SDMS DocID 2037780

FOCUSED FEASIBILITY STUDYFOR THE

MALVERN TCE SUPERFUND SITEWHITELAND TOWNSHIP, PA

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Golder Associates Inc.1951 Old Cuthbert Road, Suite 301 •Cherry Hill. NJ 08034 1Telephone (856) 6 1 6-8 1 66 "Fax (856) 6 16- 1874

FOCUSED FEASIBILITY STUDYFOR THE

MALVERN TCE SUPERTUND SITEWHITELAND TOWNSHIP, PA

Prepared for:

Chemclene Site Defense Group

Prepared by:

Golder Associates Inc.1951 Old Cuthbert Road, Suite 301

Cherry Hill, New Jersey 08034

DISTRIBUTION.

5 Copies U.S. Environmental Protection Agency2 Copies PA Department of Environmental Protection1 Copy CSDG Technical Committee2 Copies Golder Associates

May 2002

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JtJ Golder/̂Associates

Project No: 003-6000

A R O Q 0 6 6 UOFFICES ACROSS ASIA, AUSTRALASIA, EUROPE, NORTH AMERICA, SOUTH AMERICA

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Golder Associates Inc.

1951 Old Cuthbert Road, Suite 301

Telephone (856) 6 1 6-8 1 66Fax (856) 6 16- 1874

May 17, 2002 Project No.: 003-6000

USEPA Region III1850 Arch StreetPhiladelphia, PA 19103-2029

Attn: Mr. Charlie Root

RE: FOCUSED FEASIBILITY STUDYMALVERN TCE SUPERPUND SITEEAST WHITELAND TOWNSHIP, CHESTER COUNTY, PENNSYLVANIA

Dear Mr. Root:

On behalf of the Chemclene Site Defense Group, Golder Associates Inc. is pleased to submit tothe USEPA three copies of the Focused Feasibility Study (FFS) for the Malvern TCE SuperfundSite. The FFS provides an evaluation of an Alternative Soil Remedy for the FDA/MA portion ofthe Site. As requested, two copies of the FFS have been sent to Ms. April Flipse of PADEP andMs. Mary Jo Apakian of CDM Federal. Additional copies have been submitted to the partieslisted below.

We would be glad to discuss any questions or comments that may arise during your or yourcolleagues' review of the FFS. Please contact either Mr. Chris Young at de maximis, inc. (610-435-1 151) or me if you would like to discuss any aspect of the FFS.

Very truly yours,

GOLDER ASSOCIATES INC.

7-7

Randolph S. White, P.E.Principal

RSW:lrlG:\PROJECTS\003-6000MALVERN\FFS\EPA1_TRDOC

cc: April Flipse, PADEPMary Jo Apakian, CDM FederalCSDG Technical CommitteeChris Young, de maximis, inc.Paul Boni, Esq.

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TABLE OF CONTENTS '

Cover Letter

Table of Contents i

SECTION PAGE

1.0 INTRODUCTION 11.1 General Site Description 11.2 Background 2

2.0 BASIS FOR CONSIDERATION OF AN ALTERNATIVE SOIL REMEDY 42.1 Remedial Design Contingency Plan (Appendix C to RDWP) 52.2 USEPA Remedy Update Directive 52.3 USEPA Superfund Reforms 62.4 Refined USEPA ROD Remedy Cost Estimate 6

3.0 CONCEPTUAL SITE MODEL - FDA/MA SOILS 73.1 Surrounding Area 73.2 Site Geology 73.3 Nature and Extent of Constituents in Subsurface Soil 73.4 Summary of FDA/MA Soil Exposure Risks 9

4.0 DESCRIPTION AND TECHNICAL EVALUATION OF THE ALTERNATIVESOIL REMEDY 114.1 Remedial Action Objectives 114.2 Description of Alternative Soil Remedy 11

4.2.1 Site Preparation 124.2.2 SVE Well Installation 134.2.3 Collection and Treatment Systems Installation 144.2.4 System Operation and Performance Evaluation 144.2.5 Closure Activities 154.2.6 Alternative Soil Remedy Summary 15

4.3 Alternative Soil Remedy Performance Assessment 154.3.1 Summary of On-Site SVE Pilot Study Results 164.3.2 SVE as a USEPA Presumptive Remedy 174.3.3 Previous Evaluation of SVE by USEPA 184.3.4 Summary of Performance Assessment 19

5.0 DETAILED ANALYSIS OF THE ALTERNATIVE SOIL REMEDY 205.1 Protection of Human Health and the Environment 205.2 Compliance with ARARs 205.3 Long-Term Effectiveness and Permanence 215.4 Reduction of Toxicity, Mobility, or Volume 225.5 Short-Term Effectiveness 225.6 Implementability 235.7 Cost 245.8 State and Community Acceptance 24

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6.0 DETAILED COMPARISON OF THE ALTERNATIVE SOIL REMEDY TO THEUSEPA ROD REMEDY 256.1 Comparison of Potential VOC Mass Removal 25

6.1.1 Alternative Soil Remedy 256.1.2 USEPA ROD Soil Remedy 26

6.2 Threshold Requirements 266.2.1 Overall Protection of Human Health and the Environment 266.2.2 Compliance with ARARs 27

6.3 Balancing Criteria 276.3.1 Long-Term Effectiveness and Permanence 276.3.2 Reduction of Toxicity, Mobility or Volume 286.3.3 Short-Term Effectiveness 296.3.4 Implementability 316.3.5 Cost 31

6.4 State and Community Acceptance 33

7.0 SUMMARY 34

8.0 REFERENCES 35

In OrderFollowing

Page 35LIST OF TABLES

Table 1 Alternative Soil Remedy Cost EstimateTable 2 Revised Cost Estimate for USEPA ROD FDA/MA Soil Remedy Expanded to

Address the Extent of VOCs Identified During the Pre-Design Investigation

LIST OF FIGURES

Figure 1 Site Location MapFigure 2 Site LayoutFigure 3 Generalized Fence DiagramFigure 4 FDA/MA Subsurface Soil Characterization (Phase I)Figure 5 FDA/MA Subsurface Soil Characterization (Phase II)Figure 6 Interpreted Zones of VOC Exceedances of ROD SCSFigure 7 Conceptual Layout of SVE for FDA/MA Soils

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1.0 INTRODUCTION

This Focused Feasibility Study has been prepared on behalf of the Chemclene Site Defense

Group (CSDG) for the Malvem TCE Superfund Site (Site) located in East Whiteland Township,

Chester County, Pennsylvania. The primary objective of the Focused Feasibility Study is to

provide a technical evaluation of an Alternative Soil Remedy within the Former Disposal

Area/Mounded Area portion of the Site and to compare the Alternative Soil Remedy to the

remedy selected by USEPA as presented in the 1997 Record of Decision (USEPA ROD). The

evaluation of the alternative remedy and comparison to the USEPA ROD remedy has been

conducted in accordance with the nine National Contingency Plan (NCP) criteria.

1.1 General Site Description

The Site is located in East Whiteland Township, Chester County, Pennsylvania as shown on

Figure 1. The Site is owned and operated by Chemclene Corporation (Chemclene), which

currently operates a hauling operation and stores, repackages and sells hydrogen peroxide at the

258 North Phoenixville Pike location. Former operations at the Site have primarily included the

storage and sale of new solvents and the distillation recycling of used chlorinated solvents for

resale of the purified materials. The entire Site encompasses approximately five acres along the

southeast side of Bacton Hill, and consists of a Main Plant Area (MPA), located at the 258 North

Phoenixville Pike address, and a Former Disposal Area (FDA) and Mounded Area (MA) that are

connected to the MPA by a long narrow meadow corridor that coincides with the Williams

Transcontinental Natural Gas Pipeline right-of-way, as shown on Figure 2.

This Focused Feasibility Study addresses soils within the FDA/MA portion of the Site, which is

located approximately 1,900 feet southwest of the MPA, and consists of a partially wooded area

covering approximately 2 acres surrounded by forested land, as shown on Figure 2. As stated in

the Final Data Summary Report prepared by CH2MHill on behalf of USEPA (CH2MHU1, April

1995), borrow pits (approximate 15 feet in depth) were excavated in the FDA portion of the Site

in 1952 to supply construction materials for the gas pipeline that is currently operated by

Williams Transcontinental. These pits were reportedly filled by Chemclene over time with

discarded drums, equipment, rubbish, and soil. Subsequently, the drums and debris were

removed by Chemclene over several episodes from 1981 through 1984. Approximately 300

drums and impacted soil/debris were removed from two excavations to a depth of about 15 feet.

The FDA currently contains two partially water-filled excavations surrounded by remnant soil

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piles generated during the previous drum removal activities and is surrounded by an 8-foot-high

chain-link security fence.

The MA portion of the area is located directly west of the FDA. Previously, earth mounds

existed as the ground surface expression of drums buried in shallow excavations and/or natural

depressions. The drums were removed in the early 1990's and the removed soils returned to the

excavation leaving the mounded area in its current essentially flat ground surface condition

(CH2MH111, 1997a).

1.2 Background

The Site was placed on the National Priorities List (NPL) in September 1983, after concentrations

of TCE exceeding USEPA maximum contaminant levels (MCLs) were detected in nearby

domestic groundwater wells (located in Hillbrook Circle, south of the FDA/MA) as shown on

Figure 2. In 1987 Chemclene Corporation, as an operating facility, entered into a Resource

Conservation and Recovery Act (RCRA) Corrective Action Order with the USEPA. A RCRA

Facilities Investigation (RFI) Work Plan was approved for the Site in 1989. However, in July

1992, Chemclene withdrew its RCRA Part B Application as a treatment, storage, and/or disposal

facility, did not fully implement the RFI Work Plan, stopped accepting used solvents for

reclamation and halted its distillation process. As a result of Chemclene's failure to complete the

RFI and implement interim corrective measures, USEPA placed the Site under the

Comprehensive Environmental Response and Liability Act (CERCLA) remedial program in

November 1993.

The USEPA completed a Remedial Investigation of the Site, including the FDA/MA, in January

1997 and a Feasibility Study in June 1997. The Proposed Remedial Action Plan for the Site was

published in June 1997. USEPA issued a ROD presenting the selected remedial action for the

Site in November 1997. As described in the 1997 USEPA ROD, the selected remedy for

FDA/MA soils is excavation (to a depth of 15 feet, as assumed in the USEPA Feasibility Study),

off-site treatment and disposal of soils impacted by volatile organic compounds (VOCs). The

overall objective of the remedy as stated in the USEPA ROD is to reduce the potential for

continued migration of contaminants from impacted soils to the groundwater.

Golder Associates, on behalf of the CSDG, conducted a Pre-Design Investigation of the FDA/MA

soils, along with other areas and media at the Site in accordance with a Remedial Design Work

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Plan (RDWP) approved by USEPA on October 31, 2000. During the course of conducting the

Pre-Design Investigation, it became readily apparent that subsurface conditions in the FDA/MA

differed considerably from what was described in the USEPA Feasibility Study and ROD, and as

a result, the effectiveness of the USEPA ROD remedy to address the newly identified conditions

was questioned. Consequently, Golder Associates, on behalf of the CSDG, proposed to USEPA

to conduct an on-site Soil Vapor Extraction (SVE) pilot study to confirm the effectiveness of

SVE as an alternative for the removal of VOCs from impacted soils within the FDA/MA. The

SVE pilot study was completed between November 2001 and January 2002 and the results were

presented to USEPA at a meeting on March 5, 2001. During that meeting, USEPA requested that

the CSDG prepare and submit a Focused Feasibility Study that formally evaluates an Alternative

Soil Remedy for FDA/MA soils based on SVE and compares that alternative remedy to the

USEPA ROD remedy in accordance with the nine NCP criteria. This Focused Feasibility Study

is being submitted to USEPA to fulfill this requirement.

