NCD095458527_19980501_FCX Inc. (Statesville)_FRBCERCLA RD_Remedial Design OU-3-OCR

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MAY 111998
SUPERFUND SECTION
REMEDIAL DESIGN ,voRK PLAN
FOR OPERABLE UNIT THREE (OU3)
FCX-STATESVILLE SUPERFUND SITE
STATESVILLE, NORTH CAROLINA
Prepared for:
EL PASO ENERGY CORPORATION
1001 Louisiana Street
Houston, Texas 77002
Prepared by: ·
ECKENFELDER INC.®
227 French Landing Drive
Nashville, Tennessee 37228
[phone]
May 1998
0313.02
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Letter of Transmittal
Table of Contents
List of Tables
List of Figures
1.0 INTRODUCTION
TABLE OF CONTENTS
1.1 Site Condition and Remedial Design Objectives
1. 1. 1 Soil Design Objectives
1.1.2 Groundwater Design Objectives
1.2 Background
1.2.1 Site Description
1.2.2 Site History
1.2.3 Overview of Existing Data
1.3 Description of OU3 Remediation Technologies
1.3.1 Air Sparging
1.3.2 Soil Vapor Extraction
1.3.3 Monitored Natural Attenuation Overview
1.4 Organization of Remedial Design Work Plan
2.0 PRE-DESIGN INVESTIGATION
2.1 Evaluation of Existing Data
2.2 Installation of Monitoring Wells
2.3 Groundwater Sampling and Analysis
2.3.1 Monitoring Well Sampling and Analysis
2.3.2 Residential Well Sampling and Analysis
2.4 Evaluation Process for Natural Attenuation
2.5 Implications for the Remedy and AS/SVE Pilot Test
2.6 AS/SVE Pilot Test
3.0 REMEDIAL DESIGN
3 .1 Preliminary Design
3.1.1 Data Summary
3.1.2 Design Criteria Report
3.1.3 Outline of Draft Plans and Technical Specifications
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TABLE OF CONTENTS (Continued)
3.1.4 Plan for Satisfying Permitting Requirements
3.1.5 Preliminary Schedule and Project Delivery Strategy
3.2 Intermediate Design
3.3 Pre-Final Design
3.3.1 Design Analysis
3.3.2 Plans and Specifications
3.3.3 Construction Schedule
3.3.4 Cost Estimate
3.4 Final Design
3.5 Remedial Action Work Plan
3.5.1 Construction Management Plan
3.5.2 Construction Quality Assurance Project Plan
3.5.3 Field Sampling Plan
· 3.5.4 Contingency Plan
3.5.5 Project Delivery Strategy
3.5.6 Groundwater and Surface Water Monitoring Plan
3.5.7 Operation and Maintenance Plan
4.0 PROJECT MANAGEMENT PLAN
4.1 Team Organization
4.1.1 ECKENFELDER INC. Project Team
4.1.2 Chemical Analysis Laboratory
4.1.3 Subcontractors
4.2 Data Management
4.2.1 Field Data
4.2.2 Laboratory Data
4.3 Document Control
4.4 Monthly Reporting
4.5 Project Meetings with USEPA
4.6 Community Relations
5.0 PROJECT SCHEDULE
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TABLE OF CONTENTS (Continued)
APPENDICES
Appendix A -Potential Source Areas Identified During RI
Appendix B -Supplemental Information on Natural Attenuation
ATTACHMENTS
Attachment 1 -Pilot Test Work Plan
Attachment 2 -Addendum to the Field Sampling Plan
Attachment 3 -Addendum to the Quality Assurance Project Plan
Attachment 4 . Health and Safety Plan
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Table No.
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2-4
LIST OF TABLES
Monitoring Wells Selected for Groundwater Sampling
Bioparameters for Evaluation of Natural Attenuation
Analytical Parameters and Weighting for Preliminary
Screening of Natural Attenuation
Interpretation of Points Awarded During Screening Process of
Natural Attenuation
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LIST OF FIGURES
Figure No. Title
1-1 Site Location Map
2-1 Monitoring Well Location Map
4-1 Project Organization for Remedial Design of OU3
5-1 Schedule for Remedial Design of OU3
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1.0 INTRODUCTION
This Remedial Design (RD) Work Plan provides a description of the activities and a
schedule for preparing the RD for Operable Unit Three (OU3) of the FCX-Statesville
Superfund Site (the Site) in Iredell County, North Carolina. The OU3 RD addresses
the remediation of the soils and groundwater associated with the property currently
owned and operated by Burlington Industries, Inc. (Burlington). Operable Units
One (OUl) and Two (OU2) address soil and groundwater contamination associated
with the FCX property, which is located to the South of the Burlington property.
The OU3 RD for the primary remedy is being conducted by El Paso Natural Gas
d/b/a El Paso Energy (El Paso). Subsequent phases, if required, will be conducted by
the FCX-Statesville Superfund Site OU3 Respondent Group (Group), which consists
of El Paso and Burlington.
1.1 SITE CONDITION AND REMEDIAL DESIGN OBJECTIVES
Several media and constituents of concern are associated with OU3. On-Site soil
contains inorganics, polynuclear aromatic hydrocarbons (PAHs), and most notably,
volatile organic compounds (VOCs). The groundwater contains primarily VOCs.
Surface water and sediment associated with an intermittent stream originating from
the seep to the north of the Burlington textile plant also contains some inorganic
constituents, polychlorinated biphenyls (PCBs), and VOCs.
The overall objective of the RD is to develop a design for the selected remedy as
defined by the Record of Decision (ROD), consistent with the requirements of the
Consent Decree (CD) and the Statement of Work (SOW). The remedy to be
designed, as defined in the SOW, includes treatment of VOC-containing soil in the
vadose zone with soil vapor extraction (SVE), and treatment of the VOC-containing
groundwater zone with air sparging. Monitored natural attenuation may also assist
in treatment of the VOCs at the Site. The RD will include a pre-design investigation
and a pilot test to provide additional data needed for design development. The
additional data to be obtained is intended to provide information critical to
preparing the design of the selected remedial components. In addition,
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interpretation of the data will help ascertain the site-specific limitations of the
remedial components, help identify modifications (if needed), and aid in appropriate
value engineering.
Section 1.2 of this RD Work Plan provides background information and the ROD
provides a description of the remedy selection process. Section 1.3 provides a
description of the remedial technologies included in the selected remedy for OU3,
including SVE, air sparging, and intrinsic remediation. The design objectives for
soils and groundwater in OU3 are provided below.
1.1.1 Soil Design Objectives
Elevated levels of several constituents, primarily VOCs, are present in the soil of
OU3. No cleanup levels have been established for on-Site impacted soil; however,
the objective of the soil RD is to minimize the potential for vapor transport and
infiltration of VO Cs from the soil into the groundwater using SVE technology.
1.1.2 Groundwater Design Objectives
Groundwater containing VOCs has been identified in the shallow saprolite and
intermediate bedrock aquifers; however, the vertical and horizontal extent of the
VOCs has not been fully determined. Air sparging was selected to treat
groundwater constituents of concern by removing VOC mass and controlling
migration in order to meet Federal Maximum Contaminant Levels (MCLs) or the
North Carolina Groundwater Standards, whichever are more protective. The
objective of the RD for groundwater is to design an air sparging remediation for
impacted groundwater based upon the results of the pre-design investigation and
pilot test described in this RD Work Plan.
Sampling and analysis of the groundwater will be performed to monitor the OU3
Remedial Action (RA) performance as well as to determine the extent and
effectiveness of natural attenuation. Institutional controls, including restrictive
covenants, will be considered in the RD for the affected area. The purpose of these
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institutional controls, if required, would be to prohibit the consumption of impacted
groundwater from drinking water wells associated with the property currently
owned and operated by Burlington.
1.2 BACKGROUND
The background information includes a site description, a site history, and an
overview of existing data.
1.2.1 Site Description
The OU3 Site is located in Iredell County approximately 1.5 miles west of downtown
Statesville, North Carolina near the intersection of Yadkin and Phoenix Streets (see
' Figure 1-1). The Site consists of the soil, groundwater, sediment, and surface water
contamination emanating from the textile plant property currently owned by
Burlington. The property is approximately 15 acres in size. Two large buildings
consisting of a warehouse (approximately 60,000 square feet in size) and the textile
plant building (approximately 275,000 square feet in size) are present on-Site.
Land immediately surrounding the Site is predominantly industrial with a variety of
other uses ranging from commercial to residential with associated school and church
facilities. Farther from the Site, rural land in the Statesville area is used for timber
farming, farming of grain crops, and dairy farming.
The Site is situated in the Inner Piedmont Physiographic Province in western-
central North Carolina and is characterized as gently roJling slopes. The Site lies
within the geologic belt known as the Blue Ridge-Inner Piedmont Belt, which
consists of metamorphic rocks including gneisses and schists. These rocks have
weathered to form a relatively thin overburden of saprolite, which is observed
throughout the Site.
Groundwater at the Site is observed within the saprolite and underlying bedrock.
Saprolite forms the uppermost hydrogeol06'1C unit. Groundwater occurs within the
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FIGURE 1-1
SITE LOCATION MAP
FCX-STATESY1LLE SUPERFUND SITE, OU3
STATESVILLE, NORTH CAROLINA
5/98
k • N0shville, Tetv1essee
Moh•oh, New Jer.iey ECKENFELDER rnc.•
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pore spaces of the saprolite under water table conditions. Groundwater within the
fractured bedrock unit occurs under unconfined or semi-confined conditions. Site
information indicates that the two units are in hydraulic communication.
