UNITED STATES ENVIRONMENTAL PROTECTION · PDF file · 2017-12-13bgs below ground...

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4

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EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) ALTERNATE ENERGY RESOURCES (AER)

NATIONAL PRIORITIES LIST SUPERFUND SITE AUGUSTA, GEORGIA

JUNE 2015 /r" ^C,: „

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TABLE OF CONTENTS

ABBREVIATIONS AND ACRONYMS

I. Introduction 1

II. Summary of Site History 2

III. Description of the Remedy 3

IV. Basis for 2015 ESQ 5

V. Description of Significant Differences 7

VI. Supporting Agency Comments 8

VII. Statutory Determinations 8

Vlil. Public Participation Compliance 8

IX. Declaration 8

LIST OF FIGURES

Figure 1 - Site Location Map 10 Figure 2 - Facility Layout Map 11 Figure 3 - Picture of AER Property taken in 1989 12 Figure 4 - Site Map 13

LIST OF TABLES

Table 1 - Summary of Modifications to the ROD Selected Remedy 15

LIST OF APPENDICES

A - GA DNR Concurrence with the ESD B - Administrative Record Index

TABLE OF CONTENTS

ABBREVIATIONS AND ACRONYMS

AER Alternate Energy Resources AGO Administrative 8ettlement Agreement and Order on Consent

for Remedial Investigation/Feasibility 8tudy ARARs Applicable or Relevant and Appropriate Requirements bgs below ground surface CERCLA Comprehensive Environmental Response, Compensation,

and Liability Act COCs Chemical of Concern CY Cubic Yards DCE Dichloroethene EPA U.8. Environmental Protection Agency ERD Enhanced Reductive Dechlorination FS Feasibility 8tudy GADNR Georgia Department of Natural Resources ISCO ln-8itu Chemical Oxidation 188 ln-8itu 8tabilization I8TD ln-8itu Thermal Desorption MCLs Maximum Contaminant Levels MNA Monitored Natural Attenuation NPDE8 National Pollution Discharge Elimination 8ystem NPL National Pnorities List O&M Operations and Maintenance 08WER Office of 8olid Waste and Emergency Response PAH Polynuclear Aromatic Hydrocarbon PCE tetrachloroethene ppm parts per million PRP Potentially Responsible Party RAOs Remedial Action Objectives RD Remedial Design RGs Remedial Goals Rl Remedial Investigation ROD Record of Decision 8VE 8oil Vapor Extraction ICE trichloroethene Mg/L micrograms per liter yocs Volatile Organic Compounds

11

Explanation of Significant Differences Aitemate Energy Resources Site

EXPLANATION OF SIGNIFICANT DIFFERENCES TO THE REMEDY ALTERNATE ENERGY RESOURCES SITE

AUGUSTA, RICHMOND COUNTY, GEORGIA

I. INTRODUCTION

A- Site Name and Location

The Aitemate Energy Resources, Inc., Site (AER or the Site) is located at 2736 Walden Drive, in the southern part of the city of Augusta, Richmond County, Georgia (Figure 1). The National Superfund Database Identification Number is GAD033562461. The Site was placed on the National Priorities List (NPL) in 2006.

B. Lead and Support Agencies

The lead agency is the United States Environmental Protection Agency. The support agency is the Georgia Department of Natural Resources (GA DNR).

C. Legai Authority

Under Section 117(c) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. §9617(c), and 40 C.F.R. § 300.435(c)(2)(l) of the National Contingency Plan (NCP), if the EPA determines that differences in the remedial action significantly change but do not fundamentally alter the remedy selected in the Record of Decision (ROD) with respect to scope, performance, or cost, the EPA shall publish an Explanation of Significant Differences (ESD) which explains the differences between the remedial action being undertaken and the remedial action set forth in the ROD and the reasons for such changes. The remedial action described in this ESD remains protective and continues to meet Applicable or Relevant and Appropriate Requirements (ARARs) under 40 C.F.R. §§ 300.430(f)(l)(ii)(B)(l) arid (2) of the NCP.