The PDI Report is being submitted to USEPA concurrent with this Focused Feasibility Study and

provides detailed information with respect to Site and regulatory background, the results of

USEPA's Remedial Investigation and the activities and results of the Pre-Design Investigation.

Summaries of the results from the Pre-Design Investigation and the USEPA Remedial

Investigation conducted for FDA/MA soils are also presented in this Focused Feasibility Study.

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2.0 BASIS FOR CONSIDERATION OF AN ALTERNATIVE SOIL REMEDY

In reviewing the new information, which is the primary basis for consideration of an Alternative

Soil Remedy for the FDA/MA portion of the Site, it is recognized that the USEPA Feasibility

Study (CH2MHill, 1997) originally evaluated SVE as a potential remedy for the FDA/MA. The

review concluded that in situ SVE-based remediation of the FDA/MA soils "would attain risk-

based remedial action levels for soil and subsurface sources" pending verification by a pilot

study. The Remedial Design Contingency Plan, included as Appendix C in the USEPA approved

Remedial Design Work Plan (RDWP), also allowed for consideration of alternative approaches

should subsurface soil conditions in the FDA/MA vary from what was described in the USEPA

Feasibility Study and ROD. Finally, SVE is a USEPA presumptive remedy for VOC-impacted

subsurface soils and provides protection of human health and the environment by permanently

removing VOCs from the soil, complies with applicable or relevant and appropriate requirements

(ARARs), and provides both long- and short-term effectiveness.

Significant new site-specific information, including a comprehensive subsurface soil investigation

and an on-site SVE pilot study, has been conducted and presented to the USEPA and PADEP

since the execution of the USEPA ROD and affect the basis of the former remedy selection. This

significant new information is consistent with the requirements for re-evaluation of the selected

remedy in accordance with 40 CFR §300.825(c). This new information is not in the

Administrative Record for the Site and was not available for consideration in the public comment

process on the Proposed Remedial Action Plan. Because this new information has materially

altered the previous remedy selection basis, it warrants re-consideration of the FDA/MA soil

component of the USEPA ROD Remedy.

The Alternative Soil Remedy presented herein is protective of human health and the environment

and is more readily implemented than the USEPA ROD remedy. Furthermore, a pilot study has

been completed confirming its effectiveness. The Alternative Soil Remedy will also result in

substantially less adverse impacts to the surrounding community, site workers, and local ecology,

and is more cost effective. Therefore, Golder Associates strongly believes that if this new site-

specific information had been available at the time of remedy selection, an Alternative Soil

Remedy of the type recommended herein would have been selected by USEPA consistent with

the NCP criteria and the statutory requirements of CERCLA.

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The following discusses specific issues relating to the basis for considering an Alternative Soil

Remedy for FDA/MA soils.

2.1 Remedial Design Contingency Plan (Appendix C to RDWP)

The Remedial Design Contingency Plan, included as Appendix C of the USEPA approved

RDWP, presents an approach for revising the USEPA ROD remedy should information obtained

during the Pre-Design Investigation substantially change the technical basis for selection and

design of the soil remedy, and/or should the re-evaluation of the assumptions made during the

USEPA Feasibility Study indicate that other remedial approaches would more effectively meet

the USEPA ROD performance standards. Based on the results of the Pre-Design Investigation, it

was determined that subsurface conditions vary considerably from those considered during the

USEPA ROD remedy selection process and that implementation of the Alternative Remedy will

more effectively meet the USEPA ROD objectives. Therefore, the Remedial Design Contingency

Plan, which discusses the possibility of SVE removal of VOCs as an alternative approach for

FDA/MA soils supports this evaluation of the Alternative Soil Remedy.

2.2 USEPA Remedy Update Directive

An additional basis for considering a change to the USEPA ROD remedy for FDA/MA soils is

presented in Superfund Reforms: Updating Remedy Decisions (OSWER Directive 9200.0-22).

Although intended to be applied to RODs existing at the time of publication, the concepts may be

applied to the consideration of the Alternative Soil Remedy. This directive states that:

"The purpose of this Superfund Reform is to encourage appropriate changesToremedies selected in existing Superfund Records of Decision (RODs). Theseupdates are intended to bring past decisions into line with the current state ofknowledge with respect to remediation science and technology and by doing so,improve the cost effectiveness of site remediation while ensuring reliable shortand long term protection of human health and the environment."

The directive goes on to say that "Modification of RODs generally is appropriate where

significant new information has become available (i.e., the information was not available at the

time the USEPA ROD was signed) that substantially supports the need to alter the remedy."

Further, the directive states that "In cases where a change in remedial technology or approach is

proposed, remedy updates should be based on site-specific information gathered or developed

after the USEPA ROD was signed." The directive also provides that updates are appropriate

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when new information indicates another remediation technology would perform as well as the

selected remedy for a significantly lower cost.

The significant new information obtained during the Pre-Design Investigation (including the SVE

Pilot Study) clearly meets the above USEPA criteria for significant new information. This new

information has a direct bearing on the evaluation of a more cost-effective remedial technology

for subsurface soils at the Site.

Moreover, the project schedule related criteria of the directive are also met because the project is

at the beginning of the design phase of the remedial process. Thus, USEPA's selection of the

Alternative Soil Remedy will not impact the design and construction schedule.

2.3 USEPA Superfund Reforms

In October 1995, the USEPA issued the Superfund Administrative Reforms (USEPA, 1995)

which provide a basis for re-evaluating remedy decisions, especially when new technical

information becomes available or when applicable regulatory policy changes occur after remedy

decisions have been made. The reforms allow for revising remedy decisions at specific sites

where new technical information or technological advancements become available that can

achieve the same level of protectiveness to human health and the environment and will comply

with ARARs at a lower cost. Clearly, the new information and analyses presented in this Focused

Feasibility Study indicate that the Alternative Soil Remedy is in line with these reform initiatives

and is the appropriate remedy to address the remedial action objectives for FDA/MA soil.

2.4 Refined USEPA ROD Remedy Cost Estimate

A revised cost estimate for implementing the USEPA ROD remedy for FDA/MA soils has been

developed by Golder Associates based upon the information provided in this Focused Feasibility

Study (see Section 6.3.5). The revised cost for the USEPA ROD remedy for FDA/MA soils is

$17.8 million, which is more than two times greater than the cost estimate of $7.0 million

presented in the USEPA ROD. Because USEPA has stated in The Rule of Cost in the Superfund

Remedy Selection Process (USEPA, 1996) that cost-effectiveness is an important criterion for

remedy selection, this revised cost estimate has modified the basis for the previous remedy

selection.

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3.0 CONCEPTUAL SITE MODEL - FDA/MA SOILS

Section 1.1 presented a general description of the FDA/MA portion of the Site. The following

presents a description of the surrounding area and the subsurface conditions identified during the

Pre-Design Investigation.

3.1 Surrounding Area

Adjacent to the Site are residential areas and areas with natural forestation and vegetation to the

west, north and east. A natural gas pipeline right-of-way and abandoned railroad extend along

the southern boundary of the area. The closest residential dwellings are within 400 feet of the

FDA/MA and are part of the Hillbrook Circle Subdivision. The Spring Mill Farms residential

development lies approximately 500 feet to the northeast. The Great Valley Senior High School

is located on Phoenixville Pike, approximately 1,800 feet southeast of the Site. Phoenixville

Pike, the main access route to the Site, is a busy, two-lane road.

3.2 Site Geology

The overburden soils within the FDA/MA can be categorized into three general vertical horizons:

• Upper clay - consisting of a locally disturbed surficial mostly silty clay unit with anaverage thickness of about 5 feet extending to depths of about 10 feet in places;

• Interbedded zone - consisting of silty sands, silts and clays interbedded with thin,discontinuous layers of sands and gravels lying about 20 to 25 feet below the upper clay;and,

• Lower clay - consisting of suffer and more homogeneous silty clays lying below theinterbedded zone and on top of the underlying carbonate bedrock that variably liesbetween about 45 to 60 feet bgs.

Figure 3 presents a generalized fence diagram illustrating the general lithology of the FDA/MA

overburden.

3.3 Nature and Extent of Constituents in Subsurface Soil

Significant new technical data has been gathered since the USEPA ROD was issued in November

1997 that has refined the understanding of the lateral and vertical distribution of subsurface

impacts. Data collected during the Pre-Design Investigation are presented and described in detail

in the PDI Report (Golder, 2002b). As described in the PDI Report, the actual lateral and vertical

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distribution of VOC impacts differed from the assumptions presented in USEPA's Feasibility

Study and adopted by the USEPA ROD. The predominant VOC mass lies within the interbedded

zone and extends to roughly 30 to 35 feet at concentrations exceeding the ROD SCS.

Conversely, the USEPA ROD assumed a limited aerial extent and maximum depth of

approximately 15 feet. Figures 4 and 5 provide a summary of the subsurface soil sample analyses

results obtained during the USEPA Remedial Investigation and Pre-Design Investigation.

The subsurface data were interpreted by the Environmental Visualization System Version 5.51

(EVS) to identify areas where VOC levels exceed the ROD SCS in the FDA/MA. A three-

dimensional simulation of the extent of VOC exceedances is shown on Figure 6.

The lateral and vertical extent of VOCs has been well defined for the purpose of the design and

implementation of an effective soil remedy. The majority of the subsurface soil VOC impacts are

contained within the lower portions of the upper clay and throughout the interbedded zone.

Smaller amounts were found in the upper portions of the lower clay. The VOCs of interest are

PCE, TCE, and 1,1,1-TCA and their natural breakdown products. Concentrations of VOCs

within the lower portion of the upper clay and the interbedded zone are variable, with limited

samples exceeding 1,000 mg/kg at depths approaching 25 feet (e.g., GB-2-B2 in the MA and GB-

39 in the FDA). Further, VOC concentrations in the lower portion of the interbedded zone and

upper portion of the lower clay have a substantially smaller aerial extent and lower concentrations

that quickly diminish with depth generally below about 30 to 35 feet in the upper portion of the

lower clay. These data are consistent with the extent and magnitude of VOCs detected in

groundwater, as described in the PDI Report, which are not indicative of a substantial source in

the vadose zone, but are more reflective of impacts from a diffuse source with the overburden

material. The depth to groundwater measured during the Pre-Design Investigation has ranged

from approximately 60 to 70 feet bgs below the FDA/MA.

The PCB results from the Pre-Design Investigation indicate limited detections of PCBs. None of

the PCB detections in the MA exceeded the ROD SCS of 1 mg/kg. Therefore, the final remedy

will not need to directly address PCBs in the MA. Within the FDA, PCB concentrations are low

and sporadically exist in shallow soils and soil piles and in a few localized deeper locations. Of

the PCB detections exceeding the ROD SCS, the highest is 14.44 mg/kg at GB-18 (a northern

excavation sidewall sample), the lowest value is 1.26 mg/kg at GB-11 (northern excavation base

sample). The average of the sample results that exceed the ROD SCS is approximately 6 mg/kg.

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The deepest PCB detection above ROD SCS occurred north of the northern excavation in boring

GB-35V (4.6 mg/kg at 16 feet bgs). The majority of the PCB Aroclors detected (1260 and 1254)

are some of the least mobile PCB Aroclors. Figures 4 and 5 show the locations and

concentrations of PCBs detected in the FDA/MA.