Groundwater gradients observed on-Site indicate that groundwater in the saprolite
and bedrock appears to be flowing both to the north and to the south from the textile
plant.
1.2.2 Site History
A textile plant was constructed at the OU3 Site in 1927. From 1955 to 1977, the
textile plant was operated by Beaunit Mills, later known as Beaunit Corporation
(Beaunit). In 1967, Beaunit became a subsidiary of El Paso. In April 1977, Beaunit
sold substantially all of its assets, including the plant, to Beaunit II, Inc. As a part
of that transaction, Beaunit changed its name to BEM Holding Corporation (BEM),
and Beaunit II, Inc. changed its name to the Beaunit Corporation. In July 1978, the
textile plant was sold by the Beaunit Corporation (formerly Beaunit II, Inc.) to
Beaunit Fabrics Corporation (Beaunit Fabrics). In 1981, Burlington purchased
certain assets, including the textile plant, from Beaunit Fabrics. Burlington
presently operates the textile plant.
In June 1993, the United States Environmental Protection Agency (USEPA)
Region IV signed an Administrative Order on Consent for OU3 with Burlington, as
well as the former property owner, El Paso. The Final ROD for OU3 was issued by
USEPA Region IV in September 1996. The CD for OU3 was lodged on December 18,
1997, and became final on April 1, 1998. [The USEPA issued an Explanation of
Significant Difference (ESD) for OU3 on __ .]
1.2.3 Overview of Existing Data
Soil Sampling Data. The Remedial Investigation (RI) for OU3 was conducted in
three phases ("Final Remedial Investigation Report, FCX-Statesville Superfund Site
Operable Unit 3, Statesville, North Carolina," July 23, 1996, by Aquaterra, Inc.).
Eleven potential source areas were evaluated as part of the RI and are illustrated in
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Appendix A. In most cases, these source areas represent general areas of concern
and sufficient data do not exist to identify specific sources of releases. The 11
potential source areas are discussed further in the RI and include:
Former Rail Spur Line and Machine Shops (Rail Spur Area)
Former Dry Cleaning Machine and Truck Offloading Area (Dry Cleaning
Area)
Mop Pit (Mop Pit Area)
Fuel Oil Underground Storage Tanks (Tank Area)
Pollution Control Unit 2 and Existing Maintenance Shop Area (PCU 2
Area)
Pollution Control Unit 1 (PCU 1 Area)
Southern Railroad Line (Railroad Line)
Storm Drains and Sanitary Sewers (Storm Drain Area)
Other Industrial Facilities in the Area (Other Industrial Facilities)
FCX
Industrial Facilities to the West
Transmission Repair Facility
As a result of the RI, a total of 13 VOC compounds were detected in the 145 soil
samples that were analyzed for VOCs. The distribution of the VOCs
1,2-dichloroethene (DCE) (total), ethylbenzene, tetrachloroethene (PCE), toluene,
trichloroethene (TCE), and xylenes are thought to be representative of the
distribution of VO Cs in soils at the facility.
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A total of 26 semi-volatile organic compounds (SVOCs) (primarily PAHs) were
detected in the 125 soil samples analyzed for SVOCs.
Fifteen soil samples were analyzed for pesticide compounds. The pesticide 4,4-DDT
was detected at the Refuse Piles, at the southern boundary of the PCU 1 Area, and
along the Railroad Line. The 4,4-DDT is not considered to be Site-related and was
only detected at the southern boundary of the textile plant and off-Site to the north
of the property. The PCB Aroclor 1254 was detected in a single location at the Mop
Pit Area and PCU 2 Area.
Fifteen soil samples were analyzed for inorganic constituents. The inorganic
constituents with maximum concentrations exceeding twice the background
concentration included aluminum, arsenic, barium, calcium, cobalt, lead,
magnesium, manganese, mercury, potassium, and zinc. Inorganic concentrations
were highest at the sewer line west of the textile plant, at the underground storage
tanks (USTs), at PCU 1, and near the Mop Pit.
Groundwater Sampling Data. A total of 32 VOCs were identified in
114 groundwater samples collected from 36 shallow wells, 6 Geoprobe locations, and
32 Hydrocone locations. The VOCs most commonly identif.ed in the groundwater
included 1, 1-dichloroethane (DCA), 1, 1-DCE, cis-1,2-DCE, PCE, toluene,
1, 1, 1-trichloroethane (TCA), TCE, and vinyl chloride.
Five SVOCs were identified in 23 samples from 19 shallow wells. Four SVOCs were
identified in 14 samples from 12 intermediate depth wells. Nine pesticide
compounds were identified in 14 samples from 11 shallow wells. One pesticide
compound (heptachor epoxide) was identified in samples from 3 intermediate depth
wells.
A total of 23 VOCs, including carbon tetrachloride, chloroform, 1,1-DCA, cis-1,2-
DCE, 1,1-DCE, PCE, toluene, 1,1,1-TCA, and TCE, were identified in 43 samples
collected from 20 intermediate-depth wells.
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A number of inorganic constituents in the groundwater were identified which
exceeded twice the background metals concentrations. These inorganic constituents
were aluminum, arsenic, barium, calcium, chromium, cobalt, copper, iron, lead,
magnesium, mercury, nickel, potassium, selenium, sodium, vanadium, and zinc.
The elevated levels of inorganic constituents in the groundwater during the OU3 RI
may be indicative of suspended solids rather than dissolved inorganic constituents.
Surface Water and Sediment Sampling Data. Fourteen surface water samples
were collected from six stations representing a seep and surface water drainage
north of the Site. A total of 13 different VOCs were identified in the 14 samples.
These VOCs include acetone, chloroform, 1,1-DCA, 1,2-DCA, 1,1-DCE, cis-1,2-DCE,
trans-1,2-DCE, 1,2-dichloropropane, methylene chloride, PCE, TCE, toluene, and
vinyl chloride. Five surface water samples were analyzed for inorganic constituents.
The inorganic constituents that exceeded twice the background concentrations for
surface water included barium, calcium, chromium, cobalt, iron, magnesium,
manganese, nickel, potassium, sodium, vanadium, and zinc.
The VOCs 1,2-DCE (total), 1,2-dichloropropane, TCE, and vinyl chloride were
detected in the sediment sample collected from the seep area. In addition, the
compounds methylene chloride and toluene were also detected in the sediment
collected at the pond. There were no VOCs detected in sediment samples taken at
the intermittent stream north of the seep and at the drainage area northwest of the
Site.
There were no SVOCs detected in the sediment samples. However, of the five
sediment samples analyzed, PCB Aroclor 1254 was detected at 350 µg/kg in SED-1
collected where the stream enters the pond. The PCB Aroclor 1254 was also
detected in the SED-1 duplicate sample at 220 µg/kg and in SED-3 collected from the
northwest drainage area at 37 µg/kg. The pesticide 4,4-DDT was detected in SED-2
at 2.1 µg/kg.
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The inorganic constituents identified in each of the five sediment samples included
aluminum, arsenic, barium, beryllium, calcium, chromium, cobalt, copper, iron, lead,
magnesium, manganese, nickel, potassium, sodium, vanadium, and zinc. Calcium
and zinc were the only inorganic constituents which exceeded twice the soil
background concentrations.
1.3 DESCRIPTION OF OU3 REMEDIATION TECHNOLOGIES
Various technologies were reviewed in the ROD for remediation of OU3 including air
sparging, SVE, and groundwater extraction and treatment. The remediation
technologies for OU3 selected by the ROD include air sparging, SVE, and monitored
natural attenuation.
1.3.1 Air Sparging
Air sparg:mg introduces air into aquifers to remove VOCs. This is accomplished
through injection of air under pressure through small diameter wells that are
screened below the contaminated interval and/or near the base of the aquifer. The
injected air moves radially outward and upwards from the well screen towards the
groundwater surface in discrete channels. The VOCs are stripped from the aqueous
phase into the gas phase. The introduction of air necessarily introduces oxygen into
groundwater. This increases the oxidation/reduction potential (Eh) of the
groundwater and promotes aerobic degradation of aerobically degradable compounds
such as benzene and toluene. Added oxygen can also promote cometabolism of some
chlorinated solvents provided one of several compounds (e.g., toluene, methane, etc.)
is also present. At the same time, the addition of oxygen can interfere with the
reductive dechlorination (natural attenuation) of chlorinated solvents. Sparging can
be performed using nitrogen rather than air if anaerobic conditions need to be
maintained.
Air sparg:mg is most effective when operated in a pulse mode (air injection in
individual wells operated on an of£'on cycle). Wben air flow is initiated, air moves
through the soils opening discrete channels. Wben the air flow is interrupted, the
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air channels fill with water. This movement of water in and out of channels, as well
as the mounding that occurs when air flow is initiated, serves to mix the
groundwater and enhance the removal ofVOes.
The effectiveness of air spargmg 1s dependent upon many factors including the
Henry's law constant of the specific constituents as well as both the initial
concentration of constituents and their respective cleanup levels. Of particular
importance are the details of the site hydrogeology. Small differences in soil
permeability can significantly affect the flow paths of air within the saturated zone.
