periodically replaced and may be regenerated.

• More effective on organic rather than inorganic compounds. • May require implementation of removal and discharge technologies if used in treatment

system. • Can be applied as an interim treatment technology as inline residential filter. • Requires disposal of spent carbon material.

Membrane filtration Separates contaminants from water by passing it through semi-permeable barrier or membrane; membrane allows some constituents to pass while blocking others

• Effective on organic and inorganic compounds. • Requires implementation of removal and discharge technologies.

Air stripping Increases surface area of contaminated water to air to partition volatiles from groundwater

• Generally considered for VOCs. • Requires implementation of removal and discharge technologies.

Groundwater Direct Pathway Restriction

Whole-house filters Physical or chemical process whereby a filter, typically using activated carbon, is installed and treats all water entering the house. Installation usually requires a licensed plumber, and there is ongoing maintenance to replace the filters as necessary.

• Effective as an interim solution; installation time can be hours or days per location. • Requires replacement and disposal of spent filter units. • Does not address vapor intrusion issues.

Point-of-use filters Physical or chemical process whereby a filter, typically using activated carbon, is installed and treats water at a point of use. Such filters are typically installed on faucets or underneath sinks. There is ongoing maintenance to replace the filters as necessary. Can be difficult to use with showers / baths.

• Effective as an interim solution; installation time can be hours or days per location. • Requires replacement of spent filter units. • Does not address vapor intrusion issues.



Page 5 of 5


Alternate water supply – bottled water Bottled water is supplied for use. Does not address direct contact with bath water. Bottled water needs to be delivered on an ongoing basis. Can get to be very expensive compared to other alternatives.

• Typically used as part of the initial stages of an emergency response / time critical removal action, prior to the installation of a more permanent remedy (such as the other technologies listed in this section).

Alternate water supply – municipal water A connection is made to a municipal water supply. This typically requires a licensed contractor or plumber to perform the work.

• Effective both in the short term and long term. • Public water supplies are monitored on a continual basis. • Does not address vapor intrusion issues.

Notes:

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act DPE dual phase extraction EPA United States Environmental Protection Agency IDEM Indiana Department of Environmental Management ISCO in-situ chemical oxidation MNA monitored natural attenuation NAPL non-aqueous phase liquid NPDES National Pollutant Discharge Elimination System POTW publicly-owned treatment works SVE soil vapor extraction TPE two phase extraction VOC volatile organic compound

TABLE 2-5 GROUNDWATER REMEDIATION CANDIDATE TECHNOLOGIES SCREENING


Page 1 of 4

Technology Effectiveness Implementability Relative Cost Retaineda Reason for Elimination or Retainage

No Action

No action • Capable of handling any volume of groundwater.

• Not effective at reducing contamination. • Not effective with respect to risk reduction.

Easy to Implement Low Yes Inclusion is a CERCLA requirement.


Groundwater use restrictions

• Capable of handling volume of groundwater. • Not effective at reducing contamination. • Not entirely effective at reducing human

health risk when used alone.

Easy to Implement Low Yes May be effective in conjunction with other alternative technologies.

Property access restrictions • Capable of handling volume of groundwater. • Not effective at reducing contamination. • Not entirely effective at reducing human



Land use restrictions • Capable of handling volume of groundwater. • Not effective at reducing contamination. • Not entirely effective at reducing human




MNA • Capable of handling volume of groundwater. • Not effective at reducing contamination. • Not effective at reducing human health risk in

the short term when used alone.


Removal

Extraction wells • Capable of handling volume of groundwater. • Effective at containing plume migration. • Low effectiveness at reducing contamination. • Low effectiveness with respect to risk

reduction.

Easy to Implement Moderate Yes NA

TABLE 2-5 (Continued) GROUNDWATER REMEDIATION CANDIDATE TECHNOLOGIES SCREENING


Page 2 of 4


Interceptor trench • Not capable of handling volume of groundwater.