3.4 Summary of FDA/MA Soil Exposure Risks

The following summarizes the USEPA Baseline Risk Assessment results presented in the USEPA

Remedial Investigation Report and summarized in the USEPA ROD.

USEPA evaluated potential residential, industrial and trespasser direct contact exposures

(inhalation, ingestion and dermal) to FDA/MA soils. Except for the residential child soil

ingestion pathway, the potential risk estimates for all other direct contact exposure pathways to

FDA/MA soils were calculated to be within or less than the acceptable risk range established by

USEPA. The residential child exposure hazard index (4.0 for FDA soils and 2.5 for MA soils), as

stated in the USEPA Baseline Risk Assessment, only "slightly exceeds USEPA's benchmark"

and that "this hazard is associated with iron and manganese." All potential carcinogenic risks

associated with FDA/MA soil exposures are within USEPA's acceptable range.

The Uncertainty Analysis section of the Baseline Risk Assessment further discussed the estimated

hazard associated with potential future child resident exposure to soil as being mainly due to iron

detected in soil. The discussion further stated that:

• The reference dose for iron is provisional and possesses only a moderate level ofconfidence

• Iron is considered a human nutrient; and,

• The presence of iron is not necessarily due to historical activities.

Thus, the only soil direct contact exposure risk estimates that exceed the USEPA acceptable

range is attributable to natural background levels of iron and manganese. In summary, the

USEPA risk assessment concluded that there are no unacceptable risks from residential,

industrial, or trespasser direct contact exposures to site related constituents in FDA/MA soils.

The USEPA risk assessment did identify unacceptable risks from drinking untreated groundwater

at the FDA/MA portion of the Site. However, the nearby residents have been connected to a

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public water supply system1, thereby eliminating the current potential exposure pathway and thus,

the associated risks. The only remaining exposure pathway of concern is the potential future

residential use of groundwater should the FDA/MA be developed for residential purposes and not

connected to the public water supply system, which is an unlikely hypothetical scenario.

The results of the ecological portion of the USEPA Baseline Risk Assessment are based on two

evaluation approaches, direct toxicity and food chain accumulation. The direct toxicity

evaluation determined that neither metals nor volatiles pose a risk to ecological receptors in

FDA/MA soils. PCBs were determined to pose a potential ecological risk based on the food

chain evaluation. Similar to the human health assessment, the potential ecological risk associated

with metals was determined to be due to natural background conditions.

1 The USEPA ROD remedy required providing a public water supply to the Hillbrook Circle development residents.The CSDG have completed this aspect of the USEPA ROD and all the Hillbrook Circle residents are now connected toa public water supply.

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4.0 DESCRIPTION AND TECHNICAL EVALUATION OF THE ALTERNATIVESOIL REMEDY

This section provides a description of the Alternative Soil Remedy, including a technical

evaluation of the effectiveness of the SVE technology applied to FDA/MA soils.

4.1 Remedial Action Objectives

Given the results of the Baseline Risk Assessment presented in Section 3.4 of this Focused

Feasibility Study, the principal objective for remediation of subsurface soil in the FDA/MA, as

stated in the USEPA ROD, is "to reduce the potential for continued migration of contaminants in

these soils to the groundwater." USEPA developed the ROD SCS for VOCs based on the

groundwater protection objective as presented in the USEPA Technical Memorandum dated

December 20, 1996. The SCS were presented in the USEPA ROD as conservative standards to

guide the excavation remedy toward achieving the overall groundwater protection objective.

Notably, the concern for PCBs raised in the USEPA ROD focused on potential ecological

impacts, not potential impacts to groundwater. Therefore, the remedial action objective for PCB

remediation is to minimize ecological receptor exposures to PCBs in soils.

4.2 Description of Alternative Soil Remedy

Based on the results of the Pre-Design Investigation, VOCs are the primary constituents of

concern in FDA/MA soils and extend at concentrations exceeding the ROD SCS across the

FDA/MA to depths of about 30 to 35 feet bgs. PCBs are not a remedial concern in the MA. In

the FDA, PCBs marginally exceeding the ROD SCS were sporadically detected, primarily at

shallow depths. The deepest detection of PCBs exceeding the ROD SCS was at boring location

GB-35 (4.6 mg/kg at 16 feet bgs).

An Alternative Soil Remedy has been developed to address the above soil impacts and to achieve

the remedial action objectives for FDA/MA soils in a reliable and cost-effect manner. An SVE

system will accomplish the primary remedial action objective, namely, protection of groundwater

from future VOC impacts. Excavation of the limited shallow PCB impacted soils and adequate

cover over the remaining few isolated areas of deeper PCB impacts will accomplish the

ecological receptor protection objective.

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The Alternative Soil Remedy involves five major stages of implementation: site preparation

(which will accomplish the required PCB remediation), SVE well installation, VOC collection

and treatment systems installation, SVE system operation and performance evaluation (which will

accomplish the required VOC remediation), and closure.

4.2.1 Site Preparation

During typical site preparation for SVE systems, grading operations are performed to create a

generally flat working surface. Limited excavation of shallow PCB impacted soils is also

necessary to minimize ecological exposures and thus will be accomplished as part of site

preparation. As discussed previously, PCB impacts to MA soils are not a remedial concern.

Soils in the FDA impacted with PCBs at concentrations above the SCS will be excavated to a

depth of 2 feet and re-filled and graded with clean soil (18 inches of general fill covered with 6

inches of topsoil) as determined during remedial design to maintain proper grades.

The soil piles in the FDA area will also be removed or regraded as necessary based on the overall

grading plan prepared during detailed design and the results of sample analyses to be conducted

during remedial action. Soil piles, surface soil, and the remnant roll-off contents with

constituents at levels that exceed the ROD SCS will be removed and disposed of off-site. Soil

piles having PCB (and VOC) concentrations below the SCS will be used as grading material to

help fill in the surficial PCB excavation areas and other low lying areas.

The two partially water-filled excavations in the FDA are intended to be used as SVE extraction

galleries. Initially, the accumulated water will be removed from the two excavations during the

site preparation stage. The water will be tested and disposed of accordingly. To improve

pneumatic connection between the extraction galleries and surrounding subsurface soils, 2 feet of

sidewall and base materials (which have likely clogged with fine particles and vegetative debris

over the years) will be removed from the excavations and disposed of along with other impacted

soils removed from the FDA. The excavations will then be filled with a material having a higher

pneumatic permeability than the surrounding soils and covered with a low permeability layer to

mimic the upper clay low permeability cover over the interbedded zone that lies across the

remainder of the FDA/MA. The removal of this 2-foot soil/sediment layer from the sides and

bottom of the excavations will result in the removal of additional PCBs.

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'>Completion of the Site preparation work will leave only two measured PCB exceedances of the

ROD SCS. These two exceedances occur at depths between 10 and 16 feet bgs, which are

inaccessible to ecological receptors.

Grading will also be performed in the MA. When completed, site preparation will provide a

relatively clear and flat working surface to build and operate the SVE system and will have

accomplished the USEPA ROD objective for PCBs by providing protection of ecological

receptors.

Preparation activities also include improving the access road along the railroad right-of-way;

building a road crossing of the pipeline right-of-way; removing the fence around the FDA (where

needed to implement the remedial action in the area); installing a temporary fence around the

working area; and removing an old roll-off container and other debris if encountered and

characterizing and disposing of such items as appropriate. A contingency plan will also be

developed for the handling and removal of drum carcasses, if any are uncovered during the Site

preparation work.,

4.2.2 SVE Well Installation

As shown on Figure 7, the SVE wells designed to remove VOCs from the lower portion of the

upper clay and throughout the interbedded zone will be installed at a 35-foot lateral spacing with

screens extending from about 5 feet below ground surface (feet bgs) to approximately 25 to 35

feet bgs. The results from the SVE pilot study demonstrated a 25-foot radius of influence.

Therefore, the 35-foot spacing provides more than 30% overlap of influence from adjacent SVE

wells. The specific screen interval and depth at each well will be based on the Pre-Design

Investigation results (e.g., boring logs and subsurface soil sample analyses results) and will be

finalized during design. Additional SVE well(s) may be constructed to confirm that the SVE

system addresses the extent of VOC impacts.

The deep wells used to extract VOCs from the lower clay below the interbedded zone will also be

installed at a 35-foot lateral spacing, as shown on Figure 7. Fewer wells are installed in this zone

as the lateral distribution of VOC impacts at depth are substantially less. The length and depth of

screens will be based on the Pre-Design Investigation boring results, which provided an overall

vertical delineation of VOC impacts and top of bedrock. Refinements to the screen settings, if

necessary, will be accomplished using borings installed during SVE well installation.

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4.2.3 Collection and Treatment Systems Installation

A series of wellhead assemblies, piping (underground and/or aboveground, heat-traced as

necessary), condensate collection traps (if needed); knock-out pot, blower system,

valves/controls; monitoring equipment; and other appurtenances will be installed. A temporary

fence will be installed around exposed equipment associated with the SVE system. Electrical

power will be brought to the FDA/MA. The SVE air emissions treatment system will likely

consist of vapor phase activated carbon units constructed in series2. The type, size, and details of

the SVE collection and treatment systems will be defined during detailed design.

4.2.4 System Operation and Performance Evaluation

During start-up operations, the SVE system will be balanced to optimize extraction flow rates,

VOC mass removal, and energy use. Long-term operation of the SVE system will be conducted

on a routine basis and will include monitoring of flow rate, VOC concentrations and system

vacuums. Ongoing adjustments of the system operation will be made as needed to optimize VOC

mass removal until the SVE system begins to reach the limits of the technology. This occurs

when the rate of mass removal begins to become diffusion limited and further continuous SVE

operation does not efficiently remove VOCs, i.e., the system begins to reach its asymptotic

endpoint.

It is anticipated that different portions of the system will begin to reach their asymptotic

endpoints at different times. To maximize the efficiency of SVE performance in these portions,

the operation of the effected wells will be switched to a cycling mode (singly or in clusters).

Cycled operation maximizes the rate of VOC mass removal by allowing sufficient time for

remaining low levels of VOCs to diffuse from the soil matrix to the vapor phase where they can

be extracted in a pulsed manner. Cycling operations will be adjusted as needed and continued

until the removal of the rebounding mass is negligible.

Ultimately, the operational effectiveness of the SVE system will reach the limits of the

technology where, after cycling operation, the rate of VOC mass removal asymptotically levels

off to a point that is negligible as compared to the energy expenditure needed to continue

2 For the purpose of this Focused Feasibility Study, the vapor phase treatment component of the Alternative SoilRemedy is assumed to be activated carbon. Other vapor phase treatment technologies may be considered duringdetailed design. Further, it may not be necessary to treat extracted VOC vapors during the entire period of operation,particularly in the later stages when potential VOC emissions will be substantially reduced. In any case, vapor phasetreatment will be provided to the extent necessary to comply with federal and state air emission regulations.

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operation of the SVE system. This point is commonly referred to as the asymptotic endpoint of

an SVE system. Specific criteria for defining the asymptotic endpoint (i.e., the SVE operation

performance objectives) will be developed during detailed design. Once the VOC removal

reaches asymptotic conditions, system operation will be discontinued.

4.2.5 Closure Activities

Once the SVE system reaches its performance objectives, and following USEPA's system shut-

down approval, the SVE system and wells will be decommissioned and removed from the Site.

