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II

III

FEASIBILITY STUDYSHOFE'S LANDFILL

GIRARD TOWNSHIP, PENNSYLVANIA

VOLUME I

Prepared for

Lord Corporation2000 W. Grandview BoulevardErie, Pennsylvania 16512

Prepared by

_ ECKENFELDER INC,I Nashville, Tennessee• and

Mihwah, New Jersey

6476

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July 1989 ARSONSRevised January 1990 ' '

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January 16, 1990

Mr. Eugene A, KillerLord Corporation2000 West Grandview BoulevardErie, Pennsylvania 16512

RE! Revised Lord/Shope Feasibility Study Report

Dear Mr, Killer;

We are pleased to present Volume I of the revised Feasibility Study (FS)I Report for the Lord/Shope site located in Glrard Township, Pennsylvania. The

FS report wag originally submitted in July 1989 In accordance with theapproved Work Plan. The Phase II Remedial Investigation (RI) Report has beenrevised to address the comments received in a letter from PennsylvaniaDepartment of Environmental Resources (PADER) dated December 6, 1989. Minorrevisions have been made throughout the FS report to provide consistency withthe final RI report, The appendices contained in Volume II have not beentransmitted as they were not revised,

If you have any questions regarding this or any other matter, please do nothesitate to contact me. We have enjoyed working with Lord Corporation on thisassignment.

Sincerely,

£fKE)«FEt»Eil INC, (formerly AWARE Incorporated)

nich, P.E.

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TABLE OF CONTENTS

Section No. IlilS E - '

LETTER OF TRANSM1TTAL

REPORT ORGANIZATION.Table of Contents »

List of Tables viList of Figures ix

EXECUTIVE SUMMARY ES-1

1,0 INTRODUCTION '"'

Site Background Information, 1 Site Location,2 Site Layout,3 Site History and Waste Components4 Land Use,5 Climate and Meteorology6 Surface Water Hydrology -14,6,1 Elk Creek Tributaries -146,2 Site Drainage -147 Geologic Conditions -168 Groundwater Conditions -188,1 Water Table Zone -198,2 Intermediate Zone -208.3 Deep Confined Zone -21

,2 Nature and Extent of Contamination -22.2.1 Soil Contamination 1-23.2.1.1 Shallow Soil Contamination 1-23,2,1.2 Deep Soil Contamination 1-25.2.2 Groundwater Contamination 1-27.2.2,1 Water Table Aquifer 1-28.2.2,2 Intermediate Zone 1-31,2,2.3 Deep Zone 1-36.2.2,4 Summary of Groundwater Quality 1-36.2.3 Other Environmental Media 1-37

2.0 REMEDIAL OBJECTIVES 2-1

2.1 Protection of Public Health andEnvironment 2-1

2.1.1 Contaminant Source and PotentialMigration Pathways 2-2

2.1.1,1 Air Pathway 2-22.1.1.2 Soil Pathway 2-22,1.1,3 Surface Water/Sediment Pathway 2-32.1.1,4 Groundwater Pathway 2-5

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TABLE OF CONTENTS (Cont'd)

Section No. Title

2.1,2 Summary 2-52,2 State/Federal Applicable or Relevant

and Appropriate Requirements (ARARs) 2-62.2.1 Existing Landfill Cap 2-72.2,2 Groundwater Cleanup 2-82,2.3 Groundwater Recovery or Recharge Wells 2-102.2.4 Groundwater Treatment and Discharge to

Surface Water 2-102.2,4.1 NPDES Program 2-102.2.4.2 Pennsylvania Water Quality Standards 2-102.2,4.3 DER Toxics Management Strategy 2-112.2.4.4 Discharge to POTWs 2-142.2,4.5 Air Emissions 2-142,2,4.6 Discharges to Commercial Treatment

Facilities 2-172.2,5 On/Off Site Treatment/Disposal 2-172.2,6 Floodplain Considerations 2-172,3 Cleanup Standards 2-192,3,1 Air Emissions Standards 2-192.3,2 Groundwater Cleanup Standards 2-192.3,3 Surface Water Discharge Standards 2-19

3.0 IDENTIFICATION AND SCREENING OFREMEDIAL ACTION TECHNOLOGIES 3-1

3.1 Identification of General ResponseActions 3-2

3.2 Screening of Remedial Action Technologies 3-43.3 Source Control Technologies 3-123.3.1 No (Further) Action 3-123,3,2 Limited Action 3-133.3.3 Near Source Groundwater Collection

and Treatment 3-143,3,3,1 Vellpoints 3-173,3.3.2 Extraction Wells 3-203.3,3,3 Vertical Trench Drain 3-223,3,4 Upgradient Cut-Off Wall Extension 3-243,3.5 In Situ Biological Degradation 3-263,3,6 In Situ Vapor Stripping 3-293.3.7 Excavation 3-313,3.8 Incineration 3-323.3,9 Landfill Disposal 3-343,3,10 Summary of Source Control Technologies 3-373,4 Migration Control Technologies 3-393.4.1 Groundwater Collection 3-393.4.1.1 Wellpoints 3-393.4,1.2 Extraction Wells3.4,1.3 Trench Drains AR30Q88

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. TABLE OF CONTENTS (Cont'd)

Section No. Title Page No.

I 3,4,2 Groundwater Treatment 3-4)3,4,2,1 Pretreatment with Granular Media

I Filtration 3-453.4.2,2 Air Stripping 3-473.4,2.3 Granular Activated Carbon 3-493.4.2.4 Biological Powdered Activated Carbon

I Treatment (PACT) 3-55• 3,4,2.5 Ultraviolet - Ozone Oxidation 3-58

3.4.2,6 Summary of On Site TreatmentI Technologies 3-60

3.4.2.7 Local POTW 3-633,4.2.8 Commercial Treatment 3-64

I 3.4,2.9 Summary of Off Site TreatmentI Options 3-65' 3,4,3 In Situ Biological Degradation 3-66

3,4,4 Treated Groundwater Discharge 3-67I 3,4,4.1 Discharge to Tributary of Elk Creek 3-67| 3.4.4,2 Discharge to Elk Creek 3-69

3.4,4,3 Discharge to Crooked Creek 3-691 3 . 4 . 4 , 4 Comparison of Remaining Discharge

Options 3-693,5 Results of the Three-Dimensional Ground-

water Flow Model 3-693,6 Treatability Study for In Situ Vapor

Stripping 3-703,7 Groundwater Treatability 3-71

I 3,8 Technologies to be Carried Forward toAssembly of Alternatives 3-75

4,0 ASSEMBLY OF REMEDIAL ALTERNATIVES 4-1

4,1 Introduction 4-14,2 Source Control Technologies 4-14,3 Migration Control Technologies 4-24,4 Assembled Remedial Action Alternatives 4-24,4.1 Remedial Action Alternative No. 1 4-34,4,2 Remedial Action Alternative No. 2 4-34.4,3 Remedial Action Alternative No. 3 4-34.4,4 Remedial Action Alternative Nos, 4A

and 4B 4-3

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TABLE OF CONTENTS (Cont'd)

Section No. Title Page No.

5.0 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES 5-1

5,1 Introduction 5-15,2 Description of Remedial Action

Alternatives 5-35,2,1 Alternative No, l--No (Further) Action 5-35,2,2 Alternative No, 2--Source Control and

Migration Control by GroundwaterExtraction, Groundwater Treatment, andDischarge to Surface Water 5-3

5.2,2.1 Access Control 5-35,2,2.2 Groundwater Extraction 5-45,2,2,3 Groundwater Treatment 5-95,2.2.4 Discharge to Unnamed Tributary of

Elk Creek 5-205.2.2.5 Groundwater Cleanup Plan 5-205,2,2,6 Air Emissions from Stripping Column 5-265,2,3 Alternative No, 3--Source Control by In

Situ Vapor Stripping; Source Control andMigration Control by GroundwaterExtraction, Groundwater Treatment, andDischarge to Surface Water 5-29

5,2,4 Alternative No, 4A--Source Control byExcavation and On Site Incineration;Source Control and Migration Control byGroundwater Extraction, GroundwaterTreatment, and Discharge to SurfaceWater 5-37

5.2.4,1 Excavation 5-375,2,4,2 On Site Incineration 5-395,2,5 Alternative No, 4B--Source Control by

Excavation and Off Site Incineration;Source Control and Migration Control byGroundwater Extraction, GroundwaterTreatment, and Discharge to SurfaceWater 5-40

5.3 Individual Assessment of Remedial ActionAlternatives 5-42

5.4 Comparative Analysis of Remedial ActionAlternatives 5-42

5,4,1 Overall Protection of Human Health andEnvironment 5-44

5,4.2 Compliance with ARARs 5-445.4.3 Long-Term Effectiveness and Permanence 5-445.4.4 Reduction of Toxicity, Mobility, or Volume

through Treatment 5-455.4.5 Short-Term Effectiveness 5-475.4,6 Implementability AR30 PwO5.4,7 Costs " 5 - 5 0

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ITABLE OF CONTENTS (Cont'd)

I Section No. Title P»fi« 1q.

| 5,A,8 Anticipated State Acceptance 5-525,4,9 Anticipated Community Acceptance 5-52

. 5,4,10 Comparative Analysis Summary 5-52

Appendices Title

A Description of Three-Dimensional GroundwaterFlow Model

B Treatability Study for In Situ VaporStripping at the Lord CorporationShope's Landfill, Cirard Township, Pennsylvania

C Bench-Scale Treatability Study ofSimulated Groundwater at the Shope'sLandfill Site

D Documentation of ARARs

I E Estimated Time Frame f o r CroundwaterRestoration

0

Air Dispersion Model for Stripper Emissions

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LIST OF TABLES

Title

Lord/Shope Landfill Chronology

Climatological Data Summary, Erie,Pennsylvania 1-13

1-3 Summary of Volatile Organic Concentrationsin Groundwater 1-38

1-4 Summary of Metals Concentrations inGroundwater 1-46

2-1 Federal and Commonwealth Drinking WaterStandards and Advisories which arePotential ARARs for the Shope's Site 2-9

2-2 Pennsylvania Water Quality Standards forElk Creek and its Unnamed Tributariesand Crooked Creek 2-12

2-3 Pennsylvania Water Quality Criteria forPriority Pollutants 2-15

2-4 Pennsylvania Water Quality Criteria forNon-Priority Pollutants 2-16

I 2-5 Summary of Drinking Water and SurfaceWater Standards, Criteria, andAdvisories 2-20

3-1 Identification of General ResponseActions for the Lord/Shope Site 3-3

3-2 Site and Waste CharacteristicsAffecting Remedial TechnologySelection 3-6

3-3 Remedial Technology Pre-ScreeningLord/Shope Site 3-7

3-4 Summary of Organic ContaminantCharacteristics Relating toSuitability of In Situ Biodegradationand Vapor Stripping 3-28

3-5 Anticipated Characteristics of RecoveredGroundwater Lord/Shope Landfill flR30|l|'52

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LIST OF TABLES (Cont'd)

Table No, Title

3-6 Physical Properties of Organic Compounds 3-44

3-7 Granular Media Filtration ProcessDefinition 3-48

3-8 Air Stripping Process Definition 3-51

3-9 Granular Activated Carbon ProcessDefinition 3-54

3-10 Biological PACT* Process Definition 3-57

3-11 Ultraviolet-Ozone Process Definition 3-61

3-12 Comparison of On Site GroundwaterTreatment Technologies 3-62

3-13 Identification of Treated CroundwaterDischarge Options 3-66

3-14 Characteristics of Recovered GroundwaterBased Upon Phase II RI 3-74

3-15 Determination of Allowable GroundwaterDischarge Concentrations 3-76

3-16 Summary of Remedial Technologies CarriedForward 3-77

5-1 Preliminary Process Design Criteria forGroundwater Treatment Facilities 5-15

5-2 Projected Average Effluent Characteristicsfor Treated Groundwater 5-19

5-3 Rationale for Selection or Exclusion asCleanup Parameters and Bases for

• Cleanup Levels 5-21

5-4 Croundwater Cleanup Levels 5-24

5-5 Estimated Emission Rates from Air Stripper 5-28

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LIST OF TABLES (Cont'd)0 Table No. Title

O

5-6 Total Volatile Organics Stripping Rate'with ISVS Unit at Corresponding FlowRate and Vacuum 5-35

5-7 Compatibility of Remedial Alternativeswith Evaluation Criteria 5-43

5-8 Cost Analysis Summary 5-53

5-9 Assessment of Remedial Action AlternativesAgainst Evaluation Criteria 5-54

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LIST OF FIGURES

Figure No. Title Page Ho.

1-1 Location Map ' 1-5

1-2 Base of Landfill Contour Map 1-6

1-3 Land Use Map 1-11

1-4 Zoning Map 1-12

1-5 Surface Hydrology 1-15

1-6 Regional Surficial Geologi" Map 1-17

1-7 Soil TVO Isocons - Surficial Soil 1-24

1-8 Volatile Organic Isocons - Croundwater-Water Table Zone 1-30

1-9 Volatile Organic Isocons - Groundwater-Intermediate Zone 1-32

2-1 Floodplain Map 2-18

3-1 Preliminary Screening and Selection ofCandidate Remedial Technologies 3-5

1 3 - 2 Lowering the Water Table to EliminateContact with a Disposal Site 3-15

3-3 .Schematics of a Typical Wellpoint System 3-18

3-4 Site Map Showing Location of ExistingCut-Off Wall and Proposed Wall Extension 3-25

3-5 Granular Media Filtration ProcessFlow Diagram 3-46

3-6 Air Stripping Process Flow Diagram 3-50

3-7 Granular Activated Carbon Adsorption 3-53

3-8 PACT* Procen Flow Diagram 3-56

3-9 Ultraviolet-Ozone Process Flow Diagram 3-59

4-1 Assembly of Remedial ActionAlternatives

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LIST OF FIGURES (Cont'd)

Figure No, , Titjs Page No.

5-1 Plan View of the Preliminary Locationsfor the Groundwater Extraction Systems 5-5

5-2 Schematic of Wellpoint System PlacedI Below Ground Surface 5-7

5-3 Cross-Section of Croundwater ExtractionSystems 5-8

5-4 Process Flow Diagram for ProposedGroundwater Treatment Facilities 5-11

5-5 Extraction Probe Location Map 5-31

5-6 Predicted VOC Residuals in Zone ofInfluence versus Time for Remediationof Crested Soil Southeast of Landfillbased upon Field and LaboratorySimulation Data 5-32

5-7 Predicted VOC Residuals in Zone ofInfluence versus Time for Remediationof Soil in Landfill Toe Area BasedUpon Field and Laboratory SimulationData 5-33

5-8 Limits of Excavation - Remedial ActionAlternatives 4A and 4B 5-38

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EXECUTIVE SUMMARY _.

(JThe purpoae of this Feasibility Study (FS) is to analyze appropriatetechnologies to be employed in the remediation of the Shope's Landfill and theenvironmental media in the near vicinity of the landfill,

The FS for the Shope's site consisted of three study phases which were neededto provide for the appropriate selection of the most effective remedialalternative;

• Phase I, identification of candidate remedial technologies• Phase II, screening of technologies• Phase III, assembly and detailed analysis of alternatives

The work plan for this FS was approved by PADER in December 1987. Thefeasibility study is based primarily upon the results of the RemedialInvestigation (RI), which was completed in two phases. The RemedialInvestigation report has been submitted to PADER and USEPA prior to thedevelopment and submittal of this Feasibility Study, (vjj

In support of the Remedial Investigation and Feasibility Study, a number ofother scientific investigations have been conducted, These include thefollowing:

• a biological investigation

• an initial and a revised baseline public health evaluation

• the development and use of a three-dimensional groundwater flowmodel for the site

• a preliminary in situ vapor stripping treatability Investigation

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fT*} • a preliminary groundwater treatability invsstigatlon

• an Investigation into the specific laws, regulations, and otherapplicable or relevant and appropriate requirements (ARARs) requiredby CERCLA

All of these investigations and studies are appended to the feasibility studyor have been separately submitted to PADER and the USEPA.

, The evaluation procedures employed have resulted in the selection of aremedial alternative which will provide source control by in situ vapor

, stripping of the landfill itself and the soils immediately surrounding thelandfill; and source and migration control by groundwater extraction andtreatment, The source control features of this remedial alternative preventthe release of landfill constituents into the soils and groundwaterdowngradient of the landfill, Additionally, the groundwater plume associstedwith the landfill is captured by groundwater extraction techniques and

/->. transported to a groundwater treatment, system, This groundwater treatment|~~- system will provide iron removal, air stripping of the groundwater for removal

of volatile organic chemicals, and discharge of the treated groundwater to aI tributary of Elk Creek,

This remedial alternative is recommended because it meets all of theevaluation criteria required by the USEPA and the NCP and was found to be themost protective of human health and the environment and the mostcost-effective,

All conclusions reached in this FS are the result of compliance with theevaluation criteria specified in the NCP and by USEFA guidance documents, theuse of technologies currently available for the development of remedialalternatives, the need to produce a technically and cost-effective selectionfor remediation, and the interest of protecting human health and the

• environment,

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1.0 INTRODUCTION

This report presents the results of the Feasibility Study (FS) conducted forthe Shope's Landfill site in Girard Township, Pennsylvania, This site wasformerly owned and operated by Melvln Shope, who disposed of industrial wastesgenerated by two Lord Corporation plants, located at 12th Street in Erie,Pennsylvania and in Saegertown, Pennsylvania. Lord Corporation has acquiredthe property and is now responsible for all aspects of the site, includingenvironmental remediation. The landfill was placed on the National PrioritiesList (NPL) in September 1983 under provisions of the Comprehensive Environ-mental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended,The U,S, Environmental Protection Agency (USEPA) has enacted regulationspursuant to CERCLA requiring that a Remedial Investigation/FeasibilityStudy (Rl/FS) be conducted at certain NPL sites (see 40 CFR 300).

The FS for the Shope's site consisted of three study phases to provide for theselection of the appropriate remedy: Phase I, Development of Alternatives;Phase II, Initial Screening; and Phase III, Detailed Analysis of Alternatives,The work plan for the FS was approved by the Pennsylvania Department ofEnvironmental Resources (DER) in December 1987,

Remedial Investigation

The Shope's Landfill Phase 1 RI was conducted between 1986 and mid-1987 andsubmitted to the USEPA and the Pennsylvania DER in August 1987. The RI wasconducted on behalf of Lord Corporation in order to supplement data that had

I been collected during previous investigations. This work included twohydrogeologic investigations conducted in 1979 through 1980 b'y—Dr. SamuelHarrison, followed by additional hydrogeologic work by Wehran Engineering in1981. A number of remedial options were evaluated on the basis of thosehydrogeologic investigations. An option was selected that included theremoval of exposed drums, construction of a composite surface seal or cap andan upgradient cut-off wall, and improvements to site surface water drainage,

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Those remedial measures were implemented during 1982 end 1983, A ConsentOrder 6 Agreement was entered into by Lord Corporation and Pennsylvania DER (. fwhich, in addition to the requirements associated with the remedial action,included the development and implementation of a monitoring program.Additional monitoring wells were installed by ECKENFELDER INC, in 1984 inorder to expand the existing monitoring well network, A Hydrogeologic Summaryreport was prepared in 1985 on the basis of data'Collected from these newlyinstalled monitoring wells,

A considerable body of hydrogeologic and water quality data was in place as aresult of the above described programs, prior to the initiation of the RI.The RI, which was conducted in accordance with RI guidance documents and withthe approval of DER, addressed these existing data in addition to presentingnew data, In this way, the RI report represents a comprehensive report ofmost of the field investigations that have been conducted at the site.

In late December 1987 DER determined that additional data would be useful tofurther characterize the Shope's Landfill site, Therefore, Lord Corporationwas requested to plan and implement a supplemental or Phase II RI, The /v SPhase II RI was conducted during 1988 and 1989, ^^

The Phase II report is essentially an update of the original 1987 report thatalso contains the new data collected to date, The RI report primarilyaddresses the hydrogeologic characterization of the site, However, othermedia such as site surface water and air quality have been addressed as well.In addition, a biota study was conducted. The baseline public healthevaluation of the site was revised and updated at the conclusion of thePhase II RI,

The information contained in the RI report provided much of the data used todefine and evaluate remedial alternatives considered in the development of theFS. Additional field investigations and treatability studies were conductedto further evaluate selected remedial alternatives and to develop designparameters and performance characteristics for selected remedial alternativesand the recommended remedial action. flR30 I 40 I

'•L,/ Thfi RI identified the primary environmental concern at the site as •' groundwater contamination plume in the Intermediate Zone of groundwater.

The Water Table Zone was also shown to be contaminated, principally at thedowngradient margin of the landfill. Small volumes of surface water andshallow soils have also been shown to be contaminated in areas at orimmediately adjacent to the site,

Report Organization

The FS has been conducted in accordance with USEPA guidance documents andrequirements of the National Contingency Plan (NCP), as amended, and includesthe following:

• A description of the site history and a summary of the nature andextent of site contamination.

i• The development of a range of feasible remedial alternatives,

O• The development of applicable or relevant and appropriate

I requirements (ARARs) for the protection of public health and theenvironment.

I i A detailed technical evaluation of candidate remedial alternatives.

' i An analysis of environmental impacts,

• A detailed cost analysis of candidate remedial alternatives,

• An evaluation and summary of institutional requirements,

• A summary of candidate remedial alternatives,

• The recommended remedial alternative,

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I.I SITE BACKGROUND INFORMATION

In this section, the location, physical features, and a brief history of thelandfill are presented,

1,1,1 Sit* Location

The Shope's Landfill site is located in Girard Township, Erie County,Pennsylvania (Figure 1-1). The property encompasses approximately 25 acresand is situated between US Route 20 to the north and Interstate Route 90 tothe south. The property is bounded on the east by the Melvin Shope residence,an apple orchard and vineyard to the south, an evergreen nursery to the west,and overgrown cropland to the north. The nearest population center, GirardBorough, is located two miles to the northeast, The only nearby residencesare located along Pieper Road, to the east and northeast and along Route 20 tothe north, The Overtake Golf Course is located close to the site to thenorth.

1.1.2 Site Layout

The landfill occupies approximately four (4) acres of the central portion ofthe property (Figure 1-2), The remainder of the Lord property includes mowedgrass land, an orchard on the east, and forested land on both the north andwest,

The site ranges in elevation from a maximum of 820 ft Mean Sea Level (MSL) onthe landfill cap to less than 780 ft at the northwest corner of the property,The landfill itself is manifested as a grass covered mound, rising a maximumof 20 ft, The adjoining land slopes gently to the north and northwest,

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CUT-OFF WALL ORIENTATION- —— — — - —— 1 tuftm i mmmiitAPfROXIMATE LANDnLL rCRIMETER

• 7/11

FIGURE 1-1

BASE OF LANDFILLCONTOUR MAP

SHOPE'S flW-n'FfccOIRARD TWP..PA. • ,/i

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o 1,1,3 Site History and Waste Components

The Lord/Shope site was formerly used as an industrial waste landfill. Thesite was owned and operated by Melvin Shope who resided to the east of thelandfill. Mr. Shope, who worked for Lord Corporation in the MaintenanceDepartment, hauled and disposed of wastes generated from Lord's 12th Street,Erie, Pennsylvania and Saegertown, Pennsylvania plants. No wastes other thanthose generated by these Lord Corporation facilities are reported to have beendisposed at the Shope's site. The landfill was operated from the late 1950suntil 1979,

The wastes contained in the landfill were disposed of directly upon, theoriginal ground surface, On this basis, the thickness of the waste does notexceed e maximum of 20 ft, The approximate landfill base grade is presentedin Figure 1-2.

The waste contained in the landfill reportedly consists primarily of wasterubber scrap, demolition debris, pallets, and paper. However, drummedchemical wastes consisting primarily of spent adhesives, waste paint, andpaint sludges were also disposed in the landfill, These containednon-halogenated compounds including ketones, toluene, xylene, and naptha, withonly small proportions of chlorinated compounds. Minor quantities of drummedwastes including chlorinated paint and degreasing solvents, non-PCB cuttingoils, and miscellaneous acids and caustics were also deposited in the landfill,Disposal of drummed waste was discontinued following a fire that occurred atthe landfill in June 1971,

A remedial action in accordance with the Consent Order & Agreement wasundertaken in the Fall of 1982 and Spring of 1963. The purpose of this workwas to reduce the volume of leachate generated and released from the landfilland to provide for post-construction monitoring, The remediation Includedremoval of exposed drums and construction of a composite cap, in upgradientcut-off wall, and a storm water drainage system. The combined effect of thecomposite cap and upgradient cut-off wall has been to reduce the amount of

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leachate generated by more than 99 percent, The storm water drainage systemhas served to mitigate soil erosion and reduces the possibility nf overland ( [)flow contamination,

Table 1-1 provides a chronology of response actions for the site,

1.1.4 Land Use

The area surrounding the Shope's Landfill is primarily rural. Figure 1-3indicates that the area within the vicinity of the landfill is predominantlyused for agricultural purposes, With the exception of a number of scatteredresidential areas bordering the roads, the only other significant land use isthat of the Overlake Golf Course located to the north-northeast of the site,

The scattered residences within the vicinity of the site are supplied withwater from private wells, and use aeptic systems, The nearest residences in adowngradient direction (north) from the landfill are located approximately4,000 ft away.

Zoning regulations exist in Cirard Township. Land zoning in the vicinity ofthe site is depicted on Figure 1-4, The site and the land adjacent to thesouth is presently zoned A-l (Agricultural). The adjoining land to the northis zoned R-3 (High Density Residential) even though it is presently vacant,Land immediately west of the site is zoned R-l (Low Density Residential),

1,1.5 Climate and Meteorology

Monthly climatological data for temperature, precipitation, and snowfall atErie, Pennsylvania are presented in Table 1-2, The measuring station forthese data is located at the Erie International Airport approximately 11 milesnortheast of Shope's Landfill, The climate in this part of the State ischaracterized as continental; however, the presence of nearby Lake Erie Is amajor factor with regard to the overall climate, The lake generally moderatesthe temperatures and produces an excess of cloudiness and frequent snow andrain squalls, Table 1-2 indicates that temperatures range from a AKnval taUf

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TABLE 1-1oLORD/SHOPE LANDFILL CHRONOLOGY

0

Q.

1959-1979 •

1979 •*

1980 tt

1981 •

Lord waste disposed of at landfillproperty.

by Kelvin Shope, on Shope

Landfill closed by DER.Lord undertakes investigation of waste, conditions at site,and some surface clean-up.

CERCLA (Superfund Law) passed,Local consultants conduct InitialInstall 18 monitoring wells,

hydrogeology study and

Lord hires experienced environmental engineering consultant.Consultant Installs 10 additional monitoring wells, test pits,and borings and performs hydrogeologic assessment and]additional surface clean-up.

1982 • Consultant submits Remedial Action Plan with 10 alternativesconsidered, Including exhumation of waste.

• Lord signs Consent Order and Agreement with DER to implementselected remedial action.

1982-1983 • Remedial action including impervious cap and slurry wallconstruction.

1983 • Lord takes ownership of landfill property.

1983-1985 • Lord Annual Report shows effectiveness of remedial action.* DER requires additional monitoring wells to refine plume

definition.

1985 t National Contingency Plan issued with new USEPA remediationguidelines,

« DER/USEPA require focused RI/FS based on new USEPA guidelinesincluding new air quality study, soils study, and hydrogeologystudies.

1986 * Lord commences performance of work plan for focused RI/FSincluding Installation of 16 more perimeter monitoring wells.

• SARA (Superfund amendments) passed with new guidelines forRemedial Investigation and Feasibility Studies,

• Lord acquires some adjoining property to the north.

1-9

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\ • ' - ' . ' . ' . . ' ' . ' ' i • '! - -: .'1'.''•'.'. V fc,'.:.. •ijVB

oTABLE 1-1 (Cont'd)

LORD/SHOPE LANDFILL CHRONOLOGY

1987 • Lord installed 3 early warning wells, 1 perimeter wells, and3 background wells (75 wells total) and performed endangernentstudy, hydrogeologic investigation, stream sampling,biological study, and RI study.

• DER/USEPA require Feasibility Study of scope required by SARA,Including evaluation of on-aite source remediation.

t New Consent Order for RI/FS signed,e FS Work Plan Submitted and subsequently approved.

1988 * DER responds to Lord RI report with comments which escalaterequirements for RI above approved work plan:» Quality assurance requirements - project plan; re-

characterize site; complete analysis of all parameters tocontract lab protocol.

t Additional biological studies, including wetlandsassessment.

• Additional hydrogeologic requirements - monitoringwells; surface soils; piezometers; borings.

• Additional surface water and stream studies,• Additional statistical analyses - heavy metals;

groundwater and surface water.• Revised baseline public health evaluation incorporating

all data above,

1988-1989 • Lord submits work plan for Phase II RI.• Lord submits Quality Assurance Project Plan (QAPP) for

additional RI work,« Lord encountered delay in obtaining access from adjacent

property owner; DER intervened,* Phase II RI Is conducted,

1980. • Lord submits Phase II RI report, biota study, revised BaselinePublic Health Evaluation, and FS report to DER and USEPA(July).

• DER and USEPA provide final comments on RI/FS documents(December).

1990 t Lord submits final project documents to agencies (January).

AR30I469

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I -\

AQRICULTURAL< II RESIDENTIALC COMMERCIALF FORESTOC GOLF COURSE

LAND USE MAPSHOPE'S LANDFILL SITElOURCIl ALIION (1191,KV, INI) f———,

PA.T.B'OUADMN.LE |»} LWO CW.