Difficult to Implement High No The effectiveness of a groundwater interceptor trench is questionable, given the high permeability of the aquifer. The construction of an interceptor trench would be challenging in a mixed-use area such as the Lane Street Site, and would be disruptive to the community. Removal of groundwater through an interceptor trench would require a significant amount of construction and a long treatment time frame and therefore is not suitable for use as a remedy.

DPE • Not capable of handling volume of groundwater.


Difficult to Implement High No DPE is most effective when used to address NAPL phase product; however, the groundwater contamination at the Lane Street Site consists of low dissolved concentrations of contaminants.

Discharge

Puterbaugh Creek • Capable of handling volume of groundwater. • Not effective at reducing contamination. • Not effective with respect to risk reduction.

Moderate to Implement Moderately High Yes Discharging groundwater to surface water requires the highest level of treatment prior to discharge and would be difficult to implement.

POTW • Likely capable of handling volume of groundwater

• Not effective at reducing contamination • Effective with respect to risk reduction

Moderate to Implement High No Discharge of groundwater to a POTW would require removal and treatment of the groundwater prior to discharge. Typically, POTWs have difficulty handling the additional volumes of treated water, which may stress local waste water infrastructure that is in place. Disposal costs, permitting and the long treatment and construction time frame of this combination of technologies makes discharge to a POTW not suitable as a remedy.

Reinjection or infiltration • Not likely capable of handling volume of groundwater.


Moderate to Implement

Moderate No Discharge of groundwater through reinjection or infiltration would require removal and treatment of the groundwater prior to discharge. A suitable location for the re-injection well field would have to be determined; currently there are no suitable areas identified.

Off-site disposal • Capable of handling volume of groundwater. • Not effective at reducing contamination. • Effective with respect to risk reduction.

Easy to Implement High No Off-site disposal of groundwater is prohibitively expensive because of collection and transportation costs; treatment of groundwater and discharge to the POTW or reinjection/infiltration are preferable for permanent remedies.

Containment



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Containment with a barrier wall

• Capable of handling volume of groundwater • Not effective at reducing contamination

unless implemented with removal and ex-situ treatment component

• Effective with respect to risk reduction

Difficult to Implement Moderate No Groundwater discharge into the watershed or sensitive receptors has not resulted in human health or ecological risks; hence containment of groundwater is not necessary.

Containment with a barrier wall and low-permeability cap

• Capable of handling volume of groundwater. • Not effective at reducing contamination

unless implemented with removal and ex-situ treatment component.

• Effective with respect to risk reduction.

Difficult to Implement High No Groundwater discharge into the surface watershed or sensitive receptors has not resulted in human health or ecological risks; hence, containment of groundwater is not necessary.

In-Situ Treatment

Bioremediation • Capable of handling volume of groundwater. • Effective at reducing contamination. • Likely effective at reducing human health

risk.

Easy to Implement Moderate Yes Pilot testing would be required. Bioremediation has been proven effective at other nearby sites such as the Geocel Corporation facility.

Reactive wall/funnel and gate

• Capable of handling volume of groundwater. • Effective at reducing contamination. • Effective at reducing human health risk.

Difficult to Implement High No Site configuration would require multiple installations to capture and treat plume. Given the existing land use, the configuration of a funnel and gate system would be very difficult. Other in-situ technologies can address contamination through easier implementation and lower costs.

ISCO • Capable of handling volume of groundwater. • Effective at reducing contamination. • Effective at reducing human health risk.

Easy to Implement Moderate No Treatment of groundwater using ISCO would require time for construction, implementation, and multiple rounds of injections to address human health risks. Typically, this is more effective on sites with high levels of contamination. Nearby sites have been effectively remediated with bioremediation, which poses less risk and lower costs.

Air sparging • Capable of handling volume of groundwater. • Effective at reducing contamination. • Effective at reducing human health risk.