Site restoration activities such as vegetating disturbed areas will be completed and the fence will

be removed. It is estimated that closure activities may commence within 2 to 5 years following

start-up of the SVE system.

4.2.6 Alternative Soil Remedy Summary

The Alternative Soil Remedy contains an excavation component similar to the USEPA ROD

Remedy for FDA/MA soils albeit at a much smaller scale. However, unlike the USEPA ROD

remedy, the Alternative Soil Remedy removes the majority of the VOCs from soil via SVE rather

than excavation, thus facilitating the removal of deeper VOC impacts identified in the Pre-Design

Investigation. The SVE system will not only effectively extract VOC from shallow subsurface

soil as contemplated by the USEPA ROD Remedy, it will also remove VOCs from deeper, less

accessible locations not considered in the USEPA Feasibility Study or ROD. Treatment of VOCs

will be accomplished off-site as part of the vapor phase carbon treatment/regeneration. Operation

and maintenance activities and performance monitoring will be conducted to ensure the long-term

effectiveness of the Alternative Soil Remedy for meeting the principle objective of the USEPA

ROD, namely groundwater protection.

4.3 Alternative Soil Remedy Performance Assessment

Since the signing of the USEPA ROD, significant new, site-specific technical information has been

developed that has allowed a more refined and conclusive evaluation of the performance of the SVE

technology applied to FDA/MA soils. In particular, an on-site SVE pilot study was performed. This

section discusses the evaluation of the performance of SVE in FDA/MA soils for meeting the overall

groundwater protection objective.

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4J.I Summary of On-Site SVE Pilot Study Results

Golder Associates conducted a program of full-scale field testing to assess the potential performance

of SVE and to satisfy the concern identified in the USEPA ROD, namely that there was insufficient

information to adequately evaluate the SVE technologies' effectiveness in site-specific conditions.

Notably, USEPA's Feasibility Study also identified the need to conduct a pilot study.

Success Criteria

The SVE pilot study was completed in the MA portion of the Site in accordance with the

USEPA-approved SVE Pilot Study Work Plan (PSWP; Colder, 2001b). In the PSWP, Golder

Associates specified the following operational criteria to be used to determine "success" of the

SVE system:

• Remove and sustain the removal of significant quantities of VOC mass with initialrecovery rates in excess of 1 pound per day;

• Achieve adequate air flow through the impacted soil zones, defined as an air flow rategreater than 20 standard cubic feet per minute (scfm) at vacuum levels less than 16 inchesof mercury (in Hg);

• Achieve a 30-day time interval radius of influence (ROI30) of 10 feet or greater;

• Soil air-phase permeabilities should be greater than IxlO"9 cm2;

• Chemicals should be volatile and exhibit appropriate Henry's Law constants and vaporpressures for effective removal by SVE;

• Depth to water table should exceed 10 feet; and,

• Highly permeable fill or man-made passageways (i.e., sewers or pipe ways) should beabsent to minimize airflow short circuiting or preferential flow.

SVE Pilot Study Results

Results of the pilot study indicate that the SVE pilot system has met or exceeded the performance

criteria defined in the USEPA approved SVE PSWP for the FDA/MA as evidenced by the

following observations:

• Mass removal rates of approximately 18 pounds per day were attained (PSWP criteria - >1 Ib/day), indicating that SVE can remove substantial VOCs at a sustainable rate. Thepilot study results showed an increasing area of influence around the extraction well andhence, increasing concentrations extracted with time;

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• Air flow rates for the three SVE test cluster wells combined were Over 20 scfm (PSWPcriteria - > 20 scfm);

• The ROIjo was estimated to be 25 feet (PSWP criteria - > 10 feet);

• Air permeability was estimated to be 3x10~9 cm2 to IxlO"8 cm2 (PSWP criteria - > IxlO"9

cm2);

• The VOCs of interest all exhibit Henry's Law Constants amenable to effective removalby SVE; and,

• The depth to groundwater ranges between 60 to 70 feet bgs (PSWP criteria is 10 feet).

The Pilot Study also indicated that the zones of potentially higher permeable material (i.e., the

thin, discontinuous layers of sands and gravel within the interbedded zone) did not result in short-

circuiting the performance of the system. In fact, the results indicate that the interbedded unit

(which contains the majority of the VOC mass) responded uniformly as a sandy/silty material.

This homogeneous domain (as observed during the pilot study) is more favorable than a domain

having preferential flow paths within highly permeability areas. The uniform vertical and

horizontal performance results observed during the test will also reduce the need for the

installation and operation of a system with targeted intervals in a full-scale SVE system, i.e.,

fewer wells with longer screens can be used. In addition, the upper clay provides a natural low

permeability cover over the system, minimizing ambient air infiltration and maximizing vapor

extraction from the most impacted unit, the interbedded zone, that lies directly beneath the upper

clay.

In summary, the results of the SVE Pilot Study indicate that removing substantial quantities of

VOC mass from the impacted soil zones in the FDA/MA is achievable and that SVE is a viable

alternative technology to consider for remediating VOC impacted soils in the FDA/MA.

4.3.2 SVE as a USEPA Presumptive Remedy

The SVE technology has been identified by USEPA as a presumptive remedy for sites with soils

contaminated by VOCs in the technical guidance entitled: "Presumptive Remedies: Site

Characterization and Technology Selection for CERCLA Sites with Volatile Organic Compounds in

Soils" (USEPA 540-F-93-048, 1993). In 1997, USEPA published supplemental technical guidance

that addresses and recommends SVE for removal of VOCs in low to moderate permeability soils,

such as those at the FDA/MA. In particular, the conditions within the FDA/MA meet the

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requirements for successful remediation presented in the 1993 and 1997 USEPA technical guidance

and the U.S. Army Corps of Engineers Design Manual (USACOE, 1995) as follows:

• The vast majority of the constituents present in the soil are halogenated volatile organicsthat are listed by the USEPA as amenable to SVE removal. Removal of the PCBs, doesnot interfere with the effectiveness of SVE;

• The constituents of primary concern have Henry's Law Constants >0.00024 (atm-mVmol) @ 20°C and vapor pressures >1.0 mm Hg @ 20°C, as shown below:

ConstituentPCETCE

1,1,1-TCA1,1 -DCE1,1 -DCA

Methylene chloride

Henry's Law Constant(atm-m3/mol)

0.0230.01030.0130.023

0.00590.00131

Vapor Pressure(mm Hg)

18.560100500180349

The moisture content of the soil above the water table is well below 50 percent (5 to 18percent); and,

The soil was found to exhibit less heterogeneity than predicted by the original conceptualmodel of the FDA/MA, and no high permeability preferential pathways negatively effectingsystem performance were identified during the pilot study.

The USACOE recommends pilot testing to confirm the feasibility of SVE in low to moderate

permeability soils, such as at the FDA/MA. A pilot study was performed that confirms SVE as a

feasible remedial technology for VOC removal under site -specific conditions. Moreover, the new

USEPA presumptive remedy guidance identifies ten case studies where SVE has been successfully

employed in low permeability soils impacted with VOCs. The mass removal rates and vapor flow

rates observed during the on-site SVE pilot study are within the ranges observed in these case

studies. In fact, the pilot study data presented for the FDA/MA Site predicts performance well in

comparison to the case studies presented by USEPA as successful applications of the technology.

4.3.3 Previous Evaluation of SVE by USEPA

SVE was investigated as a possible remedy for the soils in the FDA/MA in the USEPA

Feasibility Study. It was favorably recognized in the USEPA Feasibility Study to protect human

health and the environment; provide long-term effectiveness and permanence; reduce toxicity,

mobility, and volume of contaminants; and be implementable. The USEPA ROD states that the

SVE alternative remedy "will greatly accelerate the rate at which the clean up levels can be

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attained. VOC contaminants will be removed from the subsurface soils." However, the USEPA

ROD states that the effectiveness of SVE needs to be demonstrated for site-specific conditions

through a treatability study, which, while not conducted as part of the USEPA Feasibility Study

or ROD remedy decision process, was conducted during the Pre-Design Investigation as

described above.

4.3.4 Summary of Performance Assessment

In addition to 1) its designation by the USEPA as a presumptive remedy for VOCs; 2) the

identified Site conditions being amenable to successful SVE remediation as shown by

USEPA/ACOE studies and documents; and 3) positive review of the application of SVE to

FDA/MA soils by the USEPA in the Feasibility Study and ROD, the performance of SVE for

effectively removing VOCs from FDA/MA soils was confirmed by the results of the SVE pilot

study conducted at the Site. The limited PCB impacts will be addressed by excavation and off-

site disposal of PCB impacted soil within the first 2 feet of ground surface soil piles and the

sidewalls and base of the excavations. For the minor PCB impacts at depth (only two remaining

locations), ecological receptors will be protected by limiting exposure through the remaining

cover material.

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^5.0 DETAILED ANALYSIS OF THE ALTERNATIVE SOIL REMEDY

This section provides a detailed analysis of the Alternative Soil Remedy in accordance with the

same NCP criteria that were used to evaluate the alternatives considered in the USEPA ROD.

This evaluation demonstrates that the Alternative Soil Remedy meets the requirements of the

NCP and the statutory criteria in Section 121 of CERCLA.

5.1 Protection of Human Health and the Environment

The Alternative Soil Remedy provides a high degree of long-term protection of human health and the

environment by removing VOCs from the soil through SVE, thus meeting the USEPA groundwater

protection objectives. SVE, identified by USEPA as a presumptive remedy for the remediation of

VOCs in subsurface soils, has been well documented by USEPA and the USACOE to be effective in

the subsurface conditions similar to those that exist in the FDA/MA. Importantly, the effectiveness

of SVE has been confirmed by an on-site SVE pilot study as a method that can effectively remove

large quantities of VOC from subsurface soils. This substantial removal of VOC mass will provide

effective source control and treatment mitigating future impacts of VOC leaching from unsarurated

zone soils to groundwater in support of the USEPA ROD MNA remedy for FDA/MA groundwater.

In fact, the USEPA ROD concurs that SVE will provide overall protection of human health and the

environment (see Section IV, Comparative Analysis of Alternatives). The removal of surficial PCB

impacts and the remaining cover over the few minor, localized PCB impacts at depth will minimize

potential future ecological receptor exposures to PCBs. Therefore, the Alternative Soil Remedy

provides protection of human health and the environment.

5.2 Compliance with ARARs

The Alternative Soil Remedy will comply with ARARs as follows:

• If the residuals generated during the implementation of the Alternative Soil Remedy(excavated soil, spent carbon, etc.) are determined to be hazardous as defined in RCRA, theremedy can easily be implemented consistent with RCRA and Pennsylvania hazardouswaste regulations related to pre-transport, transport, treatment, and disposal of hazardouswastes. Otherwise, the residuals will be handled in compliance with applicable non-hazardous solid waste regulations;

• Fugitive dust and VOCs that may be generated during remedial activities will be controlledto comply with federal and state air regulations such as those contained in the federally-approved State Implementation Plan and the National Ambient Air Quality Standards forParticulate Matter and VOCs;

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• Because VOCs may be released into the air during remedial activities, particularly duringlimited excavation activities, air monitoring will be performed in accordance with applicableOSHA regulations and guidance;

• The installation of wells will be conducted in accordance with Chester County and otherapplicable drilling regulations; and,

• Air emissions from the SVE system will be controlled by an on-site treatment systemdesigned for the VOCs of interest. Specifics of the VOC capture system will be determinedduring the detailed design phase. The air emissions control system will be designed andoperated in compliance with the State and Federal air regulations, including Air EmissionsStandards for Equipment Leaks (40 CFR §264.1030-1063), national Emission Standards forHazardous Air Pollutants (if applicable), Best Available Technology regulations (25 PACode §127.12), air permitting requirements, and Pennsylvania guidelines for remediationprojects, as necessary.

