TECHNOLOGY

PUBLIC REVIEW FEASIBILITY STUDY REPORT VOLUME I CONTRACT NO. X-312

A. O. POLYMER SITE SUSSEX COUNTY, NEW JERSEY

PREPARED FOR:

STATE OF NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION DIVISION OF HAZARDOUS SITE MITIGATION TRENTON, NEW JERSEY

APRIL, 1991

Rob'nson Plaza II. Suite 2OO, Pittsburgh, PA 152Q5 2] 7SB-32OC PUBLIC REVIEW FEASIBILITY STUDY REPORT VOLUME I CONTRACT NO. X-312

A. O. POLYMER SITE SUSSEX COUNTY, NEW JERSEY

PREPARED FOR:

STATE OF NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION DIVISION OF HAZARDOUS SITE MITIGATION TRENTON, NEW JERSEY

APRIL, 1991

PREPARED BY:

ICF TECHNOLOGY INCORPORATED Robinson Plaza II, Suite 200 Pittsburgh, Pennsylvania 15205

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o vo TABLE OF CONTENTS A.O. POLYMER SITE FEASIBILITY STUDY VOLUME I

Page No. 1.0 INTRODUCTION ...... 1-1 1.1 Purpose and Organization of Report ...... 1-1 1.2 Site Background Information ...... 1-2 1.2.1 Site Description ...... 1-2 1.2.2 Site History ...... 1-7 1.2.3 Environmental Setting ...... 1-8 1.3 Nature and Extent of Contamination ...... 1-13 1.3.1 Source ...... 1-13 1.3.2 Soil ...... 1-13 1.3.3 Groundwater ...... 1-15 1.3.4 Potable Wells ...... 1-22 1.3.5 Surface Water ...... 1-22 1.3.6 Sediment ...... 1-23 1.4 Baseline Risk Assessment ...... 1-24 1.4.1 Human Health Assessment ...... 1-24 1.4.2 Environmental Assessment ...... 1-28 2.0 REMEDIAL ACTION OBJECTIVES ...... 2-1 2.1 Exposure Pathways, Media and Contaminants to be Addressed ...... 2-1 2.2 Applicable or Relevant and Appropriate Requirements (ARARs) ...... 2-3 2.2.1 Consideration of ARARs ...... 2-3 2.2.2 Potentially Applicable ARARs ...... 2-5 2.2.3 Remediation Goals ...... 2-11 2.3 Remedial Action Objectives ...... 2-11 2.3.1 Source Control Objectives ...... 2-20 2.3.2 Management of Migration Objectives ..... 2-20

3.0 IDENTIFICATION AND SCREENING OF REMEDIAL TECHNOLOGIES ... 3-1 3.1 General Response Actions ...... 3-1 3.1.1 No Action with Institutional Controls ..... 3-1 3.1.2 Containment ...... 3-2 3.1.3 Removal ...... 3-2 3.1.4 Treatment ...... 3-2 3.1.5 Disposal ...... 3-2 3.2 Remedial Technology Screening ...... 3-2 3.3 Identification and Screening of Groundwater Remedial Technologies ...... 3-4 3.3.1 Minimal Action Technologies - Groundwater . . 3-6 > 3.3.2 Containment Technologies - Groundwater . . . 3-7 t? 3.3.3 Removal Technologies - Groundwater ..... 3-8 3.3.4 Treatment Technologies - Groundwater .... 3-9 § 3.3.5 Disposal/Discharge Technologies - Groundwater 3-19 •-

3 VO *> u> AOP-35-H j TABLE OF CONTENTS (Continued) Page No. 3.4 Identification and Screening of Soil Remedial Technologies ...... 3-23 3.4.1 Minimal Action Technologies - Soil ..... 3-24 3.4.2 Containment Technologies - Soil ...... 3-27 3.4.3 Removal Technologies - Soil ...... 3-29 3.4.4 Treatment Technologies - Soil ...... 3-30 3.4.5 Disposal Technologies - Soil ...... 3-38 3.5 Summary of Remedial Technology Screening ...... 3-40

4.0 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES .... 4-1 4.1 Alternative Development and Evaluation Criteria ... 4-1 4.1.1 Alternative Development Criteria ...... 4-2 4.1.2 Alternative Evaluation Criteria ...... 4-2 4.2 Source Control (Soil) Remedial Alternatives ..... 4-3 4.2.1 SC-1: No Action ...... 4-5 4.2.2 SC-2: Capping ...... 4-6 4.2.3 SC-3: Soil Flushing ...... 4-9 4.2.4 SC-4: Soil Vapor Extraction ...... 4-17 4.2.5 SC-5: Soil Vapor Extraction and Soil Flushing ...... 4-21 4.2.6 SC-6: Excavation and Low Temperature Thermal Desorptlon ...... 4-23 4.2.7 SC-7: Excavation and Off site Landfill . . . 4-28 4.2.8 Summary of Source Control Alternative Screening ...... 4-29 4.3 Management of Migration (Groundwater) Remedial Alternatives ...... 4-29 4.3.1 MM-1: No Action with Institutional Controls ...... 4-31 4.3.2 MM-2: Extraction and Treatment: Biological /Air Stripping/ Carbon Adsorption ...... 4-32 4.3.3 MM-3: Extraction and Treatment: Steam Stripping/Carbon Adsorption ..... 4-41 4.3.4 NM-4: Extraction and Treatment: PACT . . . 4-45 4.3.5 MM- 5: Extraction and Treatment: UV Oxidation ...... 4-47 4.3.6 Summary of Management of Migration Alternative Screening ...... 4-50 4.4 Extraction System Alternatives ...... 4-50 4.4.1 Option A ...... 4-51 4.4.2 Option B ...... 4-54 4.4.3 Natural Attenuation ...... 4-54 4.4.4 Natural Soil Flushing ...... 4-56 o o

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AOP-35-H 11 TABLE OF CONTENTS (Continued) Pace No. 5.0 DETAILED EVALUATION OF REMEDIAL ALTERNATIVES 5.1 Overview of Evaluation Criteria ...... 5-1 5.1.1 Threshold Criteria ...... 5-1 5.1.2 Primary Balancing Criteria ...... 5-2 5.1.3 Modifying Criteria ...... 5-2 5.2 Description of Evaluation Criteria ...... 5-2 5.2.1 Overall Protection of Human Health and Environment ...... 5-2 5.2.2 Compliance with ARARs ...... 5-2 5.2.3 Short Term Effectiveness ...... 5-3 5.2.4 Long Term Effectiveness ...... 5-4 5.2.5 Reduction of Toxicity, Mobility or Volume . . 5-4 5.2.6 Implementability ...... 5-5 5.2.7 Cost ...... 5-5 5.2.8 State Acceptance ...... "...... 5-8 5.2.9 Community Acceptance ...... 5-8 5.3 Detailed Evaluation of Source Control Alternatives . 5-8 5.3.1 SC-1: No Action ...... 5-8 5.3.2 SC-2: Capping ...... 5-10 5.3.3 SC-3: Soil Flushing ...... 5-13 5.3.4 SC-4: Soil Vapor Extraction ...... 5-17 5.3.5 SC-5: Soil Vapor Extraction and Soil Flushing ...... 5-21 5.3.6 SC-6: Excavation and Low Temperature .... Thermal Desorption ...... 5-25 5.3.7 Summary of Source Control Alternative Costs . 5-32 5.4 Detailed Evaluation of Management of Migration Alternatives ...... 5-32 5.4.1 MM-1: No Action ...... 5-32 5.4.2 MM-2: Extraction Treat - Biological/ A1r Stripping/Carbon Adsorption . . . 5-36 5.4.3 MM-4: Extract and Treat - Powdered Activated Carbon Treatment (PACT) . . 5-40 5.4.4 MM-5: Extract and Treat - UV Oxidation . . . 5-47 5.4.5 Summary of Management of Migration Alternative Costs ...... 5-54 5.5 Comparison Among Alternatives ...... 5-54 5.5.1 Source Control Alternatives ...... 5-54 5.5.2 Management of Migration Alternatives .... 5-62 5.6 Site Remediation Alternatives ...... 5-63 o TJ

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AOP-35-H 111 TABLE OF CONTENTS (Continued) LIST OF TABLES Tables Page No. 1-1 Above-Ground Storage Tank Information 1-6 1-2 Organic Chemical Sunmary for Surface and Subsurface Soil Samples 1-16 1-3 Summary of Inorganic Substances In Groundwater Samples 1-18 1-4 Organic Chemical Summary for Monitoring Well Samples 1-20 1-5 Summary of Chemicals of Potential Concern 1-25

2-1 Base Line Risks for Exposure Pathways 2-2 2-2 Potential Chemical - Specific ARARs 2-6 2-3 Organic Chemical Summary and ARARs for Groundwater 2-8 2-4 Potential Location - Specific ARARs . 2-9 2-5 Potential Action - Specific ARARs 2-12 2-6 Soil Remediation Goals 2-19

3-1 Identification of Potential Groundwater Remediation Technologies 3-5 3-2 Identification of Potential Soil Remediation Technologies 3-25 4-1 Chemical Properties of Selected Soil Contaminants 4-15 4-2 Chemical Properties of Selected Groundwater Contaminants 4-39 5-1 Cost Estimate Summary - SC-1 5-11 5-2 Cost Estimate Summary - SC-2 5-14 5-3 Cost Estimate Summary - SC-3 5-18 5-4 Cost Estimate Summary - SC-4 5-22 5-5 Cost Estimate Summary - SC-5 5-26 5-6 Cost Estimate Summary - SC-6 5-30 5-7 Cost Estimate Summary - Source Control Alternatives 5-33 5-8 Cost Estimate Summary - MM-1 5-37 5-9 Cost Estimate Summary - MM-2 5-41 5-10 Cost EstlMte Summary - MM-4 5-48 5-11 Cost EstlMte Summary - MM- 5 5-55 5-12 Cost EstlMte Summary - Management of Migration Alternative 5-59 5-13 Present North Cost Summary - 5X Discount 5-65 5-14 Present Worth Cost Summary - 10X Discount 5-66

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AOP-35-H 1V TABLE OF CONTENTS (Continued) LIST OF FIGURES Figures Page No. 1-1 Site Location 1-3 1-2 Study Area 1-4 1-3 Site Layout 1-5 1-4 Geologic Cross-Sections 1-9 1-5 Shallow Piezometric Contour Hap 1-12 1-6 TCE Isoconcentration Contour Hap 1-14 1-7 1-17

3-1 Groundwater Technology Screening 3-41 3-2 Soil Technology Screening 3-42

4-1 Contaminated Soil Area and Volume Estimates 4-4 4-2 SC-2: Capping Alternative 4-7 4-3 Asphalt Cap Cross-Section 4-8 4-4 SC-3: Soil Flushing 4-11 4-5 Proposed Leach Field 4-12 4-6 SC-3: Soil Flushing 4-13 4-7 SC-4: Soil Vapor Extraction 4-18 4-8 Soil Vapor Extraction Process Diagram 4-19 4-9 Low Temperature Thermal Desorption Process 4-24 4-10 SC-6: Excavation and Thermal Treatment 4-26 4-11 MM-2: Biological/Air/Carbon 4-33 4-12 Biological Treatment 4-35 4-13 Air Stripping 4-36 4-14 Carbon Adsorption 4-37 4-15 HM-3: Steam Stripping/Carbon 4-42 4-16 HH-4: PACT 4-46 4-17 HH-5: UV Oxidation Treatment 4-48 4-18 Groundwater Extraction System Capture Zones 4-52 4-19 Groundwater Extraction System Option A - (4 Pumping Wells) - 72 GPH 4-53 4-20 Groundwater Extraction System Option B - (7 Pumping Wells) - 126 GPH 4-55 APPENDICES A State of New Jersey Applicable or Relevant and Appropriate Requirements B Comparison of the Performance of RCRA and Lined- Asphalt Caps > 13 C Recharge Basin Hounding and Estimated Soil Flushing Times o=> D Groundwater Hodeling o E Alternative Cost Calculations £

AOP-35-H Section 1

AOP 001 0948 A. 0. Polymer Site Public Review Feasibility Study April 1991

1.0 INTRODUCTION The A.O. Polymer site is an active chemical facility located in Sparta Township, Sussex County, New Jersey. Upon the discovery of groundwater contamination near the site in 1978, the New Jersey Department of Environmental Protection (NJDEP) contracted ICF Technology Incorporated (ICF) to perform a Remedial Investigation and Feasibility Study (RI/FS) under the NJDEP X-312 Term Contract Program to satisfy the state's Management Plan for Hazardous Waste Site Cleanups. The RI/FS was Federally funded under a cooperative agreement between NJDEP and the U. S. Environmental Protection Agency. ICF completed the Remedial Investigation (RI) in June of 1990. The RI revealed that residual soil contamination from a former disposal lagoon area on the A.O. Polymer property is the major source of the groundwater contamination in the vicinity of the site. Using the information in the RI and the baseline Risk Assessment (RA), ICF prepared this draft Feasibility Study (FS) Report to evaluate options for site remediation.

1.1 PURPOSE AND ORGANIZATION OF REPORT The purpose of the Feasibility Study is to develop and evaluate alternatives to address the contamination issues at the A.O. Polymer site. The report was developed within the guidelines of CERCLA and SARA and was prepared with the intent of providing the NJDEP with sufficient data to select an appropriate alternative for remediation of the site. This FS is comprised of four sections: Section 1.0 - Provides site background Information, site history, a discussion of the nature and extent of contamination, and the results of the baseline Risk Assessment. Section 2.0 - Presents applicable or relevant and appropriate regulations, requirements to be considered (ARARs and TBCs) and remedial action objectives. Section 3.0 - General response actions are identified and potential remedial technologies for site remediation are identified and screened. Screening criteria include effectiveness, implementability and cost. Section 4.0 - Presents Source Control (SC) and Management of Migration (MM) remedial alternatives which have been developed by combining feasible remedial technologies. Remedial alternatives are evaluated based on their effectiveness, implementability, and cost (preliminary cost estimates). Section 5.0 - Presents detailed descriptions of all alternatives which passed the screening process of Section 4.0. Also, a detailed evaluation and comparison of each remedial alternative is given with respect to nine criteria: AOP-35-H 1-1 A. 0. Polymer Site Public Review Feasibility Study April 1991

1) Overall protection of human health and the environment 2) Compliance with ARARs 3) Long-term effectiveness and permanence 4) Reduction of toxldty, mobility, or volume through treatment 5) Short-term effectiveness 6) Implementability 7) Cost 8) State acceptance 9) Community acceptance

1.2 SITE BACKGROUND INFORMATION 1.2.1 Site Description The A. 0. Polymer site (Figure 1-1) is located at*44 Station Road in the Township of Sparta in Sussex County, New Jersey. The site occupies about four acres near Sparta Station bounded on the north and east by Station Park, on the southeast by Station Road, and on the south and west by New York, Susquehanna and Western (NYS&W) railroad tracks. Several small businesses and three homes are located near the site on Station Road. Sparta High School lies one-half mile to the north-northeast and a private gun club 1s located 500 feet northwest of the site. The Wall kill River passes about 200 feet to the southeast of the site. A map of the site and Its surroundings is shown in Figure 1-2. The A. 0. Polymer complex has been the site of specialty polymer resin manufacturing for over 30 years. The present layout of the A. 0. Polymer Complex is shown in Figure 1-3. Significant site features include the site office and laboratory facilities, the main reactor building, assorted storage buildings, and a non-contact water cooling pond. An old NYS&W railroad structure is located to the north of the plant. The yard surrounding the main buildings contains approximately 20 storage tanks of various sizes, numerous drums and old equipment. The office, reactor building, and lab are currently used by A. 0. Polymer 1n their manufacturing processes. The reactor building reportedly contains two reactor units for the manufacture of urethane and ketone resins, two formaldehyde storage tanks and other assorted storage tanks and vessels. Table 1-1 presents available Information on above ground exterior storage tanks at the A. 0. Polymer Site. In addition to these tanks, 1t 1s reported by State enforcement Inspectors that a 10,000 gallon 12 Fuel 011 storage tank and a plant waste water septic tank are also present onslte.

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AOP-35-H 1-2 N

ALLKILL RIVER

0

BASEMAP TAKEN FROM USGS 7.5 MINUTE TOPOGRAPHIC SERIES NEWTON EAST, NJ | FIGURE I-I A.O. POLYMER SITE SITE LOCATION FEASIBILITY STUDY ICF TECHNOLOGY INCORPORATED DATE; JUNE 10, 1987 DR.: S.M.METZ PITTSBURGH, PA SCALE: 2000' 34090-001-04 1-3 v..__,/ ' y / J

X^JH Ct«

C-AtffAl DATA WSULKILL RIVEft

A.O. POLYMER SITE SPARTA. NEW JERSEY ICF/SRW ASSOCIATES PITTSBURGH, PA

1-4 STATION PARK

DRUM AND MACHINERY

V SPARTA GUN CLUB

RAILROAD BUILDING

STOAA6E

LABORATORY

OFFICE

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I FIGURE 1-3 S A. 0. POLYMER SITE SITE LAYOUT FEASIBILfTY STUDY ICF TECHNOLOGY INCORPORATED DATE: JUNE 10,1987 DR.: S. M. METZ PITTSBURGH, PA SCALE: IM*IOO' 34090-001-04 1-5 A. 0. Polymer Site Public Review Feasibility Study April 1991

TABLE 1-1 ABOVE GROUND STORAGE TANK INFORMATION A. 0. POLYMER SITE* Tank Number1 Description Contents/Use Known To Be In Use 400 g reactor/mixer polyol storage and polyol premix 2 1200 g tank polyol and TDI mixing 3 1200 g tank polyester manufacture 4 4500 g reactor/mixer polyol storage; premix of butyl methyl methylmethacrylate and acrylic acid 5 4000 g tank formaldehyde storage 6 3000 g tank formaldehyde storage 7 5000 g reactor final processing of all product

Status Uncertain 8 3000 g tank storage of MEK3 or cyclohexanol (empty) 9 3000 g tank empty 10 3000 g tank empty 11 3000 g tank empty 19 - 20 3000 g storage tank polyol storage 21 4000 g storage tank polyol storage 22 1100 g storage tank polyol storage

Known To Be Inactive 12 - 15 4000 g mixing tanks 3X caustic solution in water 16 - 18 1000 g tapered tanks "evil smelling fluid" 23 - 25 horizontal storage tanks unknown 26 16000 g vertical storage tank unknown 27 20000 g vertical storage tank unknown Unless stated otherwise all tanks described herein are above-ground tanks. 1 See Figure 1-3 2 Toluene diisocyanate 3 Methyl ethyl ketone Source: Inspection Reports from NJDEP Files - June 4, 1978, through o October 3,1981. TJ

o ^0 tn AOP-35-H 1-6 A. 0. Polymer Site Public Review Feasibility Study April 1991

A 5,000 square feet pond 1s present in the southeast quadrant of the property. This pond has no surface outlet, and is lined with concrete. It is reportedly used for the recirculation of non-contact cooling water and is periodically replenished by water from an onsite production well. An undetermined quantity of drums, two small out-buildings and various process machines exist onsite. Observations indicated that the vast majority of the drums contained finished resin products. 1.2.2 Site History Mohawk Industries began operations at the site in the early 1960's. Mohawk was involved in production of various resins using polymerization processes. According to NJDEP records, Mohawk also engaged 1n the reclamation of electronic component cleaning fluids containing various freon compounds in alcohol, and the distillation of a substance known as balata, a chewing gum additive. In 1978 the facility was purchased by A. 0. Polymer Corporation. Along with the property, A. 0. Polymer purchased the rights to manufacture resin products previously produced by Mohawk. The most recent state records available to ICF indicated that A. 0. Polymer still utilizes the same processing machinery, storage vessels and laboratories used by Mohawk. In December 1978, NJDEP Inspectors and Sparta Health Department officials discovered volatile organic chemical contamination in three domestic wells along Station Road. In June 1979, the owners of the three affected wells filed damage claims with the State Hazardous Spill Fund, and in January of the following year, the District No. 1 Water Line was connected to these homes. This remedial action was partially financed by funds from the Hazardous Spill Fund. In conjunction with the groundwater Investigation, the Division of Waste Management (DWM) began Investigating reports of drum stockpiling. On September 25, 1978, A. 0. Polymer Corporation was cited by NJDEP officials for violations concerning storage of hazardous wastes. This notice, however, was rescinded because wastes in question reportedly belonged to Mohawk Industries. Further DWM Investigations Implicated waste disposal and storage practices used by Mohawk Industries 1n the groundwater contamination problem. According to NJDEP files, waste handling practices under Mohawk included improper storage of over 800 decomposing drums, and burial of crushed drums, chemical waste, and sludges in several small unlined lagoons located north of the site (see Figure 1-3). In 1980 and 1981, partial cleanup of the site was Initiated by NJDEP with funding available through the State Hazardous Spill Fund. This cleanup removed about 949 drums or their contents and 1820 cubic yards of contaminated soils. Concern for the contamination of the Allentown aquifer and other domestic well water supplies, including the Sparta High School located one-half mile to the north, spurred additional investigations by NJDEP. After a site inspection in AOP-35-H 7 ~' A. 0. Polymer Site Public Review Feasibility Study April 1991

November 1981, A. 0. Polymer was cited for failing to have a state discharge permit for process water discharged to the cooling lagoon. This action was dropped when A. 0. Polymer insisted that the lagoon was lined with PVC and received non-contact process water that contained no waste materials. In January 1982 the Division of Water Resources Installed 11 monitoring wells on and adjacent to the site to determine the extent of groundwater contamination. Sampling revealed that contamination had reached the Allentown formation, and could be found in monitoring wells in Station Park 300 yards to the northeast of the site. Inspections of the A. 0. Polymer operation continued through 1983. In May of 1983, it was discovered that laboratory sinks and other plant waste water was discharged to septic tank systems. In 1984, investigation of the site was remanded to the Division of Hazardous Site Mitigation. In December, 1987, the NJDEP initiated a RI/FS of the area in vicinity of the groundwater contamination with ICF acting as the consulting engineers. The RI report was finalized by ICF in June of 1990. 1.2.3 Environmental Setting Topography Sussex County is located in the Valley and Ridge physiographic province. This area is characterized by linear valleys and ridges, predominantly trending northeast and southwest. This linearity 1s the result of two major tectonic upheavals which severely deformed the entire region. As a result, bedrock is highly deformed by both folding and faulting. Fracture trace analysis of the area surrounding Sparta revealed a major linear trend of N 40 E. The A. 0. Polymer Site is located in the southwestern end of the Wallkill River Valley on the western flank of a small hill which rises to an elevation of approximately 700 feet. The Wallkill River Valley in the vicinity of the site is broad and level, with an average elevation between 600 and 640 feet. The Sparta Mountains to the east of the site rise to an elevation of over 1,200 feet. To the west, the Wallkill Valley is bordered by rugged hills which range in elevation from 900 to 1,100 feet. Geology The region 1s underlain by the various rock types Illustrated in Figure 1-4. The Wallkill River valley forms a rift-like feature separating the Pre- Cambrian crystalline rocks lying east and west of the valley. The valley floor is underlain by a combination of the Cambrian Hardystone Quartzite and ^ the Allentown member of the Cambro-Ordivician Kittatinny Formation. The o Allentown member is a thick, rhythmically bedded dolomite which dips to the

AOP-35-H 10 WALLKILL RIVER A. 0. POLYMER SITE

NW SE

LEGEND

KITTATINNY LIMESTONE

a Ch HARDYSTON SANDSTONE

t! FRANKLIN LIMESTONE »

R^/TTl '«" LOSEE GNEISS

.V* \ bgn BYRAM GNEISS

POCHUCK GNEISS

Ln

REFERENCE^ GEOLOGIC MAP OF NEW JERSEY

I FIGURE 1-4 A. 0. POLYMER SITE GEOLOGIC CROSS-SECTION IN FEASIBILITY STUDY VICINITY OF A.O. POLYMER SITE ICF TECHNOLOGY INCORPORATED DATE: JUNE 10,1987 DR.: PITTSBURGH, PA SCALE- f « 7000' 34090-001-04 1-9 A. 0. Polymer Site Public Review Feasibility Study April 1991 southeast 1n near vertical orientation. The Allentown formation 1s juxtaposed with the Precurt>r1an rocks to the west by an ancient fracture zone known as the "zero fault". All bedrock encountered during the remedial investigation was classified as dolomite suggesting that the Allentown member 1s present beneath the entire study area. Borehole and seismic refraction data infer a bedrock ridge extending from the A.O. Polymer site northeastward beneath the central part of Station Park and a burled bedrock valley in the vicinity of the Wallkill River. The zero fault appears as a band of highly fractured rock approximately 300-400 feet wide trending southwest-northeast through the study area approximately 500-600 feet northwest of the A.O. Polymer facility. The orientation of these features is approximately N 40 E paralleling the regional trend. Depth to bedrock ranged from 15 to 123 feet. Near the zero fault, bedrock 1s characterized by highly weathered and broken angular rock fragments separated by wide, sand, gravel and clay-filled fractures oriented at various angles. In the vicinity of the Wallkill river, bedrock is believed to contain some significant solution cavities filled with sand and gravel. Between the fault zone and the Wallkill River, bedrock is more sound, however weathered zones and water bearing fractures occur often. Overburden in the study area consists of silts, sands, gravels and boulders believed to be a Wisconsin glacial outwash deposit. This unit typically grades from silt and coarse sand near the surface to fine to coarse sand and gravel with boulders at depth. A transitional zone between the overburden and competent bedrock consisting of weathered dolomite, boulders, gravel sand and clay was encountered in several borings. The thickness of these deposits ranges from less than 15 feet near the bedrock structural high to over 125 feet near the Wallkill River. Surface Water Hydrology The A.O. Polymer facility is situated In an upland area which drains to the Wallkill River and an unnamed tributary to the Wallkill River located northwest of the site. The Wallkill River originates about 1.2 miles southwest of the site at a privately owned and regulated 700 acre Impoundment known as Lake Mohawk. From Lake Mohawk, the river flows northeast through Station Park passing about 200 feet southeast of the A.O.Polymer site. Five miles north of Sparta, the Wallkill River enters Franklin Pond and then joins Roundout Creek which flows into the Hudson River in New York State. A.O. Polymer appears to lie on a surface water divide separating the Wallkill River and Its unnamed tributary. This tributary originates near the NYS&W railroad tracks north of A.O. Polymer and flows along the northwestern border of Station Park, past Sparta High school and finally joins the Hal kill River about one mile northeast of the site. In the vicinity of the site, The Wallkill River is a relatively slow moving meandering stream. The water surface elevation of the stream 1s typically about 608 feet MSL upstream the site and about 589 feet MSL near West Mountain Road. The average discharge upstream of Station park during Phase II was about 15 cubic feet per second. The discharge downstream of the park during the same period was about 25 cfs. This Increase In flow suggests that the Wallkill River receives groundwater discharge from the underlying aquifers. AOP-35-H 1-10 A. 0. Polymer Site Public Review Feasibility Study April 1991

The seven day low flow at the 10 year recurrence Interval at the closest stream gaging station located In Franklin, NJ is about 0.06 cfs. Groundwater Hydrology Groundwater is present in the both the overburden and bedrock. Within the overburden it resides in Intergranular pore spaces and within the bedrock it resides mostly in fractures. Because of the Inherent permeability of the overburden and the ready avenues of pressure dissipation which numerous bedrock fractures and solution features provide, it Is believed that the overburden and bedrock are hydraulically connected. Consequently, the bedrock and saturated portions of the overburden are expected to act as a single three dimensional groundwater flow system. This system 1s under water table conditions and the difference in water levels between overburden and bedrock wells in clustered pairs indicates the magnitude of the vertical flow component. Water levels and hydraulic conductivity data generally support the Idea that the bedrock and are hydraulically connected. Upward vertical gradients are noted primarily in well nests near prospective discharge areas. These occur in the swampy area surrounding the unnamed tributary and near both banks of the Wallkill River. Downward gradients occur primarily in upland areas where recharge 1s expected to occur. The piezometric map for bedrock wells indicates a flow regime that is, in most respects, a subdued version of the shallow flow regime portrayed by overburden wells. This similarity suggests that the same recharge and discharge conditions govern flow in both the overburden and bedrock. While performing slug tests in several overburden wells, it was noted that water level changes were induced in companion bedrock wells. These observations provide further evidence that the bedrock and overburden units are hydraulically connected. The general flow regime in the study area 1s portrayed by the piezometric contour map shown in Figure 1-5. This contour map Includes hydraulic heads for all wells screened within 30 feet of the water table. The shallow piezometric contour imp suggests that the A.O. Polymer Site 1s situated atop a groundwater mound. The reason for the groundwater mound 1s unknown but may be due to a combination of several factors Including leakage of water from process pipes or septic tanks, Inflow of groundwater from the hills to the southwest, or enhanced recharge caused by the poor surface drainage that exists at the complex. Flow appears to diverge from a groundwater divide that strikes northward fro* the plant towards monitoring well AOP-106. West of this divide groundwater flows to the northwest towards the unnamed tributary of the Wallkill River. East of the divide, flow converges towards the Wallkill River. It 1s suspected that most of the flow directed to the east discharges to the Wallkill River.

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c l£» Ul AOP-35-H AOP-IO4 MOHITOMINt WCLL » CENT IFICiT ION NUMBER •W.4T WkTtM LEVEL ELEVATION, JANUARY 12, IMO ELEVATION CONTOUR CONTOUD INTERVAL- I FEET SURFACE WATER tAUOMO STATION 1-12 A. 0. Polymer Site Public Review Feasibility Study April 1991

Hydraulic conductivities of the overburden ranged from 0.22 ft/day to 26.63 ft/day with a representative average of about 13 ft/day. The hydraulic conductivities in the bedrock were within the same order of magnitude, ranging from 0.43 ft/day to 56 ft/day with an average of about 28 ft/day. Based upon these hydraulic conductivity values, hydraulic gradients, and an assumed porosity of 25 %, an interstitial flow velocity of about 0.9 ft/day was calculated for flow occurring towards the Wallkill River. 1.3 NATURE AND EXTENT OF CONTAMINATION 1.3.1 Source The remedial investigation provided source characterization through the sampling of monitoring wells on and around the A.O. Polymer property and through the use of both electromagnetic induction (EM-31) and ground penetrating radar (GPR). The pattern of groundwater contamination indicates an old source area corresponding with disposal lagoons remediated in 1980-81 by NJDEP as the primary source. The approximate location of the former disposal lagoons is shown on Figure 1-6. A second and perhaps more recent source of ketones may exist to the northwest of AOP-3 but this source has not been identified. The trend of the contamination associated with the ketones indicates a small one- time release whose source may never be established. A more complete discussion of Ketone contamination may be found in Section 1.3.3, Organic Data. 1.3.2 Soil Inorganic Data Phase I soil samples were analyzed for substances on the EPA Inorganic Target Analyte List (TAL). Twenty of the 24 inorganic substances on the TAL were detected in soil samples. In itself, this observation does not indicate a contamination problem because trace metals always occur naturally in soils at some "background" level related to the chemical composition of the rock and minerals from which the soils were formed. To distinguish whether the metal concentrations detected in onsite soil samples were natural or related to anthropogenic contamination sources, onsite soil concentrations were compared to concentrations in three background samples collected from Station Park. With the exception of zinc, magnesium, and calcium, this analysis revealed no significant difference in the concentrations of metals between background and ^ onsite soils. Although zinc, magnesium and calcium concentrations are higher o onsite than in background areas, these differences appear to have no relationship to historical waste disposal practices. This indicates that 0 metals contamination in soils 1s not of significance at the A. 0. Polymer 2 site. o i-D I—1 AOP-35-H i 1-3 f v mP-7 „. If "- - " lL ,»^ •'"- ' ,-N • -V- --•**>— r ; .- _-\) //- -__j5r-=ry^- _~ \ LOCATION OF FORMER DISPOSAL LAGOONS

A EAST SEEP ~ \ ™ ' L-, , | y , -. y ( )M '-""' .;£?*** -^ _ , ~---~="\l> , <

AcUx/ ~:x MONITORING WELL ' " ^ ' -• ^X.^'-. .» PIEZOMETER \—\ Q> \ NN-k . '

9IO CONTAMINANT CONCENTRATION IN uj/l f FIGURE 1-6

NO CONTAMINANT NOT DETECTED A 0 POLYMER SITE ISOCONCENTRATION CONTOUR MAP NS WELL NOT SAMPLED SPARTA, NEW JERSEY CONTOUR Of EQUAL CONTAMINANT ICF TECHNOLOGY INCORPORATED DATE MAY 23, 1990 OR 'K. GARDNER CONCENTRATION IN SROuNDWATEK PITTSBURGH , PA SCALE l"« 300' A. 0. Polymer Site Public Review Feasibility Study April 1991

Organic Data Surface and subsurface soils within the A. 0. Polymer complex are contaminated with polycyclic aromatic hydrocarbons (PAHs), halogenated aliphatic hydrocarbons (HAHs) and several other organic chemicals. A summary of the organic contaminants found in soils is presented in Table 1-2. Sample locations and a summary results are shown on Figure 1-7. PAH contamination is a localized surface phenomena that appears to be focused around the south end of the old NYS&W Railroad building. This contamination may be related to the handling of fuel oil at facilities on railroad property. It is not likely that the PAH contamination is related to past waste disposal activities at the site or to present operations. HAH compounds were detected primarily in test borings located in the former lagoon disposal areas in the north end of the A. 0. Polymer Site. The HAH contamination consisted primarily of common chlorinated industrial solvents such as tetrachloroethene (PCE), trichloroethene (TCE) and 1,1,1,-trichloroethane (1,1,1-TCA). Maximum levels of these contaminants in soils are as follows: TCE 27,000 ug/kg PCE 2,600 ug/kg 1,1,1-TCA 32,000 ug/kg HAH contamination was primarily a subsurface phenomenon with the highest concentrations being detected in samples from 10 to 12 feet in depth. This indicates that the contamination is the residual material left after NJOEP had excavated and backfilled the lagoon disposal sites. Strongly associated with HAH contamination were a number of monocyclic aromatic hydrocarbons (MAHs) such as toluene and xylene, phenolic compounds, and phthalate esters.

1.3.3 Groundwater Inorganic Data Only Phase I monitoring well samples were analyzed for TAL Inorganics. Nineteen of the 24 Inorganic target analytes were detected in the monitoring well samples. Inorganic results are summarized in Table 1-3. Inorganic concentrations in monitoring wells were generally unremarkable. Iron, aluminua, magnesium, calcium, sodium, and potassium are major cations generally found in high concentrations in natural groundwater. With the exception of Iron, few detections in the A. 0. Polymer site monitoring wells, exceeded the range of concentrations reported as normal for the Delaware River Basin in regional literature. This suggests that overall quality of groundwater in the study area with respect to inorganic contaminants 1s within normal limits.

'•£>

AOP-35-H 1-15 TABLE 1-2 Organic Chemical Sunnary For Surface and Subsurface Soil Samples* A.O. Polymer Feasibility Study

Frequency Minimum Maximum Location of Other of Detected Detected Average Maximum Locations Detection Value Value Value Concentration Detected CLASS TARGET COMPOUND (1) (ug/kg) (ug/kg) (ug/kg)

nnkWWEnn I b V m» • r nn I t v n i VK^^nnwn^ V TETRACHLOROETHENE 5 2.6 2600 931.28 TB-11 TB-12 V 1,1,1-TRICHLOROETHANE 5 7.5 32000 7786.90 TB-11 TB-1, 12 V TRICHLOROETHENE 4 14 27000 7603.50 TB-12 TB-11 V TRANS-1,2-DICHLOROETHENE 2 2.7 5100 2551.35 TB-11 T8-12 V 1,1,2-TRICHLOROETHANE 1 500 TB-12 V TR I CHLOROFLUOROMETHANE 1 53000 TB-11 --MONOCYCLIC AROMATIC HYDROCARBONS----- V TOLUENE 6 2 61000 14105.17 TB-11 TB-1.12.AOP-113 V XYLENES (TOTAL) 5 51 34000 12732.20 TB-12 TB-1, 11 V ETHYLBENZENE 5 35 15000 5666.20 TB-11 TB-1. 12 V CHLOROBENZENE 2 970 1500 1235.00 TB-12 TB-11

V 2-BUTANONE 4 3.2 13 6.85 TB-11 TB-3,4,8 ----POLYCYCL1C AROMATIC HYDROCARBONS- -- B PHENANTHRENE 8 95 5800 2229.38 TB-1 SS-048,T8-7,9,12 B 2-METHYLNAPHTHALENE 7 66 9600 2476.57 TB-1 TB-9, 11. 12 8 CHRYSENE 6 64 560 277.33 TB-7 SS-048, TB-2, 9, 12 8 FLUORENE 5 37 4200 2204.40 TB-1 TB-12 8 PYRENE 5 130 740 422.00 TB-1 SS-048, TB-2, 7,9 8 NAPHTHALENE 5 35 16000 3351.00 TB-1 TB-9, 11, 12 B ACENAPHTHENE 4 46 2600 1861.50 TB-1 TB-2 B FLUORANTHENE 4 57 960 361.75 TB-7 SS-048, TB-2, 9 B BENZO(K)FLUORAMTHENE 4 64 880 363.50 TB-7 SS-048, TB-2, 9 B BENZO(B)FLUORANTHENE 4 64 880 366.00 TB-7 SS-048, TB-2, 9 B BENZO( A) ANTHRACENE 3 110 590 306.67 TB-7 SS-048, TB-9 B BENZO(A)PYRENE 3 100 520 290.00 TB-7 SS-048, TB-9 B BENZO(G,H.I)PERYLENE 2 150 290 220.00 TB-7 SS-048 B INDENO(1,2.3-CD)PYRENE 2 120 260 190.00 TB-7 SS-048 B DIBENZ(A,H)ANTHRACENE 1 120 TB-7 ----PHTHALATE ESTERS------B BIS(2-ETHYLHEXYL)PHTHALATE 6 75 41000 8992.50 TB-5 TB-11, 12, 14 B DI-N-BUTYLPHTHALATE 4 38 260 98.75 TB-12 TB-5, 15 B BUTYLBENZYLPHTHALATE 3 77 290 150.00 SS-048 TB-15 . . - -PHENOL I C COMPOUNDS------A 4-METHYLPHENOL 3 96 14000 4945.33 TB-11 TB-12 A PHENOL 2 150 2600 1375.00 TB-11 TB-12 A 2-METHYLPHENOL 1 1700 TB-11 A 2,4-DIMETHYLPHENOL 1 760 TB-11 --- -MISCELANEOUS COJ1POUMP3 ------B DIBENZOFURAN 3 1900 4600 3400.00 TB-1 B N - N I TROSOD 1 PHEN YLAM I NE ( 1 ) 2 46 120 83.00 TB-5 TB-15 B 1,2-DICHLOROBEHZEHE 1 1100 TB-12 B 2,4-DINITROTOLUEHC 1 300 TB-2 B 2,6-DINlTROTOLUENC 1 64 TB-2 V VINYL ACETATE 1 1.2 TB-1 A BENZOIC ACID 1 1300 TB-11 P BETA-BHC 1 a TB-1 P HEPTACHLOR EPOXIDE 1 58 SS-048

NOTES: V Volatile organic compound A Acid extractable compound B Base/Hue tra I Compound 0 P PCB/Pesticides ~ 1 No. detections in 43 Samples Phase II samples analyzed for V only o 0 •Source: A. 0. Polymer Site Remedial Investigation, ICF Technology, July 1990 h-" o 10

1-16 N

LEGEND

PAH TOTAL POLYCYCLIC AROMATIC HYDROCARBON

HAH TOTAL HALOGENATED ALIPHATIC HYDROCARBON

MAH TOTAL MONOCYCLIC AROMATIC HYDROCARBON

KET TOTAL KETONES

PE TOTAL PHTHALATE ESTERS

PHL TOTAL PHENOLS

* MIS TOTAL MISCELLANEOUS COMPOUNDS

NO NONE DETECTED

R DATA REJECTED DUE TO QUALITY COHTTROC DEFICIENCIES

NOTE

CONCENTRATIONS IN ug/dg

o "0

[FIGURE 1^ AO POLYMER SITE OCCURRENCE OF SPARTA, NEW JERSEY ORGANIC CONTAMINANTS IN SOIL ICFTKCIINOI.OCl INCORI'OR VTKD DATE JUNE 29,1988 OR K. GARDNER PIT T SBUROl, PA SCALE !"• 100' 3409O-OO3-I2 1-17 TABLE 1-3 Suanary of Inorganic Substances in Ground Water Samples* A. 0. Polymer Site Feasibility Study

Detections Locations Frequency MiniMUM Max i MUM Exceeding Where Standard/ of Detected Detected Average Standard/ Standard/ Criteria Detection Value Value Value Criteria Criteria Exceeded ANALYTE (ug/l) (ug/l) (ug/l) (ug/l) ARSENIC 18 4 66 15.5750(1) 1 AOP-3 BERYLLIUM 6 1.1 1.9 1.3.0039(35 ) 6 AOP-2. 101-105 CHROMIUM 10 7.5 93 24.1550(1) 2 AOP- 102. 103 COPPER 19 8.5 89 28.02 1300(2) 0 LEAD 15 2.3 36 13.8350(1) 0 NICKEL 6 22 83 34.00 15.4(3) 6 AOP- 101 -103. 105, 108, 109 SILVER 2 29 30 29.50 50(1) 0 ZINC 15 87 1900 518.20 5000(3) 0 BARIUM 24 12 556 102.29 1000(1) 0 l IRON 23 958 51100 14227.43 7200(4) 12 AOP- 1-5, 7.8, 11, 102, 103. 105. 108 00 MANGANESE 25 4.3 2160 569.73 NA NA VANADIUM 13 3.1 60 16.39 NA NA ALUMINUM 25 48 22900 3295.20 NA NA COBALT 7 5.1 20 10.23 NA NA MAGNESIUM 25 2380 86900 32733.20 52000(4) 3 AOP- 102, 103, 108 CALCIUM 25 12000 202000 67364.00 107000(4) 4 AOP- 1,102. 103. 112 SODIUM 23 5350 134000 37156.09 76000(4) 1 AOP-2 POTASSIUM 13 3430 12400 5289.23 12000(4) 1 AOP- 109 CYANIDE 5 15 25 19.40200(3) 0 Notes: 1 = Safe Drinking Water Act MCL 3 ' Clean Water Act AWOC 2 * Safe Drinking Water Act MCLG 4 » Regional literature Results for Until tered Samples No. Detections in 25 Field Samples Only Phase 1 Samples Analyzed for EPA Inorganics •Source: A. 0. Polyner Site Remedial Investigation, ICF Technology, July 1990

9960 TOO duV A. 0. Polymer Site Public Review Feasibility Study April 1991

Several trace Metals including arsenic, beryllium, chromium, and nickel were detected in high concentrations compared to statutory or recommended criteria such as the Clean Water Act, Maximum Contaminant Levels (MCI) or the Safe Drinking Water Act Ambient Water Quality Criteria (AWQC). Beryllium was detected infrequently at levels close to the detection limit and It's occurrence may be related to suspended matter in the unfiltered samples submitted for analysis. Beryllium concentrations In groundwater may therefore be related to Its natural occurrence in local soils rather than to groundwater contamination. Nickel may be a naturally occurring background contaminant. A Potable well located in a background location about 3/4 of a mile southwest of the site contained nickel at a level similar to that found in monitoring wells. Chromium was detected in levels exceeding the MCL of 50 ug/1 in two nested wells located northwest of the site. It was either not detected or detected in low concentrations in all other monitoring wells. Because the two wells in which chromium was detected penetrated fine grain sediments or fracture zones filled with fine grain sediments, it 1s suspected that high chromium concentrations may also be related to the natural occurrence of chromium in soils rather than groundwater contamination. Arsenic was detected frequently at relatively high concentrations although 1t exceeded the MCL of 50 ug/1 only once. Inspection of a plot of arsenic concentrations revealed no consistent pattern that would indicate that 1t 1s a site-related contaminant. Therefore, arsenic may be a natural background contaminant. Based on inorganic data collected during the RI, it appears that there is insufficient evidence to conclude that the site is a source of inorganic contamination. In addition, it appears that the overall groundwater quality is normal for the region. These conclusions in combination with the fact that unusual levels of metal contamination were not found in onsite soils appears to indicate that inorganic groundwater contamination is not a problem of concern at the A. 0. Polymer Site. Organic Data Monitoring wells were sampled for volatile organics in both Phase I and Phase II. Semi volatile and PCB/Pesticide organics were analyzed only during Phase I. A total of 27 different target compounds were detected in the wells. The results of these analyses are summarized in Table 1-4. Groundwater contamination consists mostly of volatile organic compounds. Detected Host frequently, and in high concentrations, were eight HAH compounds and five NAH compounds. Four ketones, 4-methyl-2-pentanone (methyl isobutylketone, MIBK), acetone, 2-hexanone and 2-butanone (methylethyl ketone, MEK) also occurred in high concentrations, but with less frequency. Miscellaneous volatile organic compounds that were detected include chlorobenzene (detected twice at 1.6 and 82 ug/1), trlchlorofluoromethane (freon 11, detected once at 3.7 ug/1), carbon disulfide (detected once at 5.1 ug/1) and methylene chloride.

AOP-35-H 1-19 TABLE 1-4 Organic Chemical Sunmary for Monitiring Well Samples* A.O. Polymer Site Feasibility Study

Frequency Minimum Maximum Average Location Other of Detected Detected Value of Maxim* Locations Detection Value Value Concentration Detected CLASS TARGET COMPOUND (1) (ug/l) (ug/l) (ug/l) nmkiAKimi EV nLirnniw nivn^vnHWHtf V TRICHLOROETHEHE 28 1.5 3000 326 AOP-6 AOP- .2,6,7-10,101.104.108.110,113,114,117 V 1.2-DICHLOROETHENE (TOTAL) 25 1.0 4000 834 AOP-108 AOP- ,3,7-10.101.108.110,113,114,117 V 1,1-DICHLOROETMAME 23 2.5 750 126 AOP-108 AOP- .3,6,7.9.10,101,110.113.114 V 1,1,1-TRICHLOROETHAME 21 1.1 3100 469 AOP-6 AOP-7-9, 101. 105. 107, 108. 110. 114, 117 V 1,1-DICHLOROETHENE 9 2.0 500 82 AOP-6 AOP- ,9.108.114.117 V CHLOROFORM 9 1.0 530 93 AOP-6 AOP- .9,10,108.113,114 V TETRACNLOROETHEHE 7 1.1 560 117 AOP-6 AOP-7,110,114.117 V CARBON TETRACHLORIDE 4 22.0 37 29 AOP-110 AOP-117 V 1.2-OICHLOROPROPANE 2 4.5 8 6 AOP-101 V 1 , 1 ,2-TRICHLOROETHAHE 1 2.0 AOP-117 V TR 1 CHLOROFLUOROMETHANE 1 3.7 AOP-6 --NONOCYCLIC AROMATIC HYDROCARBONS V TOLUENE 12 4.6 840 262 AOP-6 AOP-3, 9, 10, 108. 110. 114 V XYLENE (TOTAL) 10 1.0 500 97 AOP-6 AOP-3, 10, 110,114, 117 l V ETNYLBENZENE 7 1.0 140 28 AOP-6 AOP-3, 110, 113. 114 f\> V BENZENE 5 2.0 8 5 AOP-10 AOP-101 o V CHLOROBENZENE 2 1.6 82 42 AOP-6 AOP-10 ...... -KETONES ......

