F'll'J 'J.'t/032.770 i!,P,P, it> 0~ -'II-~ I ;J..¾,5 Aece; 11(:c/. WDNR., O'f/?.1 I01i Ac. h' UY1 : t 'I 7 April23,2004 Ms. Pam Mylotta Wisconsin Department of Natural Resources 2300 North Martin Luther King Jr. Street P.O. Box 12436 Milwaukee, Wisconsin 53212-0436 Re: Request for Source Area Chemical Injection Permit C & D Technologies, Inc. 900 Keefe A venue Milwaukee, Wisconsin 53212-1709 Dear Ms. Mylotta: On behalf of the Johnson Controls Battery Group, Inc. (JCBGI) and C & D Technologies, Inc. (C&D), MWH Americas, Inc. (MWH) has prepared this request for an injection permit for groundwater treatment in the acid unloading area at the above referenced site. The purpose of the permit request is to provide information to the Wisconsin Department of Natural Resources (WDNR) for approval to conduct a pilot study and full-scale injection of sodium persulfate into the acid unloading area for treatment of volatile organic compounds (VOCs) in groundwater. BACKGROUND INFORMATION Soil and groundwater contamination were found to exist on the Facility property exceeding State environmental standards, based on the August 1999 Phase II Environmental Site Assessment (ESA) of the Facility. In May and June 2001, remedial action was completed for the on-site lead, PCB, and VOC impacted soils. A summary of the remedial activities is contained in the February 2002 On­ Site Remedial Actions Construction Completion Report. Approximately 400 tons of VOC­ impacted soil was removed during this investigation. Temporary wells were installed in July 2001 and November 2001 as part of the groundwater VOC characterization investigations documented in the June 2001 and October 2001 Work Plans, respectively. Results of these investigations suggested the potential for offsite migration of VOCs in groundwater. Additional investigations were performed in May and June 2002 as documented in the Groundwater VOC Investigation Report (September 2002). The purpose of these investigations was to determine the extent and magnitude of groundwater VOC contamination and to evaluate the potential for natural attenuation. Based on the results of the groundwater VOC investigation, two areas were identified as sources of VOC contamination, the acid unloading area and the truck dock loading area. The analysis of One Science Court Tel 608 231 4747 Del1ve r, ng Innovative Pro1ects and Solut1ons Worldw1ae P.O. Box 5385 Fax. 608 231 4777 Madison, Wisconsin 53705-::)385 remedial action alternatives for both source areas is discussed in the Remedial Action Options and Design Report (September 2003). Vertical profiling was conducted by using hydraulic probe technology on May 12, 2003 to determine the presence of CVOCs in soils at depth at the truck dock loading area and the acid unloading area. Analytical results for soil samples from DB04 detected no VOC compounds at depths of 20 ft bgs to 30 ft bgs in the acid unloading area. This permit is being prepared for the acid unloading source area for both a pilot study and full-scale injection, as described above. Refer to Drawing Bl2 for location of the acid unloading source area and the projected injection areas. BENCH SCALE STUDY A bench scale test was performed in December 2003 by ORIN Remediation Technologies (ORIN), on soil samples from two different areas in the acid unloading area for treatability testing for chemical injection. The Remedial Action Options and Design Report (September 2003) identified chemical injection using potassium permanganate to be a viable and effective chemical remedial action for remediation of VOC contaminated groundwater in the acid unloading area. Based on results from this study (Appendix A), use of potassium permanganate in the chemical injection was determined to be cost prohibitive, as it must overcome the natural oxidant demand (NOD) as well as the contaminant demand. The NOD is likely from the reduced iron or ferrous iron present in the soils. The potassium permanganate preferentially reacts with the ferrous iron. Further discussion on the chemical reactions involving potassium permanganate and iron is located in Appendix A. Further testing concluded that sodium persulfate with chelated iron would be an effective, economically feasible alternative. The bench scale treatability study is included as Appendix A. INJECTION PERMIT INFORMATION There is no standard permit application apparently available for chemical injection treatment. However, MWH prepared a similar chemical injection treatment permit for the City of Hartford, Former Municipal Landfill (WDNR Facility ID: 00361, WDNR File Ref: 267059100), entitled Request/or Source Area Chemical Injection Permit dated October 24, 2000, which was approved by the WDNR. The City of Hartford permit application was used as a basis for creating this permit application for the C&D facility project site. The following is a description of site activities and information required by the WDNR for the injection permit. • Injection Chemical: Chemical injection treatment will be completed by ORIN. The chemical being used at this project will be catalyzed sodium persulfate. Chelated iron is added to the sodium persulfate, which catalyzes the reaction. Catalyzing the Ms. Pam Mylotta April 23. 