In addition, the USEPA ROD and Feasibility Study indicate that the SVE remedy can be

implemented in compliance with chemical-, location-, and action-specific ARARs that were

identified in these documents. In summary, the Alternative Soil Remedy can be constructed,

operated, and decommissioned in compliance with ARARs.

5.3 Long-Term Effectiveness and Permanence

As discussed in Section 4.3, SVE is a highly effective technology for removing substantial

quantities of VOCs from subsurface soils. In fact, USEPA has identified SVE as a preferred

technology for conditions such as those that exist at the Site. The high degree of effectiveness of

SVE has been demonstrated via the on-site pilot study and is well-documented in USEPA and

USACOE guidance and published literature. The SVE system will permanently remove VOCs

from subsurface soil, thus providing long-term effectiveness for meeting the groundwater

protection objective.

The extracted VOCs in the vapors will be treated. Therefore, the Alternative Soil Remedy meets the

CERCLA statutory goal of permanence, not only from the perspective of permanently removing the

VOC from the Site but also because the VOCs will be permanently destroyed through treatment. In

fact, the USEPA Feasibility Study describes the SVE alternative as:

"a permanent treatment solution. By-products from the SVE process consist ofspent carbon used for off-gas treatment and condensate water collected in thewater/vapor separator. The spent carbon would be sent off-site for regenerationand re-use...The condensate would be sent off-site for treatment and disposal.After remedial action, all on-site risks would be below risk-based levels.Following implementation of this alternative, the site could be returned to normaluse with few restrictions."

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Potential ecological receptors will be protected through excavation of PCB exceedances within the

first 2 feet of the ground surface. Adequate cover materials will remain over the limited deeper PCB

detections to ensure ecological protection.

Altogether, the Alternative Soil Remedy provides a reliable, long-term remedy for meeting the

remedial action objectives of protection of groundwater and ecological receptors. In addition, the

Alternative Soil Remedy provides a high degree of permanence through permanent removal of

VOCs and PCBs from soil, as well as destruction of VOCs through off-site treatment of spent

carbon.

5.4 Reduction of Toxicity, Mobility, or Volume

The Alternative Soil Remedy will provide a high level of reduction of toxicity and volume of VOCs

through on-site removal and off-site treatment. As discussed in the preceding section, the extracted

VOCs will be captured in carbon units and destroyed via off-site treatment. While already minimal,

the volume of PCBs will be further reduced through shallow soil excavation and other Site

preparation activities. Altogether, the Alternative Soil Remedy will provide a high degree of

reduction of toxicity, mobility, and volume of constituents contributing to the principal threats at the

Site.

5.5 Short-Term Effectiveness

The Alternative Soil Remedy, which is predominantly an in situ technology, is expected to have

minimal short-term impacts to the surrounding public, surrounding land, and remedial contractor

workers. The limited excavation and regrading activities performed during site preparation will

minimize the potential for VOC emissions and vehicle traffic noise due to its shallow depth and

limited extent. Soil excavations will be small and shallow, quickly completed and backfilled and

no construction personnel will need to routinely enter and work within the excavations. While

the Alternative Soil Remedy includes some off-site transportation, the amount of truck round trips

(estimated to be between 50 and 100) transporting the impacted soil and spent carbon through the

surrounding area is minimal (as compared to the USEPA ROD remedy), and is not expected to

substantially impact the local community and traffic. The limited extent of the shallow PCB

excavation activities and minimal land disturbance associated with construction of the SVE

system will preserve much of the existing forested area surrounding the FDA/MA.

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Given the small size and shallow depth of the excavations and short duration of excavation

activities, and the small amount of SVE well drill cuttings that will become exposed at the

surface, engineering controls can effectively reduce VOC emissions to protect workers and

potential downwind receptors. During the shallow PCB excavations, the installation of SVE

extraction wells and installation of subsurface piping may require limited use of personnel

protection equipment and air monitoring, which is standard in the industry. Soil erosion that

could potentially occur during construction (grading of surface material, construction of surface

water controls, limited small scale excavations, etc.) can be easily and effectively controlled by

standard engineering practices.

Operation of the SVE blower can potentially increase background noise levels at nearby residences.

However, background noise can be effectively controlled by enclosing the blower in a building, thus

muffling ambient noise. A diesel-powered electrical generator will not be required as permanent

electrical power will be supplied via power lines. Notably, Golder Associates was not notified of any

residential noise complaints when both a blower and unenclosed diesel generator were employed

during the Pilot Study.

Typical operating periods for SVE systems range between 2 and 5 years. During this time, the

system will require minimal operational and maintenance activities, including the periodic exchange

of carbon. Fencing installed during the site preparation phase will discourage trespassing during the

Alternative Soil Remedy implementation and operation.

The Alternative Soil Remedy is expected to be effective in the short-term. Potential short-term

impacts associated with construction and/or operation and maintenance of the Alternative Remedy

can be readily addressed. In fact, USEPA's Risk Reduction Engineering Laboratory in Cincinnati,

Ohio has stated that SVE is an in situ process that minimizes exposure to the public, personnel,

and the surrounding environment (Frank & Barkley, 1994).

5.6 Implementability

The Alternative Soil Remedy can be easily implemented. The installation of SVE wells and

associated piping and appurtenances is relatively straightforward. The SVE collection and treatment

systems utilize standard, off-the-shelf equipment that can readily be installed and operated. Agency

approvals for air emissions are expected to be easily obtained. By limiting the area and depth of

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excavation, the Alternative Remedy minimizes potential implementability issues associated with

larger scale excavations, including potential VOC emissions, truck traffic, etc.

Overall, no technical problems are envisioned which would adversely affect the schedule,

implementation or operation of the Alternative Soil Remedy. Services, materials and equipment

needed to design, install, operate and maintain the Alternative Soil Remedy are standard and widely

available.

5.7 Cost

Table 1 provides a breakdown of the cost estimate associated with the Alternative Soil Remedy and

includes total operation and maintenance costs over a 5-year period as well as administrative design

and contingency costs. The 5-year period is used solely for costing of the Alternative Soil Remedy.

The period of operation for SVE typically ranges between 2 to 5 years. The estimated construction

cost, O&M cost, and system decommissioning cost are $1.8 million, $1.6 million, and $100,000

respectively, resulting in the total estimated cost for the Alternative Soil Remedy of $3.5 million.

5.8 State and Community Acceptance

These criteria are used to evaluate technical and administrative issues or concerns that the

Commonwealth of Pennsylvania or local community may have regarding the Alternative Soil

Remedy. Neither the Commonwealth of Pennsylvania nor the local community are expected to

raise technical or administrative concerns that cannot be adequately addressed, particularly since

SVE is a presumptive remedy. The results of the SVE pilot study and the Alternative Soil

Remedy concepts were presented to both USEPA and the Pennsylvania Department of

Environmental Protection (PADEP) representatives during a meeting on March 5, 2002. PADEP

representatives did not voice opposition to consideration of the Alternative Soil Remedy. While

some public opposition may be realized as a result of the limited transport of impacted soil

through the community and possibly noise, these issues are minor when compared to the USEPA

ROD remedy, which would result in a far greater level of adverse community impacts. In

accordance with the USEPA Guidance for Conducting Remedial Investigations and Feasibility

Studies Under CERCLA (USEPA, 1988), these two criteria will be more fully addressed during

the final remedy selection process, i.e., public comment on a ROD modification.

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6.0 DETAILED COMPARISON OF THE ALTERNATIVE SOIL REMEDY TO THEUSEPA ROD REMEDY

The following provides a comparison of the proposed Alternative Soil Remedy to the USEPA ROD

remedy using the NCP criteria as the basis for comparison. This comparison demonstrates that not

only is the Alternative Soil Remedy consistent with the NCP (as discussed in Section 5.0), the

Alternative Soil Remedy is at least equal to and in several ways surpasses the USEPA ROD remedy

with respect to the NCP criteria.

One of the advantages of the Alternative Soil Remedy over the USEPA ROD remedy involves the

extent of VOC mass removal that can be accomplished by the Alternative Soil Remedy. Mass

removal of VOCs is a critical component of several of the NCP criteria and therefore needs to be

considered for both the Alternative Soil Remedy and the USEPA ROD remedy prior to the detailed

comparison to the NCP criteria.

6.1 Comparison of Potential VOC Mass Removal

As shown on Figure 6, the extent of VOC impacts ascertained during the Pre-Design Investigation

was simulated by EVS. The EVS simulation provides a 3-D representation of VOC impacts in

relation to the geologic zones and water table within the FDA/MA. As stated previously, VOC

impacts are concentrated in the lower portion of the upper clay and interbedded zone (highest

concentrations were detected roughly between 10 and 25 feet) and extend to approximately 30 to 35

feet bgs within the upper portion of the lower clay.

6.1.1 Alternative Soil Remedy

The Alternative Soil Remedy includes the installation of at least 35 SVE wells at 35-foot spacing

across the lateral extent of VOC-impacted areas of the FDA/MA. The wells would be screened (20

to 30 feet in length) within the upper clay and interbedded zone. An additional eleven wells will be

installed at 35-foot spacings and screened within the lower clay to extract deeper VOC impacts as

determined during the Pre-Design Investigation. The 35-foot well spacing provides for a 30%

overlap of SVE well influence.

The SVE system therefore will extract VOC mass from all impacted areas, including those at depth.

The SVE pilot study confirmed the effectiveness for achieving substantial mass removal rates, not in

only the more impacted areas of the interbedded zone, but from deeper VOC impacts as well.

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6.1.2 USEPA ROD Soil Remedy

As discussed in the USEPA Feasibility Study, the USEPA ROD contemplated excavation of soil

in the FDA/MA to a maximum depth of 15 feet bgs and from a much smaller lateral extent than

identified during the Pre-Design Investigation. Section 4.3.3.4, pg. 4-50 of the USEPA

Feasibility Study states that "The maximum depth of excavation was assumed to be 15 feet based

on a review of characterization data from the Remedial Investigation," and "Approximately 5,700

cubic yards of contaminated surface and subsurface soil would be excavated and shipped off-site

for treatment and disposed of in a landfill." Based on the results of the Pre-Design Investigation,

the amount of soil requiring excavation to meet the ROD SCS is approximately 92,000 tons, or

over twelve times the amount of soil considered by the USEPA ROD remedy. This excavation

would also require the removal of an additional approximately 70,000 tons of unimpacted soil to

achieve the necessary safe cutback angles. Furthermore, approximately 5 acres of forested land

beyond the excavation will need to be cleared to provide space for slope cutbacks, stockpiles, and

equipment staging/traffic.

Therefore, the extent of soil excavation contemplated in the USEPA ROD remedy would not

address a large majority of the VOC impacted soil exceeding the ROD SCS. In order to meet the

excavation performance standards stated in the USEPA ROD, the excavation would need to be

expanded over twelve times in size. Clearly, the technical challenges of such an expansion were

not considered in the USEPA ROD and the Alternative Soil Remedy can more effectively remove

VOC mass under the given conditions.

6.2 Threshold Requirements

6.2.1 Overall Protection of Human Health and the Environment

The only potential risks identified in the USEPA Risk Assessment and ROD associated with Site

related chemicals of concern are attributable to the potable use of groundwater impacted by VOCs at

the Site and ecological risks associated with direct contact to PCBs.