As a result, individual wells may remediate relatively small or large areas based on
differences in lithology that are not necessarily evident from well logs. Pilot tests, as
described in Attachment 1, are typically required to determine the area of influence
of individual wells. There can be large variability across even a small site, which
will not necessarily be identified by the pilot test.
For the reasons discussed in Section 1.3.2, SVE is frequently used in conjunction
with air sparging as per the selected remedy for OU3.
1.3.2 Soil Vapor Extraction
Soil vapor extraction uses the induced movement of air through the vadose zone to
remove VOes. In the most commonly practiced method of application, a blower (e.g.,
a vacuum source) is attached to an extraction well which is screened across the
impacted interval of the vadose zone. The blower creates a reduced pressure within
the well bore and induces air flow from the surrounding soils towards the well. As
the air moves through the impacted soils, the portion of the VO es that is present in
the vapor phase flows towards the well and is removed through the well along with
the extracted air. The voes associated with the soils and present as free phase
liquids (either between the soil particles or present as a layer on top of the
groundwater) will gradually partition into the surrounding soil gas and will be
extracted with the recovered air.
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SVE has been used widely at eEReLA, ReRA, DOD, DOE, and state mandated
sites for the remediation of chlorinated solvents, non-chlorinated solvents, and for
lighter petroleum hydrocarbon blends. SVE was developed principally to remove
voes. Its applicability to SVOes and non-volatile compounds is limited to the
extent that these compounds are biodegradable by aerobic microorganisms.
SVE is an attractive technology because it is applied in situ, reqmres minimal
disruption to normal site activities, and can be implemented beneath buildings,
roadways, parking lots, and other man-made structures. Furthermore, the process
removes contaminant mass with minimal potential to spread the contamination. In
some cases SVE can also serve to prevent migration of vapors into basements and
utility trenches. Many voes are relatively easily leached from the unsaturated
zone to the saturated zone. SVE contributes to the long-term improvement of
groundwater quality by removing voe mass from the unsaturated zone.
As a result of having been used at a large number of sites under a wide variety of
conditions, design protocols for SVE are available and there are numerous
equipment vendors who can provide components or pre-assembled systems.
Installation and operation of SVE systems are relatively straightforward making the
technology cost-effective for many site conditions especially for very large soil
treatment areas.
SVE has been implemented as part of multicomponent remedial systems in
conjunction with air sparging and monitored natural attenuation as well as other
technologies. SVE is commonly an integral part of air sparging systems. The SVE
component can remove existing mass from the vadose zone as well as capturing
voes stripped from the saturater! zone as a result of air sparging.
1.3.3 Monitored Natural Attenuation Overview
Natural processes that reduce the mass and concentrations of the chlorinated
organics present in OU3 have been observed in Site groundwater samples. For this
reason, monitored natural attenuation is being evaluated to determine the extent to
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which it may complement the active remediation technologies of SVE and air
sparging being evaluated at the Site. Monitored natural attenuation, also referred
to as intrinsic remediation, relies on the natural restorative capacity of aquifers to
control migration and reduce the masses of constituents of concern. The
mechanisms that contribute to natural attenuation include adsorption, diffusion,
dispersion, volatilization, and degradation.
The hydraulic conductivity, gradient, and porosity of the aquifer determine the rate
of groundwater flow. As the groundwater moves through the aquifer, mixing of
affected groundwater with clean groundwater occurs as a result of dispersion and, to
a lesser extent, diffusion. These processes result in somewhat lower constituent
concentrations and marginally broader plumes. As the constituents move through
the aquifer they adsorb to the aquifer materials, especially when appreciable organic
content is present, and subsequently desorb (dissolve). The adsorption/desorption
process retards the rate at which constituents move through the aquifer. As a
result, constituent migration is slower than otherwise would occur as a consequence
of groundwater flow through the aquifer. The processes of diffusion, dispersion, and
retardation moderate constituent concentrations but do not cause a reduction in
constituent mass. Chemical and biological degradation reactions reduce both mass
and concentrations of the degradable organic constituents. For chlorinated aliphatic
hydrocarbons (e.g., PCE and TCE), the process of degradation in groundwater occurs
largely through anaerobic (in the absence of oxygen) biodegradation. The specific
process is referred to as reductive dechlorination. In this process, chlorine atoms of
chlorinated ethenes are sequentially replaced with hydrogen atoms as shown below.
PCE ➔ TCE ➔ DCE ➔ Vinyl Chloride ➔ Ethene
Ethene, vinyl chloride and DCE can also be biodegraded aerobically, ultimately
yielding chloride ions, carbon dioxide, and water.
The reductive dechlorination process requires the presence of other degradable
organic compounds and species referred to as electron acceptors, and appropriate
geochemical conditions. According to the protocol, these parameters, as well as the
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presence and distribution of the chlorinated solvents and degradation products, should be measured from appropriate monitoring wells and interpreted as part of the natural attenuation evaluation. A preliminary "Technical Protocol for Natural Attenuation of Chlorinated Aliphatic Hydrocarbons in Ground Water" is under development by the U.S. Air Force Center for Environmental Excellence (AFCEE) and the USEPA. USEPA Region 4 has incorporated that document into the recently issued "Draft Region 4 Approach to Natural Attenuation of Chlorinated Solvents." Both of the documents provide useful guidance to evaluate specific sites for the potential for monitored natural attenuation to be incorporated into the Site remedy. Another USEPA document, "Draft Interim Final OSWER Monitored Natural Attenuation Policy," clarifies USEPA's policy regarding the use of "monitored natural attenuation" for the remediation of contaminated soil and groundwater. The AFCEE and OSWER documents are reproduced as part of Appendix B.
It is necessary to evaluate the extent to which the combined effects of the several natural attenuation processes are able to limit constituent migration and reduce constituent masses. This is accomplished through the use of fate and transport models such as BIOSCREEN.
If monitored natural attenuation is selected as a component of the Site remedy, long term monitoring of Site contaminants and natural attenuation parameters will be required. The primary objective of long term monitoring is to observe whether the natural attenuation processes along with any active remediation are serving to reduce or limit expansion of the plume.
A more thorough description of the mechanisms that contribute to natural attenuation of chlorinated ethenes such as those present at the Site is presented in Appendix B. The evaluation process for natural attenuation is discussed in Section 2.4.
1.4 ORGANIZATION OF REMEDIAL DESIGN WORK PLAN
The contents of this RD Work Plan are organized as follows:
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Section 2.0 -Pre-Design Investigation. Tasks to be performed in order
to provide data necessary to prepare the RD. Activities include installation
of additional monitoring wells, sampling and analysis of groundwater from
monitoring wells and from residential drinking water wells, and an air
sparging and SVE (AS/SVE) pilot test.
Section 3.0 -Remedial Design. Components of Preliminary,
Intermediate, and Pre-Final/Final RDs and the RA Work Plan.
Section 4.0 -Project Management Plan. Project management
including team organization, data management, document control, monthly
reporting, meetings, and community relations.
Section 5.0 -Project Schedule. Proposed schedule for the OU3 RD
activities.
Appendix A-Potential Source Areas Identified during RI
Appendix B -Supplemental Information on Natural Attenuation
Attachment 1 -Pilot Test Work Plan. Proposed AS/SVE Pilot Test to
collect data to support the RD.
Attachment 2 -Addendum to the Field Sampling Plan (FSP)
Attachment 3 -Addendum to the Quality Assurance Project Plan
(QAPP)
Attachment 4 -Health and Safety Plan (HASP)
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2.0 PRE-DESIGN INVESTIGATION
The pre-design investigation will build upon the existing data obtained during past
inves1igations. The pre-design investigation includes installation of monitoring
wells, groundwater sampling and analysis, an evaluation of the extent of natural
attent1ation at the Site, and an AS/SVE pilot test.
2.1 EVALUATION OF EXISTING DATA
A revi"w of the existing groundwater quality data indicates that the horizontal and
vertical extent of constituents of concern at the Site requires further definition.
Monitoring wells W-20s and W-20i represent the further-most down-gradient
monitoring points associated with the northern groundwater plume. These wells
exhibit levels of VOCs that are above the groundwater preliminary remediation
goals (PRGs). As a result, further down-graclient definition of the northern
groundwater plume is required. The vertical extent of constituents of concern has'
not be defined at this location. As a result, further vertical definition is also
required at monitoring wells W-20s and W-20i.
In order to evaluate natural attenuation, additional data related to the Site
geochemistry and constituents of concern are required. The additional data will
provide information to evaluate whether various biological processes are occurring
and also provide an indication of whether conditions are favorable for reductive
dechlorination. The specific parameters and the wells from which samples will be
collected are discussed in Section 2.2 and Section 2.3
2.2 INSTALLATION OF MONITORING WELLS
Additional saprolite and bedrock monitoring wells will be required to characterize
the hori20ntal and vertical extent of the constituents of concern in the OU3
groundwater. One well couplet, W-3ls and W-3li (see Figure 2-1) will be installed
to further delineate the down-graclient extent of the northern groundwater plumes.