Moderate to Implement Moderate No As far as the technology goes, air sparging is implementable. Logistically, implementing air sparging would be difficult due to the large area requiring treatment and the built-up, mixed-use nature of the Lane Street Site. Treatment of groundwater using air sparging would require time for construction, implementation, and operation to address human health risks. The long treatment time frame makes this technology not suitable for use as a remedy.

SVE • Capable of handling volume of groundwater. • Not effective at reducing contamination. • Effective at reducing human health risk.

Moderate to Implement Moderate No Highly effective for vadose zone contamination and significantly less effective for saturated zone and groundwater contamination; therefore, this technology is not retained.



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Ex-Situ Treatment

Bioreactors • Capable of handling volume of groundwater. • Effective at reducing contamination. • Effective at reducing human health risk.

Difficult to Implement High No Technology is more difficult to implement and likely more expensive than other ex-situ treatment technologies and therefore it is not retrained.

Activated carbon/adsorption • Capable of handling volume of groundwater. • Effective at reducing organic contamination. • Effective at reducing human health risk.

Easy to Implement Moderate Yes Activated carbon filtration may be used as a primary treatment or as a secondary treatment downstream from a primary treatment. This technology would be effective in combination with other ex-situ treatments.

Membrane filtration • Capable of handling volume of groundwater. • Effective at reducing contamination. • Effective at reducing human health risk.

Moderate to Implement High No Technology may be less effective for a large scale treatment system and requires substantial maintenance during operation; therefore, membrane filtration was not retained.

Air stripping • Capable of handling volume of groundwater. • Effective at reducing contamination. • Effective at reducing human health risk.

Easy to Implement High Yes Treatment of groundwater using air stripping would require time for construction, implementation, and operation to address human health risks. This technology is most effective when used in combination with other ex-situ treatments.

Notes:

a Technology may be used in conjunction with other technologies CERCLA Comprehensive Environmental Response, Compensation, and Liability Act DPE dual phase extraction ISCO in-situ chemical oxidation MNA monitored natural attenuation NA not applicable NAPL non-aqueous phase liquid POTW publicly-owned treatment works SVE soil vapor extraction

TABLE 5-1 COMPARATIVE ANALYSIS OF GROUNDWATER REMEDIAL ALTERNATIVES


Page 1 of 2

Evaluation Criteria

Remedial Alternatives Alternative 1

No Action Alternative 2

Monitored Natural Attenuation Alternative 3

Enhanced Bioremediation Alternative 4

Extraction and Ex-Situ Treatment System THRESHOLD CRITERIA1 Overall protection of human health and the environment

Not protective; no action would be taken ICs and MNA would be protective overall ICs and enhanced bioremediation would be protective overall

ICs with extraction and ex-situ treatment would be protective

Criterion Score Fail Pass Pass Pass Compliance with ARARs

Does not comply Meets applicable ARARs Meets applicable ARARs Meets applicable ARARs

Criterion Score Fail Pass Pass Pass

PRIMARY BALANCING CRITERIA2 Long-term effectiveness and permanence

Ineffective until natural attenuation has achieved RALs, but won’t know when that occurs

Somewhat Effective Highly Effective Highly Effective and Permanent

Site conditions would remain the same Unlikely that RAOs will be achieved in reasonable time

Permanent over the long term. Permanent over the long term, may have “rebound”

Criterion Score 1 3 5 4 Reduction of toxicity, mobility, or volume through treatment

Ineffective Somewhat Effective Highly Effective Highly Effective

No additional treatment, only unmonitored natural processes

May reduce the toxicity, mobility, or volume of the COCs through natural degradation, not

treatment

Will reduce the toxicity and volume of contaminated groundwater

Will reduce the toxicity, mobility, and volume of contaminated groundwater; treatment

Criterion Score 1 2 5 4 Short-term effectiveness

Not effective in short term in protecting receptors, no measures taken to reduce exposure

Slight impact during implementation Slight impact during implementation Significant impacts during implementation