The Alternative Soil Remedy will provide greater overall protection of human health and the

environment as it will result in the removal of substantially more VOC impacted soil, particularly

from depths greater than 15 feet, i.e., the maximum excavation depth contemplated in the USEPA

ROD remedy and thus will result in a higher degree of groundwater protection, which is the principle

remedial action objective. Furthermore, if the USEPA ROD remedy were expanded to provide an

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equivalent degree of protection as the Alternative Soil Remedy, it would result in substantial

negative impacts to the short-term protectiveness of the remedy. Both remedies provide adequate

protection of ecological receptors. The Alternative Soil Remedy provides greater short-term

protectiveness, i.e., will result in much less adverse effects from VOC emissions, truck traffic, etc., as

discussed below.

6.2.2 Compliance with ARARs

Both alternatives contain an excavation component and both alternatives can comply with applicable

Federal and Pennsylvania Solid and Hazardous Waste Regulations. Further, the Alternative Soil

Remedy will be able to comply with air emission control requirements and other ARARs listed in

Section 5. 3.

There is some question as to whether or not the USEPA ROD remedy or even more so, an expanded

excavation remedy will be able to control VOC emissions from excavations, stockpiles, loading

activities, etc., to the extent necessary, to provide safe ambient air quality and protect nearby

residents and on-site workers. Impacted soil faces exposed during excavations and stockpiles and

soil handling, loading, and unloading activities will emit substantial quantities of VOCs to the

atmosphere. While there are potential means to control these VOC releases, at the scale of the

excavation required, it is questionable whether these controls will be effective. It is quite possible

that air quality and OSHA ARARs could not be complied with unless the excavation were conducted

within an enclosure; such an approach presents an entirely new set of technical challenges that are

not discussed in this Focused Feasibility Study.

In summary, it is anticipated that the Alternative Soil Remedy will comply with ARARs. While the

USEPA ROD shallow excavation might also be able to comply with ARARs, expanding the USEPA

ROD excavation remedy would raise concerns for being able to meet OSHA and USEPA/PADEP air

quality requirements.

6.3 Balancing Criteria

6.3.1 Long-Term Effectiveness and Permanence

Section 4.2 and 5.3 demonstrate that the Alternative Soil Remedy will provide a high level of

long-term effectiveness and permanence for remediating VOCs to the full depth and extent of

impacts and for achieving the principle remedial action objective, namely, the protection of

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groundwater, as well as the protection of potential ecological receptors. Unless substantially

expanded, the USEPA ROD Remedy will not be effective as considerable quantities of VOCs

would not be addressed. Expanding the excavation to address deeper VOCs that potentially could

impact groundwater quality presents additional challenges. Consequently, the Alternative Soil

Remedy provides a much higher degree of long-term effectiveness than the excavation remedy

contemplated in the USEPA ROD.

Both alternatives provide for the permanent removal of VOCs from the Site. However, the

Alternative Soil Remedy provides a higher degree of permanence than the USEPA ROD Remedy

because it permanently removes more VOCs from the subsurface.

Permanent removal of PCBs from the FDA/MA will be accomplished by both alternatives. Even

though the USEPA ROD remedy will remove a greater amount of PCBs, the removal of these

PCBs is not necessary to meet the ecological protection objectives of the USEPA ROD. Thus,

both alternatives provide an equivalent degree of effectiveness and permanence for meeting the

remedial action objectives associated with PCB remediation.

Altogether, the Alternative Soil Remedy provides a higher degree of long-term effectiveness and

permanence than the USEPA ROD remedy.

6.3.2 Reduction of Toxicity, Mobility or Volume

The Alternative Soil Remedy provides a high degree of reduction of toxicity and volume through

the removal and treatment of substantial quantities of VOCs. The USEPA ROD remedy will also

provide reduction of toxicity and volume as the excavated soil is removed from the Site and

treated using off-site thermal treatment. However, as discussed in preceding sections, the USEPA

ROD remedy will not address a large quantity of VOC impacted soil and thus will achieve less

reduction of toxicity and volume as compared to the Alternative Soil Remedy. Only if the

USEPA ROD remedy excavation was substantially widened and deepened, conditions that were

not contemplated in the USEPA ROD, would it achieve an equivalent reduction of toxicity and

volume.

While the total volume of PCB impacted soil is minimal, both remedies provide for the reduction

of a volume of PCBs necessary to satisfy the remedial action objective for the protection of

ecological receptors.

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')hi summary, the Alternative Soil Remedy provides a much greater reduction of toxicity and

volume of site-related impacts than the USEPA ROD remedy as it will remove a much larger

quantity of VOCs. Altogether, the Alternative Soil Remedy provides a greater degree of

reduction of toxicity, mobility, or volume necessary to meet the remedial action objectives.

6.3.3 Short-Term Effectiveness

Section 5.5 discusses the short-term effectiveness associated with the Alternative Soil Remedy.

In summary, while it was shown that the Alternative Soil Remedy had limited potential short-

term impact concerns, there are substantial potential short-term effectiveness concerns associated

with the expanded USEPA ROD remedy (which would be required to address VOC exceedances

of the ROD SCS). These concerns result from the need to control VOC/dust7odors during

excavation and soil handling activities, health and safety concerns for remediation workers, the

large volume of associated off-site truck traffic, and impacts to potential off-site receptors such as

the nearby residential developments and school.

A summary of some of the major short-term effectiveness concerns posed by the USEPA ROD

remedy and magnified by an expanded excavation remedy is presented below.

Potential Risks to Off-Site Residents and Workers

Prior to conducting a large-scale excavation of VOC impacted soil, a short-term health riskevaluation should be conducted to assess potential effects of VOC released from theexcavation and soil handling activities on workers and the general public via the inhalationexposure pathway. This assessment would allow a determination of whether the excavationneeds to be conducted within an enclosure, the degree of temporary covers needed, andlogistically how much active face and exposed soil surface can be exposed at any one time,thus reducing the efficiency and increasing the cost of the excavation remedy.

Site Worker Health and Safety

The VOC impacted soil excavation and handling activities required to implement the USEPAROD remedy will likely need to be performed in Level B personnel protection. Site workerswho are already performing high construction safety risk excavation activities will experienceeven higher risks as a result of having to operate heavy equipment and perform other work incumbersome Level B protection.

VOC Impacted Soil Transportation

• The expanded USEPA ROD remedy will require the off-site transportation and disposalof approximately 92,000 tons of VOC impacted soil. This large-scale transportationproject will involve approximately 3,000 truck round-trips through residentialneighborhoods and by public schools. Notably, a public school is located directly across

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'\Phoenixville Pike from the Site entrance. Besides creating a considerable disturbance tothe community via noise and dust, this type and magnitude of truck traffic will also:

• Increase the risk of further human exposures to VOCs via ambient/fugitive releases ofVOCs to the surrounding residential communities and along route to thetreatment/disposal facility, in addition to the potential for accidental spills;

• Increased traffic, physical damage to local roads, and heightened potential for automobileaccidents; and,

• Loss of VOCs to the atmosphere and potential worker safety risks due to loading andunloading operations.

Loss of Forested Areas

It is estimated that 5 acres of forested land surrounding the FDA/MA will result in order toprovide space for slope cutbacks, stockpiles, equipment staging, roadways, and constructionmanagement facilities necessary to complete the expanded excavation. Only minimal, if any,loss of the surrounding forested land would result from implementation of the AlternativeSoil Remedy.

As stated previously, an SVE system should be able to complete the remediation of the VOC

impacts in about 2 to 5 years. Most of the adverse short-term impacts (which are limited in

nature and are manageable) would occur during site preparation and system installation, which

can easily be completed in a single construction season. As stated by representatives from the

USEPA Risk Reduction Engineering Laboratory, SVE is a process that minimizes exposure to

site personnel, the public, and surrounding environment and, once installed, will result in minimal

disruptions. Only limited, if any, short-term effectiveness concerns will result from the

installation of the SVE wells and piping system.

In summary, the Alternative Soil Remedy is expected to result in considerably less adverse short-

term effects than the USEPA ROD remedy and all of these short-term effectiveness concerns are

manageable. Both the USEPA ROD remedy and the Alternative Soil Remedy can be constructed

in one construction season. Subsequently, the Alternative Soil Remedy is expected to require

operation for about 2 to 5 years to complete the remediation. During this period, there are no

anticipated significant short-term effects. Conversely, the substantial adverse short-term effects

associated with an expanded USEPA ROD remedy severely questions the feasibility and

appropriateness of its use. Altogether, the Alternative Soil Remedy will result in much less

adverse short-term effectiveness concerns than the USEPA ROD remedy.

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-

6.3.4 Implementability

The Alternative Soil Remedy is expected to be much more easily implemented than the USEPA

ROD remedy, particularly if the USEPA ROD remedy were to be expanded to include a laterally

broader and deeper excavation. The pilot study demonstrated that not only is SVE an effective

method for removing VOCs from FDA/MA soil, but SVE wells can easily be installed in the

FDA/MA. In addition, the equipment and services needed to implement the SVE system are

routine and widely available. The USEPA presumptive remedy guidance for SVE (USEPA,

1993) concurs with this assessment and concludes:

• There are few administrative difficulties and the technology is readily available frommany sources;

• SVE has been used successfully at numerous Superfund sites to address VOC impacts;and,

• Installing and operating SVE wells requires fewer engineering controls than excavation.

The limited shallow soil excavation for PCBs associated with the Alternative Soil Remedy, is

readily implementable. Conversely, the excavation needed to address the currently defined limits

of VOC impacts is not readily implementable. Therefore, the USEPA ROD remedy is expected

to be extremely difficult to implement, particularly if it were to be expanded to a laterally broader

and deeper excavation. While the equipment and services required to implement routine

excavation/disposal operations are conventional and widely available, for the numerous reasons

discussed above, which included controlling VOC emissions, controlling odors and dust,

managing high volume of truck traffic, and minimizing community disturbance will make an

expanded USEPA ROD remedy extremely difficult to implement.

6.3.5 Cost

Revised USEPA ROD Remedy Cost Estimate

New and significant technical information obtained during the Pre-Design Investigation

necessitates revision of the USEPA ROD remedy cost estimate. The revised cost of the USEPA

ROD remedy for FDA/MA soils has substantially increased from approximately $7.0 million (as

stated in the USEPA ROD) to $17.8 million as shown in Table 2, primarily as a result of the

findings of the additional delineation work performed during the Pre-Design Investigation. The

major assumptions utilized in the revised USEPA ROD remedy cost estimate include:

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The cost estimate assumes expansion of the USEPA ROD remedy to address the fullextent of VOC impacts. Based on the lateral and vertical extent of impacts determinedduring the Pre-Design Investigation as shown on Figure 5, and considering the typicalconstruction practice of "squaring off," the volume of soil exceeding the ROD SCS isestimated to be 92,000 tons, or over 12 times the volume estimated in the USEPAFeasibility Study (7,400 tons) and considered in the USEPA ROD. This volume does notinclude the volume of "clean" soil surrounding the excavation that would need to beremoved to provide safe slope cutbacks;

Approximately 50 percent of the excavated soil is assumed to exceed USEPA's LandDisposal Restrictions and thus require off-site thermal treatment prior to disposal at aSubtitle C Landfill. The USEPA Feasibility Study and ROD assumed that all excavatedsoil would require treatment prior to land disposal; and,

The transportation and disposal rates USEPA utilized in the USEPA ROD remedy costestimate were substantially reduced based on current remediation contractor estimates.