D. Basis for this ESD

This ESD is being written to document modifications to the remedy Selected in the ROD signed on September 27, 2010.

The EPA is modifying the soil remedy for the Site. The selected soil remedy included three technologies, In-Situ Thermal Desorption (ISTD), In-Situ Chemical Oxidation (ISCO), and In-Situ Stabilization (ISS) to address the varying concentrations of soil contamination. Based upon the results of the soil Remedial Design (RD), ISS alone was determined to be the best of the three technologies to meet the soil remediation goals (RGs) in the ROD.


The EPA is also modifying the groundwater remedy for the Site. The selected groundwater remedy was Enhanced Reductive Dechlorination (ERD). Based upon the results of the groundwater RD and subsequent treatability studies, in-Situ Chemical Oxidation (ISCO), another in-situ technology evaluated in the ROD, was determined to achieve the RGs faster than ERD.

E. Avaiiabiiity of Documents

This 2015 ESD and supporting documents are part of the Administrative Record (NOP 300.825(a) (2)) for the Site. The Administrative Record, including its index, is available to the public and may be reviewed at the folidwing locations:

Information Repositorv EPA Region 4 Office Maxwell Library U.S. EPA 1927 Lumpkin Drive 61 Forsyth Street Augusta, North Carolina Atlanta, Georgia 30303 (706)793-2020 (404)562-8816

ii. SUMMARY OF SFFE HiSTORY

AER operated as a commercial waste storage and treatment facility from 1975 until 2000 when it declared bankruptcy. During the period of operation, the AER facility blended high-BTU materials to be used as fuel in industrial boilers, recycled waste solvents by distillation, and treated used oils, wastewater, and coolants. In July 1976, AER, Inc. began distilling waste oils into No. 5 fuel oil. Some water distilled from the waste fuels appears to have been discharged to an earthen pit, which later became the Rainwater Collection Basin. The facility layout is shown in Figure 2.

AER, Inc. submitted a RCRA Part B application in 1981 to store waste solvents prior to blending with fuels. Interim status was approved in 1983 for two areas. AER, inc. was issued a RCRA Permit in 1987, which required post-closure monitoring of the closed catch basin and a former drum storage area. AER, Inc. continued to distill waste solvents until 1993.

The AER facility generated wastes from the fuels blending, distillation, waste oil, and coolant operations from 1983 to 1993. Although all wastes that were not destined for energy recovery were to be shipped offsite, a number of historical releases to the ground surface, municipal storm sewer, and onsite catch basins have been documented. These released materials included solvents, waste oil, diesel fuel, and distillation/oil processing residues. In 2000, AER, Inc. ceased operations and declared bankruptcy. A picture of the AER Property taken in 1989 during its operations is shown in Figure 3.

Explanation of Significant Differences Alternate Energy Resources Site

The first environmental investigation at the Site was prompted by reported spills in 1984. AER, Inc. subsequently entered into consent orders with GA DNR. The first groundwater assessment concluded that VOCs had impacted groundwater downgradient of the AER Property. GA DNR conducted a sampling investigation of private drinking water wells during September 1986 that identified impacts from tetrachloroethene (PCE), trichloroethene (TCE), and 1,1-dichloroethene (1,1-DCE) in selected private wells. AER, Inc. performed a well use survey that identified downgradient residents who utilized groundwater as a drinking water source. AER, Inc. connected all but one of these residents (who refused connection) to the municipal water supply at that time.

Based on the results of the well sampling activities, GA DNR required AER, Inc. to perform an investigation of the area of impacted groundwater. The entire AER Site, including the AER Property and the area of plume extension is shown in Figure 4 (the AER Site extends to Rocky Creek to the south). AER, Inc. operated a groundwater recovery system from the late 1980s until 1999 to address VOC-impacted groundwater that was migrating off-Site to the immediate south.