1000______0______1000 K*P LOCATION

(Ml

riQURE 1-9

6416* f t f l T/lt

ECKENFELDERINC

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\ " LEGEND'\A-I AGRICULTURAL

_.-'R-l LOW DENSITY RESIDENTIALR-2 MEDIUM DENSITY RESIDENTIALR-3 HIGH DENSITY RESIDENTIALC-l HIGHWAY /PLAZA COMMERCIAL

SOURCE! ULUONJIISt.MEV.IHI)PA, T,9' OUAORAMOLE , , ..... ..._

2.0IRARD TOWNSHIP OFFICIAL ' J 'ZONING MAP, (12/3/791

2000______0 2000 MAP LOCATION

•Cllt lilt

SHOPE'S LANDFILL SITE

;418A OIRARD TWP..PA. ' T/I(' /ECKENFELDER

INC

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TABLE 1-2

CLIMATOLOCKAL DATA SUMMARY'ERIE, PENNSYLVANIA

Temperature Data (°F)1951-1980

Month

NormalDaily

Maximum

NormalDaily

MinimumNormalMonthly

PrecipitationData (Inches)

1873-1984Mean

Precipi- MeanCation Snowfall

Wind Data1873-1984

Mean PrevailingSpeed Direction(mph)( Through 1963)

JanuaryFebruaryMarchAprilMayJuneJulyAugustSeptemberOctoberNovemberDecember

Annual

30,932.2M.I53.764.fr74,078,277,071,060.147.135.7

55,5

18,017,725,836,145,455.259,959,453.143,234,324.2

39,4

24.525,033.544.955.064.669.168.262.051.740.730.0

47.4

2.672.392,783.113.363.473.293.293.663.513.492,89

37.91

21.615.310,52.50.00.00,00.00,00,4

1 1 , 120,6

81,9

13,312.213. 21 1 , 710,09.59,08,99.9

11,213.013,5

11.2

WSWWSW 'NNEWSWWSWssssSSESSWssws

"Source: NOAA (1984)

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maximum of 78,2 in July to an average low of 17,7°F in February. Theprecipitation is relatively evenly distributed throughout the year with thehighest monthly precipitation being recorded in September ai 3.66 in. and thelowest being recorded in February at 2.39 in. The most significant snowfalloccurs in January with an average monthly accumulation of 21.6 in.

1.1.6 Surfice Water Hydrology

1.1.6,1 Elk Cr««k Tributaries. The land in the vicinity of the Shope'ssite Is drained by two unnamed streams that are tributaries of Elk Creek, ElkCreek is a major stream that drains directly into Lake Erie, approximately2 1/2 miles to the north. The larger of the two unnamed streams, termed theElk Creek Tributary, originates approximately 2/3 miles southeast of the siteand flows around the south, west, and north sides of the site. A smallerstream, the Unnamed Tributary, originating immediately north of the site,flows north to a point where it joins the Elk Creek Tributary. Neither ofthese streams flows directly on the Shope's site,

The Elk Creek Tributary flows continuously throughout the year in the vicinity f'>';,jof the site. However, the smaller Unnamed Tributary stream flows onlyseasonally, in periods of wet weather, in the upper 1,000 ft of its length.During the Phase II RI, stream flow measurements were collected at fourlocations on the Elk Creek Tributary and at two locations on the UnnamedTributary, The measured average volumetric discharge rates ranged from 1.2 to3.4 cfs in the Elk Creek Tributary, increasing as one progresses downstream.The locations of these two streams are designated on Figure 1-5.

1.1.6,2 Site Drainage, Surface drainage of precipitation on the landfillcap is now well controlled by drainage improvements constructed as a part ofthe remedial action in 1962 and 1963, Cap run-off is directed through severalswales off the cap and around the perimeter of the landfill towards the woodedarea west of the site, Most of this run-off likely recharges the water tablein this area, However, some of this flow also moves directly to a poorlydefined swale that flows in a northwesterly direction from the site,

AR30U731-14 . . . .

FIGURE t.,.A STREAM SAMPLING LOCATIONS

(WATER a SEDIMENT)

IOURCE: ALIIONt (1999,REV, lPA, r.S'uSGSOUADRANGLE -, f ' " LORD CORP7

1000 Q ______2000 MAP LOCATION

«cal» tut

SURFACE Nfm<DL(l(a¥

SHOPE'S LANDFILL SITEGIRARO TWP..PA. T/,,

'ECKENFELDER

INC

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Prior to the construction of the site cap and the associated drainage swales,a significant quantity of uncontrolled surface flow occurred to the north ofthe site into the small stream. In an effort to stop this flow, a shallowdrainage swale was constructed by the northern, adjacent property owner. Thisswale was constructed parallel to the present northern property line to directthe flow in an easterly direction toward the small stream.

Several areas adjacent to the site are seasonally wet. These areas havepreviously been termed "seep" areas by representatives of the DER, However,they art not truly seeps as flow has never been observed to imanate from these•rets, Rather, these "seeps" are localized areas in which the (hallow water

j table intersects the ground surface in low-lying areas,

I 1,1,7 Geologic Conditions

Typical geologic features in the vicinity of the Shope's site are depicted onI Figure 1-6, This figure depicts the surficial glacial deposits as they have

been mapped by Schooler (1974), Of primary interest are the Ashtabula indI Cirard end moraines and a beach ridge formed along the shoreline of the last

inundation of glacial Lake Maumee III.

" A conceptual geologic model for the Lord/Shope site and vicinity has been. presented previously in the RI report. This model is based upon the known| regional setting as well as upon an interpretation of data generated by the RI. and by previous studies. With a database consisting of more than 50 test

borings and more than 90 individual wells and piezometers, a reasonable degreeof confidence in the conceptual model is possible,

Detailed descriptions of the materials encountered beneath the site arepresented on the boring logs in Appendix A of the Phase II RI report. Theaoil descriptions presented are based upon visual examination, the results oflaboratory grain size analysis, and index testing. The descriptions are in

AR30II.751-16 0

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BEACH RIDSE DEPOSITSGLACIAL MORAINE

SOURCEl I. ALtlON (II9*,REV, 1949) f———.PA. 7,i' QUADRANGLE , \ (

2.SCHOOLER(|97t) I————^2000 *» '•OC»TIOM

REGIONAL SURFICIALGEOLOGIC MAPSHOPE'S LMQFIII.LORD CORP.GIRARD TWP.,PA

ECKENFELDER «,£

AR30U76

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accordance with a modification of the soil classification system suggested byD. M. Burmister (1956). The results of the laboratory test) are presented inAppendix E of the Phase 11 RI report,

Generally, the site is underlain by a thick series of glacial deposits. Thesedeposits include at least three laterally extensive glacio-lacuitrine depositsinterbedded with intervening glacial tills, Minor amounts of glaciofluvialdeposits were obaerved at the surface, Bedrock was not encountered in any ofthe borings conducted during tho RI.

1,1,8 Groundwater Conditions

Groundwatar has been observed to occur within three zones beneath the Shopi'sstudy area:

• As an unconfined Water Table Aquifer within the shallow soils,

• As an intermediate depth confined zone within the coarser grainedsoils of the Maumee III B and the coarse grained Ashtabula Till.

1 As a deep confined zone within the coarser grained deposits of theMaumee III A.

Zones of lower hydraulic conductivity, termed aquitards, separate each of thewater-bearing zones, The Upper Aquitard separates the Water Table andIntermediate Zones, while the Lower Aquitard separates Intermediate and DeepZones. Monitoring wells and piezometers have been installed in each of thenzones, allowing the determination of their respective piezometric surfaces.

Deeper water-bearing zones probably exist bilow those that were studied at i'part of the RI, These zones may be contained within deeper glacial depositsand/or bedrock that underlies the site,

AR30U77

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O1,1,8.1 Water Table Zone, An unconfined Water Table Aquifer occurswithin the shallow soils beneath the study area and ranges in depth from 15 to30 ft, These shallow soils primarily consist of the coarse-grained AshtabulaTill and Maumee 111 C lacustrine deposits, but intermittently consist offine-grained soils as well. These shallow soils are among the most permeablethat occur at the site, with an estimated average hydraulic conductivity ofapproximately 6 x 10"* cm/sec,

The unconfined Water Table Aquifer receives recharge predominately throughdirect infiltration of precipitation. As such, the elevation of the wateritable surface of this zone is more sensitive to seasonal variations than are

I the deeper units.

I The surface of the unconfined zone occurs at relatively shallow depths beneaththe site, ranging from zero to approximately 10 ft below ground surface,except beneath the waste disposal area where it is somewhat deeper. Water

I table elevation contours have been interpolated from water level data obtainedfrom monitoring wells, The water table has been assumed to intersect surface

i) water on the site so that available stream gauge data have been employed forwater table contouring, as well, The water table surface generally reflects

I the ground surface topography, with a gradient ranging from 0,02 to 0,06,

j The direction of lateral groundwater flow is generally to the north andI northwest, Groundwater flow within the Water Table Aquifer presumably flows

toward and discharges to the two small streams located north and west of thesite, The horizontal flow rate of the Water Table Aquifer is estimated to beapproximately 82 ft per year, The water table surface is shown to be nearlycoincident with the ground surface at several locations north and west of thesite, These seasonally wet areas thus represent the surface expression of thewater table, Several of these areas located immediately adjacent to thelandfill, termed "seep" areas by DER, have been the subject of much interestbecause they contain contaminated groundwater, However, the term seep isreally a misnomer in that no observable flow emanates from these areas,

AR30U781-19

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1.1.6.2 intermediate Zone. Groundwater occurs under confined and/orsemi-confined conditions in the laterally continuous Intermediate Zone. This '.„_)zone is found primarily in the coarse-grained soils of the Maumee III BLacustrine deposits but is also found in the coarse-grained Ashtabula Tillbeneath the southern portion of the site, The geologic dnpoalts comprisingthis zone have a moderately low hydraulic conductivity (approximately6 x 10" cm/sac), However, this unit cannot truly be termed an aquifer as itprobably would not be capable of transmitting significant quantities of waterunder ordinary hydraulic gradients (Freeze and Cherry, 1979). Therefore, thisunit has been termed a "water-bearing zone", This water-bearing zone isalmost completely confined by overlying fine-grained till and lacustrinedeposits represented, respectively, by the Ashtabula subunit and theMaumee III B subunit, However, in several areas, notably that beneath thelandfill and in the plume extension area north of the site, the IntermediateZone has been shown to be only semi-confined.

The piezometric surface is shown to slope to the northwest in a similar butmore subdued manner than that of the overlying Water Table Aquifer. Adeviation from this pattern is suggested in the southern portion of the site f•,'•*,in that an apparent groundwater divide exists in the intermediate Zone betweenthe landfill and monitoring well V-26B southeast of the landfill (see Figure1-2).

A prominent lobe in the piezometric contours has been depicted in the area ofthe plume extension. This apparent local reduction in the magnitude of headloss through the formation may indicate a local increase in hydraulicconductivity in this immediate area.

The potential direction of the vertical component of flow through theconfining layer overlying the Intermediate Zone tends to be variable, and isdependent upon the relative topographic position of the overlying Water TableAquifer. At several locations, the piezometric surface is above the groundsurface. Under these conditions, the potential exists for upward flow throughthe confining layer.

AR30U791-20 ' '

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n

o

o

Several areas exist in which little or no hydraulic separation is affordedbetween the Intermediate Zone and the overlying Water Table Aquifer. Thisfact likely may have a profound effect on contaminant transport routes whencoupled with the known head differential between the two zones,. A downwardgradient existing beneath the landfill allows contaminants to migrate downwardinto the Intermediate Zone which is only semi-confined in this area, Aftertraveling laterally to the north, a portion of this flow may migratevertically upward under the influence of the strong upward gradients that havebeen observed,

The previously described lobe in the piezometric *urface may partially be theresult of this discharge to the overlying Water Table Aquifer, Thehydraulic conductivity of the Water Table Aquifer in this area is shown to berelatively high; this may have a controlling influence on the localized upwardmigration. Therefore, a relative reduction in head loss in the IntermediateZone occurs and is manifested as a localized lobe in the piezometric surface,

The rate of horizontal flow through the Intermediate Zone is estimated to beapproximately 10 ft/yr. This flow rate compares very closely to the knowncontaminant travel distance on the north-central and northwest sides of thesite, However, the situation in the plume extension area directly north ofthe site is somewhat more complex, The migration rate of the plume extensionis controlled primarily by localized stratigraphic conditions. The overallplume extension migration rate is estimated to be approximately 69 ft/yr.

1,1.8,3 Deep Confined Zone, A deep confined water-bearing zone has beenidentified at a depth ranging from approximately 75 to 105 ft below the groundsurface, This zone is contained within the coarser-grained layers of theMaumee III A lacustrine deposits, The Maumee III A has been described aspossessing a hydraulic conductivity on the order of 4 x 10"5 cm/sec, Thiszone is fully confined by the Lower Aquitard represented by the fine-grainedglacial till with a hydraulic conductivity believed to be less than 5 x10"7 cm/sec,

1-21 AR30U80

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The piezometric surface for the Deep Zone indicates that groundwmer in thedeeper confined zone flows toward the southwest, This is significantlydifferent than the direction of flow in tho previously described overlyingzones.

The Deep Zone probably receives its recharge through the very slow downwardflow through the confining layer thai necessarily would occur under theinfluence of the considerable downward vertical gradient that has beenidentified, Other upgradient, recharge zones may also exist north of the site.This flow path is shown to be directly to the regionally low area representedby Crooked Creek to the southwest of the site. Therefore, Crooked Creek moa;likely serves as the discharge point of this deep confined zone,

The rate of recharge to the Deep Zone is likely to be very slow due to the lowhydraulic conductivity of the overlying confining layer. Groundwater has beenestimated to move downward through the confining layer at a rate of no greaterthan 1,1 ft/yr. The rate of horizontal flow through the Deep Zone has beenestimated at approximately 2,4 ft/yr,

1.2 NATURE AND EXTENT OF CONTAMINATION

The RI identified the environmental media contaminated or potentiallycontaminated at the site as being groundwater, subsurface soils, and, to avery limited extent, surficial soils.

The nature and extent of site and environmental contamination has beenevaluated by a number of site investigations. The latest hydrogeologic fieldinvestigation was conducted in 1988 and 1989. This investigation wasperformed in order to supplement data from past studies and to provide data tofurther assess site hydrogeologic characteristics and the nature and extent ofthe contamination of soils and groundwater at the site. The results ofstudies which examined the local soil and groundwater are summarized below.

AR30IWI

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in tkit ftaite .14. n o t . a ,due to tubttandand colon on condition of the o*lglna«

O1,2,1 Soil Contamination

Several investigations have been conducted for the purpose of investigatingshallow and deep soil contamination, The most recent soil studies werecompleted by ECKENFELDER INC, during the RI,

1,2,1.1 Shallow Soil Contamination. A survey of shallow soilcontamination waa conducted in the area aoutheaac of the landfill by Wehran in1983, This study identified an area in which soils were moderatelycontaminated and several sample locations indicated significantly higherlevels of contamination,

ECKENFELDER INC, conducted a shallow soil .evaluation in 1964 and 1985. Inthis study, samples were collected from 94 locations located at 100 ftintervals around the landfill in order to determine the areal extent ofshallow soil contamination by volatile organic chemicals. The distribution ofthe samples was extended until areas of contamination had been completelydelineated on the basis of a field measurement with a photoionizing trace gasdetector. The results of the photoionizer data are plotted on Figure 1-7.The borings were advanced with the use of a hand-operated bucket auger; mostwere advanced to a maximum depth of 3.5 ft. In 1988, seven additional soilsamples were collected from areas previously shown to contain the highestlevels of volatile organic compounds,

Shallow soil contamination has been identified in several areas around thelandfill, Several of these areas correspond to the so-called "seep" areas inwhich contaminated standing water has been observed, This is the case inareas immediately northeast, north, and southwest of the landfill. Laboratoryanalysis of soil samples collected during the evaluation indicated thatshallow soil contamination is highly localized and that it exists in lowconcentrations for volatile organic compounds.

AR30U62'V . ' 1-23

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, .f"\ UN.,-//;V\ :>f•""\

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The most significant area of shallow soil contamination is located in a smallarea immediately southeast of the site. One possible explanation for thiscontamination is spillage from trucks entering the site at the time oflandfill operation.

The volatile constituenTT'within the surficial soils can be characterized onthe basis of the 1985 and 1986 laboratory data. Tetrachloroethene has beenshown to be the most abundant constituent, with concentrations being detectedin 12 samples at values up Co 620 ppb. Toluene was detected in four samplesat concentrations ranging to 15 ppb, while trichloroethylene was detected infour samples ranging to 5.4 ppb. Ethyl benzene is the only other compoundfound in more than one sample and was detected in three samples atconcentrations ranging up to 5.3 ppb. Benzene and methylene chloride werefound in only one sample each at concentrations of 6.A and 6.0 ppb,respectively,

1,2,1,2 Deep Soil Contamination, During the RI, deep soil samples werecollected using a test boring drill rig as a part of two investigations, Onestudy investigated the perimeter area immediately southeast of the landfill,The other study investigated the groundwater plume extension north of the

' landfill.I

Landfill Perimeter Borings

Four deep test borings (B-85-1 through B-85-4) were d r i l l e d in order todetermine the depth of soil contamination that was identified in the perimeterarea located immediately southeast of the landfill. This area is the same inwhich relatively high shallow soil contamination was found,

The data indicate that the most significant levels of deep soil contaminationoccurred in boring B-65-2 located on the hill 70 ft southeast of the landfill.

i Levels of Total Volatile Organics (TVO) measured vith the field photionizerI detector reached a maximum of 580 HNU units at a depth of 13 ft in boring

B-85-2. Below that depth, contamination levels dropped to nearly

L AlttOim

I

I

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t 1-25

• • • .due to tubttandand^ colon{on condition of the o*lglno*

non-delectable levels at a depth of 30 ft. The magnitude and penetration ofsoil contamination was not as extensive in the other borings, with boringB-85-3, also located on the h i l l , showing the lowest levels of contaminants.

The volatile constituents identified by the selected laboratory analyses ofthe deep soils are very similar to those for the surficial soils,Tetrachloroethene was found in a number of deep samples at concentrationsranging up to 51,7 ppb. Scattered low level detections of ethyl benzene,toluene, and trichloroethene was also observed in these samples.

Plume Extension Borings

Twenty-two test borings, designated B-B6-! through B-86-22, were drilled in1986 in the area north of the landfill, The soils were not believed to becontaminated as a direct result of chemical leakage or spillage as are thesoils on the landfill perimeter, Rather, the soil pores are believed tocontain the contaminated groundwater of the plume extension. Thedetermination of soil contaminant levels serves as an indicator for theapproximate delineation of the plume extension.

Contamination levels in the soil samples were determined in the field with theuse of the photoionizing trace gas meter. These data correspond to theapproximate configuration of the plume extension in the water-bearing WaterTable Aquifer and Intermediate Zones. The individual photoionizer data arepresented on the boring logs in the RI report, , A number of samples wereselected from the borings for subsequent laboratory analysis. TVO values forthe majority of samples were found to be below detection limits, with actualconcentrations ranging from below detection limits to a maximum of 43 HNUunits, As with the surficial soil and with the landfill perimeter borings,contamination of deeper soils, not directly associated with the landfill, ishighly localized and exists at relatively low concentrations, Compoundsdetected in the laboratory analyses of the soil samples, and their maximumrespective concentrations, were: acetone (1.7 ppm), methyl ethyl ketone

AR30U851-26

I L ;•, . " , * * . ' ' .

,/ps (0.3 ppm), vinyl chloride (0.3 ppm), 4-methyl-2-pentanol (2.6 ppm), 2-butanol'• ' (0.4 ppm), letrahydrofuran (0,3 ppm), methyl isobutyl kelone (1.0 ppm), and

o

methylene chloride (0.2 ppm).

1,2,2 Croundwater Contamination

A contaminant plume has been identified consisting primarily ofnon-halogenated volatile organic compounds, but also containing halogenatedvolatile organic compounds, The plume is restricted primarily to theIntermediate Zone and has migrated approximately 150 to 600 ft toward thenorth and west, An exception is a plume extension that has migratedapproximately 1,400 ft to the north in an area shown to have a higherhydraulic conductivity,

The Water Table Aquifer has also been shown to be contaminated, mainly in theimmediate vicinity of the landfill. There is some hydraulic interaction (and,therefore, contaminant transfer) between the Intermediate Zone and the WaterTable; however, contaminants are observed to be migrating from the siteprimarily within the Intermediate Zone,

A group of halogenated and non-halogenated volatile organic compounds has beenidentified by the CLP analytical protocols that are presently employed toanalyze the site groundwater samples. This group includes primarily methylisobutyl ketone (MIBK), 4-methyl-2-pentanol, acetone, methyl ethyl ketone(MEK), vinyl chloride, trans-l,2-dichloroethene, and terahydrofuran (THF), Inaddition to each of these compounds, the GC analytical methodology that wasemployed prior to 1966 had identified significant concentrations ofcyclohexanone, 2-butanol, isopropanol, and tetrachloroethene. These compoundscorrespond well to the types of wastes known to have been disposed in thelandfill, The various ketones are shown to be the predominant organicconstituents,

I AR30U86o! V. 1-27

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With several exceptions, semi-volatile constituents that represent actual con- .t.ditions have not been detected in groundwater samples colluded from the site. '-.--'The exceptions include the low level detections of benzo (k) fluoranthene andbenzole acid in several of the plume wells located very close lo the margin ofthe landfill,

The primary plume constituents at the Shope's site are volatile organiccompounds, However, a number of inorganic compounds principally consisting ofa group of metals and chloride have been noted in wells installed in the plume.Earlier data showed that the combined effects of these and other compoundsserve to elevate the TDS and Specific Conductance levels in the plume,However, these compounds have not been shown to be as sensitive as (.he organicconstituents in the delineation of the leading edge of the plume,

Statistically significant levels of metals have also been detected in theWater Table and Intermediate Zones including barium, cadmium, chromium,cobalt, copper, mercury, and zinc, However, most of these metals arerestricted to the wells located close to the landfill, Only barium exceedsits MCL for drinking water.

The Deep Zone has not shown evidence of any contamination. Residential wellsin the area have also not shown any evidence of contamination.

The distribution of contaminants within each water-bearing zone will bediscussed in the following subsections.

1.2,2,1 Water Table Aquifer. For the most part, the Water Table Aquiferhas been shown to be contaminated only a short distance past the downgradlentmargin of the landfill, In addition, the observed levels of contaminationhave decreased over time, A low level volatile plume has been identified toemanate from the landfill and spread out to the north in a downgndientdirection,

AR30U871-28

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The Water Table Aquifer plume has been difficult to characterize because thecompounds in various areas of the plume vary widely from one another. Forexample, of the wells located close to the landfill, W-9WT showed thattrans-l,2-Dichloroethene and trichloroethene are the primary constituents,W-1WT showed that vinyl chloride i) the primary constituent, while Well W-3WThas been observed to be clean. This heterogeneity is even more marked in thewells located further from the landfill. Examples of this are seen inWell W-21A, which has shown very low levels of tetrachloroethylene and MIBK inone sample and was free of volatiles in other samples, and in W-32A, which hasa very low level of trans-l,2-dichloroethene in one sample but was clean inanother.

This observed heterogeneity of constituents may reflect the fact that wastescontaining different compounds were disposed in different areas of thelandfill, Furthermore, the heterogeneity may be explained in that the plumeis fairly mature and that the detection of different compounds in differentareas of the plume may reflect varying constituent migration rates as well asthe breakdown of various compounds, The position of the water tablecontaminant plume, based upon latest available data, is depicted onFigure 1-8.

Semi-volatile organic compounds were detected in only three samples collectedfrom three plume wells. Semi-volatiles in liio Water Table have beencharacterized by the presence of Benzo (k) fluoranthone in plume Wells W-1WTand W-3WT at levels ranging up to 52 ppb, This compound was also detected inone sample from Well W-39A at a level of 46 ppm, This type of compound iscommonly associated with coal And petroleum derivatives which may or may notbe related to the landfill,

PCBs and pesticides were not detected in any wells in ''.is zone,

A statisticil analysis was performed on metals data fi im wells in the WaterTable Aquifer. Compared to background data, sii nificantly elevatedconcentrations were found in some cross-gradient \ e l l s and in plume

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I Wells W-IWT and W-3WT. There were no elevated concentrations In any of the| ) perimeter wells, In the plume wells, barium is elevated at the one percentI level in Well W-IWT and mercury may be elevated there. Arsenic and lead may

be elevated in Well W-3WT, No significantly elevated concentrations appear in| my other plume wells. In the cross-gradient wells, arsenic is significantly

elevated in W-5WT and W-8WT, chromium is elevated in W-8WT and perhaps H-5WT; and lead Is elevated in W-5B. These results are hard to explain since the

cross-gradient wells should not be impacted by the landfill,

Arsenic concentrations in the Water Table wells do not exceed the MCL value of50 ug/1. The MCL for barium (1,000 ug/1) is also not exceeded in wells inthis zone, There have been sporadic exceedances of the MCLs for chromium,lead, and cadmium (150, 50 and 10 p.g/1, respectively) in certain of the Water

I Table monitoring wells. However, these are isolated events and the majorityof the data show that these exceedances are not representative and they are

] suspected to be due to laboratory error or inefficient sample filtration.

O

O

Contaminants within the Water Table Aquifer likely migrate downward into theunderlying, semi-confined, Intermediate Zone, This movement occurs under theinfluence of the substantial downward vertical gradient that exists beneathand immediately north of the landfill,

1,2,2.2 Intermediate Zone, The Intermediate Zone provides the primaryconduit for the movement of contaminants from the site, A plume has beendefined emanating from the site and moving toward the north and northwest,

Water quality improvements over time have also been observed in a number ofIntermediate Zone monitoring wells. Typical of this improvement is monitoringwell W-12A in which TVO levels have been observed to decrease from a high of222 ppb in 1963 to a level of 6 ppb in late 1965, However, while many ofthese wells have improved to a significant degree, all previously contaminatedIntermediate Zone wells still contain detectable levels of TVO and TotalHalogenated Volatile Organics (THVO), The primary plume constituents in theIntermediate Zone are MIBK, 4-methyl-2-pentanol, vinyl chloride, and THF. Thegroundwater plume within the Intermediate Zone has beenFigure 1-9.

1-31

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The Intermediate Zone groundwater plume can be separated into several distinctareas. Much of the plume is migrating slowly to the northwest within themoderately low transmissivity materials that constitute the majority of theIntermediate Zone. In addition, some low level contamination also exists inan area located east or cross-gradient from the site, However, most of theplume is likely migrating more rapidly through the area of highertransmissivity directly north of the site, which has been termed the plumeextension,

The portion of the plume northwest of the site has migrated approximately 150to 600 ft past the margin of the landfill. This rate of movement correspondsvery well to measured hydraulic conductivity values.

Low levels of volatile organics consisting of tetrahydrofuran (THF) have beenobserved in a group of cross-gradient wells located east of the site, THF hasbeen observed in Wells W-7 and W-8A at concentrations as high as 70 and89 ppb, respectively, These data from the cross-gradient wells are consistentwith available historical data in which THF has been the primary parameterthat was observed previously on the basis of CC data, However, it should benoted that the THF levels that are currently observed in these wells aresignificantly lower than those that were previously detected, Furthermore, novolatile organic compounds have been detected in any of the residential wellslocated to the east of this particular area,

The hydrogeologic conditions of the Intermediate Zone to the east of thelandfill are similar to the area northwest of the landfill in that groundwaterflows to the northwest at a relatively slow rate, However, on the basis ofthese data, it is difficult to directly attribute these detections ofvolatiles to the landfill due to its cross-gradient position with respect tothese wells, The presence of these volatiles may be due to spillage that mayhave occurred along the landfill access road,

AR30|t»921-33

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The conditions of contaminated flow within the plume extension are somewhatdifferent than described previously for the discrete Water Table and f j)Intermediate Zones, The plume extension has migrated a greater distance pastthe landfill than the other portions of the plume, This movement is believedto be under the influence of the higher hydraulic conductivity conditions thathave been identified in the area ol the plume extension, In addition, theseparation between the Water Table and Intermediate Zones is not as pronouncedas has been observed elsewhere on the site. The two water-bearing zonesbehave almost as one unit within the area directly north of the landfill,

The water quality data available for wells W-20B and W-34 represent thetypical levels of contamination in this northern plume, MIBK has beenobserved in well W-20B at concentrations ranging to 2,400 ppb. Samples fromwell W-34 have contained MIBK, 4-methyl-2-pentanol, and vinyl chloride at atotal concentration ranging to 1,513 ppb. Other water quality data show thatthe volatile organic levels decrease rapidly to the north. Therefore, thesenorthern areas may represent an area of low level "fringe" contamination. Anexception to this is well W-36B, where trans-l,2-Dichloroethene was observedin one sample at 1,200 ppb, while other samples from this well have been free f^\of volatiles.

The Intermediate Zone and the overlying Water Table Aquifer appear to behaveas one combined unit in the area of the highest levels of contamination in theplume extension. In this way, contaminants migrating through the IntermediateZone can move upward under the influence of the observed upward verticalgradients, Thus, the migration of contaminants may be partially controlled bythe more highly transmissive, but laterally discontinuous, units of the WaterTable Aquifer,

The contaminants in the plume extension will probably not migrate into aregional flow system such that they would impact existing downgradientresidential wells, The present maximum extent of the plume extension has beendefined by the uncontaminated conditions of perimeter well clusters W-27 andW-32, If the plume migrates beyond wells W-27 and W-32, it is still unlikely

AR30U931-34 ,

.u. that it would impact the downgradient residential wells. This is due to the1 |._y fact that a significant amount of the plums would be expected to discharge to

surface streams due to observed upward hydraulic gradients, Furthermore,•natural attenuation w i l l serve to further decrease the level of anycontaminants that may continue flowing past the stream. Any discharge ofcontaminants to Elk Creek tributaries would be minimally detectable in thatthe expected flux would be low with respect to the dilution factor from otherflow sources,

Semi-volatile organic compounds were detected in only a limited number ofsamples collected from the Intermediate Zone wells, Benzo (k) fluoranthene

J was detected In two wells located at the margin of the landfill, W-1A and W-3,nt levels ranging up to 57 ppb, This compound was also detected In one sample

( c o l l e c t e d from Well W-39B at a concentration of 55 ppb, In addition, benzoleacid at levels ranging up to 4,300 ppb was detected in Well W-3, No other

I semi-volatiles were detected at levels above the detection limit,

PCBs and pesticides were not detected in any wells in this zone,

ORelative to background data, the statistical analyses Indicate significant

j elevated concentrations of arsenic in some perimeter wells, especially, W-32Band W-23B, Lead is also elevated in W-32G, Arsenic and lead are also

i significantly elevated in some cross-gradient Intermediate Zone wells: W-5Aand W-8A for arsenic and W-5A for lead, As in the Water Table Zone, theseresults are difficult to interpret, but the fairly large percentages ofnon-detects in the data for both arsenic and lead may be affecting theresults,

The results of the plume wells are consistent with earlier results, Bariumfor example, has concentrations as high as 5,800 ppb in wells near thelandfill and lower concentrations further away from trie landfill, Theelevated barium concentrations are significant at 1 percent level inWells W-1A, W-3, W-20B, W-33, W-34, and W-39B, Other metals which havesignificantly higher concentrations (at 5 percent or less) in plume wells are

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arsenic in W-lA, cadmium in W-lA, W-3, and W-20B, chromium in W-39B, cobalt in _.W-lA, copper in W-3, lead in W-33, mercury in W-lA and W-20B, and zinc in \.3W-lA, W-3, and W-4A. When reviewnd on an individual basis and includingpossibly significant results, Wells W-lA shows elevated concentrations for9 metals, Well W-3 for 4 metals, Well W-20B and W-39B for 3, Well W-33 for 2,and Wells W-4A and W-34 for 1 each. This is roughly consistent with thedistances of the wells from the landfill and the previously determinedboundaries of the plume,

The present MCL for barium (1,000 ug/1) is exceeded in 6 wells in theIntermediate Zone: W-1A, W-3, W-20B, W-33, W-34, and W-39B, The proposed MCLvalue of 5,000 ug/1, however, is only exceeded in W-3. Arsenic concentrationsin the Intermediate Zone wells do not exceed the MCL value, As with the WaterTable wells, there have been sporadic exceedances of the MCLs for chromium,lead, and cadmium in certain of the Intermediate Zone wells, but these areisolated, unrepresentative events,

1,2,2,3 Deep Zone. Groundwater in the Deep Zone is not affected by thelandfill, This is based upon the uncontamlnated condition of the downgradient L-'.'Jdeep wells. Furthermore, the Deep Zone is believed to be confined by the lowhydraulic conductivity glacial till that represents the Lower Aquitard, Thedirection of groundwater flow, while very slow, has been shown to be in nearlythe opposite direction as that in the overlying zones, The hydrogeologic dataindicate that the Deep Zone is overlain by a laterally continuous, lowhydraulic conductivity aquitard, as discussed previously,

1,2,2,4 Summary of Groundwater Quality, Concentrations of the variousorganic and inorganic groundwater analytical parameters vary by several ordersof magnitude depending upon the locations of the various wells and thewater-bearing zone sampled, The complete groundwater data for the variouswells within the three water bearing zones are tabulated in the RI report.