Notably, the estimated revised cost of the USEPA ROD remedy did not increase proportionally

with the twelve-fold increase in soil volumes. This disproportionate revision is a result of the

revised cost estimate utilizing lower unit costs for transportation and disposal based on recent

contractor updates and assuming less soil will require off-site treatment prior to disposal.

Alternative Soil Remedy Cost Estimate

The estimated cost for the Alternative Soil Remedy is about $3.5 million (see Section 5.8 and

Table 1) assuming a 5-year period for SVE operation.

Comparison of Remedial Cost

As discussed in the USEPA document "The Role of Cost in the Superfund Remedy Selection

Process," (USEPA, 1996):

"Cost is a critical factor in the process of identifying a preferred remedy. In fact,CERCLA and the NCP require that every remedy selected must be costeffective."

The document continues to discuss that "A remedial alternative is cost-effective if its costs are

proportional to its overall effectiveness." "Effectiveness" is further defined by the evaluation of

three of the five balancing criteria: long-term effectiveness, reduction in toxicity, mobility and

volume through treatment, and short-term effectiveness. In addition, the preamble to the NCP

further provides that where two alternatives have similar levels of effectiveness and

implementability but their costs vary significantly, cost can be used to eliminate the more costly

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alternative (55 Fed. Register §715, March 8, 1990). Clearly, the Alternative Soil Remedy is the

most cost-effective remedial alternative.

On the basis of the evidence presented in this Focused Feasibility Study, the Alternative Soil

Remedy is concluded to be more protective, effective, and implementable than the USEPA ROD

remedy, particularly, considering some of the potential short-term concerns associated with an

expanded excavation program in the FDA/MA. Therefore, given the large cost difference

between the two alternatives, the Alternative Soil Remedy is clearly the more cost-effective

alternative. Accordingly, the Alternative Soil Remedy is the preferable choice for remediation of

the VOC and PCB impacted soil in the FDA/MA.

6.4 State and Community Acceptance

The state and community acceptance criteria are used to evaluate the technical and administrative

issues and concerns the Commonwealth of Pennsylvania and the local community may have

regarding the Alternative Soil Remedy. Neither the Commonwealth of Pennsylvania nor the local

community is expected to raise technical or administrative concerns regarding the Alternative

Soil Remedy that cannot be adequately addressed. The results of the SVE pilot study and the

Alternative Soil Remedy concepts were presented to both USEPA and PADEP representatives

during a meeting on March 5, 2002. While some public opposition may be realized as a result of

the limited transport of impacted soil through the community and possibly noise, these issues are

expected to be easily overcome, especially given the choice between the Alternative Soil Remedy

and the USEPA ROD remedy, which would result in a far greater level of adverse community

impacts. In accordance with the USEPA Guidance for Conducting Remedial Investigations and

Feasibility Studies Under CERCLA (USEPA, 1988), these two criteria will be more fully

addressed during the final remedy selection process, i.e., public comment on a ROD modification.

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7.0 SUMMARY

As previously stated, the Alternative Soil Remedy provides a superior level of long-term

protection for reducing future VOC impacts to groundwater and performs at least as well and

surpasses the USEPA ROD remedy in many respects considering all of the NCP threshold and

balancing criteria. The Alternative Soil Remedy will result in less adverse short-term effects and

will be easier to implement at a much lower cost. Therefore, based on the USEPA definition of

cost-effectiveness, and the NCP, the Alternative Soil Remedy is a much more cost-effective

alternative than the USEPA ROD remedy for FDA/MA soils, even considering expansion of the

USEPA ROD remedy excavation. Consequently, Golder Associates suggests that the Alternative

Soil Remedy is preferable in accordance with the NCP, the statutory requirements of CERCLA,

and the Superfund Reforms. All of the factors presented in this document, and as summarized

above, provide a strong administrative and technical basis to allow USEPA to consider the

Alternative Soil Remedy presented herein and to modify the USEPA ROD remedy for FDA/MA

soils accordingly.

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8.0 REFERENCES

CH2MHill, 1997. Final Feasibility Study Report, June 1997.

Frank, V., and N. Barkley, 1994. Remediation of Low Permeability Subsurface Formations byFracturing Enhancement of Soil Vapor Extraction, USEPA, Risk Reduction Laboratory,Cincinnati, Ohio, April 1994.

Golder Associates Inc., 2000. Remedial Design Work Plan, May 2000.

Golder Associates Inc., 2001 a. Pre-Design Investigation Data Report Summary Report. July 2001.

Golder Associates Inc., 2001b. Soil Vapor Extraction Pilot Study Work Plan, September 2001.

Golder Associates Inc., 2002a. SVE Pilot Study Report, April 2002.

Golder Associates Inc., 2002b. Pre-Design Investigation Report, April 2002.

High Vacuum System Accelerates Remediation of Low Permeability Soils and Aquifers, TheHazardous Waste Consultant, July/August 1995

PADEP, 1995. Pennsylvania Land Recycling and Remediation Standards Act, July 1995.

PADEP 1997. Administration of the Land Recycling Program (Title 25, Chapter 250), August 1997.

Sirtler, S.P. and M.D. Slavin, 1994. Use of High Vacuum Technology to Remediate Soils andGroundwater in Low-Permeability Formations, AAPG Bulletin, Volume 78, No. 8, August1994.

USEPA, 1993. Presumptive Remedy, Site Characterization and Technology Selection for CERCLASites with Volatile Organic Compounds in Soil, OSWER Directive 9355.0-48FS, September1993.

USEPA, 1995. Engineering and Design: Soil Vapor Extraction and Bioventing, Engineer Manual1110-1 -4001, November 1995.

USEPA, 1995. Administrative Reforms to Superfund, October 1995.

USEPA 1996. The Role of Cost in the Superfund Remedy Selection Process, EPA540/F-96/018,September 1996.

USEPA, Superfund Reforms: Updating Remedy Decisions, OSWER Directive 9200.0-22.

USEPA, 1997a. Presumptive Remedy: Supplemental Bulletin Multi-Phase Extraction Technologyfor VOCs in Soil and Groundwater, OSWER Directive 9355.0-68FS, April 1997.

USEPA, 1997b. Record of Decision for the Malvern TCE Superfund Site, November 1997.

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May 2002Table 1

Alternative Soil Remedy Cost EstimateFocused Feasibility Study

Malvem TCE Superfund Site

003-6000

Lint .

'• -Vf*VSVE 01 01SVE 01.02SVE 01.03SVE 01.04SVE 01.05

SVE 02.01SVE 02.02SVE 02.03SVE 02.04SVE 02.05

SVE 03.01SVE 03.02SVE 03.03SVE 03.04SVE 03.05

SVE 04.01SVE 04.02SVE 04.03SVE 04.04SVE 04.05SVE 04.06SVE 04.07SVE 04.08SVE 04.09SVE 04.09

SVE 05.01SVE 05.02SVE 05.03SVE 05.04SVE 05.05SVE 05.06SVE 05.07SVE 05.08SVE 05.09SVE 05.10SVE 05.11SVE 05.12SVE 05.13SVE 05.14

SVE 06.01SVE 06.02SVE 06.03SVE 06.04SVE 06.05SVE 06.06

SVE 07.01SVE 07.02SVE 07.03SVE 07.04

SVE 08.01SVE 08.02

Construction PhaseItem Description

Site PreparationClearing & GrubbingAccess Road - DaylightingAccess Road • DGA SurfaceGas Pipeline CrossingFence Removal

SUBTOTAL

Site ManagementMobilizationOffice Trailer CompoundUtilitiesGeneral Conditions ( Contractor Superintendent. Supplies, and Health and Safety)Project Surveying

SUBTOTAL

PCB soil Removal and SoH CapPCB ExcavationBackfill for Soil CoverCover Grading and CompactionImport and Place Aggregate Backfill in ExcavationsSoil Sampling

SUBTOTAL

SVE Wells and TrenchingShallow SVE WellsDeep SVE WellsVapor Monitoring ProbesWell VaultsControl VaultsUnderground PipingTrench Excavation, Bedding/, and BackfillImport Additional BackfillControl Valving. Flow Sensors. Sampling PortsAdditional Borings. Soil Sampling, and SVE Well Installation

SUBTOTAL

SVE SystemFoundation and SlabPre-Engmeered BuildingBlower UnitsHeat ExchangerBuilding PipingVapor Phase Carbon Vessels Assembly (8.000 Lb)Initial Carbon (16, 000 Lbs)Carbon Vessel Valve Tree. Piping and SlackCondensate Sump and pump (secondary containment)Building Eleclncal (Class 1. Division II)Instrumentation and ControlCondensate TankUtilities! 3 Phase 4160 Volt Service, plus telephone)Perimeter Fence (Temporary)

SUBTOTAL

DisposalPCB Soil Waste CharaclenzationPCB Soil - Loadout. Transport and Disposal (Assume Treatment required)PCB Soil - Loadout. Transport and Disposal (Assume Landfill)Soil Cuttings.Liquids DisposalTrenching Spoils

SUBTOTAL

System StartupLabor /EquipmentLaboratory Analytical (TO-14 Modified)OversightVendor Inspection and Certification

SUBTOTAL

Site RestorationTopsoilSeeding

SUBTOTAL

Subtotal

20% Contingency

TOTAL CONSTRUCTION PHASE TOTAL

Quant

1.00

1 004667350700

16661

200020001667

7501 00

1225

6052404615

3500250017546

1.00

1600

6002112

16000111111

1000

2010001000

801200

175

10040605

1546

125

Units

AcreLSSYSYLF

LSMonthsMonthsMonths

LS

TonsTonsSY

TonsLS

VLFVLFVLFEAEALFLF

TonEALS

SFSFEAEALS

EA

LBSEALSEALF

EALSLF

AnalyticalTonTonTon

GallonsTon

MrsEAMrsEA

SFMSF

Unit Cost

$15.000.00$8.000.00

$11.10$75.00$450

$25,000.00$2.500.00$2.000.00$30.000.00$5,00000

$11.65$15.50$3.24$2800

$5,00000

$95.00$95.00$55.00$250.00

$2,50000$7.75$2400$860

$21500$20,00000

$4.50$60.00

$30.00000$15,000.00$20.000.00$15.000.00

$1.39$27.000.00$8.50000$25,000.00$18.000.00$5.000.00$40.00000

$22.50

$500.00$205.00$48.00

$205.00$0.85

$205.00

$75.00$20000$100.00$40000

$1550$50.00

Cost

15.0008.000

51.80026.250

3.150

$ 25.000$ 15.000$ 12.000$ 180,000$ 5.000

23,30931.000

5.40021.0005.000

116.37557.47513.20011.50037.50027.12560,000

1,5059,890

$ 20.000

$ 7.20036.00060.00015.00020.00030.00022.18427.0008.500

25,00018.0005.000

40.00022,500

$ 10.000$ 205.000$ 48.000$ 16,400$ 1.020$ 35.875

$ 7,500$ 8,000$ 6.000$ 2,000

$ 23.968$ 6.250

Subtotal Cost

~-~- - : V

$ 104.200

$ 237,000

$ 85.709

$ 354.570

$ 336.384

$ 316.295

$ 23.500

$ 30.218

$ 1.487.875

$ 297.575

$ 1 ,785.450

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May 2002Tablet

Alternative Soil Remedy Cost EstimateFocused Feasibility Study

Malvern TCE Superfund Site

003-6000

LineRsforoncv

SVE 0901

SVE 09.02SVE 09.03SVE 0904SVE 0905SVE 09.06SVE 09.07

SVE 10.01SVE 10.02SVE 10.03SVE 10.04SVE 10.05SVE 10.06

SVE 11.01SVE 11.02

SVE 12.01SVE 12.02SVE 1203SVE 12.04

SVE 13.01SVE 13.02SVE 13.03SVE 13.04SVE 13.05

SVE 14.01SVE 1402

SVE 1403

SVE 1404

SVE 14.05SVE 14.06SVE 14.07

Operational PhaseItem Description

Performance MonitoringWeekly Site Visits (1 months)Monthly Site Visits (7 - 60 Months)Laboratory Analytical (TO-14 Modified)ReportingSoil Confirmation Sampling BoringSoil AnalyticalSoil Confirmation Sampling Reporting