The well couplet will consist of a monitoring well screened within the saprolite and a
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Proposed Intermediate Monitoring Well Location
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Deep Monitoring Well Location
0313
FIGURE 2-1
MONITORING
LOCATION
WELL
MAP
FCX-STATESVILLE SUPERFUND SITE. OU3
STATESVltLE, NORTH CAROLINA
5/98
~-a
ECKENFELDER me.• NostMlle, T enneszee
Mahwah, ~ Jer--,
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monitoring well screened within the underlying bedrock unit. To further evaluate
the vertical extent of the groundwater plume, monitoring well W-20d will be added
to the existing monitoring well couplet W-20s and W-20i. The wells will be installed
according to the procedure in the document, "Field Sampling Plan, FCX-Statesville
Operable Unit 3, Iredell County, North Carolina," prepared by Aquaterra, Inc., and
dated February, 1994. This document will be referred to as the Aquaterra FSP.
A review of the groundwater quality data indicates that the groundwater plume
within the saprolite is migrating horizontally, and may be progressing downward as
the plume migrates off-Site to the north. As a result, the down-gradient saprolite
monitoring well W-3ls will be screened near the base of the saprolite aquifer.
Monitoring well W-3li will be installed within the underlying bedrock unit to
evaluate the possible down-gradient extent of the groundwater plume. The boring
will be advanced into the bedrock to a maxim um depth of approximately 50 feet. As
the boring is advanced, packer tests will be conducted on five-foot intervals to
evaluate bedrock permeability. The screening interval will target higher permeable
zones. If the selected screening interval is selected above the target depth of the
boring, the boring will be backfilled with bentonite to the desired screening depth.
The procedure for interval packer testing is included in Attachment 2, the
Addendum to the FSP.
Monitoring well W-20d will be installed within the underlying bedrock to evaluate
the vertical extent of the constituent migration. Initially, this boring will be
advanced to depth of approximately 94 feet (total depth of W-20i) and six-inch
surface casing will be installed. As the boring is advanced past 94 feet, packer tests
will be conducted on five-foot intervals to develop a vertical permeability profile; and
groundwater samples will be collected on 25-foot intervals through the packers and
analyzed for VOCs (24-hour turnaround). This process will be continued until VOC
concentrations fall below the site PRGs. The monitoring well will then be screened
within the highest permeable zone within the 25-foot interval. The groundwater
samples will be collected according to the Aquaterra FSP; analysis of the samples
will be according to Attachment 3, the Addendum to the QAPP.
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2.3 GROUNDWATER SAMPLING AND ANALYSIS
The on-Site and off-Site sampling will be performed to further delineate the
horizontal and vertical. extent of constituents of concern, to evaluate metals
concentrations,. and measure biodegradation parameters. Additionally potable
water from residential groundwater drinking wells located down-gradient of the site
will also be sampled in order to establish a broader database of groundwater quality
samples.
2.3.1 Monitoring Well Sampling and Analysis
The three newly installed wells (W-20d, W-3la, and W-3li) will be sampled to assess
the potential down-gradient and vertical extent of the groundwater plume (see
Figure 2-1). As specified in the ROD and ESD, groundwater samples will be
analyzed for VOCs, pesticides, and metals. The sampling will be performed
according to the procedure in Attachment 2, the Addendum to the FSP; the analysis
will be performed according to Attachment 3, the Addendum to the QAPP.
Metal concentrations were observed at greater than twice the background levels in
data collected during the RI. Historical data and soils analysis indicated that
significant sources of metals have not been associated with the Site. As a result a
select number of monitoring wells were sampled for total and filtered metals
analysis. In all cases, metals concentration drop significantly in the filtered sample.
These results from the RI strongly supported the conclusion that metals at the Site
exist as suspended solids or colloids due to sampling technique and are not
considered to be associated with Site activities. Filtered groundwater results are
generally not accepted by the USEPA. Therefore, to confirm this conclusion, the
selected wells previously analyzed as filtered samples, will be re-sampled using a
slow purge technique. Slow purge techniques have been accepted by the USEPA
and allows for an unfiltered sample to be collected with significant reductions in
suspended solids. The slow purge method involves purging the wells at a rate of less
than l liter per minute. Six monitoring wells will be sampled, including background
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well W-lls, to evaluate metals concentrations in groundwater (see Figure 2-1).
Table 2-1 lists the selected wells to be sampled and the parameters that the samples
will be analyzed for. Groundwater samples from these wells will be collected
according to the Aquaterra FSP and analyzed for metals according to Attachment 3,
the Addendum to the QAPP.
Natural attenuation is being evaluated to address the constituents of concern in
groundwater. The necessary bioparameters (also called biodegradation parameters)
that will be used to evaluate a site for reductive dechlorination are presented in
Table 2-2. The analysis will include a combination of field measurements and
laboratory analyses. Dissolved oxygen (DO), carbon dioxide, iron (II),
manganese (II), and sulfide will be measured in the field because of the sensitivity of
the analysis to atmospheric exposure. In addition, the field measurements will
include traditional field parameters, i.e., conductivity, oxidation-reduction potential
(ORP), pH, and temperature.
These natural attenuation parameters will be measured from monitoring wells
located within the plume and outside the plume. The wells currently identified for
sampling and analysis for natural attenuation parameters are listed in Table 2-1.
The locations of monitoring wells to be sampled for the natural attenuation
evaluation are presented on Figure 2-1. The Aquaterra FSP contains the procedure
for collection of these groundwater samples; Attachment 3, the Addendum to the
QAPP, presents field and laboratory analytical methods for sample analysis.
Since startup of the OUl groundwater extraction system is scheduled for May 1998,
it was necessary to collect and analyze a portion of the aforementioned monitoring
well samples in parallel with preparation of this RD Work Plan for OU3. This
sampling effort was intended to take advantage of the opportunity to obtain baseline
data prior to the initiation of the operation of OUL The baseline samples that were
collected and analyzed included groundwater samples from the existing wells listed
in Table 2-1. The baseline sampling plan (letters to Mr. McKenzie Mallary of
USEPA Region IV from Mr. Kenton H. Oma ofECKENFELDER INC. dated April 17
and 28, 1998) was approved by the USEPA.
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TABLE 2-1
MONITORING WELLS SELECTED FOR GROUNDWATER SAMPLING
RD WORK PLAN FOR OU3
FCX-STATESVILLE SUPERFUND SITE
Groundwater Sampling Parameters"
Monitoring Well Plume Definitionh Metals' Natural Attenuationd
Existing Wells:
W-5s
W-6s
W-9s
W-16s
W-16i
W-17s
W-lls'
W-5i
W-lOi'
W-12i'
W-12s'
W-18s
W-19s
W-20s
W-20i
W-22s
W-22i
W-24s
W-28i
W-29i
W-30i
New Wells:
W-20d
W-3ls
W-3li
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
•The analytical methods for the analyses of groundwater samples are given in the Addendum
to the QAPP.
"These parameters are the Target Compound List (TCL) VOCs and pesticides and the Target
Analyte List (TAL) metals.
0These parameters are TAL metals.
"These parameters are given in Table 2-1 of the Addendum to the QAPP.
"Metals evaluation background well.
'Natural attenuation background well.
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TABLE 2-2
BIOPARAMETERS FOR EVALUATION OF NATURAL ATTENUATION
RD WORK PLAN FOR OU3
FCX-STATESVILLE SUPERFUND SITE
Electron Acceptors and By-Products
Dissolved Oxygen (DO)•
Nitrate/Nitrite
Manganese (total)
Manganese (II)•
Iron (total)
Iron (II)•
Other Degradation Parametersh
voes
Ethene/Ethane
Volatile Fatty Acids
Nutrients
Dissolved Total Organic Carbon (TOC)
Geochemical Parameters
pH•
Oxidation-Reduction Potential (ORP)•
°Field measurements.
Sulfate
Sulfide•
Alkalinity (carbonate/bicarbonate)
Carbon Dioxide•
Methane
Chloride
Phosphate (total)
Total Kjeldahl Nitrogen (TKN)
Ammonium Nitrogen
Nitrate/Nitrite
Temperature11
Conductivity•
bJncludes electron donors, nutrients, and degradation byproducts.
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2.3.2 Residential Drinking Water Well Sampling and Analysis
The ROD indicates that in order the establish a broader database of groundwater
quality and, if necessary, protect private well users living down-gradient from the
Site, groundwater samples wiH be collected and analyzed prior to implementation of
the RA.
A survey of residential drinking water wells was conducted during the RI. The
survey identified no residential drinking water wells within a radius of 0.5 miles
from the Site, however; residential drinking water wells were identified within
3 miles of the Site.
The closest down-gradient residential drinking water wells that are within the same
drainage basin as the Site are located to the south along Buffalo Shoals and
Slingshot Street (see Figure 2 of the RI). The two closest wells from this area will be
sampled. As specified in the ROD and ESD, the groundwater samples from these
wells will be analyzed for VOCs, pesticides, and metals (plume definition
parameters). Sample collection will be according to Attachment 2, the Addendum to
the FSP; sample analysis will be according to Attachment 3, the Addendum to the
QAPP.
2.4 EVALUATION PROCESS FOR NATURAL ATTENUATION
The evaluation of natural attenuation consists of four components that attempt to
quantify the contributions from biodegradation and physical processes. The
evaluation process will be applied to what might be considered four plumes. These
consist of the upper or unconsolidated groundwater to the north and to the south of
the groundwater divide, and the lower or bedrock aquifer to the north and to the
south of the groundwater divide. The four plumes will each be evaluated using the
four evaluation components, which are summarized in the following discussion.
