Infrastructure, environment, buildings Mr . Kevin Lynch United States Environmental Protection Agency, Region 2 290 Broadway, 20 111 Floor New York, New York 10007-1866 Subject: Responses to USEPA's June 21, 2010 Comment Letter to the Feasibility Study Work Plan AVX Corporation Olean, New York Dear Mr . Lynch: On behalf of AVX Corporation {AVX). ARCADIS has prepared this letter in response to the United States Environmental Protection Agency's (USEPA's) June 21. 2010 comment letter {received June 28, 2010) regarding the Feasibility Study Work Plan (FS Work Plan) for the AVX site located at 1695 Seneca Avenue in Olean, New Yori< {site). The USEPA's June 21, 2010 letter addresses the FS Work Plan through additional correspondences, including: • ARCADIS' March 16, 2010 Responses to USEPA's March 1, 2010 Comment Letter to the FS Work Plan • USEPA's March 1, 2010 Comments to the December 2009 FS Work Plan Each of the USEPA's comments in the June 21 . 2010 letter is provided below in italics, followed by AVX's response. We will submit a revised FS Wor1< Plan incorporating the changes within 2 weeks of reaching consensus with the USEPA on the changes to be made to the FS Work Pla n. Specific Comment 1: Response to EPA Comment 10: It is certainly premature to state or infer that A VX- derived chemical constituents are not contributing to the groundwater contamination to the south of the railroad tracks. Comments supporting this assumption should be stricken from the te)(t. Response to Speciflc Comment 1: The USEPA has agreed that it w ill approve an FS Work Plan containi ng ARCADIS' professional opinions that were expressed both in the December 2009 FS Wor1< Plan Imagine the result 1901011351 avx olean rte r. WOil< PIM 011910 ... ARCAOIS U.S •• Inc. One Adams Place 310 Seven Fields Blvd Suite 210 Seven Fields Pennsylv•nia 16046 Tel 724.7 42. 9180 Fax 724.742.9189 www.arcadll-us.com Diile: July 19, 2010 Con!ac:t: Mark B. Hanish Phone: 724.742.9180, ext. 518 Email: mark.hanish@arcadis-us. com 0..ret : 8 0007385.0000 297733 11111\ 11111111m 1 111111111111 1111111111
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~ARCADIS Infrastructure, environment, buildings
Mr. Kevin Lynch United States Environmental Protection Agency, Region 2 290 Broadway, 20111 Floor New York, New York 10007-1866
Subject:
Responses to USEPA's June 21, 2010 Comment Letter to the Feasibility Study Work Plan AVX Corporation Olean, New York
Dear Mr. Lynch:
On behalf of AVX Corporation {AVX). ARCADIS has prepared this letter in response to the United States Environmental Protection Agency's (USEPA's) June 21. 2010
comment letter {received June 28, 2010) regarding the Feasibility Study Work Plan (FS Work Plan) for the AVX site located at 1695 Seneca Avenue in Olean, New Yori< {site). The USEPA's June 21, 2010 letter addresses the FS Work Plan through
additional correspondences, including:
• ARCADIS' March 16, 2010 Responses to USEPA's March 1, 2010 Comment
Letter to the FS Work Plan
• USEPA's March 1, 2010 Comments to the December 2009 FS Work Plan
Each of the USEPA's comments in the June 21 . 2010 letter is provided below in
italics, followed by AVX's response. We will submit a revised FS Wor1< Plan
incorporating the changes within 2 weeks of reaching consensus with the USEPA on
the changes to be made to the FS Work Plan.
Specific Comment 1:
Response to EPA Comment 10: It is certainly premature to state or infer that A VXderived chemical constituents are not contributing to the groundwater contamination to the south of the railroad tracks. Comments supporting this assumption should be stricken from the te)(t.
Response to Speciflc Comment 1:
The USEPA has agreed that it will approve an FS Work Plan containing ARCADIS'
professional opinions that were expressed both in the December 2009 FS Wor1< Plan
Imagine the result 1901011351 avx olean rte r. WOil< PIM 011910 ...
and in the March 16, 2010 Response to USEPA's March 1, 2010 Comment 10 to the FS Work Plan. The USEPA may Include, in their approval letter of the FS Work Plan. statements which preserve its disagreement with these opinions.
Specfflc Comment 2:
Besponse to EPA Comment 11: As long as ARCADIS is not implying that A VXderived constituents have not migrated into the City Aquifer south of A VX-190, the response appears satis;actory.
Response to Specific Comment 2:
Please refer to Response to Specific Comment 1
Specific Comment 3:
Response to fEPAl Comments 13and14: A satisfactory response has been provided on the need for further field characterization studies to aid in the alternatives development and evaluation process. However, no sufficient justification tias been provided for the delay in submitting designated subsoil sample locations inside the A VX building. This infonnation should provide immediately.