In 2005, EPA sampled surface soil and sediment at 13 locations. Soil samples were analyzed for VOCs, PAHs, and RCRA metals. The results revealed soil samples contained elevated concentrations of VOCs and/or PAHs. The AER Site was proposed to the National Priorities List (NPL) in September 2005, and the listing was finalized in April 2006.

In October 2006, the EPA and fifty-six (56) settling parties signed an Administrative Settlement Agreement and Order on Consent (Settlement Agreement) for the conduct of a Remedial Investigation (Rl) and Feasibility Study (FS). The Rl report was approved in November 2008, the FS report was approved in April 2010 and the ROD was signed on September 27, 2010.

III. DESCRIPTION OF THE REMEDY

The selected remedy for soil was In-Situ Thermal Desorption (ISTD), In-Situ Solidification/Stabilization (ISS), In-Situ Chemical Oxidation (ISCO) and institutional Controls (ICs). The selected remedy for groundwater was Enhanced Reductive Dechlorination (ERD) of on and near-Property groundwater, monitoring and ICs to achieve cleanup levels at the AER Site.

The components of the selected remedy:

• Demolition of Buildings - Buildings and structures on the AER Property would be demolished and building debris removed from the property prior to implementation of the remedial actions.

• ISTD in Primary Source Zones 1 and 2 - ISTD treatment would be focused on soil impacts in an area where contamination extended to approximately 30 to 35 ft. below ground surface (bgs) (Zone 1) and in areas GP-8, GP-9, & GP-38 where

Explanation of Significant Differences Alternate Energy Resources Site I

impacts extend to approximately 16 to 20 ft. bgs (Zone 2). • Pre-design soil sampling would be conducted to refine the extent of the required

treatment zones. • The iSTD treatment would involve installation of approximately 85 evenly spaced

heating sources to depths of approximately 25 to 40 ft. bgs. Approximately 22 SVE wells would be Installed at even Inten/als across the treatment zones and would be screened from surface to total depths of approximately 20 to 30 ft bgs. Extracted soil vapor would be cooled to condense steam. Condensate and non-condensable vapors would be treated with GAG prior to discharge to the POTW and atmosphere, respectively, If required. Total soli treatment volume would be approximately 7,900 CY.

• Soil sampling would be conducted near the end of treatment to confirm that cleanup levels had been achieved.

• 1800 - A pre-desIgn treatability study would be performed to refine the composition and mass of oxidant and stabilizing agent required In the soils to be treated. Pre-design soil sampling would be conducted to refine the extent of the required treatment zones.

• A pilot test would be conducted to ascertain that design mixes from the treatability study and planned application technologies are effective.

• A persulfate solution would be sprayed Into treatment areas while an approximately 8 foot diameter auger mechanically mixes the soil to total depth of Impacts. The auger would treat one soil column at a time, creating a grid of treatment columns across Impacted areas.

• All Secondary Soil zone soils above cleanup levels would be mixed with the ISCO reagent to the total depth of Impacts.

• Once thorough mixing has been achieved, a stabilizing agent would be added to the treatment zone and mixed with the soil. This ISS would reduce mobility of any remaining COCs and would enhance the structural stability of the soil.

• The concentrations of applied ISCO reagent and ISS agents would be adjusted for different soil zones with varying contaminant concentrations based on the results of the treatability study.

• Soil samples would be collected to confirm constituent concentrations had been reduced to below the cleanup levels.

• At completion of the treatment, the AER Property would be re-graded and seeded with grass for erosion control.

• ICs - Implement land development/land use restrictions (e.g., through deed restrictions or zoning restrictions) at the AER Property to ensure that future land use Is limited to commercial, Industrial, and/or recreational uses.

• Abandon EX Wells - Extraction wells on the AER Property would be abandoned to limit potential downward migration of COCs through the well columns.