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1. Groundwater Quality Data. These data include the concentrations and
distribution of the parent compound and its degradation products. The
presence of degradation products provides direct evidence of
biodegradation. The distribution of the parent compound and degradation
products provides semiquantitative information regarding the degree to
which biodegradation contributes to limiting constituent migration.
Groundwater quality data collected over time may also demonstrate that
the plume has reached a steady state condition.
2. Bioparameter Data. These data include results from measurements of
groundwater conditions that affect biodegradation and that provides
indirect evidence of biodegradation of the constituents of interest. This
includes electron acceptors, electron donors, pH, and oxidation-reduction
potential. A qualitative review of these data may provide evidence of
conditions that are consistent with ongoing biodegradation.
3. Numerical Ranking. The groundwater quality and bioparameter data
are used to assign ranking points using the preliminary protocol developed
by USEPA and AFCEE. The ranking provides a numerical comparison to
other sites where reductive dechlorination has been evaluated. A high
ranking means strong evidence for biodegradation of chlorinated organics.
A low ranking means inadequate evidence for biodegradation of chlorinated
organics.
4. Fate and Transport Modeling. This is used to simulate past, current
and future concentrations of the parent compound along the plume. The
modeling quantifies (approximately) the contribution from natural
attenuation including biodegradation and provides an indication of how
groundwater constituent concentrations within the plume will change over
time.
The groundwater quality data from previous investigations and from the pre-design
investigation described in this RD Work Plan will be evaluated to identify the
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presence and relative concentrations of constituents of concern and daughter
products including in particular PCE. Trends in concentrations over time and along
the groundwater flow path will be evaluated to provide a semi-quantitative
understanding of the extent to which reductive dechlorination is limiting the
migration of groundwater constituents in the down-gradient direction.
The bioparameter data will be organized in tabular form to illustrate for each
bioparameter the differences in values between samples of groundwater obtained
from within and from outside of the plume. The differences in the values obtained
from within and outside of the plume will be evaluated to determine whether
reductive dechlorination is occurring in the aquifer, which electron acceptors are
playing a significant part in the process, and whether conditions across the aquifer
are favorable for natural attenuation.
This qualitative evaluation will be augmented by application of the ranking system
described in the preliminary protocol developed by the USEPA and AFCEE. Values
for the parameters listed in Table 2-3 generated from field and laboratory
measurements will be used to assign ranking points. The points will be added and
the total score will be compared to the classification table in the protocol (Table 2-4).
The groundwater quality data, the established hydrogeological properties (hydraulic
conductivity, gradient, and estimated porosity), calculated retardation coefficients,
plume dimensions, and published biodegradation rates under natural attenuation
conditions will be used in the fate and transport model, BIOSCREEN. The model
will be calibrated using the existing data to provide a reasonable fit with the
distribution of PCE along the flow path.
The calibrated model will be used to simulate future concentrations along the flow
path with emphasis placed on groundwater quality downgradient of the Site.
Simulations will be conducted for future periods of five, ten, and twenty-five years
from the time of sampling.
F: \DAT A '-11roj\ o:J 1 3. 02\JI02. doc 2-7
---
Analyte
Oxygen3
Oxygen a
Nitrate3
Iron (Ii)'
Sulfa tea
Sulfide•
Methane3
:rviethanea
fl.1ethanea
-
Oxidation reduction
potential a
DOC
Temperaturea
Carbon dioxide
Alkalinity
Chloridea
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TABLE 2-3
ANALYTICAL PARAMETERS AND WEIGHTING
FOR PRELIMINARY SCREENING OF NATURAL ATTENUATION
Concentration in Most
Contaminated Zone
< 0.5 mg/L
> 1 mg/L
< 1 mg/L
> 1 mg/L
< 20 mg/L
> 1 mg/L
> 0.1 mg/L
>1 mg/L
< 1 mg/L
< 50 m V against Ag/AgCl
<-100 mV
5 <pH< 9
> 20 mg/L
> 20°c
> 2 x background
> 2 x background
> 2 x background
Interpretation
Tolerated, suppresses reductive dechlorination at higher concentrations
Vinyl chloride may be oxidized aerobically, but reductive dechlorination will not
occur
May compete with reductive pathway at higher concentrations
Reductive pathway possible
May compete with reductive pathway at higher concentrations
Reductive pathway possible
illtirnate reductive daughter product
Vinyl chloride accumulates
Vinyl chloride oxidizes
Reductive pathway possible
Reductive pathway possible
Tolerated range for reductive pathway
Carbon and energy source; drives dechlorination; can be natural or anthropogenic
At T > 20°C, biochemical process is accelerated
Ultimate oxidative daughter product
Results from interaction of carbon dioxide with aquifer minerals
Daughter product of organic chlorine; compare chloride in plume to background
conditions
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Points
Awarded
3
-3
2
3
2
3
2
3
1
2
2
1
1
1
2
Page I of2
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_,,------
--
Analyte
Hydrogen
Hydrogen
iiii
Volatile fatty acids
BTEX'
Perchloroethenen
Trichloroethenea
Dichloroethenea
Vinyl chloridea
Ethene/Ethane
Chloroethanea
1, 1, 1-Trichloroethanea
1, 1-dichloroethenea
riRequired analysis.
iiii iiiii iiil iiiiii llii liiil liiiiil liiilll llii1 liiii1
TABLE 2-3 (Continued)
ANALYTICAL PARAMETERS AND WEIGHTING
FOR PRELIMINARY SCREENING OF NATURAL ATTENUATION
Concentration in Most
Contaminated Zone
>lnM
<lnM
> 0.1 mg/L
> 0.1 mg/L
> 0.01
> 0.1
Interpretation
Reductive pathway possible; vinyl chloride may accumulate
Vinyl chloride oxidized
Intermediates resulting from biodegradation of aromatic compounds; carbon and
energy source
Carbon and energy source; drives dechlorination
Material released
Material relesaed or daughter of product of perchloroethene
Material released or daughter product of trichloroethene; if amount of cis-1,2-
dichloroethene is greater than 80 percent of total dichloroethene, it is likely a
daughter product of trichloroethene
Material released or daughter product of dichlrooethenes
Daughter product of vinyl chloride/ethene
Daughter product of vinyl chloride/ethene
Daughter product of vinyl chloride under reducing conditions
Material released
Daughter product of trichloroethene or chemical reaction of 1,1,1-trichloroethane
hPoints awarded only ifit can be shown that the compound is a daughter product (i.e., not a constituent of the source NAPL).
F: "\DAT A \J'ROJ\0313.02\ 1'0203.DOC
Points
Awarded
3
2
2
2
3
2
Page 2 of2
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Score
0 to 5
6 to 14
15 to 20
>20
TABLE 2-4
INTERPRETATION OF POINTS AWARDED DURING
SCREENING PROCESS OF NATURAL ATTENTATION•
Interpretation
Inadequate evidence for biodegradation of chlorinated organics
Limited evidence for biodegradation of chlorinated organics
Adequate evidence for biodegradation of chlorinated organics
Strong evidence for biodegradation of chlorinated organics
'Refer to AFCEE Proposed Protocol for Natural Attenuation in Appendix B.
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For one time period (to be determined), a sensitivity analysis will be performed. The
sensitivity analysis will be performed by independently varying four to five
parameters. Modeling runs will be conducted with the varied parameter set at
values lower and then higher than the values in the calibrated model. Based on the
sensitivity analysis, reasonable ranges of results will be developed. The analysis
will provide a basis for understanding how the simulated groundwater quality would
be affected by changes in the critical modeling parameters. The sensitivity analysis
results will be presented in tabular form with individual runs included in an
appendix to the RD report. BIOSCREEN is not appropriate for this task. An
ECKENFELDER INC. published in-house model based on the same principals as
BIOSCREEN will be used.
Additional modeling will then be used to simulate groundwater quality subsequent
to installation of the AS/SVE system. Parameter values used in the model will be
based on the results of the earlier model calibration and sensitivity analysis.
Groundwater quality will be simulated for periods of five, ten, and twenty-five years.
2.5 IMPLICATIONS FOR THE REMEDY AND AS/SVE PILOT TEST
It is anticipated that the final remedy for the OU3 groundwater may consist of a
combination of source control (air sparging) and monitored natural attenuation.
Since the AS/SVE system will have impacts on biodegradation processes, it is
necessary to consider both components of the remedy when designing the pilot test.
The groundwater quality data from previous investigations have been used to help
determine the location of the AS/SVE pilot test. The physical constraints of the Site
have also been considered in selecting the location of the AS/SVE pilot test. The
bioparameter data, along with the groundwater quality data and BIOSCREEN
model results, will provide an indication of the current rates of remediation
occurring within the groundwater plume as a result of biodegradation and as a
result of other attenuation mechanisms. Modeling will also allow simulation of
potential future contributions of natural attenuation to groundwater quality
improvements. This will provide insight into how mnch mass removal and
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groundwater remediation needs to be achieved through source control measures
. such as air sparging.
Additionally, the new groundwater quality data from the pre-design investigation
and modeling results will provide insight into the extent to which air sparging might
negatively impact natural attenuation. The combined information could, for
example, suggest modifications to the air sparging process, such as sparging with
nitrogen rather than air and whether this modification would be practical.