V ACETONE 28 2.0 8100 716 AOP-6 AOP-1-4, 6-8, 10, 11, 103-109 V 2-BUTANONE 13 5.0 18000 1703 AOP-3 AOP-6, 8, 11, 101, 106- 108,1 14, P-5 V 4-NETHYL-2-PENTANONE 11 6.0 2900 423 AOP-6 AOP- 1,3. 9, 108. 110. 113 V 2-HEXANONE 2 3.0 32 18 AOP-110 AOP-10 --MISCELANEOUS ORGANIC COMPOUNDS V NETHYLEHE CHLORIDE 30 2.0 1600 90 AOP-6 P-5-8, AOP- 1-4, 6- 11, 101, 102, 104- 110, 113, 114, 11 A PHENOL 12 5.2 310 73 AOP-6 AOP- 1-3, 9,10, 101. 107, 108,114 A 4-NETHYLPHENOL 2 5.4 17 11 AOP-110 AOP-9 V CARBON DISULFIDE 5.1 AOP-1 B IIS(2-ETHYLHEXYL)PHTHALATE 97.0 AOP- B 1, 2 -Dl CHLOROBENZENE 2.2 AOP- B Dl-N-BUTYLPHTHALATE 5.8 AOP- B 2-METHYLNAPNTHALENE 3.0 AOP- A BENZOIC ACID 14.0 AOP- P ALPHA-BHC 0.2 AOP-3 P BETA-BHC 1.1 AOP-6 mmm

Notes: V » Volatile organic compound P * PCB/Pesticide Fraction A » Acid extarctable compunds 1 * Nuaber of detections in 56 field samples B « Base Nuetral «x tract able compound Phase II samples analysed for V only •Source: A. 0. Polymer Site Remedial Investigation, 1CF Technology, July 1990

8960 100 A. 0. Polymer Site Public Review Feasibility Study April 1991

Non-volatile compounds detected included two phthalate esters, two phenolic "~ compounds, dlchlorobenzene, 2-methylnapthalene, benzole add, and alpha and beta BHC (pesticides). The non-volatile compounds were found with a very low frequency (two times or less) and, in all cases, accounted for less than 10% of the total organic concentration in any sample. In nearly all cases the miscellaneous non-volatile compounds were detected in AOP-6. The HAH compounds found most frequently in highest concentrations are two commonly used industrial solvents TCE and TCA along with their typical degradation by-products. In general, these contaminants were found in highest concentrations at two wells - AOP-6 and 108. The high concentrations were present in wells monitoring the shallow flow regime. Contaminants were generally not detected or found at very low concentrations in the deep wells. Two exceptions to this observation are AOP-8 and 9 both of which are bedrock wells. However, these two wells are located atop the bedrock structural high and their screened intervals are actually shallow In relation to the typical deep bedrock wells elsewhere on the site. The lateral extent of HAH groundwater contamination is typified by the TCE isoconcentration contour map shown in Figure 1-6. When considered in relation to shallow groundwater flow, this map appears to indicate a distribution that characterizes the movement of a contaminant plume away from a point source. A point source is indicated in the vicinity of AOP-6 and AOP-1 which corresponds with the former Mohawk Industries waste disposal lagoons remediated by NJOEP in 1980 and 81. Movement is indicated to the east-northeast which generally coincides with the movement of groundwater toward the Wall kill River. The general distribution of both TCA and TCE degradation by-products is the same as for TCE, however, they appear to be more widely distributed with downgradient and peripheral locations in the plume containing higher concentrations of by-products then of the original parent compound. The wider distribution of degradation by-products tends to Indicate that the plume has "aged" - a condition that would be expected since the last discharges from the suspected Mohawk source area occurred approximately 10 years ago. Another class of compounds found frequently and in high concentrations in groundwater are the MAH compounds - ethylbenzene, benzene, toluene and xylenes. These organic compounds are common Industrial solvents and constituents of gasoline and other petroleum by-products. The general distribution of these contaminants 1s similar to TCE and TCA which suggests a common source. This was expected because MAHs were strongly associated with TCE and TCA 1n the contaminated soils from test borings 11 and 12 near the suspected source area. The compounds were not found in AOP-8 and 9 although they were detected in the wetland surface water along the Wall kill River indicating a seemingly anomalous pattern. The absence of MAHs 1n AOP-8 and 9 is, however, not unexpected. MAH compounds are less dense than water and in bulk form are expected to "float" on the water table. TCE and TCA are denser ^ than water and to a limited extent tend to sink as long as they are not o restricted by permeability limitations. Therefore, at the source area the MAH compounds had less opportunity to penetrate the groundwater to any great 0 depth. MAHs may not have been detected at AOP-8 and 9 because these wells are 3 screened at a depth deeper than the lower extent of the MAH fraction of the plume. AOP-35-N 1-21 A. 0. Polymer Site Public Review Feasibility Study April 1991

Another group of compounds that were found at a high frequency and in high concentrations are the ketones. The ketones are distributed somewhat differently than the other compounds. The contaminant movement suggests two source areas, one being the old Mohawk disposal lagoons and a second as yet unidentified source located farther to the south. The distribution difference is due primarily to the occurrence of ketones in high concentrations at AOP-3. In Phase I, 2-butanone or HEK concentrations at AOP-3 were an order of magnitude higher (18,000 ug/1) than found in Phase II. Between Phase I and Phase II, the NJDEP/DHSM sampled AOP-3 and found even higher concentrations (50,000 ug/1). This rapid variation in concentration suggests the passage of a small, highly concentrated slug such as might occur from an accidental spill. Inspection of the groundwater flow pattern suggests a possible source area to the northeast of AOP-3 somewhere between the cooling lagoon and AOP-114. An unsuccessful attempt was made to locate the source of MEK at AOP-3 with a soil gas survey. The timing of such an occurrence could be relatively recent considering the groundwater velocities that appear to exist at the site. 1.3.4 Potable Wells Inorganic Data Thirteen metals were found in potable well samples. None of the constituents detected were present at levels exceeding Safe Drinking Water Act HCLs or MCLGs. The background well located approximately 3/4 miles southeast of the site served as a further comparison. Barium, copper, manganese, cobalt, magnesium and calcium concentrations in the background well sample exceeded the concentrations found 1n potable wells nearer the site. The only trace metals detected in other potable wells that were not detected in the background well were selenium, zinc, and vanadium. Selenium was detected once at a level below the MCL of 10 ug/1. Vanadium, was found at 3.7 ug/1 in the Sparta High School well. This detection was not verified in a duplicate sample collected at the well which makes the result questionable. Zinc was found in the A.O. Polymer facility well and in AOP-DW-006 at levels substantially below the MCLG. The background well contained 29 ug/1 of nickel. This may indicate that nickel occurs naturally in local groundwater. Organic Data No organic contaminants were detected In potable wells. 1.3.5 Surface Water > v Inorganic Data o Surface waters were sampled for Inorganic HSL parameters during Phase I. 2 Station 1, which 1s located approximately 100 feet upstream of the railroad trestle, served as an adequate background sample. g AOP-35-H 1-22 A. 0. Polymer Site Public Review Feasibility Study April 1991

With the exception of selenium, downstream samples contained no Inorganic contaminants with concentrations significantly different than the upstream background sample. There also appears to be no significant difference between the concentration of Inorganics found in the cooling pond and those found in the upstream background sample. Selenium was the only constituent detected In downstream samples that was not detected at the background station. However, the single detection of selenium alone 1s Insignificant; the concentration was close to the detection limit and further sampling upstream 1s expected to yield a few detections similar to this detection. Organic Data Three stations on the Wall kill River, one near the NYS&W railroad trestle (Station 1), one near Station Road (Station 2), and one near AOP-117 (Station 4) were sampled for organic HSL contaminants during Phase I. Two of these stations (1 and 4) and two new stations: one near the foot bridge (Station 3) and one near West Mountain(Station 5) were sampled in Phase II. The A. 0. Polymer cooling lagoon was also sampled in Phase I. Two zones of wetland surface water: one located near the upper soccer fields (north zone) and one . located along the Wall kill River near the softball field (east wetlands surface water zone) were sampled In Phase II. The potentially site related contaminants 1,2 and 1,1-DCE, both blodegradation by-products of TCE were detected in samples from the Wall kill River from locations in the vicinity of and downgradient of the groundwater contaminant plume. Although detections were at very low levels, 1,1-DCE was detected in Phase I and Phase II. In addition, the Phase II sample from the east wetlands surface water Indicated substantially higher concentrations of TCE, TCA, MAHs and several degradation by-products. Therefore, it 1s suspected that the contaminated groundwater 1s currently discharging to the Wall kill River. Xylenes, at 17 ug/1, were detected in the A.O. Polymer cooling lagoon. Its detection could be the result of contamination of the plant process water in the A.O. Polymer facility. However, It could also result from many other causes, including the solution of exhaust fumes from vehicles which enter and leave the site via the access road near the lagoon. 1.3.6 Sediment Inorganic Data Benthic sediments from the Wallkill River were sampled only during Phase I. With the exception of beryllium, nickel, and cyanide, there 1s little difference between the concentrations detected in the upstream station and the stations located downstream of the site. Beryllium was detected downstream of the site at two stations. Nickel and a cyanide were detected at the Station Park downstream station. Although these >-, contaminants were not detected 1n the background sample there 1s not sufficient reason to conclude that they are the result of contamination. = ^j AOP-35-M _ ^ A. 0. Polymer Site Public Review Feasibility Study April 1991

Beryllium was detected in both onsite and background soils at concentrations comparable to those detected in the sediment. Nickel, although not frequently detected in onsite soils, does appear to be a normal constituent of groundwater. In the surface water environment, it is possible for nickel, which was introduced by groundwater discharge, to accumulate in sediment because it co-precipitates with iron. Cyanide may be natural constituent in water and can accumulate in organic matter in benthic sediments. Organic Data Twelve compounds, including toluene, di-n-butyl phthalate, and 10 PAHs were detected. The largest concentrations of PAHs were detected in the upstream sample. PAH concentrations were lower in downstream samples. This indicates an upstream source of contamination. The source of contamination is not indicated by the data. However, PAHs are ubiquitous in the environment because of their close association with the use of fossil fuels and fossil fuel by-products. In addition, PAHs tend to accumulate in sediment because of their high affinity for organic carbon. Therefore, the source of contamination may be the general human activities throughout the Wall kill River Valley upstream from the site. Toluene and di-n-butyl phthalate were not detected in the background samples, but were detected in downstream samples.

1.4 BASELINE RISK ASSESSMENT The risk assessment conducted for the A. 0. Polymer site is a baseline assessment that addresses potential hazards to human health and the environment posed by contamination in the site study area in the absence of remedial actions. The purpose of a baseline assessment is to provide information to aid in the determination of whether remedial actions should be undertaken. The main components and results of the human health assessment are summarized in Section 1.4.1. The conclusions of the environmental assessment are summarized in Section 1.4.2. 1.4.1 Human Health Assessment Chemicals of Potential Concern Chemicals of potential concern are defined as those chemicals that are believed to be associated with activities that occurred at the A. 0. Polymer Site. Exposure concentrations for the chemicals of concern, developed using RI data are used to quantitatively characterize risks. In general, nearly all of the organic contaminants detected in soil, groundwater to surface water > discharge areas and surface water were selected as chemicals of concern. A TJ list summarizing these contaminants is presented in Tablt 1-5. Inorganic 3 substances were generally not selected as contaminants of concern because O their occurrence is not believed to be site related and is reflective of

AOP-35-H i -j TABLE 1-5 SUMMARY OF CHEMICALS OF POTENTIAL COHCERH FOR THE A.O. POLYMER SITE A.O. POLYMER FEASIBILITY STUDY

Surface Soil Groundwater Surface Water

Beta-BHC Acetone Wall kill River: B1s(2-ethylhexyl)phthalate alpha-BHC 2-Butanone beta-BHC 1,2-01chloroetnene Butyl benzylphthalate Benzene (total) 01-n-butylphthalate Benzole acid 2,4-Dlnltrotoluene B i s(2-tthylhexyl)phthalate East Seep: 2,6-dlnltrotoluene 2-Butanone Ethyl benzene Carbon disulflde Acetone Heptachlor epoxide Carbon tetrachlorlde Benzene PAHs (carcinogenic) Chlorobenzene 2-Butanone PAHs (noncarclnogenic) Chlorofor» Carbon disulfide Tet rachloroethene 01-n-butylphthalate Carbon tetrachlorlde 1,1.1-Trlchloroethane 1,2-01chlorobenzene Chlorobenzene Toluene 1,1-Dlchloroethane Chloroform Vinyl acetate 1.1-01chloroethene 1.1-Dlchloroethane Xylenes (total) 1.2-d1chloroethene (total) 1.1-dichloroethene 1,2-Dlchloropropane 1.2-01chloroetnene Ethyl benzene Ethyl benzene Susurface Soil 2-Hexanone Methyl ene chloride 4-Methyl-2-pentanone Tetrachloroethene Benzole add Methylene chloride Toluene B1s(2-ethylh*xyl)phthalate 4-Methlphenol 1.1.1-Trtchloroethane 2-6utanone PAHs (noncarclnogenic) 1.1.2-Trlchloroethane Butyl benzylphthalate Phenol Trichloroethene Chlorobenzene Tetrachloroetnene Vinyl chloride 1,2-01Chlorobenzene Toluene Xylenes (total) trans-l,2-01chloroethene 1.1.1-Trlchloroethane 2.4-D1methylphenol 1.1.2-Trlchloroethane Di-n-butylphthalate Trichloroetnene North Seep: Ethyl benzene Tri chlorof1uoromethane 2-Methyl phenol Xylene (total) None 4-Methylphenol N-nltrosodiphenylamine PAHs (carcinogenic) Sediment Cooling Pond: PAHs (noncarclnogenic) Phenol None Xylenes (total) Tet rachloroetnene Toluene 1.1.1-Trlchloroethane 1.1.2-Trichloroethane Trichloroethene Trichl orof luoroMthanaj Xylenes (total)

U) APO-T-1-5-3S-M 1-25 A. 0. Polymer Site Public Review Feasibility Study April 1991 background conditions or regional contamination problems. However, potential risks associated with some of the regionally elevated contaminants, Including arsenic, were assessed qualitatively. Human Exposure Pathways Potential human exposure pathways were selected for evaluation under current land-use conditions only. Future land-use condition pathways were considered to be similar to current pathways and were not evaluated. The exposure pathways, which were evaluated either qualitatively or quantitatively, are the following

o Groundwater — ingestion by residents (quantitative) and dermal contact by residents during in-home use. (qualitative); o Air — inhalation of chemicals that volatilize from groundwater through soil to ambient air by residents and recreational users of Station Park (quantitative), and inhalation of chemicals that volatilize during in-home use of groundwater by residents (qualitative); o Surface water — exposure to children playing in the east wetlands surface water via dermal contact (quantitative) and via Inhalation of chemicals that volatilize from the surface water (qualitative). Exposures and risks associated with the other water bodies (Wallkill River and the cooling pond) were considered negligible relative to those associated with the east wetland surface water. Exposure scenarios for each of the potential exposure pathways shown above were developed, and concentrations of chemicals to which populations might be exposed (exposure point concentrations) were determined. No ambient air samples were collected as part of the RI sampling; therefore, for the inhalation pathways, air concentrations at the exposure points were estimated based on measured groundwater concentrations from shallow wells within the contaminated groundwater plume area. For the other exposure pathways quantitatively evaluated, exposure point concentrations were assumed to be the concentrations detected during RI sampling of various media. In the absence of other Information, concentrations In the exposure medium were assumed to remain constant over the duration of exposure. Risk Characterization The calculation of risk for the exposure pathways selected to be assessed quantitatively Involves estimating Intakes by potentially exposed populations based on the assumed exposure scenario. These Intakes are then combined with reference doses (RfDs, defined as acceptable dally doses for noncarclnogens) or slope factors (for potential carcinogens) to derive estimates of noncardnogenlc hazard or excess lifetime cancer risks of the potentially exposed populations. AOP-35-H 1-26 A. 0. Polymer Site Public Review Feasibility Study April 1991

Based on recent EPA guidance on risk assessment (EPA 1989), intakes were quantified by estimating the reasonable maximum exposure (RME) associated with the pathway of concern. The RME is intended to represent a possible upper bound exposure to a typical individual and Is combined with upper bound toxicity criteria to estimate risks. In this assessment, an average case exposure, calculated using the arithmetic mean concentration, was also presented. This was done to provide a measure of the degree to which the RME concentration exceeded the mean, yielding an indication of the overall uncertainty in the assessment. Based on the exposure and risk analyses presented in the previous sections, the conclusions of the quantitative risk assessment are as follows: o Groundwater — For residents ingesting groundwater from the A.0.Polymer site, the lifetime upper bound excess cancer risk 1s 2x10"* under the average* case and 4xlO"4 under the RME exposure case, primarily due to 1.1-dichloroethene. The hazard index under both the average and RME exposure case exceeds one due primarily to the liver toxicants carbon tetrachlorlde, 1.2-dichloroethene, and trichloroethene. These risks exceed EPA's Superfund risk range of 10"6 to 10"4 (EPA 1990). o Air ~ For local residents, the upper bound excess lifetime cancer risk 1s 8x10 under the average case and 6x10 under the RME case. For recreational users of Station Park, the upper bound excess lifetime cancer risk is 9X10 under the average case and 6x10 under the RME case. The majority of the cancer risks associated with inhalation of volatile chemicals in air is due primarily to 1,1-dichloroethene. The hazard Index for air exposures to both residents and recreational users did not exceed one in any case. o Surface water — Only a single exposure case was evaluated for direct contact with east wetland surface water because only one sample was collected from the wetland. The upper bound excess lifetime cancer risk for children wading in the east seep 1s onexoneO , due solely to vinyl chloride. The hazard Index 1s less than one. Qualitative risk assessments are performed by making Judgements on the relative levels of exposure and risk via various pathways. The conclusions drawn for the qualitatively evaluated pathways are discussed below. o Groundwater and Air ~ Exposure to residents via dermal contact with groundwater during In-home use, together with exposure via Inhalation of chemicals that have volatilized during activities such as showering, cooking, and washing clothes, are expected to be similar to exposure via ingestion of groundwater. Thus, risks

AOP-35-H 1 97 A. 0. Polymer Site Public Review Feasibility Study April 1991

calculated for Ingest ion of groundwater may be doubled to include the effects of these pathways to human health. o Surface water — potential inhalation exposures and risks for children playing in the wetland surface water can be evaluated by comparing them to those for recreational users of Station Park. The surface water concentrations of the volatile chemicals in the wetland surface water are similar to or lower than the RME concentrations for volatile chemicals in shallow groundwater which were used to estimate ambient air concentrations in the park. Also, children would be exposed less frequently and for fewer years than the park users. Therefore, Inhalation risks to children playing at the east wetlands surface water are probably less than those estimated for park recreational users. 1.4.2 Environmental Assessment The environmental assessment was limited to a qualitative evaluation of potential impacts associated with chemicals in surface water. Potential impacts associated with contamination in subsurface soil and groundwater were not evaluated because no pathways exist by which receptors can be exposed to chemicals in these media. Potential Impacts associated with chemicals in surface soil were not evaluated because of the relatively low chemical concentrations in surface soil and the limited distribution of all the surface soil chemicals of potential concern. The assessment was further limited to an evaluation of potential impacts in aquatic receptors in the east wetlands surface water because exposures and risks are potentially greatest in these receptors. This 1s based on the fact that surface water chemical concentrations are highest in the east wetlands surface water and that aquatic receptors could be continuously exposed to surface water contaminants for all or part of their lifetime. Surface water exposures in exclusively terrestrial species would necessarily be less because these species would only occasionally be exposed to chemicals in surface water. None of the east wetlands surface water chemicals of concern bioaccumulates extensively, therefore, significant exposures in terrestrial wildlife from occasional use of surface water is very unlikely. o Aquatic Invertebrates — Potential Impacts in aquatic Invertebrates were evaluated by comparing east wetlands surface water concentrations with lowest-observed-effect levels (LOELs) for aquatic species (where available). The comparisons revealed that wetland surface water chemical concentrations are between two and five orders-of-magnitude below the LOELs. Direct comparisons could not be made for the chemicals in the east wetlands surface water for which LOELs were not available, however these chemicals were detected at generally low levels and aquatic toxicity data Indicate that volatile organic chemicals Induce toxic effects 1n aquatic organisms via a non-specific narcotic or anesthetic mode of action. o Amphibian Species — Of the chemicals detected In the east o wetlands surface water, amphibian toxicity data were located only 10

AOP-35-H j_28 A. 0. Polymer Site Public Review Feasibility Study April 1991

for carbon tetrachloHde, chloroform, and methylene chloride. LCmo v*1ues f°r these chemicals were used in this assessment to Indicate the concentrations at which frog populations breeding in the east wetlands surface water would begin to be significantly Impacted. LC,0 values were used to Identify exposure levels that could severely affect the viability of the population at the east wetlands surface water. The detected concentrations of carbon tetrachloride, chloroform, and methylene chloride in the east wetlands surface water are below both LC50 and LC10 values. Some of the other chemicals in the east wetlands surface water were detected at higher concentrations, however the probability of Impacts from these chemicals could not be fully evaluated given the lack of additional toxicity data for amphibian species.

o vO -J, AOP-35-M Section 2

AGP 001 0978 A. 0. Polymer Site Public Review Feasibility Study April 1991

2.0 REMEDIAL ACTION OBJECTIVES This section presents the remedial action objectives for the A. 0. Polymer site. Remedial action objectives are statements that specify site remediation goals and identify which contaminants, media and exposure pathways will be addressed by remedial actions. Section 2.1 identifies the contaminated media which pose the most significant risks at the site. Remediation goals establish exposure levels that are protective of human health and the environment. They are developed by considering applicable or relevant and appropriate State and Federal Regulations (ARARs), State and Federal guidance classified as to be considered (TBCs), the toxic or carcinogenic potential of contaminants, aggregate risks posed by multiple contaminants or exposure pathways, and environmental threats. ARARs, TBCs and remediation goals are identified and described in Section 2.2 and the remedial action objectives for the A. 0. Polymer site are presented in Section 2.3. The remedial action objectives are subsequently used in screening of remedial technologies (Section 3.0) and in the development and screening of remedial alternatives (Section 4.0).

2.1 EXPOSURE PATHWAYS, MEDIA AND CONTAMINANTS TO BE ADDRESSED Site-related contamination is present in groundwater, soil and surface water. A base line risk assessment was performed during the RI to evaluate the significance of potential exposure to this contamination. Because surface soil contamination was infrequent and of low concentration, direct contact with contaminated soil was determined to be an exposure pathway of little significance. Continuous exposures over long periods of time would have to occur to result in significant health risk and this situation is unlikely, even for site workers. Contact with severely contaminated subsurface soils near the former lagoon area was also found to be of little consequence because exposure would be difficult. Contaminated subsurface soils are, however, suspected of contribution to groundwater contamination as a result of leaching. Ingestion of contaminated groundwater, inhalation of volatiles from the groundwater contamination plume, and direct contact with contaminated surface waters are potentially more significant exposure pathways. The potential health risks resulting from these pathways were subsequently evaluated for both carcinogens and noncarcinogens. The aggregate risks resulting from exposures to all contaminants of concern are summarized in Table 2-1. In each exposure pathway most of the risk was due to a few chemicals of concern namely tetrachloroethene, trichloroethene, 1,1-dichloroethene, 1,2-dichloroethene and vinyl chloride. By comparison, the current NCP lists acceptable cancer risks at between IxlO"4 to IxlO'6 and acceptable exposure to noncarcinogens as less than 1. The only potential risks that exceed these benchmarks are those for groundwater ingestion. Although within acceptable limits, inhalation risks and direct contact with contaminated surface water exceed the IxlO"6 point of departure 2 and add to the total risk of the site. o 10 AOP-35-H ^O TABLE 2-1 BASE LINE RISKS FOR EXPOSURE PATHWAYS A.O. POLYMER FEASIBILITY STUDY

CARCINOGENIC NON-CARCINOGENIC EXPOSURE RISK RISK PATHWAY (1) (Z) Groundwater Ingest Ion 4x10'* (3) 5. (4) Residential Inhalation 6xlO'5 (5) 0.04 Recreational Inhalation 6x10"' (6) 0.004 Direct Contact with Surface Water 1x10"' (7) 0.0002

(1) Upperbound excess cancer risk representing the probability of contracting cancer due to exposure to concentrations of chemicals of concern at the site.

(2) Chronic Daily Intake: Risk Reference Dose Ratio. (3) 1.1-DCE represents over half of the agregate risk. TCE, PCE and 1,1-TCA also contribute significantly to risk. (4) Risk due mostly to 1,2-DCE and TCE. (5) Risk due almost entirely to 1.1-DCE. (6) Risk due almost entirely to 1,1-OCE. (7) Risk due almost entirely to vinyl chloride.

O 13 o o

O VD AOP-35-M 2-2 A. 0. Polymer Site Public Review Feasibility Study April 1991

Environmental risks due to site contamination were also evaluated. Exposure to contaminated groundwater discharging to wetlands of the Wallkill River was determined to be the only potential environmental exposure route for endemic aquatic species. Environmental impacts of contamination were determined to be negligible because the contaminants of concern are nonbioaccumulative and are minimally toxic to wildlife. All significant risks stem directly from either ingestion of contaminated groundwater, discharge of contaminated groundwater to surface water or from volatile vapors emanating from the groundwater contaminant plume. Therefore, contaminated groundwater will be addressed by potential remedial actions. The exposure pathway of concern will be groundwater ingestion because this pathway represents the largest risk to human health. By addressing this risk the other risks will be reduced as well. In addition, it appears that the contaminated subsurface soils, while posing no direct contact threat, do represent a potential source of additional groundwater contamination. Therefore contaminated subsurface soils will also be addressed.

2.2 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS) AND GUIDANCE TO BE CONSIDERED (TBCS) 2.2.1 Consideration of ARARs and TBCs The National Contingency Plan (NCP) and Section 121 of SARA require that, upon completion, remedial actions attain Federal ARARs, unless specified waivers are granted. State ARARs must also be attained under Section 121(d) of SARA, if they are legally enforceable and consistently enforced statewide. Therefore, potential ARARs and TBCs are identified at this time to aid in develop of remedial action objectives and in establishment of required cleanup levels. ARARs and TBCs are used to: 1) develop remedial action objectives and determine the appropriate extent of cleanup, 2) to scope and formulate remedial action alternatives, and 3) to govern implementation and operation of the selected remedial alternative. According to SARA, ARARs may be waived under certain conditions, provided that protection of human health and the environment is still assured. These waiver conditions are as follows: o The selected remedial action is an interim remedy or portion of a total remedy which will attain standards when complete. o Compliance with such requirements will result in greater risk to human health and the environment than alternative options. o Compliance with requirements is technically impracticable from an § engineering perspective. ^ o The selected remedial action will provide an equivalent standard § of performance using another approach. ^ o VO CO I—I AOP-35-H 2-3 A. 0. Polymer Site Public Review Feasibility Study April 1991

o The requirement 1s a state requirement that has been Inconsistently applied. o The alternative will not provide a balance between public health and environmental welfare and the availability of funds to respond to existing or potential threats at other sites, taking into account the relative immediacy of the threats. ARARs are classified as either applicable, or relevant and appropriate, other guidance and regulations may be classified as TBCs. Applicable Requirements Applicable requirements refer to those Federal or State requirements that would be legally enforceable. An example of an applicable requirement would be the Safe Drinking Water Act's Maximum Contaminant Levels (MCLs) for a site that causes contamination of a public water supply. Relevant and Appropriate Requirements Relevant and appropriate requirements are Federal or State standards, criteria, or guidelines that are not legally enforceable at the site, but which address problems so similar to those onsite that their application 1s appropriate. For example, while RCRA regulations are not applicable to closing undisturbed hazardous waste in place, the RCRA regulations for closure by capping may be deemed relevant and appropriate. During the FS process, relevant and appropriate requirements are Intended to have the same weight and consideration as applicable requirements. To Be Considered Other Federal and State guidance documents or criteria that are not generally enforceable but are advisory are "to be considered" during the FS process. For example, where no specific ARARs exit for a chemical or situation, or where such ARARs are not sufficient to be protective, guidance documents or advisories may be considered in determining the necessary level of cleanup for protection of public health and the environment. ARARs and TBCs are further categorized as either chemical-specific, location- specific, or action-specific. Chemical Specific Chemical-specific requirements define acceptable exposure levels for specific hazardous substances and therefore may be used as basis for establishing preliminary remediation goals and cleanup levels for chemicals of concern in the designated media. Chemical-specific ARARs and TBCs are also used to determine treatment and disposal requirements that may occur in a remedial activity. In the event a chemical has more than one requirement, the more stringent of the two requirements will govern.

AOP-35-N 2-4 A. 0. Polymer Site Public Review Feasibility Study April 1991

Location Specific Location-specific requirements set restrictions on the types of remedial activities that can be performed based onsite-specific characteristics or location. Alternative remedial actions may be restricted or precluded based on Federal and State site laws for hazardous waste facilities, proximity to wetlands or floodplains, or to man-made features such as existing landfills, disposal areas, and local historic landmarks or buildings. Action Specific Action-specific requirements set controls or restrictions on the design, implementation, and performance of waste management actions. They are triggered by the particular types of treatment or remedial actions that are selected to accomplish the cleanup. After remedial alternatives are developed, action-specific ARARs and TBCs that specify performance levels, as well as specific levels for discharges or residual chemicals, provide a basis for assessing the feasibility and effectiveness of the remedial actions. 2.2.2 Potentially Applicable ARARs and TBCs The EPA Compliance With Other Laws manual lists all Federal ARARs and TBCs which may affect remedial actions at superfund sites. A preliminary list of probable State ARARs and TBCs was provided by NJDEP and is included in this report as Appendix A. These documents were reviewed to identify which ARARs and TBCs are most pertinent to problems and potential remedial actions that could be taken at the A. 0. Polymer Site. Chemical-specific ARARs and TBCs that are pertinent to the A. 0. Polymer Site are identified in Table 2-2. Most of the ARARs identified are relevant and appropriate, and could be used along with the TBCs to identify cleanup action levels for soil and groundwater. A list of site specific groundwater contaminants and available standards promulgated by chemical-specific ARARs and TBCs is presented in Table 2-3. As shown in the table, many of the groundwater contaminants at the site have MCLs or MCLGs. The primary contaminants in the soil at the site are volatile and base-neutral organic chemicals. State ARARs and TBCs pertaining to cleanup action levels for organic contaminants in soil specify that risk-based action levels are preferred however, in the absence of risk assessment-based action levels, the following NJOEP recommended soil action levels for soil cleanup are to be used: Volatile organics 1 ppm total Base-neutrals 10 ppm total o o Location-specific ARARs and TBCs are listed in Table 2-4. Most location- specific ARARs regulate the extent of activity that may be taken 1n wetlands, recreational lands or historic sites or, 1n the event that an action is taken

AOP-35-H 2-5 TABLE 2-2 POTENTIAL CHEMICAL-SPECIFIC ARAfiS A. 0. POLYMER FEASIBILITY STUDY

Standard, Requirement, Criteria or Limitation Citation Description Status nt

FEDERAL ARMS Resource Conservation 40 C.F.R. Defines those solid wastes which Relevant/ As a previously operating disposal facility, these and Recovery Act (RCltt) Part 264.1 are subject to regulations as Appropriate requirements are relevant and appropriate. May also be - Identification and hazardous wastes under 40 C.F.R. applicable for treatment residuals, which may be hazardous Listing of Hazardous parts 262-265 and Parts 124. wastes. Waste 270.271. Safe Drinking Water Act 40 C.F.R. Establishes health-based Relevant/ The Maximum Contaminant Levels (MCLs) for inorganic and National Primary Water Part 141 standards for public water Appropriate organic contaminants are legally enforceable for public Standards system. water supplies, but may be considered relevant and appropriate as treatment standards for contaminated groundwater. SDWA Maximum 40 C.F.S. Establishes drinking water To Be MCLGs for inorganics and organic contaminants are Contaminant Level Goal 141.11 - quality goals set at levels of Considered established using health-based criteria. NCLGs may be (MCGs) 141.16 anticipated adverse health considered in establishing treatment standards for effects, with an adequate margin groundwater. of safety. Clean Water Act Water 40 C.F.R. Sets criteria for water quality Relevant/ Criteria available for water and fish tngestlon Quality Criteria Part 131 based on toxicity to aquatic Appropriate consumption only for human health. Criteria available for organisms and human health. freshwater and marine water for aquatic life.

100

OP-JS-M Table 2-2 (Continued) Potential Chemical-Specific ARARs Page 2

Standard, Requirement, Criteria or Limitation Citation Description Status Comment

STATE ARMS SOLIDS Sludge Quality Criteria NJAC 7:14 - New Jersey Water Pollution Relevant/ ARAR for sludges generated during wastewater treatment. 4 appendix Control Act Contaminant Appropriate B-l Indicators. New Jersey Department June 1, 1966 Cleanup based on background Relevant/ NJOEP Action levels will be used as cleanup criteria for of Environment Document levels for inorganics, and risk Appropriate soil for total volatile organics, total base-neutrals, and assessment for organIcs total petroleum hydrocarbons (includes PAHs). including total volatile organics, total semi-volatile organlcs (base neutral(s), and total petroleum hydrocarbons

GROUNDWATER Safe Drinking Water Act A-280 State criteria for drinking Relevant/ ARAR if more stringent than the Federal MCLs. Maximum Contaminant Amendments water Appropriate Levels GrounoVater Protection NJPDES Standards when written into Applicable Hay be ARAR if treated groundwater Is reinjected. NJDEPS permits Groundwater Standards NJAC 7:9-6 New Jersey Water Pollution Relevant/ Relevant and appropriate for groundwater cleanup. NJAC 7:14 A- Control Act standards for Appropriate 6:15 groundwater SURFACE WATER Surface Water Criteria NJAC 7:9-4 Criteria for surface water Relevant/ Relevant and appropriate for groundwater cleanup, if classes; St. (saline Appropriate treated wtaer is discharged to surface water. estuarian), SC (saline coastal), and FW2 (general freshwater).

S8fiO TOO

AOP-JS-H 2-7 TABLE 2-3 ORGANIC CHEMICAL SUMMARY AND ARARS FOR GROUNDWATER A.O. POLYMER FEASIBILITY STUDY

Fr«qu*ney Avirag* F«d«r«l Maudmum NJSVOA F«d«r«l Htitmtm •f D«t«ct1o(i V«lu« MCL> HCLGt Class Target Compound (1) (1*971) (|ig/l ) (iig/D (ng/i) (ng/i)

HALOGENATED ALIPHATIC HYDROCARBONS

V TRICHLOROETHENE 28 3,000 326 5 1 V 1.2-OICHLOROETHENE (TOTAL) 25 4,000 834 "170 10 "170 V 1,1-DICHLOROETHANE 23 750 126 - - V 1.1,1-TRICHLOROETHANE 21 3,100 469 200 26 V 1.1-OICHLOROETHENE 9 500 82 7 2 V CHLOROFORM 9 530 93 100 - V TETRACHLOROETHENE 7 560 117 5 1 0 V CARBON TETRACHLORIDE 4 37 29 5 2 -- V 1,2-DICHLOROPROPANE 2 8 6 5 - 0 V 1,1,2-TRICHLOROETHANE 1 2 - - - V TRICHLOROFLUOROMETHANE 1 3.7 - - -

MONOCYLCIC AROMATIC HYDROCARBONS

V TOLUENE 12 840 262 2,000 . 2,000 V XYLENE (TOTAL) 10 500 97 10,000 44 V ETHYLBENZENE 7 140 28 700 - 700 V BENZENE S 8 5 5 1 V CHLOROBENZENE 2 82 42 100 4 100

KETONES

V ACETONE 28 8,100 716 - - - V 2-BUTANONE 13 18,000 1,703 - - - V 4-METHYL-2-PENTANONE 11 2.900 423 - - - V 2-HEXANONE 2 32 18 - - -

MISCELLANEOUS COMPOUNDS

V METHYLENE CHLORIDE 30 1.600 90 . 2 , A PHENOL 12 310 73 - * 3,500 - A 4-METHYLPHENOL 2 17 11 - - - V CARBON DISULFIOE 1 5 - - - - B 8 I S ( 2-eTHYLHEXYL ) PHTALATE 1 97 - - - - B 1,2-OICHLOROBENZENE 1 2 - 10 600 100 B OI-N-BUTYLPHTHALATEE 1 6 - - - - B 2-METHYLNAPHTHALENE 1 3 - - - - A BENZOIC ACID 1 14 - - - - P ALPHA-BHC 1 0.2 - - - - P BETZ-BHC 1 1.1 - " — -

NOTES:

¥ - Volatile organic compounds A • Acid extractable compounds 8 « Base Neutral extractable compounds P « PCB/Pestlcide Fraction Frequency of Detection (1) • Number of detections in 56 field samples *NJAC 7:9-6 Groundwater Standard "Cis - 1.2 - DCE NCL « 70 Trans - 1.2-DCE MCL • 100 ug/1 o o

O 03 AOP-35-H 2-8 TABLE 2-4 POTENTIAL LOCATION-SPECIFIC ARARS A.O. POLYMER FEASIBILITY STUDY

Standard, Requirement, Criteria or Limitation Citation Description Status nt

FEDEML AKAHS Clean Water Act Section 404 Prohibits discharge of dredged Applicable There are wetlands associated with the 40 C.F.R or fill material into wetlands Walkill River at the site. 230, 231 without permit. Preserves and enhances wetlands.

National Historic 16 U.S.C. Requires federal agencies to Applicable Based on NJDEP review of the site, it Preservation Act s 470 take into account the effect was determined that the project area is of any federally-assisted sensitive for discovery of cultural 40 C.F.R. undertaking or licensing on resources. Accordingly a Stage IA s 6:301 (b) any district, site, building, survey should be performed for the structure, or object that is project area to assess any cultural 36 C.F.R included in or is eligible for resources that may be Impacted by Part BOO inclusion in the National remedial actions. Register of Historic Places.

Executive Order Executive Requires federal agencies to Relevant/ Site is not on federal property; Protecting Wetlands Order No. minimize the destruction, Appropriate however, wetlands exist at the site. 11990 loss, or degradation of wetlands on Federal property.

Fish and Wildlife 16 U.S.C. Requires consultation when Relevant/ Remedial actions are not expected to Coordination Act 661 federal department or agency Appropriate have a detrimental impact on river, proposes or authorizes any fish, or wildlife. However, informal 40 C.F.R. modification of any stream or consultation with the U.S. Fish and s 6:302 (g) other water body, and adequate Wildlife Service is recommended by provision for protection of NJDEP. fish and wildlife resources.

/.aeo TOO Table 2-4 Potential Local-Specifics ARARs Page 2

Standard, Requirement, Criteria or Limitation Citation Description Status Comment

STATE ARABS Wetland Act of 1970 NJSA 13:9A-1 Listing and permit Applicable Wetlands exist near the Walklll River. et.ieo. requirements for regulated Might be applicable, depending on activities. chosen remedial alternative. Open Lands Management NJAC 7:2-12.1 Considers Impact on Applicable Applicable is Station Park was funded et.seo. recreational projects funded by Open Lands Management Grants (TBO by by Open Lands Management NJDEP). Grants.

Endangered Plant/Animal New Jersey's Threatened To Be Considered Informal consultation with U.S. Fish Species Habitats Plant/Animal Species. List of and Wildlife Service recommended by threatened habitats where they NJDEP. occur.

AOP-3S-H A. 0. Polymer Site Public Review Feasibility Study April 1991

because no other alternative is feasible, establish procedures for mitigating or repairing any resulting damage. Several location-specific ARARs are considered legally applicable and the rest are relevant and appropriate. There is also one TBC. Informal consultation with the U.S. Fish and Wildlife Service has determined that the immediate site area does not contain critical habitats of rare or endangered species. Action-specific ARARs that are pertinent to the A.O. Polymer Site are identified in Table 2-5. The action-specific ARARs generally set performance standards or permitting requirements for management, treatment, disposal, transportation or discharge of hazardous waste or waste streams. Most could be directly applicable depending on the technologies that are selected in the remedial action. 2.2.3 Remediation Goals With appropriate mitigating measures and engineering controls, most remedial actions can be designed to comply with location- or action-specific ARARs and TBCs. Thus, the action- and location-specific ARARs and TBCs may effect the cost, implementability, and/or effectiveness of specific remedial actions but have little direct relevance to remedial action objectives. These ARARs and TBCs will not be discussed in detail in this section, but will be discussed in subsequent sections of the report as they pertain to the development of remedial action objectives and the screening or evaluation of remedial technologies and alternatives. Chemical-specific ARARs can be used directly to set remedial action goals. Host of the risk due to ingestion of groundwater at the site is due to a few chemicals of concern namely tetrachloroethene, trichloroethene, 1,1- dichloroethene, and 1,2-dichloroethene all of which are represented by MCLs or MCLGs. Therefore the remediation goals or corrective action criteria for these and other contaminants will be based on MCLs. The corrective action criteria are listed in Table 2-6. State standards for soil cleanup prefer site specific risk assessment-based remediation goals. Because subsurface soil contaminants pose minimal direct contact risks, action levels based on this pathway are not applicable. However, contaminated soils do pose a continuing threat to groundwater and therefore, cleanup goals for soils should be set at levels protective of groundwater. For Teachable contaminants currently found in both groundwater and soils as well as for poorly leached soil contaminants such as PAHs which are not currently found in groundwater, the goal will be NJDEP soil action levels.

2.3 REMEDIAL ACTION OBJECTIVES > Contaminated subsurface soils in the vicinity of the former Mohawk lagoons ^ represent the most significant source of site contamination and the groundwater plume represents contamination that 1s believed to have migrated § from that area. Consistent with the NCR, remedial action objectives were •- o u> AOP-35-H 5 TABLE 2-5 POTENTIAL ACTION-SPECIFIC ARARS A.O. POLYMER FEASIBILITY STUDY

Standard, Requirement, Criteria or Limitation Citation Description Status CoMnent

FEDERAL AttAKS 40 C.F.R Establishes criteria for use Relevant/ The current subtitle D program Is RCRA Crtterta for Part 257 in determining which solid Appropriate principally aimed at municipal and Clarification of Solid Waste waste disposal facilities and Industrial solid waste. Disposal Facilities and practices pose a reasonable Practices. probability of adverse effects on health or the environment and thereby constitute prohibited open dumps. RCRA Hazardous Waste 40 C.F.R Establishes procedures and Relevant/ Creates no substantive clean-up Management Systems General Part 260 criteria for modification or Appropriate requirements. revocation of any provision in ro 40 C.F.R. Part 260-265. I RCRA Standards Applicable to 40 C.F.R Establishes standards for Applicable Treatment residuals generated by some Generators of Hazardous Waste Part 262 generators of hazardous waste. onsite treatment alternatives may be classified as RCRA hazardous waste.

RCRA Standards Applicable to 40 C.F.R Establishes standards which Applicable Applicable if alternative developed Transporters of Hazardous Part 263 apply to persons transporting would involve off-site transportation Waste hazardous waste within the of hazardous treatment residuals or U.S. if the transportation other hazardous waste. requires a manifest under 40 C.F.R Part 262

RCRA Standards of Owners and 40 C.F.R Establishes minimum national Relevant/ These regulations are appropriate for Operators of Hazardous Waste Part 264 standards which define the Appropriate any action, including disposal In a Treatment, Storage, and acceptable management of RCRA facility. Disposal Facilities hazardous waste for owners and operators of facilities which treat, store, or dispose of hazardous waste.

RCRA Land Disposal 40 C.F.R. Established a timetable for Applicable Regulates land disposal of any Part 268 restriction of burial of hazardous waste that may be generated wastes and other hazardous onsite as a result of treatment. materials.

06*0 100 AP-3S-H Table 2-5 (Continued) Potential Action-Specific ARARs Page 2

Standard, Requirement, Criteria or Limitation Citation Description Status Comment

FEpCRAL ARARS (Continued! Clean Water Act 33 U.S.C. Restriction and maintenance of Applicable Must be considered for actions which 1251 40 the chemical, physical and may affect water quality. C.F.R. biological integrity of the nation's water Effluent Limitations Section 301 Technology-based discharge Applicable Pretreatment standards may be applied limitations for point sources of groundwater discharged to Publicly- of conventional, Owned Treatment Works (POTW). nonconvent tonal and toxic pollutants. rs> i Water Quality Related Section 302 Protection of intended uses of Applicable If treated groundwater is discharged to Effluent Limitations receiving waters (e.g., public the Walkil) River. water supply, recreational uses).

Toxic and Pretreatment Section 307 Establishes list of toxic Applicable Will be applicable If groundwater Effluent Standards pollutants and promulgates discharged Into POTWs. pretreatment standards for discharge Into POTWs.

National Pollutant Section 402 Issues permits for discharge Applicable If groundwater is to be discharged to Discharge Elimination Into navigable waters. the Walktll River after treatment. System (NPOES) Only off-site discharges would be required to obtain a permit. On-site CERCLA activities are exempt from obtaining permits under SARA (Section 121).

Safe Prinking Water Act Underground Injection 40 C.F.R. Provide requirements for an Applicable Will be applicable if groundwater Is 144-147 Underground Injection Control reinjected into aquifer. (UIC) plan and establishes classification of wells.

C660 TOO dOV Table 2-5 (Continued) Potential Action-Specific ARARs Page 3

Standard, Requirement. Criteria or lint tatton Citation Description Status ent

FEDERAL AIMS (Continued) Other Occupational Safety and 29 U.S.C. ss Regulates worker health and Applicable Under 40 C.F.R. s 300.38. require* ints Health Act 651-678 29 safety. of this Act apply to all response C.F.R. 1910. activities under the NCP. 1926. 1904

Hazardous Materials 49 C.F.R. Regulates transportation of Applicable ARAR only if alternative developed Transportation Act Parts 100-177 hazardous materials. would involve transportation of hazardous materials. rs» Clean Air Act National Ambient Air 40 C.F.R. 50 Establishes discharge limits Applicable Applicable if remedial action incudes a Quality Standard for seven pollutants. technology that Mould result in air emissions.

Listing Criteria Section 112 Establishes health basis to Applicable Applicable if remedial action includes list pollutants as hazardous. a technology that would result in air emissions.

"60 100 dOV Table 2-5 (Continued) Potential Action-Specific ARARs Page 4

Standard. Requirement, Criteria or Limitation Citation Description Status Comment

STATE ARARS tContinued) Air Pollution Controls Permit Conditions Letter to Robert Amended permit conditions with Applicable Applicable If air stripping used for Palasits, respect to total flow rate, groundwater cleanup. Ellzabethtown emissions rates and testing. Water Company 6/17/85 Air Pollution Control Nemo from Milton Controls and prohibits air Applicable Applicable if air stripping used for Polakovic on air pollution, particle emissions groundwater cleanup. stripping of and VO emissions. ro contaminated water, 12/8/82. t/t Air Stripping Guidelines Memo from Criteria for air pollution Applicable Applicable if air stripping used for Assistant Corim. control requirements and groundwater cleanup. Tyler exemptions.

N.J. Air Pollution Memo from Information required for air Applicable Applicable for treatments which produce controls Regulations William pollution control permits must an air stream in need of further O'Sullivan, be submitted for review; treatment. 3/23/87 approved equipment must be used in hazardous waste site cleanups.

Air Pollution Control 2/83 - Specifies maximum air Applicable Should be considered if incineration is Guidelines for Resource Addendum contaminant emissions rates, used. Recovery Facilities and 3/1/84 testing requirements, and Incinerators minimum design standards.

£660 100 Table 2-5 (Continued) Potential Action-Specific ARARs Page 5

Standard. Requirement, Criteria or Limitation Citation Description Status Comment

Incinerator Permit Permit and Specifies requirements for Applicable Applicable for hazardous waste Conditions Certificate operating, analytical and Incinerators. No. 68326, reporting, and waste analysts Roll ins halogen limit on waste feeds, Environmental stack emission testing, Services performance standards and monitoring and Inspection requirements.

Groundwater Controls o» Groundwater Quality NJAC 7:9-6 Protection and enhancement of Applicable If treated groundwater were to be Criteria NJAC 7:14A-6.14 groundwater resources. relnjected to groundwater.

Requirements for NJAC 7:26-9 Groundwater monitoring system Applicable Applicable for any remedial alternative Groundwater Monitoring requirements. requiring groundwater monitoring.

Discharges to Surface Water New Jersey Pollutant Discharge NJAC 7:14A Issue NJPDES permits for Applicable If treated groundwater is discharged to Elimination System (NJPDES) discharge to surface water and the Walk)II River. groundwater. Water Quality Standards NJAC 7:9-4.1 Protection and enhancement of Applicable If treated groundwater is discharged to et.sea. surface water resources. the Walkill River.

Policy/Procedures for Nemo from Ed Information required for a Applicable Applicable If treated waters are Discharge to Surface Waters Post, 11/1/63 Superfund Site DSW permit. discharged to Walkill River. (DSW) from Superfund Sites Checklist for Development of Memo from Ed Consideration used in Applicable Applicable if treated waters are Best Professional Judgement Post, 3/1/83 preparing NJPDES-DSW Permit. discharged to the Walkill River. Permits

TOO dOV Table 2-5 (Continued) Potential Action-Specific ARARs Page 6

Standard, Requirement. Criteria or Limitation Citation Description Status Cement

STATF ABABS

Wastewater Discharge NJAC 7:9-5,1 HinimuM treatment requirements Applicable If treated groundwater is discharged to Requirements et.«eo. and effluent standards for the Walkill River. discharge to surface water.

New Jersey Safe NJAC 7:10 Sets standards for drinking Relevant/ Will be ARAR for water treatment Drinking Water Act water including MCLS, Appropriate standards if more stringent than the disinfection requirements, federal MCLs.12 secondary drinking water regulations and monitoring requirements. I •—• •-J Other Emergency Response NJSA 26:2019 Control exposure to air Applicable ARAR for any technology having Notice of Release of Hazardous pollution by immediate potential for an air release incident. Substance to Atmosphere notification to the department hotline of any air release incident. Water Pollution Control NJAC 7:21(E) Immediate notification of any Applicable ARAR for any technology having spill of hazardous substances. potential for a spill of a hazardous substance.