Response to Specific Comment 3:
The approximate preliminary sampling locations are depicted on the attached figure. Final locations of the borings will be determined in the field and will be dependent on such things as the location of subsurface utilities and other access restrictions that will be identified just before initiation of the work.
Specific Comment 4:
Response to fEPAl Comment 16: EPA concurs that a step test would be beneficial. The initial pumping rate should be set at 50 gpm, because the historical data shows that was an average now rate for a significant period of time. To help evaluate the connection of the upper hydrogeologic units to the lower aquifer, wells A VX-6S and AVX-7S should be retained in the monitoring plan. Water levels should also be collected at CW-9, manually if needed (CW-9A and CW-10A are already scheduled for a pressure transducer). Which methods of data analysis are most appropriate for these hydro/0gic units and site conditions and are planned to be used here? Revised details of the pumping test plan should be submitted.
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Response to Specific Comment 4:
AVX appreciates that the USEPA agrees a step test would be beneficial in evaluating the area of capture influence of pumping well PW-1 and to identify a future pumping rate, which will maintain optimum capture for a potential groundwater extraction final remedial alternative. Establishing this rate will be important as the relative feasibility
of groundwater extraction as a possible final remedial measure is evaluated during the FS process. To meet this objective. it is not necessary to evaluate capture at a
pumping rate of 50 gallons oer minute (gpm) because there· is already adea\Jate
information to evaluate potential capture at a flow rate of 50 gpm. Therefore, the FS Won< Plan cans for starting at a low end flow rate of 150 gpm but will include evaluation of historical data for capture at 50 gpm.
The method of analysis will Include preparation of potentlometric surface maps, drawdown maps, and time-drawdown hydrographs. The test will also generate a
dataset of water-level data that will also be available for model development and calibration, in the event a groundwater model is needed for future remedial alternative analysis/design. Because hydraulic parameters have been well
established for the City Aquifer through previous hydraulic testing (e.g., Pump Test Report [Blasland, Bouck & Lee. Inc., May 2002]), no further hydraulic parameter estimation is planned at this time. Nonetheless, if needed and appropriate, the test data will be evaluated using t~e Theis solution for pumping tests in a confined aquifer
(i.e., the solution applied for the 2002 pumping test). Based on review of the data, alternate solutions, such as the Hantush-Jacob solution for a pumping test in leaky
confined aquifer, may be considered.
Specific Comment 5:
Resoonse to CEPAl Comment 17: Water-level recorders should collect data for at least five days after pump shutdown to confirm the drawdown from the existing regional water level conditions.
Response to Specific Comment 6:
As requested, we will include monitoring wells AVX-65, AVX-75, and CW-9 in the
monitoring well network for the test.
The objective of the recovery test is to develop potentiometric surface maps,
drawdown maps, and time-drawdown hydrographs, which will be used as additional ·
Unes of evidence for establishing th.e area of capture influence of the pumping well under stressed conditions at multiple flow rates. Recovery data is not needed to
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meet this objective. Recovery data is imoortant for tests desi11ned to estimate aquifer hydraulic conductivity and storage, both of which have been wen estaoushed through testing at the site and in the Olean well field site, and not as important for our current assessment. In response to tt)is request, we will monitor water levels in the monitoring well network for a 24-hour post-pumping recovery period and include the recovery data in the FS Report.
Although we believe.that the additional wells that the USEPA has asked be included in the step test mo11itoring plan are unnecessary to meet the objectives of the step test, we will nonetheless also include monitoring wells AVX-6S, AVX-7$, and CW-9 in the monitoring well network for the test.
Specific Comment 6:
Response to fEPAl Comment 22: A) The test as desiqned using a tracer sol11tinn Rt one location in the source area should. yield specifte lnfon:m1tinn about hydraulics at that location. However, if the pilot test were doNfl!lith one of the chemical reagents being considered for the remedy, it could provide additional information to evaluate both the hydraulic injectability and the possible effectiveness of the chemical. B) As previously requested, one or more additional injection loc~tions .~hn11/rl bB considered for testing because the upper units are variable hydraulically. The hydraulic results of the injection tests are also going to be used to evaluate the enhanced reductive dechlorination alternative. C) What is the expected volume of iiljectant that is expected to be used for the test at the source area? What volume of soil material is expected to be treated?
Response to Specific Comment 6:
Part A
• Success.ful implementation of any injection-based remedial technology, including enhanced reductive dechlorination or in-situ chemical oxidation (ISCO), depends upon being able to obtain adequate distribution of the injectate to areas targeted for remediation. At the AVX site, there is a lack of information on whether fluids injected within the target remedial area will be distributed sufficiently to allow injection-based remedial methods to be deemed feasible. This is the data gap that the tracer study is in'tended to fill.