2.6 AS/SVE PILOT TEST
The proposed AS/SVE pilot test will be conducted according to the Pilot Test Work
Plan, included as Attachmeri t 1.
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3.0 REMEDIAL DESIGN
The Remedial Design phase of the work will involve preparation and submittal of
technical plans and specifications at various stages of completion (preliminary,
intermediate, and pre-final/final) as specified by the CD and SOW and as generally
described in the USEPA "Superfund Remedial Design and Remedial Action
Guidance Manual" (OSWER Directive 9355.0-4A, June 1986).
In accordance with the Consent Decree, four deliverables are tci Le prepared and
submitted to the regulatory agencies during the Remedial Design phase of the
project. These deliverables are the Preliminary Design, the Intermediate Design,
and the Pre-Final/Final Design. It is proposed (and latitude is provided Ly
Section VI, 11, e of the CD) that an Intermediate Design Meeting and design
progress presentation be substituted for the Intermediate Design. An RA Work
Plan is also required as part of the RD. The content of each deliverable and the
Intermediate Design meeting are described below.
3.1 PRELIMINARY DESIGN
The technical requirements of the RA will be outlined in the Preliminary Design.
The Preliminary Design submittal will identify the major components of the final
design, and will include the following:
Data Summary
Design Criteria Report
Outline of Draft Plans and Technical Specifications
Plan for Satisfying Permitting Requirements
Preliminary Schedule and Project Delivery Strategy
Each of the components of the Preliminary Design deliverable is discussed below.
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3.1.1 Data Summary
Existing hydrogeology, groundwater, and soil characterization information will be
summarized. Additional data collection consisting of the pre-design investigation
and the AS/SVE pilot test will also be presented. This information will be presented
as part of the Design Criteria Report.
The pre-design investigation will be conducted to further delineate the horizontal
and vertical extent of constituents of concern, to evaluate metals concentrations,
sample off-Site residential drinking water wells, and collect biodegradation
parameters. The results of this investigation will be summarized with supporting
appendices. Data collected to further delineate the horizontal and vertical extent of
constituents will be presented in tabular format, along with select concentration
maps. Geologic and well construction logs will be provided for newly installed wells.
Metal concentrations will be summarized and tabulated such that comparisons can
be made between newly collected data, current background data; and historical
data. Groundwater quality data associated with the residential drinking water well
sampling will be tabulated and evaluated for potential constituents of concern. A
Site map will be provided illustrating the residential well locations.
Natural attenuation data related to the Site geochemistry and groundwater
parameters will be summarized and tabulated to support whether various biological
processes are occurring and also provide an indication of whether conditions are
favorable to reductive dechlorination of the groundwater constituents of concerns.
Additionally, the Site will be scored for the potential that natural attenuation is
occurring based on the USEPA's site scoring protocol.
The results that will be presented in the Design Criteria Report from the AS/SVE
pilot test will include both physical and chemical data for various AS/SVE operating
conditions. The physical data will include air flow rates, temperatures, vacuums,
and groundwater levels. Chemical data will include aqueous and vapor phase
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VOCs, aqueous phase dissolved oxygen, vapor phase oxygen, and carbon dioxide.
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The results of the helium tracer jtests will be presented.
3.1.2 Design Criteria Report'
The Design Criteria Report will include a characterization of soil and groundwater.
The report will provide the necessary technical criteria to be utilized in the design of
the remediation system. Existing data from previous investigation activities as well
as new data will be utilized. The report will describe the approach and technical
basis for design decisions, sizing, spacing, capacities and rates. The report will be
prepared in a form such that information will be added in the future rather than
starting over. That is, the calculations to be performed will be identified as part of
this submittal. Future submittals will include the results of these calculations and
the actual calculations as appendices.
The design criteria will constitute the beginning of the engineering design analysis
and will generally include the basis for selecting locations, capacities, spacing, and
sizing of the injection and extraction wells.
The design criteria report will also include any changes proposed to the selected
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remedy based upon evaluation, of the pre-design investigation and/or pilot test
results. An evaluation supporting significant proposed changes would also be
included.
3.1.3 Outline of Draft Plans and Technical Specifications
Preliminary plans and technical specifications will be developed as part of the
Preliminary Design. At this time it is expected that the following drawings will be
prepared as part of the RD:
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Cover sheet with site location maps
Existing conditions plan
Site plan of the remediation system
Cross sections of the remediation system
Extraction and injection system details (extraction wells, monitoring wells,
collection and discharge system, security, etc.)
Piping and instrumentation diagram (P & ID)
Electrical layout and requirements
To the extent practicable, draft versions of these drawings will be provided with the
Preliminary Design submittal. Detailed design of the system components will be
included in the Pre-Final Design submission. When the Pre-Final Design is
submitted, the construction plans will provide detail sufficient for bidding and
actual construction by a qualified contractor including plan views, profiles, cross-
sections, details, instrumentation, etc., as appropriate.
An outline of technical specifications will be prepared that will address various
aspects of the work and supplement the drawings. The specifications will include
general material, equipment, and procedure requirements and other related items.
As part of the general requirements, a Health and Safety Plan Specification for the
remedial contractor will also be included.
At this point it is expected that the outline of technical specifications may include
the following, which will be further refined during development of the specifications
as needed:
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Work Area Preparation
Clearing and Grubbing
Earthwork and Materials
Trenching
Piping and Manholes
Sediment and Erosion Control
Fencing
Landscaping
Restoration of Structures
Concrete
Injection, Extraction, and Monitoring Wells
Electrical Work.
Mechanical Work
The technical specifications will be prepared in a typical, standardized Construction
Specifications Institute (CSI) Master Format and may include definition of:
Description of Work
Related Work
Quality Assurance/Quality Control (QA/QC)
Submittals
Materials and Equipment (referenced to standard specifications where
appropriate, e.g., ASTM)
Construction or Execution (again referenced to standard specifications
where appropriate and including quality control procedures)
Defective Work
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System Start-up and Project Close-out
Construction Facilities and Temporary Controls
3.1.4 Plan for Satisfying Permitting Requirements
The Preliminary Permitting Requirement Plan to be submitted will identify and
briefly describe the permits and/or approvals that may be needed for the
implementation of the RA, along with anticipated acquisition time frames. Permits
and/or approvals associated with the daily construction activities are assumed to be
the responsibility of the remedial action contractor and will not be included here.
3.1.5 Preliminary Schedule and Project Delivery Strategy
A preliminary construction schedule and strategy for implementing the RA will be
prepared. The preliminary version will include summary information with minimal
detail and will be expanded and modified as appropriate as the RD progresses.
3.2 INTERMEDIATE DESIGN
A meeting will be held approximately at the mid point between submission of the
Preliminary Design and the Pre-Final Design. The presentation will include an
update of the design analysis and presentation of drawings in progress at
approximately 60 percent completion. An updated draft construction schedule will
be provided at this time. Comments received during or following the meeting will
be considered and incorporated into the Pre-Final Design as appropriate. Value
engineering proposals (which include process, material, or approach options that
reduce or control cost while maintaining effectiveness) would also be presented at
this time.
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3.3 PRE-FINAL DESIGN
A memorandum will be included with this submittal inrucating how USEPA
comments on the Preliminary Design submittal and the Intermeruate Design
Presentation were incorporated into the Pre-Final Design. The Pre-Final Design
submittal will include the following components:
Design Analysis
Plans and Specifications
Construction Schedule
Construction Cost Estimate
3.3.1 Design Analysis
An Engineering Design Analysis Report and supporting calculations, separate from
the plans and specifications (Contractor Bidrung Documents), will be prepared for
submission with the Pre-Final Design. The purpose of the design analysis will be to
state the logic behind design decisions and present design calculations with
assumptions. The design analysis will include evaluation of the need for an SVE air
emission control system. This evaluation may include _modeling and will be based
upon the results of the pilot test and the North Carolina Air Emission Standards.
Design requirements and provisions including a summary of existing conditions and
Site constituents, as well as other design criteria, will be presented.
3.3.2 Plans and Specifications
Pre-Final Design plans and specifications will be developed and submitted. A
preliminary list of plans and specifications is provided in Section 4.1. These plans
will include equipment and instrumentation plans, and associated civil, mechanical,
and electrical plans, sections, and details. Specifications will include general
requirements; sequence of construction; type of construction, services, and materials
to be supplied; quality control procedures; supplemental conditions; special
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requirements; and other contractual requirements, in addition to the technical
specifications. The outline of specifications provided in the Preliminary Design
submittal will be expanded into complete specifications for materials, equipment,
and procedures. The presentation of the plans and specifications will be consistent
with the outlined project delivery schedule and will conform with the CSI Master
Format.
As part of the remedial design specifications, a remedial action Health and Safety
Plan Specification will be included. This specification will outline the minimum
requirements of the contractor health and safety plan [to be developed and
implemented by the selected contractor(s)) throughout remedial action activities at
the Site.
The Decontamination Plan specification, which will also be incorporated into the
remedial design specifications, will provide specifications for preparation of
procedures and plans for the decontamination of equipment and disposal of
contaminated materials during remedial action. Minimum acceptable performance
requirements for decontamination equipment and components will be included in
the specification.
3.3.3 Construction Schedule
A remedial action construction schedule will be presented with the Pre-Final
Design. It is currently anticipated that the schedule will be developed using
computer software known as Timeline®, which is utilized in conjunction with
Microsoft Windows®. This schedule will include dates for future deliverables and
field activities and will also be incorporated into the RA Work Plan.