Air Pollution Control NJAC 7:27 Lists requirements for control Applicable ARAR for any technology causing air of air pollution. emissions. Noise Control Act NJSA 13:16-1 Prohibits and restricts noise Applicable ARAR for any/all remedial activities. et.seo. which unnecessarily degrades the quality of life.

Noise Pollution NJAC 7:29-1 Sets maximum limits of sound Applicable ARAR for any/all remedial actions. from any industrial, comnercial, public service or conmunity service facility.

S660 100 Table 2-5 (Continued) Potential Action-Specific ARARs Page 7

Standard. Requirement, Criteria or limitation Citation Description Status ent

STATE MARS (Continued! Well Drilling and Sealing and Pu Installation General Requirements for NJAC 7:9-7 Regulates permit procedures, Applicable Applicable If additional wells need to Permitting Wells general requirements for be constructed for extraction or drilling and installation of reinjection of water. wells, licensing of Hell driller and pump installer, construction specifications, and well casing.

Sealing of Abandoned NJAC 7:9-9 General requirements for Applicable Applicable If old wells need to be Wells sealing of all wells (e.g., sealed. single cased, multiple cased, CO hand dug, test wells, boreholes and monitoring wells, abandoned wells).

Well Drillers and Pump NJSA M:4A-5 Well drillers licensing, Applicable Applicable If additional wells need to Installers Act et.seu. supervision, inspection and be constructed for extraction of water. sampling. .

Soil Decontamination Permit Requirements Proposed permit requirements Applicable Applicable for soils containing Conf. Terra-Vac for portable soil volatile organics. Corp. (memo from decontamination operations. Joel Leon, 12/2/86)

96*0 TOO dOtf A. 0. Polymer Site Public Review Feasibility Study April 1991

TABLE 2-6 GROUNDWATER REMEDIATION GOALS (a) A.O. POLYMER SITE FEASIBILITY STUDY

Contaminant Groundwater Cleanup Objective (ng/1)

Chloroform 5 1,1-dichlorethene 2 1.1-dichlorethane * Tetrachloroethene 1 1.2-dichlorethene 10 1,1,1-Trichlorethene 26 Trichloroethene 1 Benzene 1 Chlorobenzene 4 Toluene * Ethyl benzene * Xylene 44 Acetone * 2-Butanone * 4-Methyl-2-Pentanone * Phenol * Bis(2ethylhexyl)phthalate 5

Notes: (a) NJDEP Corrective Action Criteria. * Sum of these must be less than 50 pg/1.

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AOP-35-H 2-19 A. 0. Polymer Site Public Review Feasibility Study April 1991 developed for both source control (SC) and management of migration (MM) remedial actions. 2.3.1 Source Control Objectives The soil contamination address under source control is considered an operable unit and is defined as the contaminated subsurface soil in the area of the former disposal lagoons, from approximately 9 feet below the ground surface down to groundwater at approximately 25 feet below the ground surface. The contaminants of concern included the Teachable volatile organics presently posing the most risk in groundwater. These primarily include halogenated aliphatic hydrocarbons however monocyclic aromatic chemicals, phenols an d PAHs were also found in smaller concentrations. Since the contaminated soil is at least 2 feet below the ground surface, there is little risk of a direct contact hazard. Howev-^ the soil probably contributes to groundwater contamination by leach: -3 of soluble contaminants. Therefore, the following source control response objectives have been identified: o Eliminate or minimize leaching of contaminants from the soil to ensure adequate protection of groundwater against the continued release of contaminants from the contaminated soil. o For Teachable contaminants, the remediation goal will be to clean up the soil to levels protective of groundwater. For non- Teachable contaminants the goal will be to comply with NJOEP soil action levels and, other guidance regarding soil cleanup levels.

2.3.2 Managemen•"•»—^Mt -_ . ofI^^^____^___ MigratioM - n Objective- B_ftb^l. I _^As ^_ Based on results :f the RI, compounds from the "source", as defined above, have created a plume of contaminated groundwater in the water table aquifer. The plume follows groundwater flow patterns from the source and discharges to the Wall kill River. The RI determined that the maximum lateral extent of the groundwater plume has been reached, and that the leading edge of the plume is intercepted by the Wallkill River. Contamination appears to be limited to relatively shallow portions of the water table aquifer. Contaminants of concern in groundwater at the site are primarily volatile organics, including PCE, TCE, TCA, monocyclic aromatics, and ketones. Base- neutrals, such as phenols and phthalates are also present, but in smaller concentrations. Inorganic contamination is not a concern at the site, because inorganic concentrations in groundwater did not exceed expected background levels for groundwater. Potentially unacceptable human health risks have been identified based on potential ingestion of contaminated groundwater. However the plume potentially poses other borderline risks which may compound the risk. > Therefore, the following management of migration response objectives have been TJ identified: o o Ensure adequate protection of human health from potential 2 Ingestlon of contaminated groundwater. o V u. AOP-35-H 2-20 <3°'~~ A. 0. Polymer Site Public Review Feasibility Study April 1991

Restore contaminated groundwater for potential future use by reducing contaminant levels in the area of the plume to levels established by chemical-specific ARARs and TBCs. Comply with other ARARs and TBCs regarding treatment or discharge of contaminated groundwater.

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VO AOP-35-H 2-21 Section 3

001 1000 A. 0. Polymer Site Public Review Feasibility Study April 1991

3.0 IDENTIFICATION AND SCREENING OF REMEDIAL TECHNOLOGIES This section presents the identification and screening of potentially applicable remedial technologies for addressing contamination in soil and groundwater at the A. 0. Polymer Site. Each potentially applicable remedial technology identified is evaluated based on effectiveness and implementability criteria. The remedial technologies that remain following this screening are assembled in Section 4.0 of this report into an array of remedial alternatives to address public health and environmental risks at the site. General response action categories are Identified in Section 3.1 Section 3.2 presents the methodology used to evaluate and screen remedial technologies. Section 3.3 presents identification and screening of groundwater remedial technologies, and Section 3.4 presents identification and screening of soil remedial technologies. Section 3.5 summarizes remedial technology screening results for groundwater and soil. 3.1 GENERAL RESPONSE ACTIONS Remedial technologies are categorized in terms of general response actions. General response actions are broad categories of remedial approaches capable . of addressing contamination problems at the site. The response actions include: o No Action with Institutional Controls o Containment o Removal o Treatment o Disposal A general discussion of the types of technologies included in each general response action category is presented below: 3.1.1 No Action with Institutional Controls NCP regulations and CERCLA as amended require the evaluation of a no action alternative as a basis of comparison with other remedial alternatives. Because no-action technologies result in contaminants remaining onsite, CERCLA as amended requires a review of the site every five years. The institutional controls associated with the no action alternative may reduce potential hazards by reducing exposure to the chemicals causing the hazards. Institutional control measures may Include control of site access, public awareness and education programs, restrictions on groundwater usage, or warnings against excavation and use of soil in the area. Monitoring technologies are implemented to provide a data base to evaluate changes in site conditions and to monitor potential risks over time. Monitoring technologies will provide significant Information for the required five-year reviews.

AOP-35-H 3-1 A. 0. Polymer Site Public Review Feasibility Study April 1991

3.1.2 Containment Containment technologies control potential hazards by eliminating routes of exposure or reducing the rate of exposure to acceptable risk levels through Isolation. Containment technologies nay reduce contaminant movement, but do not reduce the toxicity or volume of contaminants at the site. These technologies require perpetual monitoring to determine whether containment measures are performing successfully. Under CERCLA as amended, reevaluation of containment options 1s also required every five years. 3.1.3 Removal Removal technologies for solids refer to methods used to excavate and handle soils, wastes, and other solid materials. Removal technologies for groundwater refer to methods used to collect or extract groundwater. Removal technologies provide no reduction in toxicity or volume of wastes, but may be used in conjunction with treatment or disposal technologies. Removal technologies may also be used to reduce migration, as in gradient control. 3.1.4 Treatment Treatment technologies reduce the volume, toxicity, or mobility of contaminants by biological, physical, thermal, or chemical processes. Treatment to reduce volume Includes concentrating contaminants. Treatment to reduce toxicity Includes methods to destroy or modify the properties of the chemical to render it less harmful. Treatment may include methods to modify the physical or chemical properties of the waste to reduce mobility. CERCLA as amended favors use of treatment technologies to achieve remedial objectives, unless site conditions limit their application. 3.1.5 Disposal Disposal technologies are designed to designate the final resting place for treated or untreated waste or waste residuals. Remedies requiring the onsite or offsite disposal of wastes can only be implemented if that waste 1s disposed in a facility operating in compliance with Sections 3004 and 3005 of the Solid Waste Disposal Act.

3.2 REMEDIAL TECHNOLOGY SCREENING Screening of remedial technologies 1s used to select those that are most appropriate to remediate the contamination problems at the A. 0. Polymer Site. This screening process evaluates the relative effectiveness, Implementabillty, and, in some cases, cost of the technologies. The purpose of technology screening 1s to Identify technologies which are not effective or are not > implementable at the site, and eliminate them from further consideration. o The remedial technologies retained following this screening will be used in developing remedial alternatives 1n subsequent sections of this report. 0

AOP-35-H 3_2 § A. 0. Polymer Site Public Review Feasibility Study April 1991

Each remedial technology or process option 1s screened individually in a process where the screening criteria are ranked 1n order of relative importance, as described below. The effectiveness and implementabil ity of each technology or process option is evaluated, and technologies judged to be inferior in meeting effectiveness and implement ability criteria are eliminated from further screening. Technologies which are judged similar using the effectiveness and implementabil ity criteria are subjected to screening using the cost screening criteria. Effectiveness screening criteria that will be used Include: 1. The reliability in meeting target clean-up levels, or in achieving response objectives related to public health and welfare, or the environment. Technologies that do not achieve target clean-up levels, or that do not effectively contribute to the protection of public health, welfare, or the environment at the site will not be considered further. 2. The degree of permanent reduction in toxicity, mobility, or volume of site contaminants achieved by the technology. Technology types and process options that permanently reduce toxicity, mobility, or volume will be preferred over those that do not provide these benefits or the same degree of benefit. 3. The long-term risks and liability due to treatment residuals or containment systems. Technology types and process options that have significantly lower long-term risks and liability will be preferred. 4. The risks to the public, workers, or the environment during implementation. Technologies posing significantly smaller adverse risks during implementation will be preferred. Implementabil ity screening criteria that will be used include: 1. The site characteristics limiting the construction or effective functioning of the technology. Technologies that are limited by site conditions to a degree that their effective functioning is seriously impaired will be eliminated. 2. Waste or media characteristics that limit the use or effective functioning of the technology. Technologies that are limited by waste or media characteristics to a degree that their effective functioning 1s seriously Impaired will be eliminated. 3. The availability of equipment needed to Implement the technology or the capacity of offslte treatment or disposal facilities needed to remediate the site. Technologies that are commercially developed and readily available will be given preference.

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AOP-35-N ,3 A. 0. Polymer Site Public Review Feasibility Study April 1991

Cost screening criteria Include: 1. Relative magnitude of capital and operation and maintenance costs when evaluating comparable technologies. Technologies with lower order-of- magnitude capital and operation costs will be preferred if the effectiveness and implementability criteria are judged similar. A range of technologies have been Identified for addressing soil and groundwater contamination problems at the site. Some remedial technologies contain one or more process options within the technology type. The technologies and process options within the technology type. The technologies and process options are evaluated and screened in the following sections. Groundwater technology 1s presented In Section 3.3, and soil technology screening is presented 1n Section 3.4.

3.3 IDENTIFICATION AND SCREENING OF GROUNDMATER REMEDIAL TECHNOLOGIES In this section, potentially applicable technologies for the remediation of groundwater contamination at the A. 0. Polymer Site are Identified. The applicability of a technology to the site 1s evaluated by considering the site remedial response objectives, characteristics of the groundwater contamination, site hydrogeology, and other specific site conditions. The technology identification process produced a number of technologies and process options which are potentially applicable to address the contaminated groundwater at the A. 0. Polymer Site. The applicable technologies, as well as the available process options within the technology type are summarized in Table 3-1. Contaminated groundwater at the site has been found in the water-table aquifer. Contamination appears to be limited to relatively shallow portions of the water-table aquifer. The remedial investigation determined that the maximum lateral extent of the groundwater plume has been reached, and that the leading edge of the plume is Intercepted by the Wallkill River. The pattern of groundwater contamination Indicates that the most likely source of a majority of the groundwater contamination 1s residual subsurface contamination of the soil beneath the former Mohawk disposal lagoons. Contaminants of concern in groundwater at the site are primarily volatile organics, Including PCE, TCE, TCA, BTEX, and ketones. Base-neutrals, such as phenols and phthalates are also present, but in smaller concentrations. Inorganic contamination 1s not a concern at the site, because Inorganic concentrations in groundwater did not exceed expected background levels for groundwater. > c In the following sections, specific remedial technologies and process options v for addressing groundwater contamination at the A. 0. Polymer Site are 0 described and are screened by evaluating their effectiveness and 3 Implementability at the site. Whenever possible, one process option within each technology type is selected to represent that technology type. M o o AOP-35-N TABLE 3-1 IDENTIFICATION OF POTENTIAL GROUNOWATER REMEDIATION TECHNOLOGIES A. 0. POLYMER FEASIBILITY STUDY

General Response Action Remedial Technology Process Option

No Action with Groundwater Use Restrictions Institutional Controls Groundwater Monitoring Containment Subsurface Barriers Slurry Walls Removal Groundwater Extraction Extraction Wells Collection Trenches

w Treatment Physical Treatment Air Stripping/Steam Stripping iin Activated Carbon Adsorption Filtration Precipitation Biological Treatment In-Situ Biological Aerobic Biological Anaerobic Biological Chemical Treatment Reduction Oxidation UV/Oxidation Thermal Treatment Wet Air Oxidation Disposal/Discharge Ons He Discharge to Surface Water Discharge to Wetlands Discharge to Recharge Basin Groundwater Reinjection Offsite Discharge to POTW soot too A. 0. Polymer Site Public Review Feasibility Study April 1991

3.3.1 No Action with Institutional Controls Technologies - Groundwater The minimal action general response category for groundwater includes actions such as restrictions on future groundwater use and groundwater monitoring. Groundwater Use Restrictions This action would require that all deeds for property within the contaminated plume area include permanent restrictions on the use of groundwater and the drilling of new wells. Effectiveness There are currently no human health risks associated with ingestion of groundwater, since the contaminated zone of the aquifer is not currently being used as a drinking water supply at the site. Since human health risks are Identified based only on potential future use, restrictions on future groundwater use could be effectively used to manage long-term risks associated with ingestion of contaminated groundwater. Public awareness and education programs could also be implemented in conjunction with the restrictions on future groundwater use. Obviously, target cleanup levels for groundwater will not be met by this technology, and groundwater use restrictions will not reduce toxicity, mobility, or volume of contaminated water. However, response objectives related to public health may be met by Implementing groundwater use restrictions as long as the restrictions are strictly enforced. ImplementabiHty Groundwater use restrictions are easily implemented through deed restrictions or other institutional controls, but are only effective if properly enforced. Conclusion Groundwater use restrictions should be Implemented at the site until the contaminated groundwater at the site 1s remediated either through extraction and treatment or natural attenuation. Groundwater use restrictions will not meet target cleanup levels for groundwater; however, they are effective in managing long-term public health risks as long as the restrictions are strictly enforced. They may be applied alone or in conjunction with other technologies, and will be maintained for further consideration in developing remedial alternatives. Groundwater Monitoring >o Groundwater monitoring would Include periodic sampling and analysis of ^ existing and/or new groundwater monitoring wells. 0

o AOP-35-H A. 0. Polymer Site Public Review Feasibility Study April 1991

Effectiveness Groundwater monitoring technology is not effective in meeting target cleanup levels for groundwater, in achieving response objectives, or in reducing toxicity, mobility, or volume of contaminants. However, groundwater monitoring is required to track the contaminant plume and to evaluate the progress and effectiveness of any groundwater remediation that is implemented at the site. If no groundwater remediation is implemented, groundwater monitoring at hazardous waste sites Is usually conducted for at least 30 years to determine whether contaminant concentrations have decreased to safe levels through natural flushing and/or attenuation. Implementability Groundwater monitoring is easily implemented, but would require long-term management efforts. Conclusion Groundwater monitoring is effective in tracking the contaminant plume and in evaluating the effectiveness of groundwater remediation efforts. It will be - maintained for further consideration in developing remedial alternatives. 3.3.2 Containment Technologies - Groundwater The containment general response category for groundwater includes subsurface barriers such as slurry walls to control groundwater flow. Surface capping, which could be considered a groundwater containment technology, is evaluated under soil containment technologies in Section 3.4.2. Slurry Walls Subsurface barriers constructed of low permeability material have been used on many sites to control groundwater movement. Vertical barriers control groundwater by restricting movement across the barrier. The slurry wall is constructed by backfilling an excavated trench with bentonite slurry. Effectiveness Slurry walls are not effective in meeting target cleanup levels for groundwater, in achieving response objectives, nor in reducing toxicity, or volume of contaminants. Generally, the purpose of slurry walls is to reduce contaminant migration by controlling groundwater movement. Slurry wall containment systems are effective in controlling groundwater movement only if the bottom of the slurry wall Intersects a natural zone of low permeability. Since the bedrock at the A. 0. Polymer Site 1s highly fractured, and no natural zone of low permeability exists at the site, slurry walls would not be very effective in containing or controlling groundwater flow.

o o AOP-35-M A. 0. Polymer Site Public Review Feasibility Study April 1991

Slurry walls have been used at some sites upgradient of the source, to reduce groundwater flow through the source and subsequent leaching of contaminants Into the groundwater. Since the contaminant source at this site Is located in the vadose zone (above the groundwater table), the groundwater 1s not in contact with the source. Therefore, slurry walls could not be applied at this site to reduce groundwater flow through the source. t ability Construction of slurry walls at the site 1s feasible. Conclusion Slurry walls would not function effectively in controlling groundwater flow at this site since the bedrock is highly fractured a*-d there is no natural confining layer to key the wall into. Since the source at this site 1s above the water table, the use of slurry walls to reduce groundwater contamination by reducing groundwater flow through the source does not apply. Therefore, slurry walls will not be retained for further consideration in developing remedial alternatives. 3.3.3 Removal Technologies - Groundwater Subsurface collection trenches and/or extraction wells may be used to control groundwater movement or to collect groundwater at the site for subsequent treatment. Subsurface trenches may also function to recharge treated water into the groundwater system for disposal or to help control migration of groundwater during the extraction period. Extraction Wells Extraction well systems consist of one or more pumping wells which are used to remove water from a contaminated groundwater plume. Effectiveness Extraction wells are not effective In meeting target cleanup levels for groundwater, or 1n reducing toxicity or volume of contaminants. In general, the purpose of extraction wells is to collect contaminated groundwater for subsequent treatment or disposal. Extraction wells are most effective in hydrogeologlc formations with high rates of transmissivity. The contaminated aquifer at the A. 0. Polymer site consists mostly of glacial outwash deposits which have relatively high transmissivity rates and are conducive to groundwater pumping. Extraction wells systems are well -developed and very reliable in collecting groundwater. £ >n Iip1enentab1l1ty o Construction of extraction wells 1s a standard procedure using readily *- available equipment, and could be easily Implemented at the site. ^_i o AO-3S-H ° A. 0. Polymer Site Public Review Feasibility Study April 1991

Potentially, existing monitoring wells could be used as part of a groundwater extraction system. Conclusion Extraction wells are more effective and more efficient than collection trenches in collecting groundwater In the hydrogeologic conditions found at the A. 0. Polymer Site. Therefore, collection trenches will be eliminated rom further consideration, and extraction wells will be retained as a representative groundwater extraction technology for development of remedial alternatives. 3.3.4 Treatment Technologies - Groundwater Contaminants of concern in groundwater at the site are primarily volatile organics, including PCE, TCE, TCA, BTEX, and ketones. Base-neutrals, such as phenols and phthalates are also present in smaller concentrations. A number of treatment technologies are applicable to the contaminants of concern in the groundwater. These contaminants may require the application of several technologies to reduce the contaminant concentrations to the required discharge levels. Potentially applicable treatment technologies for groundwater include: Physical Treatment: air stripping, steam stripping, activated carbon adsorption, filtration, precipitation Biological Treatment: in-situ biological, aerobic, anaerobic Chemical Treatment: reduction-oxidation, ultraviolet (UV) oxidation Thermal Treatment: wet air oxidation. Some available water treatment technologies are not applicable to the contaminated groundwater at the Site, and are not considered in the screening process. These technologies Include: 1) reverse osmosis, which is used for treatment of brackish waters or aqueous metal wastes, 2) oil/water separation, which is used for oily water, and 3) ion exchange, which is used to treat metals in solution. Air Stripping or Steam Stripping Air stripping and steam stripping are mass transfer processes in which volatile contaminants in water are transferred to the gaseous phase. This > process works best on contaminants with high volatility and low solubility. o

Effectiveness o_ o Air stripping is an effective and reliable technology for removing aromatic ^ and chlorinated aliphatic hydrocarbons from groundwater. The ketones that are ^ o o

MP-3S-H •» n A. 0. Polymer Site Public Review Feasibility Study April 1991 present in the site groundwater are more difficult to remove by air stripping, but may be effectively removed by steam stripping. iBplementabinty Air stripping and steam stripping are commercially available technologies, and could feasibly be Implemented at the site. One potentially limiting factor in the use of air or steam stripping is the problem of off-gases. Since the stripping process transfers contaminants from water to air, off-gas treatment may be required. Generally, vapor-phase carbon or catalytic converters are used to treat off-gas. Off-gas treatment adds cost and complexity to the operation of packed-tower air stripping facilities. Another potentially limiting factor 1s the precipitation of iron, which may clog the packing and result in the need for frequent acid washing of the tower. Long-term management of the stripping unit and the associated water treatment system would be required to insure the continued operating efficiency of the system. Conclusion Air stripping and steam stripping are effective and reliable technologies for removing certain types of organic contaminants from waste water, and can be effectively used as part of a complete water treatment system. They will be retained for further consideration in developing remedial alternatives. Activated Carbon Adsorption Carbon adsorption removes organics from aqueous waste via surface attachment (adsorption) of organic solutes onto the surface area of activated carbon. This technology is applicable for organic waste streams with high molecular weights and boiling points, low solubility and polarity, and relatively non- polar chlorinated hydrocarbons and aromatlcs. Carbon adsorption can treat concentrations up to 10,000 ppm; however, it 1s often more cost-effective to pretreat water using another method, and use activated carbon as a polishing step. Activated carbon treatment works best for aqueous streams with suspended solids less than 100 ppm and oil and grease contents of less than 10 ppm. Pretreatment may be necessary or desirable when these criteria are exceeded. Effectiveness > Carbon adsorption 1s a well-developed and proven technology for removing g certain types of organics from waste water. It readily adsorbs aromatic compounds (those based on a benzene ring structure) and chlorinated o aliphatics, both of which are present In the site groundwater. It also 2 removes pesticides, herbicides, and even mercury and radon. However, low molecular weight compounds such as aliphatics, ketones, adds, aldehydes, and »- alcohols are poorly adsorbed. The ketones, which are contaminants found in 2 o

AOP-35-M A. 0. Polymer Site Public Review Feasibility Study April 1991 the groundwater at the A. 0. Polymer Site are not treated effectively with carbon adsorption. Implementability Carbon adsorption is a commercial technology which is readily available, and could be easily implemented at the site. If the water contains suspended solids, the carbon unit needs to be backwashed when head loss builds up to the maximum desired value. In addition, the activated carbon must be replaced when the organic removal capacity of the carbon is exhausted. Monitoring of the effluent is required to determine when the adsorption capacity of the carbon has been exhausted. Regeneration or disposal of exhausted carbon is required. Long-term management of the carbon unit and the associated treatment system would be required to insure the continued operating efficiency of the system. Conclusion Carbon adsorption is an effective and reliable technology for removing some types of organics form waste water, and it can be effectively used as part of. a complete water treatment system. It will be retained for further consideration in developing remedial alternatives. Filtration Filtration is used to remove suspended solids from water, usually as a pretreatment to other treatment processes, such as air stripping, carbon adsorption, or ultraviolet oxidation. A number of filtration options are available, including cartridge filters, bag filters, or granular media (sand) filters. Solids collected in the filter must be treated or disposed. Effectiveness Filtration is a commonly used and reliable method of removing suspended solids from groundwater. Filtration may also remove metals which are adsorbed onto suspended solids. Filtration does not remove dissolved organic contaminants from groundwater, but Is effective as a pretreatment for other treatment processes. Implementability Filtration is commercially available and would be easily implemented in conjunction with an onsite water treatment system. Conclusion Filtration is an effective and reliable technology for removing suspended solids from water as pretreatment step in a complete water treatment system. It will be retained for further consideration in developing remedial alternatives.

AOP-35-H 3-11 A. 0. Polymer Site Public Review Feasibility Study April 1991

Precipitation Precipitation 1s a physicochemical process that 1s used to remove metals from an aqueous stream. When used prior to other treatment technologies, this process reduces the problems of reduced efficiency and operational difficulties that can result from incidental precipitation of dissolved metals. For example, iron may exist in groundwater as the more soluble Fe*2 species but may be oxidized to the less soluble Fe during aeration in a air stripping process, resulting in formation of a solid Iron oxyhydroxide precipitation which may "plate" onto the stripping tower or packing material, or may cause clogging of activated carbon units. Thus, removal of possibly interfering substances such as iron by utilizing precipitation as a pretreatment can be very Important to the overall operating efficiency of a treatment system that utilizes several unit processes in series. Effectiveness Precipitation is a commonly used and reliable method of removing dissolved metals from water. Metals are not considered to be a groundwater contaminant at the A. 0. Polymer Site; however, removal of Interfering dissolved metals 1s effective as a pretreatment for other treatment processes. Implenentabinty Precipitation may Involve several steps, including 1) an oxidation/reduction step in which the metal ion to be precipitated is adjusted to the correct valence state for the precipitation reaction, 2) a pH adjustment step to optimize the precipitation process, 3) additional of a precipitating agent (most commonly hydroxide or sulfide), 4) coagulation/flocculatlon/ sedimentation to remove the metal precipitate from suspension (granular media filtration or pressure filtration may be substituted for this process). The order of these steps may vary according to the specific precipitation process being employed. Precipitation generates a seal-solid metal sludge as a by-product. This sludge is likely to be considered hazardous, especially if toxic metals are present in the waste stream being treated. TCLP testing is required to determine if the sludge 1s hazardous. The sludge will require dewatering using a filter press, and subsequent offsite disposal. Conclusion Precipitation 1s an effective and reliable technology for removing dissolved metals from water. Hetals are not considered to be a groundwater contaminant at the A. 0. Polymer Site; however, removal of possibly interfering substances ^ such as iron by utilizing precipitation as a pretreatment can be very o Important to the overall operating efficiency of a treatment system that *° utilizes several unit processes in series. Precipitation will be retained for o further consideration In development remedial alternatives. o

MP-35-H 3-12 A. 0. Polymer Site Public Review Feasibility Study April 1991

Ifl-Siiu Biological Treatment Biological treatment, the microbial degradation of organic compounds, has been widely used to remove organic chemicals from ater. The microbial degradation of organics transforms organic carbon to inorganic carbon dioxide through enzymatic oxidation. End products produced by aerobic degradation are usually carbon dioxide and microbial biomass. In-site biological treatment of groundwater 1s Implemented by stimulating biological activity through enrichment with appropriate nutrients (nitrogen and phosphorous) and by increasing oxygen transfer (oxygen 1s usually introduced as a solution of hydrogen peroxide) within the saturated zone of the contaminated aquifer. This process 1s usually used to enhance or speed up aquifer reclamation, and is not meant to be used alone to remediate the aquifer. In-situ biological treatment is implemented in conjunction with a groundwater extraction and treatment system. Groundwater is withdrawn from the formation and is treated to remove contaminants, and then a portion of the water is amended with nutrients and hydrogen peroxide, and is reinjected into the aquifer. Effectiveness Simple aromatic hydrocarbons and ketones, all of which are present in the site groundwater, are generally readily degradable to carbon dioxide and water. Polyaromatics (not present In site groundwater) are degraded very slowly. The extent to which a compound is degradable also depends on the degree to which it is halogenated. Halogenated (chlorinated) hydrocarbons such as chloroform, carbon tetrachloride, tetrachloroethylene, trlchloroethylene, and dichloroethylene, all of which are present 1n the A. 0. Polymer groundwater, degrade more slowly and may produce by-products of partial degradation which can be equally toxic or more toxic than the parent compounds. For example, the partial degradation of trichloroethene results in the formation of vinyl chloride, which is known to be more toxic than it's parent compound. In-situ biological treatment of the contaminated aquifer degrades the organic contaminants and ultimately reduces the volume and toxicity of the organic contamination. There is not a high degree of reliability in achieving required clean-up levels when using in-situ biological treatment alone. However, this process may be used in combination with other treatment technologies to enhance or speed up aquifer reclamation. Implementab1l1ty The technology used to Implement the desired biological reaction in groundwater (amending treated water with nutrients and hydrogen peroxide), 1s o well-developed and easily Implemented. However, reinjection of the treated o water presents certain problems. Freezing of reinjection piping 1s a problem in the winter. Other potential problems with reinjection include sand

AOP-3S-M 3-13 A. 0. Polymer Site Public Review Feasibility Study April 1991 clogging due to chemical precipitation or suspended sol Ids, dead spots, and air locks. Conclusion Simple aromatic hydrocarbon and ketones, all of which are present in the site groundwater, are generally readily biodegradable. However, the reliability of 1n-situ biological treatment in achieving target clean-up levels for these compounds 1s relatively low. In addition, partial degradation of some halogenated compounds may produce more toxic compounds. Therefor, in-situ biological treatment will be eliminated from further consideration. Aerobic Biological Treatment Aerobic biological treatment, the microbial degradation of organic compounds in the presence of oxygen is the most «ide1y used biological process. The microbial degradation of organics transforms organic carbon to inorganic carbon dioxide through enzymatic oxidation. Aerobic degradation produces carbon dioxide and microbial blomass (sludge) as byproducts of the degradation process. The sludge will require subsequent treatment or disposal. Aerobic process options include activated sludge, trickling filters, rotating biological contact (RBC) reactors, and powdered activated carbon treatment (PACT). Activated sludge is the term generally used to denote an aerobic flocculent slurry of microorganisms which remove organic matter from waste water and are then removed themselves through sedimentation. A trickling filter is a packed tower, fixed film reactor. Based on their ability to reduce the waste concentration at a relatively low operating cost, many filters have been used as a pretreatment step preceding other biological treatment processes. The waste water turns in a thin sheet over the packing material upon which a microbial film is growing. Rotating biological contact reactors (RBCs) are similar to trickling filters and utilize fixed f1l» biological processes to remove soluble organic chemicals. Powdered activated carbon treatment (PACT), an innovative biological approach, utilizes activated sludge in conjunction with powdered activated carbon. Powdered activated carbon 1s added to the aerator of the activated sludge system. Many compounds are adsorbed on the carbon which 1s removed and recycled along with the blomass in the clarifier. As the compounds adsorbed to the activated carbon are recycled with the sludge, they have a much longer system detention time, allowing a greater degree of biological degradation. Sludge generated by this process can either be dewatered and disposed or can be regenerated using wet oxidation.

AOP-35-H A. 0. Polymer Site Public Review Feasibility Study April 1991

Effectiveness Aerobic treatment may be applicable to some of the organ ics present in the groundwater at the site; however, many chlorinated compounds (trichloroethene, tetrachloroethene, etc.) are not readily biodegradable. Biological treatment is effective for some of the ketone compounds, which are not treatable by other treatments such as air stripping or carbon adsorption. Although the biological oxygen demand (BOD) was not measured for the A. 0. Polymer groundwater, based on the low concentrations of organics found in the groundwater, it is unlikely to be greater than 50 ppra. A minimum of 50 ppm BOO is generally required in order to maintain a microbial population; however waste water with lower BOO can be treated by seeding the bioreactor periodically with microbes and by adding nutrients to support the microbial population. Implementability Mobile biological treatment units are commercially available. Spent biomass (sludge) may require additional treatment or offsite disposal. Long-term management of the biological treatment unit and the associated pumping system would be required to insure the continued operating efficiency of the system. Conclusion Aerobic biological treatment 1s not effective for the chlorinated compounds (trichloroethene, tetrachloroethene, etc.), which are not readily biodegradable. However, it 1s effective in removing ketones as well as some monocyclic aromatics in the site groundwater. Since ketones are difficult to remove using any other types of treatment, aerobic biological treatment will be retained for further consideration in the development of groundwater treatment alternatives. Anaerobic Biological Treatment Anaerobic biological treatment, the microbial degradation of organic compounds in the absence of oxygen, 1s best suited as a pretreatment step for wastes containing more than 4000 ppm COO. Anaerobic microorganisms responsible for contaminant degradation produce methane and carbon dioxide as byproducts of the degradation process.

Effectiveness o> *a Anaerobic systems are capable of breaking down more halogenated compounds than aerobic bi ©degradation; however, they are not as reliable as aerobic systems. o Anaerobic degradation is much slower than aerobic degradation; detention times 2 are often on the order of one to five days, resulting in a need for large treatment tanks if substantial flows are anticipated. Anaerobic biological >-

AOP-35-M 3-15 A. 0. Polymer Site Public Review Feasibility Study April 1991 treatment 1s More applicable to treatment of organic sludge than to groundwater treatment. iMplenentabinty The technology for anaerobic biological treatment 1s well-developed and easily Implemented. Anaerobic systems are widely used 1n Industry to treat uniform, concentrated biodegradable aqueous waste due to the relatively low cost, low sludge production,a nd production of usable methane. However, application to variable waste streams typically associated with groundwater treatment is relatively Infrequent since anaerobic systems are more prone to upset due to variations in waste stream characteristics than aerobic systems. Conclusion Anaerobic biological treatment is more applicable to treatment of organic sludge than to groundwater treatment. Also, anaerobic treatment systems are prone to upset with variable waste streams. Therefore, anaerobic treatment is eliminated from further consideration 1n the development of remedial alternatives for groundwater treatment. Chemical Reduction-Oxidation Chemical reduction-oxidation (REOOX) reactions involve the chemical transformation of reactants in which the oxidation state of one reactant is raised while the other is lowered. The process destroys or reduces the toxicity of many toxic organics. The process involves mixing an oxidizing or reducing agent with the contaminated water in a mixing tank and allowable adequate time for the oxidation reaction to occur. To ensure a complete reaction between the reactants and the oxidizing or reducing agent, certain operating parameters including pH, chemical additions, mixing, and contact time must be carefully controlled. Oxidation-reduction potential (ORP) electrodes are used to monitor the progress of the reaction. Ultraviolet (UV) oxidation 1s also a form of chemical oxidation, but 1s discussed separately In the next section. Effectiveness Chemical reduction 1s used primarily to treat various metal ions. Reduction is not generally used 1n application Involving organics. Chemical oxidation has been used for treatment of various oxidizable organics Including aldehydes, mercaptans, phenols, benzidine, and other substances. •> However, the presence of a wide range of contaminants may complicate the ^ process and produce unwanted side effects. For example, partial degradation of trlchloroethene results 1n the formation of vinyl chloride, which 1s known <=> to be more toxic than it's parent compound. Also, chlorinated hydrocarbons 2 can degrade to chlorine in the form of hydrochloric add or chlorine gas. M O AOP-35-H % A. 0. Polymer Site Public Review Feasibility Study April 1991

Imp1e»entab1l1ty The equipment required for reduction-oxidation treatment is well-developed and readily available; however, implementation of oxidation-reduction 1s complex. Each system must be specifically designed for a particular application. The presence of a wide range of contaminants and waste stream variability complicate the process. Laboratory and or pilot scale testing are essential to determine chemical feed rates, reactor retention times, and to evaluate the effects of oxidation of waste streams with a wide range of organic contaminants. Conclusion Reduction-oxidation 1s not applicable and 1s not recommended for treatment of contaminated groundwater at A. 0. Polymer. The reactions are difficult to control, particularly for variable waste streams or waste streams with a wide range of organic compounds. In addition, oxidation of chlorinated hydrocarbons can result in the production of unwanted by-products of the reactions, such as vinyl chloride. Reduction-oxidation is eliminated from further consideration in the development of groundwater treatment alternatives. Ultraviolet (UV1 Oxidation UV Oxidation, a form of chemical oxidation, is an emerging technology for cleanup and destruction of organlcs In groundwater. Commercial applications using hydrogen peroxide and ozone as the oxldant have been developed. In this process, ultraviolet light reacts with hydrogen peroxide and/or ozone molecules to form hydroxyl radicals. These very powerful chemical oxidants then react with the organic contaminants in water. In addition, many organic contaminants absorb ultraviolet light and become more reactive with the chemical oxidants. If carried to completion, the end products of the oxidation process are carbon dioxide, water, and any other oxidized substances associated with the original organic wastes (e.g., organic sulfides would be oxidized to produce carbon dioxide, water, and sulfate ions). Effectiveness UV/Oxidat1on 1s very effective in oxidizing a variety of chlorinated and aromatic hydrocarbons. Ketones can be oxidized to varying degrees. For example, MEK can be oxidized, but acetone 1s more difficult to oxidize. § However, acetone 1s less toxic than other ketones and is easily biodegradable. ^ o As in chemical oxidation, the presence of a wide range of contaminants may o complicate the process and produce unwanted side effects. For example, the partial degradation of trichloroethene results in the formation of vinyl chloride, which is known to be more toxic than its parent compound.

AOP-35-M 3-17 A. 0. Polymer Site Public Review Feasibility Study April 1991

The system may or may not be able to achieve cleanup levels for groundwater when used alone. Bench scale studies or pilot studies would be required to determine the effectiveness or this method 1n achieving discharge requirements. The system has no filter or adsorption media to dispose of or regenerate. It destroys VOCs and other organic contaminants without air emissions or generation of residual hazardous waste. ImpleMntabllUy Design and operation of a UV/Ox1dat1on system 1s dependent on the type an concentration of organic contamination, the light transmittance of the water, and the type and concentration of dissolved solids. Excessive suspended sol Ids can occlude the ultraviolet light, thus decreasing the effectiveness of the system. Pretreatment of the contaminated groundwater may be necessary to reduce the suspended solids content. Mobile treatment units are commercially available. Long-term management of the system would be required to insure it's continued operating efficiency. Conclusion Pilot testing and full-scale applications have substantiated the effectiveness of UV/Ox1dat1on systems to treat VOCs and other organic contaminants in contaminated groundwater. It appears that this technology may be effective in treating most of the contaminants in the groundwater at the A. 0. Polymer site, and it will be retained for further consideration in developing alternatives for groundwater treatment. Wet Air Oxidation Wet air oxidation is a thermal treatment technology which Involves the aqueous phase oxidation of dissolved or suspended organic contaminants at elevated temperatures and pressures. The waste stream 1s heated and then allowed to oxidize in the presence of oxygen. The contaminants oxidize and cause a rise in temperature. The gas and liquid phases can then be separated, with the wastes going out in the gas phase. Effectiveness Wet air oxidation 1s effective in treating a wide variety of organic contaminants; however, it is most applicable to concentrated waste streams with organic concentrations greater than 10,000 ppm. Impleaentablllty o A limited number of mobile units for wet air oxidation are available. Contaminants 1n the off -gas may require further treatment such as vapor-phase carbon adsorption. o V-" 00 AOP-35-H 3-18 A. 0. Polymer Site Public Review Feasibility Study April 1991

Conclusion Wet air oxidation Is most applicable to concentrated waste streams with organic concentrations greater than 10,000 ppm. It is extremely expensive, and its use is not justified for treating low concentration groundwater. Wet air oxidation is at least an order of magnitude more costly than other equally effective treatment processes. It will be eliminated from further consideration in developing alternatives. 3.3.5 Disposal/Discharge Technologies - Groundwater Several onsite and offsite disposal/discharge options are potentially applicable to discharges resulting from groundwater remediation actions. Onsite discharge options include discharge to surface water or to a recharge basin, and groundwater reinjection. Discharge to surface water would be accomplished by means of an outfall from an onsite treatment plant to the Wall kill River. Discharge to groundwater would be accomplished by means of injection wells. Offsite discharge/disposal options include discharge to a POTW, or offsite disposal at a commercial treatment or disposal facility. Depending on the available capacity and the available treatment processes, untreated or pretreated groundwater could be discharged to a local POTW. For disposal of water at a commercial treatment facility, the water would be hauled in tanker trucks. Discharge to Surface Water Treated water from an onsite treatment facility may be discharged to surface water and would involve construction of an outfall from the onsite water treatment facility to the Wallkill River. Effectiveness Discharge to surface water 1s the most straightforward, low cost method to discharge treated water from an onsite treatment plant. ImpleroentabllIty Discharge to surface water would require that water be treated to the effluent requirements specified by an NPDES permit. These effluent limitations would be determined by the State of New Jersey. Conclusion Discharge to surface water following treatment 1s the most straightforward, Q low cost method of discharging treated water from an onsite treatment plant, ^ and will be retained for further consideration in developing groundwater treatment alternatives. o

AOP-35-H 3_19 2 A. 0. Polymer Site Public Review Feasibility Study April 1991

Discharge to Wetlands Treated water from an onsite treatment facility may be discharged to the wetland areas near the Wall kill River. Effectiveness Discharge to surface water is a straightforward, low cost method to discharge treated water from an onsite treatment plant. Because heavy pumping from the groundwater extraction system may dry up the wetland areas, discharge of treated water from the onsite treatment plant may mitigate this potential problem. Impleaentability Discharge to the wetlands would require that water be treated to the effluent requirements specified by an NPDES permit. These effluent limitations would be determined by the State of New Jersey. Conclusion Discharge to wetlands following treatment is a straightforward, low cost method of discharging treated water from an onsite treatment plant. It may also be used to recharge the wetland area if groundwater pumping drys the area. Discharge to wetlands will be retained for further consideration in developing groundwater treatment alternatives. Discharge to Recharge Basin After extraction and treatment, treated water from an onsite treatment facility would be pumped to a recharge basin constructed over the former site of the disposal lagoons or at some other location onsite. Recharge of water through the contaminated soil beneath this area will result in additional leaching and mobilization of soil contaminants for subsequent extraction and treatment. This will result in more rapid extraction and treatment of the water-soluble contaminants found in these subsurface soils. Effectiveness The effectiveness of this soil flushing by water recharge 1s dependent on a number of parameters Including the Infiltration rate and hydraulic conductivity of the soil, the solubility of the contaminants, contaminant adsorption, etc. Recharge of large quantities of water can alter hydrogeologic conditions and may create new groundwater flow patterns. For example, if a recharge basin were constructed 1nt he area of the former disposal lagoons, groundwater mounding could be created, which may cause contaminants to migrate to new areas of the aquifer.

AOP-35-H A. 0. Polymer Site Public Review Feasibility Study April 1991

Implementablllty A recharge basin is relatively simple to construct and operate. If implemented in the area of the former disposal lagoons, additional groundwater control may be required to control migration of contaminants. The groundwater recharge operation would require close monitoring and analysis to ensure that migration is controlled. Based on the soil characteristics and on percolation test data from the area, the infiltration rates are such that a recharge basin could be sized to accept any discharge from an onsite treatment facility. Thus, a recharge basin is an effective option for discharging water from an onsite treatment facility. Conclusion This technology is an effective method for onsite discharge of treated water, and also may be potentially effective in leaching contaminants from the subsurface soil in the area of the former disposal lagoons. It is easily implemented, and will be retained for further consideration in developing remedial alternatives. Groundwater Rein.lection Groundwater reinjection is accomplished by installation of one or more injection wells to reintroduce treated water back into the aquifer. In certain hydrogeologic situations, injection systems are used in conjunction with extraction wells In order to control hydraulic gradients and to facilitate aquifer restoration. Effectiveness Groundwater reinjection 1s most effective in aquifers with high transmissivity. Injection wells create groundwater mounding at magnitudes equal to the drawdown in an extraction well. Drawdowns in the aquifer at A. 0. Polymer could range from 10 to 30 feet. Therefore, groundwater mounding in injection wells would raise the water level by this amount. This would create flooded conditions downgradient, where the water table 1s only a few feet below the ground surface. Other potential problems with reinjection include sand clogging due to chemical precipitation or suspended solids, dead spots, and air locks. For these reasons, reinjection wells are often not reliable in accepting a given flow rate over a given period of time, thus auxiliary wells would be required. Implementablllty > o Groundwater reinjection would require significant capital expenditures to install the required reinjection pumping and piping network. Freezing of 0 reinjection ping 1s a problem 1n the winter. Reinjection piping would have to 2 be installed in trenches below the frostline, and any above-ground piping would have to be insulated. <- o N> f—i AOP-35-H A. 0. Polymer Site Public Review Feasibility Study April 1991

Injection wells would have to be periodically replaced as they became clogged or cease functioning effectively. Long-tern maintenance of the pumps and piping would be required. Conclusion Although this technology is technically feasible in certain areas of the site, it is an expensive and complex method to Implement. Potential mechanical problems make reinjection much less reliable than surface water discharge. In addition, the cost 1s at least an order-of-magnltude greater than surface water discharge, wetland discharge, or recharge basin discharge. For these reasons, groundwater reinjection will not be ronsider further in developing alternatives. Surface water discharge, wet la a dlsch e, and recharge basin discharge will be retained as the representative proc options for onsite discharge. Discharge to POTW This off site discharge option would involve discharging untreated or pretreated groundwater to a POTW facility. The closest publicly owned treatment works (POTW) to the site is in the town on Sparta. Effectiveness The treatment processes at the Sparta POTW include extended aeration, clarification, mixed media filtration, and ultraviolet disinfection. These processes may not remove all of the contaminants in the A. 0. Polymer groundwater. Pretreatment would probably be required to reduce contaminant to acceptable levels to meet POTW pretreatment standards for industrial effluent. If waste water is accepted without treatment, onsite treatment costs and potential operational problems would be eliminated. Pretreatment standards for the POTW discharge may be much less stringent than for discharge directly to surface water. Implementability According to the manager of the Township of Sparta Public Works Department, the township Is currently constructing a new 50,000 GPD waste water treatment system. They are currently accepting a flow of 40,000 GPO and anticipate growth in the near future that would increase the flow to close to 50,000 GPD. Therefore, the POTW would be unable to accept water from the A. 0. Polymer Site due to capacity limitations. The Sparta POTW facility is located at the north end of Lake Mohawk, and the closes point to discharge to the sewer system is Mohawk Avenue, a distance of over a mile. A sewer line would have to be constructed to discharge to the existing sewer system. Since this distance is over a mile, several pumping stations may be required. Otherwise, water would have to be hauled in tanker trucks to the POTW or to the nearest existing sewer. o N> ro AOP-35-H 92 A. 0. Polymer Site Public Review Feasibility Study April 1991

Conclusion Due to capacity limitations at the Sparta POTW, this discharge option is not implementable and will not be considered further 1n the development of remedial alternatives. Qffsite Treatment Facility In this technology, extracted untreated groundwater would be transported offsite to a licensed commercial waste treatment facility, where it would be treated and discharged under the facility's RCRA and NPDES permits. An offsite industrial treatment facility that has the capacity to accept a large volume of low concentration waste water and has the capability to treat the expected groundwater contaminants would have to be Identified. Effectiveness This disposal option for groundwater would be an effective method of treating the contaminated groundwater extracted from the plume. Inplementabllity Potential problems with this option Include excessively high transportation and disposal costs, and logistical difficulties in maintaining continuous pumping without overwhelming transport capabilities. Based on preliminary unit costs provided by treatment facilities, disposal of untreated water at an offsite facility would result in costs which are orders-of-magnitude greater than onsite treatment and discharge options. Cycle-Chem Incorporated of Elizabeth, NJ estimated that treatment costs would be approximately $1.25/gallon, not including transportation costs. Based on data presented in this report, onsite treatment costs per gallon are approximately two orders- of-magnitude less. Additionally, commitment to this course of action would be susceptible to increased public risk due to extensive transportation of contaminated materials. Conclusion Based upon the anticipated excessive costs and other related problems, offsite disposal of contaminated groundwater is eliminated from further consideration.

3.4 IDENTIFICATION AND SCREENING OF SOIL REMEDIAL TECHNOLOGIES In this section, potentially applicable technologies for the remediation of soil contamination at the A. 0. Polymer Site are identified. The applicability of a technology to the site Is evaluated by considering the site remedial response objectives, characteristics of the soil contamination, and specific site conditions.