For the purpose of examining potential remedial actions for the contaminatedgroundwater in the plume extension, a "worst case" scenario was developed,

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This scenario assumed that the undeveloped land adjacent to and downgradient(north and northeast) from the landfill would be developed to accommodateresidential housing. It was assumed that wells would provide water to eachresidential unit and that these wells could potentially be contaminated by thegroundwater , ume emanating from the landfill.

Tables 1-3 and 1-4 provide a summary of representative groundwater chemicalconcentrations for the Water Table Zone adjacent to the landfill (perimeter),the Intermediate Zone adjacent to the landfill, and the Intermediate Zone inthe plume extension.

1.2,3 Other Environmental Media

Several of the other environmental media at or near the aite have been sampledduring the RI project and during previous investigations. These media includesurface waters and sediments from the stream tributaries, "seep" areas,drainage swales, standing water in low-lying areas, and ambient air. Thesignificant conclusions of the RI regarding these other media are aummarizedbe lowi

• No indications of landfill-derived organic compounds have beenobserved in the two small streams in the vicinity of the site, withthe possible exception of elevated metals in the small streamlocated north of the landfill.

• Small volumes of surface water containing volatile organics havebeen identified in the "seep" areas immediately adjacent to the site,However, no observable flow emanates from those wet areas.

• The ambient air quality at and adjacent to the landfill is not beingaffected by the site. All photoionizer detector readings indicatednon-detectable or background levels of volatile organic compounds.

AR30U96

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o 2,0 REMEDIAL OBJECTIVES

The overall objective of this FS is to Identify and evaluate remedialalternatives that will serve to prevent potential risk to public health and/orto the environment by mitigating potential exposure to contaminatedgroundwater and soils in a manner consistent with the requirements of CERCLAand the NCP,

Contaminant source control is a remedial objective that would reduce the rateof release of contaminants into the water-bearing zones at the site, Thiscould possibly reduce the overall time frame for site cleanup and couldfacilitate cleanup of downgradient groundwater and soils.

Remediation of contaminated groundwater, which exists downgradient of thelandfill site, is a remedial objective intended to minimize potential exposureof groundwater contaminants to the public and to the environment and to makepotential future well water supplies available.

Technologies that may be employed to implement the remedial objectives must beI able to meet the requirements of public health and environmental standards and' other "applicable or relevant and appropriate requirements" (ARARs) as well as

address operational, Institutional, cost, and other implementation factors.Remedial objective site cleanup standards for the protection of public healthand the environment are discussed in this section.

2,1 PROTECTION OF PUBLIC HEALTH AND ENVIRONMENT

As part of the RI activities, a Baseline Public Health Evaluation wasconducted in order to determine whether potential contaminant transportpathways posed a current risk to public health or the environment, and also toprovide information needed to evaluate any further remedial actions that maybe warranted. A discussion of the findings of this effort is presented inorder to identify potential concerns for the protection of human health andthe environment,

Q AR30I5JO2-1

o

2,1,1 ConUminint Source and Potential Migration Pathways

Contaminant migration pathways which could potentially affect the environmentor human health include: groundwater, air, soils, and surface water/sediments,Work conducted during the Baseline Public Health Evaluation evaluatedpotential risk to human health and the environment for each of these media,

2,1,1,1 Air Pathway. Migration of contaminants to air is an improbablecontaminant transport route because the landfill has been capped with animpermeable composite cap. Air quality surveys were conducted in 1984 and198B and included the landfill and an area 300 ft in any direction from thelandfill. An HNU photoionization trace gas detector was used to analyze airsamples to detect the presence of organic vapors. None of the measurementstaken indicated the presence of organic air contaminants above backgroundlevels, A very minor source of potential air contamination could result fromvolatile organic compounds being released from the so-called "seep" areas.Pennsylvania DER expressed a concern with respect to the potential release ofthese compounds. Therefore, subsequent to the Phase II RI, quantitativeestimates of worst-case maximum flux rates of volatile organics from thenortheast "seep" and the resulting potential exposure concentrations atdownwind receptors were made, Even under these worst-case conditions,inhalation of volatiles from surface water seeps did not present anunacceptable risk to human health, Therefore, the air pathway is not ofconcern at the Lord/Shope site,

2,1,1.2 Soil Pathway. Potential exposure to contaminated soils isconsidered to be unlikely since virtually all of the contaminated shallowsoils lie either beneath the landfill cap or otherwise are found beneath theground surface, The ground surface surrounding the cap is heavily vegetated,further reducing the risk of potential exposure to contaminated soil, Theonly exceptions to this are the exposed "seep" areas, the crested soil pile atthe southeast corner of the landfill, and other small areas adjacent to thelandfill, The "seep" areas are localized expressions of the Water TableAquifer at the land surface and therefore should be addresseflBsOlUTJtg3) (thegroundwater pathway,

2-2 G

^— . . • • . ' ' - -

O

Contaminated subsurface soils do not appear to pose any likely threat, lo humanhealth or the environment as a result of direct exposure unless they areexcavated, Risks associated with contaminated subsurface soilsâre related togroundwater contained within the soil media.

.2,1,1,3 Surface Water/Sediment Pathway, Significant contamination ofsurface water due to contaminated stormwater runoff has been eliminated as apotential exposure pathway by the installation of the composite cap over thelandfill, site regrading, revegetation, and stormwater diversion. Surfacewater is drained from the site through a stormwater drainage system whichconveys water to unnamed tributaries of Elk Creek.

Surface water contamination from the landfill due to recharge by contaminatedgroundwater is not a significant contaminant pathway due to the 99 percentreduction in leachate volume resulting from leachate controls (upgradientcutoff wall, capping, etc,) installed in 1983, The Water Table Aquifer hasnot been found to be significantly contaminated except in the immediatevicinity of the landfill and, therefore, should not pose a risk to surfacewater, The Intermediate Zone, which has been shown to be contaminated, mayrecharge surface water, but the contaminant concentrations in potentialrecharge areas are believed to be so low as not to constitute a risk.Analysis of samples of surface water and sediments taken near the landfillduring the RI in 1986 under conditions of groundwater recharge indicated thatthese media are free from contamination by organic compounds and are at levelscomparable to background levels for metallic constituents, During thePhase II RI, additional surface water and sediment samples were collected fromthe streams near the site. There were no appreciable differences betweenupstream and downstream surface water characteristics,

The Deep Zone has been identified as being free from contamination andtherefore does not represent a potential source for contamination of surfacewater.

RR30I5I22-3

Potential ingestion of contaminated stream sediments was examined in theRevised Baseline Public Health Evaluation. The upper bound carcinogenic risk f j)was estimated at 3.8 x 10"5. This value is within the target range of 10"4 to10"' and therefore does not pose an unacceptable risk to human health. Thenoncarcinogenic risk computation produced a chronic hazard index value of only0.0035, which is well below the level of concern for potential healthrisks (1.0),

A biological investigation of the landfill site and surrounding area wasconducted during the RI in 1986 to assess potential impacts of the landfill onthe benthlc fauna of the receiving streams, Terrain in the immediate area wasalso evaluated to examine potential impacts to critical habitats, Thisinvestigation concluded that there was no apparent indication that thelandfill had produced a toxic impact on local aquatic communities.

At the request of Pennsylvania DER and USEPA, additional biota studies wereconducted during the Phase II RI.

Overall, the aquatic biota in the unnamed tributaries indicated water quality A;~is fair to excellent with a good number of species and numbers of organisms.There is no fishery in these streams and, therefore, no pathway for chemicaltransport to humans even if chemicals were present. There are no presentlyrecognized wetlands in the vicinity of the unnamed tributaries at ordownstream of the site, There are some areas upstream which include somehardwood swamp environments. These areas are not on the National WetlandsInventory. The area is above and outside of any planned activities. Noendangered species are known to exist in or near the streams, There is noevidence of any impacts to biota in either stream from activities at Shope'slandfill. In addition, no planned activities will modify these streams oraffect fish or wildlife,

For the reasons set forth in the proceeding paragraphs, surface water/sediments is not a migration pathway of concern at the Lord/Shope site.

AR30I5I32-4

2,1,1,4 Groundwattr Pathway, No current threat to human health or to the| environment is known to exist as a result of exposure to contsmlnued

groundwater emanating from the site. The nearest well users hydraulicillydowngradient of the landfill are approximately 3,000 ft away, a distance thitensures the safety of existing well water supplies from the advancing plume,There are no water supply wells located within the plume of groundwatercontamination, nor are there any plans to intercept contaminated groundwaterfor water supply purposes,

As an added precaution, however, residential early warning wells have beeninstalled between the landfill and downgradient .•.sidences, The wells ire

i situated to allow adequate time for the development of alternative watersupplies in the unlikely event that contamination is detected. To date (July

I 1989), these early warning wells show no evidence of site contaminants, whichis expected based upon the low groundwater velocities in this area,

I The possible future ingestion of contaminated groundwater from the site wasexamined in the Revised Baseline Public Health Evaluation, The "best

(] estimate" and "upper bound" carcinogenic risks were calculated as 1 x 10"' and1,2 x 10"', respectively, These projected potential future risks were due to

I the presence of vinyl chloride, Ingestion of the localized "seeps" (WaterTable), were this to occur, also could present risks,

' 2,1.2 Summary

Remedial actions at the site have significantly minimized the production ofleachate from the landfill. However, because of prior leachate release, aplume of contaminated groundwater is emanating from the site and is moving tothe north. The plume has proceeded past the landfill property boundary andextends beneath adjoining agricultural land. This property is zoned for highdensity residential use although there is no high density development in thearea, There is no current threat to the environment as a result of previousreleases, A potential future threat to human health could occur ifcontaminated groundwater were used as a potable water supply,

P , „ AR30I5II,

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As discussed previously, the Water Table Aquifer is found to be contaminatedprincipally in the immediate vicinity of the landfill, Source control options (jto be evaluated should include the removal and treatment of contaminatedgroundwater in this water-bearing zone, The Intermediate Zone is found to becontaminated with low concentrations of organic compounds, Source andmigration control options to be evaluated should include the remediation ofcontaminated groundwater in this water-bearing zone. The Deep Zone has notbeen fount! to be contaminated, and does not represent a potential groundwatercontamination pathway.

The Water Table Zone (source control) and the Intermediate Zone (migrationcontrol and source control) are subdivisions of the groundwater pathway whichshould be considered in the development of future additional remedial actionsfor the site, Remedial actions for groundwater will also address contaminatedsubsurface and "seep" area soils. The groundwater chemical quality datapreviously summarized in Tables 1-3 and 1-4 are representative of siteconditions and can be used in the development of remedial actions for the site,Air and surface water/sediments are not transport pathways of concern at theLord/Shope site. .

S-ii'2,2 STATE/FEDERAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)

USEPA's policy on the selection of remedial actions at a CERCLA site requiresthat primary consideration be given to remedies that attain applicable orrelevant and appropriate federal and state requirements (ARARs). Whilefund-financed or enforcement actions do not require environmental permits,states and private parties are not precluded from obtaining permits. Inaddition, all off-site actions must be in compliance with other environmentallaws, including permit requirements. USEPA published their "CERCLA Compliancewith Other Laws Manual" in August 1988.

In addition, Pennsylvania DER has provided a list of potential ARARs underCommonwealth regulations, Both of these documents were reviewed to determinewhich items may be ARARs for the Shope's site, This review involved

AR30I5I5" o

o consideration of the nature and extent of the problem at the site as well asthe types of remedial alternatives expected. ARARs which would directlyaffect the Initial identification and screening of remedial technologieswere identified and are summarized in this section. More complete listingsand analyses of federal, Commonwealth, and local ARARs applicable specific tovarious remedial alternatives are provided in the institutional requirementsdiscussions in this report.

2.2.1 Existing Landfill Cap

The USEPA and Pennsylvania DER have promulgated regulations which addressclosure and post-closure care at permitted hazardous waste landfill sites,These regulations are codified at 40 CFR 264, Subpart N and in Chapter 75,Subchapter D of Title 25 of the Pennsylvania Code. Although not directlyapplicable to the Shope's site, these regulations may be relevant andappropriate, Under 40 CFR 264,31Q(a), a final cover design is required whichprovides long-term minimization of migration of liquids through a closedlandfill; functions with minimum maintenance; promotes drainage and minimizeserosion or abrasion of the cover; accommodates settling and subsidence so thatthe cover's integrity is maintained; and, has a permeability that is less thanor equal to the permeability of any bottom liner system or natural subsoilspresent, The cover system which is now in place at the landfill meets theserequirements, Post-closure care regulations (40 CFR 266,310(b)) includerequirements under 40 CFR 264,117-.120 (post-closure care and use of property,a written post-closure plan, post-closure notices, and certification ofcompletion of post-closure csre) as well as the following: maintenance of theintegrity and effectiveness of the final cover; continuation of operation ofleachate collection and removal system until leachate is no longer detected;maintenance and monitoring of groundwater monitoring system; prevention ofrun-on and run-off; protection and maintenance of surveyed bench marks; and,notification of the Regional Administrator of leaks detected in leak detectionsystems.

O AR30I5I62-7

o

2.2.2 Groundwtter Cleanup

The USEPA and Pennsylvania DER have promulgated regulations which addressgroundwater corrective actions at permitted hazardous waste sites.. These arecodified at 40 CFR 264, Subpart F, and in Chapter 75, Subchapter D of Title 25of the Pennsylvania Code, Although not directly applicable to the Shope'ssite, these regulations may be relevant and appropriate, Contaminatedgroundwater at the point of compliance may be cleaned to three levels underthese requirements: to background (upgradient) conditions; to groundwaterprotection standards (Maximum Contaminant Levels under the Safe Drinking WaterAct); or to demonstrated Alternate Concentration Limits (ACLs), which areshown to be protective of human health and the environment. Groundwater inthe vicinity of Shope's landfill is consistent with classificationrequirements as a Class II groundwater resource, according to the USEPACroundwater Classification System. Class II groundwaters are eithercurrently, or potentially, a source of drinking water. For this site, thegroundwater in the Water Table and Intermediate Zones immediately downgradientfrom the landfill are potentially, but not currently, drinking water sources.

Interim guidance from the USEPA for Class II, potential but unused sources ofdrinking water, indicates that Maximum Contaminant Levels (MCLs) are generallyrelevant and appropriate cleanup standards, However, the USEPA hasestablished MCLs for a limited number of contaminants, Cleanup standards forcontaminants which do not have an MCL are either background concentrations orACLs. ACLs may establish groundwater standards such that the ACL will "notpose a substantial present or potential hazard to human health or theenvironment as long as the alternate concentration limit is not exceeded"(40 CFR 264,94(b)|,

For those compounds which do not have a promulgated MCL, health advisories andother guidance have been developed in some cases, Table 2-1 summarizescurrent and proposed federal and Commonwealth drinking water standards andhealth advisories available for the site contaminants for consideration indeveloping remedial actions for the Shope's Landfill,

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o

TABLE 2-1

FEDERAL AND COMMONWEALTH DRINKING HATER STANDARDSAND ADVISORIES WHICH ARE POTENTIAL ARARs FOR THE SHOPE'S SITE

Parameter

ArsenicBariumCadmiumChromiumLeadBenzeneChlorobenzeneTrichloroethyleneVinyl Chloridetrans-1 ,2-DlohloroethyleneMethyl Ethyl KetoneTetraohloroethylene

Toluene

MCLa(uB/1)

501,000

1050505—52—--—

--

ProposedMCL

( MB/1)

5,0005

100..—100....100—5

2,000

HealthAdvisory(ug/1)

„

««--

«----«

270 (10 day)750 (10 day)

. 175 (10 day)20 (longer tern)

2,200 (10 day)S'lO (longer term)

"Promulgated federal Maximum Contaminant Levels (MCLs).Voposed federal MCLs, 51 PR 22062, May 22, 1989.

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2.2.3 Groundwater Recovery or Recharge Wells ^_ODER'a Bureau of Topographic and Geologic Survey administers Chapter 107 ofTitle 25, which is concerned with licensing of water well drillers, preventionof pollution of underground waters, and submittal of well construction records.These requirements would be directly applicable to the construction ofgroundwater recovery or recharge wells at the site,

In addition, any recharge wells Installed at the site may be subject to thepermitting and design and operation standards specified in the federalUnderground Injection Control (UIC) regulations,

2,2,4 Groundwater Treatment and Discharge to Surface Water

Groundwater treatment and discharge actions at the site would be subject tothe directly applicable National Pollutant Discharge Elimination System(NPDES) permit regulations, water quality standards, etc, found inChapters 91 through 95 of Title 25. These requirements are monitored tnd

x^Ximplemented by DER's Bureau of Water Quality Management.

2.2.4.1 NPDES Program. Discharge of treated groundwater to surfacewaters of the Commonwealth must be conducted in accordance with the provisionsof the NPDES program. Similarly, a permit to construct may need to be appliedfor and secured prior to construction of any treatment facilities.

2.2,4,2 Pennsylvania Water Quality Standards. The Commonwealth's WaterQuality Standards are set forth in Chapter 93, Title 25 of the PennsylvaniaCode, The closest potential receiving streams for treated groundwaterdischarges from the Shope's site are Elk Creek and its unnamed tributaries andCrooked Creek (see Figure 1-5). In Chapter 93, designated uses specified forElk Creek are Warm Water Fishes (WWF), Migratory Fishes (MF), and all otherstatewide water uses (water supply, recreation categories and subcategories).The unnamed tributaries of Elk Creek are designated as protective of Cold

AR30I5I92-10

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o Water Fishes (CWF), Migratory Fishes (MF), and all other statewide water uses,Crooked Creek is designated as High Quality - Cold Water Fishes (HQ-CWF),Migratory Fishes (MF), and all other uses,

Tables 3, 4, and 5 and List X of Chapter 93 were used to prepare the summaryof water quality standards (Table 2-2) applicable to Elk Creek and its unnamedtributaries and Crooked Creek in Erie County, As specified in paragraph (b)of Section 93.5, these standards apply to the 7QIO (actual or estimated lowestseven consecutive day average flow that occurs in 10 yr) design stream flowconditions in streams with unregulated flow, If the 7Q10 value is zero, DERspecifies the design flow based upon identified or estimated flow at thatpoint where a use from the statewide list becomes possible. In cases wherethe water quality standard is more stringent than the ambient stream

I concentration, the ambient stream concentration is used to establish specificeffluent limits.

D

O

2.2.4.3 DER Toxics Management Strategy. In late 1981 DER published thefirst edition of their Toxics Management Strategy, the object of which is toencourage a consistent, statewide approach for dealing with the prioritypollutants, and other pollutants with known or suspected toxic impacts, underthe National Pollutant Discharge Elimination System (NPDES) program. TheStrategy has been revised (updated) several times, the most recent editionbeing published in March 1989, Several portions of the Strategy may berelevant and appropriate to the discharge of groundwater from the Shope'ssite,

In general, discharge parameters and limits ore derived from (1) promulgatedeffluent limitations guidelines, if they exist for a given type of discharge,or best engineering judgment; and (2) water quality considerations, Theformer deals with the expected capabilities of technology in reducingpollutant loads, while the latter addresses the protection of human health andaquatic life, Permit limits must be based on the more stringent of the twofactors,

i

AR30I5202-11

TABLE 2-2

PENNSYLVANIA HATER QUALITY STANDARDS FORELK CREEK AND ITS UNNAMED TRIBUTARIES

AND CROOKED CREEK

0

Parameter Units Value(a)

Aluminum -- Not to exceed 0,1 of the 96-hrLC.Q for representativeImportant species,

Alkalinity rag/1 (as CaCOj) >20a

Ammonia Nitrogen mg/1 Based on stream pH andtemperature.

Arsenic , mg/1 ;«0.05

Bacteria No./lOO ml 5/1 to 9/30: <200°10/1 to 1/30: ~<2,000

Chromium (VI) mg/1 <0.05

Copper — Not to exceed 0,1 of the 96-hrLC5Q for representativeimportant species.

Cyanide (Free) ms/1 0.005

Dissolved Oxygen rag/1 Minimum daily average; 6,0Minimum value: 5.0

Fluorlde mg/1 <_2.0

Iron mg/1 Total: <_1.5Dissolved: <0.3

Lead mg/1 <0.05, or 0,01 of the 96-hrLCgo for representativeImportant species, whicheveris less.

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o

TABLE 2-2 (Cont'd)

PENNSYLVANIA HATER QUALITY STANDARDS FORELK CREEK AND ITS UNNAMED TRIBUTARIES

AND CROOKED CREEK

Parameter Units

Manganese mg/1

Nickel

Nitrite + Nitrate mg/1 (as N)

Osmotic Pressure (OP) mllliosmoles/kg

pH standard units

Phenollos mg/1

Temperature F

Total Dissolved Solids mg/1

Zinc

Value(s)

iV>Not to exceed 0,01 of the96-hr LCg. for representativeimportant species.

i10ISO6

6.0 to 9.0

<0.005

Based on ambient streamtemperature.

Monthly average: <500Maximum value: 750" •

Not to exceed 0,01 of the96-hr LCgQ for representativeimportant species.

Except Hhere natural conditions are less.Calculated as a function of equilibrium relationship for ionized and unionizedammonia, For calculating effluent limits, the 30Q10 stream flow rate is used."Geometric mean based on five consecutive samples, each sample collected ondifferent days.For Crooked Creek, no value shall be less than 7.0 rag/1,A loss stringent value nay be developed based on bioassays or aquatic fieldstudies,No rise when ambient temperature is 5B°F or above; not more th*i|£%ty'|s§2l&veambient until stream temperature reaches 58 F; not to be ohangea T>y more wan2 F during any one-hr period.

2-13

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DER uses a six step process for applying the Strategy to each dischargesituation, After an Initial review of the discharge application and (|background information, priority and other toxic pollutants In the dischargewaters are Identified, DER then selects the governing water quality criteriaand effluent guidelines to calculate allowable technology-based and waterquality-based discharge limitations. In the absence of effluent guidelines,bett engineering judgment is used to define the technology-based limits. Thisis the case at the Shope's site.

The Chapter 93 water quality standards are used in the water quality analysis;however, the Strategy (in Appendix C) alao incorporates USEPA and DERrecommended criteria. If a pollutant has both a Chapter 93 and a USEPAcriterion for protecting the same stream use, then the Chapter 93 valuegoverns. If the criteria are intended to protect different stream uses, themost stringent criterion is used, Water quality-based limits are calculatedwith the selected criteria and 7Q10 stream flow data, Short-term discharges(limited or intermittent) receive special consideration,

Water quality criteria available in DER's Toxic Management Strategy for those ^\priority pollutants and non-priority pollutants which are in the suite of •— 'chemicals known to be present in groundwaters underlying the Shope's site aresummarized in Tables 2-3 and 2-4, respectively.

2.2,4,4 Dischirjiu to POTWs, If groundwater is discharged to a nearbyPublicly Owned Treatment Works (POTW), the discharge must be approved inaccordance with the POTW's pretreatment program. For an industrial discharge(other than sanitary wastewater), a permit is issued by the local POTWadministering agency,

2.2.4.5 Air Emissions. Groundwater and/or other treatment operations(e.g., air stripping) which result in atmospheric emissions will require apermit to construct and a permit to operate from the DER Bureau of Air QualityControl, Chapters 123, 127, 129, 130, 135, 137, and 139 of Title 25 containthe potentially applicable air pollution regulations,

AR30I523

2-14

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'I i PENIimVANH ma giULlTT CRITERIA rO« MIOIITt POUtWSTS*

0

o

Pirintltr

»ra«nle (»a'!)C.dnlun

Chronltin

Lend

Zlno

Ben:«n«ChlorolxnstntTetnchlorogthylcneToluene1 ,2"tr«n9-I>lctiloroet(iylencTrlchloroethylone

i _ IP-M __ ..„.„. ..._JSMii!Jri}J.»ver«Bc""" •""——-"•

190Rip 10,7952 Until - 3,1°0)(II) llnrdneaa i 50; 100; 200 (ns/1)Crlt, < 0,66| 1,1; 2,0 (p 8/1)11 < £xp (0, 9199 |lnll|«1, 561)II i 50; 100) 200 (us/1)Crlt, > 131| 221| 391 (ps/1)Enp (l,266|ln'l]-1.66l)II < 50 i 100 i 200 (rr.B/1)Crlt. = 1.3; 3.2; 7.7 (pB/1)tip (0.8173 Until t 0,7614)II c 50 i 100| 200 (ns/1)Crlt, • 59; 110) 190 (pg/1)1292361393301,350«50

rjjjjij/lj""""M«Klnun

360Flip (1,129 |lnll) - 3.929)IH) IHrJneaj : 50| 100) 200 (iifi/l)Crlt. > 1.6) 3.9; 9,6 (m/l)16 • E«p (0, 9190 |lnll|*3. 60S)H > 50; 100; 200 (ite/1)Crlt. . 996| 1,716) 3,116 (p8A)Exp (l,266|lnll)- 1.H16)H t 50; 100; 200 (KB/))Crlt. • 31; 92; 200 (nB/l)Exp (0.8H7311nH|. 0,6604)H t 50; 100| 200 (nc/1)Crlt > M; 120; 210 (UB/D6401,1806951,6506,7502,250

*Fron T«bl« C of DER's Tunica Hananenenl Strittry, K«rch 1989,

2-15

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• -,-„— —,.,,-,.„....,;...-...-.rr.'V.'.',K.™«»S£iii!"••• »-i. • vi-7 ";-•— -" «••— ••"»•»«•••'•*.•. not a4 «eadabl* a*0J!mI tabet, It 14 due to 4ub4tanda«d coto* o* condition of thebjfe.-.,v:,"•:•:•,. . ,• • • • • • ' «•' ••• •

TABLE 2-1

PENNSYLVANIA HATER QUALITY CRITERIA FOR NON-PRIORITY POLLUTANTS8(u g/1)

examines water quality criteria for non-priority pollutants on a case-by-casebasis and one or more of these may be modified.bGoverning criterion, as defined in the Toxic Management Strategy, is the morestringent limit for protection of aquatic life or human health.

AR30I525

2-16

o

Parameter

Acetone

Barium

Methyl Ethyl Ketone

Methyl Isobutyl Ketone

"From Table C-3 of DER's

GoverningIn-StrearaCriterion

500

1,000

1,500 '

830

Toxics Management

AquaticLife

Criterion

500

5,000

31,500

1,600

Strategy, October 1986.

HumanHealth

Criterion

2,210

1,000

1,500

830

However, DER

O

O

2,2.4.6 Discharges to Commercial Treatment Facilities. If groundwater istransported to a commercial wastewater treatment facility, the transportationand treatment of the wastewater will require compliance with its NPDES permitas well as applicable requirements of Title 25 of the Pennsylvania Code andpertinent federal CERCLA, RCRA, DOT, and OSHA requirements and otherapplicable regulations,

2.2.5 On/Off Site Treatment/Disposal

On or off-site treatment (e.g., incineration and landfilllng) of wastesremoved from the landfill site would be subject to the directly applicablerequirements of the Pennsylvania Solid Waste Regulations found in Chapter 75of Title 25 of the Pennsylvania Code, as well as pertinent federal CERCLA,RCRA, DOT, OSHA requirements and other applicable regulations,

2.2,6 Floodplain Considerations

The Shope landfill is located near two unnamed tributaries of Elk Creek, Thetributaries Clow around all four sides of the site, passing nearest to thelandfill at the southwest corner, The tributaries converge north of thelandfill, then flow north to a confluence with Elk Creek, In addition,Crooked Creek and its tributaries are located further to the south of thelandfill, The area around the landfill has been mapped with respect topotential flood areas. Portions of the banks of Elk Creek and Crooked Creekhave been identified as Zone A, which corresponds to areas of special floodhazards without base flood elevations determined. However, the landfill andall of the immediately surrounding area has been designated Zone C, whichcorresponds to areas of minimal flood hazards, Figure 2-1 is a copy of theFlood Insurance Rate Map (FIRM), dated June 1976, for the landfill andvicinity. The FIRM designation indicates that the Shope landfill and adjacentareas are not subject to flooding.

AR3015262-17

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2,3 CLEANUP STANDARDS

Cleanup standards relevant to remedial actions taken at the Shope's Landfilldepend upon a number of factors. Cleanup standards for various environmentalemissions associated with remedial actions at this site are summarized below,

2,3.1 Air Emissions Standards

Technologies exist for the cleanup of pollutants from air emissions associatedwith available remedial technologies which could be used at this site. Sincethe limits of technology Cor air emissions are not a significant factor in thepreliminary screening of technologies for remedial action for this site, therequirements Cor air emissions will be examined in detail during the technicalanalysis and the analysis for institutional requirements in Section 5,0.