3.3.4 Cost Estimate
A construction cost estimate will be prepared for both capital construction cost and
annual operations and maintenance costs. The cost estimate will be based upon
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standard estimating guides, contractor and supplier quotes and previous experience
on similar projects.
3.4 FINAL DESIGN
After receipt of USEPA comments on the Pre-Final Design, discussion of comments,
and completion of necessary revisions, the Final Remedial Design will be submitted
to the USEPA for final approval. The Final Design will include a completed
engineering design analysis, final plans and specifications, final construction
sch~dule, and cost estimate. The plans will be certified by a Professional Engineer
registered in the State of North Carolina.
3.5 REMEDIAL ACTION WORK PLAN
The RA Work Plan which provides a detailed plan of action for completing the RA
activities, will present a discussion of the tasks to be performed, including the
following elements:
RA Schedule
Permitting Plan
Construction Management Plan (CMP)
Construction Quality Assurance Project Plan (CQAPP)
Field Sampling Plan
Contingency Plan
Project Delivery Strategy
Groundwater and Surface Water Monitoring Plan
Operation and Maintenance Plan (O&MP)
The construction schedule prepared as part of the Final Design will be incorporated
into the RA Schedule. The RA Permitting Plan will be included in the Pre-Final
submission. This plan, discussed in the preliminary design submittal requirements,
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will be finalized for Pre-Final submission. The remaining deliverables are described
below.
3.5.1 Construction Management Plan
This plan will describe how construction activities will be implemented and
coordinated with USEPA during the RA phase of work. An RA Coordinator, as well
as other key project management personnel, and lines of authority will be
designated in the plan for activities during the RA. The plan will provide an
organizational chart and descriptions of the duties of each of the key personnel,
including the on-Site representative. The plan will also include procedures for
administration of construction changes and subsequent USEPA review and
approval.
3.5.2 Construction Quality Assurance Project Plan
An RA Construction Quality Assurance Project Plan (CQAPP) will be provided and
will include a description of the observations and control testing to be used to
monitor construction; a schedule for managing submittals, testing, inspections, and
other QA functions; reporting procedures; and a list of definable features. The plan
will set forth provisions for the following activities:
Review of contractor qualifications
Review of con tractor plans
Monitoring compliance of contractor with plans, specifications, and
contract terms, including observations and tests to be used in monitoring
construction
Monitoring and reporting the progress of the work
Review and approval of contractor(s) claims for payment
Review and evaluation of change order requests
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Compilation of project documentation
The CQAPP will also include a description of activities, project organization,
authority and responsibilities of project staff, special procedures, and a schedule of
activities.
3.5.3 Field Sampling Plan
A Field Sampling Plan will be developed and submitted. This plan will be directed
at monitoring construction performance and will include air monitoring, other
health and safety related monitoring requirements, and equipment and material
performance monitoring.
3.5.4 Contingency Plan
An RA Contingency Plan, to be implemented if needed during remedial action
activities at the Site, will be developed. This plan will address the following topics:
Pre-emergency planning
Personnel roles, lines of authority, and emergency services
Emergency recognition and prevention
Evacuation routes and procedures
Incident reporting
Emergency medical treatment procedures
Fire, explosion, spills, and leaks
Emergency equipment and facilities
3.5.5 Project Delivery Strategy
A project delivery strategy will be submitted which addresses the management
approach for implementing the Interim RA. The strategy will also include a list of
drawings, and the anticipated means of implementing the RA [i.e., procurement
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methods, phasing alternatives, method for selection of contractor(s), the number of
prime contractors and their responsibilities].
3.5.6 Groundwater and Surface Water Monitoring Plan
A Groundwater and Surface Water Monitoring Plan will be developed. This
monitoring will measure progress towards meeting performance standards. The
monitoring plan will specify sampling methods, monitoring frequencies, analytical
parameters, and report requirements.
3.5.7 Operation and Maintenance Plan
An Operation and Maintenance Plan (to be used after the remedial action is
complete) will be developed and submitted. This plan will describe the anticipated
operation and maintenance requirements for the remedial system. Key components
of the plan will include development of O&M manuals, O&M tasks and their
frequencies, monitoring tasks (both on site and remote), record keeping tasks,
reporting tasks, and a Health and Safety Plan for operation.
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4.0 PROJECT MANAGEMENT PLAN
Project communication and coordination will be conducted in accordance with this
project management plan. The project management plan includes a description of
the project team and the plans for data management, document control, monthly
reporting, project meetings with the USEPA, and community relations.
4.1 TEAM ORGANIZATION
The project organization for the RD is shown in Figure 4-1. The Remedial Project
Manager (RPM) for USEPA Region IV is Mr. McKenzie Mallary. The Technical
Committee Project Coordinator for the RD of the selected remedy (air sparging,
SVE, and monitored natural attenuation) is Ms. Nancy K. Prince, CGWP, of El Paso.
Should it be necessary to implement an alternate remedy, the USEPA will be
advised of a reorganized project team. The Assistant Project Coordinator is Mr.
Marc R. Ferries, also of El Paso. The work to prepare the RD will be conducted by
ECKENFELDER INC. Aquaterra, Inc, who conducted the RI/FS for OU3, will
provide support to the Technical Committee and will provide transfer of information
to ECKENFELDER INC. Communications by ECKENFELDER INC. with the
USEPA and the State of North Carolina, including deliverables and correspondence,
will be coordinated through the Project Coordinator or her designated
representative.
4.1.1 ECKENFELDER INC. Project Team
The team for this project has been assembled from individuals with experience in
the key areas associated with projects of this type: hydrogeologic investigations,
AS/SVE pilot testing, natural attenuation, fate and transport modeling, data
management and interpretation, remedial designs, remedial action planning, and
construction management. The team will be complemented by the addition of three
technical advisors.
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I USEPA REGION N
REMEDIAL PROJECT MANAGER
I McKENZIE MALLARY
EL PASO ENERGY
TECHNICAL OOMM1'l"l'EII:
PROJECT COORDINATOR
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NANCY K. PRINCE, OOWP
ALTERNATE PROJECT tX>ORDINATOR
MARC R FERRIES
g PROJECT DIBECTOR
ROBERT E. ASH TV, P.E.
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TBCHNICAL ADVISORS TRANSITION SUPPORT
ROBERT D. NORRlS, Ph.D. PROJECl' MANAGO
SHARON MYERS JEFFREY L. PINTEN1CH, P .E~ CHMM KENTON IL OMA. P .F. AQUATERRA, INC.
RONALD A. BURT, Ph.D, P.G.
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TASK LEADER TASK LEADER TASK LEADER
I PR&-DESIGN INVEBTIGATION AB/fNE PILOT Tl!BT REMEDIAL DESIGN
GREGORY L. CHRIBTIANS, P.G. M. MARIA MEGEHEE KENTON R OMA, P.E.
I -WELL INSTALLATION ELECTRICAL Illl8IGN 1--
GEOLOGIC EXPLORATION, INC. SMITH SECKMAN REID, INC.
I -CHRMICAL ANALYBIS
II -D. RICK DA VIS 1---I ECKENFELDKR, INC. PIIOJllCT STAFF w _J .,: STEPHEN A. BATISTE, E.lT. u JONATHAN P. MILLER, E.lT. (/)
I
SAMUEL P. WILIJAMS, P.G. ,-
0 DATA VALIDATION OTHER TECHNICAL AND _J ~ 1--[L ENVIRONMENTAL DATA SUPPORT STAFF AS
SERVTGm APPROPRIATE
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FIGURE 4-1 -
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I PROJECT ORGANIZATION FOR " I REMEDIAL DESIGN OF OU3 ,,., -,,.,
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ci FCX-STATESVILLE SUPERFUND SITE
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z STATESVILLE, NORTH CAROLINA
('.) 0313 5/98 z
ji 1--,.__ __ -~ ii' Ncshvillo, Tennoneo 0 ECKENFELDER INC." Mohwch, Now Jaraoy ,,,_
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As illustrated in Figure 4-1, the project team will be directed by Robert E. Ash, IV,
P.E., Assistant Division Director of the Waste Management Division of
ECKENFELDER INC. The Project Manager will be Mr. Kenton H. Oma, P.E.,
Assistant Technical Director of the Waste Management Division. The technical
advisors to the project will consist of: Dr. Robert D. Norris, Technical Director of In
Situ Remediation, Mr. Jeffrey L. Pintenich, P.E., CHMM, Director of the Waste
Management Division and Senior Vice President, and Dr. Ronald A. Burt, P.G.,
Director of the Hydrogeology Division. Mr. Gregory L. Christians, P.G., Project
Manager in the Hydrogeology Division will serve as Task Leader for the pre-design
investigation. Ms. M. Maria Megehee, Assistant Project Manager in the Waste
Management Division, will serve as Task Leader for the AS/SVE pilot test.
Mr. Oma will be Task Leader for the RD. Other technical and support staff will
assist these key project personnel. The ECKENFELDER INC. project team
members are located in the Nashville, Tennessee office.
Project Director -Robert E. Ash, IV, P.E.