AOP-35-H 3-23 A. 0. Polymer Site Public Review Feasibility Study April 1991

The technology Identification process produced a number of technologies and process options which are potentially applicable to address the contaminated soil problems at the A. 0. Polymer Site. The applicable technologies, as well as the available process options within the technology type are summarized In Table 3-2. The majority of soil contamination was found 1n subsurface soils beneath the location of the former Mohawk disposal lagoons. Subsurface soil contamination in this area was found between 10 feet below the ground surface and the water table at 25 feet below the ground surface. The highest concentrations of contaminants Included volatile organlcs (halogenated aliphatic hydrocarbons and mono-aromatic hydrocarbons) and phenolic compounds. PAHs were also found in smaller concentrations. In the following sections, specific remedial technologies and process options for addressing soil contamination at the A. 0. Polymer Site are described and are screened by evaluating their effectiveness and implementability at the site. Whenever possible, one process option within each technology type 1s selected to represent that technology type. 3.4.1 No Action with Institutional Control Technologies - Soil The no-action with Institutional controls general response category for soil includes actions such as site fencing, restrictions on future excavation in the contaminated areas, and monitoring. Site Fencing This action would require that contaminated soil areas be fenced to prevent access. Effectiveness Fencing is an effective action for restricting access to prevent direct contact with contaminated surface soil. Fencing 1s potentially effective for surface soil contamination within the plant area at A. 0. Polymer. However, fencing would not be effective for the former disposal lagoon area at A. 0. Polymer, since that area has only subsurface contamination and direct contact 1s already restricted by the clean surface soil. Site fencing will not reduce toxicity, mobility, or volume of contaminants. Implewentability Fencing is feasible is the areas of the plant where surface contamination was found, but it may Interfere with plant operations. In addition, it could interfere with access to the gun club. v oT3

O O h->

AOP-35-M 3_24 %> to TABLE 3-2 IDENTIFICATION OF POTENTIAL SOIL REMEDIATION TECHNOLOGIES A. 0. POLYMER FEASIBILITY STUDY

General Response Action Remedial Technology Process Option

No Action with Site Fencing Institutional Controls Deed Restrictions Monitoring Containment Capping RCRA Cap Multi-Media Cap Asphalt Cap w Removal Excavation rs> 01 Treatment Physical Treatment Stabilization In-Situ Soil Flushing Soil Vapor Extraction Biological Treatment Biodegradatlon Land Treatment Thermal Treatment Low Temperature Thermal Desorption Onsite Incineration Offsite Incineration Disposal Onsite Landfill Offsite Landfill

TOO dOV A. 0. Polymer Site Public Review Feasibility Study April 1991

Conclusion Site fencing is not effective in the former lagoon area that has only subsurface soil contamination, and 1s not Implement able in the plant areas because It may interfere with plant operations. Site fencing is not effective in managing long-term public health risks or in achieving site response objectives. It will not be maintained for further consideration in developing remedial alternatives. Deed Restrictions This action would require that all deeds for property within the contaminated soil area include permanent restrictions on the excavation and use of soil within the designated contaminated area. Effectiveness Deed restrictions against excavation can be used to restrict future uses or activities onsite that may result in direct contact with contaminated soils. The effectiveness of this action depends on proper enforcement. If properly enforced, deed restrictions against excavation are effective in managing public health risks associated with direct contact with contaminated soil. ARARs related to environmental protection will not be met by deed restrictions against excavation, and deed restrictions against excavation will not reduce toxicity, mobility, or volume of contaminants. ImpleraentabiHty Deed restrictions may be difficult to enforce in the long-term, since the contaminated soil is located on private property. Public and plant employee awareness and education programs should be implemented in conjunction with the deed restrictions against excavation to make people aware of the potential hazards associated with excavation or contact with contaminated soil. Conclusion Deed restrictions against excavation should be Implemented at the site until the contaminated soil at the site is remediated either through some type of soil remediation or through natural attenuation. If properly enforced, deed restrictions against excavation are effective in managing public health risks associated with excavation of contaminated soil, and will be maintained for further consideration in developing remedial alternatives. Soil Monitoring Soil monitoring would include periodic sampling and analysis of surface and subsurface soils. o o

*°p-35-H 3-26 A. 0. Polymer Site Public Review Feasibility Study April 1991

Effectiveness Soil monitoring technology is not effective in achieving response objectives or in meeting ARARs. However, soil monitoring is required to monitor soil contamination and to evaluate the progress and effectiveness of any soil remediation that is implemented at the site. Even if no soil remediation is implemented, monitoring at hazardous waste sites 1s usually conducted for at least 30 years to determine whether contaminant concentrations have decreased to safe levels though natural flushing and/or attenuation. Implenentab1l1ty Soil monitoring is easily Implemented, but would require long-term management efforts. Conclusion Soil monitoring is effective in monitoring the natural flushing and attenuation of soil contamination and in evaluating the effectiveness of soil remediation efforts. It will be maintained for further consideration in developing remedial alternatives. 3.4.2 Containment Technologies - Soil The potentially applicable technology for in-situ containment of contaminated soils is capping the contaminated areas with a low permeability cover to reduce infiltration and subsequent leaching of contaminants from the soil, and to reduce potential direct contact hazards. The onsite landfill technology, which could be considered a soil containment technology, is discussed under soil disposal technologies in Section 4.4.3. Capping Three capping options will be considered: 1) a RCRA cap, 2) a multi-media (soil and HOPE liner) cap, and 3) an asphalt cap. A RCRA cap 1s a multi-layer cap satisfying the recommendations of ERA in the RCRA Guidance Document (RCRA Guidance Document, Surface Impoundments, Liner Systems and Freeboard Control, July 1982). The RCRA cap consists of a Systems and Freeboard Control, July, 1982). The RCRA cap consists of a two-foot thick compacted clay layer overlain by a high density polyethylene (HDPE) synthetic membrane Uner, HDPE synthetic drainage net, and 2-3 ft. of clean fill and topsoil. The topsoil layer would be vegetated with grass to resist erosion. A multi-media cap 1s a simplified version of the RCRA cap, and would consist of a 6" sand layer, overlain by an HDPE liner and synthetic drainage net, overlain by 2-3 feet of cover soil, and vegetation to resist erosion. Asphalt 1s a low permeability material that can function in a similar manner as the other caps, but provides a usable area for parking or other land use

AOP-35-H A. 0. Polymer Site Public Review Feasibility Study April 1991 needs. An HOPE liner can be Included in the design to make the asphalt cap perform as well as the other caps in minimizing or eliminating Infiltration. Effectiveness The placement of a cap over the contaminated soil areas of the site would provide containment and reduce potential surface contact hazards posed by contaminated soils. A cap Is also effective in minimizing Infiltration and subsequent leaching of contaminants in underlying soil. A RCRA cap and a multi-media cap are both considered extremely effective in limiting Infiltration, and subsequent leaching of contaminants from the underlying soil. Both caps would require periodic maintenance to prevent excessive erosion and to ensure the continued integrity of the liners. An asphalt cap without a liner is not as effective in limiting Infiltration as the other caps because asphalt is susceptible to cracking due to natural freeze/thaw cycles. However, an asphalt cap underlain by an HOPE liner, would be equally as effective in minimizing infiltration as other multi-layer caps. (Appendix F presents a comparison of the relative effectiveness of RCRA and lined asphalt caps.) Periodic maintenance of the asphalt would be required to ensure its continued integrity. All three types of caps are equally effective in reducing the potential for direct contact with contaminated soils. ImplementablHty All three types of caps could be Implemented at the site of the former disposal lagoons to limit infiltration through the subsurface contaminated soils. The RCRA cap would be the most d1f~~ ~ult to implement, because the overall thickness of a typical RCRA cap is to 7 feet. The roadway would have to be relocated in order to provide aa=quate side slopes for the cap. A multi-media cap would be easier to construct since it can be only 3 to 4 feet thick; however relocation of the roadway may also be required with this options. An asphalt cap would be the most desirable if current and future land use is to be considered. Current land use in the vicinity of the proposed cap Includes a private access road to the gun club area, and storage/maintenance areas used by A. 0. Polymer. With the asphalt cap option, the access road could be maintained in the same location, and the asphalt cap could also be used for parking, etc. With the RCRA and multi-media caps, the access road would require relocation and the capped area must be protected from future land use in order to protect the integrity of the cap. Conclusion > RCRA caps and multi-media caps are designed primarily for use in capping ^ landfills, where large settlements are expected. The thick clay layer within these capping systems Is self healing and essentially reseals any cracks that o may develop during excessive settlement. In the Intended application at A. 0. 2 »—> o AOP-35-H _ oo A. 0. Polymer Site Public Review Feasibility Study April 1991

Polymer Site, settlement will not be a major problem, and the use of a RCRA or multi-media cap 1s not justified. A RCRA and a multi-media cap are both effective In minimizing infiltration and an asphalt cap can be made equally effective by placing an HOPE liner underneath. Both the RCRA and multi-media caps present difficulties in implementation and prevent future land use in the capped area. The asphalt cap is easier to construct and preserves future land use. Therefore, the asphalt cap with underlying HOPE liner will be retained as the representative capping technology. 3.4.3 Removal Technologies - Soil The potentially applicable technology for removal of contaminated soil 1s excavation. Excavated soil would be treated or disposed and the excavation would then be backfilled with clean fill. Excavation The lateral and vertical extent of contamination in surface an subsurface soils has not been delineated precisely. Therefore the extent of excavation required to achieve the target clean-up, levels is difficult to estimate. In the area of the former disposal lagoons, the volume of contaminated soil is estimated to be 7,500 cubic yards, based on the available information, however, the contaminated subsurface soil 1s covered by approximately 4,500 cubic yards of clean soils, which would also have to be excavated 1n order to provide access to the contaminated soil zone. Effectiveness Excavation is not intended to reduce the toxiclty or volume of contaminated soil; however, it is required for subsequent treatment or offsite disposal. Imp1ementab1l1ty Excavation of 12,000 cubic yards of soil Is a relatively large operation and may be difficult to Implement without disturbing existing plant operations at A. 0. Polymer. Excavation would require staging areas for equipment, stockpile area, and equipment operating areas. The excavation would have to be carefully staged and managed in order to reduce the possibility of spreading contamination via fugitive dust, storm- water runoff, and Infiltration of precipitation through contaminated soil stockpiles. There are risks of exposure to volatilization of VOCs during excavation of the contaminated materials. Ambient air monitoring and appropriate health and safety measures would be required 1n order to protect worker health and safety.

AOP-35-H 3-29 A. 0. Polymer Site Public Review Feasibility Study April 1991

Excavation uses standard earth-moving equipment which 1s readily available. Due to the limited space available and the depth of excavation required, extensive bracing of the excavation may be required. Conclusion Although Implementation may be complex, excavation 1s required for subsequent treatment and/or disposal. Therefore, this technology will be retained for further consideration in developing remedial alternatives. 3.4.4 Treatment Technologies - Soil Contaminants of concern in the subsurface soil in the former disposal lagoon area include relatively high concentrations of volatile organIcs (halogenated aliphatic hydrocarbons and mono-aromatic hydrocarbons), phthalate esters, and phenolic compounds. PAHs were also found in smaller concentrations. A number of treatment technologies are applicable to the contaminants of concern in the soil. A number of these technologies can be applied in-situ (without excavating the soil), and the rest require excavation prior to treatment (ex-situ). Potentially applicable treatment technologies for soil . Include: Physical treatment: stabilization, in-situ soil flushing, soil vapor extraction Biological treatment: biodegradatlon, land treatment Thermal treatment: Low temperature thermal desorption, incineration (onsite and offsite). Some available soil treatment technologies are not applicable to the contaminated soil at the site, and are not considered in the screening process. These technologies include: 1) dewaterlng, which is used for removing fluid from sludges, 2) solids processing, which Includes crushing, grinding, or sieving to size-segregate material for subsequent treatment, 3) slurrying, which is used to create slurries for subsequent treatment, 4) In- situ biological, which 1s considered applicable only for soils below the water table, 5) radio-frequency heating, 1n-s1tu vitrification, and critical fluid extraction, all of which are extremely costly and are still in the experimental stages of development, and 6) solvent extraction (TEA) and dechlorination, which are both used primarily to treat PCB-contaminated soil' or sludges. Stabilization Stabilization, also referred to as solidification or fixation, applies t processes of mixing a setting agent with excavated or 1n-s1tu contaminated . soils to form a hard, durable product in which contaminants are chemically bound and/or entrapped by the solidified mass. Typical additives Include

MP-35-H 3-30 A. 0. Polymer Site Public Review Feasibility Study April 1991

Portland cement, flyash, kiln dust, lime, soluble silicates, gypsum, and various combination of these materials. The purpose or goal of stabilization is to Improve the handling and physical characteristics of sludges, and/or to reduce the mobility of the contained pollutants. Solidification may be required to stabilize residual sludges from biological or other types of treatment processes prior to disposal (e.g., solidification or stabilization may be necessary in order to pass the free liquids test). Effectiveness Organic wastes are not effectively immobilized by solidification. Organics interfere with the setting reaction of Portland cement, affecting the durability an the characteristics of the final product. This precludes the use of solidification as a primary treatment for onsite soils contaminated with organic wastes. However, solidification is effective in stabilizing residual sludges from some types of treatment. Implementability In-situ solidification (deep soil mixing) of the subsurface contaminated soils, can be performed using equipment and technology available from a number of vendors. Solidification of excavated soil or residual treatment sludges can also be performed post-excavation in mixing pits. Conclusion Since organic wastes are not effectively immobilized by solidification, solidification will not be considered as a primary treatment for onsite soils, which are contaminated with organics. However, it may potentially be used to stabilize residual treatment sludges prior to disposal. It will be retained as a support technology in developing remedial alternatives. In-situ Soil Flushing In-situ soil flushing Involves flushing a solvent (an organic solvent or water) through the soil to solubilize the compounds and carry them out of the soil to the water table. The contaminants and the solvents or water then enter the groundwater, where they will subsequently be collected and treated. Obviously, this technology can only be implemented in conjunction with groundwater collection and treatment. If an organic solvent 1s used in this process to flush contaminates from the soil, there is a substantive risk that the solvent Itself will add to the 5 environmental degradation of the groundwater if it is not subsequently ^ collected and treated. It 1s more acceptable and environmentally safer to sue ^ water as the solvent in this process. o

o IjJ

AOP-35-H 3-31 A. 0. Polymer Site Public Review Feasibility Study April 1991

A potential option 1s to add a biodegradable detergent or other surfactant to the water being flushed through the soil, 1n order to Increase the solubility of the contaminants 1n the soil and reduce the time required for flushing. A major benefit of this technology 1s that 1t can be used to treat soil 1n- situ, thus eliminating the need for excavation. It 1s most applicable to contaminated subsurface soils which would be difficult or expensive to excavate and treat. At A. 0. Polymer, this technology would be most applicable for the contaminated subsurface soils 1n the area of the former disposal lagoons. Effectiveness The success of this type of treatment depends on a number of factors, including the solubility and partitioning tendencies- of the contaminants, the permeability of the soil matrix, and the effectiveness of the groundwater extraction and treatment system in collecting and treating groundwater contaminated by this process. Highly permeable soils permit larger flow rates of the solvent through the soil matrix, and thus reduce the time required for flushing. The sand soil at the A. 0. Polymer Site has relatively high permeability and transmlssivity values, and is conducive to treatment using this method. Soil flushing is most effective 1f the contaminants in the soil are highly soluble and poorly adsorbed to soil particles, because they are flushed from the soil matrix more quickly. At the former disposal lagoons, the major contaminants in the subsurface soils are halogenated aliphatic hydrocarbons (HAHs), monocyclic aromatic hydrocarbons (MAHs), and phenols. These t.iree groups of contaminants are all soluble 1n water to some degree. Polycyclic aromatic hydrocarbon (PAHs) and phthalate esters, which are not as soluble in water as the other groups,* are also present, but in smaller concentrations. The groundwater flow patterns must be well understood and there must be an effective groundwater collection system 1n place to ensure complete collection of all contaminants flushed from the soil using this process. In some cases, it is difficult to ensure a high degree of reliability In collecting all of the contaminants flushed from the soil using this process. However, since the hydrogeology at the A. 0. Polymer Site 1s relatively straight-forward and well understood, a reliable extraction system could be designed to collect the contaminants flushed from the soil in this manner. Due to the heterogeneous nature of soil, the uneven distribution of soil ^ contaminants, and lack of performance data, it 1s difficult to predict the o success of this treatment method. Since most of the soil contaminants are water soluble to some degree, this method will flush some of the contaminants ^ out of the soil. However, there 1s not a high degree of reliability in o achieving target cleanup levels. V-J o UJ to AOP-35-H 3 22 A. 0. Polymer Site Public Review Feasibility Study April 1991

ImplenentablHty Soil flushing in the area of the former disposal lagoons could be easily implemented using a recharge basin constructed over the area. The source of water for the recharge basin would most likely be the treated discharge from the onsite water treatment plant. Conclusion Soil flushing may be an effective method to flush contaminants from the subsurface soil sin the former disposal lagoon area, and could be easily implemented in conjunction with a groundwater collection and treatment system. It will be retained for further consideration in developing remedial alternatives. Soil Vapor Extraction The soil vapor extraction technology provides a method for removing VOCs from the vadose zone. The process involves applying a vacuum to venting wells installed in the contaminated vadose zone to volatilize the organics in the vadose zone and draw the vapors in to the lower portion of the well. Consideration must be given to further treatment of the vented vapors to mitigate atmospheric discharge of hazardous vapors. Activated carbon is normally used to adsorb the extracted vapors. A major benefit of this technology is that it can be used to treat soil in- situ thus eliminating the need for excavation. It is most applicable to contaminated subsurface soils which would be difficult or expensive to excavate. At A. 0. Polymer, this technology would be most applicable for the contaminated subsurface soils in the area of the former disposal lagoon. Effectiveness The process is minimally effective for removal of contaminants having vapor pressures lower than 20 mm Ph at temperatures of 25 degrees C or less, and is most effective when used for removal of contaminants having vapor pressures greater than 100 mm Hg at 25 degrees C or less. In general, the lower the vapor pressures, the Tower the rate of removal for the compound. At the former disposal lagoons, the major contaminants in the subsurface soils are halogenated aliphatic hydrocarbons (HAHs), monocyclic aromatic hydrocarbons (MAHs), and phenols. These three groups of contaminants are relatively volatile, and nay be removed using this method. Polycyclic ^ aromatic hydrocarbon (PAHs) and phthalate esters, which are not as volatile, o are also present, but in smaller concentrations. This process will not be effective in removing these contaminants. o

AOP-35-H A. 0. Polymer Site Public Review Feasibility Study April 1991 iBplMentablllty Soil vapor extraction uses standard equipment which Is readily available, and is this respect, would be easy to Implement. Activated carbon, which would be used to treat the extracted vapors, would have to be regenerated or disposed. there are risks of exposure to volatilized VOCs during the extraction process. Ambient air monitoring and appropriate health and safety measures would be required 1n order to protect worker health and safety. Conclusion The soil vapor extraction technology provides a potentially effective method for removing VOCs from the contaminated subsurface vadose zone soil in the area of the former disposal lagoons. The technology 1s implementable using commercially available equipment and materials. It will be retained for further consideration In developing remedial alternatives. Blodearadation Blodegradatlon is applied either in-situ or to excavated soil by stimulating . blodegradatlon mechanisms that result in degradation of organic contaminants in the soil. Biological treatment creates a favorable environment for those microorganisms capable of degrading the compounds of Interest. Blodegradation rates may be Increased by optimizing various soil conditions such as soil pH, soil moisture content, oxygen content, temperature, and nutrient concentrations. Treatment residuals would be a sludge consisting of dead cells and nondegraded organics which may require treatment and/or disposal. Effectiveness The complex nature of soil contamination at the site limit the effectiveness of blodegradatlon techniques. Significant reductions in toxiclty could be achieved only if a diverse microbial population capable of degrading the compounds of Interest can be maintained. Impleaentablllty Site-specific bench and pilot tests would be required to determine the specific conditions required to degrade the specific soil contaminants. Application of this technology would also require long-term operations to develop, acclimate, and maintain the necessary microbial population. > Conclusion 3 Considering the complexity and experimental nature of biodegradation, and the 2 availability of more reliable solids treatment technologies for the site, biodegradation will not be retained for further consideration. £ UJ

AOP-35-H 3-34 A. 0. Polymer Site Public Review Feasibility Study April 1991

Land Treatment This treatment involves the excavation of contaminated solids and either onsite land fanning or transportation to an offsite land fanning site. At the disposal site, the wastes are mixed Into the upper soil horizon where contaminants are degraded through chemical, physical and biological treatment processes. Effectiveness This treatment has not proven to be effective for the degradation of highly chlorinated aromatic compounds and other organics which are resistant to biological attack. Thus, the reliability of achieving cleanup standards in soil through land farming technology is low. In addition, it requires spreading and mixing of contaminated soil into areas which are currently non-contaminated. It creates'a situation where contamination could be spread by fugitive dust, storm-water runoff, and precipitation infiltrating through the contaminated soil. Impleroentability Land farming may not be implementable from a regulatory point of view, due to the potential contamination of large areas of land which are currently clean. Conclusion This technology is not reliable in treating contaminated soil to cleanup standards, and is likely to spread contamination by fugitive dust, storm-water runoff, and infiltration. For these reasons, it will be eliminated from further consideration in developing remedial alternatives. Low Temperature Thermal Desorption Low temperature thermal desorption, also referred to as low temperature thermal soil aeration or low temperature thermal stripping, is a mass transfer process in which excavated soils are passed through a thermal process where volatile contaminants in soils are transferred to the gas phase. The gas is then passed through a carbon adsorption system, afterburner, or other air pollution control device. The system consists of two main elements, an indirectly fired rotary dryer, and a gas treatment system. Waste 1s fed into the rotary dryer where it is > heated to a temperature of 450 to 850 degrees fahrenheit. The thermal energy ^ vaporizes the volatile and semi-volatile organics from the sol Ids. The off gas passes through a treatment system consisting of a liquid scrubber, a g condenser, a particulate filter, and a carbon adsorption unit. >-

3-35 A. 0. Polymer Site Public Review Feasibility Study April 1991

Effectiveness This process 1s most applicable for relatively large volumes of moderately contaminated wastes, where Incineration nay be cost prohibitive. This process performs well on wastes with low moisture contents and low Btu values, which are generally difficult to incinerate and generate greater amounts of ash during the incineration process than high BTU materials. The process has been demonstrated to be effective for a wide range of volatile and semi-volatile organic contaminants. Based on previous performance data, the type of soil matrix at the A. 0. Polymer site, and the relatively low concentration of contaminants in the soil, there 1s a high degree of reliability in achieving target cleanup levels for soil using this treatment. Implenentabmty Several companies are currently operating mobile treatment units. Permitting requirements are substantially less stringent than for incineration. Due to the low concentrations of organics in the soil, it is not land banned under current land disposal restrictions. If cleanup levels in treated soil - are achieved, the soil will not require offsite disposal and may be used as backfill. Treatment process residuals may require further treatment or disposal. The technology requires monitoring and management throughout the period of operation. Conclusion The low temperature thermal desorption technology provides a reliable and effective method for removing VOCs from excavated contaminated soil at the site. The technology is implementable using commercially available equipment and materials. It will be retained for further consideration in developing remedial alternatives. Onsite Incineration Incineration involves the thermal oxidation or destruction of organic matter. Most types of solid or liquid waste can be treated by incineration systems; however, incineration 1s most effectively used for wastes with high BTU values (i.e., liquids or sludges with high concentrations of organic material). For soil contaminated with low levels of organics, supplemental fuel must be added. Incineration systems produce the following types of effluent: combustion gases, treated solids (residual ash), scrubber water, and particulates. The combustion gases, which are treated to remove hydrochloric acid and particulates, are released through the stack, requiring no further treatment. The air pollution control devices have an effluent stream composed of a slurry from the wet scrubbers and/or particulates.

AOP-35-H 3-36 A. 0. Polymer Site Public Review Feasibility Study April 1991

In incineration of the A. 0. Polymer soil, the residual ash would probably not be hazardous, since the soil does not contain large concentrations of heavy metals. If the ash passes the EP Toxlcity Test or TCLP test, it may be disposed of without treatment on-site. Effluent from the air pollution control devices include particulate catch from Electrostatic Precipitator (ESPs) baghouses or scrubber water. If the particulates are caught in the dry form, they may be treated with the solid stream described previously. Liquid effluent from the scrubber system will contain hydrochloric acid. This stream is usually neutralized using a solution of sodium hydroxide which precipitates as a salt. The scrubber water blowdown stream is an aqueous solution of sodium chloride with high suspended solids. The scrubber stream is of low volume, and could easily be treated in an onsite water treatment facility, or taken offsite for treatment. Effectiveness Incineration thermally destroys organic wastes, thereby reducing or eliminating volume and toxicity of the contaminants. Implementabllity Mobile incinerators need not receive Federal, State and Local permits, but they must meet substantive requirements that are part of the permitting process. Onsite incinerators that are constructed as permanent facilities do require permitting. Soil has low Btu values and is difficult to incinerate. Supplemental fuel should be required. This would require onsite fuel tanks and fuel deliveries, which creates the potential for additional site contamination from leaking fuel. The incineration process requires management of potentially hazardous ashes or residues from the Incinerator. Large quantities of ash are likely to be generated, since the soil to be Incinerated is a low Btu substance. The nature of the contamination at the site does not preclude the use of incineration, and site characteristics may allow for a mobile incinerator to be operated onsite. However, a permanent facility could not be built onsite due to the site space constraints and future use of the property. Conclusion This technology is effective in permanently destroying a high percentage of all organic contaminants found 1n onsite soil, however, for soil with low levels of organics and low Btu values, such as the soil at A. 0. Polymer, incineration 1s not an efficient Method of treatment. In addition, extensive permitting requirements must be met, handling of supplemental fuel could

AOP-35-H 3-37 A. 0. Polymer Site Public Review Feasibility Study April 1991

create additional onslte contamination, large quantities of ash will be generated and Must be Managed. Low temperature thermal desorptlon 1s effective 1n treating the contaminated soil, and is the preferred thermal process option. Therefore, incineration will not be retained for further consideration in developing remedial alternatives, and low temperature thermal desorptlon will be the selected process option. Offsite Incineration Incineration technologies used In off site commercial facilities are the same as those described in the preceding section for onslte incineration. The following additional considerations apply. High costs are incurred for incineration of large volumes of low Btu waste. Soils must be shipped to the commercial facilities in incinerable containers {e.g., fiber or plastic drums or repackaged at the incinerator facility. Storage and capacity limitations for soil Inhibits the handling of large volumes at most commercial facilities. Capacity limitations are severe as the land disposal restrictions come into effect, causing additional wastes to be . treated using incineration. Whenever a facility 1s being considered as a disposal option, it is necessary to verify that it is in compliance with all RCRA storage, treatment, and disposal requirements. Conclusion For the same reasons stated for onsite incineration, offsite incineration will not be retained for further consideration in developing remedial alternatives. 3.4.5 Disposal Technologies - Soil Applicable disposal technologies for soils include construction of an onsite landfill or containment cell, and offsite disposal at an approved landfill. Onsite Landfill A RCRA landfill would be constructed onslte to contain the excavated contaminated soil. The landfill would Include a double liner system with leachate collection and detection systems, and a RCRA approved cap. Long-term maintenance and groundwater monitoring would be required. Effectiveness > o Onsite landfill ing provides a relatively reliable method to contain wastes. ••d Properly constructed and maintained landfills reduce the mobility of o contaminants; however, the reliability of containing the waste depends on the 2 quality of construction of the landfill cell. o u> AOP-35-N A. 0. Polymer Site Public Review Feasibility Study April 1991

The construction of an onsite landfill represents a long-term liability, since the integrity of the landfill cell cannot be guaranteed over the long-term. Implementability Site space limitations may preclude the use of this technology. Long-term management efforts are required for maintenance of the landfill and for groundwater monitoring. Because this approach does not treat the contaminants or offer a permanent remedy, it is not favored by CERCLA as amended. Construction of an onsite landfill represents a long-term liability. For a relatively small volume of waste, the cost of constructing an onsite landfill may exceed the cost of some types of onsite treatment or disposal at an offsite landfill. Conclusion Due to the long-term liability and long-term management efforts associated with onsite landfills, and because this approach does not treat the contaminants or offer a permanent remedy, the onsite landfill technology will not be considered further in developing remedial alternatives. Offsite landfill ing as described in the following section shall be retained as the representative disposal technology. Offsite Landfill This technology requires collection of excavated soil and wastes, followed by offsite transportation to an approved offsite landfill. Effectiveness Performance data for offsite landfills exist for 20 to 30 years, and long-term performance is dependent onsite conditions, waste, and compatibility. Volume or toxicity of waste 1s not decreased. The offsite landfill technology does not achieve permanence of remedy and under CERCLA amendments, offsite transport without treatment is a least-favored remedial action. Implementab111ty Volatilization of organics could pose a health hazard during excavation and transportation of contaminated soils. Properly constructed and maintained landfills reduce the migration of contaminants, but require long-term management efforts. Offsite facilities are available within a reasonable > trucking distance from the site. Compliance with RCRA and state regulations % needs to be considered for each offsite facility proposed for contaminated soil disposal. o o I—" Conclusion »-< The offsite landfill technology is an effective means of disposing of 2 contaminated materials removed from the site. Due to the low concentrations '~°

AOP-35-H 3-39 A. 0. Polymer Site Public Review Feasibility Study April 1991 of organ1cs 1n the soil, the soil 1s not land banned under current land disposal restriction. Remedial alternatives utilizing Iandf1111ng can be compared to remedial alternatives based on treatment technologies. Additionally, remedial alternatives could be developed which utilize Iandf1111ng 1n conjunction with treatment. This technology will be maintained as a representative disposal technology, although use of landfills 1s discouraged under CERCLA, as amended.

3.5 SUMMARY OF REMEDIAL TECHNOLOGY SCREENING Selection of representative technologies favored the process options that screening Information Indicated would be more effective and Implementable at the site. For some technology types, more than one process option was determined to be effective. Results of the technology screening Indicated some technologies would not be effective in meeting response objectives when applied Individually. However, they could be valuable when combined with other technologies 1n forming an alternative, and were retained for use as support technologies. Figures 3-1 and 3-2 present flow chart summaries of groundwater and soil remedial technology screening. Technologies that remain following screening will be used in developing remedial alternative for the A. 0. Polymer Site in Section 4.0.

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AOP 001 1043 A.O. Polymer Site Public Review Feasibility Study April 1991

4.0 PFVFIOPMEMT AND SCREENING OF REMEDIAL ALTERNATIVES In this section, potential remedial alternatives for source control and management of migration are developed, based on the results of technology screening in Section 3.0. The alternatives are then screened on the basis of effectiveness, implementability, and cost considerations. This screening step is performed in an attempt to narrow the field of potential alternatives, while preserving an adequate range of options. The alternatives that remain following this screening will be further evaluated in the detailed analysis of Section 5.0. In formulating a remedial action alternative, CERCLA requires EPA to place an emphasis on risk reduction through destruction or treatment of hazardous waste. Section 121 of CERCLA establishes a statutory preference for remedial actions that permanently and significantly reduce the toxicity, mobility, and volume of hazardous waste. Section 121 also requires that EPA select a remedy that is protective of human health and the environment, is cost-effective, and utilizes permanent solutions and treatment technologies to the maximum extent practicable. Based on these guidelines, a range of treatment alternatives for source control and management of migration are presented. A discussion of alternative development and evaluation criteria is presented in Section 4.1. Source control and management of migration alternatives are developed and screened in Sections 4.2 and 4.3, respectively. Source control remedial alternatives consist of remedial actions which prevent or minimize risks by controlling the source of the contamination. At the A. 0. Polymer Site, the "source" is defined as the contaminated subsurface soil in the area of the former disposal lagoons. Management of migration alternatives consist of remedial actions which prevent or minimize risk due to the migration of hazardous substances in groundwater. The development of alternatives may include preliminary design calculations, process flow diagrams, sizing of key components, and preliminary site layouts. The information presented in the alternative development process will be used as a basis for preparing cost estimates in the detailed evaluations of Section 5.0. Section 4.4 presents a discussion of alternatives for groundwater extraction systems, and presents a summary of the results of solute transport modeling. Layouts of collection systems for the various extraction options are presented.

4.1 ALTERNATIVE DEVELOPMENT AND EVALUATION CRITERIA CERCLA, Section 121(b) Identifies the following statutory preferences that must be considered when developing and evaluating remedial alternatives: > hd o Remedial actions that Involve treatment that permanently and significantly reduces the volume, toxicity, or mobility of the o hazardous substances are preferred over remedial actions not 2 involving such treatment.

AOP-35-H . , 4-1 A.O. Polymer Site Public Review Feasibility Study April 1991

o Offsite transport and disposal of hazardous substances or contaminated materials without treatment is considered the least favorable option when practical treatment technologies are available. o Remedial actions using permanent solutions, alternative treatment technologies, or resource recovery shall be evaluated. 4.1.1 Alternative Development Criteria Based on these statutory preferences, and the remedial action objectives identified in Section 2.0, remedial alternatives were developed to meet the following criteria: o The remedial alternative is protective of human health and the environment. o The remedial alternative attains chemical-specific ARARs and can be Implemented in a manner consistent with location-specific and action-specific ARARs. o The remedial alternative uses permanent solutions and treatment technologies to the maximum extent practicable. o The remedial alternative is capable of achieving a remedy in a cost-effective manner. 4.1.2 Alternative Evaluation Criteria In accordance with the requirements set forth in CERCLA, as amended, Section 121, and in the NCP (40 CFR 300.68(g)), the evaluation criteria to be used for screening of remedial alternatives includes effectiveness, implementability, and relative cost. A description of each criteria 1s presented below. Effectiveness The factors to be considered in evaluating the effectiveness of a remedial alternative are listed below, in order of importance: o The alternative provides long-term protectiveness of human health and the environment. > o The alternative reduces the toxiclty, mobility, or volume of ° contamination. o o The alternative attains chemical-specific ARARs and can be 2 Implemented in a manner consistent with location-specific and action-specific ARARs.

AOP-35-H 4-2 A.O. Polymer Site Public Review Feasibility Study April 1991

Implementabilitv The factors to be considered in evaluating the implementability of a remedial alternative are listed below, in order of importance: o It is technically feasible to construct and operate the various components of the alternative. o It is administratively feasible to comply with the substantive requirements of any necessary permits. Key components of the alternative are readily available, and the time required for implementation is reasonable. Cost The intent of the alternative screening with respect to cost is to make order- of-magnitude cost comparisons to screen out alternatives with much higher costs which do not provide a comparable increase in effectiveness or implementability. Alternatives which have excessive costs (at least an order- of-magnitude higher than a comparable alternative) are eliminated from further consideration. Cost may be used to distinguish between various onsite treatment alternatives, but may not be used to compare treatment versus non- treatment alternatives.

4.2 SOURCE CONTROL (SOIL) REMEDIAL ALTERNATIVES The pattern of groundwater contamination indicates that the soil at the site of the former disposal lagoons is a probable source of groundwater contamination. For purposes of developing source control remedial alternatives, the area and volume of contaminated soil has been estimated based on available Information. The areal extent of contamination has been estimated based on the location of the former disposal lagoons. The estimated areal extent of contamination, as Illustrated on Figure 4-1, is approximately 13,000 square feet. Two test borings in this area (TB-11 and TB-12) Indicate that soil contamination exists from a depth of approximately 10 feet below the ground surface to the elevation of the groundwater table at a depth of approximately 25 feet below the ground surface. The soil from the ground surface to a depth of 10 feet 1s assumed to be clean as a result of the disposal lagoon area remediation by NJDEP in 1980-81. Based on the estimated area and depth of contamination, the contaminated soil volume 1s estimated to be approximately 7500 cubic yards. The remedial alternatives for source control address this "source" area only. Contaminated soil in other areas of the site was determined to be of limited public health risk 1n the baseline risk assessment, and will not be addressed in this Feasibility Study. The one exception is the septic tank and leach field which will be cleaned and removed or replaced as part of every alternative except the No-action Alternative SC-1.

AOP-35-H LOCATION OF FORMER DISPOSAL LAG

ESTIMATED AREA OF CONTAMINATED SOIL • 13.000 S.F. A. 0. POLYMER SITE CONTAMINATED SOU. ESTIMATED VOLUME OF CONTAMINATED SOIL • 7.5OO C.Y. FEASIBILITY STUDY AREA AND VOLUME ESTIMATES ICK TECHNOLOGY INCURI'ORATKD DATE' AUG. 3,1990 | PR • S.M.METf PITTSBURGH, P* SCALE' I'-SO' DWO. NO.' 4-4 A.O. Polymer Site Public Review Feasibility Study April 1991

OSWER Directive 9355.3-01, "Guidance for Conducting RI/FS Under CERCLA", Interim Final, October, 1988, indicates that a range of Source Control (SC) remedial alternatives should be developed that include: o A no-action alternative o One or more alternatives that utilize containment with little or no treatment, but protect human health and the environment by preventing potential exposure and/or reducing the mobility of contaminants o A number of treatment alternatives that range from one that would eliminate, to the extent possible, the need for long-term management, to one which uses treatment as a principal component. Considering this guidance and current knowledge of the site, the following potential source control remedial action alternatives have been developed: SC-1 No Action with Institutional Controls SC-2 Capping SC-3 Soil Flushing SC-4 Soil Vapor Extraction SC-5 Soil Vapor Extraction and Soil Flushing SC-6 Excavation and Low Temperature Thermal Desorption SC-7 Excavation and Offsite Landfill 4.2.1 SC-1: No Action with Institutional Controls This alternative 1s included as required under CERCLA. No action would be taken to contain, control, or treat soil contamination. Because contaminants remain untreated onsite, site reviews would be required at least every 5 years. Periodic subsurface soil sampling and analysis would be required to assess the natural soil flushing process and to provide data for periodic reviews. Three 25 foot test borings are assumed to be installed annually over a 30-year period, with three soil samples taken from each boring, for a total of 9 samples annually. Soil samples are to be analyzed for total volatile organics, base-neutrals, and add extractables. Effectiveness There is minimal human health or environmental risk associated with the contaminated subsurface soil since there is little chance of direct contact. However, if nothing 1s done to control infiltration into these soils, the contaminants in the soil will continue to leach to the groundwater. i No reduction in toxicity, mobility, or volume of contamination would be achieved. All potential human health risks associated with contaminated £ groundwater would remain. The soil would continue to act as a source of *- groundwater contamination until the soil was remediated through natural soil ^ o CO

AOP-35-H 4_5 A.O. Polymer Site Public Review Feasibility Study April 1991 flushing and natural attenuation. This process has been estimated to take more than 60 years (see Appendix C). Implementability Periodic subsurface soil monitoring is the only action required, and it is technically and administratively simple to Implement. Test borings, soil sampling, and analysis of soil samples are standard practices, and the required services and equipment are readily available. Cost The only costs associated with this alternative Include monitoring and cost of periodic reviews. Conclusion The no action alternative is retained as required by CERCLA. 4.2.2. SC-2: Capping Capping represents an alternative that utilizes containment with no treatment, as required under CERCLA guidance. Capping would reduce Infiltration and subsequent 1 Khing of soil contaminants into the groundwater. An asphalt cap with an underlying HOPE liner was selected as the representative process option for the capping alternative. This cap configuration is more preferable to a RCRA or other multimedia type cap at the site because the underlying materials are stable and not subject to settlement. Consequently, the expensive self-healing clay layer and geofabric reinforcement materials of the latter cap designs are unnecessary. The HOPE liner incorporated Into the proposed cap design provides a capping system as effective in minimizing Infiltration as RCRA or multi-media soil caps. In addition, the asphalt cap preserves existing land use by providing storage and parking space for A.O. Polymer and parking for the Sparta Gun Club. The proposed cap design Includes, from bottom to top, a 6" layer of sand, a 60 ml HOPE Uner, synthetic flow net for drainage, a layer of filter fabric for separation, a 12" layer of sand and gravel, and a 2.5" layer of asphalt. The total thickness of the entire cap system 1s approximately 21 Inches. A layout plan, showing the location of the proposed cap 1s presented in Figure 4-2. The dimensions of the cap are approximately 70 feet X 185 feet, or an area of approximately 13,000 square feet. A typical cross-section of the proposed cap is shown on Figure 4-3. o Because contaminants remain untreated onsite, site reviews would be required o at least every 5 years. Periodic groundwater sampling and analysis would be required to provide data for periodic reviews.

AOP-35-H 4-6 PROPOSED ASPHALT CAP

OCATION OF FORME DISPOSAL LAGOONS

ASPHALT CAP CROSS-SECTION A. 0. POLYMER SITE SC-2: CAPPING ALTERNATIVE ILLUSTRATED IN FIOURE 4-3 FEASIBILITY STUDY ICFTECHNOLOGY INCORPORATED DATE JULY 23, (990 DR.'K. GARDNER PITTSBURGH, PA SCALE' I" • 9O' OWO. NO.' 4-7 ASPHALT SURFACE

i——2V2 ASPHALT LAYER

12" SAND 8 GRAVEL o •

21' FILTER FABRIC -SYNTHETIC FLOW NET 6" SAND LAYER -60ml HOPE LINER -FILTER FABRIC 00 EXISTING GRADE

[FIGURE 4-3 A. 0. POLYMER SITE ASPHALT CAP CROSS-SECTION FEASIBILITY STUDY : TOO ICF TECHNOLOGY INCORPORATED DATE JULY 23, I99O DR.'K. GARDNER PITTSBURGH, PA SCALE' NONE DWG. NO. A.O. Polymer Site Public Review Feasibility Study April 1991

Effectiveness Capping would effectively reduce the mobility of contaminants in the soil by minimizing infiltration and subsequent leaching of contaminants into the groundwater. Therefore, capping does achieve the response objective of protecting groundwater. Since no treatment of soil is provided, this alternative does not attain soil cleanup levels. No reduction in toxicity or volume of contamination would be achieved. Implementability It is technically and administratively feasible to construct and maintain an asphalt cap over the area of the former disposal lagoons. For the most part, the area is relatively flat, and little grading or'excavation would be required. No permits would be required; however, some type of agreement may be required with A. 0. Polymer, since the proposed cap would be located on A. 0. Polymer property. Standard construction methods and materials, which are readily available, would be utilized in the construction of the cap. The time required for construction of the cap would be less than two months, weather permitting. Periodic subsurface soil monitoring is technically and administratively simple to implement. Special drilling techniques will be required, so that soil samples can be obtained without drilling through the asphalt cap. Test borings, soil sampling, and analysis of soil samples are standard practices, and the required services and equipment are readily available. Cost The costs associated with this alternative are relatively low and include asphalt cap construction and maintenance, site monitoring, and cost of periodic reviews. Conclusion This alternative provides protect!veness of the groundwater resources from further contamination by minimizing the infiltration of water and subsequent leaching of contaminants Into the groundwater. However, without removal of the contaminant source it 1s not a permanent solution. It 1s relatively easy to implement, and reduces the mobility of contaminants at a relatively low cost. It will be retained for detailed evaluation. 4.2.3 SC-3— :— Soi—l— Flushing Soil flushing enhances the natural flushing and natural attenuation of soil contamination by recharging the area with water via a recharge system. Water soluble contaminants which are most prone to leaching will be flushed from the soil into the groundwater. Since soil flushing contaminates the groundwater

AOP-35-H mg A.O. Polymer Site Public Review Feasibility Study April 1991

below the site, this alternative is most appropriately Implemented 1n ~~ conjunction with a groundwater extraction and treatment alternative. A subsurface recharge basin, or leach field, 1s the recommended process option for soil flushing. The other potential option, spray irrigation, presents problems with freezing during the winter months. The subsurface recharge basin consists of a network of 4" diameter perforated PVC pipe laid in a 12- 16" thick gravel bed. The gravel bed should have a 2 - 3 feet thick layer of soil over it to prevent freezing. Filter fabric is used to separate the gravel layer from the surrounding soil. The proposed recharge basin above the soil contamination zone (the "east" recharge basin) is located near a local groundwater divide. The recharge basin will create a groundwater mounding effect, which could cause water from the recharge basin to flow in a westerly direction, and into a different drainage basin. In order to alleviate this problem, a second ("west") recharge basin will be placed outside of the contaminated zone on the west side of the groundwater divide to control the direction of flow from the east recharge basin. The flow rate to the west recharge basin will be larger than the flow rate to the east recharge basin, thus creating a larger groundwater mounding effect, forcing the water from the "east" recharge basin to flow 1n an easterly direction. The location and general layout of the proposed recharge basins are shown in Figure 4-4. A more detailed layout and a typical cross-section of the proposed recharge basins are shown on Figure 4-5. Two options are available for a water supply for recharging the leach field including: 1) effluent from the onsite treatment system, or 2) a new well — could be installed to supply clean water for this purpose. Since pumping from a nearby water supply well may complicate groundwater flow patterns, it was assumed for purposes of this study that effluent from the onsite treatment system would be used to recharge the leach field. This concept is illustrated in Figure 4-6. Periodic subsurface soil sampling and analysis would be required to monitor the progress of the soil flushing and to provide data for periodic reviews. Three test borings are assumed to be performed annually over a 30-year period, with three soil samples taken from each boring, for a total of 9 samples. With a recharge basin 1n place, test borings would have to be drilled at an angle using special drilling techniques, so that soil samples can be obtained without drilling through the recharge basin. Soil samples are to be analyzed for total volatile organ ics, base-neutrals, and acid extractables. Effectiveness > Soil flushing does not reduce the toxicity or volume of the soil contaminants, o but achieves clean up objectives by actually increasing the mobility to allow subsequent collection and treatment of the solublUzed contaminants using a 0 groundwater extraction or treatment system. =

o Ul

ACP-35-H 4_1Q PROPOSED LEACH FIELD FOR GROUNDWATER FLOW CONTROL (SEE FIGURE 4-5 FOR DETAILS)

ESTIMATED LOCATION OF LOCAL GROUNDWATER DIVIDE

PROPOSED LEACH FIELD(SEE FIGURE : 5 FOR DETAILS)

-A TEMPORARY O ^STOCKPILE •JO -J5 (AREA FOR

LOCATION OF\ FORMER DISPOS LAGOONS

WATER SUPPLY LINE FROM ONSITE WATER TREATMENT FACILITY (SEE FIGURE 4 - 6 )

A. 0. POLYMER SITE SC-i SOIL FLUSHING FEASIBILITY STUDY ICKTKCIINOLOGY INCORPORATE) DATE JULY 25, I990 DR.'K. GARDNER PITTS8URGH.P* SCALE' l'«50' CONTROL VALVE

4"0 PVC SUPPLY LINE FROM ONSITE WATER TREATMENT FACILITY (SEE FIGURE 4-4)

DISTRIBUTION PIPING 4"0 PERFORATED PVC, SLOPED AT 1% FOR GRAVITY FLOW

I 1-^ rs> PROPOSED LEACH FIELD

SCALEO =25

9 ROADWAY

4" 0 PERFORATED PVC 3' COVER SOIL DISTRIBUTION PIPING

18"

18" PERMEABLE GRAVEL BED, WRAPPED IN FILTER FABRIC SECTION A-A (LEACH FIELD) NOT TO SCALE | FIGURE 4-5

A. 0. POLYMER SITE PROPOSED LEACH FIELD FEASIBILITY STUDY

TOO ICK TECHNOLOGY INCOK I'ORATKI) DATE=JULY 30, 1990 DR. = K. GARDNER PITTSBURGH, PA SCALE: AS NOTED DWG. NO. LEACH FIELDS SOIL FLUSHING (SEE FIGURE 4-

,.'-<;v r—ar^—>i»

-T. ' ~ V; 'i'—" ,-«

,n-- fi

A. 0. POLYMER SITE FEASIBILITY STUDY DATE JULY 25, I99O Dft

4-13 A.O. Polymer Site Public Review Feasibility Study April 1991

The ability of a soil contaminants to be flushed through the soil matrix 1s dependent on the properties of the soil. The sandy soil at the A. 0. Polymer Site has a relatively high permeability and lends it self to this type of treatment. Highly permeable soils will allow large quantities of water to be flushed though the soil matrix. Physical properties of the contaminants, such as the solubility of the compound in water, the compound molecular weight, and the chemical desorption rate also affect the ability of a compound to be flushed from the soil. Table 4-1 presents molecular weight, water-solubilities and a qualitative assessment of the amenability of selected soil contaminants to soil flushing. Chlorinated aliphatic hydrocarbons such as tetrachloroethene, trichloroethene, and 1,1,1-trichloroethane which either contribute significantly to groundwater risks or, through biodegradatlon, yield by-products which contribute significantly, will be relatively amenable to soil flushing. Phenolic compounds have high solubilities and will also be rapidly flushed. The monoaromatic hydrocarbons, including chlorobenzene, ethylbenzene, toluene, and xylenes have relatively low solubilities in water, and these compounds may not be as effectively removed by soil flushing. However, these compounds are more susceptible to biodegradation in groundwater and soil flushing may enhance removal by this mechanism. The PAHs and phthalate esters are relatively insoluble in water and may not be effectively removed, but are not contaminants of concern at this site, since they were not present in groundwater and average soil concentrations and do not exceed the New Jersey soil action levels of 10 ppm total for base-neutrals. Non-toxic or biodegradable surfactants or chelating agents may be added to the recharge water to enhance the solubility of the contaminants. Because of the large number of variables which influence soil flushing, there is a degree of uncertainty in the ability of this alternative to achieve remediation objectives in a given time frame. Appendix C discusses soil flushing rates and provides an estimate indicating that soil cleanup objectives may be achieved within 5 years under this alternative. Although this estimate is approximate, it 1s significantly shorter than flushing under natural conditions. The design of the groundwater extraction system would also be modified to optimize the performance of the combined soil-flushing and groundwater extraction systems. In addition, a degree of uncertainty Is also inherent in any groundwater control systM. Soil flushing would require careful monitoring of gradient control during Implementation to insure that no contamination spreads to previously unaffected areas or areas that have been remediated. Implementability It is technically feasible to construct the recharge basins Illustrated on the accompanying figures, 1n the area of the former disposal lagoons. The area 1s flat and little site preparation or regrading would be required. No permits would be required; however, some type of agreement may be required with A. 0. Polymer, since the proposed recharge system would be located on A. 0. Polymer property.