2,3.2 Groundwater Cleanup Standards

The USEPA and the Pennsylvania DER have promulgated regulations which mayapply to groundwater cleanup requirements at hazardous waste sites. Thesecriteria have been summarized on Table 2-5 along with pertinent surface watercriteria for this site. Cleanup criteria for groundwater used in the FSevaluations consider MCLs and drinking water health advisories for allparameters,

2,3,3 Surface Water Discharge Standards

If a POTW or commercial treatment facility is selected for off-site treatmentand disposal of contaminated groundwaters, then the NPDES permit limits ineffect for that facility must not be exceeded as a result of treatingcontaminated groundwaters from the Shope's site,

The discharge of treated groundwater into Elk Creek or a tributary or CrookedCreek could require treatment to levels to meet water quality criteria assummarized in Tables 2-2, 2-3, 2-4, and 2-5. Federal and staRePv')ni " ^standards and criteria are in Table 2-5.

2-19

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'

I ' 3.0 IDENTIFICATION AND SCREENING OF REMEDIAL ACTION TECHNOLOGIES

The comprehensive FS for the Lord/Shope Landfill is developed to lead to therecommended remedial actions for mitigating significant site problems, Toarrive at the recommended remedial actions, an evaluation process consistingof the following three phases was developed:

• Phase 1: Preliminary screening and selection of candidate remedialtechnologies.

• Phase II; Assembly and initial screening of remedial actionalternatives.

• Phase III: Detailed analysis of alternatives and recommendation ofi proposed remedy.

This section of the FS addresses Phase I and consists of the identification of./J general response actions appropriate to the environmental contamination at

this site, identification of potential remedial action technologies, andscreening of remedial action technologies,

Identification and pre-screening of appropriate candidate technologies wereundertaken using the following USEPA documents as guidance;

• Handbook for E v a l u a t i n g R e m e d i a l A c t i o n Technology Plans(USEPA 1983).

• Handbook—Remedial Action at Haste Disposal Sites (USEPA 19B5),

I• "Interim Guidance on Superfund Selection of Remedy" (USEPA 1966),

• Compendium of Costs of Remedial Technologies at Hazardous WasteSites (USEPA 1987).

Guidance on Feasibility Studies Under CERCLA (USEPA 1

3-1

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Additionally, the Superfund Amendments and Reauthnrlzation Act. (SARA) requiresthat:

i Remedies must be protective of human health and the environment(meet or exceed ARARs or health based levels).

• Remedies should attain federal and state public health andenvironmental standards.

• Remedies must be cost effective,

• Remedies should utilize permanent solutions and alternativetreatment technologies or resource recovery technologies to themaximum extent practicable,

3,1 IDENTIFICATION OF GENERAL RESPONSE ACTIONS

General response actions for each of the two remedial action objectives;contaminant source control and contaminant migration control, have beenidentified, The general response actions and technologies presented inTable 2-1 of Guidance on Feasibility Studies Under CERCLA were evaluated forapplicability. Additionally, in situ vapor stripping and other innovative insitu technologies were evaluated as potential control technologies,

The remedial action objectives and general response actions appropriate tothis site are summarized in Table 3-1, Each action is intended tospecifically address the contamination and transport pathways identified inthe RI, A no action alternative for each remedial action objective isincluded, as required by the NCP, for the purpose of providing a baseline forthe comparison of alternatives,

AR30I5323-2

TABLE 3-1

IDENTIFICATION OF GENERAL RESPONSE ACTIONS FORTHE LORD/SHOPE SITE

Remedial Action Objectives General Response Actions

Contaminant Source Control No (further) action

Additional containment of sourcecontamination

I Collection and treatment or sourcecontaminant plume (on/off site)

In situ contaminant source treatment

Removal or contaminant source; on/off-site treatment and/or disposal

Contaminant Migration Control No (further) action

Groundwater collection and discharge(on/off-site)

Groundwater collection, treatmentand discharge (on/off site)

In situ treatment

O AR30I533

3-3

3.2 SCREENING OF REMEDIAL ACTION TECHNOLOGIES _Q

Applicable technologies that will meet the remedial objectives for the sitewere determined by identifying all available remedial technologies and thenselecting potentially applicable technologies through a technical screeningprocess. Figure 3-1 outlines this screening process, Technologies whichcould not meet the screening criteria were not given further consideration.Technologies which met the screening criteria were assembled into remedialaction alternatives,

The available remedial technologies listed were compared to site and wastecharacteristics identified in Table 3-2. Available technologies wereassembled and pre-screened to remove inappropriate technologies from furtherconsideration. Pre-screening considerations were identical to those for themore detailed technology screening process, but were not as completelydeveloped,

Those technologies compatible with site and waste characteristics whichsurvived pre-screening were summarized, then evaluated to determine if they i • j

«-may be able to meet public health and environmental protection standards.Technologies which are capable of meeting public health and environmentalstandards were then evaluated in terms of the level of technology development,performance record, and construction and operations and maintenancerequirements, Technologies whose costs were greater than an order ofmagnitude above those technologies which produce comparable protection werenot carried forward.

Technologies included in the screening process are identified in Table 3-3.These technologies were screened as discussed above and applicabletechnologies were then carried forward for further analysis,

AR30I53I*' ' "

I•oI

0

REMEDIAL RESPONSE ACTIONS

,

AVAILABLE REMEDIAL TECHNOLOGIES

TECHNOLOGY COMPATIBLE WITH SITE AND NO NOT CARRIEDWASTE CHARACTERISTICS FORWARD

i

YES

TECHNOLOGY ABLE TO MEET PUBLIC HEALTHAND ENVIRONMENT PROTECTION STANDARDS

i YIS

TECHNOLOGY APPLICABLE IN TERMS OF:

• livtl ol ttcnnology divtlopmim• psrlorminci ricord• construction ind 0 & M riqulrimtnti

i YES

TECHNOLOGY COST ORDER OF MAGNITUDEGREATER THAN TECHNOLOGY WITH

COMPARABLE BENEFITS

N0 NOT CAKfllED—^ FOHWABO

N0 NOT CAnmio- •ONWAHD

YE1 NOT CARRIED~^ FORWARD

rSELECTION OF REMEDIAL TECHNOLOGIES

FIGURE 3-1

PHASE I

PRELIMINARY SCREENING AND SELECTION OF CANDIDATE REMEDIAL TEDHNOLOOJES

O\\

flR30!5353-5

oTABLE 3-8

SITE AND HASTE CHARACTERISTICS AFFECTINGREMEDIAL TECHNOLOGY SELECTION

Site Characteristics

Site waste volume Depth to bedrockArea Depth to aquitard(s)Site configuration Dtreotlon(s) and rate(s) orSlope/topography groundwater movementSoil characteristics • Potential receptorsClimate ' Existing land useDrainage features Potential future land useHater bearing zone characteristics Surface water characteristics and useGround/surface water recharge Surface water discharge considerationsVadose zone characteristics

Haste Characteristics

Quantity and concentration of Attenuation factorscontaminants Thermal properties

Volatility DensityBiodegradability HomogeneityCarclnogenicity PersistenceAcute/chronic toxioity Bioaccumulatlon factorsSolubilityTreatability

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REMEDIAL TECHNOLOG

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3.3 SOURCE CONTROL TECHNOLOGIES

The purpose of source control technologies is to prevent or minimize migrationof hazardous lubitinces from the source msteriil. Source control technologiesanek to completely remove, treat, and/or contain the hazardous substances atthe source. These measures may be implemented singularly or in combinationwith one or more migration control technologies.

There are nine (9) potentially feasible source control technologies that havebeen identified and preliminarily screened in this FS report (see Table 3-3).These technologies include:

• No (Further) Action• Limited Action• Near Source Groundwater Collection (Gradient Control) and Treatment• Intragradient Cut-Off Wall (Wall Extension)• In Situ Biological Degradation• In Situ Vapor Stripping• Excavation• Incineration• Landfill Disposal

Each of these technologies is discussed in the following subsections.

3,3.1 No (Further) Action

The no (further) action alternative is required by the NCP for the purpose ofproviding a baseline from which other actions can be compared, Remedialsource control efforts were performed at the Shope's site in August toNovember 1962 and in June to August 1963. Ten options for site remediationwere evaluated. The plan chosen was selected on the basis of overall siteimprovement and cost effectiveness, The plan was approved by the USEPA and bythe DER prior to implementation. Briefly, this plan called for the removal of

o

3-12 AR30I5J»2 ©

I"--, exposed drums, installation of an upgradient cut-off wall, and for the site toI be covered with in impermeable composite cap, The cut-off wall was intended

to reduce the volume of groundwater inflow from the upgradient direction. Thecap was intended to virtually eliminate the infiltration of precipitation intothe waste fill, Leachate generation has been reduced by approximately99 percent duo to the cap and cut-off wall, The cap has also proven to beeffective in preventing migration of volatile organic compounds via the airpathway.

Technology Description. The no (further) action alternative consists ofcontinued groundwater monitoring and maintenance of the composite cap,including periodic removal of standing water in "seep" areas adjacent to thelandfill, There are no other remedial activities associated with thisalternative,

O

Public Health and Environmental Protection Standards, Implementation ofthis alternative will not facilitate compliance with public health standardsfor Class II (downgradient) groundwater or reduce future potential humanhealth or environmental risk associated with contaminated surficial soils and"seeps",

Cost Considerations, Estimated costs for continued implementation of theno (further) action alternative are approximately ?100,000/yr,

3.3.2 Limited Action

The limited action alternative consists of the operation and maintenanceelements of the no (further) action alternative with the added task of fencingthe landfill site,

Technology Description, In this alternative, approximatelyfive (5) acres of land would be enclosed within an eight (6) ft high chainlink fence topped with three (3) strands of barbed wire, Several gates wouldbe provided for access, The fencing would be constructed such that the "seep"

AR30I5M' "V\ 3-13

ii trr Mt*u6*<««<<«*<< «<o« on condition oi tkt

areas would be enclosed within the secured site, limiting access to unknowingtresj>«!«Brf and possibly deterlng vandals, ( )

Public Health and Environmental Protection Secured, Implementationof this alternative will not result in compliance with public health standardsfor Class II groundwater but will effectively mitigate against any potentialhuman health or environmental risk associated with contaminated surficialsoils and "seeps",

Coat Considerations, Estimated costs for implementation of thelimited action alternative are $60,000 for capital improvements and 5102,000annually for operation and maintenance requirements, which includes the$100,000 annual cost of the no (further) action alternative,

3,3.3 Near Source Groundwater Collection and Treatment

There are three reasons for collecting groundwater'

• To lower the water table. p^• To contain a contaminant plume.• To treat the groundwater (typically performed in conjunction with

the one of the first two reasons).

For the purposes of source control, groundwater is collected to lower thegroundwater table and/or to contain a contaminant plume near thesource. Lowering the water table to a level which is permanently below thecontamination source (in this case, the landfill) eliminates leachate producedwhen groundwater flows through a waste (see Figure 3-2), Thus, leachate isonly produced by percolation of incident precipitation through the waste or byrelease of stored water from the waste, As discussed previously, both ofthese leachate production mechanisms have been addressed to a significantextent by the construction of an upgradient cut-off (diversion) wall and acomposite cap. At the Shope's site, the Water Table Zone immediately adjacent

AR30I5H3-14 • ' '

•0

OROUND WATIR FLOW

IIFOM »UMPINQ

AFTIR *UMPINO

SOURCE i F.O. Drlseoll, 'Qroundwslsr And Walls',and Edition, me, Johnson Division,t*. MM), Minnesota

LORD CORPORATION - IHOM LAHOf ILLIrli, FWins»l»innlt _____FIQURE 3-2

LOWERINQ THE WATER TABLETO ELIMINATE CONTACT WITH

A DISKM41 BITt _ECKENFELDER

INC

3-is AR30I5I.5

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to the landfill contains site contaminants. If the groundwater is collectedat the Shope's site, it will need to be treated and discharged an discussedlater in this section.

There are several ways to collect and treat groundwater. Collection ofgroundwater can be accomplished by pumping or by interception using subsurfacedriins, Technologies that appear to be feasible for the Lord/Shope Landfillinclude pumping via groundwater extraction wells or (typically) the moreshallow wellpoints, and intercepting the groundwater via a vertical trenchdrain. Treatment technologies and discharge options for the treatedgroundwater are discussed in later subsections, Selection among the use ofwellpolnls, extraction wells, or trench drains depends upon several factorsincluding: general site conditions, site hydrogeologic conditions, required

I pumping time, volume of water to be pumped, and equipment availability.

I The use of near source groundwater collection technologies presupposes that| contaminated groundwater will be present for collection. Section 8 of the RI

report discusses remedial activities performed at the site in 1902 and 1983I and the effectiveness of those activities. Isopach maps of the saturated

wistt fill in July 1981 and July 1984 indicate a significant reduction in theI volume of saturated waste as a result of the remedial activities, These

isopach maps are based upon average conditions, As such, depending uponseasonal groundwater conditions, there may actually be more or less saturated

' waste,

If collection of near source groundwater is determined to be a feasiblealternative for site remediation, the system will be designed as a permanentone, Many factors relating to the design of a temporary system are alsoapplicable to the design of a permanent system. Since permanent groundwaterayitemi must operate continuously, they should be conservatively designed andmechanically simple to minimize operation and maintenance requirements,

( P e r m a n e n t systems are designed so that specified results are achieved duringperiods of high groundwater levels due to natural or man-made conditions,

AR30I5I*63-16 ' "I

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3.3.3.1 Wellpoints.

0Technology Description. Wellpoint systems are groups of closely

spaced wells usually connected to a header pipe or manifold and, pumped fromeach well or as a single system by suction lift. Wellpoint systems arerelatively easy to install and are adaptable to a wide range of siteconditions. They are particularly suited to the following situations;

• Sites where the pumping water level is within suction lift.

•• i Geologic formations with low transmiislvity (i.e., fine sand and/orsilt) where close spacing of the wellpolnts is required,

i

• Near surface formations that overlie relatively Impermeable layersor thin formations where the submergence available for well screens

i i s sma11,

During operation of a wellpoint system, a pump lifts water from each well bys~\ producing a partial vacuum in the header and riser pipes, The partial vacuum,

or suction lift, that a pump can maintain determines the drawdown in eachI wellpoint, The maximum drawdown is the difference between the suction head

and the static water level (Figure 3-3),

Lowering the groundwater level involves creating a composite cone ofdepression, The wells must be placed close enough such that the drawdown fromeach well overlaps with adjacent wells and pulls the water level down aspecified distance at intermediate points between wellpoints, Figure 3-3 is arepresentation of how the overlapping areas of influence around two adjacentwellpoints produces an enhanced drawdown of the water level, In the case of

. source control at the Lord/Shope Landfill, the zone of influence would beintended to intercept any leachate percolating through the waste and into thegroundwater,

AR30I5I*73-17

^

HEADER PIPE-

STATIC .WATER '. . ._.LEVI.L- .' . X

PUMP

o

SOURCE : F.Q, Drlsooll, •Q.roundwitir And Wills',2nd Edition, list, Johnson Division,81, Paul, Mlnnisols

LORD CORPORATION - IHOPE LANDFILLIf Ii, Ptnniylirinli ____

• WELLPOINT FIGURE 3-3SCHEMATICS OF A TVPICAU

WELLPOINT SYSTEM

ECKENFELDER t* . __i j]Q Mahwah,Ncw>ncy

AR3GI5ii83-18

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OIn practice, the maximum suction lift that can be developed is approximately22 to 24 ft minus losses. Therefore, most wellpoint systems are designed forsuction lifts of IS ft or less. The hydraulic conductivity of the Water TableZone and its close proximity to the ground surface makes it well suited topumping. As such, a wellpoint system appears to be well suited to the Shope'ssite for the purpose of containing contaminant migration from the source inthe Water Table Zone immediately adjacent to the landfill.

Groundwater contamination in the vicinity of the landfill is in both the WaterTable and Intermediate Zones, A wellpoint system placed adjacent to thenorthern edge of the landfill would be designed to intercept the contaminatedgroundwater from the Water Table Zone before it flows into the IntermediateZone where it has been observed to migrate in a northerly direction away fromthe landfill, It may also be used to ensure that contaminated groundwatercontinues to exist in the Water Table Zone only in the immediate vicinity ofthe landfill and does not migrate from the source in that upper zone. Suctionlift limitations preclude the use of wellpoints to intercept the IntermediateZone groundwater,

Wellpoints are typically less than 2 in, in diameter and yield less thatI 25 gpm. They are constructed of mesh, slotted pipe, or trapezoidal-shaped

wire wrapped on a rod to form a screen, Spacing depends upon the hydraulicconductivity of the material, the required drawdown, and the depth to whichthe wellpoints can be installed, For the Shope's site, spacing will bedetermined using a detailed three dimensional computer model of the site whichsimulates site behavior determined through observations during both static andtransient (aquifer pump test) conditions.

Public Health and Environmental Protection Standards. The use ofwellpoints as a remedial technology should promote the achievement of Class IIgroundwater quality criteria, A wellpoint system would possibly be wellsuited to the Shope's site for the purpose of containing contaminated leachatefrom the source in the Water Table Zone immediately adjacent to the landfill,

AR30I5V93-19

Cost Considerations, The order of magnitude costs estimated for awellpoint system to intercept Water Table Zone contaminants adjacent to the (\landfill boundary range from $50,000 to $250,000 in capital costs and $10,000to $20,000 in annual operations and maintenance expenditures.

3.3,3,2 Extraction Wells.

Technology Description. Extraction well installations typically pumpmany times the volume of water pumped by an individual wellpoinl. Extractionwells are best suited to the following situations!

• Environments where pumping water levels exceed the maximum suctionlift,

• Geologic conditions with relatively high transmissivity (i.e., sandor sandy soils),

• Geologic formations that extend considerably below the pumping waterlevels allowing deeper wells, greater drawdown, larger area of /?Ainfluence, and larger yields, ^"^

Extraction wells are similar in design and construction to water supply wells.They typically have diameters of six in, or more with relatively long screenssnd a filter around the screen to improve the yield of each well, Typically,in an extraction well system, each well has its own pump and the extractedgroundwater is directed to a single collection or discharge point, Extractionwells may be used in conjunction with a vacuum system if the geologicformation is somewhat fine grained and/or stratified, The addition of avacuum increases the hydraulic gradient to the well,

For source control at the Lord/Shope Landfill, extraction wells could beutilized to lower the water table in the vicinity of the'landfill much thesame way that a wellpoint system would. However, these wells are differentfrom wellpoints in that they have a larger zone of influence. Therefore,

~ AR30I5503-20

pMf?lM.••;. ;":'V;>j:-.&fe4iil

0

o

o

significantly fewer wells might be required to achieve the desired effects,For this option, several wells would be placed near the landfill in such aconfiguration that their overlapping zones of influence would lower the watertable beneath the landfill to a level permanently below the waste.,

To fully intercept all of the contaminated groundwater beneath the landfill,the wells would have to be placed into the Intermediate Zone wherecontaminants have been found to be migrating away from the source. However,the Intermediate Zone is actually a water bearing zone instead of an aquifer.This is because this zone has been found to have a moderately low hydraulicconductivity and, therefore, is not capable of transmitting significantvolumes of groundwater under normal hydraulic gradients. As such, extractionwells completed in the Intermediate Zone for the the purpose of source (ormigration) control may require special provisions, such as a partial vacuum,to be capable of providing the desired drawdown effects. Another alternativewould be to simply use closer spacing for the wells, which would require alarger number of wells and would increase costs.

Extraction wells for source control at the Lord/Shope Landfill are also afeasible option for combination with wells used for migration control. Theaddition of more wells within the contaminant plume north of the landfillwould act to contain and possibly reverse the migration of the plume, Thenumber and approximate locations of these wells for optimum utilization willbe determined using the detailed, three-dimensional computer model of thesite.

Public Health and Environmental Protection Standards. The use ofextraction wells would contribute to the goal of meeting Class II groundwaterquality criteria.

Cost Considerations. Estimated order of magnitude costs for theinstallation of extraction wells for the purpose of source control at thissite range from $40,000 to $75,000 for capital expenditures and an annualoperating cost of $10,000 to $20,000.

AR30I55I3-21 •.

3.3.3.3 Vertical Trench Drain.

Technology Description. Where the geologic formation at a site isstratified with a low permeability material interbeddod with a morepermeable layer and the water in both strata needs to be intercepted, verticaltrench drains are feasible options, The drain is designed to have asignificantly more permeable material in a trench sized to carry the requiredvolume of water. Therefore, trench drains are not effective in highlypermeable material. The groundwater is typically collected in one or moresumps within the trench and pumped to a collection point for treatment anddischarge, The capacity of trench drains can be increased by the installationof a perforated pipe at the base of the trench to conduct water to thesump(s),

A variation of the trench drains can be used in conjunction with wells orwellpoints to conduct perched water to a lower formation where the water ispumped by the wells, In this case, the drain is short or it may even simplybe a borehole filled with permeable material. The advantages of a subsurfacedrain over a well system are the ease of construction and low maintenance.

For the Lord/Shope Landfill, a trench drain could be used to lower the watertable similar to pumping via groundwater wells. A trench would be designedand located to intercept the groundwater table such that the increasedpermeability of the drain material would cause the water level to drop belowthat of the waste in the landfill. Therefore, leachate migration would befurther reduced, The trench would be located adjacent to and downgradientfrom the landfill such that it would Intercept all groundwater flow previouslypassing through the waste.

It could also be constructed down into the Intermediate Zone through the upperaquitard such that water from the Water Table Zone would be transmitted to thelower Intermediate Zone for collection. Collection would then be accomplishedwith a well or wellpoint system.

o

3-22AR30I552 ,' • ' (J

/p\ The material in the drain would consist of a coarse sand or gravel with at'••-•• least two orders of magnitude Increased permeability over native materials,

thus creating a proper hydraulic break, The trench would be lined with igeotextile to prevent migration of fine soil particles into, the coarsematerials, In addition, a number of sumps would be constructed along thebottom of the trench for collection of the intercepted groundwater, Thiswater would then be intermittently pumped for treatment and then discharged,

A trench drain at the Lord/Shope site may not create the desired drawdowneffects due to the depth of the contaminated groundwater and the relativelylarge area over which the groundwater must be lowered, Trenches would belimited in depth due to constructabillty problems, Depths greater thenapproximately 8 ft would require shoring for worker safety and dewatering forconstruction access, In addition, soils adjacent to the landfill, have b»enfound to be contaminated and their excavation during trend* construction, m ybe considered as hazardous waste generation, with accompanying problems. Suhddrains consisting of a column of pervious material used in conjunction W'.th a

— well system may provide equal results at less cost by allowing the groundwater'••s.X in the Water Table Zone to be transmitted to the Intermediate Zone for

extraction.

Public Health and Environmental Protection Standards, Theinstallation of a vertical trench drain system can contribute to the goal ofachieving Class II groundwater quality for this site,

j Cost Considerations, Order of magnitude costs for the installationof vertical trench drains at this site range considerably due to

I unknowns associated with installation requirements, especially the optimumdepth, Capital costs for the installation of vertical trench drain systems

j range from $100,000 to $1,000,000, Annual operating and maintenance costs forthese systems would range from $10,000 to $100,000 per year,

I

L HR30I5533-23

3,3.4 Upgradient Cut-Off Wall Extension

Technology Description, As discussed previously, an upgradientcut-off wall has been constructed along the southern edge of the Lord/ShopeLandfill as part of previous remedial activities (see Figure 3-4), Thiscut-off wall was Intended to divert groundwater flow around and below thelandfill. The RI report demonstrates that the Initial remedial activitieshave been 99 percent effective in reducing leachate. However, there remains asmall volume of saturated waste within the landfill, The source of this water

| is unknown; it is believed to be residual water,

I The RI report indicates horizontal flow in the two upper geologic layers, theWater Table Zone and the Intermediate Zone, is toward the northwest, As such,

| the .cut-off wall currently may not be diverting all groundwater flow aroundthe landfill, To divert any such flow, a wall extension would be placed along

: the remaining perimeter of the landfill to join the ends of the existing wall.' The potential wall extension to form a circumferential wall is shown on

Figure 3-4. Construction methods and materials and the depth and thethickness of the wall extension would match those of the existing cut-off wall.In addition, the extension would be keyed into the existing wall such thatseepage at the connection could not occur. The three-dimensional computermodel will be used to determine potential benefits of a wall extension.

Public Health and Environmental Protection Standards. The extensionof the upgradient cut-off wall will contribute to the goal of attainingClass II groundwater quality criteria.

Cost Considerations. The order of magnitude capital cost for theupgradient cut-off wall extension for approximately 1,500 linear ft is$300,000. There are no operating and maintenance costs associated with thistechnology,

n

AR30I55I*3-24

o

o

P.W'1'U** in t k i '<t 4.4 due to tubttandand colon on condition

3.3.5 In Situ Biological Degradation ..

Technology Description, Biological degradation or bioreclamation Isa technique for treating soil and groundwater contamination by aerobic oranaerobic mlcrobial action, The basic concept Involves altering environmentalconditions to enhance the native microblal metabolism or cometabolism oforganic contaminants, resulting in the breakdown and detoxification ofcontaminants, The technology has been developing rapidly over recent years,and bioreclamation appears to be one of the more promising of the in situtreatment techniques,

The biodegradation method that has reached the most advanced stage . ofdevelopment for in situ treatment is one which relies on aerobic (oxygenrequiring) organisms in the vadose zone. Enhanced indigenous microbieldegradation involves optimizing environmental conditions by providing anoxygen source and nutrients (as necessary) which are delivered to thesubsurface through an injection well or infiltration system. These optimizedconditions enhance the microbial activity, Indigenous microorganisms cangenerally be relied upon to degrade a wide range of compounds given proper (.< •'•,nutrients and sufficient oxygen. Specially adapted or genetically manipulatedmicroorganisms are also available and may be added to the treatment zone,This option would only be recommended as an alternative if preliminary studiesindicated that the indigenous organisms were not capable of suitably degradingthe contaminants of concern.

Anaerobic microorganisms are also capable of degrading certain or&aniccontaminants. Methanogenic consortiums, groups of anaerobes thai [unctionunder reducing conditions, are able to degrade halogenated aliphatic organiccompounds (e.g., TCE) while aerobic organisms cannot. The potential foranaerobic degradation has been demonstrated in numerous laboratory studies aswell as in industrial waste treatment processes that use anaerobic digestersor anaerobic waste lagoons as part of the treatment process, Using anaerobicdegradation as an in situ reclamation approach is theoretically feasible butnot as well demonstrated as aerobic in situ treatment,

AR30I556'

r~\'•

The feasibility of bioreclamation as an In situ treatment technique isdictated by waste and site characteristics. More specifically, those factorswhich determine the applicability of • bioreclamition approach are:

• Biodegradability of the organic contaminants

• Environmental factors which affect mlcrobial activity

• Soil characteristics

• Site hydrogeology

• Internal distribution of disposal debris

' Many of the compounds identified in the groundwater at the Shope's site arei suitable to biological degradation (see Table 3-4), based upon the informationI from traditional wastewater treatment facilities, However, the even and^^^ complete distribution of the microorganisms into the vadose zone of theJ landfill could prove exceedingly difficult, Furthermore, the maintenance of

the necessary saturated condition under the landfill cap would be difficult toachieve and absolutely contrary to the goal of minimizing leachate generation,

!

Public Health and Environmental Protection Standards, Since thistechnology is not fully demonstrated for capped landfills which are notsaturated, it is not clear that the public health and the environmentalstandards applicable to this site will be met.

Cost Considerations. Order of 'magnitude costs for the installationof a biological degradation system for the landfill range from $7,000,000 to$14,000,000 on a capital basis and could require expenditures, for operatingand maintenance requirements of $700,000 to $1,400,000 per year.

AR30I5573-27

oTABLE 3-1

SUMMARY OF ORGANIC CONTAMINANT CHARACTERISTICSRELATING TO SUITABILITY OF IN SITU BIODEQRADATION

AND VAPOR STRIPPING

Contaminant

Acetone8TetrahydrofuransMethyethyiketoneBenzeneCyolohexanoneKethylisobutylketone1-Methyl-2-pentanol2-ButanolIsopropyl AlcoholVinyl chloride1,1-Pichloroethanetrans-1 ,2-DiohloroethyleneTetraehloroethyleneTriohloroethylene

Vapor Pressure,mm HB 6 20 C

89 (5°C)131

77.57616512,32

2,660 (25 C)180200 (1l)0C)1160

Time (mln) to Remove1 g at 5 ml/min,Air Flow UnderIdeal Conditions(Vapor Stripping)

671

192

205185

1,580181

Amenable toBiological

Degradation InHastewaterTreatment

YNYYYYYv (BY ^NYYYY

"compound successfully removed in laboratory, pilot, op field scale vaporstripping study.

AR30I55B G3-28

. . . . . --„. ... ,,.,,,-,..-,,..... -.,-../;••.»•)

j| we jjage <iwd <fc.U inamt it not at ntadablt on. ltgiblt,.at tki-labtl, it it due. to tub4tandand colon on condition oi tht oniginnl pti

---iT riffi ''' '"I"

O

3.3.6 In Situ Vapor Stripping

Technology Description. In situ vapor stripping involves the removalof volatile organics from a soil matrix by mechanically drawing or venting airthrough the unsaturated soil layer. It is usually a relatively inexpensiveoption. Significant costs can occur if vented air needs to be drawn throughactivated carbon or other air pollution control devices prior to discharge tothe environment. The soils are gradually treated as the volatile organics arepartitioned from the soil particles. Volatile organic compounds and soilmoisture are driven into the air phase within the soil pore spaces. The insitu air stripping system must be designed and operated in accordance withsite specific subsurface conditions to maximize the contaminant removaleffectiveness. Models have been developed which maximize the efficiency andminimize the costs for use of in situ vapor stripping at a given site.

Design and operation of an in situ stripping system is based upon the theoryof gas movement in porous media, Air stripping applications at hazardouswaste sites must address the chemical characteristics of contaminant migrationas well as the characteristics of air flow and pressure in the subsurfacesoils, In situ air stripping is receiving more attention as a potentialremedial action alternative where volatile compounds are involved, Thetechnology already has a record In the successful remediation of gasolinespills.

Based upon the knowledge of the site to date, the in situ vapor strippingtreatment of the nonsaturated (vadose) zone beneath the cap offers the mostencouragement. A list of the chemicals found in the groundwater (andextrapolated to have leached from the site but still be present in the soil)is given in Table 3-4, A minimum empirical value of 1,0 mm Hg (vapor precsureat 6B°F) is frequently used as a criterion for a compound to be successfullystripped, Based upon this value, all the compounds listed in Table 3-4 willbe able to be extracted using a vapor stripping process. Another approachbased upon ideal conditions using the ideal gas law also indicates that themajority of the compounds identified to date will be amenable to stripping.

O AR30I559"' 3-29

i***iwi(fa»t1«Vts.i'(.l, j.'tifcjirii«llJ

The value for the rate of removal under ideal conditions is coupled with thefact that those compounds indicated with the superscript "n" in Tnblo 3-4 havn /"""V,been successfully removed in previous air stripping studies, v""

Additional information at the laboratory- and field-scale will be required toconfirm in situ vapor stripping as a viable alternative. Buried debris couldsignificantly reduce the efficiency of this treatment option by creatingpoints of stagnation. Sufficient air flow to strip the volatile organiccontaminants may not reach these areas of stagnation. Small pockets ofresidual contamination could result. It should be noted that the impermeablecap at the Shope's site would need to be violated to permit the collection ofcontaminated soil for laboratory testing and, ultimately, the placement of airvents and stripping wells.

Public Health and Environmental Protection Standards. In situ vaporI stripping is an innovative technology that has a growing record of

demonstrated performance for the remediation of hazardous materials. If thetechnology proves feasible after further analyses and laboratory testing, then

, it is believed that this technology will contribute to the goal of achievingClass II groundwater criteria. U would also reduce the mobility, toxicity,and volume of wastes in the landfill. Chemicals stripped from thecontaminated soils at the landfill may either be vented to the atmosphere orto a fume incinerator or be adsorbed onto activated carbon for subsequentdisposal. Air emissions will require compliance with the State ImplementationPlan and any other state or local air emission standards. The disposal ofcontaminated granular activated carbon may require management as a hazardouswaste. The pertinent federal and state regulations governing the management,transportation, and disposal of these wastes would need to be adhered to.

Cost Considerations. In situ vapor stripping over an area ofapproximately 4,3 acres to a deptli of 10 to 20 ft would require estimatedcapital expenditures ranging from $250,000 to $750,000, Annual operatingexpenditures associated with in situ vapor stripping could range from $50,000to $150,000.

AR30I5603-30

fe " .:5± g g

,..-\. 3,3.7 Excavation

Technology Description. Excavation of the contaminated soils at theShope's Landfill site would provide definitive leachate source control, Thissource control technology would be uied in conjunction with a disposalalternative, i.e., incineration or landfill disposal, Equipment required forthe excavation of contaminated wastes at this site may include backhocs,excavators, a dragline, front end loaders, and dump trucks, This technologyis a conventional and demonstrated practice with a proven performance record.Inherent operation and maintenance problems associated with excavation can bemanaged by routine equipment repair and maintenance,

r.:.^«vation of only wastes and soils associated with the landfill proper isbelieved to be feasible and will be examined further. Excavation and disposalof soils associated with the contamination plume are not feasible due to thelow concentrations of contaminants present.

Partial excavation of exposed drums and grading of the landfill have beenl] performed as part of the initial remedial activities at the site. Additional

excavation may entail removing buried wastes such as rubber scrap, demolitionI debris, wood, paper, and drums and allowing the contaminated soils to remain,

or complete excavation of all wastes and contaminated materials may berequired. In addition, soils beneath the landfill may be excavated to some

, depth to remove the most contaminated material or to a depth whereuncontaminated soils are found, Based upon these potential excavationschemes, the volume of material to be excavated may range from approximately140,000 cu yd to 210,000 cu yd, These estimates are based upon a landfillarea of 4,3 acres and an average depth of 20 ft which represents the entirelandfill volume and the entire volume plus 10 ft of contaminated underlyingsoil, respectively,

Public Health and Environmental Protection Standards, There areinherent potential problems involved in excavating and transportingcontaminated materials, Excavation of any portion of the Lord/Shope Landfill

Q fl??°'56l3-31

b « « « « * v ^ * . a 4labtl, it it due to 4ub4tandand colon on condition oi tkt oniginal

would greatly increase potential risk to remedial contractor employees andpublic health or the environment via airborne particles, such as contaminated f j)dust and organic vapors, Transportation of the contaminated material wouldexpose the public and the environment along the route of transport foroff site disposal options,

Any excavation into the capped landfill would Increase potential risk to humanhealth or the environment and would involve compliance with the entirespectrum of environmental standards and regulations as well as OSHA, DOT, andother ARARs.

Cost Considerations. Excavation of 140,000 cu yd to 210,000 cu ydwould require order of magnitude expenditures of $2,800,000 to $10,500,000depending upon the amount to be excavated, difficulties encountered duringexcavation,and the excavation depth. There would be no on-going expendituresassociated with this technology,

3.3.8 Incineration

Technology Description. Specific potential methods of incinerationfor the Lord/Shope Landfill include rotary kiln, cement kiln, and some typesof multiple hearth incinerators. These types of incinerators are capable ofburning solid, bulk wastes of the type that would be excavated at this site,Some pretreatment of the wastes may be required prior to incineration (i.e.,any saturated waste may have to be physically dewatered or treated to removeexcess water so thnt incinerator efficiency is not adversely affected),

The nearest off site, fixed Incinerator is located in Ohio, near Cleveland.Two other incinerators are significantly further from '.he Shope site and arelocated near Chicago, Illinois and in Mew Jersey near Camden, These threefacilities all operate rotary kiln incinerators and accept the forms and typesof wastes which would be generated at the Shope's site, On site mobileincinerators are available from various contractors for treatment of wastes ata particular site, These mobile treatment facilities may be brought to a siteand set-up and operated exclus.ivelyfor the wastes encountered

'•' 3-32

O

There are advantages and disadvantages to both on site and off siteincineration systems beyond those which are common to both, Incinerationsystems brought on site obviously reduce transportation cost to a minimumsince the wastes need only be moved from one portion of the site, to another.These savings are partially offset by initial set-up costs, but the extent ofthe savings depends on the location of the nearest fixed incinerator; thefarther away it is, the more expensive transportation to the site will be,Another advantage to on site incineration is that once the incinerator inoperational, it will burn only wastes found on site, Therefore, thevariability of the waste is minimized which in turn reduces the potential foroperating problems. However, these mobile systems must obtain operatingpermits for each individual site, This procedure may be time consuming andexpensive,

Off site incineration facilities are already setup and operating, therefore,there are no costs incurred by the generator associated with initial set-up ofthe system or with obtaining operating permits, However, the wastes must betransported to the facility, which may be quite expensive depending upon theproximity of the site to the treatment facility, In addition, these off siteincineration facilities will be Incinerating other wastes from other sites.Therefore, the variability of the material being burned by the off sitefacility is potentially great and the associated costs may significantlyincrease to compensate for variability in heat content, halogen, or otherwaste components. Another consideration is the capability of the incinerationfacility to burn the wastes soon after receipt, Some facilities have largeback-logs which may adversely affect overall implementation time.

In summary, incineration of the wastes at the Lord/Shope Landfill site is afeasible and effective alternative, but the associated costs may prohibit itfrom being the alternative of choice,

Public Health and Environmental Protection Standards, Excavation andincineration of the contaminated soils and materials at the Shope's Landfillconstitute an effective source control action which would significantlycontribute to the goal of obtaining Class 11 groundwater quality standards,

AR30I5633-33

However, excavation and incineration of materials would substantially increasethe risk to public health and the environment associated with waste ( j)excavation, transportation, and thermal destruction, Excavation of thematerials could result in public or environmental exposure to .contaminateddusts and/or organic vapor during the excavation process. Remedial contractorworkers would be at much risk to exposure from these sources. Off sitereleases to the environment during excavation could occur due to stormwaterrun-off or spillage during transportation to an off site disposal facility.

In general, public health and environmental protection standards would beadvanced in terms of groundwater quality at the risk of the release ofcontaminants to the atmosphere and surface waters,

Cost Considerations, The order of magnitude costs for on siteincineration are estimated to range from $42,000,000 to $63,000,000, Off siteincineration of wastes excavated from the landfill would result in costsranging from $64,000,000 to $126,000,000, Transportation costs which must beadded to off site incineration costs are estimated to range from $14,000,000to $24,000,000. ft

w

3.3.9 Landfill Disposal

Technology Description. As a source control technology, landfilldisposal of the wastes in a secure RCRA-permitted landfill would requireexcavation similar to that required for incineration. The wastes would thenbe placed in an upgraded landfill on site or hauled away to a permitted offsite landfill for disposal, Landfilling is a containment technology, Notreatment of the waste at the Shope site would take place, As such, placementin a landfill would simply move the waste to a different, but safer, location.Properly designed landfills control the release of contaminants to theenvironment by significantly reducing the volume which flows through thebottom liner. Thus, the environment is better able to handle thecontaminants,

3-34

«B30l56liG

•n

QI

O

As stated previously, excavation may be performed on the entire landfill orthe entire landfill plus some contaminated underlying soil, Based upon thisrange of options, the volume of material to be excavated may range fromapproximately 140,000 cu yd to 210,000 cu yd (the landfill plus 10 ft ofunderlying soil), The same Inherent potential problems associated withexcavation for treatment of the wastes by incineration are associated withexcavation of the wastes for landfilllng at an upgraded, on site landfill oran off site landfill, As discussed previously, these problems includeexposure of the public and environment to potential dangers which do not existwhile the waste is buried.

Sincn initial remedial activities included grading the sttn, construction of Acomposite cap over the surface, and construction of erosion control ditches,the site may essentially be considered an adequately designed and constructedlandfill, The only missing portion is a bottom liner and leachatedetection/collection system. However, if water flux into and/or through thewaste can be minimized or collected, a bottom liner would not be significantlymore beneficial.

There are two (2) off site, permitted landfills within 200 miles of theShope's site, located near Buffalo, New York. Both are permitted to acceptsome of the forms and types of wastes which would be generated by theexcavation of the Shope's Landfill, Because of the close proximity ofpermitted landfills to the Shope's site, transportation costs would berelatively low, However, transportation costs for an off site landfill wouldstill exceed those for an on site landfill in addition to the threats ofpotential exposure discussed earlier. Another advantage to the off sitelandfill alternative is that operational permits would not be required of thegenerator as they would if an on site facility were to be constructed,

One advantage to an on site facility (upgraded from the existing construction)is the minimized on site hauling costs, However, the current size andcondition of the property on which the landfill lies preclude the constructionof a new, updated landfill system, Additionally, the costs associated with

AR30I5653-35

upgrading to a new landfill are not justified since previous remedialactivities for the existing landfill have proven to be effective and, C |)therefore, a new landfill would not provide significantly beneficial results,

Public Health and Environmental Protection Standards. The landfilldisposal option poses potential violations of a number of public health andenvironmental protection standards, Excavation of the materials would berequired for either on site or off site land disposal. The risks associatedwith excavation and off site transportation have been previously discussed.Landfill disposal would require that the excavated materials be deposited in asecure RCRA-permltted landfill. Due to the land disposal restrictions for"California list" wastes issued by USEPA (40 CFR 268), it is no longerfeasible to dispose of some of the contaminated materials by land disposal,At the very least, pretreatment will be required, increasing the capitalcosts,

Land disposal of contaminated soils or wastes is not consistent with SARAwhich expresses preference for permanent remedies in which treatmentpermanently and significantly decreases the toxicity, mobility or volume of /V 'ithe hazardous contaminants, SARA requires that the remedies should "to themaximum extent practicable" utilize "permanent solutions" and alternativetreatment technologies or resource recovery technologies, CERCLA specificallyaddresses off site transport and disposal of hazardous materials bycharacterizing this option as the least favorite alternative remedial actionwhere practicable treatment technologies are available,

Cost Considerations. Costs associated with on site land disposalinclude the construction of a secure RCRA-permltted landfill equipped withdouble liners, leachate control, and groundwater monitoring elements. Majorcost elements associated with on site land disposal are construction of theRCRA-permitted landfill, excavation, deposit of contaminated materials intothe landfill, and landfill closure and post-closure care and monitoring.Capital costs associated with this option range from $14,000,000 to$21,000,000 with annual operating requirements of $700,000 to $1,050,000.

AR30I5663-36 ,r

u " siS!if ^ jif_

PI

O

The principal cost factors associated with off site land disposal are:excavation of contaminated materials, transportation of contaminated materialsto the landfill site, costs of land disposal at the off site facility, closureof the Shope's Landfill and restoration of the land to former grqde, and longterm liability associated with land disposal options. Off site disposal costsare estimated to range from $35,000,000 to $52,500,000, Transportationcosts would range from $10,000,000 to $19,500,000.

3,3,10 Summary of Source Control Technologies

The most promising source control technology is near source groundwatercollection and treatment. This technology, using wellpoints, an extractionwell system, a trench drain, or a combination thereof, can effectively captureleachate from the landfill and direct any leachate and contaminatedgroundwater to a treatment system.

The use of an intragradient cut-off wall extension may reduce the amount ofleachate collected for treatment, as compared to groundwater collectionwithout the wall extension, but at a much higher cost.

In situ biodegradation in an unsaturated landfill environment is not afeasible technology,

In situ vapor stripping could remove VOCs from the landfill but would notremove non-strippable waste constituents present, In situ vapor strippingwould reduce the volume, mobility, and toxicity of the wastes and will beevaluated further.

Excavation of wastes and contaminated soils must be considered as part ofoff site treatment and/or disposal as well as on site treatment and requiresfurther examination.

Incineration of excavated wastes and soils from the landfill is an establisheddestruction technology that meets the criteria for initial screening oftechnologies and will be evaluated further, noon c

3-37

f c ; . - * " a « . elabtl, 4,t it due to tubttandand colon on condition oi

On site landfill disposal of excavated wastes and soils would require thepermitting and construction of a RCRA-permitted hazardous waste landfill as Q }well as closure and post-closure requirements and continuing environmentalliability, On site Isndfilling without treatment would not . represent apermanent solution nor would the toxicity or volume of the waste be reduced,Off site landfill disposal would require the transportation and disposal ofsignificant quantities of hazardous wastes and contaminated soils to aRCRA-permitted landfill, Landfilling without treatment will not be possibledue to the land disposal ban at 40 CFR 266 and would not represent a permanentsolution, nor would the toxicity or volume of the waste be reduced.Therefore, on site or off site landfill disposal will not be consideredfurther as source control options. .

A combination of near source groundwater collection and treatment with in situvapor stripping could result in the permanent reduction of waste constituentmobility, toxicity, and volume and, therefore, warrants further examination.

Limited action of fencing all or portions of the site should be considered inthe development of the final source control alternatives for the Lord/Shope ;' . site,

Source control technologies which will receive more detailed evaluationinclude;

• Near source groundwater recovery and treatment, with or without acut-off wall extension,

• Excavation and incineration (on site or off site) of landfill wastesand contaminated soils.

• In situ vapor stripping.

• A combination of near source groundwater recovery and treatment,with or without a cut-off wall extension, and in situ vapor

strippine' ' AR30I568 r3-38 !•

o

o

o

3.4 MIGRATION CONTROL TECHNOLOGIES

3.4.1 Groundwater Collection

As stated in subsection 3.3.3, there are basically three reasons forcollecting groundwater. For the purposes of migration control, groundwater iscollected to contain (and In some cases to retrieve) a contaminant plume,This is achieved by stopping and/or reversing groundwater flow at the edge ofthe plume, Therefore, additional contamination of groundwater is halted andexisting contamination may be remediated by collection and treatment ofgroundwater.

Collection of groundwater for migration control is performed in the samemanner as for source control. Therefore, as discussed previously, apparentlyfeasible technologies applicable to the Shope's site include pumping viawellpoints and/or extraction wells and interception by subsurface drains.Selection of the most suitable technology (or combination of technologies)will depend upon general site conditions, site hydrogeologic conditions,required pumping time and volume, and equipment availability. A detailedgroundwater model will aid in this evaluation.

Technology descriptions for the three alternatives are provided insubsection 3.3,3, Only minor differences in application related to sourcecontrol versus migration control exist, These differences are subsequentlydescribed,

3.4,1,1 Wellpoints.

Technology Description. The inherent differences in the definitionsof source control and migration control are reflected in the method ofapplication of a wellpoint system. For migration control, wellpoints would beplaced near the leading edge of or within the contaminant plume, In this waythe wellpoint system will intercept the plume such that the plume is containedand the contaminated groundwater can be extracted for treatment. The

AR30I5693-39

wellpoints would be placed such that the zone of influence intercepts theentire leading edge of the plume. The system may also be placed some distanceupgradient of the edge of the plume to pull it back to a predetermined area.This application of a wellpoint system Is slightly different than that forsource control where the wellpoints prevent migration from the source andisolate it from the rest of the plume.

Public Health and Environmental Protection Standards. Use of awellpoint system as a remedial technology should promote the achievement ofClass II groundwater quality standards. A wellpoint system may be suited forthe Shope's site for the purpose of containing the contaminant plume,

Cost Considerations, The order of magnitude costs estimated for awellpoint system used for migration control range from $75,000 to $400,000 incapita) costs and $15,000 to $25,QUO in annual operation and maintenancecosts,

3.4,1.2 Extraction Wells.

Technology Description. The technology for extraction wells used formigration control is the sane as for source control, The difference is thatfor migration control, a well (or wells) would be located such that the zoneof influence intercepts the leading edge of the contaminant plume such thatthe plume is contained and/or reversed, As stated previously, extractionwells can easily be utilized to act as both a source and migration controlsimply by strategically locating the wells to isolate the source from thegroundwater and to intercept the edge of the contaminant plume, Sinceextraction wells have a larger zone of influence, fewer wells than wellpointsare needed to achieve migration control,

Public Health and Environmental Protection Standards, The use ofextraction wells will contribute to the goal of meeting Class II groundwaterquality standards,

AR30l5703-40 ' . "

o Cost Considerations, Estlmnted order of magnitude coots for theinstallation of extraction wells for the purpose of migration control at thissite range from $75,000 to $150,000 for capital expenditures and an annualoperating and maintenance cost of $20,000 to $30,000,

3,4.1.3 Trench Drains,

Technology Description, The physical location of a trench drain atthe Shope's site is the only difference between its application as a migrationcontrol versus a source technology, Instead of being utilized to isolate thesource, a trench drain would be located to contain the contaminant plume andto collect contaminated groundwater for treatment, One or more trenches couldbe located to intercept all leading edgei, of the plume such thnt containmentis achieved,

Public Health and Environmental Protection Standards. TheI installation of a vertical trench drain system can contribute to the goal of

achieving Class II groundwater standards for this site.

OCost Considerations. Order of magnitude costs for the installation

of vertical trench 'drains at this site range considerably due to unknownsassociated with Installation requirements. Capital costs for the installationof a vertical trench drain system range from $150,000 to $1,500,000. Annualoperating and maintenance costs for the system would range from $10,000 to$30,000.

3.4.2 Groundwater Treatment

Groundwater to be treated at the site will probably include groundwaterextracted from the landfill margin and trom the plume extension. Table 3-5summarizes the preliminarily anticipated characteristics of recoveredgroundwater based upon the Phase I RI, Preliminary conservative estimateswere that the landfill margin would be extracted at a rate of 25 gpm to assuresource control and to prevent contaminant migration; groundwater from the

O AR30IS7I3-41

. ,!, ''", "f",'* Ml'''*'v-' ^ <'"«

TABLE 3-5

ANTICIPATED CHARACTERISTICS OF RECOVERED GROUNDHATERLORD/SHOPE LANDFILL

(PRELIMINARY-PHASE I RI BASIS)

Parameter

PH

Units

s.u.Conductivity M mhos/cmTDSCODChlorideSulfateAsBaCdCrPbAcetoneTetrahydrofuranMethyl Ethyl KetoneBenzeneCyclohexanoneMethyl Isobutyl Ketone1-Methyl-2-PentanolTolueneXylene2-ButanolIsopropyl AlcoholVinyl Chloride1 ,1-Dichloroethane1,1-Diohloroethylenetrans-1 ,2-DiohloroethyleneChloroform1,1,1-TriohloroethaneCarbon TetrachlorideTetraehloroethyleneTriohloroethylene

mg/1mg/1mg/1mg/1mg/1inE/1JIB/1mg/1mg/1us/1us/1Mg/1us/1MS/1ug/1MS/1MS/IMG/1ug/1ug/1ug/1ug/1Mg/1MB/1MS/1MB/1MB/1MS/1MB/1

PlumeExtension(75 gpm)

6.9650516111516

0,0052.1300.0080.0170.035237ND215.67.6195156NDND2178NDNDND10ND18NDNDND

LandfillMargin(25 gpm)

7.51,7651,15918252115

0.0090.890,120,020,111,3561307501925

1,935' 5,235• • 2 5

262,86211,339

7.91611305115192135

Combined(100 gpm)

7.092972613117216

0.0062.010.0360.0180.05151733203912

6301,126

66.5731

3,6132110151317559

AR30I5723-42

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plume extension would be extracted at a rate of 75 gpm, The combined totalgroundwater extraction flow rate was preliminarily estimated to beapproximately 100 gpm. When the plume extension and landfill marginextraction flows are combined, the composite contaminated concentrationsummary should be as that indicated in Table 3-5. Groundwater treatmentsystems will be designed on a preliminary basis for this screening effortusing the combined 100 gpm groundwater characteristics indicated on Table 3-5.The groundwater will be extracted until compliance with Class II groundwaterquality standards is achieved, Pertinent physical and reported treatabilitycharacteristics are provided in Table 3-6,

There ore seven (7) groundwater treatment technologies that arc potentiallyapplicable to groundwater at this site, These include;

• Air Stripping

• Granular Activated Carbon

Activated Sludge With PACT*

• Oxidation by Ultraviolet Light Catalyzed Ozone (or equivalentchemical oxidation processes)

• Biological Treatment at the Local Publicly Owned Treatment Works(POTW)

• Commercial Disposal

• In Situ Biodegradation

There are certain groundwater treatment technology unit operations that may benecessary to support the principal treatment technology and these pretreatmentoperations will be discussed first in this subsection on a case-by-case basisfor each principal treatment technology,

AR30I5733-43

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3.4.2.1 Pratreatment with Granular Media Filtration. In addition tothe major removal processes, some ancillary treatment may be required toeither prepare the water for treatment or to polish the treated effluent.This ancillary treatment would consist of chemical addition, flocculation, andgranular media filtration for suspended solids removal. This may be necessaryto prevent clogging of equipment (i.e., air strippers, GAC adsorbers, andUV-ozone) and to improve effluent quality in the case of biological PACT*,

Technology Description, Each of the on site treatment options mayrequire removal of suspended solids either before or after treatment for theprotection of equipment and process media or to improve effluent quality-Suspended solids removal could utilize chemical addition, in the form offerric sulfate (Fe(SO )j) end polymer, followed by a flocculation step andgranular media filtration,

The ferric sulfate may also serve as a precipitating agent for removal oftrace metals (if required) in the raw groundwater, Ferric sulfate additionwould not be required for treatment of PACT* effluent due to removal of tracemetals by adsorption onto biological floe and the powdered activated carbon inthe system.

A process flow diagram is presented in Figure 3-5, Wastewater, either rawgroundwater or PACT* effluent, flows to the flash mix tank where theappropriate chemicals are added, Ferric sulfate and polymer will be added forpretreatment of raw groundwater, while polymer alone would be added forpost-treatment of PACT* effluent, From the flash mix tank, the water flows toa flocculator where the contents are slowly mixed to provide the necessarytime and energy for particles to coalesce, Following the flocculation step,the water flows to an automatic backwash gravity granular media filter, Thewater passes through a layer of sand or other similar media which traps thesuspended particles, As the filter media accumulates material, the head lossincreases, When a preset head loss is achieved, indicating blinding of the

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filter, the unit begins backwaahing, The backwanhed material then will flowto a storage tank for holding until disposal, Table 3-7 presents pertinentprocess design information.

When the granular media filtration process is used as a presentment step, Hla anticipated that silt and trace metal concentrations will be reduced bygreater than 50 percent. Suspended solids should be reduced to 5 mg/1 frontthe filter. It is not possible to provide accurate estimates of reductions inother constituent concentrations without pilot testing.

Post-treatment of biological PACT* effluent will probably be necessary toreduce effluent suspended solids concentrations. The filter will be capableof reducing effluent suspended solids concentrations to 5 to 10 mg/1 whichwill also reduce associated non-soluble biochemical oxygen demand (BOD). '•

Public Health and Environments! Protection Standards, Use of «granular media filtration system and precipitation system as a pretreatmentstep will contribute to the groundwater cleanup objectives relative to theClass II groundwater quality criteria and will facilitate compliance withsurface water criteria and discharge standards. If the granular mediafiltration system is used with biological PACT* as a tertiary treatment step,then the system will contribute directly to the pollutant load reductions andcontribute to compliance with surface water criteria and standards.

Cost Considerations. The capital and operating and maintenance costsassociated with the granular media filtration system are $250,000 andS46,000/yr, respectively, These costs are based on the process designinformation outlined in Table 3-7.

3.4.2.2 Air Stripping.

Technology Description. Following treatment by granular mediafiltration, the groundwater could pass through an air stripping deviceconsisting of a countercurrent packed tower. Groundwater would be pumped to

AR30I5773-47 ' ' ' ' '

TABLE 3-7

GRANULAR MEDIA FILTRATIONPROCESS DEFINITION

Flow 100 gpra

Influent TSS 30 rog/1

Effluent TSS 5 rog/1

Chemical AdditionFe (S0a) , 35 rcg/1Polymer 3 5 reg/1

Type Flash nix, floooulator, automaticbackwash granular media filter

Flash Mix 2 ft x 2 ft x 2 ft

Floooulator 8 ft 6 in. x 8 ft 6 in. x 5 ft

Filter 8 ft 9 in. x 11 ft B in. x 5 ft

Media Depth 21 in., dual media

Power Requirements 5 hp

Backwash 1,500 gpd

Backwash Storage 5,000 gal

Hydraulic Loading 0,8 gpm/ft

Solids Loading 0,3 Ib/ft2-day

AR30I5783-48

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the top of the column and fall by gravity through the packing. Atmosphericair is forced countercurrent to the liquid flow at typical air to water ratiosof 50:1 by a fan or blower. The off-gas is vented to the atmosphere from thetop of the stripping tower. The treated effluent then flows by gravity fromthe bottom of the tower. A process flow diagram is presented in Figure 3-6.Process design information is presented in Table 3-8,

Air stripping has been shown to be effective in removing greater than90 percent of most volatile organic compounds, however, some compounds are notas amenable to stripping, such as acetone, tetrahydrofuran, methyl ethylketone, methyl isobutyl ketone, and isopropyl alcohol, Depending on the levelof treatment required, it may be necessary to follow air stripping withactivated carbon adsorption or other treatment for removal of less volatilecompounds. Pilot testing is needed to further evaluate this technology,

Public Health and Environmental Protection Standards. The use of airstripping as a treatment technology will assist in the achievement of theClass II groundwater quality standards, Effluent from the stripping unit willprobably meet surface water standards and criteria without further treatmentbut may require treatment by another technology to remove the lees volatileorganic compounds, Because of the extremely low concentrations ofcontaminants found in the groundwater at the Shope's site, it is not believedthat any air quality standards would be exceeded by stripper emissions,

Cost Considerations, Order of magnitude capital and operating andmaintenance costs associated with air stripping are estimated at $50,000 and$36,000/yr, respectively, The costs are based upon process design informationin Table 3-8,

3.4.2.3 Granular Activated Carbon.

Technology Description. Granular activated carbon (GAC) adsorptionis capable of removing most of the Shope's groundwater contaminants to someextent. The GAC adsorbers would follow granular media filtration pretreatment

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TABLE 3-8

AIR STRIPPINGPROCESS DEFINITION

Flow 100 gpm

Type Counterourrent packed tower

Air to Hater Ratio 50:1

Air Flow ' 670 to 1,000 cfm

Power RequirementsFan 2 hpPump 5 hp

Tower DimensionsHeight 35 ftDiameter 3 ft

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(and possibly air stripping) and serve as the final treatment step,Groundwater constituents are adsorbed onto the surface of the carbon through a • { |)variety of mechanisms. A process flow diagram is presented in Figure 3-7,Groundwater which has been pretreated through granular media filtration forremoval of suspended material (which could potentially clog the GAC columns)is pumped through the GAC columns, The groundwater may pass through an airstripper prior to the GAC system to remove volatile compounds and increase thecarbon life, After flowing through the carbon adsorbers the treated effluentis acceptable for final discharge, As the carbon adsorption capacity becomesexhausted, it is replaced with fresh carbon, The exhausted carbon is disposedof at a landfill, or is regenerated for further use,

Process design information is presented in Table 3-9,

Granular activated carbon is expected to reduce the organic constituents by JOto 90 percent with the exception of 2-butanol and isopropyl alcohol which arenot highly adsorbable, The anticipated removals are based on publishedinformation, but pilot testing is required for an accurate determination ofeffluent quality.

Public Health and Environmental Protection Standards. The use of CACas a treatment technology will contribute to the goal of. meeting the.Class II groundwater quality standards. The use of GAC technology will ensurethat the surface water standards and criteria are not exceeded for dischargeof GAC effluent, Spent carbon from the GAC system may constitute a hazardouswaste, Handling, transportation, and disposal of spent activated carbon wouldhave to comply with RCRA and Pennsylvania hazardous waste managementrequirements,

Cost Considerations, Order of magnitude capital and operating andmaintenance costs associated with GAC treatment are estimated at $375,000 and$200,000/yr, respectively, These costs were based on design informationpresented in Table 3-9,

AR30I5823-52 "

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GRANULAR ACTIVATED CARBONPROCESS DEFINITION

Type Downflow adsorber columns

Flow 100 gpm

Number 2

Configuration series operation

Carbon 11,230 ibs

Carbon Usage 100 Ibs/day

. • Hydraulic loading 1.3 gpn/ft

Empty Bed Contact Time 30 min

Power Requirements 20 hp

AR30I581*

3-54

3.4,2.4 Biological Powdered Activated Carbon Treatment (PACT).

Technology Description. The biological powdered activated carbontreatment system (PACT*) operates essentially aa a standard activated sludgesystem, The major difference is that powdered activated carbon (PAC) is addeddirectly to the aeration basin to enhance treatment efficiency, The PACadsorbs wastewater constituents that may be difficult to degrade, thusimproving treatment efficiency over that for standard activated sludge,

Figure 3-8 presents a process flow diagram of the PACT* system, Nopretreatment is required, therefore, the influent from the groundwaterrecovery wells is pumped directly to the aeration basin, PAC is added dailyto the aeration basin in a prescribed dose where it comes in contact with thegroundwater and biological solids which grow in the aeration basin. Thebiological solids metabolize organic compounds in the groundwater while thePAC provides a growth medium as well as adsorption sites for non-degradablecompounds. Some adsorption of heavy metals will also occur. Oxygen is addedto the aeration basin for biomass metabolism through aeration of the liquidwhich also provides mixing. Nutrients are added for biomass growth.

The biomass, PAC, and groundwater mixture, collectively known as mixed liquor,then flows to a clarifier where suspended solids, i.e., biomass and PAC, areseparated from the liquid. Polymer is added prior to the clarifier to enhancesolids separation. The majority of the settled solids are returned (recycled)to the aeration basin while a portion are wasted from the system. The wastesolids are transferred to a holding lank where they are concentrated prior tofinal disposal.

The PACT* process may need to be followed by a granular media filtration unitas described previously for removal of residual suspended solids. Processdesign information is presented in Table 3-10.

It is anticipated that the PACT* process might remove 80 to 90 percent of allof the organics. The organic groundwater constituents will be either

AR30I5853-55

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TABLE 3-10

BIOLOGICAL PACT*PROCESS DEFINITION

Plow 100 gpm

Type PACT

Configuration Concentric aeration baain/clarlfler withintegral sludge storage tank

VolumeAeration Basin 29,200 galSludge Storage 15,700 galClarifier 25,000 gal

DimensionsAeration Basin 31 ft 0Clarifier 20 ft 0Depth 13.67 ft

Thickened Haste Sludge 50 Ib/dayConcentration 6 percent solidsVolume 100 gal/dayPower Requirements 310 kwh/dayCarbon 30 Ibs/dayPolymer 1 Ib/dayNutrients 2 Ib/day

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biodegraded or adsorbed onto the carbon, thus providing effluent qualityacceptable to discharge. However, it would be exceedingly difficult tosustain any active biomass with the very low concentrations of organiccontaminants (substrate) in the extracted groundwater, The expected removalsare based on past experience with the process; bench or pilot tests wouldprovide definitive performance data,

Public Health and Environmental Protection Standards, The use ofPACT*technology for groundwater remediation could contribute to the remedialgoal of meeting the Class II ground-water quality standards. Properlydesigned PACT* systems typically discharge effluents extremely low in residualcontaminant concentrations. PACT* technology should be able to discharge aneffluent which will meet the surface water quality standards and criteria.The sludge generated by the plant is not expected to be hazardous, however,testing would be required to confirm this.

Cost Considerations. Order of magnitude capital and operating andmaintenance costs for a PACT* system are estimated at $700,000 and $85,500/yr,respectively, These costs are based on design information presented inTable 3-10.

3.4.2.5 Ultraviolet - Ozone Oxidation.

Technology Description. Oxidation using ozone with ultra violet (UV)light to catalyze the reaction has been found to be effective for removal oforganic compounds associated with this groundwdter. Removal of silt andinorganics such as metals would require a chemical addition and filtrationpretreatment step as described previously.

A process flow diagram for the ultraviolet-ozone oxidation process ispresented in Figure 3-9. Effluent from the granular media filtration itep ispumped through the UV-ozone unit where ozone, generated on site, is added.The water flows through a closed vessel with intense ultraviolet lightdirected to the water.

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Organic compounds are eventually oxidized to CQj and water thus providingnearly complete removal of organic compounds, The treated effluent then flows f j)to the final discharge point.

Pertinent process design information is presented in Table 3-11. Bench orpilot testing would be required to confirm design criteria.

Ultraviolet ozone systems have been demonstrated to clean contaminatedgroundwater to less than drinking water standards at some sites. Removals of60 to 90 percent arc expected for the Shope's site.

Public Health and Environmental Protection Standards, The use ofUV-ozone oxidation will contribute to the goals of achieving Class IIgroundwater quality standards and assuring that surface water standards andcriteria are not exceeded, There are no sludges or significant atmosphericcontaminant releases associated with ultra violet-ozone treatment,

Coat Conaiderations, Order of magnitude capital and operating andmaintenance costs associated with the ultra violet-ozone treatment system are /Q!N

\li>';yestimated at $450,000 and $105,000/yr, respectively. These costs are based ^-'upon the process definition information presented in Table 3-11. ' (Note;Chemical oxidation utilizing hydrogen peroxide may provide equivalent resultsand order of magnitude costs should be similar to those for the UV-ozoneprocess.)

3.4.2.6 Summary of On Site Treatment Technologies. Severaltreatment technologies are capable of achieving the expected desired levels ofeffluent quality, Various process components can be put together to improvetreatment efticiency, such as stripping followed by GAC, or PACT* followed byGAC. This would be required if a higher level of treatment was necessary,Table 3-12 presents a summary of the possible treatment processes with thelevel of treatment potentially achievable by each.

AR30I5903-60

TABLE 3-11

ULTRAVIOLET - OZONEPROCESS DEFINITION

Flow 100 gpm

Type Ultraviolet - ozone oxidation

PowerOzone 22 kwUV 11 kw

Hydraulic Retention Time i|8 min

Volume i| ,800 s&l

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Air stripping with filtration Is the most cost affective option, however, thequality of effluent may not be high enough for discharge to nurfaco waters,

• The-biologic«l~PAOT»-procesB--is-'not-an-«ttr«ctive-technology-due to the lowcontaminant (substrate) concentrations available for supporting biomass growth.PACT* with GAC polishing is the highest cost alternative but may achieve ahigh level of treatment, while chemical oxidation (UV-ozone) providesequivalent treatment capacity at « slightly lower cost, Based on thisanalysis, there appears to be no justification to consider PACT* or PACT* withGAC polishing beyond this point.

3.A.2.7 Local POTW.

Technology Description. Treatment of the contaminated groundwatercould poisibly be accomplished at the local POTW. Croundwater from thelandfill site could be pumped to a city sewer line located approximately fourmiles away from the site. The groundwater would be diluted with the normalsewage flow, then treated In the existing wastewgter treatment facility.

The only capital equipment item required for this treatment option wouldconsist of a lift station and pipeline from the landfill site to the nearestsewer, a distance of approximately four miles. The impact of the groundwateron the existing facility would be highly dependent on the actual flow and thedesign capacity of the existing plant.

The addition of groundwater to the existing POTW facility flow could cause adeterioration in effluent quality from the POTW. ECKENFELDER INC. conducted alimi'.od site inspection of the POTW operated by Girard Borough in October 1967.The POTW is a small conventional biological treatment facility which treatssanitary wastewater from the Borough only. The anticipated groundwater flowfrom the Lord/Shope site of 100 gpm or 144,000 gpd represents a populationequivalent of roughly an additional 1,000 to 1,500 people, It is doubtfulthat such a relatively large additional flow could be handled by this smallPOTW.

AR30I5933-63

Public Health ind Environmental Protection Standards. The use ofthis treatment and discharge option could promote improvements in groundwaterquality toward achieving the Class II groundwater quality standards, However,the limited capacity of the POTW would cause violation of their NPDESdischarge permit if the Shope's site flow were received. Discharge to thePOTW must be in accordance with th« requirements of the national prelreatmenlprogram and/or any local protreatmont ordinance applicable to the treatment ofthese waters,

Cost Considerations. The order of magnitude capital and operatingand maintenance costs associated with the treatment of groundwater it thelocal POTW are estimated at 81,580,000 and S102,000/yr, respectively, Thecosts are based on installation and maintenance of a four mile pipeline to thecity sewer and sewer charges related to the dally flow of groundwater,

3,A,2,8 Commercial Treatment,

Technology Description, Commercial disposal would involve thetransport of groundwater to a commercial treatment facility which would thentake responsibility for processing and discharging the treated groundwater,

In this option, the raw groundwater would be transported by a 5,000 gal tankertruck to a commercial disposal site located in New Jersey, Approximately30 round trips per day would be required to handle the 150,000 gal per dayestimated groundwater flow. Once at the treatment facility the groundwaterwould undergo neutralization, primary clarification, and biological PACT*treatment, with the final effluent discharged to the Delaware River.

The effluent quality from the commercial treatment site will be highlydependent upon the other wastes being treated with the groundwater. Theaverage flow of the commercial treatment facility is approximately 40 mgd,hence the groundwater will only contribute approximately 0.3 percent of thetotal flow and even less of the organic load, The effluent quality from thecommercial plant should not, therefore, be impacted by the groundwater,

AR30I59I*3-64

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However, it should be noted that there may be severe environmental penaltiesfor transporting the groundwatcr over such long distances, The probability ofaccidents leading to spills Involving the transportation vehicles increasesproportionally to the number of vehicle-miles driven and the number ofvehicles in use, For this particular case, at least 30 tanker trucks would berequired with each covering approximately 450 miles each way for a total of900 miles per trip, This results in a requirement of 60 vehicles, 30 goingeach way each day, The total miles covered would be 9.8 million miles peryear, The expense and logistics make this option unacceptable, both from anenvironmental aspect, (i.e., spill potential) and from a cost aspect.

Public and Environmental Health Standards. Treatment of recoveredgroundwater from the Shope'a Landfill property should not cause the commercialfacility to violate Us existing NPDES standards, Discharge of the treatedgroundwaters should not exceed any New Jersey surface water standards orcriteria for discharge into the Delaware River, Because of the high volume ofgroundwater shipped to the treatment facility, risks to human health and theenvironment exist as a result of traffic accidents, tanker spillage, andother stresses to the environment related to the consumption of raw materialsand environmental emissions associated with over-the-road transportation,Implementation of this option would produce less environmental and publichealth benefit than other options available,

Cost Considerations. Order of magnitude capital and operating andmaintenance costs associated with contract disposal of the groundwater areestimated at 55,000,000 and ?29,500,000/yr, respectively,

3.4.2,9 Summary of Off Site Treatment Options, Neither off sitetreatment option is particularly attractive in terms of cost and benefit topublic health and the environment, Treatment and discharge via the local POTWis not a valid option due to the limited treatment capacity, The option oftrucking raw groundwater to a commercial disposal site located in New Jerseyis not a feasible option, Extraordinary costs for such an option would beassociated with increased risk to public health and the environment as a

AR30I5953-65

result of its implementation. For these reasons, off site shipment and _.treatment of contaminated groundwaters in a commercial facility will not be I. Jconsidered further.

3,4.3 In Situ Biological Degradation

Technology Description. In situ biological degradation technologyfeatures the use of indlgeneous or supplemental bacteria which metaboliteorganic contaminants in groundwater, The rate and effectiveness ofbiodegradation can be enhanced by providing oxygen and nutrients which aredelivered to the subsurface through an injection well or an infiltrationsystem. Anaerobic organisms in the subsurface environment are also useful inthe degradation of certain organic contaminants and are able to degradecertain compounds, such as aliphatic organic compounds (e.g., TCE), whereaerobic organisms cannot. The compounds Identified in the groundwater at thissite appear to be suitable to biological degradation (see Table 3-4).However, in order for this technology to be effective, it is essential thatadequate distribution of microorganisms into the Intermediate Zone of thecontamination plume be accomplished. Furthermore, the extremely low levels of /-$Ncontaminants in the groundwater and soils, coupled with the relatively highsolublities of these chemicals, offer little advantage to an in situbiological process as compared to above-ground treatment systems.

The feasibility of employing in situ biodegradation as a migration controltechnology depends upon a number of site specific factors;

• Biodegradability of the organic contaminants,

• Environmental factors which affect microbial activity.

• Soil characteristics,

• Site hydrogeology,

AR30I5963-66

O• Distribution of contaminants within the groundwater plume in the

Intermediate Zone.

Preliminary analysis indicates that this treatment technology is ,not a viableoption.

Public Health and Environmental Protection Standards. Implementationof the in situ biodegradation technology option is not recommended because itis uncertain if this technology can restore groundwaters to meet Class IIgroundwater quality standards. There are no other public health orenvironmental standards directly associated with this option.

Cost Coniiderations. Order of magnitude capital and operating andmaintenance costs associated with in situ biodegradation of the groundwaterplume are estimated at $500,000 to $1,500,000 and $50,000 to $150,000/yr,respectively.

3.4.4 Treated Groundwater Discharge

Several options for discharge of treated groundwater from the Shope site wereidentified. These options were subjected to an initial screening to identifythose which are worthy of consideration in subsequent remedial alternativesdevelopment, As summarized in Table 3-13, for technical and economic reasons,four of the identified options (Nos. 4, 5, 6, and 7) were initially discarded:discharge to Lake Erie, discharge to the Girard sanitary sewer, groundwaterrecharge, and transport to an off site location, The remaining alternativesare discussed below.

3.4,4.1 Discharge Co Tributary of Elk Creek. The unnamed tributary ofElk Creek which traverses the western bound of the site is the closestpotential receiving water for discharge of treated groundwater. It isexpected that the 7Q10 stream flow in this tributary is on the order of 1 to2 cfs, This discharge point is close to Lord Corporation's property and would

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Orequire one property easement for the discharge piping, Capital and operatingand maintenance costs for this discharge alternative are preliminarilyestimated at 550,000 and 55,000/yr, respectively.

3,4,4.2 Discharge to Elk Creek. Elk Creek is located approximately1,5 miles from the project site. The higher stream flow (as compared to thetributary) affords greater assimilative capacity, However, numerous propertyeasements would be required for the discharge piping, Capital and operatingand maintenance costs are estimated at $800,000 and $25,000/yr, respectively,

3,4,4.3 Discharge to Crooked Creek, Crooked Creek is located roughly1.5 miles from the project site, While it may afford a higher stream flow ascompared to the Elk Creek tributary, its special protective designation (HighQuality) may restrict discharge limits, As with Elk Creek, a number ofproperty easements would be required. Capital and operating and maintenancecosts are estimated at $800,000 and $25,000/yr, respectively,

3,4.4,4 Comparison of Remaining Discharge Options, Capital costs fordischarge to either Elk Creek or Crooked Creek are preliminarily estimated at$800,000, These are more than an order of magnitude greater than the $50,000estimated cost for discharge to the tributary of Elk Creek, Given therelatively low volume projected for treated groundwater discharge (100 gpm or0,22 cfs), and the adequate flow volume in the tributary (worst case estimatedat 1 cfs), there is no reason to discharge to the main streams of either ElkCreek or Crooked Creek.

3.5 RESULTS OF THE THREE-DIMENSIONAL GROUNDWATER FLOW MODEL

A three-dimensional groundwater flow model (Modflow) has been calibrated forthe Lord/Shope site and utilized in the selection of groundwater collectionsystems and in their conceptual design, The model is described in Appendix A,Conclusions of the modeling effort are presented below,

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Due to the steepness of the water table gradient and the relatively lowpermeability of the shallow soil, further extension of the cut-off wall wouldbe largely ineffective.

Near source groundwater recovery systems would be effective as a containmentapproach. The systems must include both the Water Table Zone and theIntermediate Zone. Model results show that for the Water Table recoverysystem to be effective, water levels must be lowered to within 3 ft of thebottom of the aquifer. The recovery system should collect groundwater alongthe weit and north perimeter of the landfill, over a total linear distance ofapproximately 1,000 ft. Although a trench drain could be used, the requireddepth of installation (up to 30 ft in some areas) and the need to dewaterduring construction favor the use of a wellpoint system. Wellpoints need tobe spaced on 25 ft centers. It is expected that this system will recover 15to 20 gpm.

Groundwater from the Intermediate Zone along the landfill perimeter can bestbe recovered with 5 to 8 extraction wells along the same general alignment asthe wellpoint system. The total flow of recovered groundwater anticipated is5 to 10 gpm from this zone,

A downgradient plume recovery system would be effective as a capture approachin the Intermediate Zone, This would require five extraction wellsstrategically placed within the bounds of the plume, The maximum anticipatedyield from the plume is in the range of 25 to 50 gpm.

3.6 TREATABILITY STUDY FOR IN SITU VAPOR STRIPPING

During the Phase II RI, <ind in support of this FS, ECKENFELDER INC. conductedfc treatability study to assess the potential applicability of in situ vapor•tripping (ISVS) as a remedial technology for source control at the site.This study included field investigations with a portable ISVS unit, laboratorysimulations, and preliminary mathematical modeling. The report for the study

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In provided us Appendix B. Conclusions of the t r e n t a b t l i t y study arcsummarized below.

ISVS is a feasible remedial technology both for the waste in the landfill andfor shallow soils adjacent to the landfill which contain volatile organicchemicals. In situ vapor stripping is consistent with the goals of SARASection 121 which gives preference to permanent treatment technologies whichreduce the volume, mobility, or toxicity of chemicals at n site. Preliminarydata indicate a 68 to 99+ percent removal of volatile organic constituentsfrom the soil adjacent to the landfill is possible, Preliminary mathematicalmodeling indicates reasonable cleanup times to effect remediation, Both thelandfill and the adjacent soil produced appreciable amounts of volatileorganic compounds when field tested with the portable ISVS unit. It isrecommended that additional pilot scale studies be performed using in'situvapor stripping to further define full scale design.

3.7 GROUNDWATER TREATABILITY

Based upon the results of the Phase I Ri, potential remedial technologies forthe treatment of contaminated groundwater were identified and subjected to apreliminary screening analysis (see Section 3,4,2). The results of theinitial screening were that air stripping, granular activated carbonadsorption, and chemical oxidation were potential groundwater treatmentprocesses that were worthy of further evaluation, U was expected that theseunit operations would be preceeded by filtration for control of suspendedsolids.

ECKENFELDER INC. conducted a treatability study to evaluate viable unitprocess both alone and in combination, The evaluations were conducted using aprepared groundwater solution and bench-scale techniques and were supported bytheoretical analyses of process performance for selected organic compounds.

O AR30I60I3-71

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The results of the treatability study are provided in Appendix C, Theprocesses evaluated were;

• Volatilization by air stripping

• Chemical oxidation using hydrogen peroxide without catalyst,peroxide with reduced iron as catalyst, and peroxide withultraviolet (UV) light as catalyst

• Chemical oxidation with ozone without catalyst

• Granular activated carbon adsorption

• Biological activated carbon (a variation of the adsorption process)

Bench-scale studies focused on the semi-volatile compounds, and these resultswere supported by theoretical analyses of unit process treatment performancefor the volatile compounds. The results were combined to project the liquidphase and off-gas effluent concentrations from the overall treatmentfacilities using alternative operations, The principal conclusions of thetreatability studies were as follows:

• Air stripping of the semi-volatile compounds was poor.' It isanticipated that air stripping would remove greater than 90 percentof the volatile organic compounds present in the groundwater.

• Hydrogen peroxide without catalytic assistance had no effect on theremoval of the semi-volatile compounds,

• Hydrogen peroxide oxidation with UV light as catalyst would require, excess UV equipment and long reaction times,

• Hydrogen peroxide oxidation with ferrous iron as a catalysteffectively reduced all of the semi-volatile compounds exceptacetone and isopropyl alcohol,

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t Ozone treatment of the groundwater would effectively reduce mm ofthe semi-volatile and volatile organics at reasonable contact times,However, the concentrations of acetone and isoprqpyl alcoholincreased during ozonation.

• Biological activated carbon treatment of the semi-volatile compoundsprovides lower effluent concentrations than granular activatedcarbon adsorption. Telrahydrofuran was not removed by eithertreatment alternative.

The quality characteristics of the recovered groundwater have been modifiedsomewhat based upon the results of the Phase II RI project, Several compoundswhich were previously expected to be present it trace concentrations weredeleted from further consideration based upon the confirmatory GC/MSanalytical work during the Phase II RI, and one compound (chlorobenzene) wasadded to the suite of chemicals expected to be present in the recoveredgroundwater. In addition, several of the organic compounds have differentconcentrations as compared to those that had been originally anticipated, Theexpected characteristics of the recovered groundwater from the site, basedupon current information, are summarized in Table 3-14, These characteristicswere determined by utilizing the groundwater quality data in Tables 1-3 and1-4 and assuming flow contributions of 20, 10, and 50 gpm from the watertable - perimeter, intermediate zone - perimeter, and intermediate zone -plume, respectively, Although the combined groundwater extraction rate isprojected at 80 gpm based upon the groundwater modeling results, the volume ofgroundwater flow to be treated has been conservatively Increased to 100 gpm toprovide some flexibility once the recovery systems are started and fine-tuned,

To determine allowable discharge concentrations for the treated groundwaterentering the unnamed tributary of Elk Creek, appropriate surface water qualitystandards and criteria were selected from Table 2-5 and were utilized inconjunction with upstream concentrations (if any) to calculate allowabledischarge concentrations, The low flow stream discharge was conservatively

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itltcUil Hi I cfi, and combined with the maximum anticipated groundwaterdischarge of 100 gil/mln (0,22 cfs), to calculate the allowable discharge /Oiconcentration! presented in Table 3-15. From comparison of these allowableconcentrations with the characteristics of the recovered groundwater, it isapparent that there Is only one parameter for which some form of treatment, isrequired -- iron, For the other compounds and elements, since water qualityconsiderations do not control the allowable discharge quantities, and thereire no directly applicable effluent limitation guidelines, the quality of thetreated groundwater discharge and the selection of the treatment processesshould be based upon best engineering judgment, Given these considerations,and the results of the bench-scale treatability studies, air strippingis selected for groundwater treatment and it will be necessary to precedethis unit operation by coagulation/flocculation and solids separation for ironremoval,

3,8 TECHNOLOGIES TO BE CARRIED FORWARD TO ASSEMBLY OF ALTERNATIVES

The technology screening process for the Lord/Shope site has resulted in theselection of a wide range of potential remedial technologies that are worthy /-ôf further consideration, These source control and migration control V_:-technologies are summarized in Table 3-16,

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TABLE 3-15

DETERMINATION OF ALLOWABLEGROUNDWATER DISCHARGE CONCENTRATIONS

Parameter

BenzeneChlorobenzene1,1-DichloroethaneTetraohloroethyleneToluenetrans-1 ,2-DiohloroethyleneTriehloroethyleneVinyl chlorideMethyl ethyl ketoneMethyl isobutyl ketoneAcetoneTetrahydrofuranl-Methyl-2-pentanolCyclohexanone2-ButanolIsopropyl alcohol

AraenicBariumCadmiumChromiumIronLeadZinc

GoverningStandard orCriterion(Kg/I)

12850..139330

1,350150»

1,500830500

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1,50050110

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(Mg/1)

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Concentration0"g/l)

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4,0 ASSEMBLY OF REMEDIAL ALTERNATIVES

4,1 INTRODUCTIONt O

A number of potentially effective remedial action technologies for theLord/Shope Landfill were identified and screened in Section 3, Thetechnologies which passed preliminary screening have application to sourcecontrol and migration control, Five remedial sction alternatives have beenassembled from these technologies, The NCP requires that a no actionalternative be developed for comparative purposes and to show the impact uponhilmin health and/or the environment if no remedial action were to be taken,

The RI and the Risk Assessment showed that site contamination at the landfillcould produce a threat to human health by ingestion of soils in the seep areasand other areas, Human health risks were also found to exist if groundwaterIn the near vicinity of the landfill (and from the off site plume) were to beconsumed in the future. Site access control would prevent any risk due tosoil ingestion. The most feasible solution for restricting site access is tofence the entire 4,2 sere Itndfill and the area immediately surrounding the ,-,,landfill, This should be included as a component of all remedial actions --Jother than the no action alternative,

4,2 SOURCE CONTROL TECHNOLOGIES

Fast remedial actions, including the installation of an upgradient cutoff walland a landfill cap, have reduced leachate generation from the landfill by atleast 99 percent, The smill amount of leachate generated might be sufficientto produce a future potential risk to human health via the groundwater pathway,For this reason, a source control remedial action alternative was deemednecessary, Effective source control technologies were found to include thefollowing;

• groundwater collection using wellpoints for the Water Table andextraction wells for the Intermediate Zone

• in situ vapor stripping AR3Q|fiflQ• excavation and incineration - • • „

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4.3 MIGRATION CONTROL TECHNOLOGIES

Groundwater constituent concentrations and flow direction have been wellestablished in the RI. Groundwater modeling in the plume/plume extension areashows that effective migration control can be achieved by groundwater recoveryusing extraction wells. These wells would be screened in the IntermediateZone snd the groundwater extracted would be pumped to anon site groundwatertreatment plant for treatment,

Since groundwater could be used in the future by private residencesdowngradient of the site, it is necessary thit the migrating plume be capturedand its migration arrested. Given the sizes of the source control andmigration control groundwater recovery systems, it is logical to plan on onecombined treatment system for these waters,

Effective migration control remedial actions were found to include thefollowing elements!

> Groundwater recovery using extraction wells in the IntermediateZone,

• Groundwater treatment using Iron removal and air stripping.

( • Discharge of treated groundwater to a tributary of Elk Creek.i

A brief summary of the remaining screened technologies and their assembly intoremedial action alternatives is presented in the following section.

4,4 ASSEMBLED REMEDIAL ACTION ALTERNATIVES

Since effective remediation of the site requires both source and migrationcontrol technologies including groundwater treatment, assembly of remedialaction alternatives is easily achieved,

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4.4,1 Remedial Action Alternative No, 1

The NCP requires that a no action alternative be carried through all of theevaluation procedures, The no action alternative is the first remedial action'alternative considered.

4.4.2 Remedial Action Alternative No. 2

A second remedial action alternative involves source control and plumemigration control by groundwater extraction using wells and wellpoints.Groundwater would be extracted from near the fill area (source control) andthe area north of the landfill in the migrating plume (migration control)continuously, This groundwater would be pumped to an on site groundwatertreatment system, The groundwater treatment system would provide pretreatmentof groundwater for iron removal and air stripping for the removal of volatile (j\jorganic compounds, The treated groundwater would be discharged to thetributary of Elk Creek.

4,4.3 Remedial Action Alternative No, 3

A third remedial alternative involves source control using in situ vaporstripping and source and plume migration control using wellpoints andextraction wells, Groundwater extracted would be treated in an on sitegroundwater treatment facility and discharged to the tributary of Elk Creek,as described above,

4,4,4 Remedial Action Alternative Nos, 4A and 4B

Option No, 4 is a two-part option and involves excavation of the fill ares forsource control and destruction of the excavated materials either by on site or

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off site incineration. These remedial options are combined with plume >*•».migration control, followed by groundwater treatment and discharge as '"'described above. Source control by groundwater extraction and treatment isalso included In this option, for at least some period of time after sourceremoval is completed.

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• • ' • ' ' ' ' - ' , ' . '• '

5,0 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVESc oIn Section 45D, appropriate technologies were assembled into remedialalternatives, The remedial alternatives have been developed and evaluated Inaccordance with the evaluation criteria specified in the NCP,

5,1 INTRODUCTION

Under CERCIA, remedial actions must meet the cleanup standards specified InSection 12) as well as other standards and requirements, The SARA amendmentshave added new requirements to CERCLA for the development and implementationof remedial actions, CERCLA requires that remedial actions:

• utilize treatment which permanently and significantly reduces thevolume, toxicity, or mobility of the hazardous substances,pollutants, or contaminants;

• be cost-effective;

@• attain ARARs (or obtain specific ARAR waivers);

• be protective of human health and the environment; and

• utilize permanent solutions and alternative treatment technologiesor resource recovery technologies to the maximum extent practicable,

In evaluating alternative remedial actions, CERCLA also requires that thelong-term,effectiveness of each alternative be taken into account includingthe following!

• long-term uncertainties associated with land disposal

• the goals, objectives, and requirements of the Solid Waste Disposal

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i the persistence, toxicity, mobility, and propensity to bioaccumulate' hazardous substances and their constituents

• short and long-term potential for adverse health effects from human' exposure

: > long-term maintenance cost

, • the potential for future additional remedial action costs if theaction were to fail

• > the potential threat to human health and the environment associatedwith excavation, transportation, and redisposal or containment •

USEPA has developed nine evaluation criteria which are intended to assure thatthe requirements of CERCLA and the NCP are meet, These evaluation criteriaare:

O"^ • overall protection of human health and the environment• compliance with ARARs• long-term effectiveness and permanency> reduction of toxicity, mobility, or volume

| • short-term effectiveness• implementability

I • cost• stnto acceptance

I • community acceptance

The remedial action alternatives developed in this section were evaluatedi according to these criteria and in accordance with the guidelines published by

USEPA in Guidance for Conducting Remedial Investigations and FeasibilityStudies Under CERCLA (EPA/540/2-89/004), and other guidance documents,

O AR30I6I65-2 , . . . . . . . .

5.2 DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES

5.2.1 Alternative No. I—No (Further) Action

A No Action alternative is required by the NCP to be fl part of the detailedanalysis of alternatives, However, this site has already undergonesignificant remedial action including the installation of an upgradient cutoffwall and a RCRA hazardous waste-equivalent landfill cap, These remedialactions were taken to reduce groundwater migration and risk of exposure towastes at the landfill, These remedial actions have proven to be extremelyeffective in meeting their objectives. Lord Corporation has been periodicallyinspecting and maintaining the cap since the closure was completed. Otheractivities include period!? groundwater monitoring and pumping/off iltedisposal of standing water in the so-called "seep" areas.

5.2,2 Alternative No. 2--Source Control and Migration Control byGroundwater Extraction, Croundwater Treatment, and Discharge to Surface Water

This remedial alternative encompasses fencing the landfill area and theextraction of groundwater in the immediate vicinity of the landfill as well asthe plume area north of the landfill, as identified in the RI report. TheWater Table Zone and Intermediate Zone groundwaters would bo pumped to a

' groundwater treatment facility for treatment prior to discharge to thetributary of Elk Creek,

5,2,2,1 Access Control, Approximately 5 acres of land, including thelandfill, would be enclosed by an P ft high, chain-link fence topped withthree strands of barbed wire, Locked access gates would be located atstrategic intervals, Groundwater treatment facilities would be located withinthis fenced area, as would the two groundwater extraction systems near thelandfill, This security measure should prevent unknowing site entry anddiscourage vandalism,

AR30I6I75-3 •'• ""

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5,2.2.2 Groundwater Extraction.

Source Control by Groundwater Extraction, Near source recovery ofgroundwater was determined to be an effective technology for containment ofthe groundwater plume emanating from the landfill. The presence of subsurfacecontamination at and near the landfill requires that a remedial alternativebe designed which would ensure collection of both the Water Table Zone and theIntermediate Zone along both the north and west sides of the landfill, Thetotal linear capture required is approximately 1,000 ft in length (seeFigure 5-1), The total anticipated groundwater flow rate from the landfilledge is 20 to 30 gpm, which includes 15 to 20 gpm from the Water Table Zoneand 5 to 10 gpm from the Intermediate Zone,

Water Table Zone, Based upon groundwater modeling simulations(Appendix A), two groundwater extraction technologies have been determined tobe feasible; a vertical trench drain or wellpoints, The geologic conditionsat the north and west sides of the landfill indicate that the bottom of thewater bearing zone, from which water would be collected, is up to 30 ft belowground surface in some areas, As such, a vertical trench drain would berequired to be approximately 30 ft deep in those areas, A drain of this depthwould present some problems in construction including dewatering of theconstruction area, cutting trench slope, or using some type of shoring toprovide physical stability of the excavation. Cutting back the trench wallswould require a larger working area than is currently available and couldcreate problems with the disposal of the excavated soil, some of which mightbe considered contaminated and/or hazardous, Shoring of the excavation wouldsignificantly increase the estimated construction cost, Given theseconstraints, the installation of a trench drain was not given furtherconsideration,

l : The only potential problem associated with wellpoints is the limited suctionlift capability of this type of system. As discussed in earlier sections,

: wellpoints are effective to maximum depths of approximately 22 ft of lift (seeFigure 3-3). Because some areas near the landfill would require groundwater

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collection to a depth of up to 27 ft (30 ft to the bottom of the water bearingzone minus a 3 ft buffer) and the limit of suction head is approximately22 ft, there is a 5 ft differential which would have to be overcome beforewellpoints could be effective. This differential could be overcome by placingthe wellpoint pump(s) and header system such that the maximum lift does notexceed 22 ft (i.e., place them in a shallow ditch or at a topographicallylower point such as the northwest portion of the landfill). Figure 5-2 is arepresentation of this type of construction. A ditch, if required, could beincorporated into the stormwater runoff diversion system currently beingutilized at the site,

Another alternative Is to place the wellpoints at low points on the existingground surface such that vertical lift does not exceed 22 ft. Extractionwells would be placed at locations where the available suction lift for thewellpoints is Inadequate, These wells, where required, could be connected tothe treatment system by a separate piping system, A spacing of 25 ft betweenwellpoints has been determined, with the groundwater model, to be adequate tocapture groundwater in the immediate vicinity of the landfill, This spacingwould require 40 wellpoints spaced over a length of approximately 1,000 ft, Across-section of the site, along a north-south alignment, showing theapproximate vertical position of the wellpoints is provided in Figure 5-3,

Intermediate Zone Near Source, Due to the depth to the IntermediateZone In the immediate area downgradient of the landfill, wellpoints or avertical trench drain are not feasible, Recovery wells are, however, a viableoption for collection of the groundwater from tho Intermediate Zoneimmediately downgradient of the landfill, The groundwntcr model Indicatesthat 5 to B recovery wells screened in the Intermediate Zone will provideadequate containment and collection of that zone near the landfill, The wellswould be located along approximately the same general alignment of thewellpoint system for the Water Table Zone (see Figure 5-1), Spacing ofapproximately 175 ft was determined to provide adequate capture andcontainment, A total, combined flow of 5 gpm to 10 gpm is expected from allof these wells with a 50 ft drawdown expected in each well, Water level-activated submersible pumps would be required for each well, JROf) I CO ft

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Migration Control by Groundwater Extraction

Plume Migration Control, The contaminant plume has beep determinedto be migrating hydraulically downgradient and north of the landfUl, in theIntermediate Zone, Based upon the results of the groundwntor mo<1«l computersimulation, a downgradient groundwater recovery system consisting of recovurywells would effectively contain and recover the groundwater plume fortreatment, Tho system would consist of five wells. Three would ho situatedalong a north-south line located north of the landfill through the approximatecenter of the plume. Two additional wells would be located on each side ofthe centerline, near the landfill, Figure 5-1 represents preliminarylocat-lons for these wells. Additional computer simulations will be performedprior to final engineering design to determine exact well locations, Thewells are anticipated to be approximately 60 ft deep, screened in theIntermediate Zone such that the water level during pumping is within 3 ft ofthe bottom of the zone at each well. A cross-section of the site showing theapproximate vertical positions of the wells is provided as Figure 5-3. Theexpected flow from each well is 1 gpm (near the landfill) increasing to 10 gpmIn the northern portion of the plume, The maximum total flow from all fivewells is estimated to be 25 gpm to 50 gpm, Environmental factors includingthe Interconnection of the Water Table and Intermediate Zones in the plumearea, coupled with the low level of volatile organic concentrations in theWater Table in the plume, indicate that there is no need to extract the WaterTable in this area,

5,2,2,3 Croundwater Treatment, A treatability study (Appendix C) hasbeen conducted using a simulated groundwater which was developed fromgroundwater characterization data from the Phase I RI report, Since thattime, new data have been collected during the Phase II Rl and the groundwaterconstituent and concentration matrix has changed somewhat, The originaltreatability study data and removal rates were reevaluated to provideengineering adjustments to reflect these changes, The treatability studyexamined the possibility of treating a composite groundwater from two sources;the landfill perimeter and from the plume extension, RDOO. I C91

5-9 .. " " O

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It was estimated that approximately 40 percent of the total extractedgroundwater flow rate (20 to 30 gpm) would be developed from source controlwellpoints and extraction wells and approximately 60 percent of the total flowrate (25 to 50 gpm) would be produced from extraction wells installed forplume migration control, For the purpose of preliminary design a total flowrate of 100 gpm was used.

Treatment standards (ARARs) are discussed in Section 3 of this report andsummarized in Appendix D, Documentation of ARARs, Data developed to dateindicate that iron in the groundwater may present problems in groundwatertreatment equipment, particularly in plugging and fouling air stripper packing,Furthermore, iron removal is required to comply with the water qualitystandard of 1,5 mg/1, The treatability investigation showed that airstripping would be an effective remedial technology for all of the chlorinatedvolatile organic compounds at an airtwater ratio of 4(1:1, The proposedtreatment facilities, therefore, include iron removal, air stripping, anddischarge of the treated groundwater to the unnamed Elk Creek tributary,Sludge handling, thickening, and dewatering processes are also provided.

The process flow diagram for the proposed groundwater treatment facilities ispresented in Figure 5-4. The individual unit processes and operations aredescribed below,

Chemical Conditioning—Coagulation/Flocculation

IGroundwater will be delivered to the treatment facilities by a common manifold

I from the individual wellheads, Chemical conditioning will be required tooxidize, precipitate, and flocculate the turbidity, iron, and aluminum toprevent build-up in the downstream treatment processes, The concentrations ofother heavy metals present in the groundwater will also be reduced throughco-precipitatioti on the iron and aluminum hydroxide floe, Conditioning willinclude addition of potassium permanganate (KMnO/,) for oxidation of iron,sodium hydroxide (NaOH) for pH adjustment, and polvmer for flocculation of

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metal precipitates and turbidity. Permanganate will be added to the manifoldline and mixed using a static in-line mixer. Permanganate wan selected sinceit is an'effective oxidant, is easily managed, and does not create largevolumes of air that may partially strip the volatile organic fraction,Polymer and caustic soda will be added directly to the flocculation basin onan as needed basis, Alternatively, polymer will be added for floeconditioning to an in-line mixer just upstream of the granular media filters,Headapace gas from the coagulation-flocculation process will be withdrawn by avacuum pump and used as inlet air to the blowers for the stripping column,The need for water traps and/or drying of this (and other) off-gases to theblowers will be determined during detailed facilities design,

Gravity Sedimentation

The estimated suspended solids concentration from the coagulation-flocculationbasin under design composite groundwator conditions is 60 to 100 mg/1, Thebroad range in projected solids levels is due to the expected variability inlocal water quality at each well. The projected operating range of solids istoo high for direct filtration and will cause rapid blinding of the filtermedia, This will result in short filter runs and excessive backwash eventsand spent backwash water for ultimate disposal, Gravity solids-liquidseparation will, therefore, be provided following coagulation to minimizesolids loading on the filters,

Lamella-typo separators will be used for the flocculated wnter. They will beplaced in a separate baffled chamber downstream from the flocculation zone,Air diffusers will be provided at the bottom of the settling tubes tofacilitate blowdown of solids and minimize plugging in the tubes, Sludge willbe collected in a hopper beneath the settlers and will be pumped to a sludgethickening tank.

AR30I6265-12

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Granular Media Filtration

OEffluent from the settling tank will be pumped to dual granular media pressurefilters for removal of solids. The filters will be operated tn; parallel ashigh rate units. Effluent from the filters will be pumped to the airstripping column, The filters will be backwashed using final effluent from aneffluent storage reservoir, Spent backwash water will be collected andsettled in a holding tank, Sludge in the holding tank will be collected andpumped to the sludge thickening tank, Supernatant from the backwash holdingtank and the sludge thickening tank w i l l be withdrawn from multiple Invnln andpumped to the influent manifold line for retreatment,

Off-gas from the pressure filters and the headspace gas from the backwashholding tank will be withdrawn by a vacuum pump and used as inlet air to theblowers for tht stripping column, The need for water traps and/or drying ofthese off-gases will be determined during the detailed design phase,

Air Stripping Column

Effluent from the granular media filters will be pumped to the air stripping K—column, The column will be operated in a downflow (liquid) counter-currentmode and will be packed with 2-inch Raschig rings, At the projected airswaterratio of approximately 40:1, the required air flow rate is 535 cfm at thedesign liquid flow rate of 100 gpm, The column off-gas will pass through ademister and be discharged to the atmosphere, Effluent from the strippingcolumn will be pumped or flow by gravity to discharge,

Sludge Drying Beds

Sludge from the thickening tank will be pumped to covered drying beds forgravity dewatering prior to ultimate disposal, The beds will consist of asand-over-gravel media and will be underlain by laterals to collect thefiltrate, Filtrate from the beds will be returned to the backwash holdingtank.

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f> Dried sludge cake will be removed and disposed to an appropriate setting, Hthe sludge Is characterized aa hazardous, the thickened sludge will bedisposed off-site by contract haul rather than dewatered on local .drying beds.The recommended method of sludge dewatering and disposal will be determinedbased on sludge characterization studies during the on-site pilot plantinvestigation.

Treatment Building

A building will be required to enclose certain treatment processes,' instrumentation and controls, and chemical feed equipment to protect them from

the climate and facilitate operations and maintenance during cold weatherI conditions, The proposed treatment building will enclose the following;

chemical conditioning feed equipment; bulk chemical storage; pressure filterinfluent and effluent pumps; pressure filters; final effluent pumps;

| office area for records management and operational control; instrumentationand controls; and the motor control center. The approximate dimensions for

[J the treatment building are 60 feet x 30 feet x 20 feet (L x W x H),

I The following unit processes/operations and equipment will be cutside the' treatment building; coagulation-flocculation; gravity settling; air stripping

column; backwash reservoir; spent backwash holding tank; sludge thickeningtank; air blowers and sludge drying beds. A small metal frame building willbe required to enclose the sludge pump and supernatant pump for the spentbackwash holding tank, the filtrate pump from the sludge drying beds, and thevacuum pump used to collect off-gas effluents from the different holding and

' treatment tanks,

The preliminary process design criteria for the groundwater treatment• facilities are summarized in Table 5-1, The projected average effluent

characteristics of the treated water are presented in Table 5-2,

O AR30I6285-14

TABLE 5-1

PRELIMINARY PROCESS DESIGN CRITERIA (,„'FOR GROUNDWATER TREATMENT FACILITIES

Unit Process and Criteria Value

Chemical Conditioning

Permanganate OxidationFeed rate-maximum 36 Ib/dFeed rate-average 20 Ib/dStorage volume drums

pH AdjustmentI Feed rate-maximum 100 Ib/d' Feed rate-average 50 Ib/d

Storage volume drumslj Polymer Addition

Feed rate-maximum 9 Ib/dFeed rate-average 6 Ib/dStorage volume drums

Cosgulation-Floeculation-Sett lingi' Number and type 1-in-ground concrete; baffled;

covered, Hydraulic detention time 30 minutesj Dimensions (L x W x SWD + FB) 12 ft x6 ft x 6 ft + 2 ft

Mixing-rapid first stage-slow paddle flocculators

Settling equipment • 1 lamella type separator

Granular Media Filters

Number and type 2-pressure type in parallelDiameter (each) 4 ftMedia sand on anthraciteSurface loading rate-average 4 gpm/ft?

-maximum 6 gpm/ft2Backwash rate 15 gpm/ft2Backwash volume/cycle 1,875 galBackwash frequency (each) 24 hours

AR30I629

5-15

TABLE 5-1 (Cont'd)

PRELIMINARY PROCESS DESIGN CRITERIAFOR CROUNDWATER TREATMENT FACILITIES


filter Pumps

Influent-number and type 2-centrlfugalCapacity (each) 120 gpm @ TDK

Backwash-number and type 1-centrifugal submersibleCapacity (each) 220 gpm Q TDK

Effluent-number and type 2-centrifugalCapacity (each) 120 gpm @ TDK

Backwash Reservoir

Number and type 1-in-ground concrete; coveredO w e t volume 3,750 gal

Dimensions (L x W x SWD + FB) 8 ft x 8 ft x 8 ft + 2 ftWater source treated effluent

Spent Backwash Holding Tank

Holding TankNumber and type 1-hopper bottomed; in-ground

concrete; coveredWet volume 4,800 galDimensions (L x W x SWD + FB) 10 ft x B ft x 6 ft + 2 ftHopper bottom slope 1:1

PumpsSludge pump to thickening tank 1-diaphragmCapacity 10 gpmSupernatant return pump 1-centrifugalCapacity 20 gpm

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Air Stripping Column

Number and type 1-packed bed; stainlesssteel shell; ambient air

Diameter 2 ftPacking media 2-J.n. Raschig ringsPacking depth (min) 6 ftColumn height 15 ftAir:Liquid (v/v) 40:1Air headless <6 in.Off-gas capture none

Effluent PumpsNumber and type 2-centrifugalCapacity (each) 120 gpm ? TDH

BlowersNumber and type 2-centrifugalCapacity (each) 600 acfm

Vacuum Pumps and Drier (if needed)Pumps, number and type 1-centrifugalCapacity (estimated) 20 cfm (? VACDrier not determined

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o TABLE 5-1 (Cont'd)


Unit Process and Criteria v"luo

Sludge Thickening Tank

Number and type 1-hopper bottomed; In-groundconcrete

Volume 4,800 galDimensions (L x W x D + FB) 10 ft x 8 ft x 6 ft + 2 ftSupernatant gravity drainageSludge pump (to drying beds) 1-diaphragmCapacity 5 gpm

Sludge Drying Beds

Number and type 2-coveredMedia sand-on-gravelSludge volume (? IX solids 1,440 gpdCycle time (dry * clean) 20 daysBed area (each) 6,000 ft2Bed dimensions (1, x W) 50 ft x 120 ftTotal area 12,000 ft2Filtrate volume-average 1 gpmFiltrate return rate 10 gpm

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TABLE 5-2

PROJECTED AVERAGE EFFLUENT CHARACTERISTICSFOR TREATED GROUNDWATER

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Parameter

BenzeneChlorobenzene1,1-DichloroethaneTetrachloroethyleneToluenetram- 1,2-dichloroe thy leneTrichloroethyleneVinyl chlorideMethyl ethyl ketoneMethyl isobutyl ketoneAcetoneTetrahydrofuran4-Methyl-2-pentanolCyclohexanone2-ButanolIsopropyl alcoholAluminumArsenicBariumCadmiumChromiumIronLeadZinc

30-Day Average Concentration(Hg/1)

55555201030

3121,140.80443

2,2105

4021,9301,000

51,290

525

2,00030440

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5.2,2,4 Discharge to Unnamed Tributary of Elk Creek, The treatedeffluent from the air stripping system would be discharged to the unnamedtributary of Elk Creek which flows by the site to the west. The length of thedischarge pipeline would be approximately 1,000 to 2,000 linear feet. Uwould be necessary to obtain an easement for this pipeline,

5,2,2,5 Croundwater Cleanup Plan, Remedial objectives for the Lord/Shoposite were established in Section 2. The groundwater In the plume downgradientfrom the landfill is a Class IIB groundwater, one which is not presently butis potentially available for uso as drinking water, Therefore, thegroundwater cleanup plan is intended to restore the quality of the groundwaterfor future use, The extraction and treatment systems would operate untilcleanup levels were achieved,

Area of Attainment

The area of attainment is defined as "the area of the plume outside theboundary of any waste to be managed in place as part of the final remedy andinside the boundaries of the contaminant plume". For the Lord/Shope site, thearea of attainment is considered to be that portion of the plume depicted inFigure 1-9 which lies outside of Lord Corporation's property boundary.Cleanup levels should ultimately be achieved within this area.

Cleanup Levels

Each of the site constituents to be considered in the potential remediation ofgroundwater at the site were evaluated for selection as cleanup parameters,Table 5-3 summarizes the rationale for selection or exclusion of each of thesite constituents, and gives the bases for determining the cleanup levels ifselection as a cleanup parameter was justified, The primary determinants forselection were demonstrtted toxicity (see the Revised Baseline Public HealthEvaluation submitted with the RI); predicted mobility (see Appendix E); andmagnitude of concentration, usually relative to the Safe Drinking WaterAct (SDWA) Maximum Contaminant Levels (MCLs) or Proposed MCLs (per Federal

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Register 54 FR 22062, May 22, 1989). MCLs are USEPA-generated values whichhave been determined to be protective of human health upon chronic, lifetimeexposures to constituents in drinking water. Therefore, where available, MCLsand proposed HCLs were the benchmarks by which cleanup parameters and cleanuplevels were initially evaluated, This approach is consistent with, andrecommended by, USEPA's Superfund Public Health Evaluation Manual (1986).

Three of the site constituents listed in Table 5-3, acetone), MEK, and MIRK,did not have MCLs or Proposed MCL9 available, but did have Agency-approvednoncarclnogenic reference doses, RfDs (see Revised Baseline Public HealthEvaluation). The RfD values arc levels below which no adverse effects tohuman health are expected, and may be used to calculate an acceptablegroundwater concentration, using worst-case, chronic intake assumptions isshown belowt

RfD x Body WeightRfD or Noncarclnogenic Exposure Level (mg/1) " —————————————

Daily Water Intake

Where:RfD « reference dose specific to noncarclnogen (mg/Kg/day)Body Weight • for adult, 70 kgDaily Water Intake • for adult, 2 liters/day

Because acetone, MEK, and MIBK did not have MCL or proposed MCL values, theabove method was used to calculate the cleanup levels for these threeconstituents, using the RfD values presented in the Revised Baseline PublicHealth Evaluation.

Several other site constituents detected in relatively high concentrations didnot have MCLs, proposed MCLs, or critical toxicity values, including:1,1-dichloroethane; tetrahydrofuran; A-methyl-2-pentanol; 2-butanol; andisopropyl alcohol, However, it is expected that remediating other organicsite constituents would provide protection from these constituents,

o AR30I6365-22

Groundwater cleanup levels to be achieved in the area of attainment are listedin Table 5-4, The constituents selected for cleanup reflect the majority ofthe potential risk posed by the site, as described in the Revi.sed BaselinePublic Health Evaluation; and, based on retardation factors, represent boththn least mobile and the most mobile plume constituents (sec Appendix E), Thecleanup levels include MCLs, proposed MCLs, and risk-based values calculatedas described above, In portions of the area of attainment, several of thecleanup levels are already being achieved.

In the following paragraphs, the most recent plume characteristics aredescribed for each chemical. It should be noted that the discussion belowonly idontifies monitoring wells which presently exceed or may possibly exceedthe proposed cleanup levels.

Aceton*. The calculated risk-based cleanup level for acetone is3,500 ug/1, During the 1988-89 sampling, acetone was only detected in onewell, W-3, at concentrations greater than this level, ranging inconcentrations from 930 to 37,000 ug/1,

Barium. The current MCL value for barium is 1,000 ug/1. The USEPA hasrecently proposed that the MCL value be increased to 5,000 ug/1, Thisproposal is believed to reflect the long-standing concern that the toxicity ofbarium has been overstated, Only one well, W-3, exhibits concentrations inexcess of 5,000 ug/1.

Benzene, Benzene has been detected recently at or near the MCL value of5 ug/1 in 5 wells: W-3WT (5 ug/1), W-4WT (5 ug/1), W-4A (5 ug/1), W-22B(8 ug/1), and W-34 (7 ug/1), The results noted for these five wells were allfollowed by one or two occasions of no detection; and it is not entirely clearthat 'benzene is really present, As a precaution, however, benzene is selectedfor a cleanup standard,

AR30I6375-23

o TABLE 5-4 .

GROUNDWATER CLEANUP LEVELSLORD/SHOPE SITE8

Parameter

AcetoneBiriumBenzinetrans-l,2-DichloroethyleneMethyl Ethyl KetoneMethyl Isobutyl KetoneTetnchloroethyleneTrichloroethyleneVinyl chloride

Concentration(ug/1)

3,5005,000

5100

1,7501,750

552

Cleanup LevelBasis

Risk-Based Calculation1*Proposed MCLCMCLProposed MCLCRisk-Based Calculation11Risk-Based Calculation1*Propose i MCLCMCLMCL

O"See text for discussion,^Calculated using method described in text and RfD values presented in theReviitd Baseline Public Health Evaluation. RfD values (in mg/kg/day) foracetone: 0.1; MEK and MIBK: 0.05.cProposed in Federal Register. May 22, 1989.

O AR30I638

5-24

+„..-•»,+* I««MC> 4* «ot a* ntnaa6.4 L.o.n..ltgiblt..at k4 ^ ^tubttandand colon of, condition • e( tkt on4g4nal:p'agti JJI

lrana-l,2-Dichloroethylene. During 1988 and 1989 groundwater samplingevents, this compound was detected in two wells in excess of the proposed MCL(100 ug/1), In W-9KT, the detected concentrations ranged from 200 to 370 ug/1,Trsns-l,2-dichloroothyleno was detected In one sample from W-36B at1,200 ug/1, however, it was not detected in three previous and one subsequentsampling event from the well,

Methyl Ethyl Ketone. MEK was detected in W-3 at 7,400 ug/1, which exceedsthe risk-based cleanup level of 1,750 ug/1. The subsequent sample from W-3did not contain MEK.

Methyl Isobutyl Ketone. During the 1968-89 groundwater sampling, MIBK wasdetected above the risk-based cleanup level of 1,750 ug/1 only in one well,W-3, Concentrations In well W-3 ranged from 3,400 to 48,000 ug/1,

Tetrichloroethylene, Tetrachloroethylene was detected in January 1989samples from W-21A and W-21B at or near the proposed MCL of 5 ug/1.'' TheJanuary results were 7 ug/1 fiom W-21A and 5 ug/1 for W-21B. The compound wasnot detected in either well during the October 1988 sampling event,

Trichloroethylene. TCE was detected in three wells (W-3, W-6B, W-9WT), Inexcess of the MCL value of 5 ug/1, The 1988 and 1989 results were as follows:W-3 (10 ug/1, ND, ND); W-6B (6 ug/1, ND, ND, ND, ND); and W-9WT (65 ug/1,47 ug/1, ND),

Vinyl Chloride, During 1988 and 1989 sampling events, vinyl chloride wasdetected in six wells in excess of the MCL value of 2 ug/1. The results bywell were as follows (In ug/l)i W-lA (56, ND, ND); W-lWT (ND, ND, 750); W-3

.— .(500, 40, 1200, 240); W-9WT (12, BMDL, ND); W-20B (2400, 1900, 200); and W-34(ND, 23, 20),

Other Elements and Compounds Considered, There are proposed MCLs forchlorobenzene (100 ug/1) and toluene (2,000 ug/1), These values were notexceeded in any of the 1988 and 1989 groundwater samples, As was discussed in

AR30I6395-25

in tk4t inamt it not atit it dut to tubttandand colon on condition o( tkt

o Section 1.2.2, there have been sporadic exceedences of MCLs for chromium,lead, and cadmium in monitoring wells in the Water Table Aquifer indIntermediate Zone, but the preponderance of data show that these excursionsare not representative of site conditions, Concentrations of arsenic in sitemonitoring wells have never exceeded the MCL value of 50 ug/1,

Institutional Controls

It would be necessary for Pennsylvania DER to place use restriction)) on thogroundwater in the area of attainment until all cleanup levels are achieved.This would prevent ingestion by humans and interference with the efficiency ofthe pumping systems,

Performance Monitoring

A performance monitoring program would need to be established to evaluate andensure the effectiveness of the groundwater restoration program, This wouldinclude periodic groundwater sampling and analysis to track progress as wellas other types of performance assurance,

Restoration Time Frame

A discussion of the estimated time frame for restoration of the area ofattainment is provided in Appendix E, The groundwater travel time in theIntermediate Zone would be approximately 10 years in the portions of the plumewhere the cleanup levels are presently being exceeded, The estimatedretardation factors for most of the plume constituents are less than 5; thosewith greater values are the chemicals which do not or may not presently exceedcleanup levels or MCLs, Based upon these values, the estimated time forrestoration is 50 years,

5,2,2,6 Air Emissions from Stripping Column, The atmospheric emissioni from the stripping column may require a permit from Pennsylvania DER in

accordance with 25 PA Code 127,1, Estimated emission rates are .provided inAR3016ii0o5-26

O

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Table 5-5. With the exception of air and water vapor, the constituents of thostack gas are volatile organic compounds (VOCs) in that they contain carbonand hydrogen, and exhibit vapor pressures in excess of 0.002 psta at 70°F and1 atmosphere (see 25 PA Code 121.1),

The total emission rate from the column would be very low--0,0264 Ib/hr, Thestack gas concentrations of the compounds would also be very low, as shown inTable 5-4, Decreasing the air flow would compromise the efficiency of thestripping process, There arc no specific numerical emission limits which areapplicable to this type of emission source, It is believed that the stripperemission may actually be exempt from the permit requirements in that due tothe low emission rates, it would be of "minor significance" (see exemptions at25 PA Code 127,14(8)). If not exempt, the emissions from the stripper must bethe minimum attainable through the use of best available technology (BAT). At25 PA Code 121.1, BAT is defined as "equipment, devices, methods, ortechniques which will prevent, reduce, or control emissions of aircontaminants to the maximum degree possible and which are available or may bemade available". However, there are no available technologies which caneffectively control such dilute concentrations of the organic compounds in thestack gas from the stripping column.

USEPA has promulgated emission limitations for vinyl chloride in the NationalEmission Standards for Hazardous Air Pollutants (NESHAPs) at 40 CFR 61,Subpart F. These apply directly to plants which manufacture vinyl chloride,polyvinyl chloride, and ethylene dichloride, however, they are believed to berelevant and appropriate to the stripper emission. The NESHAPs call for anexhaust gas concentration of 10 ppm by volume, The stripper stack gas vinylchloride concentration is projected at 3.0 ppm by volume, which is only30 percent of the NESHAP value,

Pennsylvania DER has published guidance which the agency uses to establishacceptable health-based ambient air quality concentrations for severalsubstances they have designated as air toxics (March 1984), Three of thecompounds which would be in the stripping column emission are among those with

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AR30I6I»2

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:" chronic annual quality guidelines: benzene (12,5 ug/m), trichloroothyUne(76,9 ug/ii^), and vinyl chloride (6.12 ug/m'). An air dispersion model was (j

' utilized to estimate maximum annual ground level concentrations for thesethree compounds due to the stripper emission. The results, provided inAppendix F, show that none of the guidelines would be exceeded,

5,2,3 Alternative No, 3—Source Control by In Situ Vapor Stripping; Source! Control and Migration Control by Groundwiter Extraction, Groundwater

Treatment, and Discharge to Surface Water

jSource and migration control, groundwater treatment, and discharge

i requirements are Identical to those discussed in Alternative No, 2 (above),This remedial alternative features additional source control by in situ vapor

l stripping of contaminants residing within the landfill and Its Immediatei vicinity,

, In situ vapor stripping removes volatile and semi-volatile organics fromwithin and beneath landfills, fill areas, and vadose zone soil, Ambient airis Introduced into the soil through a vent pipe and is withdrawn through a /"_"';;

v ••'vapor extraction well, As the air passes through the contaminated subsurfaceenvironment, the volatile organics sorbed onto the soil or other debris irepartitioned into the air and are removed as the air is extracted, Throughjudicious design, the presence of a cap (or other air-impermeable materials)can be used to improve the overall efficiency of the system,

ii Although the vapor pressure of a volatile or semi-volatile compound may be

high, one must also consider the solubility of a given compound, since thematerial may prefer to remain dissolved in soil pore water rather thanpartition into the air. The air/water interface and Its effects uponsolubility is only one of several interactions affecting vapor strippingefficiency and effectiveness which can occur, Through laboratory studies, a"lumped" parameter can be estimated which can depict the overall effect ofinteractions—not only between water and the constituent of interest, but alsothe interactions with soil, air, and the other chemicals present, Such

5-29flR30!6!»3 „ Q

o

interactions have a significant impact upon the removal of ihe constiluanl ofinterest via vapor stripping.

Based upon preliminary field studies, laboratory simulation studies, andmathematical modeling, it is believed that in situ vapor stripping is acompatible and feasible technology for use at the Shope Inn d f i l l . Aconceptual design has beon developed to examine the feasibility of thistechnology for this site. The conceptual design, however, is predicated uponseveral assumptions since there are slight differences in the technicalapproach for each of the three areas (see Figure 5-5) which are targeted forvapor stripping at the site. These areas include:

• the capped landfill• the crested soil southeast of the landfill• the soil at the toe of the landfill

While all three areas are amenable to in situ vapor stripping, there aretechnical differences for each that need to be addressed which require slightvariations to the basic technology, Specifically, the crested soil areasoutheast of the landfill can be treated by employing a conventional verticalvent approach, A mathematical model has been employed which indicates, on apreliminary basis, that a rapid and effective removal of the constituentspresent is possible, Figure 5-6 is a conservative representation (using themathematical model) of the removal of organic constituents with time from thislocation, presented as residual concentrations.

Given the high water table in the area around the toe of the landfill, thevapor stripping system will have to employ horizontal or trench piping.ECKENFELDER INC. has modeled this approach as well, A preliminary assessment,using the mathematical model and based upon data obtained during the on sitestudies, shows that this area can be remediated to residual contaminant levelscomparable to those of the crested soil area, in a reasonable amount of time,Figure 5-7 is a graphic representation of the residual VOC concentration withtime predicted by the model for the landfill toe area, This figure supports

""30161,1,

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5-33

•n the feasibility of employing ISVS technology for the crested soil area basedupon the preliminary field data collected and their use in the mathematicalmodel.

Representative soil and associated debris within the landfill could not bereadily sampled during the on site study, Therefore, it was not possible toperform laboratory studies and obtain the lumped partitioning coefficientsnecessary to implement the model upon which VOC removal predictions arepredicated, A preliminary assessment, based upon field efforts with aproprietary, portable, in situ vapor stripping (ISVS) unit, indicate thatremoval of 0,0076 Ib per hour (3,4 grams/hr) of total volatile organic

i contaminants was obtained from the landfill. This is based upon a flow of4,3 cfm through the ISVS unit operating at a vacuum of 120 in. of water. It

I should be noted that this removal rate is only a very rough approximation,given the heterogeneous distribution of materials under the cap and thecorresponding differing sorption of contaminants onto the various debris

I present (e.g., concrete vs, rubber vs. soil, etc,), Also, it should be notedthat initial constituent removal rates are typically high and tend to decrease

s~\_ i with time.

I Table 5-6 is a summary of removal rates obtained on site by the ISVS unit.Rates determined by the model are approximate only. Actual removal rates area function of the site characteristics existing during the stripping operation.

I See Appendix B for a detailed discussion of the Shope in situ vapor strippingstudy. This predicted removal rate, based upon the field data and

j mathematical modelling, indicates that ISVS technology technology is anappropriate technology for source control at Shope's landfill.

Overall, it is proposed to adopt a conservative approach and assume that thesoil or fill is isotropic in nature, Therefore, the radius of influence for

' the well in each case (i,e,, three locations previously described) will beequal to its depth, In the case of the lateral or trench wells, the radius of

: influence is equal to the depth to which the pipe is buried, At the toe ofthe landfill, the depth to groundwater is approximately 5 ft, The locations

O5-34

!!f i*r* *tandand colon on condition oi tkt oniginal page*'.

TABLE 5-6

TOTAL VOLATILE ORGANICS STRIPPINGRATE WITH ISVS UNIT AT

CORRESPONDING FLOW RATE AND VACUUM

EP 1

EP 2

EP 4

EP 5

EP 6

EP 7

EP 8

EP 9a

Flow Rate(cfm)

3.2

1.8

4.4

5.0

9.1

7.1

6.6

4.3

Vacuum(in of H20)

125

125

125

120

27

18

19.5

120

Stripping Rite0(Ib/hr)

0.0073

0.0033

0.0101

0.0079

0,0372

0,0381

0.0286

0.0076

(g/hr)

3.3

1.5

4.6

3.6

16.9

17.3

13.0

3.4

*EP9 average of chemical analysis runs B, C, and D, EP9A excluded because ofpossible contamination during analysis,''Stripping rate based on flow rate corrected to Standard Temperature andPressure,

5-35

O

AR30l6l»9O

of the extraction wells at the crested soil area arc based upon an approximatedepth to groundwiter of 24 ft, using a well depth of 20 ft so that the zone ofInfluence has the ridius of 20 ft.

Approximately 50 extraction wells will be required to remediate the cappedarea of the landfill, assuming the radius of the zone of Influence is 25 ft,This is a conservative estimate as the zone of influence may be somewhatlarger due to the effect of the low-permeability cap, which could greatlyreduce the number of wells, This possibility would be explored during thecourse of the pilot scale study, With an average well depth of 20 ft,approximately 1,000 linear ft of 4 in, PVC well pipe will be needed for thecapped area of the landfill, Extraction wells would be screened at the bottomIn 12 to 18 in, intervals,

For the soil piles at the toe of the landfill, horizontal extraction trenchesare proposed, With an average depth of about 5 ft to the water table,vertical wells are not practical for this area, Two trenches are required,each 300 ft long and placed 10 ft apart,

The crested soil area will require five extraction wells based upon a welldepth of 20 ft and corresponding 20 ft zone of influence,

The vapor extraction system would be driven by multiple 7,5 hp blowers with anapproximate total capacity of 400 cfm and would be configured to provideindependent, parallel, or series operation selected at the user's discretion,

Off gases from the stripping system may or may not require treatment beforebeing vented to the air, One option which may be available is to vent the offgases to the groundwater treatment air stripper stack. Off gas treatment, ifrequired, may be accomplished in several ways. The optimum off gas treatmentsystem, if required, will be determined after pilot testing and duringdetailed design. For the purpose of this FS it is assumed that off gastreatment is required and will be accomplished by dehumidifying the airstreamusing a chiller system, followed by vapor phase activated carbon treatmentwith on site carbon regeneration, AR3Qlo5Q

O .

O

5,2.4 Alternative No, 4A--Source Control by Excavation ind On Stu C.JIncineration; Source Control and Migration Control by Groundwater Extraction,Groundwater Treatment, and Discharge to Surface Water

The source control, migration control, groundwater treatment, and discharge tosurface water requirements in this option are identical to those discussed inAlternative No, 2, This remedial alternative features additional sourcecontrol by excavation of the entire lan d f i l l and immediate area to a depth of10 ft below the former original grade and on site incineration of theexcavated material,

5,2,4,1 Excavation. Excavation of the landfill would involve removal ofthe engineered cap as excavation proceeded. On the north, west, and eastsides of the landfill, the excavation would be extended beyond the delineatedfill area an additional 10 ft horizontally and 10 ft vertically to ensure thatthe areas of highest organic chemical concentrations are removed, Thesouthern side of the landfill, which is protected by an upgradient cutoffwall, would be excavated to the cutoff wall only and not beyond, The f.:,'\

•'excavation limits and soil types expected to be encountered are illustrated onFigure 5-8,

For the on site incineration option, approximately 144 tons/day of soil willbe excavated. Approximately 270,000 tons of excavated materials will requireincineration. This material will be loaded into a rotary kiln feed buildingeach operating day. The landfill excavation operation would involve the useof a single, track-mounted, 3 cu yd, front-end loader and a 15 cu yd, triaxledump truck or equivalent equipment. The loader would load the dump truckdirectly from the face of the excavation and the truck would makeapproximately ten trips a day from the excavation area to the rotary kiln feedbuilding. Site excavation for this remedial alternative would takeapproximately 5.5 years.

AR30I65I5-37

5,2,4 Alternative No, 4A—Source Control by Excavation and On Site \..JIncineration; Source Control and Migration Control by Groundwater Extraction,Groundwiter Treatment, and Discharge to Surface Water

The source control, migration control, groundwater treatment, and diacharge tosurface water requirements in this option are identical to those discussed inAlternative No, 2, This remedial alternative features additional sourcecontrol by excavation of the entire landfill and immediate area to a depth of10 ft below the former original grade and on site incineration of theexcavated material,

5,2,4,1 Excavation, Excavation of the landfill would involve removal ofthe engineered cap is excavation proceeded. On the north, west, and eastsides of the landfill, the excavation would be extended beyond the delineatedfill area an additional 10 ft horizontally and 10 ft vertically to ensure thatthe areas of highest organic chemical concentrations are removed. Thesouthern side of the landfill, which is protected by an upgradient cutoffwall, would be excavated to the cutoff wall only and not beyond, The (.,•:'.\

VJi>excavation limits and soil types expected to be encountered are illustrated onFigure 5-8.

For the on site incineration option, approximately 144 tons/day of soil willbe excavated. Approximately 270,000 tons of excavated materials will requireincineration. This material will be loaded into a rotary kiln feed buildingeach operating day. The landfill excavation operation would involve the useof a single, track-mounted, 3 cu yd, front-end loader and a 15 cu yd, triaxledump truck or equivalent equipment. The loader would load the dump truckdirectly from the face of the excavation and the truck would makeapproximately ten trips a day from the excavation area to the rotary kiln feedbuilding. Site excavation for this remedial alternative would takeapproximately 5,5 years,

5-37

AR30I65I o

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t.' u tii Kmoi tkt on4g4nal pagt 'Kif r

Soil excavated from beneath the l a n d f i l l is expected to be primarily theAshtabula Till (coarse) with some excavation into the Maumen lllc. Because ofthe depth to the water table, excavation dewaterlng will be required for theexcavation of approximately 10 ft of soils beneath the landfill, The designof the dewatering equipment would be similar to that found in the near sourcecontrol option (see Section 5,2,2,1), The collected groundwater would requiretreatment prior to disposal, Runon/runoff controls would have to be installedto ensure that surface water would not be contaminated by stormwater runofffrom the landfill during excavation. A stormwalor collection system wouldneed to be installed for this source control option, Since the excavation isinto a landfill which held chemical wastes, the excavation contractor crew andothers would be required to work in Level B safety gear, at a minimum,

5,2,4,2 On Sit'j Incineration This option involves the use of a servicecompany which would provide and operate a complete soil incineration system ona contract basis, The incineration system would be transported to the siteand erected near the landfill, The service company would provide theincineration equipment, civil construction work, operating staff,environmental permitting assistance, and the environmental monitoring and '" :reporting required by regulatory agencies, The incineration system would —'consist of a rotary kiln, an afterburner, a quench chamber, an air scrubber,an induced draft fan, and an air emissions stack, Incinerator feed operationswould require a waste staging feed area, a pug mill and/or drum shredder, anda conveyor feed system, The rotary kiln would be operated at a temperature of1,200 to I,400°F in the primary combustion chamber, in which the waste andsoil would be subject to an incinerator retention time of 30 to 60 minutes.Exhaust gases from the kiln would be combusted in an afterburner operated at atemperature of between 2,200 and 2,400°F with a retention time of at least2 seconds, Combusted off-gases would be quenched prior to scrubbing in aventuri scrubber (or equivalent) for particulate removal, The quenchedoff-gases would then be further scrubbed in an alkaline packed tower whichwill remove halogen acids, These residuals would then be transmitted to aClarifier or other device which would concentrate the particulate matter intoa sludge, The scrubbed off-gases are then conducted by an induced draft fanto the plant stack where emission? are exhausted to the atmospnettnJU I DwJ

5-39

pagt iilmtd in tkit inamt it not at ntadabls. J>n, a 4.4 due to tubttandand colon on condition of

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This alternative considers the operation of a 6 ton/per hour rotary kiln unitwhich would burn soil 24 hr per day, 48 weeks per year on a 7 day per weekbasis, This is the largest mobile rotary kiln incinerator which is available,In this fashion, approximately 48,400 tons per year of contaminated soil canbe Incinerated, At this rate, approximately 5,6 years will be required toincinerate all of the contaminated material planned for excavation,

Ash and other residue from the kiln would be disposed at an off site RCRApermitted hazardous waste landfill after solidification and stabilization,unless it is shown that the ash does not exceed any federal or state landdisposal restrictions, in which case the ash will be returned to the Shopelandfill or transported to a municipal landfill for disposal, It isanticipated that the ash will comprise 40 percent of the total volume to beexcavated and will result in disposal requirements for approximately108,000 tons per year of kiln residue, There are three licensed hazardouswaste landfills within 115 miles of the Shope landfill which are suitable fordisposal of solidified kiln ash. These are:

> Municipal and Industrial Disposal Company--Buena Viesta,Pennsylvania

• CECOS International--Niagara Falls, New York

• Chemical Waste Management of New York—Model City, New York

5.2,5 Alternative No, 4B--Source Control by Excavation and Off SiteIncineration; Source Control and Migration Control by Groundwater Extraction,Groundwiter Treatment, ind Discharge to Surface Water,

The source control by excavation and source and migration control bygroundwater extraction, groundwater treatment, and discharge to surface waterelements are identical to those discussed in earlier sections, The difference

AR3QI65I*5-40

in this alternative Is that after excavation of the fill area and soil, theexcavated materials would be transported off site (or incineration at acommercial hazardous waste incineration facility,

Commercial Incineration capacity for contaminated waste soils is currentlyquite limited in this country. There are only three operating hazardous wasteincinerators within a 500 mile radius of the Shope site which can incineratecontaminated solid materials, These include:

• Rollins Environmental Services—Bridgeport, Now Jersey

• Chemical Waste Management; Chicago Incinerator—Chicago, Illinois

• Ross Incineration Services—Cleveland, Ohio

The Rollins Environmental Services, Ross Incineration Services, and theChemical Waste Management facilities have large rotary kiln incinerators whichare equipped to incinerate contaminated soil and debris. However, none ofthese units has the capacity to incinerate the waste load from the landfill byitself and the excavated materials would have to be distributed among severalincinerators. Several other hazardous rotary kiln incinerators have beenproposed for permitting or are awaiting approval of their RCRA permits whichcould be of use in the future. For the present, the only permitted facilitieslocated within a practical distance are the Rollins Environmental Services andthe Chemical Waste Management facilities, Approximately 270,000 cu yd ofmaterial will require excavation, This includes the waste fill Itself and thesoil beneath the fill area to a depth of 10 ft. A 10 ft wide swath of soilbordering the fill area would also be excavated to a depth of 10 ft. A swellfactor of 20 percent Is assumed which will yield a volume of 324,000 cu yd ofmaterial to be transported for off site disposal, The method of excavation isgenerally described In Section 5,3,2,1.

For the off site incineration option, excavation would be accomplished byusing two track mounted, front-end loaders each with a 3 cu yd bucketcapacity, The front end loaders would load 22 yd over-the-road (OTR) dumptrailers directly from the face of the excavation, Production would be

^ AR30I655

approximately 400 cu yd/day, Approximately 18 to 20, 22 cu yd, covorod dump| trailers would be loaded for shipment each working day, Thin process would

take approximately 2,4 years,

For the off site incineration option, a dump truck loading and vehicledecontamination area w i l l be required, Special runon/runoff controls wi l l heneeded to prevent contaminated slormwator runoff from reaching surface watersupplies,

5,3 INDIVIDUAL ASSESSMENT OF REMEDIAL ACTION ALTERNATIVES

Each of the five remedial action alternatives have been evaluated with respectto the nine feasibility study evaluation criteria, A summary of thisassessment is presented In Table 5-7. These evaluation criteria include.thefollowing:

• Overall protection of human health and the environmenti Compliance with ARARs

(J • Long-term effectiveness and permanence• Reduction of toxicity, mobility, and volume through treatment• Short-term effectiveness• Implementability• Cost• State acceptance• Community acceptance

5.4 COMPARATIVE ANALYSIS OF REMEDIAL ACTION ALTERNATIVES

A comparative analysis of each alternative was conducted in order to evaluatethe relative performance of each alternative in relation to each of the ninespecific evaluation criterion. The purpose of this analysis is to identifythe advantages and disadvantages of each alternative relative to the others.

5-42

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X-N S.A.I Overall Protection of Human Health and Environment

Alternative 1 does not provide a reduction in risk to human health for futuregroundwater users. Alternatives 2, 3, AA, and AB provide overall protectionof human health and the environmnnt, In these alternatives, the small risk to

' „human health from direct contact/ingestlon of soils will be eliminated sincethe landfill will be fenced, Alternative I presents a threat to human healthvia contact/ingestlon with contaminated soils,

5.4.2 Compliance with ARARs

; Alternative 1 allows a 1 in 10 cancer risk for potential future ingeslion ofgroundwater. All of the other alternatives protect against soil and

I ' groundwater ingestion at the 1 in 10,000 cancer risk level and otherwise aredesigned to meet chemical specific ARARs. There are no location-specific

; ARARs for this site. Alternatives 2 through AD achieve compliance with anumber of action-specific ARARs including RCRA land disposal, landfill

^^^ closure, NPDES, and air emissions ARARs. Alternative AA would have RCRA';__J landfill construction requirements as an additional ARAR. For the chemical

specific ARARs, Alternatives 2 through AB would meet MCLs for groundwateron site and at the perimeter; as well as chemical-specific concentration andpollutant loading limits for air emissions, surface water discharge, andhazardous waste disposal. Alternative 1, in comparison, would not meet theMCLs for vinyl chloride, trans-l,2-dichloroethylene, and barium.

5.4,3 Long-Term Effectiveness and Permanence

There is virtually no residual risk associated with direct contact with soilor soil ingestion for any of the alternatives as long as the landfill RCRA capj.s maintained and in the case of Alternatives 2, 3, and AA and D, the siteremains fenced, Fencing the site will eliminate potential exposure tocontaminated soils in the seep areas, the crested soil area at the southeastcorner of the landfill and other small areas of contaminated surficial soils,In terms of groundwater ingestion for future users, Alternative 1 lends a

© AR30I6585-AA ' ' " ™

potential long-term cancer risk for users downgradient of the landfill. ForAlternatives 2 through 4B, any potential residual risk is eliminated using C, Jsource control, plume extraction and groundwater treatment technologies,

The adequacy and reliability of Alternative 1 is sufficient to minimizeleachate generation and prevent direct exposure to soils, There nre nocontrols in Alternative 1 for existing groundwater contamination, therefore,there are no adequacy and reliability factors available for comparison withthe other alternatives, The adequacy and reliability of controls for

, groundwater recovery and treatment for Alternatives 2 through 4B arecomparable and are adequate and reliable, Additionally, early monitoring

j wells which are provided in each of the alternatives provide backupperformance monitoring. The Alternative 3 aource control technology, vapor

j stripping, is a relatively new technology, but one which has been demonstrated' as being reliable. The controls and monitoring technology for in situ vapor( s t r i p p i n g are well established and highly reliable. Alternatives AA and AB

both feature excavation of the landfill and incineration of excavatedmaterials as source control measures. While removal of the landfill and

I contaminated materials and treatment by incineration does provide a good /'.' ";long-term solution for site remediation, the short-term implications of ~"

| excavation into the landfill and the transportation of contaminated materialsioff site for disposal are significant. For all of the five remedial actionalternatives, a 5 yr review is needed to assure long-term effectiveness and

I permanence, and the protection of human health.

5.4,4 Reduction of Toxicity, Mobility, or Volume through Treatment

Alternative 1 does not employ a treatment process and therefore docs notaddress the CERCLA statutory preference for treatment, Alternatives 2 through4B result in the reduction of toxicity, mobility and volume of site

' contaminants through various means of treatment, In Alternative 2, thegroundwater treatment technology, air stripping, provides reduction ofgroundwater toxicity and the reduction of the mass or volume of groundwaterconstituents, Source and plume migration control options in Alternative 2

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through AD reduce and eliminate the mobility of groundwater constituents inthe subsurface environment, Alternatives 3, AA, and AB also providereductions of contaminant mass, or volume, as subsequently noted,Alternative 3 involves vapor stripping of VOCs and some semi-volatilecompounds from the landfill and its immediate area, The extracted chemicalswould be adsorbed onto carbon and later incinerated during regeneration. Thestatutory preference for treatment technologies which reduce toxicity is thusmet. Both Alternatives AA and AB will reduce the volume and toxicity ofcontaminated materials through incineration,

Alternative I provides no irreversible treatment as no treatment technologiesare employed, In Alternatives 2 through AD, groundwater constituents aretreated by air stripping which renders VOC constituents subject to photodegradation, other forms of transformation, and dilution, In Alternative 3,the VOCs which are adsorbed onto carbon used in the in situ vapor strippingsystem, will be irreversibly destroyed by incineration/carbon regeneration orbiological degradation, In Alternatives AA and AB, the incineration oflandfill and surrounding area materials provides irreversible treatment,

Alternative 1 does not provide any treatment and therefore, there are noresiduals remaining, In Alternatives 2 through AB, the groundwater treatmentsystem will produce an iron sludge which is not expected to exhibit anyhazardous or toxic characteristics or have any constituent concentrationlevels that would render the materials hazardous, In Alternative 3, the vaporphase carbon adsorption system w i l l produce spent carbon which will beregenerated for reuse. In Alternatives AA and AB, incinerator ash isgenerated which will be land disposed, This ash is not expected to exhibitany hazardous or toxic characteristics or have any constituent concentrationlevels that would render the materials hazardous,

Alternative 1 does not address the statutory preference for treatment, of sitecontaminants, Alternatives 2 through AB all satisfy the CERCLA statutorypreference for treatment, as opposed to land disposal without treatment orabandonment in place without treatment,

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5.4,5 Short-Term Effectiveness

Alternative 1 does not present any short-term risk to the community but doespresent a long-term cancer risk by exposure/ingest ion of soils,Alternatives 2 and 3 do not present any substantive risk to the community,Excavation and operation of an on site incinerator in Alternative 4A willpreaent short-term risk to the community during the operating period of 5 to6 yr, There would be a significant increase in risk to the community inAlternative AB resulting from the increase in traffic caused by the 18 to20 dump trailer loads leaving the site on a daily basis,

There would be no significant risk to workers resulting from theImplementation of Alternative 1, For all of the other alternatives, therewould be minor risks to workers during well installation, construction of thegroundwater treatment facility, and other construction-related activities.There would be significantly increased risks for workers at the site inAlternatives AA and AB resulting from excavation of the landfill. Asubstantially increased risk of worker exposure/injury due to this activity ('.;•',?would be expected. In addition, Alternative AB would result in an Increasedrisk for truck driver safety while hauling loads to distant incinerationfacilities. In terms of environmental impacts, there would be no significantrisk should Alternative 1 be implemented, For Alternatives 2 through AA,there are no significant detrimental environmental impacts. All airemissions, surface water discharge, and disposal of residuals would beconducted in compliance with ARARs, For Alternative AA, there would beincreased local pollutant loadings to the atmosphere from the on siteincinerator. For Alternative AB, there would be increased local pollutantloadings to the atmosphere at off site incinerator locations and there wouldbe an increased chance of a release to the environment caused by a haulingaccident which could result in dumping contaminated materials onto land orwater.

In Alternative 1, at least 100 yr is estimated for natural attenuation anddissemination of groundwater constituents to reach MCL levels, - Jor

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Alternative 2, site design and construction could be completed within18 months of agency approval, Source and migration controls would beeffective within two months of start up. This remedial action should becompleted within 50 yr of implementation. Site design and construction forAlternative 3 could be completed within 16 months of agency approval, Sourceand migration control for this option should become effective within twomonths of startup. Completion of this remedial action should occur within50 yr of startup. For Alternative AA, site design and construction could becompleted within A6 months of agency approval, Migration control should beeffective within two months of startup and source removal should be completedwithin 6 yr of startup, This remedial action should be completed within 50 yr.Site design and construction for Alternative AB should be completed within24 months of approval. Migration control should be effective within twomonthii of startup. Source removal should be completed within 2-3 yr ofstartup, This remedial action should take no longer than 50 yr to complete,

5,4,6 Implementability

For Alternative 1, there is no action or construction that will occur, Thegroundwater recovery and treatment facilities for Alternatives 2 through ABwould be simple to construct and operate, The groundwater treatment systemrequires some operator attention. In Alternative 3, the in situ vaporstripping system would be simple to construct and operate, In Alternative 4A,the construction and permitting of the hazardous waste incinerator isconsidered to be moderately difficult and excavation of the landfill isconsidered to be difficult, For this reason, the Implementability criteriafor this option is not met, Construction and operation of the ash landfill isconsidered to be relatively simple and easy to implement. In Alternative 4B,the construction of the excavation/loading area for excavated mater tain wouldbe simple to construct and operate, However, excavation of the landfill isconsidered to be difficult,

If monitoring indicates that more action is needed for any of the alternativespresented, then it would be a simple matter to add more remedial actions if

AR30I6625-A8

For all of the remedial alternatives, the ability to monitor effectiveness \,J)exists, Over 90 groundwater monitoring wells are currently installed at thesite and nearby. For Alternative 1, groundwater monitoring plus the use ofthe early warning wells will give notice of failure of the action well beforesignificant risk exposure for downstream groundwater users can occur. Thesame Is true for Alternatives 2 through AB with the addition that routinesampling and analysis of groundwater treatment system discharges would allowmonitoring of ARAR compliance, For Alternative AA, continuous and automatedsampling and monitoring of suck emissions would give the ability loIndirectly monitor ARAR compliance for air emissions.

Groundwater monitoring and reporting to PADER does not require any approvalsfrom regulatory agencies for Alternative 1, Also, minimal coordination forreporting of the data is needed, Obtaining the required RCRA, NPDES, airemissions and other permits and approvals should be relatively easy to obtainfor Alternatives 2, 3 and AB. Alternative AA requires the acquisition ofpermits and approvals identical to those of Alternative AB with the addedrequirement of obtaining permits and approvals for the construction of a ;•'•','ilandfill and a hazardous waste incinerator. Permits for these types ofoperations are extremely difficult to obtain.

In terms of the availability of services and capacities, Alternative Irequires few services and its implementation will not affect any commerciallyavailable ca: .cities. For Alternatives 2 and 3, services and capacitiesneeded for implementation are readily available, In addition to thoseservices needed for the implementation of either Alternative 2 or 3,Alternative AA has the added need for incinerator construction and siteoperating services, which are available, For Alternative AB, most of theservices and capacities needed for the implementation of this remedialalternative are available, Transportation services are readily available.Incineration capacity is extremely limited and future capacity is uncertainand may not be available.

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For all of the alternatives, equipment, specialists and materials are readilyavailable. The availability of remedial technologies is not applicable toAlternative 1. The specialized technologies needed are available for all ofthe remaining alternatives, Alternative 2 requires groundwater treatmentpilot testing. Alternative 3 requires in situ vapor extraction andgroundwater treatment pilot testing, Alternative 4A and 4B technologies arereadily available, but the selected groundwater treatment technology requirespilot testing.

5.4,7 Costs

The capital, annual OiM, and present worth costs for these alternatives varysignificantly.

Order of magnitude cost estimates were provided in Section 3 for the purposeof preliminary screening, The costs presented in this section are for each ofthe assembled remedial alternatives, Cost estimates have been developed fordirect and indirect capital costs and operation and maintenance (04M) costs,The present worth of each alternative has been calculated for comparativepurposes. Direct capital costs include the following:

• Remedial action construction• Equipment• Buildings and services• Waste disposal costs

Indirect capital costs include:

• Engineering expenses• Environmental permit acquisition• Startup and shakedown• Contingency allowances

AR30I661)5-50

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Annual OiM costs include the following:

• Operating labor costs• Maintenance materials and labor costs• Chemicals• Energy and fuel• Purchased services• Administrative costs• OiM contingency• Costs for periodic site review (every five years)• Insurance, taxes, and license costs• Monitoring costs

The remedial action alternative cost estimates have an accuracy of +50 percentto -30 percent, For the purpose of the present worth calculations,Alternative 1 has a performance period of 100 yr and Alternatives 2, 3, 4A,and 4B can be completed in 50 yr. Major capital expenditure items arecompleted in 5 1/2 yr for Alternative 4A (Excavation and On Site Incineration)and 2 1/2 yr for Alternative 4B (Excavation and Off Site Incineration).

Alternative 1 involves no capital costs and has a long-term O&M cost of$100,000/yr in 1989 dollars, Alternatives 2 and 3 are comparable for bothcapital and operating costs with Alternative 2 requiring approximately$1,940,000 in capital cost compared to $2,500,000 for Alternative 3, The O&Mcost for Alternative 2 is $310,000 annually compared to $420,000/yr forAlternative 3 In years 1 and 2, which then decreases to $3IO,000/yr,Alternative AA is an order of magnitude higher than Alternatives 1, 2, and 3,and Alternative AB is two orders of magnitude higher than the first threealternatives considered, Alternative Aa has an estimated capital cost of$24,160,000 and a first year O&M cost of $5,760,000. This O&M cost would dropto $310,000 in year 7 of the remedial action, when the excavation andIncineration of the landfill is completed and the ash residue landfill isclosed. Alternative 4B has an estimated capital cost of $180,000,000,reflecting the extrememly high costs associated with off site transportationand incineration of such a large volume of material, The first AAO&I D<65for this alternative is $465,000 which drops to $310,000 in year 3 of theremedial action,

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1 Xhe present worth analysis employs a discount rate of 10 percent, A summaryof the costs developed for each remedial action is presented in Table 5-8,

5.4,8 Anticipated State Acceptance

State acceptance of Alternative 1 is not expected, Alternatives 2 and 3 arcexpected to be acceptable to PADER and other state regulatory agencies, It isdoubtful that state acceptance for Alternatives AA and AB would be received,

5,4.9 Anticipated Community Acceptance

In terms of community acceptance, Alternative 1 is not expected to be acceptedj by Girard Township and the surrounding area. It is expected that community

acceptance can be achieved for Alternatives 2 and 3, Community acceptance ofAlternative 4A is doubtful due primarily due to the installation of ahazardous waste incinerator and a new landfill in the midst of the community.Community acceptance for Alternative AB is also doubtful because of the

iy_) significantly increased traffic and heavy duty hauling by dump trailers oncommunity roads,

5,4,10 Comparative Analysis Summary

An examination of the compatibility of each of the remedial alternatives withthe nine CERCLA evaluation criteria indicate that remedial Alternative 1, theno action alternative, is not acceptable or compatible with any of theevaluation criteria, Remedial Alternatives 2 and 3 are both found to becompatible with all of the remedial alternative evaluation criteria. Remedialaction number 4A was found not to be compatible with the short-termeffectiveness, implementability, cost-effectiveness, and acceptance criteria,Alternative 4B was found to be compatible with most of the evaluation criteriabut not with the short-term effectiveness, cost effectiveness, and acceptancecriteria. A summary of the compatibility of the remedial alternatives withthe CERCLA evaluation criteria is presented in Table 5-9.

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Remedial Alternatives 1, AA and AB are removed from further consideration.The remaining remedial alternatives are the following: '•.., P

i Remedial Alternative 2 - Source and Migration Control by CroundwsterExtraction and Treatment

• Remedial Alternative 3 - Source Control by In Sicu Vapor Stripping;Source and Migration Control by Groundwater Extraction and Treatment

These two remedial alternatives are very similar. Alternative 2 is identicalto number 3 except that number 3 has the additional remedial action of in situvapor stripping for source control. This added feature should reduce the timeof treatment the remedial action is in progress, While Alternative 3 is$750,000 more expensive in terms of capital costs, than remedial actionAlternative 2, Alternative 3 is considered to be a more effective remedialaction. Source control by groundwater extraction which is supplemented byin situ vapor stripping is superior to source control by groundwaterextraction alone because volatile organic chemicals and some semi-volatilecompounds are quickly removed from the landfill. Under remedial (Âlternative 2, these compounds would be gradually released from the landfillvia the groundwater transport pathway and be pumped from the landfill area fora much longer period of time.

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The recommended remedial action alternative for the Shope Landfill ii§ remedial Alternative 3 - Source Control by In Situ Vapor Stripping; Source and

Migration Control by Groundwater Extraction and Treatment.

Remedial Alternative 3 has the benefit of being the most effective alternativefor this site, In terms of the FS evaluation criteria, this alternativeprovides superior overall protection of human health and the environment byremoving hazardous volatile and semi-volatile chemicals from the tource andnear lource. Compliance with ARARs would be met sooner with this alternativethan with any other alternative, The long-term effectiveness and permanenceof this remedial action is enhanced by the additional iMkOLAl CcQiW ofin titu vapor stripping. The reduction of toxicity, moonrty, or 'volume

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through treatment is accomplished by the removal and destruction of VOCs fromthe landfill and the treatment of VOCs and other synthetic organics and metalsin the groundwater. In terms of short-term effectiveness, this alternativepresents no risk to the community as compared to Alternatives AA and AB whichinvolve excavation and incineration, The selected remedial alternative has ahigh implementability rating as construction and operation of the in situvapor stripping and groundwater extraction and treatment systems arerelatively simple. It is anticipated that state (PADER) and communityacceptance will be achieved as this alternative Is effective and offersreduced risk to the community and reduced disruption of community activity.

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