No worker risks because no action would be taken Slight impact to community and site workers during monitoring wells installation

Slight impacts to community and site workers during injection wells installation and treatment

Significant impacts to community and site workers during treatment facility and piping construction

Criterion Score 3 4 4 2 Implementability Easy to implement Readily implementable Readily implementable Difficult to implementable Implementable because no action would be taken Getting access to build treatment system and discharge

permits Criterion Score 5 4 4 2

Cost (ranked relative to other alternatives)3, 4

Capital Cost: $0 Present-Value O&M Cost: $0

Total Cost: $0

Capital Cost: $294,000 Present-Value O&M Cost: $944,000 Present-Value 5YR Cost: $52,000

Total Cost: $1,290,000

Capital Cost: $2,500,000 Present-Value O&M Cost: $1,020,000

Present-Value 5YR Cost: $29,000 Total Cost: $3,550,000

Capital Cost: $4,600,000 Present-Value O&M Cost: $6,800,000

Present-Value 5YR Cost: $44,000 Total Cost: $11,400,000

Criterion Score 5 4 3 2 MODIFYING CRITERIA5 CERCLA Criteria - Alternative Total

Score

Not applicable1 17 20 14


60

Appendix A

Year Alternative 1 Alternative 4

YearAnnual O&M

Remedy Review Total

Annual O&M

Remedy Review Total

Annual O&M

Remedy Review Total

Annual O&M

Remedy Review Total

1 $0 $0 $137,000 $137,000 $134,000 $134,000 $681,000 $681,0002 $0 $0 $137,000 $137,000 $134,000 $134,000 $681,000 $681,0003 $0 $0 $137,000 $137,000 $234,000 $234,000 $681,000 $681,0004 $0 $0 $137,000 $137,000 $134,000 $134,000 $681,000 $681,0005 $0 $0 $0 $137,000 $24,000 $161,000 $134,000 $24,000 $158,000 $681,000 $24,000 $705,0006 $0 $0 $68,000 $68,000 $134,000 $134,000 $611,000 $611,0007 $0 $0 $68,000 $68,000 $134,000 $134,000 $611,000 $611,0008 $0 $0 $68,000 $68,000 $134,000 $134,000 $611,000 $611,0009 $0 $0 $68,000 $68,000 $134,000 $134,000 $611,000 $611,00010 $0 $0 $0 $68,000 $24,000 $92,000 $134,000 $24,000 $158,000 $611,000 $24,000 $635,00011 $0 $0 $34,000 $34,000 $0 $0 $611,000 $611,00012 $0 $0 $34,000 $34,000 $0 $0 $611,000 $611,00013 $0 $0 $34,000 $34,000 $0 $0 $611,000 $611,00014 $0 $0 $34,000 $34,000 $0 $0 $611,000 $611,00015 $0 $0 $0 $34,000 $24,000 $58,000 $0 $0 $611,000 $24,000 $635,00016 $0 $0 $34,000 $34,000 $0 $0 $611,000 $611,00017 $0 $0 $34,000 $34,000 $0 $0 $611,000 $611,00018 $0 $0 $34,000 $34,000 $0 $0 $611,000 $611,00019 $0 $0 $34,000 $34,000 $0 $0 $611,000 $611,00020 $0 $0 $0 $34,000 $24,000 $58,000 $0 $0 $611,000 $24,000 $635,00021 $0 $0 $34,000 $34,000 $0 $0 $0 $022 $0 $0 $34,000 $34,000 $0 $0 $0 $023 $0 $0 $34,000 $34,000 $0 $0 $0 $024 $0 $0 $34,000 $34,000 $0 $0 $0 $025 $0 $0 $0 $34,000 $24,000 $58,000 $0 $0 $0 $026 $0 $0 $34,000 $34,000 $0 $0 $0 $027 $0 $0 $34,000 $34,000 $0 $0 $0 $028 $0 $0 $34,000 $34,000 $0 $0 $0 $029 $0 $0 $34,000 $34,000 $0 $0 $0 $030 $0 $0 $0 $34,000 $24,000 $58,000 $0 $0 $0 $0 $0