AOP-35-H 4-14 TABLE 4-1 CHEMICAL PROPERTIES OF SELECTED SOIL CONTAMINANTS A.O. POLYMER SITE FEASIBILITY STUDY

Molecular Weight Water Vapor Henry's Amenable to Amenable to Solubility Pressure Law Constant Soil Flushing Vapor Extraction CHEMICAL COMPOUND (ing/1 • 20*C) (m* Hg • 20*C) (atM n'/mole) (L. M. H) (L. M. H)

HALOGENATED ALIPHATIC HYDROCARBONS Tetrachloroethene 165 150 17.8 2.6x10" N t-l.2-D1chloroethene 96 6.300 324 6.6x10* H 1.1.1-Trichloroethane 133 1.500 123 1.4x10" H Trlchloroethene 131 1.100 69 9.1x10" H 1.1.2-Trichloroethane 133 4,420 30.3 1.2x10" H TrichlorofluroMthMM 137.4 1.100 667 5.8x10' H MONOCYCL1C AROMATICS Chlorobenzene 112.6 466 11.7 3.7x10" M N •*• Ethyl benzene 106.2 152 7 6.4x10" M M •— Toluene 92.1 535 28 6.4x10" M H •" Xylene (Total) 106.2 198 10 7.0x10" M M PHENOLIC COMPOUNDS 2.4-DtMethylphenol 122.2 6.200 0.098 6.3x10 Phenol 94.11 87.000 0.524 4.0x10 2-Kethyphenol 0.15 4-Methylphenol

MISCELLANEOUS COMPOUNDS 1,2-01chlorobenzene 147.0 156 1.47 1.2x10" Benzole Acid 122.1 2700 0.005 7.0x10"

Notes: L'Low M'MediuM H-HIgh ' H - VP(atM) / SOL(M/1)] References: 1) Handbook of Environmental Fate and Exposure Data for Organic Chemicals. Philip H. Howard, 1989. — Value not found tn reference. However, phenolic compounds generally nave very high water solubility, and very low vapor pressure.

TOO A.O. Polymer Site Public Review Feasibility Study April 1991

The average Infiltration rate of local soils is moderately high (approximately 12 in/hr according to the Sparta Health Department) so basin capacities will most likely be limited by the extent of groundwater mounding. The unsaturated zone in the vicinity of the proposed basins is approximately 25 feet thick. However, to insure free drainage from the basins and to prevent excessive mounding from drastically effecting local groundwater flow, it is recommended that mounding be limited to less than half of this thickness during sustained recharge. In addition, mounding beneath the western basin must be maintained at a level several feet higher than mounding below the eastern basin to insure an effective barrier against westerly flow of leachate from the lagoon area. An analysis of mounding beneath the basins under various recharge delivery rates is presented in Appendix C. Individually, each basin is capable of receiving from 60 to 65 gpm without creating mounding in excess of 12 feet. Simultaneous operation of both basins requires that delivery rates be somewhat lower than this. The mounding analysis indicates, that if recharge rates of 52 gpm and 30 gpm were delivered to the western and eastern basins, respectively, maximum mounding under the western basin will be approximately 12 feet and mounding under the eastern basin will be approximately 9 feet. Therefore, these recharge rates satisfy both the 12 foot mounding criteria and the barrier requirement. Recharge basins use standard construction methods and materials, which are readily available. The time required for construction of the recharge system would be less than two months, weather permitting. The time required for flushing of soil contaminants to required cleanup levels was roughly estimated with a partitioning/pore volume flush model. This model estimated that Teachable contaminants would be removed to below soil remediation goals within 1 to 3 years if continuously flushed at a rate of 30 gpm. For purposes of this study an operating period of 5 years Is assumed. Periodic subsurface soil monitoring is technically and administratively simple to implement. Special drilling techniques will be required, so that soil samples can be obtained without drilling through the recharge basin. Test borings, soil sampling, and analysis of soil samples are standard practices, and the required services and equipment are readily available. Cost The costs associated with this alternative are relatively low and include recharge systta construction and operation, soil monitoring, and cost of periodic reviews. A major benefit of this treatment 1s that it is performed in-situ, thus eliminating the need for costly excavation and treatment/disposal of soil. > *o Conclusion o Soil flushing does not reduce the toxiclty or volume of the soil contaminants, £ but achieves remediation objectives by removing contaminants from the soil. If Implemented 1n conjunction with groundwater extraction and treatment, it £ Ln VO AO.-35-H A.O. Polymer Site Public Review Feasibility Study April 1991 could be effective as part of a total site remediation alternative. However, for the reasons presented in the discussions above, there is a degree of uncertainty In achieving soil remediation objectives in a given time frame . Soil flushing is relatively easy and inexpensive to implement, and will be retained for detailed evaluation. 4.2.4 SC-4: Soil Vapor Extraction The soil vapor extraction process involves applying a vacuum to venting wells installed in the contaminated vadose zone to volatilize the organics and draw the vapors Into a collection system where they would subsequently be removed with an activated carbon off-gas treatment system. The location and a general layout of a conceptual soil vapor extraction system 1s illustrated in Figure 4-7. A schematic process diagram showing the or-ration of a typical soil vapor extraction system is shown on Figure 4-8. A small amount of condensate liquid (water with contaminants at less than their saturation concentration) will be generated during the vapor extraction process. Typical condensate production volumes for projects with similar volumes of contaminated soil have ranged from 10 to 15 gallons/day for the first two weeks, with little to none produced thereafter. If an onsite water treatment system 1s operating onsite In conjunction with groundwater extraction and treatment, the condensate may be treated onsite at minimal additional cost. Otherwise, the condensate must be taken to an offsite treatment facility. x_ Periodic subsurface soil sampling and analysis would be required to monitor the progress of the soil vapor extraction process and to provide data for periodic reviews. Three test borings are assumed to be performed annually over a 30-year period, with three soil samples taken from each boring, for a total of 9 samples annually. Soil samples are to be analyzed for total volatile organics, base-neutrals, and add extractables. Effectiveness This process directly reduces the volume and mobility of soil contaminants. Soil vapor extraction collects the contaminants In the activated carbon off- gas treatment system, and thus concentrates the volatile contaminants Into the activated carbon for subsequent treatment. Since 1t removes the contaminants from the soil matrix, it also reduces the mobility of the contaminants (they can no longer act as a source of future groundwater contamination). A secondary benefit of this process 1s that natural blodegradatlon of some soil contaminants may be enhanced as a result of drawing oxygen through the soil. Vapor extraction is applicable at sites with the following site conditions: § 1) the volatile concentration in the soil 1s greater than 1 ppm, 2) the depth to groundwater 1s greater than 20 feet, 3) the volume of contaminated soil Is o greater than 500 cubic yards, and 4) the soil 1s relatively permeable to allow 2 air flow through the soil matrix. All of these conditions are present at the A. 0. Polymer Site. ?

AOP-35-N 4-17 TREATMENT STATION

LOCATION OF FORMER DISPOSAL LAGOONS

EXTRACTION WELL A. 0. POLYMER SITE INJECTION WELL SC-4: SOIL VAPOR EXTRACTION FEASIBILITY STUDY $ON. VIAPOR COLLECTION LINE Id-'TKCIINOLOGY INCORPORATED DATE = JULY 2

VACUUM PUMP CARBON ADSORPTION LJ_ LIQUID/VAPOR LIQUID RECOVERY SEPARATER TANK

PRODUCTION WELLS CONTAMINATED SOIL ZONE CLEAN AIR INJECTION WELL-

I FIGURE 4-8 A. 0. POLYMER SITE SOIL VAPOR EXTRACTION FEASIBILITY STUDY PROCESS DIAGRAM : TOO ICF TECHNOLOGY INCORPORATE) DATE JULY 23, 1990 DR.'K. GARDNER PITTSBURGH, PA SCALE= NONE DWG. NO. A.O. Polymer Site Public Review Feasibility Study April 1991

The sandy soil at the A. 0. Polymer Site has relatively high permeability and thus lends Itself to this type of treatment. Highly permeable soils will have high diffusion rates to allow large quantities of air to be passed through the soil matrix, thus increasing the volatilization of contaminants. Physical properties of the contaminants, especially the vapor pressure, and, to a lesser degree, the Henry's Law Constant, affect the ability of the contaminant to be removed from the soil through vapor extraction. Many of the soil contaminants of concern at this site, Including the halogenated aliphatic hydrocarbons and the monoaromatic hydrocarbons have relatively high vapor pressures and are very amenable to this type of treatment. Others, such as the phenolic compounds, have relatively low vapor pressures, and these most likely would not be volatilized during the soil vapor extraction process. However, phenolics tend to be very biodegradable, and may be biodegraded as oxygen is drawn through the soil matrix. The vapor pressures and Henry's Law Constants of the contaminants of concern in the soil are shown on Table 4-1. This table also presents a rating (high, medium, or low) of the responsiveness of each compound to the vapor extraction process. ImplementabmtY It is technically and administratively feasible to construct and operate a vacuum extraction system in the area of the disposal lagoons. Since the system would not occupy a large area, space constraints are not anticipated to be a problem. As with any of the source control onsite treatment alternatives, some type of agreement may be required with A. 0. Polymer, since the proposed vacuum extraction system would be located on their property. Since the vapors are collected with activated carbon, which would be subsequently taken offsite for regeneration or disposal, manifest documents may be required for offsite transport of the activated carbon. Construction of the vacuum extraction system utilizes standard construction methods and materials, which are readily available. The time required for construction of the venting wells and vapor collection system would be less than one or two months, and the time required for extraction of contaminants is typically less than one year. Periodic subsurface soil monitoring is technically and administratively simple to implement. Test borings, soil sampling, and analysis of soil samples are standard practices, and the required services and equipment are readily available. Cost The costs associated with this alternative are moderate and Include costs for implementation and operation of the soil vapor extraction system, soil monitoring, and cost of periodic reviews. A major benefit of this treatment 1s that It 1s performed in-situ, thus eliminating the need for costly excavation and treatment/disposal of soil.

AOP-35-H 4-20 A.O. Polymer Site Public Review Feasibility Study April 1991

Conclusion This process directly reduces the volume and mobility of soil contaminants, and may indirectly reduce the toxicity of some soil contaminants through enhanced biodegradatlon. If implemented in conjunction with groundwater extraction and treatment, It could be effective as part of a total site remediation alternative. Soil vapor extraction 1s relatively easy and only moderately expensive to implement, and will be retained for detailed evaluation. 4.2.5 SC-5: Soil Vapor Extraction and Soil Flushing This alternative combines the two alternatives described above. The soil flushing technology will remove aliphatic hydrocarbons and phenolic compounds relatively well, but may not be as effective in removing monocycllc aromatics. Vapor extraction, on the other hand, will perform well in removing monocyclic and aliphatic hydrocarbons but will not be as effective for phenolics. Combining both technologies Into one source control alternative will provide for more complete removal of the contaminants which pose the most threat to groundwater. Soil vapor extraction would be performed first on the soil to remove volatlles. A soil sampling and analysis program would then be implemented to assess the success of the soil vapor extraction, and to determine whether or not cleanup levels in soil have been achieved. If soil cleanup levels have not been achieved through soil vapor extraction, this process would be followed by soil flushing to flush any remaining water soluble contaminants from the soil. Periodic subsurface soil sampling and analysis would be required to monitor the progress of the soil vapor extraction process, the soil flushing process, and to provide data for periodic reviews. Three test borings are assumed to be performed annually over a 30-year period, with three soil samples taken from each boring, for a total of 9 samples annually. Soil samples are to be analyzed for total volatile organ ics, base-neutrals, and add extractables. Effectiveness The sandy soil at the A. 0. Polymer Site has relatively high permeability and thus lends itself to both soil vapor extraction and soil flushing treatment. Highly permeable soils will have high diffusion rates to allow large quantities of air to be passed through the soil matrix, thus Increasing the volatilization of contaminants. Highly permeable soils will also allow large quantities of water to be flushed through the soil matrix, thus reducing the time required for flushing. Most of the contaminants of concern in the soil are either volatile or water soluble and the combination of these two treatments would be effective in removing all of the contaminants of concern to some degree. Many of the contaminants which are not easily volatilized are very soluble, and would be

AOP-35-N 4-21 A.O. Polymer Site Public Review Feasibility Study April 1991 easily flushed through the soil. The combination of these two processes has a higher degree of reliability in reducing soil contaminant concentrations to action levels than either process alone. The degree of cleanup achieved by this alternative will determine the need for monitoring of the soil contamination. ImDlementabiHtv It is technically and administratively feasible to construct and operate both a recharge basin and a soil vapor extraction system. Soil vapor extraction would be performed first on the soil to remove volatlles. A soil sampling and analysis program would then be Implemented to assess the success of the soil vapor extraction, and to determine whether or not cleanup levels in soil have been achieved. If soil cleanup levels have not been achieved through soil vapor extraction, this process would be followed by soil flushing to flush any remaining water soluble contaminants from the soil. Details on implementability of soil flushing and soil vapor extraction are presented under alternatives SC-3 and SC-4 above. As with any of the source control onsite treatment alternatives, some type of agreement may be required with A. 0. Polymer, since the proposed vacuum extraction and soil flushing systems would be located on their property. Periodic subsurface soil monitoring 1s technically and administratively simple to implement. Special drilling techniques will be required, so that soil samples can be obtained without drilling through the recharge basin. Test borings, soil sampling, and analysis of soil samples are standard practices, and the required services and equipment are readily available. Cost The costs associated with this alternative Include costs for implementation and operation of the soil vapor extraction system, construction and maintenance of a recharge system for soil flushing, soil monitoring, and cost of periodic reviews. The major benefit of these treatments is that they are performed 1n-situ, thus eliminating the need for costly excavation and treatment/disposal of soil. Conclusion Soil vapor extraction directly reduces the volume and mobility of soil contaminants, and may Indirectly reduce the toxiclty of some soil contaminants through enhanced bi©degradation. Soil flushing does not reduce the toxiclty o or mobility of the soil contaminants, but achieves volume reduction by ^ speeding up the natural soil flushing mechanism to allow subsequent collection and treatment of the solubllized contaminants. The combination of these two § processes has a higher degree of reliability in reducing soil contaminant ^ concentration to action levels than either process used alone. ^ o Ul

AOP-35-H 4-22 A.O. Polymer Site Public Review Feasibility Study April 1991

Soil vapor extraction and soil flushing are relatively easy and only moderately expensive to Implement, and will be retained for detailed evaluation. 4.2.6 SC-6: Excavation and Low Temperature Thermal Desorotion This alternative would involve excavation of the contaminated soil, onsite treatment using low temperature thermal desorption, and backfill of the treated soil. Low temperature thermal desorption, also referred to as low temperature thermal soil aeration or low temperature thermal stripping, is a mass transfer process in which excavated soils are passed through a thermal process where volatile contaminants in soils are transferred to the gas phase. The off-gas is then passed through a carbon adsorption treatment system. The low temperature thermal desorption system consists of two main elements - an indirectly fired rotary dryer and an off-gas treatment system. Waste is fed into the rotary dryer (solid feeds must be screened to less than 2 Inches) where it is heated to a temperature of 450 to 850 degrees Fahrenheit. The thermal energy vaporizes the volatile and semi-volatile organics from the soil. The off gas passes through a treatment system consisting of a liquid scrubber, a condenser, a particulate filter, and a carbon adsorption unit. A schematic process diagram illustrating the low temperature thermal desorption process 1s presented on Figure 4-9. If the soil contaminants are removed to below the NJDEP action levels for soil, it is assumed that the treated soil may be used to backfill the excavation. effectiveness Thermal desorption reduces the mobility and volume of soil contaminants, but does not destroy organic contaminants or reduce their toxicity. Rather, the organics are physically separated from the soil. Treatment residuals will require subsequent disposal or destruction. This process Is most cost-effective for relatively large volumes (greater than 10,000 tons) of moderately contaminated solid wastes. The contaminated soil volume at the A. 0. Polymer Site has been estimated to be 7500 cubic yards, or approximately 11,250 tons. This process performs well on wastes with low moisture contents and low Btu values (i.e., soils with < 10X organics), which are generally difficult to Incinerate. The process has been demonstrated to be effective for a wide range of volatile and semi-volatile organic contaminants. All of the contaminants of concern in the soil at A. 0. Polymer are volatile or semi-volatile, and would be effectively treated using this process. Based on previous performances on similar types of soil, manufacturers of low temperature thermal treatment systems have indicated that, with the low concentrations of organic

AOP-35-H 4-23 CARBON ADSORPTION DRUMS VENT. GAS

SECONDARY TCUPCQATI IDC PARTICULATE CONDENSER FILTER

CONDENSATE STORAGE/ SEPARATION

HIGH- TEMPERATURE REHEAT

CONTAMINATED SOLIDS FEED

DRY PRODUCT Source: Adapted from Chemical Wast* Management, Inc

PROCESS FLOW DIAGRAM OF THE X*TRAX TREATMENT SYSTEM O o

m^ FIGURE 4-9

«M CO «M A. 0. POLYMER SITE LOW TEMPERATURE 5 FEASIBILITY STUDY THERMAL DESORPTION PROCESS o z ICF TECHNOLOGY INCORPORATED DATE 'JULY 3Q 1990 DR.'K. GARDNER 3 K PITTSBURGH, PA. SCALE: NONE DWG. NO.: 4-24 A.O. Polymer Site Public Review Feasibility Study April 1991 contaminants present, the process would likely reduce all contaminants to conventional detection levels. Thus, there is a high degree of reliability in achieving target cleanup levels for soil using this treatment. Bench scale studies would be required to confirm this. Based on the data supplied by vendors of this technology, 1t is the most reliable of the source control alternatives evaluated for achieving target cleanup levels in the soil. Residuals from the process Include: 1) treated soil, 2) spent carbon from treatment of off-gases, and 3) a small quantity of liquid condensate and sludge from the phase separator. Soils treated by this method would most likely not require further treatment or offsite disposal. The treated soil may be used to backfill the excavation. This represents an alternative which uses treatment as a primary component, and would eliminate or minimize the need for long-term monitoring of soil contamination. Implementabilitv This alternative requires excavation of the soil for subsequent treatment. Excavation and onsite treatment requires removing, stockpiling, and handling . contaminated soil. In this type of situation, contamination could be spread by volatilization, fugitive dust, storm-water runoff, and precipitation infiltrating through contaminated soil. Diligent control of fugitive dust and careful management of storm water will be required in order to reduce risks of spreading contamination to currently non-contaminated areas. Site space constraints affect Implementation of this alternative. Due to the large areas required to accommodate soil stockpiles, treatment facilities, staging areas and excavation equipment, careful coordination of site operations are required to maximize utilization of available space. Use of sheet piling to brace the excavation rather than safe cut-back slopes is recommended to minimize the size of the excavation and the amount of clean soil that would be removed and stored. Even with these precautions, operations associated with excavation and treatment may interfere with operations at the A.O. Polymer plant. In addition, the access road to the Sparta Gun Club will require relocation and certain areas outside of the A.O. Polymer property line will be required for stockpiles. A potential site layout, Illustrating the space required for treatment facilities, equipment operational areas, and stockpiles, 1s presented in Figure 4-10. Excavation of the contaminated soil would use standard construction methods and materials, which are readily available; however, due to the limited space > available, extensive bracing of the excavation may be required. *a Several companies are currently operating mobile treatment systems for low o temperature thermal desorption treatment. Chemical Waste Management, Inc. o (CWM) is currently operating the X*TRAX thermal desorption system at the bench scale, pilot scale (5 tons/day), and full-scale (150 tons/day) levels. Only one full-scale unit 1s currently available, but CWM reports that additional 00

AOP-35-H 4-25 CONTAMINATED __SOIL STOCKPILE

EQUIPMENT OPERATING LOW TEMPERTURE —— AREA ' ' —THERMAL TREATMENT .PROCESSING EQUIPMENT

TEMPOR CLEAN SOILX

ESTIMATED LIMITS OF EXCAVATION

CLEAN SOIL STOCKPILE AREA

A FIGURE 4-10 A. 0. POLYMER SITE SC-6: FEASIBILITY STUDY EXCAVATION AND THERMAL TREATMENT ICF TKCHNOLUGY INCOR I'ORATKD PITTSBURGH, P» 4-?6 A.O. Polymer Site Public Review Feasibility Study April 1991

units could be manufactured and operational within 9 months if required for a specific project. Since the off-gases are collected and treated with activated carbon, which would be subsequently taken offsite for regeneration or disposal, no releases of hazardous materials are anticipated. Because an externally fired dryer is used, no organic destruction takes place; thus, the unit is not required to meet the strict incinerator permitting standards. However, a submittal equivalent to a Part B Permit would be required. Manifests may be required for offsite transport of the liquid condensate, sludge, and exhausted carbon. As with any of the source control onsite treatment alternatives, some type of agreement may be required with A. 0. Polymer, since the proposed activity would be located on their property. In addition, excavation and treatment operations would require a significant amount of space on the A. 0. Polymer property, and these areas would be temporarily unavailable for A. 0. Polymer use. Exploratory sampling would be required to determine the limits of excavation, and confirmatory sampling of treated soil will be required throughout the project. It is assumed that an onsite mobile laboratory will be utilized for the analysis. Soil sampling and analysis is technically and administratively feasible to implement. Test borings, sampling, and analysis of soil samples are standard practices, and the required services and equipment are readily available. The time required for excavation, processing of soil through the thermal desorption operation, and backfill of the soil is estimated to be from 6 to 12 months. Approximately 9 to 12 months will be required up front for a soil sampling program, engineering and design, bidding and contract negotiations, and mobilization of equipment. Cost This alternative is approximately an order-of-magnitude more costly than the soil vapor extraction and soil flushing alternatives. The costs Include exploratory soil sampling and analysis, soil excavation and related material handling, mobilization and operation of the onsite thermal desorption system, analysis and offsite disposal of treatment residuals, confirmatory sampling and analysis of treated soil, and backfill of treated soil into the excavation. Conclusion This process separates and removes organics from the soil matrix. It directly reduces the volume and mobility, but not the toxicity of organic contaminants. Since it 1s proven to be effective and reliable in removing organic contaminants from soil, It will be retained for detailed evaluation.

AOP-3S-H 4-27 A.O. Polymer Site Public Review Feasibility Study April 1991

4.2.7 SC-7: Excavation and Offsite Landfill This alternative would Involve excavation of the contaminated soil, and transportation and disposal of the material at an approved offsite landfill. Subsurface contaminated soils are considered a hazardous waste because they represent soil clean-up residuals from the spill of probable hazardous wastes. Compliance with RCRA should be considered In evaluating potential landfills for offsite disposal. Due to the low concentrations of organlcs 1n the soil, the soil 1s not land banned under current land disposal restrictions. CERCLA/RCRA corrective action soils with less than 1 percent (10,000 ppm) total solvent constituents do not fall under the Superfund land disposal restrictions. Since the highest concentration of total organlcs found 1n the soil at this site 1s less than 200 ppm, this soil 1s not land banned and land disposal Is a viable alternative. Effectiveness This alternative would remove the contaminated soil from the site and would eliminate or minimize the need for long-term monitoring for soil contamination. Offsite disposal reduces the mobility of contaminants, since it removes the contaminants from the site; however, this alternative does not comply with the statutory preferences of CERCLA, Section 121(b), because It does not Involve treatment that permanently and significantly reduces the volume, toxlclty, or mobility of the hazardous substances. In addition, CERCLA states that offslte transport and disposal of hazardous substances or contaminated materials without treatment 1s considered the least favorable option when practical treatment technologies are available. Implementabllltv As previously discussed for Alternative SC-6, this alternative also requires excavation of the soil which presents material handling and related problems. Site space constraints My not be as much of a problem for this alternative since no treatment facilities are required, and the soil could be loaded directly onto trucks, thus eliminating the need for large stockpile areas. Because of the excavation and material handling Involved In Implementing this alternative, contamination could be spread by volatilization, fugitive dust, storm water runoff, and precipitation infiltrating through contaminated soil.

Reference: Superfund Land Disposal Restrictions Appendices, Sept 1989 o ICF Technology, Inc. *~*

MP-33-H 4-28 A.O. Polymer Site Public Review Feasibility Study April 1991

Excavation of the contaminated soil would use standard construction methods and materials, which are readily available. Due to the limited space available for excavation, bracing of the excavation 1s recommended as described in SC-6. No treatment residuals would be generated by this alternative. Manifests will be required for offsite transportation and disposal of the excavated material. As with any of the source control onsite treatment alternatives, some type of agreement may be required with A. 0. Polymer, since the excavation operation would be located on their property. In this alternative, excavation operations would require a significant amount of space, and may interfere with A. 0. Polymer plant operations. The total time required for excavation, offsite disposal of the soil, and backfill of the site is estimated to be from 1 to 2 years. Cost This alternative is at least an order-of-magnitude more costly than the soil vapor extraction and soil flushing alternatives. The costs include soil excavation and related material handling, analysis and offsite disposal of excavated soil, confirmatory sampling and analysis, and backfill of the excavation. Conclusion Since there are a number of other alternatives available which directly reduce the volume, mobility and toxicity of the contaminated soil, and practical treatment technologies (soil vapor extraction, soil flushing, and low temperature thermal desorptlon) are available, offsite landfill disposal will not be retained for detailed evaluation. 4.2.8 Summary of Source Control Alternative Screening Based on the Initial screening of source control alternatives, the following source control alternatives will be retained for detailed evaluation in Section 5.0: SC-1 No Action with Institutional Controls SC-2 Capping SC-3 Soil Flushing SC-4 Soil Vapor Extraction SC-5 Soil Vapor Extraction and Soil Flushing > SC-6 Excavation and Low Temperature Thermal Desorptlon o

4.3 MANAGEMENT OF MIGRATION (6RQUNDWATER) REMEDIAL ALTERNATIVES OSWER Directive 9283.1-2, "Guidance on Remedial Actions for Contaminated ^ Groundwater at Superfund Sites*, December, 1988, indicates that ..... 3 fo

AOP-35-H . A.O. Polymer Site Public Review Feasibility Study April 1991

"Several types of remedial action alternatives that span a range of technologies and restoration time frames should be developed early in the FS process. Potential response approaches include the following: o An active restoration alternative that reduces contaminant levels to required cleanup levels in the minimal time feasible o Additional active restoration alternatives that achieve cleanup levels over longer time frames o A plume containment alternative that prevents expansion of the plume o A natural attenuation alternative that includes institutional controls and monitoring o An alternative involving wellhead treatment or provision of an alternative water supply and institutional controls when active restoration is not practicable." Considering this guidance and our current knowledge of the site, the following potential management of migration remedial action alternatives have been developed: MM-1 : No Action with Institutional Controls MM-2 : Extraction and Treatment - Biological/Air Stripping/Carbon Adsorption MM-3 : Extraction and Treatment - Steam Stripping/Carbon Adsorption MM-4 : Extraction and Treatment - Powdered Activated Carbon Treatment (PACT) MM-5 : Extraction and Treatment - UV Oxidation Alternative MM-1 represents a natural attenuation alternative that includes institutional controls and monitoring. The remaining alternatives, MM-2 through MM-5, represent active restoration alternatives that utilize different treatment systems to reduce contaminant levels to required cleanup levels. Since each extraction and treatment alternative (MM-2 through MM-5) has the same extraction options, the discussion of these alternatives will focus on the effectiveness, implementability, and cost of the treatment systems. Two extraction options, one which achieves a nearly complete cleanup and one which achieves a lesser degree of active restoration are proposed. These options are described and discussed in Section 4.4. The process option for disposal of treated water for each extraction and treatment alternative which 1s evaluated in this report 1s surface water discharge to the Wall Mil River. This option 1s assumed In subsequent costing and evaluation exercises. However, the option of discharging treated water to groundwater 1s not ruled out and could be selected in the event that discharge to surface water becomes difficult to implement. Use of recharge basins for

AOP-35-H 4-30 A.O. Polymer Site Public Review Feasibility Study April 1991 disposal of treated water was discussed under SC-3 and is the recommended technology for discharge to groundwater. A plume containment alternative that prevents expansion of the plume is not considered. The reason for this is that plume containment technologies were screened out in the technology screening process due to fractured bedrock conditions at the site. Additionally, based on information presented in the RI Report, the full downgradlent extent of the plume near the Wallklll river has not been defined. Since there are no water supply wells within the contaminated aquifer, consideration of a wellhead treatment or alternate water supply alternative is not applicable. 4.3.1 MM-1: No Action with Institutional Controls This alternative would involve restrictions on future groundwater use, public awareness and education programs, and groundwater monitoring. This alternative represents a natural attenuation alternative that includes institutional controls and monitoring, as required under CERCLA. Periodic groundwater sampling and analysis would be required to monitor the progress of natural attenuation and to provide data for periodic reviews. Ten monitoring wells are assumed to be sampled semi-annually over a 30-year period, for a total of 20 samples annually. Groundwater samples are to be analyzed for total volatile organics. Effectiveness This alternative would not actively reduce the toxicity, volume or mobility of the groundwater contaminants. However, since human health risks are identified based only on potential future use, restrictions on future groundwater use could be effectively used to manage long-term risks associated with ingestion of contaminated groundwater. The groundwater would be remediated only through natural attenuation. Natural attenuation, the reduction of contaminant concentrations in groundwater over time through natural flushing was evaluated using solute transport modeling as discussed later In this section. TCE was selected as an Indicator chemical because it has a distribution similar to most other contaminants, 1s moderately mobile and persistent and possesses the lowest MCL of the contaminants of concern. Using TCE as the Indicator chemical, the time period required for cleanup levels to be achieved through natural attenuation of the > existing groundwater plume Is estimated to be approximately 27 years. In o addition, natural source flushing, the time required for precipitation and ^ infiltration to flush contaminants from the source area soils 1s estimated to 0 take up to 60 years. Therefore, If source control 1s Implemented, the time o required for natural attenuation of the aquifer will be approximately 27 """ years. If no source control 1s implemented, and no groundwater remediation is ^ implemented, the total time required for natural attenuation of the soil and o the aquifer 1s estimated to be over 87 years. ^

AOP-35-H 4-31 A.O. Polymer Site Public Review Feasibility Study April 1991

Implementability N- Groundwater use restrictions are easily Implemented through deed restrictions or other Institutional controls, but are only effective If properly enforced. Groundwater use restrictions should be implemented at the site until the contaminated groundwater at the site 1s remediated through natural attenuation. Groundwater use restrictions will not meet target cleanup levels for groundwater; however, If consistently enforced, they are effective In managing long-term public health risks. Public awareness and education programs are typically administered by either the U. S. EPA or by the State. These programs are designed to inform the public of the action being implemented at the site, and the potential public health and environmental risks remaining at the site. Periodic groundwater monitoring 1s technically and administratively feasible to Implement. Existing monitoring wells could be used, or new monitoring wells could be installed. Standard sampling and analytical equipment 1s used for groundwater monitoring, and the required equipment and services are readily available. Cost The costs associated with this alternative are low and Include administrative costs of groundwater use restriction Implementation, groundwater monitoring, and cost of periodic reviews. X. Conclusion The no action alternative results in potential human health risks. However, risks are based on potential future ingestlon, and 1f source action Is taken, risks will be reduced In approximately 27 years. Institutional controls, If strictly enforced, would be effective in protecting public health over this time period. 4.3.2 MM-2: Extraction and Treatment - Biological/A1r Stripping/ Carbon Adsorption This groundwater treatment alternative utilizes aerobic biological treatment (i.e., activated sludge) as a first step to remove biodegradable compounds including ketones and sow monoaromatic hydrocarbons. This would be followed by air stripping to remove the volatile halogenated aliphatic hydrocarbons and the remaining monoaromatic hydrocarbons. A1r stripping would be followed by activated carbon adsorption as a polishing step to remove any remaining organlcs. Treated water 1s assumed to be discharged to the Wallklll River. § However, recharge basins could be used for disposal of treated water as *° described 1n SC-3. A schematic process diagram Illustrating this treatment train 1s shown in Figure 4-11. *—o< The first primary treatment component of this treatment system 1s aerobic biological, or activated sludge treatment. In aerobic biological treatment, 0

ACP-35-N 4-32 INFLUENT BAG OR CARTRIDGE EQUALIZATION TANK FILTRATION

BIOLOGICAL TREATMENT

(AERATION STAGE)

VAPOR-PHASE CARBON TREATMENT OFF-GAS

BIOLOGICAL TREATMENT OFF-GAS (CLARIFIER STAGE)

GRANULAR PACKED DISCHARGE TO ACTIVATED TOWER CARBON SURFACE WATER AIR STRIPPER VESSELS

| FIGURE 4-11 A.O. POLYMER SITE ALTERNATIVE MM-2 FEASIBILITY STUDY BIOLOGICAL/AIR/CARBON TOO ICF TECHNOLOGY INCORPORATED DATE: AUG. 7, 1990DR.: B. SNYDER PITTSBURGH, PA SCALE: N.T.S. DWG. NO. A.O. Polymer Site Public Review Feasibility Study April 1991 micro-organisms are used to degrade organic compounds in the presence of oxygen. The nlcrobial degradation of organics transforms organic carbon into carbon dioxide through enzymatic oxidation and produces carbon dioxide and microbial biomass (sludge) as by-products. The sludge will require dewatering and offsite disposal or treatment. Periodic seeding of micro-organisms may be required due to the low BOO of the groundwater. Nutrients will be added to the system to sustain the micro-organisms. A schematic process diagram illustrating this treatment process is shown in Figure 4-12. Air stripping 1s the second primary component of this treatment system. Air stripping is used to remove the halogenated hydrocarbons and aromatics. Air stripping is a mass transfer process in which volatile contaminants in water are transferred to the gaseous phase. This process works best on contaminants with high volatility and low solubility. Since air stripping transfers contaminants from water to air, off-gas treatment may be required. Generally, vapor-phase carbon is used to treat off-gas. The presence of halogenated hydrocarbons precludes the use of catalytic converters to treat off-gas. A schematic diagram illustrating a packed column air stripper is shown in Figure 4-13. Carbon adsorption would be the third primary component of the treatment system. Carbon adsorption removes organics from waste water via surface attachment of organic solutes onto the activated carbon. Carbon adsorption is effective in removing the remaining halogenated aliphatic and monoaromatic hydrocarbons. Exhausted activated carbon would have to be regenerated or disposed, and would be replaced by new or regenerated carbon. A schematic diagram Illustrating activated carbon treatment is shown in Figure 4-14. This alternative would also Involve restrictions on future groundwater use, public awareness and education programs, and groundwater monitoring. Effectiveness Biological, air stripping, and activated carbon treatment work best for waste water with suspended solids less than 100 ppm. Some type of filtration unit, such as a granular media filter, cartridge filter, or bag filter would probably be used as a pretreatment step to reduce suspended solids and increase the efficiency of the subsequent treatments. Air stripping and carbon adsorption are often used in conjunction and complement each other's effectiveness. Many of the chemicals having relatively short activated carbon breakthrough times are volatile and are easily removed via air stripping. The combination of air stripping and carbon > adsorption is generally an effective approach to removing volatile organic ^ contaminants from water. o Ketones and some monoaromatic hydrocarbons are readily biodegradable, and 3 would be amenable to aerobic biological degradation. The halogenated aliphatics and remaining monoaromatic hydrocarbons are not readily £ biodegradable, but would be effectively removed by air stripping or carbon -j adsorption. "

AOP-35-H 4-34 Aeration Clarifier Stage Stage

Mastewater 1 1 ——— reePnarul *^^~~-^r-rr~r: )s _J L • • • Effluent Fixed Air * * • • «*> * t * * S/' Bubble nv^ Ul ^^ '$}>Z>~-rt&^ Ai^^•ri —^^^^^» •^ • Assembly M 1 Activated Sludge Recycle

SCHEMATIC DIAGRAM OF ACTIVATED SLUDGE BIOLOGICAL TREATMENT

| FIGURE 4- 12

A. 0. POLYMER SITE BIOLOGICAL TREATMENT FEASIBILITY STUDY too DATE JULY 20,1990 OR • K. GARDNER 8 LOT- ICFTECHNOLOGY INCORPORATED PITTSBURGH, PA SCALE= NONE DWG. NO. \

u* et

PACKED COLUMN AIR STRIPPER : SCHEMATIC DIAGRAM OF DESIGN BASIS, SIDE, TOP, AND ON ROAD VIEWS

I FIGURE 4-13

A. 0. POLYMER SITE AIR STRIPPING FEASIBILITY STUDY too ICFTECHNOLOGY INCORPORATED DATE AUG. 9, 1990 OR K GARDNER PITTSBURGH, PA SCALE •• AS NOTED DWG. NO. CARBON MAKE-UP

FROM CARBON REGENERATION TO CARBON SYSTEM REOENERATION 1 SYSTEM

CARBON BED CARBON BED

WATER __^EFFLUENT (TREATED WATER)

HIGH PRESSURE SPENT CARBON SLURRY WATER SCHEMATIC DIAGRAM OF GRANULAR ACTIVATED CARBON COLUMNS

f FIGURE 4-14

A. 0. POLYMER SITE CARBON ADSORPTION FEASIBILITY STUDY 80r : : ° IGFTKCIINOUHiV INCORPORATED DATE AUG. 9, 1990 DR K. GARDNER PITTSBURGH, PA SCALE= NONE DWG. NO. A.O. Polymer Site Public Review Feasibility Study April 1991

Physical properties of the contaminants, such as the solubility of the compound in water, the vapor pressure, and the BOD/COO ratio affect the ability of the compound to be treated by biological, air stripping, or carbon adsorption treatment. These physical properties of the A. 0. Polymer Site groundwater contaminants and their relative treatability by biological, air stripping, and carbon adsorption treatment is presented on Table 4-2. For example, the BOO/COO ratio indicates the ability of a compound to biodegrade. A BOD/COO ratio greater than 0.01 indicates moderate biodegradability, and a BOD/COD ratio greater than 0.1 indicates relatively high biodegradability. In general, the halogenated aliphatic hydrocarbons are relatively unbiodegradable, whereas the ketones and monocyclic aromatic hydrocarbons are moderately to highly biodegradable. Compounds which are highly water soluble or have low volatility (low Henry's Law Constants) are difficult to remove by air stripping. Compounds with Henry's Law Constants greater than 3.0 x 10 atm-m / mole are considered volatile and are amenable to removal by air stripping. In general, the halogenated aliphatic and monocyclic aromatic hydrocarbons are amenable to air stripping. On the other hand, the ketones and phenol have low volatility and very high water solubility, and would not be removed by air stripping. The effectiveness of activated carbon is limited by characteristics such as low molecular weight, high polarity, and high water solubility. Ketones and phenol, which have very high water solubility, would not be effectively treated by activated carbon adsorption. However, the halogenated aliphatic and monocyclic aromatic groups are generally effectively treated by activated carbon adsorption. Based on the known treatability characteristics of the contaminants present in the site groundwater, this treatment system consisting of biological, air stripping and carbon adsorption appears to be effective in treating all of the groundwater contaminants at the site. However, treatability studies, including bench scale testing, are recommended prior to the design of the treatment system in order to determine the system configuration and operating characteristics, and to verify that the treatment system effluent will comply with discharge limitations. Treatability studies are especially important for biological treatment. Implementabllltv In biological treatment, abrupt changes in the waste stream characteristics can generate shock loadings to the biomass. This 1s not anticipated to be a problem for this groundwater treatment application. An equalization basin before the bioreactor can reduce this effect to some degree. § >tf Some organics may volatilize during aeration in biological treatment. If required, these vapors can be vented to an off-gas carbon treatment system. § The same off-gas treatment system can be used for both the air stripping and ^ the biological treatment systems. _ o 00

AOP-35-H 4-38 TABLE 4-2 CHEMICAL PROPERTIES OF SELECTED GROUNOWATER CONTAMINANTS A.O. POLYMER SITE FEASIBILITY STUDY

Amenable to Amenable to Amenable to Water Vapor Henry's Air Carbon Biological Solubility Pressure Law Constant BOD*/COO Stripping Adsorption* Treatment 3 Chemical Compound (•g/1 • 2S*C) (M Hg f1 25*C) (atm m /»ole) Ratio (L. M. H) (L. M. H) (L.N.H)

KETOMES

4-Methyl-2-pentanone 19.000 10 0.044 Acetone 1.000,000 270 2.1x10" 0.55 2-Botanone 266.000 77.5 2.7x10-s 0.68

HAL06ENATED ALIPHATIC HYDROCARBONS

Tetrachloroethene ISO 17.6 2.6x10" 0.0 t-l,2-Dichloroethene 6.300 324 6.6x10" Chloroforn 8,200 150 .4x10" 0.0 1.1-Dtchloroethane 5,500 160 .4x10* 1.1-Otchloroethene 2.250 591 .4x10" 1.2-Dlchloropropane 2,700 42 .3x10" 1.1.1-Trlchloroethane 1,500 123 4x10 Trtchloroethene 1.100 58 1x10 TrlchlorofluroMthane 1,100 667 5.8x10" Carbon Tetrachlortde 605 113.8 3.0x10' 0.00 1.1.2-Trichloroethane 4,420 30.3 1.2x10"

MOMOCYCLIC AROMAT1CS

Chlorobenzene 466 11.7 3.7x10" 0.15 M Ethyl benzene 152 7 6.4x10" 0.009 L Benzene 1,750 95 5.6x10" 0.39 H Toluene 535 28 6.4x10" 0.12 M Xylene (Total) 190 10 7.0x10" 0.008-0.11 L-M

MISCELLANEOUS COMPOUNDS

Phenol 67,000 0.524 4.0X10" 0.61

Notes: L-Low, M«MediuM, H'High ' H - VP(atM) / SOL(M/1)*

Sources: 1) EPA Publication PB87-201034, "Remedial Action at Waste Disposal Sites". October 1985 (Table 9-1). 2) Handbook of EnvtronKntal Fate and Exposure Data for Organic Chemicals, Philip H. Howard. 1989.

-- Val.i" not found in reference. 2801 TOO dOV A.O. Polymer Site Public Review Feasibility Study April 1991

Inorganics, especially iron and manganese, tend to oxidize and clog the packing of air stripping towers, and may also interfere with the carbon adsorption and biological processes. Concentrations of iron and manganese were present in the groundwater samples at levels sufficient to potentially interfere with the treatment components; however, these samples were unfiltered. A simple bag or cartridge filter system would remove suspended solids and should significantly reduce metals concentration. If inorganics are not adequately removed by filtration, precipitation would be required as a first step in the treatment system. The need for precipitation as a pretreatment must be determined through treatabillty testing. Long-term management of the treatment system would be required to insure the continued operating efficiency of the system. The system can be automated to some extent; however, a full-time operator would be required to manage the treatment system. The implementability of public awareness and education programs, groundwater use restrictions, and groundwater monitoring is described under Alternative MM-1. Implementability of groundwater extraction systems was discussed in Section 4.4. Cost Costs associated with biological treatment Include capital costs for the bioreactor, pumps, and other mechanical equipment. 0 & M costs are relatively low and include operation of pumps, addition of nutrients, and pH adjustment. Costs associated with air stripping towers are related to tower height, air- to-water ratio, and the concentrations and volatility of the compounds being removed. Maintenance Items Include pumps, blowers, and replacement of carbon in the off-gas treatment. Tower packing may need to be cleaned occasionally if iron precipitates or slime accumulates. Costs associated with activated carbon adsorption Include the capital cost of the vessel, and the cost of replacement carbon. Periodic sampling and analysis would be required to determine when chemical breakthrough of the carbon has occurred. The need for precipitation as a pretreatment must be determined through treatabillty testing. The cost estimates presented herein assume that precipitation Is not required. The services of a full-time operator would be required. Other costs associated with this alternative Include groundwater extraction > system installation and operation, groundwater use restriction implementation, ^ public awareness/education programs, groundwater monitoring, and periodic reviews.

o 00 u>

AOP-35-H 4_4Q A.O. Polymer Site Public Review Feasibility Study April 1991

Conclusion This type of treatment train 1s cost-effective 1n treating the contaminants in the groundwater at the A. 0. Polymer Site, and will be retained for detailed evaluation. However, treatability studies are required to determine the effectiveness of the treatment system and the compliance of the treatment system effluent with proposed discharge limitations. Treatabillty studies are especially critical for biological treatment. 4.3.3 HM-3: Extraction and Treatment - Steam Stripping/Carbon Adsorption In this alternative, steam stripping would be used to remove halogenated aliphatic and monoaromatic hydrocarbons, and ketones. Off-gases from the stripper would be treated with vapor-phase activated carbon adsorption. Activated carbon adsorption would be used as a polishing step to remove any remaining organics. A schematic process diagram illustrating this treatment train is shown in Figure 4-15. The first primary component of this treatment system would be steam stripping. Steam stripping 1s similar to air stripping, in that it 1s a mass transfer process in which volatile contaminants in water are transferred to the gaseous phase; however, steam 1s used in the process to raise the temperature and Increase the volatility of contaminants which have relatively low volatility, such as ketones. Steam stripping can be used to remove contaminants with relatively low volatility, which cannot be removed via air stripping. Ketones, which are difficult to remove using air stripping, may be effectively removed with steam stripping. -^ Carbon adsorption would be the second primary component of the treatment system. Carbon adsorption removes organics from waste water via surface attachment of organic solutes onto the activated carbon. Carbon adsorption is effective in removing any remaining chlorinated hydrocarbons and aromatlcs. Exhausted carbon would have to be regenerated or disposed, and would be replaced by new or regenerated carbon. Treated water would be discharged to the Wall kill River. This alternative would also involve restrictions on future groundwater use, public awareness and education programs, and groundwater monitoring. Effectiveness Steam stripping and activated carbon treatment work best for waste water with suspended solids less than 100 ppm. Some type of filtration unit, such as a granular media filter, cartridge filter, or bag filter would probably be used o as a pretreatment step to reduce suspended solids and Increase the efficiency ^ of the subsequent treatments. 0 o Air or steam stripping and carbon adsorption are often used in conjunction and *"* complement each other's effectiveness. Many of the chemicals having ^ relatively short activated carbon breakthrough times are volatile and are o

AOP-35-N 4-41 VAPOR-PHASE CARBON TREATMENT

INFLUENT GRANULAR STEAM ACTIVATED DISCHARGE TO STEAM INJECTION STRIPPER CARBON SURFACE WATER VESSELS

BOILER (PROPANE, GAS, OIL, OR ELECTRIC)

| FIGURE 4-15 A.O. POLYMER SITE ALTERNATIVE MM-3 FEASIBILITY STUDY STREAM STRIPPING/CARBON TOO ICF TECHNOLOGY INCORPORATED DATE: AUG. 7, 1990 DR.: B. SNYDER PITTSBURGH. PA SCALE: N.T.S. DWG. NO. A.O. Polymer Site Public Review Feasibility Study April 1991

easily removed via air stripping. The combination of air stripping and carbon adsorption 1s generally a very effective approach to removing volatile organic contaminants from water. Based on the known treatablllty characteristics of the contaminants present in the site groundwater, this treatment system consisting steam stripping and activated carbon adsorption appears to be effective in treating all of the groundwater contaminants at the site. However, treatablllty studies including bench scale testing are recommended prior to the selection and design of the treatment system in order to determine the effectiveness of the treatment and the compliance of the treatment system effluent with proposed discharge limitations. Ketones may be removed to some extent in the steam stripping process; however, the reliability in achieving target cleanup levels may be low. Treatablllty studies would be required to assess the effectiveness of steam stripping in treating ketones. ImplementabiHtv Since steam stripping transfers contaminants from water to air, off-gas treatment will be required. The presence of chlorinated hydrocarbons eliminates the possibility of utilizing thermal or catalytic destruction; therefore, carbon adsorption is the only viable option for off-gas treatment. However, ketones are problematic in vapor phase carbon. Ketones create exothermic reactions with activated carbon, which may result in heat excursions, or fires. This reaction would be difficult to control in steam stripping, where the carbon bed temperature would already be elevated. Very expensive temperature monitoring and temperature control equipment would be required to prevent potential overheating and fire in the carbon bed. In addition, continuous operator attention would be required in order to monitor the system and prevent overheating. Steam stripping Is very energy-Intensive. Steam generation may account for a large portion of the operating costs of the system. Inorganics, especially Iron and manganese, tend to oxidize and clog the packing of steam stripping towers, and may also Interfere with the carbon adsorption process. Significant concentrations of iron and manganese were present in the groundwater samples; however, these samples were unfiltered. A simple bag or cartridge filter system would remove suspended solids and may significantly reduce metals concentration as well. If Inorganics are not adequately removed by filtration, precipitation would be required as a first step in the treatment system. The need for precipitation as a pretreatment must be determined through treatablllty testing. Long-term management of the steam stripping unit and activated carbon unit § would be required to Insure the continued operating efficiency of the system. ^ Because careful monitoring of the off-gas carbon treatment system 1s required, a full-time operator would be required to manage this treatment system. § i—i The implementability of public awareness and education programs, groundwater use restrictions, and groundwater monitoring is described under Alternative o 00

AOP-35-H 4-43 A.O. Polymer Site Public Review Feasibility Study April 1991

MM-1. Impleaentabllity of groundwater extraction systems is discussed in Section 4.4. Cost Steam generation is energy intensive, and would be a major operating expense. In addition, very expensive temperature monitoring and control equipment would be required to minimize the overheating potential of the carbon bed in the off-gas treatment. The services of a full-time operator would be required to manage this treatment system. Costs associated with steam stripping towers are related to tower height, air- to-water ratio, and the concentrations and volatility of the compounds being removed. Maintenance items include pumps, blowers, and replacement of carbon in the off-gas treatment. Tower packing may need to be cleaned occasionally if iron precipitates or slime accumulates. Costs associated with liquid-phase activated carbon adsorption include the capital cost of the vessel, and the cost of replacement carbon. Sampling and analysis would be required to determine when chemical breakthrough of the carbon has occurred. Other costs associated with this alternative include groundwater extraction system installation and operation, groundwater use restriction implementation, public awareness/education programs, groundwater monitoring, and periodic reviews. Conclusion Steam stripping is considered as an alternative because ketones may be removed to some extent in the steam stripping process, where they would not be removed in a standard air stripping process. However, the reliability in achieving target cleanup levels for ketones may be low. In addition, ketones are problematic in vapor phase carbon. Ketones create exothermic reactions with activated carbon, which results in overheating of the carbon bed, and may possibly result in fires. This produces operational problems which are very difficult and expensive to manage. The operating costs associated with this type of treatment system may make this alternative cost-prohibitive. Steam generation 1s energy Intensive, and would be a major operating expense. In addition, very expensive temperature monitoring and control equipment would be required to minimize the overheating potential of the carbon bed In the off-gas treatment. The services of a full- time operator would be required to manage this treatment system. Due to the operational complexities and high costs anticipated for this alternative, and the unknown effectiveness of the treatment, this alternative will be eliminated from further consideration and will not be evaluated in the detailed analysis of Section 5.0. o 00

AOP-35-M 4-44 A.O. Polymer Site Public Review Feasibility Study April 1991

4.3.4 HH-4: Extraction and Treatment - PACT Powdered activated carbon treatment (PACT) is an innovative biological approach, utilizing activated sludge in conjunction with powdered activated carbon. Powdered activated carbon is added to the aerator of the activated sludge system. The combined biological and activated carbon treatment is synergistic; the carbon enhances the biological treatment by also adsorbing biodegradable;. Many compounds are adsorbed on the carbon, which is removed and recycled along with the biomass in the clarifier. As the compounds adsorbed to the activated carbon are recycled with the sludge, they have a much longer system retention time, allowing a greater degree of biological degradation. The presence of carbon in the aeration basin also acts as a buffer to protect the easily upset biological process against shock loadings caused by sudden changes in influent concentration. Batch PACT plants are single tank systems, and consist of an aeration tank containing micro-organisms and nutrients for biological treatment, and powdered activated carbon. Depending on the flow rate of water to be treated, a continuous flow treatment process may be applicable. In a continuous flow treatment scheme, groundwater would be pumped directly to an aerobic reactor containing micro-organisms and nutrients for biological degradation, and activated carbon. An effluent stream is continuously withdrawn from the reactor and pumped to a clarifier. The supernatant (clean water) from the top of the clarifier may require filtration or a carbon polishing step prior to being discharged to the Wallkill River. A schematic process diagram, illustrating the continuous flow treatment system 1s shown in Figure 4-16. Waste sludge from the clarifier will require dewatering and offsite disposal. The waste sludge may contain elevated levels of organics and heavy metals. TCLP testing will be required to determine whether or not the sludge is hazardous. This alternative would also Involve restrictions on future groundwater use, public awareness and education programs, and groundwater monitoring. Effectiveness It is difficult to evaluate the applicability of PACT for a low concentration groundwater without information on TOC or COO of the water. In general, a minimum COO of 50 ppw 1s required to sustain biological activity in the treatment system. Treatability studies, including bench scale testing, are recommended prior to the design of the treatment system in order to determine the system configuration and operating characteristics, and to verify that the treatment system effluent will comply with discharge limitations. Implementabllitv This treatment system 1s technically and administratively feasible to implement.