SUBTOTAL

Preventative MaintenanceOrf 4 Filler ChangesBell ReplacementInstrumentation CalibrationBlower OverhaulBuildingHeat Exchanger Motor Replacement

SUBTOTAL

UtilitiesElectric (90.000 kwh)Data / Telephone

SUBTOTAL

Site MaintenanceLandscaping cuttingAccess Road RepairSnow RemovalFence

SUBTOTAL

Carbon UsageVapor Phase Carbon Supply and DisposalCarbon Hazardous Profile ApprovalCarbon Change oul LaborCondensate DisposalCondensate Wasle Slream Approval

SUBTOTAL

System RevisionsField and Laboratory Analysis o( SVE syslem performanceAdditional SVE WellsUnderground Piping RevisionsTrench Excavation. Bedding/, and BackfillControl Valving. Flow Sensors. Sampling PortsSoil Cuttings DisposalPiping Modification

SUBTOTAL

Subtotal

20% ContingencyOPERATIONAL PHASE TOTAL

Quant

4.00

59001285

25251

6065255

6060

205155

10OOOO1

131800

1

15251500

1500

15331

Unto

EAEAEA

AnnualSamplesSamples

LS

MlhEventAnnualEvent

AnnualAnnual

MonthsMonths

QuarterlyAnnualMonthAnnual

LBSLS

EventsGallon

LS

LSVLFLFLFEA

TonsLS

Unit Cost

$2.80000$2.80000$200.00

$22.000.00$1,100.00$16500

$12.00000

$12500$1.00000$5.00000$8.000.00$2.60000$2.500.00

$8.250.00$8333

$50000$750.00$200.00

S1. 500.00

$1.39$4.500.00$1.100.00

$4.00$4.50000

$50.000.00$95.00$6.50$2400

$215.00$208.00

$4.500.00

Cost

11.200165.20025.600

110.00027.500

4.125$ 12.000

$ 7.500$ 6.000$ 25.000$ 16.000$ 13,000$ 12,500

$ 495.000$ 5.000

$ 10.000$ 3.750$ 3.000$ 7.500

$ 138.700$ 4.500$ 14.300$ 7.200$ 4.500V

$ 50.000$ 49,875$ 9.750$ 36.000$ 3.225$ 6.825$ 4.500

Subtotal Cost

$ 355,625

$ 80.000

$ 500.000

$ 24,250

$ 169.200

$ 160,175

$ 1.289.250$ 257.850

$ 1,547.099

G.W03-«XMFFS\DRAFT ROD ConKIUCtioo Estimate xBTABLE 1 Colder Associates A R 0 0 0 7 0 0 Page 2 of 3

IIIIIIIIIIIIIIIIIII

May 2002Table 1

Alternative Soil Remedy Cost EstimateFocused Feasibility Study

Malvern TCE Superfund Site

003-6000

System DecommissioningLine

SVE 15.01SVE 15.02SVE 15.03SVE 15.04

SVE 16.01SVE 16.02SVE 16.03SVE 16.04

SVE 17.01SVE 17.02

SVE 18.01SVE 1802SVE 18.03SVE 18.04

Item Description

BiddingRemoval of EquipmentBuilding DemolitionConcrete Foundation RemovalSupply and Place Backfill

SUBTOTAL

SVE Wells and Underground PipingExcavation and Backfill TrenchesAbandon Wells and Monitoring Vapor ProbesGrade SiteSeeding

SUBTOTAL

UtilitiesElectricData / Telephone

SUBTOTAL

Site RestorationPerimeter Fence RemovalAccess Road Removal © Pipe CrossingTopsoilSeeding

SUBTOTAL

Quant

111

56

1667

26056950

63

11

10001

80011

Subtotal

20% Contingency

SYSTEM DECOMMISSIONING PHASE TOTAL

Units

LSLSLS

Ton

CYLFSY

MSF

LSLS

LFLSSY

MSF

Unit Cost

$10.000.00$8,000.00$4.50000

$15.50

$4.50$10.00$0.60$50.00

$3.000.00$1.000.00

$4.50$2.500.00

$1.55$50.00

Cost

$ 10,000$ 8.000$ 4.500$ 863

$ 7.500$ 26,050$ 4,170$ 3,125

$ 3,000$ 1.000

$ 4.500$ 2.500$ 1.238$ 550

Subtotal Cost

$ 23.363

$ 40.845

$ 4.000

$ 8.788

$ 76.996

$ 15.399

$ 92.395

SUMMARY OF ESTIMATED SOIL VAPOR EXTRACTION COSTS

PhaseConstruction Phase

Operational PhaseSystem Decommissioning

SVE TOTAL

Estimated Cost

$ 1,487,875$ 1,289,250$ 76,996

$ 2,854.409

Contingency20%

$ 297.575$ 257.850$ 15,399

$ 568.882

Total tsnmMMCost

$ 1.785,450$ 1.547.099$ 92.395

$ 3,423,291

G:\003-600WFFS\DRAFT ROD Constructor) Eswn*e >lsTABLE 1 GokJer Associates A R 0 0 0 7 0 I Page 3 0(3

IIIIIIIIIIIIIIIIIII

May 2002Table 2

Revised Cost Estimate for USEPA ROD FDA/MA Soil RemedyExpanded to Address the Extent of VOCs Identified During the Pre-Design Investigation

Focused Feasibility StudyMalvern TCE Superfund Site

003-6000

LineReference

EXC 01.01EXC 01.02EXC 01.03EXC 01.04EXC 01.05EXC 01.06EXC 01.07EXC 01.08

EXC 02.01EXC 02.02EXC 02.03EXC 02.04EXC 02.05EXC 02.06

EXC 03.01EXC 03.02EXC 03.03EXC 03.04EXC 03.05EXC 03.06

EXC 04.01EXC 04.02EXC 04.03EXC 04.04EXC 04.05

EXC 05.01EXC 05.02EXC 05.03EXC 05.04EXC 05.05

Item Description•-•

'• ; Site PreparationClearing & GrubbingAccess Road - ClearingAccess Road - Earthwork / Drainage SwaleAccess Road - CulvertAccess Road - DGA SurfaceGas Pipeline CrossingStrip Topsoil in Support AreaFence Removal

SUBTOTAL

MobilizationMobilizationOffice Trailer CompoundUtilities) Single Phase, plus monthly cost)General Conditions (Contractor Supervision, Supplies, and Health and Safety)Project SurveyingPerimeter Air Monitoring

SUBTOTAL

Excavation and BackfillPrepare Soil Staging AreaSoil ExcavationVapor Suppressant (Foam)Place and Compact BackfillImport Clean FillProvide and Place Topsoil

SUBTOTAL

Disposal (loadout and Transportation)Soil Classification AnalyticalLandfill Disposal ( PCE <5.6 ppm; TCE < 54 ppm)Soil Treatment and Landfill DisposalPCB Soils and VOC - Soil Treatment and Landfill DisposalManagement of wastes

SUBTOTAL

Site RestorationRemove Access Road (including Pipeline Crossing)Remove Laydown AreaTopsoil (Place Stockpile)SeedingTree Replacement

SUBTOTAL

Quant

52.0

466790

150009006667700

1151

1518

2160000800069000910008820

20046000460002000

1

16667780028380

Subtotal20% Contingency

Remedial Action Total

Units

AcreAcreSYLFSYSYSYLF

LSMonths

LSMonths

LSMonths

AcreTon

GallonTonTonTon

AnalyticalTonTonTonLS

LSSYSY

MSFEA

Unit Cost

$15.000.00$15,000.00

$1.75$60.00$11.10$100.00$1.60$4.50

$90,000.00$4.000.00$45.000.00$40,000.00$12,000.00$11,000.00

$12,000.00$1.75$3.50$1 15$8.60

$15.50

$500.00$50.00$205.00$205.00

$20,000.00

$7,500.00$1.50$3.12$50.00$85.00

Cost

$ 75,000$ 30,223$ 8,167$ 5,400$ 166,505$ 90,000$ 10.684$ 3,150

$ 90.000$ 60.000$ 45.000$ 600,000$ 12,000$ 88,000

$ 24,000$ 280,000$ 28.000$ 79.350$ 782,600$ 136,703

$ 100,000$2.300.000$9,430,000$ 410,000$ 20,000

$ 7,500$ 10,000$ 24,336$ 14.157$ 6.800

SubtotalCost

$ 389.128

$ 895,000

$ 1,193,950

$12,260,000

$ 62,793

$14,800,871$ 2,970,174

$17,771,045

G:\003-6000\FFS\DFtAFT ROD Construction Estimate.xlsrev est Golder Associates

A R 0 0 0 7 0 2Page 1 of 1

>fc;-V

1.) BASE MAP TAKEN FROM U.S.G.S. 15 MINUTEQUADRANGLE OF MALVERN, P.A..

PENNSYLVANIA

QUADRANGLE LOCATION

2000

.—SCALE

CO200QCD

r—FEET CD

Philadelphia USA

FILE No. 0036000H001PROJECT Ho. 003-6000 •** 0

SCAl£ AS SHOWN

DATE 05/16/02DESGN AMCADO AM

CHECK DSLREVIEW RSW

TITLE

SITE LOCATION MAPCDcc«=c

MALVERN TCE SUPERFUND SITEFIGURE

Urit-1 Upper CloyUnit-2 Interbedded zoneUnit-3 Lower Ctay

JOB No.: 003-6QOOOR BY: DSLCHKBY: DSL

REV BY: RSW

SCALE: AS SHOWN

DATE: 5/17/02FILE No.: fence_Dlag.doc

DIRECTORY: 003-6000VFFS

Golder Associates

GENERALIZED FENCE DIAGRAM

MALVERN PDI REPORT

CDCDCDor•or

FIGURE:

Legendfa I Interpreted Zone of Total Exceedances of the ROD Soil Clean-up Standards.• Sample location

Notes• Interpreted Zone of Exceedances generated using EVS™ (Environmental

Visualization System).

JOB No.:

DRBY:

CHKBY:

REV BY:

003-6000

ACK

ACK

THR

SCALE: AS SHOWNDATE: 5/17/02FILE No.: Soil Data EVS 2.doc

DIRECTORY: /(:DA SVE/PTReport

Interpreted Zones of VOC Exceedancesof ROD SCS - FDA/MA Area

Gold cr Associates Malvern SVE Pilot Study j^ff ft* fiQ 7 05

Shallow/IntermediateWells

Deep Wells

ShallowWells

Deep Wells

JOB No.: 003-6000DRBY ACK

CHK BY: ACK

REV BY

SCALE

DATE:

FILE No

AS SHOWN

5/17/02

Concept layout.docDIRECTORY 003-6000/FFS

Conceptual Layout of SVEfor FDA/MA

Golder Associates Malvern Focused Feasibility Study a { > ft H ft 7 Q £FIGURE: