-
I
I
I
FEASIBILITY STUDY REPORT
BLOSENSK! LANDFILL SITECHESTER COUNTY, PENNSYLVANIA
EPA WORK ASSIGNMENT. NUMBER 37-3L49.0I CONTRACT NUMBER
68-01-6699
NUS PROJECT NUMBER S759
FEBRUARY 1986
SUBMITTED FOR NUS BY: APPROVED:
Park West TwoCliff Mine RoadPittsburgh, PA 15275
___ COF=iPC)RATION 4i2-788-ioso
• D - 3 4 - 1 - 6 - 2DRAFT
* BL- n -FS-D(2)-I
(CHUT?
GEORGE V. GARTSEFF DAVID E. MaclNTYRE, P.E.PROJECT MANAGER
REGIONAL MANAGER
REGION III
A Halliburton Company
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DRAFT
CONTENTS
SECTION PAGE
EXECUTIVE SUMMARY ES-1
1.0 INTRODUCTION * -11.1 SITE BACKGROUND -11.2 REMEDIAL
INVESTIGATION RESULTS -41.2.1 CONTAMINANTS . -41.2.2 PATHWAYS AND
RECEPTORS -151.2.3 PUBLIC HEALTH AND ENVIRONMENTAL RISKS -161.3
REMEDIAL ACTION OBJECTIVES AND CRITERIA 1-211.3.1 CONTAMINATED
GROUNDWATER 1-221.3.2 CONTAMINATED SURFACE SOILS AND SEDIMENTS
1-241.3.3 RESPIRABLE CONTAMINANTS 1-251.4 FEASIBILITY STUDY
PROCEDURE 1-28
2.0 SCREENING OF REMEDIAL ACTION TECHNOLOGIES 2-12.1 SCREENING
CRITERIA . 2-12.1.1 SATISFACTION OF REMEDIAL ACTION OBJECTIVES
2-12.1.2 TECHNICAL FEASIBILITY 2-22.1.3 HEALTH AND ENVIRONMENTAL
IMPACTS 2-22.1.4 COST EVALUATION 2-32.1.5 INSTITUTIONAL
CONSIDERATIONS 2-32.2 CANDIDATE GENERAL RESPONSE ACTIONS 2-3
AND TECHNOLOGIES2.3 TECHNOLOGY SCREENING PROCESS 2-32.3.1 NO
ACTION WITH MONITORING 2-52.3.2 CONTAINMENT 2-52.3.3 GROUNDWATER
COLLECTION 2-142.3.4 SURFACE WATER CONTROLS 2-162.3.5 CONTAMINANT
EXCAVATION/REMOVAL 2-162.3.6 INNOVATIVE TREATMENT TECHNOLOGIES
2-162.3.7 GROUNDWATER TREATMENT 2-182.3.8 ONSITE STORAGE 2-212.3.9
ONSITE DISPOSAL 2-212.3.10 OFFSITE DISPOSAL 2-232.3.11 ALTERNATE
WATER SUPPLY 2-242.4 FEASIBLE REMEDIAL ACTION TECHNOLOGIES 2-25
3.0 DEVELOPMENT OF REMEDIAL ACTION 3-1ALTERNATIVES
3.1 PURPOSE OF THE ALTERNATIVES 3-13.2 PROCEDURES FOR
ALTERNATIVE DEVELOPMENT 3-13.3 LEVELS OF REMEDIATION TO BE ACHIEVED
3-23.4 FORMULATION OF REMEDIAL ACTION 3-4
ALTERNATIVES
302039
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CONTENTS (CONTINUED)
SECTION
, 3.4.1 NO ACTION 3-43.4.2 ALTERNATIVES THAT MEET CERCLA GOALS
3-4
' BUT DO NOT ATTAIN OTHER APPLICABLEOR RELEVANT STANDARDS
! 3.4.3 ALTERNATIVES THAT ATTAIN APPLICABLE OR 3-5I RELEVANT
PUBLIC HEALTH OR ENVIRONMENTAL
STANDARDS, GUIDANCE, OR ADVISORIESi 3.4.4 ALTERNATIVES THAT
EXCEED APPLICABLE OR 3-7I RELEVANT PUBLIC HEALTH AND
ENVIRONMENTAL
STANDARDS, GUIDANCE, AND ADVISORIES3.4.5 ALTERNATIVES SPECIFYING
OFFSITE STORAGE, 3-8
DESTRUCTION, TREATMENT, OR SECURE1 DISPOSAL OF HAZARDOUS
SUBSTANCES AT A
FACILITY APPROVED UNDER RCRA] 3.5 SUMMARY OF ALTERNATIVE
DEVELOPMENT 3-9
4.0 EVALUATION OF REMEDIAL ACTION ALTERNATIVES 4-14.1 EVALUATION
CRITERIA 4-14.1.1 TECHNICAL EVALUATION 4-14.1.2 PUBLIC HEALTH AND
ENVIRONMENTAL EVALUATION 4-24.1.3 INSTITUTIONAL EVALUATION 4-24.1.4
COST EVALUATION 4-24.2 EVALUATION OF ALTERNATIVES PROVIDING NO
4-5
REMEDIAL ACTION4.2.1 REMEDIAL ACTION ALTERNATIVE ONE - NO ACTION
4-5
WITH LONG-TERM MONITORING4.3 EVALUATION OF ALTERNATIVES THAT
MEET CERCLA 4-10
GOALS BUT DO NOT ATTAIN OTHER APPLICABLE STANDARDS4.3.1 REMEDIAL
ACTION ALTERNATIVE TWO -ONSITE 4-10
CAPPING OF CONTAMINATED SOILS AND WASTES;EXTENSION OF THE
COATESVILLE WATER AUTHORITYPUBLIC WATER SUPPLY; AND LONG-TERM
MONITORING
4.4 EVALUATION OF ALTERNATIVES THAT ATTAIN ALL 4-21APPLICABLE OR
RELEVANT STANDARDS, GUIDANCE,OR ADVISORIES
4.4.1 REMEDIAL ACTION ALTERNATIVE THREE- ONSITE 4-21MULTIMEDIA
CAPPING OF CONTAMINATED SOILS ANDWASTES; EXTENSION OF THE
COATESVILLE WATER AUTHORITYPUBLIC WATER SUPPLY; GROUNDWATER
EXTRACTION,TREATMENT, AND INJECTION; AND LONG-TERMMONITORING
ill 302040
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' '"'• CONTENTS (CONTINUED)
SECTION PAGE
4.4.2 REMEDIAL ACTION ALTERNATIVE FOUR - CONSTRUCTION 4-38OF A
SECURED ONSITE LANDFILL; EXTENSIONOF THE COATESVILLE WATER
AUTHORITY PUBLICWATER SUPPLY; GROUNDWATER EXTRACTION, TREATMENT,AND
INJECTION; AND LONG-TERM MONITORING
4.5 EVALUATION OF ALTERNATIVES THAT EXCEED 4-48APPLICABLE OR
RELEVANT PUBLIC HEALTH ANDENVIRONMENTAL STANDARDS, GUIDANCE,
ANDADVISORIES
4.5.1 REMEDIAL ACTION ALTERNATIVE FIVE—COMPLETE 4-48EXCAVATION
OF CONTAMINATED SOILS AND WASTES;ONSITE INCINERATION WITH
MULTIMEDIA CAP OVERRESIDUALS; EXTENSION OF THE COATESVILLE
WATERAUTHORITY PUBLIC WATER SUPPLY: GROUNDWATEREXTRACTION,
TREATMENT, AND INJECTION; ANDLONG-TERM GROUNDWATER MONITORING
4.5.2 OPTION TO REMEDIAL ACTION ALTERNATIVE FIVE— 4-58COMPLETE
EXCAVATION OF CONTAMINATED SOILS ANDWASTES; ONSITE INCINERATION
WITH STABILIZATIONOF RESIDUALS; EXTENSION OF THE COATESVILLE
WATERAUTHORITY PUBLIC WATER SUPPLY; GROUNDWATEREXTRACTION,
TREATMENT AND INJECTION;AND LONG-TERM GROUNDWATER MONITORING
4.6 EVALUATION OF ALTERNATIVES SPECIFYING OFFSITE 4-60STORAGE,
DESTRUCTION, TREATMENT, OR SECUREDISPOSAL AT A FACILITY APPROVED
UNDER RCRA
4.6.1 REMEDIAL ACTION ALTERNATIVE SIX—EXCAVATION 4-60OF
CONTAMINATED WASTE DEPOSITS AND DISPOSAL INAN OFFSITE RCRA-APPROVED
LANDFILL; THE OPTIONTO DISPOSE, CONTAIN, OR TREAT THE
CONTAMINATEDSOILS THAT UNDERLIE THE WASTE DEPOSITS;EXTENSION OF THE
COATESVILLE WATER AUTHORITYPUBLIC WATER SUPPLY; GROUNDWATER
EXTRACTIONTREATMENT, AND INJECTION; AND LONG-TERM MONITORING
5.0 SUMMARY OF REMEDIAL ACTION 5-1ALTERNATIVES
IV
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CONTENTS (CONTINUED}
APPENDICES
A BACKGROUND DATA AND CALCULATIONS FOR TECHNOLOGYSCREENING
CAPPINGGROUT CURTAININCINERATIONINNOVATIVE AND EMERGING
TECHNOLOGIESALTERNATE WATER SUPPLY
B BACKGROUND DATA AND CALCULATIONS FORALTERNATIVE EVALUATION
GROUNDWATER EXTRACTION AND TREATMENTONSITE AND OFFSITE
LANDFILLSEROSION AND SEDIMENT CONTROLSITE PREPARATIONONSITE
INCINERATIONTVOC CALCULATION FOR SOILS
COST EVALUATION
302042
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TABLES
NUMBER PAGE
ES-1 COSTS OF REMEDIAL ACTION ALTERNATIVES ($ 1000s) ES-61-1
CONTAMINANTS AT THE BLOSENSKI LANDFILL SITE 1-61-2 ESTIMATED
CARCINOGENIC RISK ASSOCIATED WITH
INGESTION OF GROUNDWATER 1-181-3 PROPOSED GROUNDWATER TREATMENT
STANDARDS 1-231-4 SUMMARY OF REMEDIAL ACTION OBJECTIVES
AND GENERAL RESPONSE ACTIONS 1-262-1 GENERAL RESPONSE ACTIONS
AND ASSOCIATED 2-4
REMEDIAL TECHNOLOGIES2-2 SUMMARY OF REMEDIAL TECHNOLOGY 2-26
SCREENING PROCESS FOR THEBLOSENSKI LANDFILL bITE
3-1 CATEGORIES OF REMEDIAL ACTION 3-3ALTERNATIVES
4-1 ALTERNATIVES TO PROPOSED INCINERATION SYSTEM ($ 1000s)
4-555-1 REMEDIAL ACTION ALTERNATIVE TRADE-OFF 5-2
MATRIX5-2 REMEDIAL ACTION ALTERNATIVES COST 5-11
SUMMARY ($1,000)
VI 302043
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FIGURES
'"'•tt/;..V-
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NUMBER PAGE
1-1 LOCATION MAP 1-21-2 SITE LAYOUT 1-34-1 PROPOSED LONG-TERM
MONITORING SAMPLE LOCATIONS 4-84-2 APPROXIMATE LIMITS OF CAPPING 4
4-124-3 TYPICAL SOIL CAP 4-164-4 TYPICAL MULTIMEDIA CAP 4-234-5
PROPOSED GROUNDWATER PUMPING AND INJECTION 4-26
WELL LOCATIONS4-6 TYPICAL PUMPING WELL 4-284-7 GROUNDWATER
TREATMENT SYSTEM-METALS REMOVAL 4-304-8 GROUNDWATER TREATMENT
SYSTEM-ORGANICS 4-32
REMOVAL4-9 PLAN OF PROPOSED ONSITE LANDFILL 4-414-10 APPROXIMATE
CROSS SECTION A-A' PROPOSED 4-42
ONSITE LANDFILL4-11 LANDFILL CAP AND BOTTOM LINER DETAILS
4-434-12 GENERAL ARRANGEMENT FOR ONSITE INCINERATION 4-514-13
PROCESS FLOW DIAGRAM FOR ONSITE ROTARY KILN 4-52
INCINERATION OF SOLID WASTE4-14 APPROXIMATE LIMITS OF PARTIAL
EXCAVATION 4-63
VII 302044
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302045
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EXECUTIVE SUMMARY
1 The Feasibility Study (FS) Report for the Blosenski Landfill
Site has been preparedat the request of the United States
Environmental Protection Agency (EPA)
1 Region III under Work Assignment Number 37-3L49.0, Contract
Number68-01-6699. This study was prepared in accordance with the
requirements of the
[ National Oil and Hazardous Substances Contingency Plan (NCP)
published pursuantto Section 105 of the Comprehensive Environmental
Response, Compensation, and
j Liability Act of 1980 (CERCLA).
ISite Background
The Blosenski Landfill Site is located on 13.6 acres in West
Cain Township, ChesterCounty, Pennsylvania. It is surrounded by
heavily wooded areas to the north andwest, and by agricultural
areas to the east and northwest. Approximately30 residents live
within a quarter-mile radius of the site.
The landfill was reportedly operated for the disposal of
municipal and industrialwastes, beginning in the late 1940s.
However, there is no specific informationregarding activities at
the site until its purchase by Joseph M. Blosenski, Jr., in
the1960s. From that time, until operations ceased in 1979, wastes
accepted at thesite for disposal included drummed industrial
wastes, truckloads of sludge, andmunicipal and commercial refuse.
Wastes were not segregated, and the siteapparently was not
lined.
Seven permits to operate the landfill were applied for in the
1970s but nevergranted. Several regulatory actions against the
owner were issued by thePennsylvania Department of Environmental
Resources (PADER). A consent decreeissued in 1979 to force site
closure required the completion of groundwater and soilstudies and
remedial measures. In accordance with this, four monitoring
wellswere installed on site by PADER in 1982. During the winter of
that year, 50 to60 drums and a leaking tank truck were removed from
the site. Samples
ES-1 302046
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DRAFT
taken by PADER and the USEPA Region III Field Investigation Team
(FIT) haveidentified soil, surface water, and groundwater
contamination with both organicand inorganic substances. These
findings were verified by the results of the morerecent remedial
investigation (Rl) performed at the site for the USEPA. Thefindings
are discussed further in the following section.
A
Remedial Investigation Results
The Rl was performed from the Fall of 1984 through the Spring of
1985 to assessthe present and potential impacts of site-related
contamination on the publichealth and the environment, and to
provide a technical basis for developingappropriate alternative
remedial actions for the site.
The Rl reported that numerous organic and inorganic contaminants
were detectedin environmental media at the site. Regional data and
site-specific observationsindicate groundwater flow at the site is
primarily through bedrock, although alocalized, perched water table
was identified in the eastern portion of the site.Volatile organic
chemicals, the primary contaminants, have entered the watertable
and migrated beyond site boundaries. Advection of volatile
contaminantsoccurs through regions of secondary permeability
(fractures, faults, and beddingplanes) in the underlying bedrock.
The majority of volatile contaminants in thegroundwater regime are
migrating to the north of the site, reflecting the
hydraulicgradient. It appears that these contaminants are then
transported to the northwestvia groundwater flow in a transmissive
zone lying beneath the intermittenttributary to Indian Spring Run.
Volatile organics were not detected in groundwatersamples obtained
to the north of this zone.
Chlorinated aliphatic compounds (primarily trichloroethene
and1,1,1-trichloroethane) were consistently detected in residential
wells located tothe south of the site. Factors that may induce
migration of chemicals to theresidential wells include the location
of the source, the location and orientation offractures, the
densities of contaminants, hydraulic influences attributable
toresidential well pumping, and the depths of residential wells.
The most probable
302047ES-2
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source of the residential well contaminants lies in the vicinity
of MW 2-1 on thesouthern portion of the site.
Two other sources of groundwater contaminants were identified:
on the west side,near MW 3-1 (monocyclic aromatics); and on the
east near TP-11 (monocyclicaromatics and chlorinated
aliphatics).
*
Although detected at the site, semivolatiles, pesticides, PCBs,
and inorganicsubstances are not migrating beyond the site
boundaries. These relativelyimmobile chemicals appear to be
confined to the immediate vicinity of thedeposition areas.
Feasibility Study Objectives and Criteria
The overall purpose of the FS process is to provide an array of
technically sound,cost-effective remedial action alternatives
(RAAs) that control the source andmanage the migration of
contaminants, and provide protection to the public health,welfare,
and the environment. In accordance with this, various cleanup
objectivesand criteria were established to provide a focus for the
general response actionsand technologies available for remediating
the Blosenski Landfill Site. Theseobjectives and criteria
include
______Cleanup Objectives______ _______Cleanup
Criteria___________
a. No action a. Establish current potential risklevels and take
no remedial action
b. Prevent an increase in the current b. Establish current
potential riskpotential risk associated with the levels and utilize
remedial tech-site nologies to prevent an increase in
potential risk levels
302048ES-3
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______Cleanup Objectives______ ______Cleanup Criteria
_______
c. Reduce the current potential risk c. Reduce the current
potential riskassociated with the site to associated with the site
to aacceptable levels target cleanup criteria of a 10~6
potential risk level, or otheracceptable level.
i
d. Reduce the risk levels to those d. Utilize remedial
technologiescorresponding to background to eliminate site
contaminantsconcentrations
Screening of Remedial Action Technologies
Based on the above objectives and criteria, numerous source
control and migrationcontrol technologies were screened to provide
a limited number of technologiesapplicable for remedial actions at
the site. Some of these technologies wereremoved from further
consideration based on site-specific information gatheredduring the
Rl and on the basis of other comparative criteria. These other
criteriainclude
• Technical performance• Magnitude of costs• Health and
environmental impacts• Institutional considerations
Applicable technologies identified during the Rl, as well as
those encompassingimportant treatment or disposal options, were
discussed and evaluated. If thetechnology was found to be
inapplicable for site-specific conditions or use, or if itwas
rejected on the basis of other criteria, it was dropped from
furtherconsideration. The remaining technologies were developed
into candidatealternatives that meet the specific remedial action
objectives and the criteria forevaluation of alternatives.
ES-4
302049
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Development and Evaluation of Remedial Action Alternatives
To evaluate a wide range of remedial responses to this site,
alternatives weredeveloped to fall into one of five cleanup
categories, which are described in theUSEPA Guidance Document on
Feasibility Studies Under CERCLA (EPA,June 1985). Each category
represents a different degree of site remediation and isdescribed
as follows:
• No action.
• Alternatives that meet the CERCLA goals of preventing or
minimizingpresent or future migration of hazardous substances and
protecting humanhealth and the environment, but do not attain all
other applicable orrelevant standards.
• Alternatives that attain all applicable or relevant public
health andenvironmental standards, guidance, or advisories.
* • Alternatives that exceed all applicable or relevant public
health and. environmental standards, guidance, and advisories.I
• Alternatives specifying offsite storage, destruction,
treatment or secureI disposal of hazardous substances at a facility
approved under the
Resource Conservation and Recovery Act (RCRA). Such a facility
must1 also be in compliance with all other applicable EPA
standards.
The following paragraphs provide brief descriptions of the RAAs
developed foreach category. Table ES-1 summarizes the capital and
present-worth cost foreach RAA.
ES-5 302050
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TABLE ES-1
COSTS OF REMEDIAL ACTION ALTERNATIVES ($ 1000s)
30-YearCapital Present Worth
___Remedial Action Alternative____ Costs (Range) Analysis
(Range)
1. No action with monitoring $80-130 ' $1,953-2,003
2. Soil cap, alternate water supply 2,706 - 4,812 5,122 -
7,233and long-term monitoring.
3. Multimedia cap, alternate water 8,481 - 13,037 13,150 -
17,706supply, groundwater extraction andtreatment, and long-term
monitoring.
4. Onsite landfill, alternate water 14,317 - 31,508 18,986 -
36,177supply, groundwater extractionand treatment, and
long-termmonitoring.
.5a. Onsite incineration, multimedia 26,113 - 32,207 47,858 -
53,952cap, alternate water supply,groundwater extraction
andtreatment, and long-term monitoring.
5b. Onsite incineration, stabilization 30,378 - 43,258 53,392 -
66,272of residuals, alternate watersupply, groundwater extraction
andtreatment, and long-term monitoring.
6. Excavation and off site disposal ofwastes in a RCRA-approved
landfill,alternate water supply, groundwaterextraction and
treatment, and long-term monitoring, including thefollowing:
Option a: Excavation and off site 89,388 - 257,503 93,858 -
261,973disposal of soils in a RCRA-approved landfill
Option b: Construct'on of multi- 44,815 - 123,782 49,484 -
128,451media cap over contaminated soils
Option c: Excavation and 45,756 - 126,006 50,027 -
130,877detoxification of contaminatedsoils
302051
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DRAFT
No Action Alternative
Remedial Action Alternative One - No Action with Long-term
Monitoring
This is a baseline alternative to provide a comparison of the
effectiveness of theother remedial alternatives against present and
potential site risks, if the siteremains remediated. Long-term
monitoring is proposed as a means to detect anyfuture changes in
site conditions or contaminant migration.
Alternatives that Meet CERCLA Goals
Remedial Action Alternative Two - Onsite Capping of Contaminated
Soils andWastes; Extension of the Coatesville Water Authority
Public Water Supply; andLong-term Monitoring
RAA Two involves leaving the existing contaminated wastes and
soils in place,while covering them with a low permeability soil cap
to reduce infiltration andprevent dermal contact. An alternate
water supply will be provided to potentiallyaffected residences by
extending the Coatesville Water Authority's main line.Additional
monitoring wells will be installed on site to detect any
futurecontaminant migration via the groundwater.
Alternatives That Attain All Applicable Standards
Remedial Action Alternative Three - Onsite Multimedia Capping of
ContaminatedSoils and Wastes: Extension of the Coatesville Water
Author ty Public WaterSupply; Groundwater Extraction, Treatment,
and Injection; and Long-termMonitoring
RAA Three is similar to RAA Two in that all site materials are
left in place.However, a multimedia cap of 10"̂ cm/sec permeability
material plus a syntheticmembrane is used in lieu of a soil cap.
Groundwater extraction, treatment (via airstripping and carbon
adsorption), and injection is added to remediate thegroundwater. An
alternate water supply and long-term monitoring are alsoprovided in
RAA Three.
302052ES-7
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Remedial Action Alternative Four - Construction of a Secured
Onsite Landfill:Extension of the Coatesville Water Authority Public
Water Supply; GroundwaterExtraction, Treatment and Injection; and
Long-term Monitoring
RAA Four involves excavating the approximately 400,000 cubic
yards ofcontaminated soil and waste material, constructing a
RCRA-approved landfill, andredepositing the materials on site. This
alternative would thus completelyencapsulate all contaminated
materials and effectivefy isolate them from theenvii^nment. An
alternate water supply, groundwater remediation, and
long-termmonitoring will be provided.
Alternatives That Exceed All Applicable Standards
Remedial Action Alternative Five - Complete Excavation of
Contaminated Soilsand Wastes; Onsite Incineration with Multimedia
Cap Over Residuals; Extension ofthe Coatesville Water Authority
Public Water Supply; Groundwater Extraction.Treatment and
Injection: and Long-term Monitoring
RAA Five, like the previous alternatives, also involves complete
excavation ofcontaminated materials. Prior to disposal on site,
however, all wastes and soils areincinerated onsite using a mobile,
rotary kiln system. Residual materials arebackfilled, and a
multimedia cap is placed over them to minimize infiltration.
Allorganic contaminants in the soils and wastes will be destroyed
via this process. Analternate water supply, groundwater
remediation, and long-term monitoringcomplete this remedial action
alternative.
Option to Remedial Action Alternative Five____Complete
Excavation ofContaminated Soils and Wastes: Onsite Incineration
with Stabilization ofResiduals; Extension of the Coatesville
WaterGroundwater Extraction, Treatment, and Injection;
Authority Public Waterarrd Long-term Monitoring
Supply;
The option of stabilizing the incinerator residuals instead of
placing them under amultimedia cap is also evaluated. A pozzolanic
process using flyash and cement asadditives is suggested for
stabilization of the metals-laden residuals. Thestabilized product
would be backfilled on site, covered with a flow zone andtopsoil,
and vegetated. As in the first incineration alternative, an
alternate watersupply, groundwater remediation, and long-term
monitoring will be provided.
ES-8 302053
-
IIt
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DRAFT
Alternatives That Specify Offsite Disposal
Remedial Action Alternative Six - Excavation of Contaminated
Waste Deposits andDisposal in an Offsite RCRA-Approved Landfill;
the Option to Dispose, Contain, orTreat the Contaminated Soils that
Underlie the Waste Deposits; Extension of theCoatesville Water
Authority Public Water Supply; Groundwater Extraction.Treatment,
and Injection; and Long-term Monitoring
*
RAA Six provides for excavation and off site disposal of the
site's waste materialsin a secure, hazardous waste landfill. Three
options are then provided for thecontaminated soils underlying the
wastes. In the first option, the soils are disposedoff site, and
the area backfilled with clean fill and revegetated. The second
optionprovides for a multimedia cap over the in-place soils to
reduce the amount ofinfiltration. The third option allows for a
series of studies to evaluate thepotential use of an innovative or
emerging technology to detoxify the soils using amobile soil
washing system. The cleansed soils would be returned to the site
asclean backfill and the cleaning fluids treated as necessary. For
all three of theseoptions, an alternate water supply, groundwater
remediation, and long-termmonitoring are provided.
302054
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1
302055
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II
DRAFT
1.0 INTRODUCTION
1.1 Site Background
The Blosenski Landfill Site occupies approximately 13.6 acres in
West CainTownship, Chester County, Pennsylvania. As shown in
Figures 1-1 and 1-2, thelandfill lies approximately 1000 feet north
of State Route 340 (Kings Highway) ̂nd2000 feet west of the
intersection of King's Highway and Cambridge Road. It issurrounded
by heavily-wooded areas to the north and to the west, and
byagricultural areas to the east and northwest. A marshy area lies
on thenortheastern section of the site, and a ravine borders the
site to the north and east.Approximately 500 feet north of the
site, an intermittent tributary flowswestward, about 2 miles, to
Indian Spring Run. About 3.5 miles west of the site.Indian Spring
Run joins Pequea Creek, which flows into the Susquehanna
Riverapproximately 30 miles southwest of the site. Approximately 30
residents livewithin a quarter-mile radius of the site.
Beginning in the late 1940s, the landfill was reportedly
operated by Perry Phillipsfor the disposal of municipal and
industrial wastes. However, there is no specificinformation
regarding activities at the site until its purchase byJoseph M.
Blosenski, Jr., in the 1960s. From that time, until operations
ceased in1979, wastes accepted at the site for disposal included
drummed industrial wastes,truckloads of sludges, and municipal and
commercial refuse. Wastes were notsegregated, and the site
apparently was not lined.
Seven permits to operate the landfill were applied for in the
1970s but nevergranted. Several regulatory actions against the
owner were issued by thePennsylvania Department of Environmental
Resources (PADER). A consent decreeissued in 1979 to force site
closure required the completion of groundwater and soilstudies and
remedial measures. In accordance with this, four monitoring
wellswere installed on site by PADER in 1982. During the winter of
that year, 50 to 60drums and a leaking tank truck were removed from
the site. Samples taken byPADER and the USEPA Region III Field
Investigation Team (FIT) have identified
1-1302056
-
•*%
1-2
-
SPRING RUN .
.APPROX. PROPERTY LINE x-̂ _..
EMPTY DRUMS
RESIDENTIAL TRAILER
———————————— KINGS HIGHWAY ROUTE 340
LEGEND2-$- ONSITE MONITORING WELL a IDENTIFICATION NUMBER
•"—- SEEP
S-fĴ DEPRESSION
Z EMBANKMENTroe
302058FIGURE 1-2
SITE LAYOUTBLOSENSKI LANDFILL SiTE. WEST CALM TWR. PA NUS
CORPORATION-3 JT» A Halliburton Company
NOT TO SCALE ———' CORPORATION
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DRAFT
soil, surface water, and groundwater contamination with both
organic and inorganicsubstances. These findings were verified by
the results of the more recentremedial investigation (Rl) performed
at the site for the USEPA. The findings arediscussed further in the
fallowing section.
1.2 Remedial Investigation Results
The Rl was performed from the Fall of 1984 through the Spring of
1985 to assessthe present and potential impacts of site-related
contamination on the publichealth and the environment, and to
provide a technical basis for developingappropriate alternative
remedial actions for the site. Results of the investigationof
various onsite and off site media indicate that the wastes disposed
at theBlosenski Landfill Site are the apparent source of
contamination found in the
• environmental media of the surrounding area.
1.2.1 Contaminants
Both organic and inorganic chemical constituents were found at
the BlosenskiLandfill Site. However, the data indicate that the
primary contaminant problem iscaused by volatile organic compounds
in the groundwater and other media.Because volatile organics are
relatively mobile in the hydrologic cycle, they areconsidered to be
indicative of the subsurface migration mechanisms at the
landfill.
Volatile organics, and their respective maximum concentrations,
detected inmonitoring well and residential well samples taken
during the Rl are as follows:
____Chemical____ Maximum Groundwater Concentration (ug/l)
benzene 11,000toluene 600ethylbenzene 54total xylenes
78chlorobenzene 341,1,1-trichloroethane 430
1-4 302059
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I\*
fa rfDRAFT
____Chemical____ Maximum Groundwater Concentration (ug/l)
1,2-dichloroethane 741,1-dichloroethane 270chloroethane
93tetrachloroethene 5trichloroeihene ' 2601,2-dichloroethene
8901,1-dichioroethene 21vinyl chloride • 450chloroform 270methylene
chloride 2,000acetone 43,0002-butanone 3502-hexanone
214-methyl-2-pentanone 7
Data from residential wells surrounding the site indicates that
volatile organiccontaminants (primarily trichloroethene and
1,1,1-trichloroethane) have migratedoff site via the
groundwater.
Volatile organics were detected in surface and subsurface soils
on the eastern,western, and central portions of the site near
monitoring wells MW 2-1 andMW 3-1. Sampling did not identify
site-related impacts resulting from volatilecontaminants on the
intermittent stream north of the site, perhaps due to dryweather
conditions prevalent during the Rl.
As compared to the levels of volatile organics contamination
detected,environmental media at the site have relatively less
contamination by semi-volatiles (acid and base/neutrals),
pesticides, polychlorinated biphenyls (PCBs), andinorganic
substances. The chemical and analytical results of the Rl indicated
thatthese substances appear to be confined to the immediate
vicinity of theirdeposition areas (see Rl Report, Section 6.6).
Contaminants found in samples takenduring the Rl are summarized in
Table 1-1.
1-5 302060
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DRAFT
I 1.2.2 Pathways and Receptors
I The Rl identified the following five pathways for the
transport of contaminants topotential receptors.
i• Groundwater Movement - Transport of contaminated groundwater
may
J occur via the generally northward hydraulic gradient or
through fractures' and joints in underlying bedrock. A perched
groundwater zone in the! southeast corner of the site may also play
a role in groundwater
contaminant migration.
i • Leachate Production - Precipitation and infiltration may
leachcontaminants from waste pockets and contaminated soils into
the
f groundwater and overburden material.
•̂
• Erosion and Runoff - Stormwater may cause erosion of
contaminatedsurface soils resulting in the contamination of surface
waters and
, sediments.I
• Volatilization - Volatile organics could be introduced to
ambient air by| soil disturbances or favorable meteorological
conditions.
I • Particulate Transport - Respirable dust particles carrying
insolublecontaminants may become airborne.
Potential receptors of contaminants at the Blosenski Landfill
Site include thefollowing:
• Local residents downgradient (whether by natural or pumping
induced; , gradient conditions) of the site who use groundwater for
drinking,
showering, lawn watering, and other domestic uses.
1-15 302070
-
DRAFT
• Onsite remediation workers who may come into contact
withcontaminated soil, water, or air during cleanup activities.
• Casual intruders who traverse the site and its environs, and
thereby ma\come into contact with contaminated surface soils,
surface waters, andsediments. They also may be exposed to
windblown, respirable dustcontaining insoluble contaminants.
• Environmental receptors, including onsite terrestrial flora
and fauna,aquatic biota in affected surface waters, and terrestrial
fauna that useaquatic animals as a food source.
1.2.3 Public Health and Environmental Risks
By assimilating the information on contaminant effects,
pathways, and receptors,the Rl identified risks to the public
health and the environment resulting from theBlosenski Landfill
Site. Potential public health risks associated with the
variouscontaminated media are summarized below.
• Groundwater - The major exposure path and subsequent potential
publichealth risk at the site is through the ingestion and domestic
use ofcontaminated groundwater. Although the two
organics-contaminatedresidential wells are located upgradient of
the site, fractured bedrock andwell pumping may have drawn the
mobile (volatile) compounds from thesite. Contaminant
concentrations found in these residential andmonitoring well
samples exceed health criteria such as USEPA HealthAdvisories
(SNARLS) for 10-day acute effects and subchronic toxiceffects, and
for long-term chronic health impacts due to contaminantingestion,
as well as Safe Drinking Water Act Maximum ContaminantLevels
(MCLs).
1-16
302071
-
I
(
DRAFT
At the concentrations in the more contaminated residential well,
thepotential risk of exposures from volatilization of contaminants
duringshower usage exceeds the potential exposure from ingestion.
Theabsorption of contaminants during bathing may be comparable to
thatfrom direct groundwater ingestion. At the contaminant
concentrationsfound during the Rl, ingestion of the groundwater
carries a correspondingcancer risk in excess of 10 , based on the*
EPA's Unit Cancer RiskPreliminary Protective Concentration Limits
(PPCLS). These risk levelsare summarized in Table 1-2. At the mean
concentrations for thecarcinogens identified in the Rl, the
estimated corresponding totalpotential risk level, due to ingestion
of water from the two contaminated
-2 -2residential wells is 2.6 x 10 , and is 1.8 x 10 for
ingestion of waterfrom contaminated monitoring wells. Since the
residents with thecontaminated wells are drinking bottled water,
these risk levels areconservative.
• Surface Waters and Sediments - Surface waters and sediments
have beenrelatively unaffected by organic contaminants from the
site, and acuteeffects from ingestion, inhalation, or dermal
exposure do not appear to bea major problem. However, levels of
chloroform and nickel in surfacewaters exceeded the chronic health
effects Ambient Water QualityCriteria (AWQC) for long-term
ingestion. However, the surface watersare not known to be used as
drinking water in the site vicinity. TheAWQC for the protection of
human health via ingestion of aquaticorganisms were not exceeded
for any identified contaminants.
• Surface and Subsurface Soils - There has been no identified
route ofexposure to contaminants in the subsurface soils. Mobile,
volatilecontaminants were found at relatively low concentrations in
the soils.Therefore, they should not significantly affect the
groundwater.Phthalate esters, pesticides, and PCBs were found at
somewhat higherconcentrations. However, they are less mobile than
the volatiles and tendto adhere to soil particles, thus presenting
a lesser threat to groundwater.
1-17
302072
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Acute exposure, however, to subsurface contaminants could occur
duringa major soil disturbance.
The potential for exposure to surface soils is much greater than
tosubsurface soils through direct contact/dermal adsorption, dust
inhalation,and accidental ingestion. Although acute effects are
highly unlikely,except during soil disturbance, chronic effects*
may occur through directcontact with PCBs, phthalate esters, and
polynuclear aromatics, orthrough inhalation of released
volatiles.
• Source Areas - In the event of a major disturbance to
identified sourceareas or buried drums, the potential for dermal
exposures increasessignificantly.
• Air - Based on a qualitative measurement of volatilized
contaminantswithin monitoring well MW 2-1, atmospheric
concentrations ofcontaminants at the site would not be expected to
exceed the City ofPhiladelphia's recommended guidelines for average
yearly concentrations.Thus, health impacts would not be expected
via inhalation. However, soildisturbance during site remediation
may result in volatilization and theintroduction of contaminated
airborne dust particles. Monitoring andproper construction
techniques will reduce these potential health impacts.
Environmental risks from the Blosenski Landfill Site include the
following:
• Surface Waters and Sediments - Levels of contaminants found in
surfacewaters and sediments are low. The Ri data did not indicate
any acute orchronic risks to aquatic biota.
* Soils jnd Groundwater - The Rl data indicate that onsite soils
andgroundwater present a low, chronic risk to biota at this
time.
1-20 302075
-
IDRAFT
1.3 Remedial Action Objectives and Criteria
The overall purpose of the Feasibility Study (FS) process is to
provide an array oftechnically sound, cost-effective remedial
action alternatives that control thesource and manage the migration
of contaminants, and to provide protection topublic health,
welfare, and the environment. To meet this overall purpose,
specificcleanup objectives and criteria are necessary to provide a
focus for the generalresponse actions and technologies available
for remediating the Blosenski LandfillSite.
Each of the contaminant pathways and potential receptors
identified in the Rl anddiscussed in the previous sections were
evaluated under the following objectivesand criteria:
Cleanup Objectives Cleanup Criteria
a. No action a. Establish current potential risklevels and take
no remedial action
b. Prevent an increase in the current b. Establish current
potential riskpotential risk associated with the levels and utilize
remedial tech-site nologies to prevent increase in
potential risk levels
c. Reduce the current potential risk c. Reduce the current
potential riskassociated with the site to an associated with the
site to aacceptable level target cleanup criteria of a
10~6 potential risk level, orother acceptable level.
d. Reduction of risk levels to those d. Utilize remedial
technologiescorresponding to background concen- to eliminate site
contaminantstrations
The results of that evaluation process are discussed in the
following paragraphs.
3020761-21
-
DRAFT
1.3.1 Contaminated Groundwater
The most significant potential public health risk associated
with the site is toreceptors who ingest, shower with, or use the
contaminated groundwater in waysthat promote direct dermal contact
and/or inhalation of volatilized contaminants.Site contaminants
have been found in domestic wells south of the site. Theprimary
pathway for contaminant migration is through the highly fractured
bedrockgroundwater system that underlies the site. Volatile organic
contaminants thatenter the system move in fractures and along
relict bedding joints with little or noattenuation or adsorption of
the contaminants. The complex fracture systemprecludes accurate
prediction of the specific flow path and flow rate of
thecontaminant plume. However, the regional groundwater system
flows toward thenorth, and site contaminants may be discharged into
an unnamed intermittenttributary of Indian Spring Run, north of the
site. Indian Spring Run is classified byPADER as a protected stream
for the prooagation of cold water fish species. Ifsite contaminants
enter the stream, they could adversely affect stream biota.
The cleanup objectives of no-action and preventing further
increase of risk are notappropriate to the groundwater
contamination problem because of the highpotential health risks
associated with ingestion, inhalation, or contact with
thegroundwater contaminants. The objectives of reducing current
potential risks toacceptable or background levels are acceptable
and feasible, since correspondingcontaminant levels associated with
the site c*»n be reduced by availabletechnologies.
As defined by the National Contingency Plan (NCP, 40 CFR 300),
and EPA'sGuidance on Feasibility Studies Under CERCLA (USEPA, June
1985), an acceptabletarget cleanup criterion for the reduction of
risk is a level of 10~4 to 10"?. Thetarget cleanup criterion used
in this FS for reducing the public health risk to anacceptable
level is the reduction of the volatile organic contaminants to
theirrespective 10~6 risk levels. For the volatile organic
contaminants found at thissite, the 10~6 risk levels are the
maximum contaminant levels (MCLs) as shown inTable 1-3.
1-22 302077
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I
II
DRAFT
TABLE 1-3
PROPOSED GROUNDWATER TREATMENT STANDARDSBLOSENSKI LANDFILL
SITE
RecommendedMaximum Contaminant 4 Maximum Contaminant
Level (RMCL)O) Level (MCL)
-
DRAFT
The target clean-up criteria for the elimination of site
contaminants is backgroundconcentrations of site contaminants in
the groundwater system. In most cases thisbackground level for
volatile organics is zero. However, this level may notnecessarily
be analytically confirmable.
1.3.2 Contaminated Surface Soils and Sedimentsi
The most significant potential pu:.:ic health risk associated
with this pathway is tochildren, who may accidentally ingest
contaminated soils if playing on the site, andto other casual
intruders, who may come in dermal contact with the
contaminatedsoils. The Rl reported that there is no significant
health risk associated with thelevel of surface contaminants found
on site and in nearby sediments. However,there is potential for
increased risk if the site erosion is allowed to continue.
The no-action and the prevent-increase-in-risk objectives are
not appropriate tothe contaminated soil pathway because of the
future public health risk associatedwith migration of the soil
contaminants. The reduction-of-risk objectives arefeasible because
the contamination levels can be reduced by available
technologies.
An acceptable target cleanup criterion for reducing the
potential health riskassociated with the contaminated soil exposure
pathways is a corresponding risklevel of 10~6. jo attain a 10~6
rjsk, the following soil contaminants must bereduced to their
respective concentration levels, shown below:
Dermal Contact (Casual Intruders)
3,3' Dichlorobenzidine 3 mg/kgPolynuclear aromatics (Total) 0.5
mg/kgPCB's (Total) 1 mg/kg
1-24
302079
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1I
if
DRAFT
Soil Ingestion (Children)
3,3' Dichlorobenzidine 8 mg/kgPolynuclear aromatics (Total) 1
mg/kgPCB's (Total) 3 mg/kg
The elimination of site contaminants will require the reduction
of all contaminantsto concentration levels equal to or less than
background levels. In most cases, thislevel is considered to be
zero, and may not be analytically confirmable.
1.3.3 Respirable Contaminants
This pathway includes dust particles that contain sorbed
contaminants, particles ofnonvolatile contaminants, and volatilized
site contaminants. The only appropriateobjective in this category
is to maintain the current risk levels during any futuresite
remediation or atmospheric condition. Reduction and/or elimination
of thepotential health risk levels can be attained by meeting the
objectives and targetcleanup criteria of the other contaminant
pathways. Therefore, they are notproposed as feasible objectives
for remediation of this pathway. Standard acceptedengineering
practices and construction management techniques will
properlyaddress risk concerns during remediation activities.
Table 1-4 lists the general response actions that m^et the
cleanup objectives andcriteria for the contaminant exposure
pathways. In Section 2.0 of this report,these actions will be
broken down into site-specific remedial technologies andscreened
for remediation applicability on the basis of technical
feasibility, publichealth and environmental impacts, institutional
issues, and costs.
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| 302082
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:, '.'' • DRAFT
1.4 Feasibility Study Procedure
The FS process is intended to develop and evaluate remedial
action alternatives forthe site using data obtained during the R!
and using other site-related informationobtained from local, state,
and Federal agencies. As a minimum, one alternativewill be
developed for each of the five cleanup categories described in the
USEPAGuidance Document on Feasibility Studies Under CERCLA (USEPA,
June 1985).These categories are described further in Section 3.0
and include the no-actionalternative as a baseline alternative.
The methodology for preparation of this FS parallels the
procedure outlined in theGuidance Document and the NCP. This
procedure is as follows.
• Identify General Response Actions - General Response Actions
(GRAs)were identified which address the site problems and
contaminantpathways identified during the Rl. Corresponding
objectives and criteriato be used in evaluating technologies within
each GRA were developed foreach contaminant pathway.
• Identify and Screen Technologies - Technologies were
identified for eachGRA and screened against the site-specific
cleanup objectives andcriteria. Technologies not meeting the site
cleanup objectives andcriteria were eliminated from further
consideration, whereas thoseremaining were screened by additional
crteria. These additionalscreening criteria included technical
feasibility; ability to adequatelyprotect the public health,
welfare, • and the environment; costconsiderations; and
institutional constraints. The results of thetechnology screening
are presented in Section 2.0 of this report.
• De.elop Remedial Action Alternatives - Remedial Action
Alternatives(RAAs) were developed from the remaining technologies
in each GRAcategory. Alternatives judged to have significant
adverse impacts or thatwere judged to be significantly higher in
cost without providing
1-28 302083
-
I
I
I
1f
DRAFT
significantly greater benefits were excluded from consideration.
At leastone RAA was provided for each of the five USEPA cleanup
categories, asrecommended in the Guidance Document. These RAAs are
discussed inSection 3.0 of this report.
The resulting group of alternatives were evaluated according to
the samecriteria used to screen the technologies: technical
feasibility, health andenvironmental impacts, costs, and
institutional concerns. The results ofthe detailed evaluation
process are discussed in Section 4.0 of this report.The RAAs
evaluated in Section 4.0 are summarized in Section 5.0 tofacilitate
EPA's review and selection of the appropriate remedial actionfor
the Blosenski Landfill Site.
1-29 302084
-
302085
-
DRAFT
2.0 SCREENING OF REMEDIAL ACTION TECHNOLOGIES
2.1 Screening Criteria
This section describes the screening process used to identify
the most appropriateor effective technologies for mitigating
contamination problems at the BlosenskiLandfill Site. A list of
candidate technologies will be identified and evaluated toeliminate
technologies that do not satisfy the appropriate cleanup objectives
andmeet technical and environmental criteria. This section
summarizes the majorjustifications for retaining or eliminating the
remedial technologies. Detailedbackground screening data are
provided in Appendix A. The screening criteriaconsist of:
• Satisfaction of site-specific objectives• Technical
feasibility• Health and environmental impacts• Cost of
implementation• Institutional considerations
Technologies that pass the screening process will be retained
for development intoappropriate RAAs.
2.1.1 Satisfaction of Remedial Action Objectives
Only technologies that satisfy the appropriate remedial action
objectives will befurther screened by the remaining criteria.
Those-objectives listed in Section 1.3will be the basis for
choosing applicable remedial technologies. A technology maybe
technically feasible and cost attractive, but if it does not
satisfy theappropriate cleanup objectives, it is considered
inappropriate for the site.
2-1 302086
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DRAFT
2.1.2 Technical Feasibility
Technologies will be evaluated in terms of their ability to
provide the desiredremediation, such as containment, treatment, or
disposal. Each technology will beevaluated based on the following
technical criteria:
t,
• Performance• Implementability• Reliability• Safety
The performance of each technology will be evaluated in terms of
its effectivenessin satisfying the cleanup objectives through
applicable technical standards andcriteria. Technologies should
also provide remediation for an extended time,.usually 30 years,
without significant deterioration. The technologies should
beimplementable; that is, they should be constructabie under the
site conditions andin a timely manner. It is important for the
technologies to be reliable, asdetermined by previous performance
data under similar conditions, ideally, thetechnologies should have
infrequent operation and maintenance (O&M)requirements, which
should be as simplified as possible when required. Eachtechnology
should also be implementable with minimum health effects, both
toremedial workers and to the surrounding community. Consideration
will be givento innovative technologies as they may be applicable
to site conditions.
2.1.3 Health and Environmental Impacts
Each technology will be evaluated for its impact on both public
health and theenvironment. Both beneficial and adverse impacts will
be assessed for thetechnologies that address the site-specific
problems and contamination pathways.The impacts associated with
both implementation and post-closure activities willbe
considered.
2-2 302087
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DRAFT
2.1.4 Cost Evaluation
Costs will be determined, as required, to screen out
technologies for which resultsof the other screening criteria are
essentially the same. Cost estimates willinclude capital costs and
O&M costs, which will be used to screen out technologiesthat
provide similar degrees of remediation but cost significantly
(e.g., an order ofmagnitude) more.
2.1.5 Institutional Considerations
The applicable Federal, state, and local standards, regulations,
and ordinances willbe addressed for each technology. Any indirect
community or other impacts willalso be discussed in this section,
as applicable.
22 Candidate General Response Actions and Technologies
The possible technologies used to remediate a site can be
classified into groupscalled General Response Actions (GRAs), each
of which can be used to control acontaminated media or its
migration pathway. Table 2-1 contains a comprehensivelisting of
GRAs and technologies that can be used for a hazardous waste
siteremediation. This list is provided to help ensure the
consideration of all possibletechnologies.
2.3 Technology Screening Process
Table 2-1 of this report identifies various GRAs that may be
applicable forcontaminant source and migration control at the
Blosenski Landfill Site. Thissection describes the screening
process used to identify, within GRA categories,the appropriate or
effective technologies for mitigating contamination under
site-specific conditions. The technologies are examined based on
their ability to meetthe cleanup objectives listed in Section 1.3,
their technical feasibility, health andenvironmental impacts, costs
of implementation, and institutional criteria.
f302088
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DRAFT
TABLE 2-1
GENERAL RESPONSE ACTIONS AND ASSOCIATEDREMEDIAL TECHNOLOGIES
General Response___Actions___ __________Remedial
Technologies__________
X
No Action - Some monitoring and analyse may be included
Containment - Capping; dust control; addition of freeboard;
groundwatercontainment barrier walls; bulkheads; gas barriers
Pumping - Groundwater pumping; liquid removal; dredging
Collection - Sedimentation basins; French drains; gas vents;
gascollection systems
Diversion - Grading; dikes and berms; stream diversion
ditches,trenches, and diversions; terraces and benches; chutes
anddownpipes; levees; seepage basins
Complete Removal - Tanks; drums; soils; sediments; liquid
wastes,contaminated structures; sewers and water pipes
Partial Removal - Tanks; drums; soils; sediments; liquid
wastes
Onsite Treatment - Incineration; solidification; biological,
chemical, andphysical treatment
Offsite Treatment - Incineration; biological, chemical, and
physical treatment(POTW or pretreatment facility)
In-situ Treatment - Permeable treatment beds; bioreclamation;
soil flushing;neutralization; land farming
Storage - Temporary storage structures
Onsite Disposal - Landfills; deep well injection
Offsite Disposal - Landfills; surface impoundments; land
application
Alternative Water - Bottled water; cisterns; above-ground tanks;
deeper orSupply upgradient wells; municipal water system;
relocation of
intake structure; individual treatment devices
Relocation - Relocate residents, businesses, and habitat
areas
302089
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DRAFT
Technologies that obviously are not appropriate for meeting the
cleanup objectives,and technologies found not to be effective under
site-specific conditions will not beevaluated further. Those
passing the initial screening will be retained fordevelopment into
appropriate remedial action alternatives.
2.3.1 No Action with Monitoring
Although not a remedial action technology per se, an evaluation
of the no actionalternative provides a baseline evaluation of
current site conditions, against whichthe relative effectiveness of
other remedial actions may be compared. The currentextent of
contamination was determined by sampling and analysis conducted
duringthe Rl.
The no action alternative will not reduce any exposure risks or
potential impacts topublic health and the environment. The addition
of continued monitoring, however,will provide a mechanism to
determine the trends of future contaminantconcentrations and
migration from the site. Samples should be taken periodically(every
3 to 12 months) and should include surface soil and groundwater
samples.All samples should be analyzed for EPA Hazardous Substance
List (HSL)compounds, including volatile organics, inorganics,
pesticides, and PCBs.
2.3.2 Containment
2.3.2.1 Surface Capping
Two of the mechanisms that are contributing to contaminant
migration from theBlosenski Landfill Site are leachate generation
due to infiltration of rainfall, anderosion of contaminated soils
or wastes caused by storm water runoff. These twomechanisms can be
controlled by installing a protective cap that reduces the rateof
infiltration and protects the contaminated media from the erosional
effects ofstorm water. Surface capping is a technology that has
been effectively utilized inindustry and in the management of
uncontrolled hazardous waste sites to controlthe contaminant
migration mechanisms of infiltration and storm water runoff.
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Potential surface capping materials include synthetic membranes,
low permeabiitysoils (clays, silty clays, clayey silts, and
selected silts), local soil materials, asphaltmaterials, chemical
stabilizers, or a multimedia cap constructed of lowpermeability
soils and synthetic membrane layers. The following
paragraphsdiscuss the application, of the above capping materials
and their relativeapplicabiity to the Blosenski Landfill Site.
• Synthetic Membranes
Synthetic membranes are considered state-of-the-art for
obtainingminimal infiltration rates as both liners and caps. A wide
variety ofpc'ymeric and synthetic materials are available for use
as liners and caps.Some of the more common types of synthetic
membrane materials arehigh density polyethylene (HOPE), polyvinyl
chloride (PVC), chlorinatedpolyethylene (CPE), chlorosulfonated
polyethylene (CSPE), butyl rubber,anc1 ethylene propylene
rubber.
The thickness of the synthetic membrane is determined in
thousandths ofan inch, or mils. Membranes range in thickness from
10 mils to over100 mils. A January 1985 information package from
the EPA HazardousSite Control Division recommended that a synthetic
membrane used inconjunction with 2 feet of compacted, low
permeability soils to form acap meeting RCRA specifications be at
least 20 mils thick, and that 60 to100 mils is frequently used by
industry. The May 1985 MinimumTechnology Guidance on Double Liner
Systems for Landfills and SurfaceImpoundments—Design, Construction,
and" Operation recommends that a30-mil membrane be utilized for
liners that are protected by a blanket ofsoil from the effects of
sun and weathering, and that a 45-mil membranebe utilized if the
membrane was exposed or uncovered for a year or more.
The selection of both the type of synthetic material and the
thickness of asynthetic membrane will depend on the site-specific
application of themembrane and the ability of the synthetic
membrane to meet the
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1 objectives established for a remedial action alternative. The
BlosenskiLandfill Site has several characteristics that limit the
effectiveness and
I reliability of a synthetic membrane cap alone. The site has
beenidentified as a municipal solid waste (MSW) landfill along with
theindustrial waste and solvent disposal activities that the RI/FS
has focused
/ on. MSW is subjected to an anaerobic decomposition and
degradationprocess when placed in a landfill. The process can cause
settling and
^ consolidation of the deposited MSW by as much as 30 to 50
percent overthe life of the landfill. Synthetic membranes and the
welds or seams that
| hold the panels of membrane together to form a cap are
susceptible tofailure when waste pockets settle. The synthetic
membrane is stretched
1 and elongated which reduces its ability to resist infiltration
and if enough* settling occurs, the membrane in that area could
fail completely. ThereI • is also some concern that the site
contaminants and their interaction withI each other might degrade
the synthetic material over time. The
installation of the synthetic membrane and subsequent
constructionactivities associated with completing or maintaining a
remedial actionexposes the membrane to equipment operations that
could cause damage.Burrowing animals could also damage the
synthetic membrane. Thesynthetic membrane also creates a low
friction surface that makes itdifficult to place cover materiais or
granular collection materials overthe membrane in steep sloped
areas. There have been incidences wherematerials have slid off a
synthetic membrane after a rain storm. The rainwaters infiltrated
the cover materials, formed a phreatic zone along theinterface, and
created a failure plane.
A synthetic membrane cap for the Blosenski Landfill is not a
goodtechnology by itself. There are implementability, reliability,
anddurability problems that could cause failure or reduced
performance of asynthetic membrane cap. The cap would not control
the rate ofinfiltration and, without a protective zone of soil and
vegetative cover,the storm water runoff from about 9.5 acres of
impervious area would bedifficult to control. The use of a
synthetic membrane in conjunction with
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low permeability soils is a better technology that offers a
backupimpervious zone in case of membrane deterioration or failure.
Theadditional cost of a multimedia cap is not an order of magnitude
higherthan a synthetic cap alone, and will be retained for further
evaluation.
Low Permeability Soils*
Low permeability soils are considered to be soils that, when
compacted,exhibit a permeability less than or equal to 1.0 x 10~7
cm/sec. Typically,these soils fall within the Unified Soils
Classification System (USCS)classifications of clays, silty clays,
clayey silts, and silts depending ontheir plasticity index and
organic or inorganic determination. Lowpermeability soil caps,
often called clay caps, are constructed of thicklayers of compacted
fine-grained soils. The soil is placed in loose lifts ,
I
6 to 12 inches thick and then machine compacted to a
predetermined 'density. This process is repeated until a compacted
layer of soil severalfeet thick is attained. The thickness of the
cap is generally in the range Iof 2 to 3 feet. The amount of
compaction required to attain apermeability within the range of
10"̂ cm/sec is typically in excess of •
:90 percent of the soils maximum dry density as determined by
standard ormodified compaction tests.
It is extremely important to note that density and
permeabilities that areattained in the laboratory are not likely to
be duplicated in the field. Thelaboratory is a controlled
environment and the purpose of the laboratorytests are to develop a
standard for field construction activities. Thelaboratory test
procedure for compaction testing utilizes impact energyto compact
the laboratory soil samples, while most field compactionmethods use
kneading and/or static pressure. Standard practice forlaboratory
permeability testing utilizes the remolded soil sample that
wassubjected to the impact compaction method. It is not unrealistic
to findthat a properly constructed, low permeability soil cap will
exhibit a
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permeability that is an order of magnitude greater than the
laboratorypermeability test results.
The selection of a suitable low permeability soil for use as an
imperviouscap will require extensive testing and evaluation. The
soils in the areawill have to be sampled and tested for grain size
distribution, plasticity,permeability, compatibility with the
chemical characteristics of theinfiltration expected to occur at
the site, and compactibility. However,the Blosenski Landfill site
has one physical characteristic that is notcompatible with the use
of a compacted, low permeability soil cap as thesingular means of
reducing the amount of infiltration generated lechate.The MSW
deposited at the site is not a suitable base for the constructionof
a compacted, controlled fill. The MSW exhibits an elastic rebound
thatwill continually subject the placed, compacted material to a
wave-likemotion. The result is an inability to achieve the degree
of compactionnecessary to attain a 1.0 x 10~7 cm/sec permeability
and numeroussurface fractures in the plastic action of the
soils.
A low permeability soil cap for the Blosenski Landfill Site is
not a goodtechnology by itself. The compaction forces needed to
attain a1.0 x 10~7 cm/sec permeability in a fine-grained soil
cannot be achieveddue to the elastic properties exhibited by MSW
landfills. The elasticrebound will also cause surface tension
cracks due to plasticity of thefine-grained soils. Soils with
larger particles and less plasticity can beused to overcome the
problems, but they will generally exhibitpermeabilities within the
range of 10~5 cm/sec. A soil cap with thoseproperties is screened
later in this section. The low permeability soilsdiscussed above
are also used in a later part of this section as part of
amultimedia cap technology screening and, therefore, will be
retained forfurther evaluation.
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Soil Cap
Soil caps are considered to be a thick layer of compacted, local
soils thatcan be effective in reducing the amount of infiltration
related leachate,but are primarily used to create a barrier between
the site contaminantsand receptors that might otherwise ingest or
contact the surfacecontaminants. They are also used in controlling
erosion relatedcontaminant migration. Based on the soil information
presented in the Rl,the soils found near the Blosenski Landfill
Site are generally of theEdgemont Series and consist of loams,
silty loams, and silts. Thesetextures of materials typically
exhibit permeabilities within the range of10~5 cm/sec.
In order to aid in evaluating the effectiveness of a soil cap
constructedfrom local soils, the HELP computer model was run on all
the potentialcap materials discussed in this section and on the
existing site conditions.Since regional climatological data and
default soil data was used in theHELP simulations, the results of
the computer simulations are presentedas a relative percentage
decrease in leachate production based on existingconditions. For
example, the HELP model showed a 2-foot-thick soil capwith a
permeability of 10~5 cm/sec to produce 99 percent less leachatethan
the existing site conditions.
The use of a 2-foot-thick soil cap with a permeability of 10~5
cm/sec isan effective technology to reduce leachate production and
controlcontaminant migration caused by erosion. The compaction
problemsidentified with the low permeability soil cap presented
earlier will notadversely impact the silty, loamy soils used in
this soil cap. The largersized soil particles will not require the
same amount of compaction forceto attain maximum densities, and the
plasticity of this texture of materialshould not create extensive
or uncontrolled surface tension cracks. Thedesired permeability
should be attainable in these types of fieldconditions. The
additional cost of securing clay-like soils and compacting
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them to a lower density to attain similar permeability does not
appear tobe a feasible option for the soil cap technology. Local
borrow should beless expensive to buy and to transport to the site
if a nearby supplier canbe found.
Although this technology does reduce the amount of leachate
produced bythe site, it does not effectively control the source in
a manner that allowsit to be considered a source control remedy.
This technology should notbe combined with other technologies that
call for contaminant migrationremediation unless another source
control technology is also incorporatedinto the remedial action
alternative.
Multimedia Cap
Multimedia caps are a combination of low permeability soils and
syntheticmembranes in conjunction with an overlying layer of
protective soil thatcan also support vegetation. In most cases, an
infiltration collection andflow zone is added between the synthetic
membrane and the protectivesoil cover. The combined effect of the
low permeability soils and thesynthetic membrane is not an overall
decrease in the permeability of thecap, but rather a factor of
safety in case one or the other imperviousmedia fail or
deteriorate.
The Blosenski Landfill Site is not suitable for capping with
either thesynthetic membrane or the low permeability soils alone.
However, thesite can be capped with a multimedia system which will
compensate forthe weaknesses of the individual materials. The soils
will not attain a10~7 cm/sec permeability, but the synthetic
membrane will. Thesynthetic membrane can be damaged through waste
settlement orconstruction activities, but the soils will have a
tendency to mold and flexwith the settlement and construction
activities. There is also someevidence that the weight of the
multimedia cap and the moistureretention capabilities of the
synthetic membrane will create a
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consolidation effect on the soils, while keeping the soils at or
aboveoptimum moisture. This combined effect may decrease the
relativepermeability of the compacted soils and create a more
uniforminfiltration barrier.
The capital costs for a multimedia cap versus a synthetic
membrane capor a low permeability soil cap is not at. order of
magnitude higher.Preliminary cost estimates for the multimeu.d cap
is about $3,000,000 andthe cost for a low permeability cap is about
$1,000,000 for a 9.5-acresite. The cost estimate for a synthetic
membrane cap is expected to fallbetween these estimates. A
multimedia cap for the Blosenski LandfillSite is a feasible
technology that can be combined with other technologiesto remediate
the site. This technology can also be used as a sourcecontrol
remedy since it effectively reduces leachate production to
nearzero.
• Asphalt Cap
Asphalt caps may be constructed over a prepared subgrade
tosubstantially reduce infiltration. However, asphalt liners are
subject tocracking from subgrade failure. This is especially true
for an areacontaining refuse, which is subject to subsidence from
wastedecomposition. Because of their structural instability,
asphalt liners willnot be retained for further evaluation.
• Chemically Stabilized Caps
Chemical stabilization involves excavating the present cover
materials,mixing them with lime or bentonite, and replacing them,
thereby forminga more impermeable cover material. These cemented
soils are subject tocracking from freeze-thaw stresses and may
deteriorate upon extendedexposure to organic solvents vapors. Due
to their long-term instability,
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chemically stabilized surface caps will not be retained for
furtherevaluation.
2.3.2.2 Groundwater Barriers
One of the site objectives is to reduce the potential public
health risks associated*
with consuming groundwater contaminants. A groundwater barrier
can help toachieve this goal by containing the groundwater within
the site and isolating itfrom the off site receptors. Groundwater
barriers can also be used to blockgroundwater movement so that it
can be collected more easily. Highly fracturedbedrock formations,
however, reduce the effectiveness of groundwater barriers.
• Soil-Bentonite Slurry Wall
A soil-bentonite slurry wall involves excavating a trench down
to bedrockunder a slurry of bentonite clay and water, then
backfilling the trenchwith the original soil admixed with the
slurry to form a low permeabilityboundary. The water table at the
Blosenski Landfill is at or below thebedrock surface. Since slurry
walls only extend down to bedrock, theywould not be effective in
reducing groundwater movement.
• Grout Curtains
A grout curtain is a seal formed in soil or rock voids from
suspensionfluids that have been pressure injected and allowed to
set up. It can beused to either contain groundwater or control its
flow direction.However, containing groundwater in fractured bedrock
would be difficult,due to the complex fracture network. The ability
to check for a sealafter grout installation is questionable. Also,
the long-term effectivenessof a grout curtain exposed to dilute
contaminant concentrations isquestionable. Since the residential
wells adjacent to the site are up to150 feet deep, the grout
curtain should extend to that same depth.Because of the depth of
seal required, a grout curtain would be a very
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expensive technology. Preliminary estimates (Appendix A)
indicate a costof $3,000,000 for a 1400 foot wall extending 150
feet into bedrock thatwould be located between the contaminated
wastes and the residences.Tor these reasons, a grout curtain will
not be evaluated further.
2.3.3 Groundwater Collection4
The groundwater contaminant concentrations beneath the site
currently correspondto unacceptable potential health risk levels.
One method of reducing the risks toacceptable levels is to collect
the contaminated groundwater to reduce itsmigration off site. There
are two general methods for collecting groundwater.One method is a
passive system using collection drains to intercept thegroundwater,
and the other is an active system utilizing pumping to increase
theflow and removal rates.
2.3.3.1 Subsurface Collection Drains
Subsurface collection drains work well in excavatable soil. At
this site,groundwater is located within the bedrock which, based on
Rl data, isapproximately 30 feet below the surface. The deepest
residential well is believedto be approximately 150 feet deep. The
collection drain would have to be at leastthis deep to reduce
contamination passing beneath the drain. This would
involveexcavating approximately 120 feet of bedrock. The cost of
this technology wouldbe at least an order of magnitude greater than
pumping and, therefore, will not beconsidered for further
evaluation.
2.3.3.2 Groundwater Pumping
Pumping is the most widely used method of groundwater
extraction. Because thegrourriwaxer flow at the site is influenced
by fractures, additional aquifer testingshould be performed during
the design phase to optimize groundwater removalsystem design.
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Groundwater pumping is feasible for the following reasons: (1)
aquifer testingduring the Rl identified sustained yields with
groundwater being intercepted in thedeep monitoring wells; and (2)
the residences have been able to extractgroundwater on a long-term
basis. Even though it is unlikely that all the fracturescontaining
contaminants can be intercepted, the overall gradient can be
controlledso that groundwater in the fractures between the well
points will eventually flowtoward the pumping well. Although
groundwater pumping in fractured bedrock\poses difficulties, it
remains a proven and cost-effective technology forgroundwater
extraction.
Once the groundwater is pumped and treated, it must be
discharged to theappropriate medium. The treatment plant effluent
will meet drinking waterstandards (MCLs), so there should be little
if any risk in contaminating the aquifer.Discharging to the
intermittent stream was considered; however, this type ofdischarge
would eventually infiltrate to the groundwater. Discharging to a
drystream might also cause problems with respect to erosion of
contaminatedsediments. For these reasons, injection to the aquifer
was chosen as the dischargemethod.
Groundwater injection may be accomplished by using seepage
basins or well points.Injection should be by wells because basins
in soil have a potential for clogging atthe surface, whereas
injection wells bypass the soil and go straight to the
bedrockaquifer. Also, clogging of the basins could cause the
discharged water to migratelaterally which could flood low-lying
areas. Injection wells can be installed at thesame time that the
well points are installed for groundwater pumping.
Injection wells should be located upgradient of the site to
create a cycle of flowthrough the waste and enhance flushing of the
contaminated groundwater. This canbest be done by locating the
wells between the site and the residences to the south.The depth of
the wells should be approximately 100 feet to attain a
sufficientrecharge rate.
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2.3.4 Surface Water Controls
Surface water diversion is an effective method of controlling
the erosion ofcontaminated sediments associated with storm water
runoff. Althoughcontamination of surface water and sediments does
not appear to pose anunacceptable risk, the possibility of future
releases should be minimized. Thesereleases can be minimized by
utilizing proper erosion and sediment controls.Diversion structures
are relatively minor technologies, which are used as
ancillarymeasures to other remedial technologies. Structures such
as berms, ditches, andsediment traps are relatively inexpensive
items used on any type of constructionactivity. Therefore, surface
water controls will be retained for further evaluation.
23.5 Contaminant Excavation/Removal
Excavation involves removing contaminated soils and wastes from
their presentlocation in preparation for onsite or off site
treatment or disposal. Since the sourceof contamination is actually
removed, the residual risks associated with exposureto surface
water and airborne migration are expected to be reduced
toapproximately background levels. Excavation will not reduce the
risk associatedwith existing groundwater contamination. It will,
however, reduce the futuregeneration of leachate.
Excavation of waste materials may pose health and safety
problems to the workersthrough direct contact or through
volatilization of organic wastes. These hazardscan be greatly
reduced by using proper equipment and construction
techniques.Excavation and/or removal will be retained for further
evaluation.
2.3.6 Innovative Treatment Technologies
The purpose of this section U to present innovative and emerging
technologies,screen them under the criteria and objectives
established previously, and developpotential remedial technologies
for use with other technologies as remedial actionalternatives. For
this report, an innovative technology is defined as a
technology
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that has not been established specifically for the particular
waste on which it is tobe used However, it has proved successful in
remediation of other wastes. Anemerging technology is a technology
that is still in the research stage and has notbeen utilized in
industry.
The fractured bedrock that underlies the Blosenski Landfill Site
has eliminatedmost of the innovative and emerging technologies
reviewed for potentialapplication as a remedial technology. Many of
the technologies utilize in-situtreatment as part of their
detoxification processes and require the controlledinjection and
extraction of solvents, microorganisms, nutrients, or
chemicals.Therefore, the fractured bedrock cannot be considered a
reliable or predictablemedia. A more complete list of the
innovative technologies that were evaluated isincluded in Appendix
A of this report.
One innovative technology that might be applicable is in-situ
vitrification. Thisin-situ detoxification process utilizes
electricity to create extremely hightemperatures in the waste or
soil. The high temperatures (2,000°F to 3,600°F)actually melt the
soils or wastes, forming a pool of liquified material that coolsand
creates a glassified media. The theory behind the technology is
that mostcontaminants are destroyed in the liquification process,
the volatile materials aredestroyed as they try to escape upward
and encounter the 3,600°C liquified soil,and the remaining metals
are stabilized within the glassified residual. Althoughthis is a
fascinating technology, it is not a technology that can be applied
or testedat the site. The mass liquification of soils and wastes is
too risky and there are toomany unknowns. The potential risks are
extremely high during the treatmentprocess and the public
perception of melting soils and wastes as a remedy for thesite
cannot be expected to be favorable.
Several other innovative technologies were reviewed and
evaluated that did notutilize in-situ treatment processes.
Typically, these technologies required theexcavation of the media
to be detoxified and the placement of the excavatedmaterials into a
treatment process. Discussion of the technologies that
wereevaluated under this scenario is included in Appendix A of this
report.
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The one technology that was thought to be feasible for
additional study was a soilwashing technolgoy. Although this
technology was not suitable for use on thecontaminated wastes, the
use of a soil washing technology on the contaminatedsoils that
underlie the wastes was selected for further study. This does not
meanto imply that soils washing is a feasible technology for
remediating thecontaminated soils at the Blosenski Landfill Site.
Rather, it is a promisingtechnology for which additional testing
and evaluation appears to be warranted atthis time. An initial
study and a pilot study is recommended as part of a remedialaction
alternative that utilizes another form of source control remedy,
thusproviding EPA the option to remediate the contaminated soils
with a proventechnology should the additional studies find that
soil washing is not applicable tothis site.
2.3.7 Groundwater Treatment
Groundwater treatment can be used prior to discharge of
extracted and collectedgroundwater to reduce the contaminant
levels. This would ensure the protection ofthe environment by
reducing the impact of groundwater contaminants on receptorswhile
restoring the natural groundwater resource. This technology would
be used inconjunction with groundwater extraction and injection
discussed previously.
In the long-term, the restoration of the groundwater quality to
the NCP'sacceptable risk levels of 10~4 to 10~7 or to background
levels will provide a futurepotable water source for nearby
residents. Because the groundwater adjacent tothe landfill is used
directly as a water supply via residential wells, the
applicablestandards are the maximum contaminant levels (MCLs) as
promulgated under theSafe Drinking Water Act, or alternate
contaminant levels (ACLs) determined bythe regulatory agencies on a
site-specific basis. The contaminants in thegroundwater that exceed
these standards are predominantly the volatile organics.
There are several types of proven technologies that can be used
to remove volatileorganics from water. Therefore, technical
infeasibility will not eliminate thetechnologies from
consideration. Any type of treatment process will require
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meeting discharge permit requirements as specified under the
Federal CleanStream Law (PL 1987, No. 394). The following unit
processes are applicable in
I removing volatile organics to provide the desired degree of
treatment.
2.3.7.1 Carbon AdsorptionI
Adsorption by activated carbon is suitable for removing a wide
variety of> contaminants including volatile organics, most acid
extractables, and pesticides.
These types of contaminants have been reduced to at least 10
ug/l in industrialj applications. The environmental impacts of
carbon adsorption are minimal, since
the absorbed contaminants are contained within the spent contact
chambers, whichI can be disposed of easily or regenerated. Carbon
adsorption is generally more
costly than other treatment processes. However, the resulting
effluent is higher inquality. Carbon adsorption will be retained
for further evaluation.
2.3.7.2 Biological Treatment
Groundwater at the Blosenski Landfill Site contains organic
contaminants that maybe biodegradable through biological treatment.
Except for a few isolated samples,however, the concentration of
organic compounds found in the groundwater isbelow the effluent
concentration achievable by conventional biological processes.Also,
most of the organic contaminants are volatile and would be emitted
to theatmosphere through agitation caused by aeration equipment.
Therefore, biologicaltreatment will not be retained.
2.3.7.3 Precipitation, Flocculation, and Sedimentation
Precipitation, flocculation, and sedimentation are processes
that have been used totreat various municipal and industrial
wastewaters containing suspended solidsand/or soluble metals. Due
to the filtering action of the soil, the presence ofsuspended
solids is generally not a problem in groundwater leachate at
theBlosenski Landfill Site, and the metals concentrations at the
site are generallybelow the National Primary Drinking Water
Standards. However, precipitation,
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flocculation, and sedimentation may be required for pretreatment
in a system fortreatment of organic contaminants, such as carbon
adsorption or air stripping.
2.3.7.4 Air Stripping
Air stripping has been demonstrated to remove various types of
volatile organics,such as the chlorinated and aromatic hydrocarbons
found in the groundwater at theBlosenski Landfill Site. Air
stripping is a flexible process that can be designed toremove at
least 90 percent of volatile organics. Air stripping is usually
carried outin packed towers.
There is a possibility of exceeding ambient air standards due to
volatilization ofcontaminants. However, this can be controlled by
using proper operationalequipment. The overall cost of air
stripping is lower than for carbon adsorption,even though
operational costs for air stripping (electricity) is higher. Air
strippingwill be retained for further evaluation.
2.3.7.5 Offsite Wastewater Treatment
The possibility of using a nearby publicly owned treatment works
(POTW) forremoval of groundwater contaminants was investigated. The
main consideration isthe cost effectiveness of designing and
building an onsite treatment plant versussending the wastewater to
the nearest POTW. In this case, the nearest POTW isthe City of
Coatesville Treatment Plant, which is located approximately 6
milesfrom the site. Even if the plant has the required capacity,
numerous institutionalconsiderations must be made regarding
community responsibility and futuregrowth. POTWs are often
reluctant to accept wastewaters that are not generatedwithin their
jurisdictional area. Nevertheless, treatment at a POTW should
beretained for further consideration.
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2.3.8 Onsite Storage
Storage measures merely transfer the wastes from one location to
another and donot meet the objective of reducing corresponding risk
to acceptable levels.Temporary stor