O 03 03 AOP-35-N 4-45 VIRGIN CARBON STORAGE POLYELECTROLYTE STORAGE

FILTRATION CLARIFICATION (OPTIONAL) PRIMARY . EFFLUENT

CONTACT-AERATION ^-EFFLUENT TANK

CARBON RECYCLE

I O»

OVERFLOW

TO REGENERATION OR SOLIDS DISPOSAL

PACT®WASTEWATER TREATMENT SYSTEM GENERAL PROCESS DIAGRAM

I FIGURE 4-16 A. 0. POLYMER SITE ALTERNATIVE MM -4 FEASIBILITY STUDY PACT DATE : AUG. 9, 1990 DR. ' K. GARDNER 6801 too ICF TECHNOLOGY INCOR I'ORATKI) PITTSBURGH, PA SCALE = NONE DWG. N0.= A.O. Polymer Site Public Review Feasibility Study April 1991

Unlike the air stripping and carbon adsorption process, the operational efficiency of the PACT system is not affected by the presence of inorganics. In fact, some heavy metals are actually removed in the process. Past experience with PACT has shown 70% to 90% removal of inorganics, including iron and manganese. Precipitation as a pre- or post-treatment process would not be required. Long-term management of the PACT treatment system would be required to insure the continued operating efficiency of the system. The services of a full-time operator would be required to manage the treatment system. The implementability of public awareness and education programs, groundwater use restrictions, and groundwater monitoring is described under Alternative MM-1. Implementability of groundwater extraction systems is discussed in Section 4.4. Cost Costs for PACT include the capital costs for equipment and installation. Operating costs include activated carbon use, polymer use, dewatering and disposal of waste sludge, equipment repair and maintenance, and power supply. Long-term management of the system would be required to insure it's continued operating efficiency. The services of a full-time operator would be required. Other costs associated with this alternative include groundwater extraction system installation and operation, groundwater use restriction implementation, public awareness/education programs, groundwater monitoring, and periodic reviews. Conclusion This type of treatment could potentially be cost-effective in treating the contaminants in the groundwater at the A. 0. Polymer Site, and will be retained for detailed evaluation. However, treatability studies are required to accurately determine the feasibility and cost-effectiveness of PACT as a treatment system. 4.3.5 MM-5: Extraction and Treatment - UV Oxidation UV Oxidation Is an emerging technology for cleanup and destruction of organics in groundwater. Commercial applications using hydrogen peroxide and ozone as the oxidant have been developed. In this process, ultraviolet light reacts with hydrogen peroxide and/or ozone molecules to form hydroxyl radicals. These very powerful chemical oxidants then react with the organic contaminants in water. In addition, many organic contaminants absorb ultraviolet light and become more reactive with the chemical oxidants. A schematic diagram illustrating a UV Oxidation system is shown in Figure 4-17. If carried to completion, the end products of the oxidation process are carbon dioxide, water, and any other oxidized substances associated with the original

AOP-35-H ELECTRICAL LAMP DRIVE ENCLOSURES CONTROL PANEL- DISCONNECT (BEHIND) PANEL OXIDATION CHAMBERS

i oo

7--

UV OXIDATION SYSTEM /PEROXIDATION SYSTEMS, INC.\ V MODEL CW-540 /

| FIGURE 4-17 A. 0. POLYMER SITE ALTERNATIVE MM-5 FEASIBILITY STUDY UV OXIDATION TREATMENT : TOO ICFTECHNOLOGY INCORPORATED DATE AUG. 23, 1990 DR.' K. GARDNER PITTSBURGH, PA. SCALE NONE DWG. NO. A.O. Polymer Site Public Review Feasibility Study April 1991

organic wastes (e.g., organic sulfides would be oxidized to produce carbon dioxide, water, and sulfate ions). Design and operation of a UV Oxidation system is dependent on the type and concentration of organic contamination, the light transmittance of the water, and the type and concentration of dissolved solids. Pretreatment, such as filtration, of the contaminated groundwater may be necessary to reduce the suspended solids content. Excessive suspended solids can occlude the ultraviolet light, thus decreasing the effectiveness of the system. Treated water may require a carbon polishing step in order to meet discharge limitations prior to being discharged to the Wall kill River. This alternative would also involve restrictions on future groundwater use, public awareness and education programs, and groundwater monitoring. Effectiveness UV/Oxidation is very effective in oxidizing a variety of chlorinated and aromatic hydrocarbons. As in chemical oxidation, the presence of a wide range of contaminants may complicate the process and produce unwanted side effects. For example, the partial degradation of trichloroethene results in the formation of vinyl chloride, which is known to be more toxic than it's parent compound. Ketones can be oxidized to varying degrees. For example, MEK can be oxidized, but acetone is more difficult to oxidize. Pilot- and full-scale applications have substantiated the effectiveness of UV Oxidation systems to treat VOCs and other organic contaminants in contaminated groundwater. It appears that this technology may be effective in treating most of the contaminants in groundwater at the A. 0. Polymer site. The system may or may not be reliable in achieving cleanup levels for groundwater when used alone. Treatability studies, Including bench scale testing, are recommended prior to the design of the treatment system in order to determine the system configuration and operating characteristics, and to verify that the treatment system effluent will comply with discharge limitations. Treatability testing will also determine whether an activated carbon system is required as a polishing step in order to achieve required discharge limitations. Implementabilitv The UV Oxidation treatment 1s technically feasible to implement. The UV Oxidation system Itself has no filter or adsorption media to dispose of or regenerate. It destroys VOCs and other organic contaminants without air emissions or generation of residual hazardous waste. c Long-term management of the system would be required to insure It's continued ^ operating efficiency. A technical service contract for continued maintenance and operation of the system can be provided by the company that manufactures o and sells the UV Oxidation system. Alternatively, the system could be managed ^ by an independent full-time operator. Batch systems require more operator ^ time than a continuous flow process. 1o0

AOP-35-N 4-49 A.O. Polymer Site Public Review Feasibility Study April 1991

The 1mplementab1l1ty of public awareness and education programs, groundwater use restrictions, and groundwater monitoring 1s described under Alternative MM-1. Implementability of groundwater extraction systems is discussed in Section 4.4. Cost Costs associated with the UV Oxidation system Include the capital cost of the unit, electricity for operating the ultraviolet light, hydrogen peroxide, and technical service and Maintenance of the system. Long-term management of the system would be required to insure it's continued operating efficiency. The services of a full-time operator would be required. Other costs associated with this alternative include groundwater extraction system installation and operation, groundwater use restriction implementation, public awareness/education programs, groundwater monitoring, and periodic reviews. Conclusion This type of treatment could potentially be cost-effective in treating the contaminants in the groundwater at the A. 0. Polymer Site, and will be retained for detailed evaluation. However, treatability studies are required to accurately determine the feasibility and cost-effectiveness of UV Oxidation as a treatment system. 4.3.6 Summary of Management of Migration Alternative Screening Based on the Initial screening of source control alternatives, the following management of migration alternatives will be retained for detailed evaluation in Section 5.0: MM-1 No Action with Institutional Controls MM-2 Extraction and Treatment - Biological/Air Stripping/Carbon Adsorption MM-4 Extraction and Treatment - Powdered Activated Carbon Treatment (PACT) MM-5 Extraction and Treatment - UV Oxidation

4.4 EXTRACTION SYSTEM ALTERNATIVES In order to comply with OSMER Directive 9283.1-2, "Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sites' (December, 1988), and to compare natural attenuation with active groundwater restoration alternatives, two potential groundwater extraction systems were developed. The groundwater extraction systems are designated as Option A and Option B, and are described below. The effectiveness and Implementablllty of each option were evaluated by using an analytical computer model to Insure that the capture zones, drawdown influences and velocity profiles were within reason for the hydrogeologic

AOP-35-M 4-50 A.O. Polymer Site Public Review Feasibility Study April 1991 system that exists at the site. To evaluate relative times required to achieve active restoration, a solute transport calculation based on average contaminant travel times was performed. Each of these evaluations are based on numerous simplifying assumptions and are therefore relative approximations of complex hydraulic and geochemical processes. The results should be considered relative and therefore suitable for making comparisons among alternatives. They should not be considered as absolute predictions of extraction system performance or contaminant behavior. It should be noted that clean up times presented herein assume that source control has been implemented. If no action at the source is taken, contaminants will continue to leach to groundwater. It has previously been shown that under natural flushing, contaminants may leach from the source for more than 60 years. A complete and detailed discussion of the technical aspects of the hydraulic and solute transport modeling is presented in Appendix D. 4.4.1 Potion A The objective of this active restoration alternative is to extract the worst of the contaminant plume in a reasonable time frame. This extraction option is designed to intercept and remove all groundwater contaminated with TCE in excess of 100 ppb. This extraction system uses a row of 4 pumping wells, positioned perpendicular to the movement of the groundwater plume. The four wells would each pump at 18 GPM, for a total pumping rate of approximately 72 GPM. The capture zone affected by this extraction system is illustrated on Figure 4-18. Discharge would be piped to the treatment plant as shown in Figure 4-19. Effectiveness This extraction option will intercept and extract groundwater from approximately 50 percent of the area contaminated by TCE and other contaminants including all groundwater containing TCE concentrations in excess of 100 ppb. Groundwater containing the highest detected concentrations of all other contaminants of concern would be extracted as well. This extraction option would not actively remove approximately 50 percent of the plume where groundwater TCE concentrations may range from 50 to 100 ppb. Therefore, this alternative does not actively restore the entire contaminated area to the groundwater remediation goal of 1 ppb. Solute transport calculations based on the average travel time for TCE from the most upgradlent part of the plume to the extraction system were performed to estimate the relative time required to restore the affected part of the aquifer. These calculations Indicate that approximately 7 years will be required to achieve the clean up criteria within the limits of the capture zone affected by this system. Implementabilitv Based on the aquifer thickness (45 feet) hydraulic conductivity (13 feet/day) and other characteristics assumed for the purposes of this report, the extraction system will induce a drawdown approaching 12 feet near the Inner

AOP-35-H 4-51 ' •"" .-:<•' 1.

4 WELL EXTRACTION SYSTEM CAPTURE ZONE (APPROXIMATE)

' ' ~~- -ss\ " ^ •'•1C.. v.; \ .„, 7WELL EXTRACTION SYSTEM . 1CAPTURE ZONE (APPROXIMATE)

^ M 0PM CXTNACTION WELL (4 WELL EXTRACTION SYSTEM) | FIGURE 4-18 0 W 9PM EXTRACTION WELL (7 WELL EXTRACTION SYSTEM) A 0. POLYMER SITE OROUNDWATER EXTRACTION SYSTEM CAPTURE ZONES .__ CONTOUR Of EQUAL TCC FEASIBILITY STUDY 0 CONCENTRATION W QDOUNOWATER ICFTECHNOLOGY INCORPORATED DATE JULY 20,1990 DR < K. GARDNER - EXTRACTION »Y1TEM CAPTURE ZONI PITTSBURGH.?* SCALE I* • 200' OWQ. NO' 4-52 WATER TREATMEN FACILITY

GRAVEL PARKING/ STAGING AREA

9ROUNOWATER COLLECTION PIPINO I FIGURE 4-19 TREATED WATER DISCHARGE A 0 POLYMER SITE GROUNDWATER EXTRACTION SYSTEM FEASIBILITY STUDY OPTION A-4 PUMPING WELLS - 72 GPM •3 — CONTOUR Of EQUAL TCE CONCENTRATION IN MOUNOWATER ICFTECHNOLOGY INCORPORATED DATE JULY 20.1990 DH • 0. BRENT •-—— HWCRTY LINC PITTSBURGH ,P» SCALE' I • 20CT WW. NO.' A.O. Polymer Site Public Review Feasibility Study April 1991

wells. This drawdown is less than 1/3 of the saturated thickness. Therefore, if the hydrogeologic parameters are representative, this option is implementable. 4.4.2 Option B The objective of this active restoration alternative is to restore a larger portion of the aquifer over a slightly longer time frame. This extraction option is designed to reduce the indicator chemical (TCE) to cleanup objectives over the largest area practicable. This extraction system uses a row of 7 pumping wells, positioned perpendicular to the direction of plume movement. The seven wells would pump at 18 GPM, for a total pumping rate of approximately 126 GPM. The capture zone affected by this extraction system is also illustrated on Figure 4-18. Discharge would be routed to the treatment system as shown in Figure 4-20. Effectiveness This extraction option will intercept and extract groundwater from more than 80 percent of the contaminated area including areas where TCE concentrations exceed over 100 ppb. All areas where maximum concentrations of contaminants occur also be restored. This option does not actively remove a small portion of contamination in the downgradient areas next to the Wallkill River. However, the extraction system location is necessary to minimize effects on the wetlands adjacent to the Wallkill River and disturbance to the athletic fields. Solute transport modeling indicates that the time required to achieve a cleanup within the active restoration area under this extraction system would be approximately 9 years. Implementabilitv The capture zone for this extraction option comes quite close to the Wallkill River indicating that there is a large potential that induced recharge from the stream could affect the performance of the pumping system. This would decrease drawdowns but require much higher pumping rates to affect the desired capture zone. In addition, this option has a large potential to dewater the wetland areas along the Wallkill River. Maximum drawdowns upon implementation of this alternative are expected to be about 17 feet. This approaches the practical limit for an aquifer assumed to be 45 feet in thickness. However, drawdowns may be moderated by induced recharges from the Wallkill River. o

4.4.3 Natural Attenuation o o The cleanup times presented above can be compared to the natural attenuation that will occur under the No Action alternatives (MM-1). Natural flushing of groundwater contaminants was evaluated using the same travel time calculation used to evaluate the extraction well options. Using TCE as an indicator

AOP-35-H 4-54 It tHt EXTRACTION WELL (TVCLL EXTRACTION SYSTEM)

•MOUN01MTER COLLECTION _____I riQURE 4-20 TREATED WATER MSCHAROC A. 0. POLYMER SITE GROUNDWATER EXTRACTION SYSTEM OPTION B-7 PUMPING WELLS-126 GPM . __ CONTOUR OF EQUAL TCE FEASIBILITY STUDY 0 CONCENTRATION M ONOUNOWATEN ICF TECHNOLOGY INCOR PORATED DATE;JULY 2O. I»9O ».• K. OARONER ————— PKOMKTT LINC PITTSauftOH.M SCALE- I* • 200' NO.' 4-SS A.O. Polymer Site Public Review Feasibility Study April 1991 chemical, the time required for cleanup levels to be achieved through natural attenuation of the groundwater plume is estimated to be approximately 27 years. Active extraction will restore affected parts of the aquifer in 7 or 9 years with the 4 and 7 well systems, respectively. To achieve total clean-up with the active restoration alternatives, the travel time required for contaminated groundwater that is not extracted to discharge to the Wallkill River must also be considered. Travel time calculations indicate that these times will be approximately 9 and 4 years for the 4 and 7 well options respectively. Therefore, times to achieve total clean up of the aquifer with active restoration are 16 and 13 years respectively. However, the benefit of active restoration alternatives is that significant risk reductions will occur in less time with active restoration while risks will decrease gradually the entire cleanup period with the natural attenuation alternative. The effectiveness and implementability of natural attenuation is discussed under MM-1. 4.4.4 Natural Soil Flushing An analysis was performed to estimate the time required for natural source flushing, i.e. the time required for precipitation and infiltration to flush contaminants from the source (the contaminated subsurface soils in the area of the former disposal lagoons) into the groundwater aquifer. This time was estimated to be at least 60 years. If no source action is taken this natural soil flushing time must be added to both natural and active restoration time frames for the aquifer. The effectiveness and implementability of this option is discussed under SC-1.

CD O

AOP-35-H Section 5

AOP 001 1100 A. 0. Polymer Site Public Review Feasibility Study April 1991

5.0 DETAILED EVALUATION OF REMEDIAL ALTERNATIVES

This section presents detailed evaluations of the selected remedial alternatives as defined in Section 4.0. The goal of the detailed evaluation is to objectively assess the alternatives with respect to nine evaluation criteria, as described below. The evaluation criteria encompass statutory requirements and include other gauges of the overall feasibility and acceptability of the remedial alternatives. This approach is not a decision- making process itself, but is designed to provide sufficient information to adequately compare alternatives, select an appropriate remedy for the site, and demonstrate satisfaction of the statutory requirements in the Record of Decision. An overview and a detailed description of the evaluation criteria are presented in Sections 5.1 and 5.2, respectively. Detailed evaluations of source control alternatives and management of migration alternatives are presented in Section 5.3 and 5.4, respectively. A discussion of assumptions, limitations, and/or uncertainties associated with each alternative shall also be presented. The detailed evaluations of management of migration alternatives will focus on treatment, rather than extraction, since each management of migration alternative has the same extraction options. The detailed evaluation of alternatives includes development of an order-of-magnitude cost estimate (i.e., having a desired accuracy of +50 percent to -30 percent) for each alternative. The cost estimate for each source control and management of migration alternative is presented in a table within Sections 5.3 and 5.4 respectively. A relative comparison of alternatives is presented in Section 5.5 and discussion of how source control and management of migration alternatives are combined to form site remediation alternatives, and cost summary tables for site remediation alternatives are presented in Section 5.6.

5.1 OVERVIEW OF EVALUATION CRITERIA In accordance with 40 CFR Part 300, Final Rule, dated March 8, 1990, nine criteria are to be considered in the detailed evaluation of alternatives. The nine criteria are categorized Into three groups, each group having a distinct function in selecting the remedy, as described below. 5.1.1 Threshold Criteria o Overall protection of human health and the environment > o Compliance with applicable, or relevant and appropriate § requirements (ARARs) o Threshold criteria are the two criteria that must be satisfied 1n order for an 3 alternative to be eligible for selection.

AOP-35-H 5-1 A. 0. Polymer Site Public Review Feasibility Study April 1991

5.1.2 Primary Balancing Criteria o Short-term effectiveness o Long-term effectiveness and permanence o Reduction of toxicity, mobility, or volume o Implementabillty o Cost Primary balancing criteria are the five criteria that are used to assess the relative performance of the alternatives, and to weigh their relative advantages and disadvantages. 5.1.3 Modifying Criteria o State acceptance o Community acceptance Modifying criteria are formally considered after public comment is received on the RI/FS Report and the proposed plan.

5.2 DESCRIPTION OF EVALUATION CRITERIA Each of the nine evaluation criteria are described in greater detail below. 5.2.1 Overall Protection of Human Health and the Environment Evaluation of the overall protectiveness of an alternative during the RI/FS should focus on whether a specific alternative achieves adequate protection and should describe how site risks posed through each pathway are eliminated, reduced, or controlled though treatment, engineering, or Institutional controls. The overall assessment of protection draws on the assessments conducted under other evaluation criteria, especially long-term effectiveness and permanence, short-term effectiveness, and compliance with ARARs. For each alternative, it should Include: o How each source of contamination is to be eliminated, reduced or controlled; and o How site risks are to be reduced. 5.2.2 Compliance with ARARS This is an evaluation to determine whether each alternative will meet all of the pertinent federal and state ARARs (as defined in CERCLA Section 121) that

AOP-35-M ._ * A. 0. Polymer Site Public Review Feasibility Study April 1991 have been Identified in Section 2.0 of this report. When an ARAR is not met, the basis for justifying a waiver under CERCLA should be identified. Each alternative is evaluated for its compliance with applicable or relevant and appropriate Federal and State requirements. The evaluation summarizes which requirements are applicable or relevant and appropriate to an alternative. The following items should be considered for each alternative: o Compliance with chemical-specific ARARs (e.g., MCLs). This factor addresses whether the ARARs can be met; and, If not, whether a waiver may be appropriate. o Compliance with location-specific ARARs (e.g., preservation of historic sites, regulations relative to activities near wetlands or floodplains, etc.). As with other ARAR-related factors, this involves a consideration of whether the ARARs can be met or whether a waiver is appropriate. o Compliance with action-specific ARARs (e.g., RCRA minimum technology standards). It must be determined whether ARARs can be met or must be waived. The evaluation should also consider whether or not an alternative is in compliance with appropriate criteria, advisories, and guidance. This involves a consideration of how well the alternative meets Federal and State guidelines that are not ARARs. 5.2.3 Short-Term Effectiveness Tie short-term effectiveness of a remedial alternative is evaluated relative to its effect on human health and the environment during implementation of the remedial action. Potential threats to human health and the environment associated with handling, treatment, or transportation of hazardous substances will be considered. The short-term effectiveness assessment is based on four key factors: o Short-terw risks that might be posed to the community during implementation of an alternative; o Potential Impacts on workers during remedial action and the effectiveness and reliability of protective measures; o Potential environmental impacts of the remedial action and the o effectiveness and reliability of mitigative measures during implementation; and 0 o o Time until remedial response objectives are achieved. ^ i—i o 00

AOP-35-H 5-3 A. 0. Polymer Site Public Review Feasibility Study April 1991

5.2.4 Long-Term Effectiveness and Permanence This criterion evaluates alternatives for their long-term effectiveness and the degree of permanence they provide. The primary focus of this evaluation is the residual risks that will remain at the site, and the effectiveness of the controls that will be applied to manage residual risks. Evaluation of a remedial alternative relative to Us long-term effectiveness and permanence 1s made considering the risks remaining at the site after the response objectives have been met. The assessment of long-term effectiveness is made considering the following four major factors: o The magnitude of the residual risk to human and environmental receptors remaining from untreated waste or treatment residues at the completion of remedial activities; o An assessment of the type, degree, and adequacy of long-term management (including engineering controls, Institutional controls, monitoring, and operation and maintenance) required for untreated waste or treatment residues remaining at the site; o An assessment of the long-term reliability of engineering and/or institutional controls to provide continued protection from untreated waste or treatment residues; and o The potential need for replacement of the remedy and the continuing need for repairs to maintain the performance of the remedy . 5.2.5 Reduction of Toxidtv. Mobility, or Volume fTMVl This evaluation criterion addresses the degree to which remedial actions employ treatment technologies that permanently and significantly reduce toxicity, mobility, or volume of the hazardous substances. Alternatives which do not employ treatment technologies are considered to not reduce toxicity, mobility, or volume of contaminants. The evaluation should consider the following specific factors: o The treatment processes, the remedies they will employ, and the materials they will treat; o The amount or volume of hazardous materials that will be destroyed or treated; o The degree of expected reduction in toxicity, mobility, or volume, * including how the principal threat is addressed through treatment; ^ o The degree to which the treatment will be irreversible; and g

AOP-35-H A. 0. Polymer Site Public Review Feasibility Study April 1991

o The type and quantity of treatment residuals that will remain following treatment. 5.2.6 Implementabilitv Implementability considerations include the technical and administrative feasibility of the alternative, and the availability of various materials and services required for its implementation. The following factors must be considered during the Implementability analysis: o Technical Feasibility: The relative ease of implementing or completing an action based on site-specific constraints, including the use of established technologies, Including: Ability to construct each component of the alternative, Operational reliability, or the ability of a technology to meet specified process efficiencies or performance goals, Ability to undertake future remedial actions that may be required, and Ability to monitor the effectiveness of the remedy. o Administrative Feasibility; The ability and time required to obtain any necessary approvals and permits from other agencies. o Availability of Services and Materials: The availability of the technologies, materials, or services required to implement an alternative, including: Available capacity and location of needed treatment, storage, and disposal services; Availability of necessary equipment and specialists and provisions to ensure any necessary additional resources; Timing of the availability of prospective technologies under consideration; and Availability of services and materials, plus the potential for obtaining bids which are competitive (which may be particularly Important for innovative technologies). 5.2.7 Cost > i) For each remedial alternative, a detailed cost analysis 1s developed in accordance with procedures 1n the Remedial Action Costing Procedures Manual o (USEPA, 1985). Cost estimates are prepared for each alternative and are based 2 on conceptual engineering and analyses. Unit prices were developed in

AOP-35-M C_C A. 0. Polymer Site Public Review Feasibility Study April 1991 accordance with the Superfund Cost Estimating Guide (CH2M Hill 1987) and are based on construction cost data (Means, 1989), engineers' cost estimates for similar work, quotes from vendors and contractors, and engineering judgement. Costs are expressed in terms of 1990 dollars. In order to allow the costs of remedial alternatives to be compared on the basis of a single figure, the present worth value of all capital and operating and maintenance costs is determined. Discount rates of 5X and 10% are used to determine the present worth value of the costs of the alternatives. Calculations used to develop cost estimates for each alternative are presented in Appendix E. Cost estimates were prepared using information currently available. Final project costs will depend on actual labor and material costs, actual site conditions, productivity, competitive market conditions, final project scope, final project schedule, the firm selected for final engineering design, and other variable factors. As a result, final project costs will vary from the estimates. Because of these factors, funding needs must be carefully reviewed before specific financial decisions are made and final remedial action budgets are established. The cost estimates are order-of-magnitude estimates with an intended accuracy range of +50 percent to -30 percent. This range applies only to the alternatives as defined herein. Each technology or process selected is intended not to limit flexibility during final design, but rather to provide a basis for making FS cost estimates. The remedial action and cost estimates will be refined during final design. The cost analysis for a remedial alternative consists of four principal elements: o Capital Costs: Capital costs consist of direct (construction) and indirect (non-construction and overhead) costs. Direct costs include costs for equipment, labor, and materials incurred to develop, construct and Implement a remedial action, and the operation and maintenance costs for the first year after the action is completed. Indirect costs are expenditures for engineering, financial, and other services that are not actually a part of construction, but are required to Implement a remedial alternative. In this Feasibility Study, indirect costs will include the following items: Health and safety Items; Permitting and legal fees; Services during construction; and Engineering and design. These Items are included in the detailed cost analysis as separate ^ line Items, and are expressed as a percentage of direct capital costs. Additionally, two contingency factors (bid and scope) are § also Included in the cost estimates to account for factors that ^ cannot be anticipated or estimated. Bid and scope contingencies ^ o AOP-35-H e c W A. 0. Polymer Site Public Review Feasibility Study April 1991

are not uniform for all alternatives. Bid contingencies address costs associated with constructing a given project, such as general economic conditions at the time of bidding, adverse weather conditions, strikes by material suppliers, and other unknowns. Scope contingencies address changes in scope that occur during final design and implementation. Scope contingencies Include provisions for Items such as inherent uncertainties In characterizing wastes or waste volumes and regulatory or policy changes that may affect FS assumptions. Scope contingencies also reflect the performance history or complexity of the remedial technology. Operation and Maintenance (0 & M) Costs: 0 & M costs refer to post-construction costs necessary to ensure the continued effectiveness of a remedial action. They typically refer to long-term power and material costs (such as the operational costs of a water treatment facility), equipment replacement costs, and long-term monitoring costs. Costs for F1ve-Year Review: CERCLA, as amended, Section 121(c) states that a review of a remedial action at least every five-years is required if the remedial action results in hazardous contaminants remaining onsite. Periodic reviews are required at the A. 0. Polymer Site under any alternative if hazardous contaminants will remain In the soil or groundwater. The estimated cost of each review, $15,000 is divided between the SC and MM alternatives. Each SC and each MM alternative include $7500 for reviews and five-year intervals are assumed for costing purposes. Present Worth Analysis: This assessment is used to evaluate the capital and 0 & M costs of a remedial alternative on a present worth basis. Present worth analysis is a method of comparing expenditures for various alternatives that occur over different time periods. By discounting all costs to a common base year, the costs for different remedial action alternatives can be compared on the basis of a single cost figure for each alternative. The total present worth for a given alternative is equal to the full amount of all costs Incurred until the end of the first year of operation (capital costs), plus the series of expenditures in following years reduced by the appropriate future value/present worth discount factors. This analysis allows the comparison of remedial alternatives on the basis of a single cost representing an amount that, 1f Invested in the base year and disbursed as needed, would be sufficient to cover all costs associated with the remedial action over Us planned life. The discount rate represents the anticipated difference between the rate of inflation and Investment return. Comparisons of present worth utilize a 5X and a 1OX discount rate.

AOP-3S-H A. 0. Polymer Site Public Review Feasibility Study April 1991

5.2.8 State Acceptance This assessment addresses the technical and administrative Issues and concerns the state may have regarding each alternative. Eventually, state comments on the selection of remedy will be addressed in the ROD. As discussed earlier, this is a modifying criteria, and will be formally considered after public comment is received on the RI/FS Report and the proposed plan. 5.2.9 Community Acceptance This assessment addresses the issues and concerns the public may have regarding each alternative. Eventually, co«Min1ty positions on the selection of remedy will be addressed in the ROD. As discussed earlier, this is a modifying criteria, and will be formally considered after public comment 1s received on the RI/FS Report and the proposed plan.

5.3 DETAILED EVALUATION OF SOURCE CONTROL (SC) ALTERNATIVES In this section, a detailed evaluation of each alternative with respect to each of the nine criteria is presented in narrative form. As described in the previous section of this report, six source control alternatives have been selected for detailed evaluation for the A. 0. Polymer Site. They will be presented in this section as follows: 5.3.1 SC-1 No Action with Institutional Controls 5.3.2 SC-2 Capping 5.3.3 SC-3 Soil Flushing 5.3.4 SC-4 Soil Vapor Extraction 5.3.5 SC-5 Soil Vapor Extraction and Soil Flushing 5.3.6 SC-6 Excavation and Low Temperature Thermal Oesorption 5.3.1 SC-I No Action with Institutional Controls The no-action alternative 1s required under CERCLA, and provides a baseline for comparing other alternatives. No remedial action would be taken to contain, treat, or control the soil contamination at the site. Overall Protection of Human Health and the Environment Because no remedial action would be taken to contain, treat, or control soil contamination, the soil would continue to act as a source of groundwater contamination, and long-term human health risks for the site would remain essentially the same as those Identified In the baseline risk assessment, as o presented In Section 6.0 of the Remedial Investigation Report. In reality, ~° the soil and groundwater contamination will decrease over time through natural o processes such as flushing and attenuation. Therefore, the risks associated o with the ingestion of contaminated groundwater will lessen as well. ""

AOP-35-H A. 0. Polymer Site Public Review Feasibility Study April 1991

There 1s little human health risk associated directly with the contaminated soil, since H Is subsurface contamination and there 1s little risk of direct contact. In addition, no significant environmental risks have been Identified with respect to terrestrial or aquatic life at the site. However, the contaminants in the soil will continue to leach to the groundwater for a period of time estimated to be more than 60 years. Therefore, the no action source control alternative 1s not protective of human health, since it provides no control of the source of the groundwater plume and no reduction in risks to human health posed by the potential future ingest ion of contaminated groundwater. Because soil contaminants will continue to leach into the groundwater over a long period of time, implementation of groundwater remediation is not desirable in conjunction with the no action source control alternative. Compliance with ARARs Total volatile organic concentrations in soil will remain at levels greater than NJDEP action levels for soil, a relevant and appropriate ARAR. Over a long period of time (approximately 60 years), the soil contamination will lessen through natural processes such as flushing and attenuation. Short-Term Effectiveness Since no remedial action is being Implemented, there would be no short-term risks posed to the community, workers, or the environment as a result of this alternative. Long-Term Effectiveness and Permanence Under the no-action alternative, soil contaminants will continue to leach to groundwater for a long period of time, until natural soil flushing and natural attenuation of soil contaminants occurs. Since untreated waste will be left onsite, monitoring of the subsurface soil will be required to provide data for periodic reviews. Source control alternatives include no Institutional or other controls to manage future groundwater contamination created by the soil contamination. However, all management of migration alternatives include Institutional controls for long-term risk management associated with potential future ingest ion of groundwater. Reduction of Toxlcitv. Mobility, or Volume This alternative provides for no active reduction 1n toxldty, mobility, or volume of contaminated soil. However, soil contamination will lessen over time through natural processes such as natural flushing and attenuation. o o

AOP-3S-H A. 0. Polymer Site Public Review Feasibility Study April 1991

ImplementabiHtv Since contaminants will be left onsite, periodic sampling of contaminated subsurface soil will be required to provide data for periodic reviews. Soil sampling is technically and administratively feasible to Implement. Test borings, sampling, and analysis of soil samples are standard practices, and the required services and equipment are readily available. Cost The only cost associated with Implementation of SC-1 Is periodic subsurface soil monitoring to assess the progress of natural soil flushing and natural attenuation. For purposes of cost estimating, three test borings are assumed to be performed annually over a 30-year period, with three soil samples taken from each boring, for a total of 9 samples annually. Soil samples are to be analyzed for total volatile organics, base-neutrals, and add extractables. The annual cost of the proposed soil sampling and analysis is $15,500. The total present worth cost of the proposed soil monitoring 1s estimated to be $319,000 (5X discount rate) and $194,000 (10X discount rate). A summary of the cost estimate is provided on Table 5-1. 5.3.2 SC-2 : Capping Capping represents an alternative that utilizes containment with no treatment, as required under CERCLA guidance. Capping would reduce the mobility of the soil contaminants by minimizing infiltration and subsequent leaching of soil contaminants into the groundwater. An asphalt cap with an underlying HOPE liner was selected as the representative process option for the capping alternative. Overall Protection of Human Health and the Environment Capping would effectively reduce the leaching of contaminants into the groundwater. Therefore, as a source control alternative, capping provides protection of the groundwater from continued leaching of soil contaminants. By reducing the leaching of contaminants Into the groundwater, this alternative will reduce the human health risks associated with potential future ingestion of groundwater. However, it 1s not a permanent solution and the existing groundwater contamination with the associated human health risks from ingestion, will remain. Compliance with ARARs Total volatile organic concentrations in soil will remain at levels greater than NJDEP action levels for soil for an Indefinite period of time. 5; -o NJDEP action levels for soil are "to be considered" in establishing cleanup levels for the A. 0. Polymer Site. There 1s no basis for justifying a waiver § of these TBCs except that residual contaminants present no direct contact "- hazard. I— i K-J

*»-35-M 5_10 S TABLE 5-1 COST ESTIMATE SUMMARY ALTERNATIVE SC-1 NO ACTION A. 0. POLYMER FEASIBILITY STUDY

Quantity Capital Annual Present Worth of ITEM Cost 0 I M Annual OIM Costs Rat* > 5X Rat* * 10X

1. LONG TERM MONITORING t REVIEW (30 YEARS) 1. Subsurface Soil Sampling t Analysis • $15,500 t 238, 300 $146,100 2. 5-Year Reviews •* 120,800 $11,600 Subtotal: SO $15,500 $259.100 $157,700 CONSTRUCTION SUBTOTAL SO ANNUAL 0 t M $15,500 $259,100 $157,700 Capital 0 t M Health and Safety OX 5X $0 $775 $11,900 $7,300 Bid Contingency OX 5X $0 $775 $11,900 $7,300 Scope Contingency OX 15X $0 $2,325 $35,700 $21,900 CONSTRUCTION TOTAL $0 $19,400 $318,600 $194,200 Permitting I Legal OX $0 Services During Construction OX $0

TOTAL IMPLEMENTATION COST $0 Engineering I Design OX $0

TOTAL CAPITAL COSTS $0

TOTAL PRESENT WORTH $319,000 $194,000

* Monitoring Period of 30 Years: 9 soil samples from 3 test borings taken annually. Analysis performed is for VOCs and SNA Extractables. *• Half of the cost of each 5-year review ($7500) is included in SC Alternatives. Reviews at t * 5 yr, 10 yr, 15 yr, 20 yr, 25 yr, and 30 yr.

5-11 A. 0. Polymer Site Public Review Feasibility Study April 1991

Short-Term Effectiveness Construction of the proposed asphalt cap 1s a standard construction technique and would involve no excavation or handling of hazardous materials. Therefore, no short-term risks to the community, workers, or the environment as a result of this alternative are anticipated. Lona-Term Effectiveness and Permanence Capping would effectively reduce the leaching of contaminants Into the groundwater. Therefore, as a source control alternative, capping minimizes the level of contamination leaching to the groundwater. Although it is not a permanent solution, capping reduces the risks associated with Ingestion of contaminated groundwater to some extent. Maintaining this level of risk reduction depends on preserving the long-term integrity of the cap. Periodic maintenance of the asphalt surface will be required in order to maintain the long-term integrity of the cap. A 1" thick asphalt overlay every five years is adequate to maintain the integrity of the cap. Source control alternatives include no institutional or other controls to manage future groundwater contamination created by the soil contamination. However, all management of migration alternatives Include Institutional controls for risk management associated with potential future ingestion of groundwater. Reduction of Toxicitv. Mobility or Volume Through Treatment Capping does not employ any treatment to reduce the toxicity, mobility or volume of contaminants. Capping would, however reduce the leaching of contaminants into the groundwater. Implementabilitv The proposed asphalt cap is technically feasible to construct. Since the area is relatively flat, only minor grading would be required to prepare the area for construction. The required construction materials, services and equipment that would be utilized to construct the cap are readily available. The time required for actual construction is estimated to be less than 8 weeks, weather permitting. Additional time would be required for design, bidding, and procurement of materials. Some type of administrative agreement may be required with A. 0. Polymer, since the proposed cap would be located on their property. Cost 3 The capital cost for construction of the proposed asphalt cap Is estimated to g be $49,000. 0 & M costs for the asphalt cap include periodic maintenance, ~

AOP-35-H A. 0. Polymer Site Public Review Feasibility Study April 1991 which is assumed to consist of an asphalt overlay every five years. No soil monitoring 1s Included in this alternative. The total present worth of the capping alternative Is $135,000 (5X discount rate) and $112,000 (10* discount rate). A summary of the cost estimate is provided on Table 5-2. 5.3.3 SC-3 : SOIL FLUSHING Soil flushing enhances the natural leaching process by flushing large quantities of water through the contaminated vadose zone soil at the former lagoon area. Contaminants which are water soluble will be rapidly flushed from the soil into the groundwater below. An artificial recharge basin is used to introduce the water needed for flushing. In addition, groundwater flow controls are used to minimize the possibility of contaminant movement into areas of the aquifer currently unaffected by contamination. The groundwater flow control in the conceptual design consists of a second recharge basin to create a mound preventing westerly flow of contaminants. The exact types, sizes and locations of additional groundwater controls would be determined during remedial design. Overall Protection of Human Health and the Environment This alternative provides protection of human health by removing contaminants from the soil in significantly less time than would occur under natural conditions and therefore reduces the potential for long-term leaching. Because soil flushing Induces accelerated leaching of contaminants Into groundwater, this alternative must be done in conjunction with a groundwater extraction and treatment system in order to be protective. Compliance with ARARs Depending on the results of the soil flushing process, total volatile organic concentrations in soil may or may not remain at levels greater than NJDEP action levels for soil. There is no basis for justifying a waiver of the NJDEP soil action levels, except that after being subjected to enhanced flushing for a period of time, any residual contamination that cannot be reduced any further will probably not be susceptible to further leaching by natural processes. Short-Term Effectiveness Construction of the proposed recharge basins uses standard construction techniques and would Involve no excavation or handling of hazardous materials. Excavation to a depth of approximately 4 or 5 feet below the ground surface o would be required; however, the contaminated soil 1s at a depth of o approximately 9 feet below the ground surface. Therefore, no short-term risks

AOP-35-H c 13 TABLE 5-2 COST ESTIMATE SUMMARY ALTERNATIVE SC-2 CAPPING A. 0. POLYMER FEASIBILITY STUDY

Capital Annual Present Worth of ITEM Quant i ty Cost 0 t M Annual OtH Costs Rate « 5X Rate - 10X

1. ASPHALT CAP (1350 S.Y.) Capital Costs: 1. Site Preparation Lump SUM $3,000 2. 6" Sand Layer 227 CY $7,510 3. Geosynthetics 1350 SY $16,790 4. 12" Gravel Layer 454 CY $9,800 5. 2 1/2" Asphalt Layer 1350 SY $6,900 6. Contractor Nob/Demob LUMP Sun $5.000 0 i M Costs: 1. Asphalt Overlay (every 5 years) 1350 SY $4,900 $13,600 $7,600

Subtotal: $49,000 $4,900 $13,600 $7,600

II. FIVE-YEAR REVIEWS (30 YEARS) * 1. 5-Year Reviews ** $20,800 $11,600 Subtotal: $0 $0 $20,800 $11,600 CONSTRUCTION SUBTOTAL $49,000 ANNUAL 0 I M $4,900 $34,400 $19,200 Capital 0 I M Health and Safety 5X 5X $2,450 $245 $3,800 $2,300 Bid Contingency 15X 5X $7,350 $245 $3,800 $2,300 Scope Contingency 15X 15X $7,350 $735 $11,300 $6,900

CONSTRUCTION TOTAL $66,200 $6,100 $53,300 $30,700 Permitting I Legal sx $3,310 Services During Construction 5X $3,310

TOTAL IMPLEMENTATION COST $72,800 Engineering I Design 12X $8,736

TOTAL CAPITAL COSTS $81,500

TOTAL PRESENT WORTH $135,000 $112,000

* No emitoring ia included for this alternative. •• Half of the coat of each 5-year review ($7500) is included in SC Alternatives. Reviews at t • 5 yr, 10 yr, 15 yr, 20 yr, 25 yr, and 30 yr.

O t?

O O

5-14 A. 0. Polymer Site Public Review Feasibility Study April 1991 to the community, workers, or the environment as a result of implementing this alternative are anticipated. Based on a simple combination partitioning/pore volume flush model, it appears possible to reduce subsurface soil concentrations of the Teachable contaminants to levels that are protective of groundwater within 3 years of implementation. However, soil flushing involves complex geochemical processes, therefore there is some uncertainty associated with this prediction. Lonq-Term Effectiveness and Permanence Potential residual risks may remain from incomplete soil flushing. Because flushing is influenced by a large number of chemical and physical processes which are difficult to predict or quantify, the potential level of residual risk is difficult to estimate. The time required to flush contamination from the soil is estimated to be approximately 3 years. An operating period of 5 years is assumed for purposes of this study. However, actual flushing rates will depend on a number of parameters including long-term infiltration capacity, soil adsorption properties, the mass of contamination present, contaminant solubility, desorption rates, and degradation rates. Estimation of these parameters has an inherent degree of uncertainty and therefore, the actual effectiveness of soil flushing should be evaluated by annual or periodic subsurface soil sampling. Some of the contaminants, such as the monocyclic aromatics (toluene, ethyl benzene and xylene) may not be leached in a reasonable time frame because of low solubility or desorption rates, and some of the less soluble contaminants may respond poorly to enhanced flushing. Therefore, volatile organic soil contamination above remediation goals or the NJOEP action levels for soil could remain after Implementation. After being subjected to enhanced flushing however, residual concentrations above action levels may prove not to be susceptible to natural flushing. Long-term monitoring of the soil and groundwater is required to Insure that these residual contaminants do not pose a threat to groundwater. The effectiveness of this alternative also depends on the reliability of the groundwater control systen 1n preventing contaminant movement Into uncontaminated areas of the aquifer. The control technology, which Includes a barrier recharge basin, 1s conceptually sound; however, performance of the control system may be less effective than predicted due to Inherent variations in aquifer properties and the complexities of groundwater behavior. As a > result of these Inherent uncertainties, close monitoring of groundwater o gradients and contaminant movement will be required throughout Implementation to insure that contaminants do not spread to previously unaffected areas of 0 the aquifer. °

AOP-35-M 5-15 A. 0. Polymer Site Public Review Feasibility Study April 1991

Source control alternatives include no institutional or other controls to manage future groundwater contamination created by the soil contamination. However, all management of migration alternatives include Institutional controls for risk management associated with potential future ingestion of groundwater. Reduction of Toxicitv. Mobility, or Volume Through Treatment Soil flushing does not reduce the toxicity, or volume of soil contaminants, but achieves reduction in contamination by actually increasing mobility to allow subsequent collection and treatment of the dissolved contaminants. No treatment residuals will be generated during implementation of soil flushing. Itnolementability The proposed subsurface recharge basins are technically feasible to construct. The standard construction materials, services and equipment that would be utilized to construct the recharge basin are readily available. The time required for actual construction would be less than 8 weeks, weather permitting. Additional time would be required for design, bidding, and procurement of materials. If onsite treatment system effluent is being discharged to the recharge basins, the recharge basins could be utilized for the life of the groundwater extraction and treatment system. The estimated total recharge capacity of the two basins, without exceeding groundwater mounding criteria, is approximately 80 to 85 GPM. This capacity is sufficient to accept all of the treated discharge from the 4 well extraction option and a substantial fraction of the discharge from the 7 well option. If the 7 well extraction option is implemented, the size of the recharge basins will have to be slightly increased. Some type of administrative agreement may be required with A. 0. Polymer, since the proposed recharge basin would be constructed on their property. Since contaminants will be left onsite, periodic sampling of contaminated subsurface soil will be required to provide data for periodic reviews. In addition, subsurface soil sampling will be required to monitor the effectiveness of the soil flushing process. With the subsurface recharge basin in place, special drilling techniques will be required so that soil samples can be obtained without drilling through the recharge basin. Soil sampling 1s technically and administratively feasible to Implement. Sampling and analysis of soil samples are standard practices, and the required services and equipment are readily available.

AOP-35-H 5-16 A. 0. Polymer Site Public Review Feasibility Study April 1991

Cost As discussed above, the time required for active soil flushing is somewhat uncertain. However, since the cost of with soil flushing alternative is primarily capital costs associated with initial construction, the system could be operated for an extended period of time without significant additional cost. The capital cost for design and construction of the proposed recharge basins is estimated at $94,900. The only 0 & M costs anticipated are for pumping of water through the system from the onsite groundwater treatment facility. An operating period of 5 years was assumed for pumping. Periodic subsurface soil monitoring is required, to monitor the effectiveness of the soil flushing process. Also, if NJDEP action levels for soil are not achieved, soil monitoring will be required to provide data for periodic reviews. For purposes of cost estimating, three test borings are assumed to be performed annually over a 30-year period, with three soil samples taken from each boring, for a total of 9 samples annually. Soil samples are to be analyzed for total volatile organics, base-neutrals, and acid extractables. A major benefit of this treatment is that it is performed in-situ, thus eliminating the need for costly excavation and treatment. The total present worth of the soil flushing alternative is $499,000 (5X discount rate) and $372,000 (10% discount rate). A summary of the cost estimate is provided on Table 5-3. 5.3.4 SC-4 : SOIL VAPOR EXTRACTION The soil vapor extraction alternative utilizes a vacuum extraction system to remove volatile organic contaminants from the vadose zone. The soil vapor extraction process involves applying a vacuum to venting wells installed in the contaminated vadose zone to volatilize the organics and draw the vapors into a collection system where they would subsequently be removed with an activated carbon off-gas treatment system. A secondary benefit of this process is that natural biodegradation of some soil contaminants, such as the phenolic compounds, nay be enhanced since the process introduces oxygen into the soil matrix. Overall Protection of Human Health and the Environment Soil vapor extraction directly reduces the volume and mobility of soil volatile and semi-volatile organic contaminants, and may Indirectly reduce the toxicity of phenolic soil contaminants through enhanced biodegradation. Soil vapor extraction collects volatile organic contaminants in the activated carbon off-gas treatment system, and thus concentrates the contaminants Into the activated carbon for subsequent treatment. Since it removes the contaminants from the soil matrix, it also reduces the mobility of the contaminants (they can no longer act as a source of future groundwater contamination).

AOP-35-H c 17 TABLE 5-3 COST ESTIMATE SUMMARY ALTERNATIVE SC-3 SOIL FLUSHING A. 0. POLYMER FEASIBILITY STUDY

Capital Annual Present Worth of ITEM Ouant i ty Cost 0 t M Annual OtM Costs Rata « 5X Rat* « 10X

I. LEACH FIELD AND WATER SUPPLY SYSTEM Capital Coats: 1. Sitt Prtparat ion/Excavation 3235 CY $15,200 2. 12" Gravtl Layer 575 CY SIS, 600 3. Filter Fabric 38950 SF $5,000 4. PVC Piping/Fitting* 3210 LF $11,800 5. Beckfill/Revegetate 2660 CY $8,000 6. Uatar Supply Line Trench 1200 LF $13,250 7. Pump Station Lump SUB $26,000 0 i M Coats: 1. Pint? naintenance/Electricity (5 y*ars) Lunp SUM $1,500 $6,500 $5,700

Subtotal: 194,900 $1,500 $6,500 $5,700

II. LONG TERM MONITORING I REVIEW (30 YEARS) 1. Subsurfact Soil Sampling I Analysis * $15,500 $238,300 $146,100 2. S-Yaar Reviews *• $20,800 $11,600 Subtotal: SO $15,500 $259,100 $157,700 CONSTRUCTION SUBTOTAL $94,900 ANNUAL 0 t M $17,000 $265,600 $163,400 Capital OtM Health and Safaty OX 5X $0 $850 $13,100 $8,000 Bid Contingency 20X 5X $18,980 $850 $13,100 $8,000 Scop* Contingency 20X 15X $18,980 $2,550 $39,200 $24,000 CONSTRUCTION TOTAL $132,900 $21,300 $331,000 $203,400 Permitting t Legal 5X $6,645 Services During Construction 10X $13,290 TOTAL IMPLEMENTATION COST $152,800 Engineering i Design 10X $15,280

TOTAL CAPITAL COSTS $168,100 TOTAL PRESENT WORTH $499,000 $372,000

Monitoring Period of 30 Years: 9 soil sseple* fro» 3 test borings taken annually. Analysis performed is for VOCs and BNA Extractables. Half of the coat of each 5-year review ($7500) is included in SC Alternatives. Reviews at t » 5 yr, 10 yr, 15 yr, 20 yr, 25 yr, and 30 yr.

o o

00 5-18 A. 0. Polymer Site Public Review Feasibility Study April 1991

Compliance with ARARs Depending on the results of the soil vapor extraction process, total volatile organic concentrations in soil may or may not remain at levels greater than NJDEP action levels for soil. There Is no basis for justifying a waiver of the NJDEP soil action levels, except that subsequent precipitation events will result in natural soil flushing, which may reduce any remaining soil contaminant levels to below NJDEP action levels over time. Treatment residuals from the soil vapor extraction process, Including liquid condensate and spent carbon, may be considered hazardous waste and would be regulated, transported, and disposed under RCRA. Implementation of this alternative may require Part B equivalency be submitted to the State of New Jersey. Manifest documents may be required for transportation and offsite disposal of the activated carbon and liquid condensate. This system must also comply with New Jersey regulations controlling air emissions. Worker health and safety would be regulated under the Occupational Safety and Health Act (OSHA). Short-Term Effectiveness Construction of the proposed soil vapor extraction system uses standard well installation and construction techniques and would involve no excavation of hazardous materials. Off-gases will be treated with activated carbon, and liquid condensate will be collected and treated or disposed. Since volatile organic contaminants are being removed from the subsurface soil and brought to the surface, some hazardous material (I.e., the exhausted activated carbon and the liquid condensate) will be handled by workers. However, proper health and safety protection and procedures will minimize risks to workers. Since the hazardous material will be contained within the activated carbon or liquid condensate, proper handling and disposal of these materials will insure the safety of the surrounding community and the environment. Therefore, no short- term risks to the community, workers, or the environment as a result of implementing this alternative are anticipated. Long-Term Effectiveness and Permanence The level of residual risk depends upon the level of contaminant reduction that can be achieved. The amount of contamination removed 1s difficult to precisely estimate because the mass transfer of vapors depends upon complex processes which are difficult to predict and quantify. It 1s possible that concentrations above remediation goals and NJDEP action levels may result even after soil venting 1s taken to completion. However, past experience on similar projects has shown the soil vapor extraction technique to be very successful in removing volatile organlcs, particularly in sandy soil matrices.

Aop-35-H A. 0. Polymer Site Public Review Feasibility Study April 1991

In addition, blodegradatlon of less volatile (phenolic) compounds may be enhanced as a secondary benefit. If volatile organic soil contamination above the NJDEP action levels for soil remains in place at the site, long-term monitoring of the soil would be required. Over tine, precipitation events will result in natural soil flushing, which may reduce remaining soil contaminant levels to below NJOEP action levels. Source control alternatives include no Institutional or other controls to manage future groundwater contamination created by the soil contamination. However, all management of migration alternatives Include Institutional controls for risk management associated with potential future Ingest ion of groundwater. Reduction of Toxicitv. Mobility, or Volume Through Treatment This process directly reduces the volume and mobility of volatile and semi- volatile organic contaminants. In addition, it may also reduce the toxicity of less volatile (phenolic) soil contaminants through enhanced blodegradatlon. Process residuals Include spent carbon and a small quantity of contaminated liquid condensate. Contaminated process residuals will be disposed offsite. Approximately 18,500 pounds of carbon will be used and 150 gallons of liquid condensate will be generated. Implementabilitv It is technically feasible to construct and operate a vacuum extraction system in the area of the disposal lagoons. Construction of the proposed soil vapor extraction system uses standard well Installation and construction techniques and would involve no excavation of hazardous materials. Since the system would not occupy a large area, space constraints are not anticipated to be a problem. As with any of the source control onsite treatment alternatives, some type of agreement may be required with A. 0. Polymer, since the proposed vacuum extraction system would be located and operated on their property. Construction of the vacuum extraction system utilizes standard construction methods and Materials, which are readily available. The time required for installation of the venting wells and vapor collection system would be less than 6 to 8 weeks, and the operational time required for extraction of contaminants 1s typically less than one year. > If soil contaminants above the NJDEP action levels are left in place, periodic ^ sampling of contaminated subsurface soil will be required to provide data for periodic reviews. In addition, post-extraction subsurface soil sampling will o be required to monitor the effectiveness of the soil vapor extraction process. 2 Soil sampling 1s technically and administratively feasible to Implement. Test i—i* co AOP-35-H 5 20 ° A. 0. Polymer Site Public Review Feasibility Study April 1991 borings, sampling, and analysis of soil samples are standard practices, and the required services and equipment are readily available. Cost The capital cost for design, installation, and operation of the proposed soil vapor extraction is estimated at $308,000. This cost includes design, installation of the system, operation and maintenance over approximately a one year period, off-gas control and treatment, offslte treatment of liquid condensate, pre- and post-treatment soil sampling and analysis. Since the soil vapor extraction process is typically completed 1n less than one year, no 0 & M costs are anticipated. If soil vapor extraction 1s not successful in removing volatile organlcs to less than 1 ppm, the NJDEP action level for soil, periodic subsurface soil monitoring will be required to provide data for periodic reviews. For purposes of cost estimating, three test borings are assumed to be performed annually over a 30-year period, with three soil samples taken from each boring, for a total of 9 samples annually. Soil samples are to be analyzed for total volatile organics, base-neutrals, and acid extractables. A major benefit of this treatment is that it is performed in-situ, thus eliminating the need for costly excavation and treatment/disposal of soil. The total present worth of the soil vapor extraction alternative is $810,000 (5% discount rate) and $686,000 (10% discount rate). A summary of the cost estimate is provided on Table 5-4. 5.3.5 SC-5 : SOIL VAPOR EXTRACTION AND SOIL FLUSHING This alternative combines the soil vapor extraction and the soil flushing processes, as described in alternatives SC-3 and SC-4 above. Soil vapor extraction would be performed first on the soil to treat volatiles. A soil sampling and analysis program would then be implemented to assess the success of the soil vapor extraction, and to determine whether or not cleanup levels in soil have been achieved. If contaminants above cleanup action levels remain, this process would be followed by soil flushing to flush any remaining water soluble contaminants from the soil. Since soil flushing leaches contaminants Into the groundwater, It must be Implemented in conjunction with a groundwater extraction and treatment alternative. The exact types, sizes and locations of the groundwater extraction system and groundwater controls, if needed, would be determined during remedial design. Overall Protection of Human Health and the Environment This alternative also removes contaminants from the source area soils and thus % provides protection of human health by minimizing long term leaching to ^ groundwater. Soil vapor extraction 1s very effective 1n removing many volatile and semi-volatile contaminants that exist at the source area but may g not perform well on those contaminants with low vapor pressures such as the f phenolic compounds and phthalates. Soil flushing which may not be extremely V-1 ro AOP-35-H » "-1 TABLE 5-4 COST ESTIMATE SUMMARY ALTERNATIVE SC-4 SOIL VAPOR EXTRACTION A. 0. POLYMER FEASIBILITY STUDY

Capital Annual Present Worth of ITEM Quantity Cost 0 t M Annual OM Costs Rate * 5X Rate * 10X

I. SOIL VAPOR EXTRACTION TREATMENT (11000 CY) Capital Coats: 1. System Installation/Mobilization Lump Sum $193,000 2. Off-gas treatment (activated carbon) Lump Sum $79,200 3. Liquid Compensate Treatment 150 gallon* $3,300 4. Soil Sampling PrograM 30 sample* $32,500

Subtotal : $308,000 $0 SO SO

11. LONG TERM MONITORING t REVIEW (30 YEARS) 1. Subsurface Soil Sampling i Analysis • " $15,500 $238.300 $146,100 2. 5-Year Reviews ** $20,800 $11,600 Subtotal: $0 $15,500 $259,100 $157,700 CONSTRUCTION SUBTOTAL $308,000 ANNUAL 0 I M $15,500 $259,100 $157,700 Capital 0 t N Health and Safety 5X 5* $15.400 $775 $11,900 $7,300 Bid Contingency 20X 5X $61,600 S77S $11,900 $7,300 Scop* Contingency 20X 15X $61,600 $2,325 $35,700 $21,900 CONSTRUCTION TOTAL $446,600 $19,400 $318,600 $194,200 Permitting t Legal 5X $22,330 Services During Construction 5X $22,330

TOTAL IMPLEMENTATION COST $491,300

Engineering t Design *** $0 TOTAL CAPITAL COSTS $491,300 TOTAL PRESENT WORTH $810,000 $686,000

• Monitoring Period of 30 Year*: 9 soil MMplet from 3 test boring* taken annually. Analysis performed it for VOCs and BNA Extractable*. *• Half of the cost of each 5-year review ($7500) is included in SC Alternatives. Reviews at t » 5 yr, 10 yr, 15 yr, 20 yr, 25 yr, and 30 yr. *** Engineering and design included in item I. (1) System installation/Mobilization

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to 5-22 to A. 0. Polymer Site Public Review Feasibility Study April 1991 effective 1n removing volatiles such as toluene, ethylbenzene and xylene may perform better than soil vapor extraction on high solubility, low volatility compounds like phenol1cs. The combination of these two technologies provides a high degree of reliability that all contaminants of concern will be removed. Because soil flushing Involves transfer of contaminants to groundwater, this alternative must be done in conjunction with groundwater extraction and treatment to be protective. Compliance with ARARs The combination of soil vapor extraction and soil flushing has a relatively high degree of reliability in reducing soil contaminant concentration to below NJDEP action levels. However, total volatile organic concentrations in soil may remain at levels greater than NJOEP soil action levels. There is no basis for justifying a waiver of the NJDEP soil action levels, except that subsequent precipitation events will result 1n natural soil flushing and attenuation, which may reduce any remaining soil contaminant levels to below NJDEP action levels over time. Treatment residuals from soil vapor extraction, including liquid condensate and spent carbon, may be considered hazardous waste and would be regulated, transported and disposed under RCRA. Implementation of this alternative may require that a Part B equivalency permit be submitted to the state of New Jersey. Manifest documents may be required for transportation and disposal of treatment residuals from the soil vapor extraction process. Worker health and safety would be regulated under OSHA. Short-Term Effectiveness No short-term risks to the community, workers, or the environment as a result of implementing this alternative are anticipated, as previously described under Alternatives SC-3 and SC-4. Long-Term Effectiveness and Permanence The level of residual risk from this source control alternative 1s difficult to quantify, since the amount of contamination removed from the soil using soil vapor extraction cannot be accurately estimated. However, past experience on similar projects has shown the soil vapor extraction technique to be very successful In removing volatile organics, particularly in sandy > soil matrices. Blodegradation of less volatile (phenolic) compounds may also >u be enhanced as a secondary benefit. In addition, the contaminants which are not easily volatilized, such as the phenol1cs, are very soluble, and would be g flushed through the soil by the soil flushing process. <-

NJ Ul AOP-35-H C_ 23 A. 0. Polymer Site Public Review Feasibility Study April 1991

If volatile organic soil contamination above the NJDEP action levels for soil remains in place at the site, long-term monitoring of the soil would be required. Source control alternatives include no institutional or other controls to manage future groundwater contamination created by the soil contamination. However, all management of migration alternatives include institutional controls for risk management associated with potential future ingestion of groundwater. Reduction of Toxicitv. Mobility or Volume Through Treatment Soil vapor extraction directly reduces the volume and mobility of volatile and semi-volatile organic contaminants. In addition, it may also reduce the toxicity of less volatile (phenolic) soil contaminants through enhanced biodegradation. Process residuals include spent carbon and a small quantity of contaminated liquid condensate. Contaminated process residuals will be disposed offsite. Soil flushing does not reduce the toxicity, mobility, or volume of soil contaminants, but rather speeds up the natural soil flushing mechanisms to allow subsequent collection and treatment of the solubilized contaminants. No treatment residuals will be generated during implementation of soil flushing. Implementabilltv It is technically feasible to construct and operate both a vacuum extraction system and a recharge basin for soil flushing in the area of the disposal lagoons. Implementability of soil flushing and soil vapor extraction are discussed under alternatives SC-3 and SC-4, respectively. If soil contaminants above the NJDEP action levels are left in place, periodic sampling of contaminated subsurface soil will be required to provide data for periodic reviews. Soil sampling is technically and administratively feasible to implement. Test borings, sampling, and analysis of soil samples are standard practices, and the required services and equipment are readily available. Cost The capital cost for design and operation of the proposed soil vapor extraction is estimated at $308,000. This cost includes design, installation of the system, operation and maintenance over approximately a one year period, off-gas control and treatment, offsite treatment of liquid condensate, pre- and post-treatment soil sampling and analysis. Since the soil vapor extraction process is typically completed in less than one year, no 0 & M > costs are anticipated. °

The capital cost for design and construction of the proposed recharge basin is 0 estimated at $94,900. The only 0 4 M costs anticipated are for pumping of 2

AOP-35-N 5-23 "4 A. 0. Polymer Site Public Review Feasibility Study April 1991 water through the system from either a supply well or an onsite groundwater treatment facility. If soil vapor extraction and soil flushing are not successful in removing contaminants to below the NJDEP action level for soil, periodic subsurface soil monitoring will be required to provide data for periodic reviews. For purposes of cost estimating, three test borings are assumed to be performed annually over a 30-year period, with three soil samples taken from each boring, for a total of 9 samples annually. Soil samples are to be analyzed for total volatile organics, base-neutrals, and add extractables. A major benefit of this treatment is that it 1s performed in-situ, thus eliminating the need for costly excavation and treatment/disposal of soil. The total present worth of the soil vapor extraction and soil flushing alternative is $1,016,000 (5X discount rate) and $889,000 (10% discount rate). A summary of the cost estimate is provided on Table 5-5. 5.3.6 SC-6: Excavation and Low Temperature Thermal Desorptlon This alternative would involve excavation of the contaminated soil, onsite treatment using low temperature thermal desorption, and backfill of the treated soil . Low temperature thermal desorption, also referred to as low temperature thermal soil aeration or low temperature thermal stripping, 1s a mass transfer process in which excavated soils are passed through a thermal treatment process to transfer volatile contaminants in soils to the gas phase. The off- gas is then collected and passed through a carbon adsorption treatment system. If the soil contaminants are removed to below the NJOEP action levels for soil, it 1s assumed that the treated soil may be used to backfill the excavation. Overall Protection of Human Health and the Environment This alternative would remove and eliminate the source of future groundwater contamination. Therefore, as a source control alternative, this alternative provides a high degree of protection of the groundwater from continued leaching of soil contaminants. If excavation and treatment of the soil 1s implemented with no corresponding groundwater extraction and treatment, the level of contaminants being introduced Into the groundwater will be minimized or eliminated. However, the existing groundwater contamination would remain. o o

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AOP-35-H 5-25 TABLE 5-5 COST ESTIMATE SUMMARY ALTERNATIVE SC-5 SOIL VAPOR EXTRACTION AND SOIL FLUSHING A. 0. POLYMER FEASIBILITY STUDY

Capital Annual Present Worth of ITEM Quantity Co*t 0 t M Annual 04* Com Rate - 5X Rate « 10X

I. SOIL VAPOR EXTRACTION TREATMENT (11000 CY) Capital Costs: 1. Systaai Installation/Mobilization LUMP Su* $193,000 2. Off-gas treatment (activated carbon) Lu*p SUB $79,200 3. Liquid Condense te TraatMnt ISO gallon* $3,300 4. Soil Sampling Program 30 staples $32,500 Subtotal: S308.000 SO $0 $0

II. LEACH FIELD AND UATER SUPPLY SYSTEM Capital Costs: 1. Sit* Prtparat ion/Excavation 3235 CY $15,200 2. 12" Gravel Layer 575 CY $15,600 3. Filter Fabric 38950 SF $5,000 4. PVC Piping/Fitting* 3210 LF $11,800 5. Backfill/Revegetate 2660 CY $8,000 6. Water Supply Line Trench 1200 LF $13,250 7. Punp Station LUMP SUM $26,000 0 t N Co*ta: 1. Pump Maintenance/Electricity (5 years) LUMP SUM $1,500 $6,500 $5,700

Subtotal: $94,900 $1,500 $6,500 $5,700

II. LONG TERM MONITORING t REVIEW (30 YEARS) 1. Subsurface Soil Sampling t Analyst* • $15.500 $238,300 $146,100 2. 5-Year Review* •* $20,800 $11,600 Subtotal : SO SIS, 500 $259,100 $157,700 CONSTRUCTION SUBTOTAL $402,900 ANNUAL 0 t N $17,000 $265,600 $163,400 Capital 0 t M Health and Safety 5X SX $20, US $850 $13,100 $8,000 Bid Contingency 20% SX $80,580 $850 $13,100 $8,000 Scope Contingency 20% 15X $80,580 $2,550 $39,200 $24,000 CONSTRUCTION TOTAL $584,200 $21,300 $331,000 $203,400 Permitting i Legal SX $29,210 Services During Construction 10X $58.420 TOTAL IMPLEMENTATION COST $671,800 Engineering t Design *** 2X $13,436

TOTAL CAPITAL COSTS $685,200 TOTAL PRESENT WORTH $1,016,000 $889,000

• Monitoring Period of30 Years: O 9 soil samples from 3 test boring* taken annually, -a Analysis performed is for VOC* and MA Extractable*. 0 *• Half of the coat of e•eh 5-vear review ($7500) is includad in SC Alternatives. o Reviews at t « 5 yr, 10 yr, 15 yr, 20 yr, 25 yr, and 30 yr. Engineering and design for soil flushing only. Engineering and design for soil vapor extraction included under its* I. (1) Systs» Installation/Mobilization 5-26 A. 0. Polymer Site Public Review Feasibility Study April 1991

Compliance with ARARs This alternative provides a high degree of reliability in achieving remediation goals and compliance with NJOEP action levels for volatile organic concentrations in soil. Treatment residuals from the low temperature thermal desorption process, including liquid condensate and spent carbon, may be considered hazardous waste and would be regulated, transported, and disposed under RCRA. Treated soil would not be considered a RCRA hazardous waste and is not land banned under the RCRA Land Disposal Restrictions. Treated soil would be used to backfill the excavations. A Part B equivalenc) submittal would be required. Because an externally fired dryer is used, no organic destruction takes place; 'thus, the unit is not required to meet the strict incinerator permitting standards. Manifest documents may be required for transportation and offsite disposal of the liquid condensate and exhausted carbon. Worker health and safety would be regulated under OSHA. Short-Term Effectiveness This type of treatment requires excavation of the soil which requires handling of contaminated material and poses Inherent short-term risks. Excavation and onsite treatment requires removing, stockpiling, and handling contaminated soil in areas which are currently non-contaminated. In this type of situation, there is a high risk of spreading contamination into the surrounding environment by volatilization, fugitive dust, storm water runoff, and precipitation infiltrating through contaminated soil. Risks of spreading environmental contamination can be minimized by diligent control of fugitive dust and careful management of storm water. However, eliminating volatilization of organics 1s difficult. Short-term risks to the environment are anticipated with this alternative. Since contaminated soil 1s being excavated and treated, workers will be potentially exposed to hazardous material. Potential exposures include respiration of volatilized organics and contaminated fugitive dust, dermal exposure by handling of contaminated soil, exhausted activated carbon, liquid condensate, etc. However, workers can be protected from the risks associated with this operation by utilizing proper respiratory protection and appropriate health and safety procedures. Once the contaminated soil enters the thermal desorption treatment unit, hazardous material will be contained within the > system. Off-gases from the thermal process will be treated using condensers, £ filters, and activated carbon. Process residuals, Including liquid condensate and exhausted activated carbon, are hazardous materials, and proper handling o and disposal of these materials will be required to protect the safety of the 2 workers, surrounding community, and the environment. i—i_"i NJ AOP-SS-H 5_27 A. 0. Polymer Site Public Review Feasibility Study April 1991

In summary, short-term risks to onsite workers and the environment are anticipated as a result of Implementing this alternative. Host risks can be managed, however, by using diligent environmental controls and proper worker health and safety practices during implementation. Some volatilization of organic* Into the environment during excavation will occur. Long-Term Effectiveness and Permanence This process has a high degree of reliability in achieving remediation goals and NJDEP action levels for soil. Only trace levels of contaminants will remain in the soil. Virtually no residual risk from contaminated soil will remain. The soil will be eliminated a source of contamination of the groundwater. Source control alternatives include no institutional or other controls to manage future groundwater contamination created by the soil contamination. However, all management of migration alternatives Include institutional controls for risk management associated with potential future ingestion of groundwater. Reduction of Toxicitv. Mobility or Volume Through Treatment The low temperature thermal desorption process directly reduces the volume of soil contaminants by physically separating the organic contaminants from the soil and concentrating them in treatment residuals, which will require subsequent disposal or destruction. Since the contaminants are removed from the soil, they are no longer available to be mobile In the environment. Thus, their mobility in the A. 0. Polymer Site environment is eliminated. Residuals from the process Include processed soil, liquid condensate, and exhausted carbon from treatment of off-gases. Since the vapors are collected with activated carbon, which would be subsequently taken offsite for regeneration or disposal, no releases of hazardous materials are anticipated. Implementabilltv Excavation and onsite treatment requires removing, stockpiling, and handling contaminated soil 1n areas which are currently non-contaminated. In this type of situation, contamination could be spread by volatilization, fugitive dust, storm water runoff, and precipitation infiltrating through contaminated soil. Diligent control of fugitive dust and careful management of storm water will be required in order to reduce risks of environmental degradation. > Site space constraints effect the implementability of this alternative. Large o areas are required for stockpiles, treatment facilities, and excavation equipment. Additionally, operations associated with the excavation and 0 treatment may interfere with existing operations of the A. 0. Polymer plant. 2 The access road to the gun club will require relocation, and extensive areas i—• «"-35-" 5-28 S A. 0. Polymer Site Public Review Feasibility Study April 1991 outside of the A. 0. Polymer property line will be required for stockpiles. Due to the limited space available, extensive bracing of the excavation using sheet piling would be required. As with any of the source control onsite treatment alternatives, some type of agreement may be required with A. 0. Polymer; however, this 1s especially relevant in this alternative, since excavation and treatment operations would require a significant amount of space and may interfere with A. 0. Polymer plant operations. Several companies are currently operating mobile treatment units. Chemical Waste Management, Inc. (CWH) is currently operating the X*TRAX thermal desorption system at the bench scale, pilot scale (5 tons/day), and full-scale (150 tons/day) levels. Only one full-scale unit is currently available, but CWH reports that additional units could be manufactured and operational within 9 to 12 months if required for a specific project. The time required for excavation, processing of soil through the thermal desorption operation, and backfill of the soil is estimated to be from 6 to 12 months, based on the 150 ton/day capacity. Approximately 9 to 12 months will be required up front for exploratory soil sampling, engineering and design, bidding, and mobilization of equipment. Exploratory sampling would be required to determine the limits of excavation, and confirmatory sampling of treated soil will be required throughout the project. It is assumed that an onsite mobile laboratory will be utilized for the analysis. Soil sampling and analysis is technically and administratively feasible to implement. Test borings, sampling, and analysis of soil samples are standard practices, and the required services and equipment are readily available. Cost This alternative 1s significantly more costly than the soil vapor extraction and soil flushing alternatives. The costs Include soil excavation and backfill operations, soil sieving or screening, material handling, mobilization and operation of the thermal desorption system, off gas control and treatment, analysis and offsite disposal of treatment residuals, exploratory sampling and analysis to define limits of excavation, and confirmatory sampling and analysis of treated soil. For cost estimating purposes, no long-term monitoring is assumed to be required. The total present worth cost of the excavation and low temperature thermal desorption alternative 1s estimated to be $4,518,000 (5% discount rate) and § $4,508,000 (10% discount rate). A summary of the cost estimate is provided on ^ Table 5-6. o o

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AOP-35-H c on TABLE 5-6 COST ESTINATE SUMMARY ALTERNATIVE SC-6 EXCAVATION AND LOW TEMPERATURE THERMAL DESORPTION A. 0. POLYMER FEASIBILITY STUDY

Capital Annual Present Worth of ITEM Quantity Cost 0 t M Annual Ott Costs Rate « 5X Rate * 10X

I. SOIL SAMPLING/ ANALYSIS PROGRAM 1. Surveying 3 days S3, 000 2. Exploratory Drilling 6300 LF $151,200 3. Sample Analysis - Exploratory * 1260 samples $90,000 4. Sample Analysis - Confirmatory ** 5 1/2 months $121,000 Subtotal : $365,200 SO SO SO

II. SOIL EXCAVATION AND BACKFILL OPERATIONS 1. Sheetpile Wall for Bracing Excavation 3750 SF $235,000 2. Excavation Operation 12000 CY $209,400 3. Backfill Operation 12000 CY $111,300

Subtotal: $555,700 $0 SO SO

III. SOIL TREATMENT - XMRAX PROCESS 1. Soil TreatMent Process ($175/ton) 11,250 tons $1,968,750 2. Permit Equivalency Submittal Lump SUM $20,000

Subtotal : $1,988,800 $0 SO SO

IV. SITE PREPARATION t RESTORATION 1. Relocate Existing Drums, etc. LUMP SUM $5,000 2. Relocate Access Road 400 LF $2,440 3. Site Security Fence 640 LF $10,140 4. Clearing and Grubbing Lump SUM $2,500 5. Construct Haul Roads 1000 CY $5,000 6. Two Site Trailers 2 years $26,800 7. Revegetation 2 acres $3,040 Subtotal: $54,900 $0 SO SO

V. FIVE-YEAR REVIEWS (30 YEARS) ••• 1. 5- Year Reviews $20,800 $11,600 Subtotal: $0 $0 $20,800 $11,600 CONSTRUCTION SUBTOTAL $2.964,600 ANNUAL 0 1 M SO $20,800 $11,600 Capital 0 1 M Health and Safety 5X OX $148,230 $0 $0 $0 Bid Contingency 15X OX $444,690 $0 $0 $0 Scope Contingency 15X OX $444,690 $0 $0 $0

CONSTRUCTION TOTAL $4,002,200 $0 $20,800 $11,600 -table continued on next page-

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5-30 Permitting i Legal U $40,022 Service* During Con*truction 5X $200,110 TOTAL IMPLEMENTATION COST *4,242,300 Engineering t Design 6X $254,538 TOTAL CAPITAL COSTS U,496,800 TOTAL PRESENT WORTH U, 518,000 U, 508,000

• Exploratory drilling to pre-determine the limits of excavation will consist of 252 test borings, with 5 samples per test boring. Volatile organic analysis will be used as an indication of contamination. Analysis will be performed at an onsite mobile laboratory equipped with gas chromatograph. •* ConfirlMtory sampling of treated soil will be performed at an onsite mobile laboratory equipped with a GC/MS. Analysis will include volatile organic analysis, base-neutral, and acid extractables. Analysis will be performed at the capacity of the mobile lab (approx. 6-8 analyses/day) throughout the duration of the project. •* Long-term soil monitoring is assumed to not be required. Half of the cost of each 5-year review ($7500) is included in SC Alternatives. Review* at t » 5 yr, 10 yr, 15 yr, 20 yr, 25 yr, and 30 yr.

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5-31 A. 0. Polymer Site Public Review Feasibility Study April 1991

5.3.7 Summary of Source Control Alternative Costs Table 5-7 presents a summary of the total present worth costs at 5% and 10% discount rates for the source control alternatives.

5.4 DETAILED EVALUATION OF MANAGEMENT OF NI6RATION (MM) ALTERNATIVES In this section, a detailed evaluation of each alternative with respect to each of the nine criteria is presented in narrative form. As described in the previous section of this report, five management of migration alternatives have been selected for detailed evaluation for the A. 0. Polymer Site. They will be presented in this section as follows: 5.4.1 MM-1 No Action with Institutional Controls 5.4.2 MM-2 Extract and Treat - Biological/Air Stripping/Carbon Adsorption 5.4.3 MM-4 Extract and Treat - Powdered Activated Carbon Treatment (PACT) 5.4.4 MM-5 Extract and Treat - UV Oxidation Two different groundwater extraction options have been developed, as previously described in Section 4.4 of this report. Each extraction option results in different costs for installation and operation of the extraction system, different flow rates of water to be treated, and different costs of water treatment. Therefore, costs are estimated for each extraction option for the extraction and treatment alternatives MM-2 through MM-5. Since the extraction options were previously discussed in Section 4.4, the detailed evaluations of MM alternatives presented in this section will focus on treatment, rather than extraction. For cost estimating purposes, the discharge of treated water for each extraction and treatment alternative is assumed to be surface water discharge to the Wallkill River or discharge to wetlands near the Wallklll River. The other discharge option, discharge to a recharge basin, is also available for each extraction and treatment alternative. However, the costs associated with installation of a recharge basin and pumping treated water up to the recharge basin are provided under the soil flushing source control alternative (SC-3). If the selected discharge option for an extraction and treatment alternative is discharge to a recharge basin, the appropriate costs from alternative SC-3 should be added to the cost estimate for the extraction and treatment alternative. 5.4.1 MM-1 : No Action with Institutional Controls ^ o This alternative represents a natural attenuation alternative and Includes ^ institutional controls and groundwater monitoring, as required under CERCLA. 0 This alternative provides a baseline for comparison with active groundwater 2 remediation alternatives. This alternative would Involve restrictions on future groundwater use, public awareness and education programs, and _, groundwater monitoring. £ to AOP-35-M 5-32 TABLE 5-7 COST ESTIMATE SUMMARY SOURCE CONTROL ALTERNATIVES A. 0. POLYMER FEASIBILITY STUDY

SOURCE CONTROL ALTERNATIVE TOTAL PRESENT WORTH COST TOTAL PRESENT WORTH COST 5X Discount Rate 10X Discount Rate

SC-1 : NO ACTION (Monitoring) $319,000 $194,000 SC-2 : CAPPING $135,000 $112,000 SC-3 : SOIL FLUSHING $499,000 $372,000 SC-4 : SOIL VAPOR EXTRACTION $810,000 $686,000 SC-5 : SOIL FLUSHING I SOIL VAPOR EXTRACTION SI,016,000 $889,000 SC-6 : EXCAVATION/LOW TEMP THERMAL DESORPTION $4,518,000 $4,508,000

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5-33 A. 0. Polymer Site Public Review Feasibility Study April 1991

Overall Protection of Human Health and the Environment Under this alternative, the groundwater would be remediated only through natural attenuation. Since human health risks are Identified based only on potential future use, restrictions on future groundwater use would be implemented to manage short-term risks associated with ingestion of contaminated groundwater until the aquifer 1s remediated through natural attenuation. The long-term human health risks for the site would remain essentially the same as those Identified in the baseline risk assessment, as presented in Section 6.0 of the Remedial Investigation Report. In reality, the soil and groundwater contamination will lessen over time through natural processes such as flushing and attenuation. Therefore, the potential human health risks associated with the ingestion of contaminated groundwater will lessen over time as well. There has been no significant environmental risks and no significant risks identified with respect to terrestrial or aquatic life at the site. Compliance with ARARs For a long period of time, a number of volatile organic compounds in groundwater will remain at levels greater than Federal and NJSWDA MCLs, relevant and appropriate chemical-spedfie ARARs and TBCs. However, the contaminant levels will gradually be reduced over the period of natural attenuation, estimated to be approximately 27 years with source control and 87 years without source control. Groundwater monitoring systems must comply with requirements specified under Citation NJAC 7:26-9. Groundwater monitoring wells must be installed and permitted in accordance with Citation NJAC 7:9-7. Short-Term Effectiveness Since no remedial action is being implemented, there would be no short-term risks posed to the community, workers, or the environment as a result of this alternative. Natural attenuation was evaluated using travel time calculations. Using TCE as an indicator chemical, the time period required for cleanup levels to be achieved through natural attenuation of the existing groundwater plume 1s estimated to be approximately 27 years. In addition, natural source flushing, the time required for precipitation and Infiltration to flush contaminants from the soil 1s estimated to take at least 60 years. Therefore, if source control is implemented, the time required for natural attenuation of the aquifer will be approximately 25 years. If no source control 1s Implemented, g and no groundwater remediation 1s implemented, the total time required for ^ natural attenuation of the soil and the aquifer is estimated to be at least 85 years. §

u> AOP-35-H e ,j *• A. 0. Polymer Site Public Review Feasibility Study April 1991

Long-Term Effectiveness and Permanence Since human health risks are Identified based only on potential future use, restrictions on future groundwater use could be effectively used to manage risks associated with ingestion of contaminated groundwater provided they are strictly enforced. Groundwater use restrictions should be Implemented at the site for 27 to 87 years until the contaminated groundwater is remediated through natural attenuation. Groundwater monitoring will be performed to assess the progress of natural attenuation and to provide data for periodic reviews. Reduction of Toxicitv. Mobility or Volume Through Treatment This alternative would not actively reduce the toxicity, volume or mobility of the groundwater contaminants. However, the soil ant groundwater contamination will lessen over time through natural processes such as flushing and natural attenuation. Implementability Public awareness and education programs are typically administered by either the U. S. EPA or by the State. These programs are designed to inform the public of the action being implemented at the site, and the potential public health and environmental risks remaining at the site. Groundwater use restrictions are easily implemented through deed restrictions or other institutional controls, but are only effective if properly enforced. Groundwater use restrictions should be implemented at the site until the contaminated groundwater at the site Is remediated through natural attenuation. Since contaminants will be left onsite, periodic sampling of contaminated groundwater will be required to provide data for periodic reviews. Periodic groundwater monitoring 1s technically and administratively easy to Implement. Existing monitoring wells could be used. Standard sampling and analytical equipment is used for groundwater monitoring, and is readily available. Cost The costs associated with this alternative include administrative costs of implementing public awareness/education programs and groundwater use restrictions, groundwater monitoring, and cost of periodic reviews. Costs associated with Implementing public awareness/education programs and § groundwater use restrictions are estimated to be $25,000. ^ Groundwater monitoring would be Implemented over a 30-year period to assess o the progress of natural attenuation. For purposes of cost estimating, ten '- monitoring wells are assumed to be sampled semi-annually over a 30-year ^ >—i U) .„ „ (Jl *»•»• "u 5-35 A. 0. Polymer Site Public Review Feasibility Study April 1991

period, for a total of 20 samples per year (24 samples per year Including blanks and duplicates). Water samples are to be analyzed for total volatile organics. The annual cost of the proposed groundwater monitoring 1s $17,000. The total present worth cost of the minimal action alternative 1s estimated to be $385,000 (5X discount rate) and $247,000 (10* discount rate). A summary of the cost estimate Is provided on Table 5-8. 5.4.2 MM-2 ; Extract and Treat - Biological/A1r Stripping/Carbon Adsorption This groundwater treatment alternative utilizes aerobic biological treatment (i.e., activated sludge) as a first step to remove biodegradable compounds including ketones and some monoaromatlc hydrocarbons. This would be followed by air stripping to remove the volatile halogenated aliphatic hydrocarbons and the remaining monoaromatlc hydrocarbons. Air stripping would be followed by activated carbon adsorption as a polishing step to remove any remaining organics. Treated water would be discharged to the Wall kill River. This alternative would also Involve restrictions on future groundwater use, public awareness and education programs, and groundwater monitoring. Overall Protection of Human Health and the Environment The groundwater will be actively restored through extraction and treatment. Depending on the extraction option used in conjunction with this alternative, the level of protection of human health provided will vary. The 4 well option will actively restore groundwater to remediation goals within approximately 50 percent of the area now affected by contamination. This Includes all areas of the aquifer where contaminants are most concentrated. The 7 well option will actively restore groundwater in approximately 80 percent of the affected area. Residual contamination that 1s not actively captured by either extraction option will be allowed to flush naturally to the Wall kill River. Groundwater use restrictions would be Implemented to manage short-term human health risks associated with potential "ingestion of groundwater until aquifer remediation is achieved. Compliance with ARARs Initially, a number of volatile organic compounds in groundwater will remain at levels greater than Federal and NJSWDA HCLs. However, the contaminants in the groundwater will gradually be reduced over the period of extraction and treatment to below HCLs. Treatment residuals, Including sludge from biological treatment and spent carbon, may be considered hazardous waste and would be regulated, transported, and disposed under RCRA.

u>

Quantity Capital Annual Present Worth ITEM Cost 0 I M OtM/Replacement 30 years, 5X 30 years, 10X

I. INSTITUTIONAL ACTIONS 1. Public Awareness/Education Program I $25,000 Groundwater Use Restrictions Subtotal: $25,000 $0 $0

II. LONG TERM MONITORING t REVIEW (30 YEARS) 1. Install additional Monitoring uell S3,000 2. Semi-annual Groundwater Monitoring * $17,000 $261,300 $160300 , 3. Five- Year Reviews ** $20, 800 $11600 , Subtotal: $3,000 $17,000 S282,000 $172000 , CONSTRUCTION SUBTOTAL $28,000 $17,000 $282,000 $172000 , Capital OIM Health and Safety 5X 5* $1,400 $14100 ,$0,600 Bid Contingency 5X 5X $1 ,400 $14100 , $8,600 Scope Contingency 5X 15X $1 ,400 $42300 , $25800 , CONSTRUCTION TOTAL $32,200 $352,500 $215000 , Permitting t Legal OX $0 Services During Construction OX $0 TOTAL IMPLEMENTATION COST $32,200 Engineering t Design OX $0

TOTAL CAPITAL COSTS $32,200

TOTAL PRESENT WORTH $385,000 $247,000

* Monitoring Period of 30 Years: 10 Monitoring wells sample* seari-annually. Analysis performed is for VOCs and MM Extrectables. ** Half of the cost of each 5-year review ($7500) is included in each MM Alternative. Reviews a t » 5 yr, 10 yr, 15 yr, 20 yr, 25 yr, and 30 yr.

o o

Ui xj 5-37 A. 0. Polymer Site Public Review Feasibility Study April 1991

Air stripping emissions would be regulated under the federal Clean Air Act. The State of New Jersey also regulates particle and volatile organic emissions from air strippers. An air pollution control permit must be Issued by the State of New Jersey for the air stripper. Discharge of the treated water to the Wall kill River would be regulated under the federal Clean Water Act, Including Section 402 - The National Pollutant Discharge Elimination System (NPDES). The State also regulates discharges to surface water under the New Jersey Pollutant Discharge Elimination System (NJPDES). Groundwater monitoring systems must comply with requirements specified under Citation NJAC 7:26-9. Groundwater monitoring wells must be Installed and permitted in accordance with Citation NJAC 7:9-7. The extraction and treatment system will be designed and operated to fully comply with all ARARs. Short-Term Effectiveness Installation of extraction wells Involves little disturbance of the subsurface environment and only minor potential for contact with contaminated materials. The treatment system will be Installed offsite and involves no contact with hazardous materials. Operation and maintenance of the treatment facility poses minor risks of contact with hazardous materials. Each of these potential risks can be managed with a Health and Safety Plan outlining the procedures to be followed during Implementation. No short-term risks to the community or the environment are anticipated as a result of this alternative. Using TCE as an indicator chemical in the solute transport calculations and assuming effective source control 1s implemented, the time period required for cleanup levels to be achieved through extraction and treatment of the existing groundwater plume is estimated to be from approximately 7 to 9 years for the 4 and 7 well options respectively. Long-Term Effectiveness and Permanence Potential residual risks are associated with the contaminated groundwater that is not actively removed by the extraction and treatment system. Because of the groundwater conditions that exist at the site, residual contamination will be flushed fro» the aquifer Into the Wall kill River. Because the active extraction systems will have removed the most contaminated part of the plume, the discharge of residual contaminants to the Wallkill River will not result in any risks that exceed those that were currently estimated in the risk assessment presented in Section 6.0 of the RI report. Since direct contact risks and environmental Impact associated with current o levels of contamination in the river are presently within acceptable limits, o the residual risks represent no Increase in threat to human health or the environment as a result of contaminant discharge to the stream. However,

AOP-35-H c ,0 A. 0. Polymer Site Public Review Feasibility Study April 1991 residual contamination will exceed groundwater remediation goals (MCLs and MCLGs) over the time It takes for these contaminants to be removed by natural processes. Based on transport calculations, between 4 and 9 years will be required before the residual contaminates are flushed to the Wall kill River for the 7 and 4 well extraction options, respectively. Since human health risks are identified based only on potential future use, restrictions on future groundwater use could be effectively used to manage short-term residual risks associated with ingestion of contaminated groundwater. Although groundwater use restrictions do not provide a permanent solution, they should be Implemented at the site until the contaminated groundwater 1s remediated through extraction and treatment. Groundwater monitoring will be performed to assess the progress of aquifer restoration and to provide data for periodic reviews. Reduction of Toxlcitv. Mobility or Volume Through Treatment This alternative would actively remove contaminants from the aquifer, and would gradually reduce the toxicity and volume of groundwater contaminants over the extraction and treatment period. Based on the known treatablHty characteristics of the contaminants present in the site groundwater, this treatment system consisting of biological, air stripping and carbon adsorption appears to be effective in treating all of the groundwater contaminants at the site. However, treatabHlty studies including bench scale testing are recommended during the remedial design to determine design parameters of the process and verify compliance of the treatment system effluent with proposed discharge limitations. Treatment residuals Include sludge from biological treatment and spent carbon from air stripping off gas treatment and from liquid-phase carbon polishing. Estimated quantities of residuals, based on Information supplied by vendors are summarized below: Extraction Option A Extraction Option B (72 aoml (126 com)_____ Sludge 50 Ib/day (40* solids) 50 Ib/day (40X solids Air Phase Carbon 63 Ib/day 125 Ib/day Liquid Phase Carbon 167 Ib/day 286 Ib/day

ImplementabHity

The implementability of groundwater extraction is described In Section 4.4 of O this report. O The implementability of the treatment system for this alternative Is described in Section 4.3 of this report.

AOP-35-H 5-39 A. 0. Polymer Site Public Review Feasibility Study April 1991

The ImplementabilHy of public awareness and education programs, groundwater use restrictions, and groundwater monitoring 1s described under alternative MM-1, In Section 5.4.1.6 of this report. Cost Costs associated with biological treatment Include capital costs for the bloreactor, pumps, and other mechanical equipment. 0 & M costs are relatively low and include operation of pumps, addition of nutrients, and pH adjustment. Costs associated with air stripping towers are related to tower height, air- to-water ratio, and the concentrations and volatility of the compounds being removed. Maintenance Items Include pumps, blowers, and replacement of carbon in the off-gas treatment. Tower packing may need to be cleaned occasionally if iron precipitates or slime accumulates. Costs associated with activated carbon adsorption include the capital cost of the vessel, and the cost of replacement carbon. Breakthrough calculations will be performed during the remedial design phase to estimate the carbon bed weight exhausted per day. The estimate will be based on chemical loadings determined from the pump test and other pre-design data collection efforts. Periodic effluent sampling and analysis during remediation would also be required to verify that the discharge is within effluent limitations. The services of a full-time operator would be required. Costs associated with Implementing public awareness/education programs, groundwater use restrictions, and groundwater monitoring are presented under alternative MM-1. For groundwater extraction option A (72 GPM), the groundwater extraction and treatment system is assumed to operate for a period of 7 years. The total present worth cost of this alternative is estimated to be 4,248,000 (5% discount rate) and $3,665,000 (10X discount rate). A summary of the cost estimate is provided on Table 5-9 (A). For groundwater extraction option B (126 GPM), the groundwater extraction and treatment system is assumed to operate for a period of 9 years. The total present worth cost of this alternative is estimated to be $7,122.000 (5% discount ratt) and $5,929,000 (10X discount rate). A summary of the cost estimate is provided on Tablt 5-9 (B).