Estimated 30 years to complete Estimated 10 years to complete Estimated 20 years to completeNet-Present Value Net-Present Value Net-Present Value Net-Present Value Annual O&M $0 Annual O&M $944,000 Annual O&M $1,020,000 Annual O&M $6,760,000 Remedy Reviews $0 Remedy Reviews $52,000 Remedy Reviews $29,000 Remedy Reviews $44,000 Capital Costs $0 Capital Costs $294,000 Capital Costs $2,500,000 Capital Costs $4,570,000

Total NPV = $0 Total NPV = $1,290,000 Total NPV = $3,550,000 Total NPV = $11,400,000Notes:A 7% Discount rate is used in accordance with Epa Guidance and OMB Circular A-94, for the beginning of the year.Final values are rounded to 3 significant figures.O&M operations and maintenanceNPV Net-present value

Alternative 2 Alternative 3Elkhart, Elkhart County, Indiana

Lane Street Ground Water Contamination SiteTABLE A-1: SUMMARY OF COSTS AND PRESENT-VALUE CALCULATONS FOR ALL ALTERNATIVES

Page 1 of 1

UNITITEM DESCRIPTION QTY UNIT PRICE COST SUBTOTAL

Mobilization/DemobilizationEquipment/personnel mobilization/demobilization 1 LS $7,750 $7,750Survey 0 $0 $0

$7,750

Site WorkSite clearing and grubbing 1 LS $5,000 $5,000

$0 $0$0 $0

$5,000

Monitoring Wells10 - 2" diameter wells 10 each $10,000 $100,000

$0 $0$0 $0

$100,000

OtherDeed restrictions, meetings, etc. 1 LS $50,000 $50,000

$0$0

$50,000$163,000

$3,260

$1,630

$167,890

$41,973$25,184

$235,000

$11,750$23,500$23,500

$293,750

USE $294,000

CONSTRUCTION SUBTOTAL

SCOPE CONTINGENCY (@ 25 Percent)

CONSTRUCTION MANAGEMENT AND INSPECTION (@ 10 percent)

ALTERNATIVE 2: MINIMAL ACTION WITH INSTITUTIONAL CONTROLS

Elkhart, Elkhart County, IndianaLane Street Ground Water Contamination Site

AND MONITORED NATURAL ATTENUATION

PROJECT MANAGEMENT (@ 5 percent)

BID CONTINGENCY (@ 15 Percent)SUBTOTAL

CAPITAL COST

SUBTOTAL

TOTAL CAPITAL COST FOR ALTERNATIVE 2

PERMITTING (@ 1 percent )

DESIGN (@ 10 percent)

BONDS AND INSURANCE (@ 2 percent)

Page 1 of 2

ITEM DESCRIPTION QTY UNITSUNIT

PRICE COST SUBTOTAL

Quarterly sampling 4 each 15,000.00$ 60,000.00$ Lab cost 4 each 10,000.00$ 40,000.00$ Consumables 4 each 2,000.00$ 8,000.00$ Sampling equipment 4 each 1,200.00$ 4,800.00$ Quarterly reports 4 each 6,000.00$ 24,000.00$

137,000$

Semiannual sampling 2 each 15,000.00$ 30,000.00$ Lab cost 2 each 10,000.00$ 20,000.00$ Consumables 2 each 2,000.00$ 4,000.00$ Sampling equipment 2 each 1,200.00$ 2,400.00$ Semiannual reports 2 each 6,000.00$ 12,000.00$

68,000$

Annual sampling 1 each 15,000.00$ 15,000.00$ Lab cost 1 each 10,000.00$ 10,000.00$ Consumables 1 each 2,000.00$ 2,000.00$ Sampling equipment 1 each 1,200.00$ 1,200.00$ Annual report 1 each 6,000.00$ 6,000.00$