• ERD - An ERD pilot test would be performed to support full-scale design and to confirm that the technology will be effective at the AER Site. Full scale system would be likely comprised of approximately 25 to 35 injection wells screened from 35 to 50 ft. bgs targeted at areas of Impacted groundwater on the AER Property and In near-downgradlent areas.

• An ERD solution would be Injected to stimulate biological activity and subsequent


reductive dechlorination of COCs. The in-situ reactive zone (IRZ) created during ERD treatment would extend downgradient in the direction of groundwater flow and would additionally treat the near-downgradient impacted areas. The IRZ typically extends as far as groundwater would travel in 1-2 months. Injection volume, injection frequency and total number of Injection events would be determined by evaluation of operational parameters over the course of the treatment.

• Quarterly monitoring of VOGs and blogeochemical parameters would also be conducted in nearby monitoring wells to assess remediation performance and to refine the injection program if necessary.

• Groundwater monitoring activities would be conducted quarterly for two years, semi-annually for the next three years, and annually thereafter.

• ICs - Implement groundwater use restrictions at the AER Property.

The goal of the remedial action is to restore the groundwater to its beneficial use within a reasonable time frame. Until this goal Is achieved, ICs will be implemented to prevent human exposure to contaminated groundwater. Public water is available In the area and is supplied from municipal wells.

IV. BASIS FOR THE 2015 ESD

The purpose of this ESD is to document a significant change to the soil and groundwater remedies.

SOIL

Remedial Action Objectives (RAOs) for soil, as Specified in the ROD, are to prevent migration of soil contaminants that could result in groundwater concentrations above levels that allow for beneficial use. The ROD's selected remedy included provisions for the use of ISTD, ISCO and ISS, alone or in combination, to prevent the chemicals of concern (COCs) from leaching to groundwater.

Additional sampling and soil investigations were conducted in support of the Remedial Design. The presence of perched water and tight clays within the treatment zone were deemed to limit the effectiveness of ISTD in the deep soils at the Site. Subsequent treatability studies were performed to assess the effectiveness of ISCO and/or ISS in soils at the Site.

The initial soil treatability study was completed in accordance with the Soil Treatability Study Work Plan. Results of the study, as presented in the Soil Treatability Study Report, show that ISCO with catalyzed sodium persulfate could possibly be an effective treatment for VOCs in soil collected from the Site, but only if applied at high concentrations. The high application rates were not cost effective and showed potential increases in the leachability of some site specific VOCs. In addition, due to the presence of competing compounds at high concentrations, TCE and PCE were not fully oxidized to the RGs at the treatment doses tested. '


(SCO applied to soils also would hinder the groundwater remedy proposed for the Site by lowering the pH of groundwater and increasing oxygen levels resulting in a delay in the groundwater remedy Implementation.

The results of a subsequent treatability study, as provided in the Soil Treatability Study Addendum (November 2012), indicated that ISS combined with soil blending limited leaching of COCs from the soils by binding contaminants within the treated soil matrix thereby eliminating the requirement for applying oxidant. The application of ISS (10% Portland cement or 10% Portland cement with activated carbon added), assured that the RGs would be achieved.

Groundwater

The groundwater remedy chosen in the ROD was In-SItu ERD. Another remedy evaluated in the ROD, ISCO, was rated equally with ERD but the cost was estimated to be significantly higher. Nonetheless, due to its potential for faster treatment, ISCO was assessed along with ERD in the RD for treatment effectiveness in an area of the Site that has consistently displayed the highest levels of contaminant concentrations in the groundwater.

According to the October 2014 report. Results of the Groundwater Assessment Work Plan, both ISCO and ERD are effective treatments for Site groundwater but ISCO is the better technology because it chemically eliminates the VOCs whereas ERD requires controlling the subsurface environment to promote the anaerobic biological degradation, a more time consuming process. ISCO also improves conditions for downgradient VOC degradation by quickly eliminating the source area VOCs. With respect to monitoring, ISCO requires analysis of fewer parameters to document the degradation process and allows a shorter monitoring period. Finally, revised cost estimates indicate that using ISCO as opposed to ERD for groundwater treatment will cut costs by several hundred thousands of dollars, largely due to a shortened monitoring time period.

Catalyzed sodium persulfate is an effective, safe, and easy way to handle oxidant that can be injected in fairly high concentrations utilizing the ISCO technology. The February 2015 Groundwater Treatability Study Report documents the results of a four week bench scale study using this substance as the treatment agent. Study results demonstrate that ISCO using activated sodium persulfate will be a fast and effective treatment for VOCs in groundwater at the Site and will be capable of reaching the RGs specified in the ROD. To further gauge the effectiveness of this substance and the ISCO technology, ISCO pilot testing was performed in the AER area that exhibited the highest contaminant concentrations in groundwater to determine the radius of influence and the required reagent dosing rates.


V. DESCRIPTION OF SIGNIFICANT DIFFERENCES

This section describes the significant differences between the remedy in the ROD and the ESQ modifications, highlighting scope, cost, and performance along with any changes in expected outcomes as a result of the modification. Table 1 summarizes the main components of the selected remedy and identifies how the remedy modification impacts these components.

The expected outcome of the modified remedy is the restoration of the groundwater that will allow for its unrestricted use. The ROD specified soil remedy (ISTD, ISCO, and ISS) was estimated to cost $4.2 million dollars and require an estimated 12 months to complete. The modified remedy (ISS) cost $3.5 million dollars and was completed in 6 months. All RGs were met as detailed in the Soil RA Completion Report, March 2014.

The ROD specified groundwater remedy (ERD) was estimated to cost $3.1 million dollars, estimated to take 2-3 years to implement and estimated to achieve RGs in 27 years. The modified remedy (ISCO) will cost approximately $3 million dollars and can be implemented in 6 months. Achievement of RGs is expected to be shorter than the ERD estimate.

VI. SUPPORTING AGENCY COMMENTS

The EPA and GA DNR have evaluated the information contained in the Administrative Record for this ESD and concur that the information supports the need for the modification to the remedy. GA DNR concurs with the modified remedy selected in this ESD.

VII. STATUTORY DETERMINATIONS

The EPA has determined that the remedy selected in the ROD and the revised remedy described in this ESD are protective of human health and the environment. Comply with Federal and State requirements that are applicable or relevant and appropriate to this remedial action and are cost-effective. In addition, the revised remedy utilizes permanent solutions and resource recovery technologies to the maximum extent practicable for this Site.

VIII. PUBLIC PARTICIPATION COMPLIANCE

This ESD and supporting information are available for public review at the locations identified within this document. In addition, a notice of availability of the ESD will be provided to a local newspaper of general circulation.


iX. DECLARATION

For the foregoing reasons, by my signature beiow, I approve the issuance of this June 2015 ESD for the AER Superfund Site located in Augusta, Georgia and the changes and conclusions stated therein.

FranKiin E. Hill, Director Superfund Division


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TABLES

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Table 1. Summary of Modifications to the ROD Selected Remedy

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Selected Remedy in the ROD Remedy Modification

Component Cost Construction Time

RAOs achieved Component Cost Construction

Time RAOs

achieved

ISTD, ISCO, ISS to treat

contaminated soil

$4.2 million 12 months 12 months

ISS using 10% Portland cement and 10% Portland

cement with activated carbon

$3.5 million 6 months 6 months

In-Situ ERD to treat

contaminated groundwater

$3.1 million 2-3 years 27 years In-Situ ISCO by activated

sodium persulfate $3

million 6 months <27 years

APPENDIX A

Georgia Department of Natural Resources Environmental Protection Division-Land Protection Branch