5.4.3 MM-4 : Extract and Treat - Powdered Activated Carbon Treatment (PACT) § "0 Powdered activated carbon treatment (PACT) is an Innovative biological approach utilizing activated sludge in conjunction with powdered activated o carbon. Powdered activated carbon is added to the aerator of the activated ^ sludge system. The combined biological and activated carbon treatment is synergistic; the carbon enhances the biological treatment by also adsorbing 4k O MP-35-H 5-40 TABLE 5-9 (A) COST ESTIMATE SUMMARY ALTERNATIVE NM-2 (A) EXTRACTION AND TREATMENT - OPTION A (72 CPM) BIOLOGICAL/AIR STRIPPING/CARBON ADSORPTION TREATMENT A. 0. POLYMER FEASIBILITY STUDY

Quantity Capital Annual Present Worth of ITEM Cost OtM Annual OtM Costs 5X Discount 10X Discount I. EXTRACTION/DISCHARGE SYSTEM 1. New Extraction Uells 4 Wells $34,100 2. Submersible Pumps 4 Pumps $1,650 $800 $4.600 $3,900 3. Collection/Discharge Piping 800 LF $14,280 4. Electrical Connections/Electric Power Lump Sun $14,250 $2,600 $15,000 $12,700 5. System Controls Lump Sun $7,660 Subtotal: $71,940 $3,400 $19,600 $16,600 11. SITE PREPARATION/TREATMENT BUILDING 1. Construct Treatment Building 5000 SF $300,000 2. Building Lighting/Heating Lump Sum $3,600 $20,800 $17,500 3. Construct Parking/Staging Area Lump Sum $8,000 Subtotal: $308,000 $3,600 $20,800 $17,500 III. WATER TREATMENT SYSTEM 1. Bag Filtration Unit $8,000 2. Equalization Basin $18,000 3. Filter Press (sludge dewatering) $20,000 4. Bioreactor $87,500 OtM (nutrients, sludge disposal, power) $21,830 $126,300 $106,300 5. Air Stripping Tower I Off -Gas System $90.000 OtM (carbon, power, maintenance) $82,700 $478,500 $402,600 6. Carbon Adsorption Equipment $15,000 a. OtM (carbon replacement) $183,270 $1,060,500 $892,200 7. Equipment Delivery and Set-up $20,000 8. Full -Time System Operator $50,000 $289,300 $243,400 Subtotal $258,500 $337,800 $1,954,600 $1,644,500

IV. TREATED WATER DISCHARGE 1. NPOES Permit $7,500 2. Weekly Effluent Sampling • $19,500 $112,800 $94,900 Subtotal : $7,500 $19,500 $112,800 $94,900 V. INSTITUTIONAL ACTIONS 1. Public Awareness/Education Program t $25,000 Groundwater Use Restrictions Subtotal: $25,000 $0 $0 VI. LONG TERM MONITORING t REVIEW (30 YEARS) 1. Install additional Monitoring well $3,000 2. Semi-annual Groundwater Monitoring •• $17,000 $261,300 $160,300 3. Five-Year Reviews ••* $20,800 $11,600 Subtotal: $3,000 $17,000 $282,100 $171,900 CONSTRUCTION SUBTOTAL $673,900 $381,300 $2,389,900 $1,945,400

-table continued on next page-

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5-41 Capital OtM Health and Safety IX U $6,739 $23,899 $19,454 lid Contingency 15X 15X $101.085 $358,485 $291,810 Scop* Contingency 15X 15X $101,085 $358,485 $291,810

CONSTRUCTION TOTAL $882,800 $3,130,800 $2,548,500 Permitting 1 Legal sx SU.UO S«rvicM During Construction 10X $88,280

TOTAL IMPLEMENTATION COST *1, 015, 200

Engineering 1 Design 10X $101,520

TOTAL CAPITAL COSTS »1. 116,700

TOTAL PRESENT WORTH $4,248,000 $3,665,000

NOTE: Cost estimate assumes 7-year period of operation for the extraction and treatment system. • Weekly effluent sampling for 7 years. Analysis performed is for VOCs. •* Monitoring Period of 30 Years: 10 snnitoring wells samples *e*i-annually. Analysis performed is for VOCs. •** Half of the cost of each 5-year review ($7500) is included in each MM Alternative. Reviews S t » 5 yr, 10 yr, 15 yr, 20 yr, 25 yr, and 30 yr.

5-42 TABLE 5-9 (8) COST ESTIMATE SUMMARY ALTERNATIVE MM-2 (B) EXTRACTION AND TREATMENT - OPTION B (126 GPM) BIT OGICAL/AIR STRIPPING/CARBON ADSORPTION TREATMENT A. 0. POLYMER FEASIBILITY STUDY

Quantity Capital Annual Present Worth of ITEM Cost 0 I M Annual O&M Costs 5X Discount 10X Discount I. EXTRACTION/DISCHARGE SYSTEM 1. Neu Extraction Wells 7 Wells $46,700 2. Submersible Pumps 7 Pumps $2,900 $1,400 $10,000 $8,100 3. Collection/Discharge Piping 1050 LF $18,840 4. Electrical Connect ions/E 1 ectric Power Lump Sum $14,475 $4,570 $32,500 $26,300 5. Systeai Controls Lunp Sun $13,405 Subtotal: $96,320 $5,970 $42,500 $34,400 II. SITE PREPARATION/TREATMENT BUILDING 1. Construct Treatment Building 5000 SF $300,000 2. Building Lighting/Heating Lunp Sum $3,600 $25,600 $20,700 3. Construct Parking/Staging Area Lump Sum $8,000 Subtotal: $308,000 $3,600 $25,600 $20,700 III. WATER TREATMENT SYSTEM 1. Bag Filtration Unit $16,000 2. Equalization Basin $26,000 3. Filter Press (sludge deyatering) $20,000 4. Bioreactor $105,000 0AM (nutrients, sludge disposal, power) $30,380 $215,900 $175,000 5. Air Stripping Tower I Off-Gas System $108,000 OM (carbon, power, maintenance) $162,850 $1,157,500 $937,900 6. Carbon Adsorption Equipment $30,000 a. OIM (carbon replacement) $321,530 $2,285,400 $1,851,700 7. Equipment Delivery and Set-up $20,000 8. Full-Tine System Operator $50,000 $355,400 $288,000 Subtotal $325,000 $564,760 $4,014,200 $3,252,600

IV. TREATED WATER DISCHARGE 1. NPOES Permit $7,500 2. Weekly Effluent Sampling * $19,500 $138,600 $112,300 Subtotal: $7,500 $19,500 $138,600 $112,300

V. INSTITUTIONAL ACTIONS 1. Public Awareness/Education Program I $25,000 Groundwater Uae Restriction* Subtotal: $25,000 $0 $0 VI. LONG TERM MONITOR I Mfi I REVIEW (30 YEARS) 1. Install additional monitoring well $3,000 2. Semi-annual Groundwater Monitoring •• $17,000 $261,300 $160,300 3. Five- Year Review* ••• $20,800 $11,600 Sifctotal : $3,000 $17,000 $282,100 $171,900 CONSTRUCTION SUBTOTAL $764,800 $610,800 $4,503,000 $3,591,900

-tablt continued on next page-

5-43 Capital OIM Health and Safety IX IX $7,648 $45,030 $35,919 lid Contingency 15X 15X $114,720 $675,450 $538,785 Scope Contingency 15X 15X $114.720 $675,450 $538,785

CONSTRUCTION TOTAL $1,001,900 $5,898,900 $4,705,400

Pemitting I Legal 4X $40.076 Service* During Construction 8X $80.152

TOTAL IMPLEMENTATION COST $1,122,100

Engineering t Design 9X $100,909

TC-tl CAPITAL COSTS $1,223,100

TOTAL PRESENT WORTH $7,122,000 $5,929,000

NOTE: Cost **tie»te assuses a 9-yeer period of operation for the extraction and treatment tystM. * Weekly effluent campling for 9 years. Analysis perforated is for VOCs. " Monitoring Period of 30 Years: 10 Monitoring wells samples s*»i-annually. Analysis performed is for VOCs. •** Half of the cost of each 5-year review ($7500) is included in each MM Alternative. Review* 8 t « 5 yr, 10 yr, 15 yr, 20 yr, 25 vr , and 30 yr.

O

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5-44 A. 0. Polymer Site Public Review Feasibility Study April 1991 biodegradables. Many compounds are adsorbed on the carbon, which 1s removed and recycled along with the biomass in the clarifier. As the compounds adsorbed to the activated carbon are recycled with the sludge, they have a much longer system retention time, allowing a greater degree of biological degradation. The presence of carbon in the aeration basin also acts as a buffer to protect the easily upset biological process against shock loadings caused by sudden changes in influent concentration. Treated water would be discharged to the Wallkill River. This alternative would also involve restrictions on future groundwater use, public awareness and education programs, and groundwater monitoring. Overall Protection of Human Health and the Environment The groundwater will be actively restored through extraction and treatment. Depending on the extraction option used in conjunction with this alternative, the level of protection of human health will vary. The 4 well option will actively restore groundwater to remediation goals, within approximately 50 percent of the area now affected by contamination. This includes all areas of the aquifer where contaminants are most concentrated. The 7 well option will actively restore groundwater in approximately 80 percent of the affected area. Residual contamination that 1s not actively captured by either extraction option will be allowed to flush naturally to the Wallkill River. Groundwater use restrictions would be Implemented to manage short-term human health risks associated with potential ingestion of groundwater until aquifer remediation is achieved through extraction and treatment. Compliance with ARARs Initially, a number of volatile organic compounds in groundwater will remain at levels greater than Federal and NJSWDA MCLs. However, the contaminants in the groundwater will gradually be reduced over the period of extraction and treatment to below MCLs. Sludge from the PACT process may be considered a hazardous waste and would be regulated, transported and disposed under RCRA. Discharge of treated water to the Wallkill River would be regulated under the federal Clean Water Act, Including Section 402 - the National Pollutant Discharge Elimination System (NPDES). The state also regulated discharges to surface water under the New Jersey Pollutant Discharge Elimination System (NJPDES). Groundwater monitoring systems must comply with requirements specified under Citation NJAC 7526-9. Groundwater monitoring wells must be Installed and permitted in accordance with Citation NJAC 7:9-7. o The extraction and treatment system will be designed and operated to fully comply with all ARARs.

AOP-35-H 5-45 A. 0. Polymer Site Public Review Feasibility Study April 1991

Short-Term Effectiveness As discussed in MM-2, this alternative poses easily managed risks to workers and no short-term risks to the community or the environment as a result of this alternative are anticipated. The time required to achieve active restoration within the affected part of the aquifer is 7 to 9 years depending on the extraction option. Long-Term Effectiveness and Permanence Potential residual risks after implementation of this alternative would be as described for MM-2. Since the identified human health risks are based only on potential future use, restrictions on groundwater use would effectively manage risks associated with ingestion of contaminated groundwater if the restrictions are strictly enforced. Although they do not provide a permanent solution, groundwater use restrictions should be Implemented at the site until the contaminated groundwater at the site is remediated through extraction and treatment. Groundwater monitoring will be performed to assess the progress of aquifer restoration and to provide data for periodic reviews. Reduction of Toxldtv. Mobility or Volume Through Treatment This alternative would actively remove contaminants from the aquifer, and would gradually reduce the toxicity and volume of groundwater contaminants over the extraction and treatment period. The treatment component of this alternative 1s a relatively new and Innovative process that is believed capable of treating all groundwater contaminants of concern. However, bench scale testing will be required to determine both the effectiveness and ability of the system to comply with discharge standards. Sludge consisting of bioaass, removed contaminants and spent carbon and requiring dewatering and offsite disposal will be generated during this treatment process. Based on Information supplied by treatment system vendors, estimated residual quantities are as follows: 4 Well Option 7 Well Option (72 aom) (126 aom) Sludge 110 Ibs/day (40X solids) 180 Ibs/day (40* solids)

Implementabllitv The implementability of groundwater extraction 1s described in Section 4.4 of this report.

AOP-35-H A. 0. Polymer Site Public Review Feasibility Study April 1991

The implementability of the treatment system for this alternative is described in Section 4.3 of the report. The implementability of public awareness and education programs, groundwater use restrictions, and groundwater monitoring is described under alternative MM-1, in Section 5.4.1.6 of this report. Cost Costs for PACT include the capital costs for equipment and installation. Operating costs include activated carbon regeneration or disposal, polymer, disposal of waste sludge, equipment repair and maintenance, and power supply. Long-term management of the system would be required to insure it's continued operating efficiency. The services of a full-time operator would be required. Treatability studies including bench scale testing are recommended during the remedial design to determine design parameters of the process and to verify compliance of the treatment system effluent with proposed discharge limitations. Treatability testing will also determine if an activated carbon polishing step is required in order to achieve effluent discharge limitations. Costs associated with implementing public awareness/education programs, groundwater use restrictions, and groundwater monitoring are presented under alternative MM-1. For groundwater extraction option A (72 GPM), the groundwater extraction and treatment system is assumed to operate for a period of 7 years. The total present worth cost of this alternative is estimated to be $2,552,000 (5X discount rate) and $2,234,000 (10* discount rate). A summary of the cost estimate is provided on Table 5-10 (A). For groundwater extraction option B (126 GPM), the groundwater extraction and treatment system is assumed to operate for a period of 9 years. The total present worth cost of this alternative is estimated to be $3,767,000 (5X discount rate) and $3,300,00 (10% discount rate). A summary of the cost estimate is provided on Table 5-10 (B). 5.4.4 MM-5 : Extract and Treat - UV Oxidation UV Oxidation 1s an emerging technology for cleanup and destruction of organics in groundwater. Commercial applications using hydrogen peroxide and ozone as the oxidant have been developed. In this process, ultraviolet light reacts with hydrogen peroxide and/or ozone molecules to form hydroxyl radicals. ^ These very powerful chemical oxidants then react with the organic contaminants o in water. In addition, many organic contaminants absorb ultraviolet light and become more reactive with the chemical oxidants. c,

AOP-35-H 5-47 TABLE $-10 (A) COST ESTIMATE SUMMARY ALTERNATIVE MM-4 (A) EXTRACTION AND TREATMENT - OPTION A (72 GPM) POWDERED ACTIVATED CARBON TREATMENT (PACT) A. 0. POLYMER FEASIBILITY STUDY

Quantity Capital Annual Present Worth of ITEM Cost 0 t M Annual O&M Costs 5X Discount 10X Discount 1. EXTRACTION/DISCHARGE SYSTEM 1. New Extraction Wells 4 Wells $34,100 2. Submersible PIMP* 4 Pumps $1,650 $800 $4,600 $3,900 3. Collection/Discharge Piping 800 LF 114,280 4. Electrical Connections/Electric Power Lump SUM $14,250 $2,600 $15,000 $12,700 5. System Control* Lump SUM $7,660

Subtotal: $71,940 $3,400 $19,600 $16,600 11. SITE PREPARATION/TREATMENT BUILDING 1. Construct Tres-Tient Building 5000 SF $300,000 2. Building Ligh* V Heat ing Lump Sum $3,600 $20,800 $17,500 3. Construct Part -^/Staging Area Lump Sum $8,000 Subtotal: $308,000 $3,600 $20,800 $17,500 III. WATER TREATMENT SYSTEM 1. Model BUO (Batch) Pact System and Auxiliary Equipment/Delivery/Set-up $190,000 2. Multi-Media Post-Filtration Unit $30,000 3. Filter Press (sludge dewatering) $20,000 4. 0 * M Costs: a. Electricity $18,250 $105,600 $88,800 b. Carbon Usage $32,850 $190,100 $159,900 c. Sludge Disposal $16,500 $95,500 $80,300 c. Polymer $600 $3,500 $2,900 5. Full-Time System Operator $50,000 $289,300 $243,400 Subtotal $240,000 $118,200 $684,000 $575,300 IV. TREATED WATER DISCHARGE 1. NPDES Permit $7,500 2. Weekly Effluent Sampling * $19,500 $112,800 $94,900 Subtotal: $7,500 $19,500 $112,800 $94,900

V. INSTITUTIONAL ACTIONS 1. Public Awareness/Education Program I $25,000 Groundwater use Restrictions Subtotal: $25,000 $0 $0 VI. LONG TERM MONITORING I REVIEW (30 YEARS) 1. Install additional Monitoring well $3,000 2. Semi-annual GrounoVater Monitoring »• $17,000 $261,300 $160,300 3. Five-Year Review ••* $20,800 $11,600 Subtotal: $3,000 $17,000 $282,100 $171,900 CONSTRUCTION SUBTOTAL $655,400 $161,700 $1,119,300 $876,200

O -table continued on next page- 13

00 5-48 Capital OIM Health end Safety IX IX $6,554 $11,193 $8,762 Bid Contingency 15X 15X $98,310 $167.895 $131,430 Scope Contingency 1SX 15X $98,310 $167,895 $131,430 CONSTRUCTION TOTAL (858,600 $1,466,300 $1,147,800 Permitting i Legal 5X $42,930 Services During Construction 10X US, 860 TOTAL IMPLEMENTATION COST $987,400 Engineering t Design 10X $98,740

TOTAL CAPITAL COSTS $1,086,100 TOTAL PRESENT WORTH $2,552,000 $2,234,000

NOTE: Cost estimate assumes 7-year period of operation for the extraction and treatment system. * Weekly effluent sampling for 7 years. Analysis performed is for VOCs. *• Monitoring Period of 30 Years: 10 Monitoring uells samples semi-annually. Analysis performed is for VOCs. *** Half of the cost of each S-year review ($7500) is included in each MM Alternative. Reviews a t » 5 yr, 10 yr, 15 yr, 20 yr, 25 yr, and 30 yr.

o o

5-49 TABLE 5-10 (8) COST ESTIHATE SUMMARY ALTERNATIVE MM-4 (B) EXTRACTION AND TREATMENT - OPTION B (126 GPM) POWDERED ACTIVATED CARBON TREATMENT (PACT) A. 0. POLYMER FEASIBILITY STUDY

Quantity Capital Annual Present Worth of ITEM Cost 0 I N Annual OM Costs 5X Discount 10X Discount I. EXTRACTION/DISCHARGE SYSTEM 1. New Extraction Wells 7 Wells $46,700 2. Submersible Pumps 7 Pumps $2,900 $1,400 $10,000 $8,100 3. Collection/Discharge Piping 1050 LF $18,640 4. Electrical Connections/Electric Power Lump SLW $14,475 $4,570 $32,500 $26,300 5. System Controls Lump SUM $13,405 Subtotal: $96,320 $5,970 $42,500 $34,400 II. SITE PREPARATION/TREATMENT BUILDING 1. Construct Treatment Building 5000 SF $300,000 2. Building Lighting/Heating Lu«p Sun S3, 600 $25,600 $20,700 3. Construct Parking/Staging Area Lump Sun $8,000 Subtotal: $308,000 $3,600 $25,600 $20,700 III. WATER TREATMENT SYSTEM 1. Model 8140 (Batch) Pact System and Auxiliary Equipment/Deli very/Set -up $600,000 2. Multi-Media Post-Filtration Unit $50,000 3. Filter Press (sludge dewatering) $20,000 4. 0 I M Costs: a. Electricity $25,550 $181,600 $147,100 b. Carbon Usage $54,750 $389,200 $315,300 c. Sludge Disposal $22,500 $159,900 $129,600 c. Polymer $900 $6,400 $5,200 5. Full-Tine System Operator $50,000 $355,400 $288,000 Subtotal $670,000 $153,700 $1,092,500 $885,200

IV. TREATED WATER DISCHARGE 1. NPOES Permit $7,500 2. Weekly Effluent Sampling * $19,500 $138,600 $112,300 Subtotal: $7,500 $19,500 $138,600 $112,300

V. INSTITUTIONAL ACTIONS 1. Pifclic Awareness/Education Program ( $25,000 Groundwater Use Restrictions Subtotal: $25,000 $0 $0 VI. LONG TERM MONITORING I REVIEW (30 TEARS) 1. Install additional monitoring well $3,000 2. Semi-annual Crounduater Monitoring *• $17,000 $261,300 $160,300 3. Five- Year Reviews *** $20,800 $11,600 Subtotal : $3,000 $17,000 $282,100 $171,900

CONSTRUCTION SUBTOTAL $1,109,800 $199,800 $1,581,300 $1,224,500

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5-50 Capital OIM Health and Safety 1X IX $11,098 $15,813 $12,245 Bid Contingency 15X 15X $166,470 $237,195 $183,675 Scope Contingency 15X 15X $166,470 $237,195 $183,675 CONSTRUCTION TOTAL $1,453,800 $2,071,500 $1,604,100 Permitting I Legal 3X $43,614 Service* During Construction 6X $87,228 TOTAL IMPLEMENTATION COST $1,584,600 Engineering 1 Design TX $110,922 TOTAL CAPITAL COSTS $1,695,500 TOTAL PRESENT WORTH $3,767,000 $3,300,000

NOTE: Co*t estimate assumes a 9-year period of operation for the extraction and treatment system. • Weekly effluent sailing for 9 years. Analysis performed i* for VOCs. •* Monitoring Period of 30 Years: 10 Monitoring wells samples seen-annually. Analysis performed is for VOCs. •*• Half of the cost of each 5-year review ($7500) is included in each MM Alternative. Reviews 8 t » 5 yr, 10 yr, 15 yr, 20 yr, 25 yr, and 30 yr.

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5-51 A. 0. Polymer Site Public Review Feasibility Study April 1991

This alternative would also involve restrictions on future groundwater use, public awareness and education programs, and groundwater monitoring. Overall Protection of Human Health and the Environment As described in MM-2 and MM-4, the groundwater would be actively remediated through extraction and treatment. The level of protection of human health provided depends on the extraction option selected. Using TCE as an indicator chemical, the time period required for cleanup levels to be achieved through extraction and treatment of the affected area of the groundwater plume is estimated to be from approximately 7 to 9 years, depending on the groundwater extraction option chosen. Groundwater use restrictions would be implemented to manage short-term human health risks associated with potential ingestion of groundwater until aquifer remediation is achieved through extraction and treatment. Compliance with ARARs Initially, a number of volatile organic compounds in groundwater will remain at levels greater than Federal and NJSWOA MCLs. However, the contaminants In the groundwater will gradually be reduced over the period of extraction and treatment to below MCLs. Discharge of treated water to the Wall kill River would be regulated under the federal Clean Water Act, including Section 402 - The National Pollutant Discharge Elimination System (NPDES). The state also regulates discharges to surface water under the New Jersey Pollutant Discharge Elimination System (NJPDES). Groundwater monitoring systems must comply with requirements specified under Citation NJAC 7:26-9. Groundwater monitoring wells must be installed and permitted in accordance with NJAC 7:9-7. The extraction and treatment system will be designed and operated to fully comply with all ARARs. Short-Term Effectiveness As discussed in MM-2 and MM-4, risks to workers are minimal and easy to manage and no short-term risks to the community or the environment as a result of this alternative are anticipated. Long-Term Effectiveness and Permanence >o As discussed in MM-2 and MM-4, potential risks from ingestion of groundwater ^ would remain at the site as a result of groundwater contamination that is not actively captured by the extraction system options. o

01 AOP-35-M "° A. 0. Polymer Site Public Review Feasibility Study April 1991

Since human health risks are identified based only on potential future use, restrictions on future groundwater use could be effectively used to manage risks associated with ingestion of contaminated groundwater. Although they are not a permanent solution, groundwater use restrictions should be implemented at the site until the contaminated groundwater at the site is remediated through extraction and treatment. Groundwater monitoring will be performed to assess the progress of aquifer restoration and to provide data for periodic reviews. Reduction of Toxicitv. Mobility or Volume Through Treatment This alternative would actively remove contaminants from the aquifer, and would gradually reduce the toxicity and volume of groundwater contaminants over the extraction and treatment period. If carried to completion, the end products of the oxidation process are carbon dioxide, water, and any other oxidized substances associated with the original organic wastes (e.g., organic sulfides would be oxidized to produce carbon dioxide, water, and sulfate ions). The treated water could require filtration or a carbon polishing step prior to being discharged to the Wallkill River but this is not necessary. No treatment residuals are generated by this process unless carbon filtration is necessary. The quantity of spent carbon utilized depends on actual effluent quantities. Implementabil UY The implementability of groundwater extraction is described in Section 4.4 of this report. The implementability of the treatment system for this alternative is described in Section 4.3 of the report. The implementability of public awareness and education programs, groundwater use restrictions, and groundwater monitoring is described under alternative MM-1, in Section 5.4.1.6 of this report. Cost Costs associated with the UV Oxidation system Include the capital cost of the unit, electricity for operating the ultraviolet light, hydrogen peroxide, and technical service and maintenance of the system. •on Since this 1s a flow-through operation, as opposed to a batch operation, the o level of maintenance and monitoring required to operate the system 1s minimal. o Long-term management of the system would be required to Insure It's continued ^ operating efficiency; however, maintenance could be performed on a full-time M basis. >-LTI•

AOP-35-H 5-53 A. 0. Polymer Site Public Review Feasibility Study April 1991

Treatablllty studies Including bench scale testing are recommended during the remedial design to determine design parameters of the process. Treatablllty testing will also determine whether pre-f1ltrat1on 1s required for efficient operation of the system, and whether filtration or activated carbon polishing are required to achieve effluent discharge limitations. For cost-estimating purposes, a pre-flltration system 1s included 1n the conceptual design but a carbon polishing step 1s assumed not to be required. Costs associated with implementing public awareness/education programs, groundwater use restrictions, and groundwater monitoring are presented under alternative MM-1. For groundwater extraction option A (72 GPM), the groundwater extraction and treatment system is assumed to operate for a period of 7 years. The total present worth cost of this alternative is estimated to be $5,038,000 (5X discount rate) and $4,390,000 (10X discount rate). A summary of the cost estimate is provided on Table 5-11 (A). For groundwater extraction option B (126 GPM), the groundwater extraction and treatment system is assumed to operate for a period of 9 years. The total present worth cost of this alternative is estimated to be $8,474,000 (5X discount rate) and $7,137,000 (10X discount rate). A summary of the cost estimate is provided on Table 5-11 (B). 5.4.5 Summary of Management of Migration Alternative Costs Table 5-12 presents a summary of the total present worth costs at 5X and 10X discount rates for the management of migration alternatives.

5.5 COMPARISON AMONG ALTERNATIVES 5.5.1 Source Control Alternatives 5.5.1.1 Overall Protection of Human Health and Environment There is little direct contact risk associated with subsurface contaminated soils at the former disposal lagoon site. However, because they are susceptible to leaching by Infiltrating precipitation, these soils represent a source of additional groundwater contamination. Source control alternative SC-1, the no action alternative, does not provide protection of human health because contaminants will continue to leach to groundwater and it is estimated that leaching will result in groundwater concentrations that exceed MCLs or MCLGs for 60 years or more. SC-2, the capping alternative, provides protection of human health by minimizing infiltration and reducing leachate generation. However, soil contaminants ^ will remain at present concentrations for an indefinite period of time and o protectIveness will be assured only as long as the Integrity of the cap is maintained. Both SC-3, the soil flushing alternative, and SC-4, the soil 0 o *»-»-M 5-54 ^ V-1 LP TABLE 5-11 (A) COST ESTIMATE SUMMARY ALTERNATIVE MM-5 (A) EXTINCTION AND TREATMENT - OPTION A (72 GPM) UV OXIDATION TREATMENT A. 0. POLYMER FEASIBILITY STUDY

Quantity Capital Annual Present Worth of ITEM Cost 0 t M Annual OtM Costs 5X Discount 10X Discount I. EXTRACTION/DISCHARGE SYSTEM 1. New Extraction Wells 4 Wells $34,100 2. Submersible Pump* 4 Pumps $1,650 $800 $4,600 $3,900 3. Collection/Discharge Piping 800 LF $14,280 4. Electrical Connections/Electric Power Lump Sun $14,250 $2,600 $15,000 $12,700 5. System Controls I imp Sum $7,660 Subtotal: $71,940 $3,400 $19,600 $16,600 II. SITE PREPARATION/TREATMENT BUILDING 1. Construct Treatment Building 5000 SF $300,000 2. Building Lighting/Heating Lunp Sum $3,600 120,800 $17,500 3. Construct Parking/Staging Area Lunp Sum $8,000 Subtotal: $308/000 $3,600 120,800 $17,500 III. WATER TREATMENT SYSTEM 1. Model CW-540 UV Oxidation System and Auxiliary Equipment/Del ivery/Set-up $465,300 2. Multi-Media Pre-Fi Itration Unit $30,000 3. Filter Press (sludge dewatering) $20,000 4. 0 I M Costs (includes Maintenance, maintenance labor, H202, power, sludge disposal t technical support) $342,480 »1, 981, 700 $1,667,300 5. Full-Tine System Operator $50,000 $289,300 $243,400 Subtotal $535,300 $392,480 $2,271,000 $1,910,700 IV. TREATED WATER DISCHARGE 1. NPOES Permit $7,500 2. Weekly Effluent Sampling * $19,500 $112,800 $94,900 Subtotal: $7,500 $19,500 $112,800 $94,900

V. INSTITUTIONAL ACTIONS 1. Public Awareness/Education Program I $25,000 Groundwater Use Restrictions Subtotal: $25,000 $0 $0 VI. LONG TERM MONITORING « REVIEW (30 YEARS) 1. Install additional monitoring well $3,000 2. Semi-annual Grounduater Monitoring *• $17,000 $261,300 $160,300 3. Five- Year Review •»• $20,800 $11,600 Subtotal: $3,000 $17,000 $282,100 $171,900

CONSTRUCTION SUBTOTAL $950,700 $436,000 $2,706,300 $2,211,600

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5-55 Capital OUt HMlth and Safety 1X U $9,507 $27,063 $22,116 Bid Contingency 15X 15X $142,605 (405,945 $331,740 Scop* Contingency 15X 15X $142,605 $405,945 $331,740

CONSTRUCTION TOTAL $1,245,400 S3, 545, 300 $2,897,200

Permitting I Legal «X $49,816 Services During Construction 7X $87,178

TOTAL IMPLEMENTATION COST SI, 382,400

Engineering 1 Design 8X $110,592

TOTAL CAPITAL COSTS $1,493,000

TOTAL PRESENT WORTH $5,038,000 $4,390,000

NOTE: Cost estimate assumes 7-year period of operation for the extraction and treatment system. • Weekly effluent sampling for 7 years. Analysis performed is for VOCs. •• Monitoring Period of 30 Years: 10 monitoring wells sample* semi-annually. Analysis performed is for VOCs. ••• Half of the coat of each 5-year review ($7500) is included in each MM Alternative. Reviews 8 t « 5 yr, 10 yr, 15 yr, 20 yr, 25 yr, and 30 yr.

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5-56 TABLE 5-11 (B) COST ESTIMATE SUMMARY ALTERNATIVE MM-5 (B) EXTRACTION AND TREATMENT - OPTION B (126 GPM) UV OXIDATION TREATMENT A. 0. POLYMER FEASIBILITY STUDY

Quantity Capital Annual Present Worth of ITEM Cost 0 t M Annual 0(M Costs 5X Discount 10X Discount 1. EXTRACTION/DISCHARGE SYSTEM 1. New Extraction Wells 7 Wells $46,700 2. Submersible Pumpa 7 Pumps $2.900 *1,400 $10,000 $8,100 3. Collection/Discharge Piping 10500 LF $18,840 4. Eltctricit Connections/Electric Power Limp Sum SU,475 S4.S70 $32,500 $26,300 5. System Controls Lump SUM $13,405 Subtotal: $96,320 $5,970 $42,500 $34,400 II. SITE PREPARATION/TREATMENT BUILDING 1. Construct Treatment Building 5000 SF $300,000 2. Building Lighting/Heating Lump Sum $3,600 $25,600 $20,700 3. Construct Parking/Staging Area Lump Sum $8,000 Subtotal: $308,000 $3,600 $25,600 $20,700 III. WATER TREATMENT SYSTEM 1. Model CW-540 I Model CW-180 UV System and Auxiliary Equipment/Del ivery/Set-up $682,400 2. Multi-Medie Pre-Filtration Unit $50,000 3. Filter Presa (sludge dewetering) $20,000 4. 0 1 M Costs (includes maintenance, maintenance labor, H202, power, sludge disposal t technical support) $599,300 $4,259,700 $3,451,400 5. Full-Time System Operator $50,000 $355,400 $288,000 Subtotal $752,400 $649,300 $4,615,100 $3,739,400 IV. TREATED WATER DISCHARGE 1. NPOES Pen* it $7,500 2. Weekly Effluent Sampling * $19,500 $138,600 $112.300 Subtotal: $7,500 $19,500 $138,600 $112,300

V. INSTITUTIONAL ACTIONS 1. Public Awareness/Education Program I $25,000 Grounduater Use Restrictions Subtotal: $25,000 $0 $0 VI. LONG TERM MONITORING t REVIEW (30 YEARS) 1. Install additional monitoring well $3,000 2. Semi-annual Grounduater Monitoring •• $17,000 $261,300 $160,300 3. Five-Year Review* *** $20,800 $11,600 Subtotal: $3,000 $17,000 $282,100 $171,900 CONSTRUCTION SUBTOTAL $1,192,200 $695,400 $5,103,900 $4,078,700

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5-57 Capital OiM Hulth and Safety U IX S1 1.922 S5 1,039 S40,787 Bid Contingency 15X 15X S178.830 * 765, 585 »61 1,805 Scop* Contingency 15X 15X t 178, 830 t 765, 585 S61 1,805 CONSTRUCTION TOTAL $1, 561,800 $6,686,100 S5, 343, 100 Permitting 4 Legal 3X S46.8S4 Service* During Cone t ruction sx STB, 090 TOTAL IMPLEMENTATION COST SI, 686,700 Engineering 4 Design 6X S101.202 TOTAL CAPITAL COSTS S1, 787, 900 TOTAL PRESENT WORTH M, 474, 000 $7,131,000

NOTE: Coet estimate assume* 9-year period of operation for the extraction and treatment system. * Weekly effluent sampling for 9 years. Analysis performed is for VOCs. *• Monitoring Period of 30 Tears: 10 Monitoring wells seaples seat-annually. Analysis performed is for VOCs. *** Half of the cost of each 5-year review ($7500) is included in each MM Alternative. Reviews 8 t « 5 yr, 10 yr, 15 yr, 20 yr, 25 yr, and 30 yr.

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00 5-58 TABLE 5-12 COST ESTIMATE SUMMARY NACEMENT OF MIGRATION ALTERNATIVES A. 0. POLYMER FEASIBILITY STUDY

MANAGEMENT OF MIGRATION ALTERNATIVE TOTAL PRESENT WORTH COST TOTAL PRESENT WORTH COST 5% Discount Rate 10X Discount Rate

MM-1 : NO ACTION $385,000 $247,000 MM-2A : BIOLOGICAL/AIR STRIP/CARBON (72 GPM) $4, 248,000 $3,665,000

MM-2B : BIOLOGICAL/AIR STRIP/CARBON (126 GPM) $7,122,000 $5,929,000 MM-4A : PACT (72 GPM) $2,552,000 $2,234,000 MM-4B : PACT (126 GPM) $3,767,000 $3,300,000 MM-5A : UV OXIDATION (72 GPM) $5,038,000 $4,390,000 MM-5B : UV OXIDATION (126 GPM) $8,474,000 $7,131,000

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'<£> 5-59 A. 0. Polymer Site Public Review Feasibility Study April 1991 vapor extraction alternative, protect groundwater and human health by removing contaminants from the soil. Soil flushing, however, must be implemented in conjunction with groundwater extraction and treatment to insure protection of human health. SC-5, soil flushing and soil vapor extraction, provides a high degree of protection because each technology is effective in removing certain contaminants that are not removed as well with the other technology. SC-6, low temperature thermal desorption provides the highest degree of protection because it physically removes and concentrates soil contaminants so that they can be disposed of offsite. Compliance With ARARs Other than chemical specific ARARs, all source control alternatives evaluated in this study are subject to regulation by few ARARs. For alternatives SC-1 through SC-5, the potential exists for soil contaminants to remain in soils at concentrations above NJDEP action levels. There is little justification for leaving contamination in soils under SC-1, because contaminants will leach to groundwater over a period of at least 60 years. Because complex geochemical removal processes are used in SC-3 through SC-5, the exact quantity of contamination removed and the time frame over which this occurs are not possible to predict with precision. However, removal processes accelerate readily occurring natural processes and any residual contaminants that remain after these alternatives have been utilized may not be susceptible to further leaching by natural conditions. SC-6 is expected to remove contaminants of concern to near conventional detection limits. Because they are not subject to RCRA land ban restrictions, treated soils can be disposed of onsite after treatment. Short Term Effectiveness SC-1 through 5 involve moderately invasive activities such as drilling and excavation, however, the major components in each alternative will not disturb the contaminated subsurface soils to any significant degree. Potential risks to workers can be managed easily by procedures outlined 1n site specific Health and Safety Plans. Few short term impacts to human health or the environment are anticipated for these alternatives. Alternative SC-6 Involves the excavation of contaminated subsurface soils. Diligent control of fugitive dust and storm water are required to prevent the spread of contamination from exposed contaminated soils to previously uncontamlnated areas. Volatilization from these soils would be difficult to control so moderate short term impacts could occur. All source control alternatives can achieve remediation objectives within 5 years. Due to the complex geochemical processes employed in SC-3 through SC-5, however, this time period is difficult to estimate precisely. o o

*»-35-" 5-60 A. 0. Polymer Site Public Review Feasibility Study April 1991

Long Term Effectiveness and Permanence SC-1 results in groundwater contamination that exceeds MCLs or MCLGs for the groundwater contaminants of concern for over 60 years. Residual risks for SC-2 stem from the fact that contaminants will be left in place at present concentrations for an indefinite period of time. Diligent maintenance of the cap and long term monitoring are required to manage those risks. Potential residual risks under SC-3 through SC-5 could result from incomplete removal of contaminants resulting in residual contamination that exceed remediation goals or NJDEP action levels. However, for the reasons previously stated, residual contaminants may not be susceptible to further leaching by natural conditions after these alternatives have been employed to their fullest extent. Long term soil and groundwater monitoring are required, however, to insure that residual contaminants do not pose a groundwater threat. Relatively little residual risk should result after implementation of SC-6. Reduction of Toxicitv Mobility and Volume Through Treatment SC-1 reduces the neither the toxicity, volume nor the mobility of the contaminants. SC-2 does not employ any treatment to reduce the mobility, volume or toxicity of soil contaminants, however, the movement of contaminants through the soil would be reduced under SC-2. SC-3 removes contaminants from the soil by actually increasing their mobility and must be done in conjunction with a groundwater extraction and treatment alternative. SC-3 through 5 removes and concentrates contaminants for later disposal or toxicity reduction. SC-5 also includes soil flushing and must be done in conjunction with groundwater extraction and treatment. SC-6 provides the highest degree of removal. SC-1 through 3 results in no treatment residuals. SC-4 and 5 will generate a small amount (approximately 150 gallons) of contaminant condensate and moderate amounts of expended activated carbon from vapor phase treatment. SC-6 results in the largest quantity of residuals, all of which must be removed from the site and treated or disposed of. Implementability SC-1 through 5 each are relatively easy to implement. All use standard construction techniques and materials. SC-4 and 5 use commercially available and tested components. The site it flat and relatively little site preparation should be required. SC-6 if most difficult to implement because of site space constraints and the engineering controls that will be needed to manage fugitive dust or storm water.

o Costs are compared in Section 5.6.

AOP-35-H 5-61 A. 0. Polymer Site Public Review Feasibility Study April 1991

5.5.2 Management of Migration Alternatives Overall Protection of Human Health and Environment MM-1, the no action alternative, provides no Immediate reduction In potential human health risks. Because significant risks are based on the potential future 1ngest1on of groundwater, actual risks will decrease over time as a result of natural attenuation and flushing of groundwater contaminants. Institutional controls can be effective 1n managing the risks during the period required for natural attenuation to occur provided that the Institutional controls are strictly enforced. This time period has been estimated to be approximately 27 years, assuming that source control 1s Implemented. The level of protectIveness provided by extraction and treatment alternatives MM-2, MM-4, and Mm-5 Is primarily a function of the extraction option that 1s selected. Option A, the 4 well option, will extract contaminated groundwater from approximately 50 percent of the area affected by contamination removing all of the groundwater contaminated with the highest concentrations of contaminants of concern. Option B, the 7 well option, will extract groundwater from approximately 80 percent of the plume. Both options will permit some residual contamination in downgradient areas to discharge naturally to the Wall kill River. Compliance with ARARs Each management of migration alternative, Including the extraction and treatment alternatives, will permit groundwater concentrations to exceed MCLs and HCLGs in some portion of the aquifer. In MM-1, these standards may be exceeded until natural restoration proceeds to completion, which is estimated to require approximately 27 years. Active restoration of groundwater to below MCLs or MCLGs in the areas within the capture zones of the extraction systems will be restored in approximately 7 and 9 years for the 4 and 7 well extraction options respectively. Residual contamination that 1s not actively removed will be flushed naturally to the Wall kill River in 9 and 4 years for the 4 and 7 well options, respectively. Both MM-4 and MM-5 will be required to comply with ARARs dealing with the transport and disposal of hazardous waste and ARARs concerning effluent discharge to surface water. MM-2 will be required to comply with these ARARs in addition to ARARs regulating air emissions. Each treatment system can be designed to comply with the substantive requirements of the ARARs. In the event that surface water discharge 1s difficult to implement because of ARAR requirements, discharge to groundwater using recharge basins such as those described in SC-3 could be utilized. o Pumping and groundwater extraction may potentially Impact wetland areas * adjacent to the Wallkill River by reducing water levels in the area. This potential impact can be mitigated by directing treated water to the wetlands.

AOP-35-M 5-Or cZy <,*0 A. 0. Polymer Site Public Review Feasibility Study April 1991

Short Tem Effectiveness The extraction and treatment alternatives involve little disturbance to contaminated subsurface areas, therefore the potential risks to site workers are minor and can be easily managed using procedures outlined in Health and Safety Plan. The potential short term risks to human health and the environment are anticipated to be low. Long Term Effectiveness and Permanence Potential long term risks result from contaminants which are left in the groundwater after Implementation. Under MM-1, the no action alternative, residual risks will decrease from present risk levels to acceptable levels over the period required for natural attenuation which is estimated to be approximately 27 years. Residual risks after implementation of active aquifer restoration will persist for approximately 9 and 4 years for the 4 and 7 well extraction options respectively. Reduction in Toxicltv. Mobility and Volume The no action alternative results in no immediate reduction in toxicity, mobility, or volume (TMV), although concentrations are expected to decrease through natural processes over a long period of time. All extraction and treatment alternatives provide some active reduction of MTV depending on the extraction option that is selected. MM-2 results in the most varied and significant quantities of treatment residuals Including sludge from the biological treatment component and spent carbon from both vapor and liquid phase carbon adsorption. Treatment residuals of MH-4 Include sludge containing spent powdered carbon, removed contaminants and biomass. MM-5, UV oxidation generates the least amount of treatment residuals of the treatment alternatives. Implementabilitv The treatment components of MM-2 are proven effective for all contaminants of concern and should be easiest to Implement because it relies on well understood and readily available commercial components. Both MM-4 and MM-5 rely on Innovative technologies for treatment. TreatabllUy studies are required during the remedial design to determine design parameters of the selected process and to determine the level of effectiveness that can be provided by these technologies. 3* O 13 5.6 SITE REMEDIATION ALTERNATIVES o O In order to formulate a complete site remediation alternative, the selected ^ source control and the selected management of migration alternative must be I-" ACP-35-H _ A. 0. Polymer Site Public Review Feasibility Study April 1991 combined. Six source control alternatives and seven management of migration alternatives were evaluated and costed in the detailed analysis of this section. Six source control and seven management of migration alternatives can be combined to form a total of 42 potential site remediation alternatives. However, some combinations of SC and MM alternatives are not recommended. For example, the soil flushing source control alternatives (SC-3 and SC-5) cannot be combined with the minimal action management of migration alternative (MM- 1). The reason for this 1s that the soil flushing would flush additional contaminants Into the groundwater, which 1s not recommended unless a groundwater collection and treatment system Is in operation. In addition, groundwater extraction and treatment alternatives (MM-2, MM-4, or MM-5) should not be Implemented unless source control 1s also Implemented. The reason for this is that the estimated period of soil leaching (over 60 years) exceeds the groundwater extraction and treatment period (7 to 9 years). After eliminating the above combinations of alternatives, a total of 34 potential site remediation alternatives remain. The cost of a complete site remediation alternative would be the sum of the costs of the selected source control and management of migration alternatives. The total present worth costs (5X and 10X discount rates) of the 34 potential site remediation alternatives are summarized on Tables 5-13 and 5-14. Alternatives using soil flushing Include the same costs for discharging treatment plant effluent to surface water as in the other source control options. This may tend to over estimate the cost of alternatives utilizing source flushing because most, if not all, of the treated groundwater would be reintroduced Into the ground rather than discharged to surface water. The total present worth of the potential cost savings for not discharging to surface water would be $122,200 (1-5X) and $103,300 (1-10%) for the 72 GPM case, and $148,000 (1-5X) and $148,000 (i-lOX) for the 126 GPM case.

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5_64 TABLE 5-13 PRESENT WORTH COST SUMMARY (5 X DISCOUNT RATE) SITE REMEDIATION ALTERNATIVES A. 0. POLYMER SITE FEASIBILITY STUDY

Source Control Alternatives Management of Migration Alternatives SC-1 No Action MM-1 Ho Action SC-2 Capping m-ZA iiotogical/Air Strip/Carbon (72 GPM) SC-3 Soil Flushing MM-28 »iological/Air Strip/Carbon (126 GPM) SC-4 Soil Vapor Extraction MH-44 PACT Tr««tl»ent (72 GPM) SC-5 Soil Flushing/Vapor Extraction HK-4B PACT Treatment (126 GPM) SC-6 Excavation/Thermal Treatment MM-5A UV Oxidation (72 CPM) MM-SB UV Oxidation (126 GPM)

Alternative SC-1 SC-2 SC-3 (a) SC-4 SC-5 (a) SC-6 and Cost $319,000 $135,000 $499,000 $810,000 $1,016,000 $4,518,000 MM-1 $385,000 $704,000 $520,000 X $1,195,000 X *4, TO3, 000 MM-2A $4,248,000 X $4,383,000 $4,747,000 $5,058,000 $5,264,000 $8,766,000 MM- 28 17,132.000 X $7,257.000 $7,621.000 $7,932,000 $8,138,000 $11,640,000 NM-4A $2, 552.000 x $2,687,000 ».05:,OCO $3,362,000 $3,568,000 *7. 070, 000 MM -48 $3,767,000 X $3,902,000 $4,266. OOC $4,577,000 $4,733,000 $8,285,000 MM-5A $5,038,000 X $5,173,000 $5,537,000 $5,848,000 $6,054,000 I*,554,TOO MM-5B $8,241,000 X $8,376,000 $8,740,000 $9,051,000 $9,257,000 $12,759,000

NOTE: Total of 34 site remediation alternatives shown. X - These alternatives cannot be combined. (a) - Also includes costs associated with surface water discharge.

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5-65 TABLE 5-U PRESENT WORTH COST SUMMARY (10 X DISCOUNT RATE) SITE REMEDIATION ALTERNATIVES A. 0. POLYMER SITE FEASIBILITY STUDY

Source Control Alternative* Management of Migration Alternatives SC-1 No Action MM-1 No Action SC-2 Capping MM-2A Biological/Air Strip/Carbon (72 GPM) SC-3 Soil Flushing MM-28 Biological/Air Strip/Carbon (126 GPM) SC-4 Soil Vapor Extraction MM-4A PACT Treatment (72 GPM) SC-5 Soil Flush ing/Vapor Extraction MM-4B PACT Treatment (126 GPM) SC-6 Excavation/Thermal TreatKent NM-5A UV Oxidation (72 GPM) MM-SB UV Oxidation (126 GPM)

Alternative SC-1 SC-2 SC-3 (a) SC-4 SC-5 (a) SC-6 and Coat $194,000 $112,000 $372,000 $686,000 $889,000 $4,508,000 MM-1 $247,000 $441,000 $359,000 X $933,000 X $4,755,000 MM-2A $3,665,000 X $3,777,000 $4,037,000 $4,351,000 $4,554,000 $8,173,000 MM- 28 $5,929,000 X $6,041,000 $6,301,000 $6,615,000 $6,818,000 $10,437,000 MM-4A $2,234,000 X $2,346,000 $2,606,000 $2,920,000 $3,123,000 $6,742.000 MN-4B $3,300,000 X $3,412,000 $3,672,000 $3,986,000 $4,189,000 $7,808,000 NM-5A $4,231,000 X $4,343,000 $4,603,000 $4,917,000 $5,120,000 $8,739,000 MM-5B $6,942,000 X $7,054,000 $7,314,000 $7,628,000 $7,831,000 $11,450,000

NOTE: Total of 34 site remediation alternative* shown. X - These alternatives cannot be combined. (a) - Also includes costs associated with surface water discharge.

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5-66