2004 Wisconsin Department of Natural Resources Page2 reaction produces sulfate radicals, which are highly reactive and have been shown to reduce levels of chlorinated compounds. The catalyzed sodium persulfate will be mixed with potable water from the City of Milwaukee municipal supply to obtain a slurry of 16% catalyzed sodium persulfate. • Injection Point Design Specifications: The catalyzed sodium persulfate reagent will be installed using a direct push injection delivery system. The injection equipment used by ORIN is housed in a trailer that contains all of the necessary pumps, tanks, and valves to conduct the injection. Once on-site, the treatment chemistry will be mixed to the proper treatment blend and concentration, and injected into the zone of contamination. The direct push injection method consists of using a Geoprobe to insert the rods into the subsurface. Once the desired depth is reached (approximately 20 feet below ground surface for this site), the slurry of catalyzed sodium persulfate reagent and water is injected through the Geoprobe rods as they are slowly raised through the contaminated zone. • Schematic of Injection Array and Rate: The injection area for the pilot study is approximately 20 feet by 20 feet. Based on an evaluation of contamination and physical subsurface characteristics, it was determined that approximately 1300 pounds of catalyzed sodium persulfate is needed for treatment of the targeted plume, through 8 direct injection delivery point locations. Based on the project design, 6.5-foot spacings and a 4-foot radius of influence is expected. Each point location will be injected with approximately 165 pounds (125 gallons of 16% catalyzed sodium persulfate slurry). The estimated target area and proposed injection locations are shown on Drawing Bl2. The injection area for the full-scale injection is approximately 115 feet by 40 feet and will include approximately 92 direct injection delivery point locations. The spacing and footing is assumed to be the same as the pilot scale study. Each point location will be injected with approximately 125 gallons of the catalyzed Sodium Persulfate solution. The following is a description of how the injection area was chosen in response to WDNR's letter "Investigations Results and Remedial Plans", dated April 20, 2004. The remedial objectives for the full scale injection are to: • Reduce source area contamination. • Prevent further off-site migration of CVOC-impacted groundwater to residential areas. • Treat CVOC-impacted groundwater which is affected by the presence of residual CVOCs in source area soils. • Minimize site operational disruptions. • Obtain closure under NR 726 for the Facility within a "reasonable" time frame. Ms. Pam Mylotta April 23, 2004 Wisconsin Department of Natural Resources Page3 The area for the full-scale chemical injection is based on groundwater quality results in the vicinity of the acid unloading area and evidence for migration of VOCs in groundwater. The results of groundwater monitoring are depicted on enclosed Drawing D13 (Total CVOCs Groundwater Isoconcentration Map, from the Groundwater VOC Investigation Report dated September 2002). · The treatment area is bracketed to the north and south, where isoconcentrations are 1 ppb or higher within the groundwater, as depicted by the isocontours. Drawing D13 indicates no migration of CVOCs to private property in the vicinity of temporary wells TW07 and TWOS, so chemical injection is not planned east of these temporary well locations. West of the temporary wells TW07 and TWOS, CVOCs is covered by a concrete cap, which can be considered a performance remedy. The CVOCs in this location have been in place for many years and show no evidence of migration at this time, here is no reason to believe they will begin to migrate at some time in the future. Therefore, this area was eliminated from the treatment area in the remedial design. Abandoned well MW04 and OP24 both lie within the proposed chemical injection zone. OP23 is south of the proposed treatment zone by design and is in line with the remedial objectives for this source area (i.e., no migration exists due east of the source area in this location). • No Temporary Exemption From NR 140 Groundwater Quality Standards: The sodium persulfate solution is a formulation composed of