• Chlorinate.d ethane daughter products (cis-dichloroethene, vinyl chloride) and chlorinated ethane daughter products (dichloroethane, chloroethane) are documented to be present at monitoring well AVX-115, confirming that
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enhanced reductive dechlorination is an appropriate technology to be considered in the FS from a chemical reaction perspective. The chemistry of the lnjectate will be evaluated in the FS based upon ample evidence available from many other sites and from documented cases in the literature that confirm that the constituents of interest can be treated via ISCO under conditions similar to those found at the AVX site. Thus, from an FS standpoint, use of either type of chemical to enhance the rate of degradation is already judged to be feasible at the site.
The FS Work Plan includes a tracer test to evaluate whether an injection of an amended fluid can properly distribute injectate chemicals to the targeted media for successful contact and destruction of the constituents of concern. If the tracer demonstrates that an adequate distribution C{;ln be achieved, there is sufficient sitespecific data and information from other sites to allow a preferred injectate to be identified in the FS Report without addiTional fieldwerk.
Part B
USEPA's Comment 22 in its March 1, 2010 letter appears to be different than the follow-up Comment 6 provided in Its June 21, 2010 letter. In USEPA's March 1, 2010 letter, it requested that the test be moved outside the center of the targeted area. In USEPA's June 21 , 2010 letter, it now requests one or more additional injection locations.
The objective at the ~r test is soecificallv to assess whether injections r.;1n be
suc~ssfully performed within an area with higher chlorinated vofatile organic compound concentrations. We recognize that there wiffbe some hydraulic variaDility in the area of injection, and for this reason, decided the tracer test area should be performed in the area tnat may be, through the FS process, targeted for future remedial actions. By performing the tracer test at the location proposed, the locationspecific information necessary for the FS-level design will be obtained. If we determine from that test that we can successfully inject and obtain a reasonable distribution of the injectate, the FS Report will conclude that injection-based technologies are potential viable atternatives. If we cannot successfully inject, the FS Report will screen out injection-based technologies. Any variations we may see in injections can be addressed during remedial design using an adaptive approach. A more detailed assessment of the level of variability is not needed for FS-level design pufJ>Oses.
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There is no reason to perform additional injections to assess the level of variabHity for the purposes of an FS-level design. Therefore, it is recommended that the tracer test be performed as described in the December 2009 FS Work Plan.
PartC
In Appendix B. (Injection Test Work Plan) of the FS Work Plan, Section 3.1 ,2 entitled Estima~ed Injection Volume, states "Based on the equation below, the estimated volume is approximately 5,300 gallons."
Please note that no soil will be treated during this test. Thus, no soil to be treated ·is zero. The tr;:lf'.P.r !'lt11r1v I~ a h¥,dra11lic +.est 'lQ14 ramecijaJ alteam!iYe pilot test. The volume of soil material expected to be affected by the injected fluid is 340 cubic yards (based on a radius of influence of 15 feet screened interval of 20 feet, and total porosity of 0.35 [65 percent solids]).
Specific Comment 7:
Response to fEPAJ Comment 23: How far is well PW-1 projected to the crosssection? How far would well 18-M need to be projected?
Response to Specific Comment 7:
Based on the scale included on Figure 1 of the December 2009 FS Work Plan, pumping well PW-1 is offset approximately 670 feet and City Well 18M is offset approximately t ,020 feet from the line of cross-section A-A' on Figure 1.
Specmc Comment 8:
EPA Region 2 is conducting a multi-year initiative to inventory wells at all Superfund sites. This program is designed to evaluate the field status of all the wells at Superfund sites and to confirm our historical information about the wells. The most convenient approach is to fill out the Field Checklists during a planned field mobilization. A spreadsheet with the checklist is attached for your use.
Response to Specific Comment 8:
The spreadsheet and Field Checklists will be completed in accordance with the USEPA's request.
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Please contact me at 724.742.9180, ext. 518 if you have any questions or comments
about information presented herein. We will submit a revised FS Work Plan incorporating the changes within approximately 2 weeks of reaching consensus with
the USEPA on the changes to be made to the FS Work Plan.
Mr. Michael Walters, United States Environmental Prot~ction Agency Mr. Michael Scorca, United States Environmental Protection Agency Mr. Vivek Nattanmai. P.E.. New York State Department of Environmental Protection Mr. Eric Wohlers. Cattaraugus County Health Department Mr. Thomas H. Windus. P.E. Olean Department of Public Works Ms. Libby Ford, QEP, Nixon Peabody, LLP Ms. Jean McCrea,.Y. Nixon Peabody, LLP Mr. Larry Blue. CHMM. AVX Corporation Mr. William B. Popham. ARCADIS