2 Martin Luther King Jr., Dr., Suite 1054, Atlanta, Georgia 30334 (404) 656-2833; Fax (404) 651-9425

Judson H. Turner, Director

May 13,2015

Ms. Giezelle Bennett Remedial Project Manager EPA Region 4, Superfund Branch Sam Nunn Federal Center 61 Forsyth St., SW Atlanta, GA 30303-8960

Re: Alternate Energy Resources (AER) Explanation of Significant Differences (ESD)

Dear Ms. Bennett:

The Georgia Environmental Protection Division (EPD) has reviewed the "Explanation of Significant Differences (ESD)-Alternate Energy Resources (AER)-National Priorities List Superfund Site-Augusta, Georgia." EPD concurs with this document.

If you have any questions on this review or any other AER issues, please contact Will Steele at 404-656-2833.

Sincerely,

Amy Potter, Uhit Coordinator DOD Facilities Unit Hazardous Waste Management Program

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APPENDIX B

05/22/2015 9:08 am [Draft]

Administrative Record Index for the

ALTERNATE ENERGY RESOURCES INC (Explanation of Significant Differences)

GAD033582461

6.0 REMEDIAL DESIGN (RD)

6.4 Work Plans and Progress Reports

1. "Remedial Design Work Plan - Soil, Alternate Energy Resources (AER) Superfund Site, Augusta, Richmond County, Georgia," Cpnestoga^Rovers & Associates. (February 2012)

2. "Soil Treatability Study Work Plan, Alternate Energy Resources (AER) Superfund Site, Augusta, Georgia," Conestoga-Rovers & Associates. (May 2012)

3. "Resuits of Groundwater Assessment Work Plan, Preparation for Groundwater Remedial Design Work Plan, AER Superfund Site, Augusta, Georgia," Conestoga-Rovers & Associates. (October 2014)

6. 8 Remedial Design Documents

1. "Soii Treatability Study, Alternate Energy Resources (AER) Superfund Site, Augusta, Richmond County, Georgia," Conestoga-Rovers & Associates. (August 2012)

2. "30% Design Report - Soii, Alternate Energy Resources (AER) Superfund Site, Augusta, Richmond County, Georgia," Conestoga-Rovers & Associates. (November 2012)

7.0 REMEDIAL ACTION (RA)

7.1 Correspondence

1. Emaii from Clay McClamon, DeMaximis to Giezelle Benriett, USEPA (with attachment). Subject: Summary of Submittals arid Discussions Establishing ISS as the Remedial Action for Soiis at AER Site. (2:43 PM). (March 23, 2015)

2. Emaii from Ciay McClamon, DeMaximis to Giezelle Bennett, USEPA (with attachment). Subject Memorandum supporting iSCO for groundwater on the AER property. (3:38 PM). (April 06, 2015)

7.4 Work Plans and Progre^ Reports

1. "Final 100% Design and Remedial Action Work Plan - Soil, Altemate Energy Resources (AER) Superfund Site, Augusta, Richmond County, Georgia," Conestoga-Rovers & Associates. (August 2013)

2. "Groundwater Treatability Study Work Pian, Altemate Energy Resources Superfund Site, Atianta, Georgia," Conestoga-Rovers & Associates. (November 2014)

3. "Revised Groundwater Piiot Test Work Plan, Altemate Energy Resources Superfund Site, Augusta, Georgia," Conestoga-Rovers & Associates. (Aprii2015)

7. 8 Remedial Action Documents

1. "Remedial Action Report - Soil, Altemate Energy Resources (AER) Superfund Site, Augusta, Richmond County, Georgia," Conestoga-Rovers & Associates. (March 2014)

2. "Soil Remedial Action Oversight Summary Report, Revision 0, Aitemate Energy Resources Site, Augusta, Richmond County, Georgia," Black & Veatch Special Projects Corp. (May 2014)

3. "Groundwater Treatability Study, Altemate Energy Resources Superfund Site, Augusta, Georgia," Conestoga-Rovers & Associates. (February 2015)

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