34,000$

ALTERNATIVE 2: MINIMAL ACTION WITH INSTITUTIONAL CONTROLS

Monitoring years 1 through 5

SUBTOTAL GROUNDWATER MONITORING YEARS 1 - 5



Lane Street Ground Water Contamination SiteElkhart, Elkhart County, Indiana

ANNUAL O&M COSTAND MONITORED NATURAL ATTENUATION



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Mobilization/DemobilizationEquipment/personnel mobilization/demobilization 1 LS $66,000 $66,000Survey 1 LS $5,000 $5,000

$71,000

Site WorkSite clearing and grubbing 1 LS $5,000 $5,000Injection wells 12 each $15,000 $180,000Extraction well 12 each $15,000 $180,000Bio barrier system 2 each $120,000 $240,000Amendments 2 each $200,000 $400,000Oxygen injection wells 10 each $15,000 $150,000Oxygen injection 1 LS $60,000 $60,000

$1,215,000

Monitoring Wells10 - 2" diameter wells 10 each $10,000 $100,000

$0$100,000

$1,386,000

$27,720

$13,860

$1,427,580

$356,895

$214,137

$1,999,000

$99,950

$199,900

$199,900

$2,500,000

ALTERNATIVE 3: IN-SITU GROUNDWATER TREATMENT THROUGH BIOREMEDIATIONCAPITAL COST


SUBTOTAL



CONSTRUCTION MANAGEMENT AND INSPECTION (@ 10 percent)TOTAL CAPITAL COST FOR ALTERNATIVE 3


SCOPE CONTINGENCY (@ 25 Percent)BID CONTINGENCY (@ 15 Percent)

SUBTOTAL

PROJECT MANAGEMENT (@ 5 percent) DESIGN (@ 10 percent)

Page 1 of 2

ITEM DESCRIPTION QTY UNITS UNIT PRICE COST SUBTOTAL

Follow up application 1 LS 100,000.00$ $100,000.00$0.00$0.00$0.00$0.00

$100,000$100,000

Quarterly sampling 4 each 20,000.00$ $80,000.00Shipping cost 4 each 1,500.00$ $6,000.00Consumables 1 LS 3,000.00$ $3,000.00Sampling equipment 4 each 1,200.00$ $4,800.00Quarterly report 4 each 10,000.00$ $40,000.00

$0.00$133,800$134,000Use

O&M COSTALTERNATIVE 3: IN-SITU GROUNDWATER TREATMENT THROUGH BIOREMEDIATION

SUBTOTAL ANNUAL MONITORING COST

O&M Cost

SUBTOTAL OF ADDITIONAL TREATMENT

Monitoring CostONE TIME FOLLOW UP APPLICATION


Page 2 of 2


Mobilization/DemobilizationEquipment/personnel mobilization/demobilization 1 LS $120,658.75 $120,659Survey 1 LS $5,000 $5,000

$125,659

Site WorkSite clearing and grubbing 1 LS $5,000 $5,000Soil excavation and transportation 20 CY $30 $600Soil disposal 20 CY $100 $2,000Site restoration 1 LS $7,000 $7,000

$14,600

Extraction SystemDrilling 12" diameter extraction wells 1,000 ft $170 $170,00012" diameter extraction well ss casing 300 ft $300 $90,00012" diameter extraction well ss screen 700 ft $250 $175,0003" diameter ss risers 200 ft $53 $10,6003" diameter HDPE pipe 500 ft $40 $20,0004" diameter HDPE pipe 500 ft $50 $25,0006" diameter HDPE pipe 200 ft $60 $12,000

$502,600

Well VaultsExcavation for well vaults 100 CY $40 $4,000Disposal of excavated soil 100 CY $45 $4,500Concrete well vaults 10 each $8,500 $85,0005 well vaults for meters, valves, and controls 10 each $10,000 $100,000Well extraction pumps and drives 10 each $8,500 $85,000Level control system 10 each $2,200 $22,000Flow meters and transmitters 10 each $3,500 $35,000Piping and valves in each vault 10 each $3,500 $35,000Sump pump 10 each $1,200 $12,000Exhaust fan and duct work 10 each $2,000 $20,000Electric service 10 each $9,000 $90,000Electrical work inside vaults 10 each $5,000 $50,000Vault heaters 10 each $1,200 $12,000

$554,500

Monitoring Wells10 monitoring wells 10 each $10,000 $100,000

$0$100,000

Treatment SystemExcavation for treatment building 20 CY $40 $800Granular foundation material 15 CY $45 $675Concrete foundation for treatment building 15 CY $500 $7,500Treatment building 500 sf $75 $37,500Air-stripper two low profile each 250 gpm 2 each $145,000 $290,000GAC water with controls 2 each $50,000 $100,000GAC off gas with controls 2 each $40,000 $80,000Piping valves and controls 1 LS $50,000 $50,000

CAPITAL COST

ALTERNATIVE 4: EX-SITU GROUNDWATER TREATMENT BY


EXTRACTION, TREATMENT, AND DISCHARGE

Page 1 of 3


CAPITAL COST



EXTRACTION, TREATMENT, AND DISCHARGE

Electrical service including transformers and distribution 1 LS $20,000 $20,000Electrical installation in the building 1 LS $35,000 $35,000Building HVAC 1 LS $65,000 $65,000

$686,475

Effluent DischargeEffluent sampler 1 each $10,000 $10,00010" diameter HDPE pipeline 6,000 ft $90 $540,000

$550,000$2,534,000

$50,680

$25,340

$2,610,020

$652,505

$391,503

$3,654,000

$182,700

$365,400

$365,400

$4,570,000



SCOPE CONTINGENCY (@ 25 Percent)BID CONTINGENCY (@ 15 Percent)

SUBTOTAL

TOTAL CAPITAL COST FOR ALTERNATIVE 4

CONSTRUCTION MANAGEMENT AND INSPECTION (@ 10 percent)

PROJECT MANAGEMENT (@ 5 percent)

SUBTOTAL


DESIGN (@ 10 percent)

Page 2 of 3

ITEM DESCRIPTION QTY UNITS UNIT PRICE COST SUBTOTAL

Operator labor 12 month 20,000.00$ 240,000.00$ Maintenance labor 1,000 hrs 120.00$ 120,000.00$ Air stripper maintenance 2 each 1,500.00$ 3,000.00$ Air filter 2 each 400.00$ 800.00$ Electric power 1,000,000 kwh 0.10$ 100,000.00$ NPDES Sampling 12 each 1,500.00$ 18,000.00$ Monthly NPDES report 12 each 5,000.00$ 60,000.00$

-$ 542,000$

Quarterly sampling 4 quarter 20,000.00$ 80,000.00$ Shipping cost 4 quarter 1,500.00$ 6,000.00$ Consumables 4 each 2,000.00$ 8,000.00$ Sampling equipment 4 each 1,200.00$ 4,800.00$ Quarterly report 4 each 10,000.00$ 40,000.00$

-$ 139,000$

Semiannual sampling 2 semiannual 20,000.00$ 40,000.00$ Shipping cost 2 semiannual 1,500.00$ 3,000.00$ Consumables 2 LS 2,000.00$ 4,000.00$ Sampling equipment 2 each 1,200.00$ 2,400.00$ Semiannual report 2 each 10,000.00$ 20,000.00$

-$ 69,000$


O&M Cost for Groundwater Treatment

SUBTOTAL ANNUAL GROUNDWATER TREATMENT O&M


SUBTOTAL ANNUAL MONITORING COST YEARS 1 - 5


O&M COSTEXTRACTION, TREATMENT, AND DISCHARGE


SUBTOTAL ANNUAL MONITORING COST YEARS 6 - 20

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