Mr. Robert E. Ash, IV, P.E., Assistant Director of ECKENFELDER INC.'s Waste
Management Division, has over 16 years of experience in the design, construction,
and remediation of industrial facilities and waste management (landfill) sites,
including CERCLA projects. Mr. Ash's experience includes the management of
complex multidisciplinary CERCLA remedial designs and implementation of these
designs. Mr. Ash has considerable experience in each facet of site remediation work
including construction observation, documentation, and interface with the
contractors and client. As project director, Mr. Ash will have overall responsibility
for project staffing and quality control. Mr. Ash is registered as a Professional
Engineer in the State of North Carolina and will serve as the design engineer of
record.
Project Manager -Kenton H. Oma, P.E.
Mr. Oma is Assistant Technical Director of the Waste Management Division of
ECiillNFELDER INC. and has over 20 years of experience in environmental
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engmeermg. He has served as project manager for Superfund remediation
programs, has prepared several technical specifications for site remediation, has
coordinated contractor observation during site remediation, and has prepared RD
work plans and completion reports for various environmental remediation projects.
Mr. Oma's experience includes field and laboratory testing of treatment
technologies, research and development of remediation technologies, and design,
installation, and operation of pilot-and full-scale waste treatment systems.
Technical Advisors -Robert D. Norris, Ph.D., Jeffrey L. Pintenich, P.E.,
CHMM, and Ronald A. Burt, Ph.D., P.G.
Dr. Robert D. Norris has been involved in the development and implementation of
in situ remediation processes for over 14 years. Dr. Norris has been responsible for
in situ and ex situ remediation projects involving natural attenuation,
bioremediation, air sparging, soil vapor extraction, and permeable migration
barriers. Over the last 10 years, he has been involved in treatability testing and
design techniques such as air sparging for both physical removal of volatile
compounds and as a means of oxygen supply for bioremediation. He has applied his
understanding of bioremediation principles and his expertise to the application of
intrinsic remediation at various sites. He is the author of the air sparging and
bioventing chapters of the American Academy of Environmental Engineer's
monograph on bioremediation. He is also a member of the National Academy of
Science Committees on Bioremediation and on In-Situ Remediation of DNAPLs and
Metals.
Jeffrey L. Pintenich, P.E., CHMM, is a Senior Vice President of the firm and
Director of the Waste Management Division in our Nashville office. He has
responsibility for all solid and hazardous waste management projects conducted out
of Nashville as well as corporate responsibility for risk assessment and air quality
projects. With 24 years experience in the field, he has directed and managed major
NPL site RD/RA and RI/FS projects, and lectures on site remediation at professional
short courses and at Vanderbilt University.
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Dr. Ronald A. Burt, Ph.D., P.G., is Director of the Hydrogeology Division in
ECKENFELDER INC.'s Nashville office, and will also serve as Technical Advisor for
the project. Dr. Burt has 18 years of experience in the fields of geology, hydrology,
and environmental chemistry, and has served as project manager and technical
director for several investigations at RCRA, CERCLA, and other hazardous waste
sites. His experience.also includes investigations at industrial landfills and facilities
including various sites with groundwater affected by chlorinated solvents.
Task Leaders -Gregory L. Christians, P.G., and M. Maria Mcgehee
Gregory L. Christians, P.G. is a Project Manager for the Hydrogeology Division of
ECKENFELDER INC. with nine years of professional experience in geological and
hydrogeological investigations. Mr. Christians' responsibilities with our firm include
design, implementation, and supervision of hydrogeologic investigations at both
controlled and uncontrolled hazardous waste sites, including CERCLA, RCRA, and
state regulated facilities. His project roles included work plan preparation,
coordination and execution of project activities (including coordination and
supervision of personnel), the evaluation of compiled data, and prepa_ration of the
final reports. He has directly supported the development of conventional
groundwater remedies, as well as innovative approaches including bioremediation
and air sparging.
Ms. M. Maria Megehee 1s an Assistant Project Manager with the Waste
Management Division of ECKENFELDER INC. Ms. Mcgehee has over six years of
professional experience including pilot testing of AS/SVE, preparation of SAMP and
QAPP documents, preparation of RD work plans, preparation of technical
specifications, construction observation, and data management.
4.1.2 Chemical Analysis Laboratory
The Analytical and Testing Services Division of ECKENFELDER INC. in Nashville,
Tennessee will perform the chemical analysis of samples collected during the course
of the work.
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4.1.3 Subcontractors
Three subcontractors will be utilized for this project, including the following:
Smith Seckman Reid, Inc. of Nashville, Tennessee will be utilized for
electrical design .
Geologic Exploration, Inc. of Statesville, North Carolina will be used for
drilling, well installation, and monitoring probe installation.
Environmental Data Services of Pittsburgh, Pennsylvania will be used for
data validation services.
4.2 DATA MANAGEMENT
Field data and analytical data will be collected during the course of the pre-design
investigation and AS/SVE pilot test.
4.2.1 Field Data
Field records will be generated for site activities including well installation, well
sampling, and the AS/SVE pilot test operations and associated sampling. Field
records will be recorded on field data sheets, drilling logs, and/or field log books.
Whenever appropriate, preprinted data sheets will be used. Field data will be
recorded with indelible ink and will include the following:
Description of field observations and procedures
Data and time
Signature of person entering data
Unique sample identification number
Location of sample
Sample collection method
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Equipment decontamination procedure
Description of deviations from plan
Field records will be kept in a secure on-Site location during field activities and will
be transferred to ECKENFELDER INC.'s office in Nashville, Tennessee upon
completion of field activities.
4.2.2 Laboratory Data
Documentation of laboratory data will be performed in accordance with the
Addendum to the FSP and the Addendum to the QAPP, Attachments 2 and 3,
respectively.
4.3 DOCUMENT CONTROL
The original manuscripts of finalized documents will be maintained in the central
files of ECKENFELDER INC. in Nashville, Tennessee. The documents in the
central files will be organized according to the project job number and task number.
Supporting files and data will be maintained in the project staff offices during the
project. At the end of the project, the files will be collected and will be transferred to
an off-Site storage facility in Nashville, Tennessee. The off-Site storage facility
meets the American Records Management Association (ARMA) requirements for
storage.
4.4 MONTHLY REPORTING
Monthly progress reports to the USEPA will be prepared as required by the Consent
Decree. The monthly reports will provide a summary of the project activities for the
previous month including:
Actions taken toward achieving compliance with the Consent Decree.
Results of sampling and tests and other data received by Respondents.
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Deliverables completed under. the work plan.
Actions, data collection, and plans scheduled for next six weeks and other
information relating to progress of the work.
Percentage of completion, unresolved delays encountered or anticipated,
and efforts made to mitigate delays.
Modifications to work plans or schedule.
Activities completed and scheduled in support of Community Relations
Plan .
4.5 PROJECT MEETINGS WITH USEPA
Review meetings with the Group and the USEPA will be attended by the Project
Manager and key· project team members as appropriate. The meetings are
anticipated to be in Atlanta, Georgia or Statesville, North Carolina. Coordination
with Weston and Westinghouse will also be required related to the ongoing work on
OUl and OU2. We have anticipated two coordination meetings at the site. The
anticipated project meetings with the USEPA are as follows:
meeting to discuss the RD Work Plan;
meeting to discuss results of the p1·e-design investigation and pilot test;
meeting to discuss the Preliminary Design Report;
meeting to present status of the design at Intermediate Completion;
meeting to discuss the Pre-Final Design Report; and
meeting to discuss the Final Design Report.
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4.6 COMMUNITY RELATIONS
This work includes providing support to the Group and the USEPA for
disseminating information to the public regarding the work to be performed. This
includes preparing project summaries, maps, data summaries, and attending public
meetings. It is assumed that the support will consist of preparation for and
attendance at two public meetings.
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5.0 PROJECT SCHEDULE
The schedule to perform the services described in this RD Work Plan is presented in
Table 5-1. Calendar dates for the schedule shown in Table 5-1 include an
assumption regarding document review time for the regulatory agencies. A 30-day
review period by the USEPA for each submittal has been assumed.
The schedule is based upon current knowledge of Site conditions. Unforeseen
conditions may impact the overall schedule. If it is determined that the selected
remedy cannot be implemented in a cost-effective or timely manner, the Group
requests the opportunity to revise the schedule presented in this RD Work Plan in
order to implement a contingent remedy.
The schedule for monitoring well sampling has been adjusted to meet the schedule
needs .for the OUl remediation. A portion of the monitoring well sampling was
performed in parallel with preparation of this RD Work Plan to accommodate the
May 1998 startup schedule for the OU! groundwater extraction system.
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Task Name
Meet.ins: with USEPA at the Site
Authorization to Proceed
Remedial Desie:n Work Plan
Pre<Jare RD Work Plan
Submit RD Work Plan
USEPA Review of RD Work Plan
USEPA A•Jllroval of RD Work Plan
Pre-Desirrn Investi<'ation
Install and Samnle Wells
Perform Pilot Test.
Prcnare Prelim. Desi,rn Renart Section
Submit Prelim. Desi"n Henort Section
Preliminarv Desi!!n
Prc•lare Preliminarv DesiE!n Rennrt
Submit Preliminarv Desi•m Reuort to USEPA
USEPA Review of Preliminarv Desi•m Rellort.
USE PA Arn)roval or Preliminarv Desi!"n Renort
Intermediate Dcsi"n
Preuare I nli,rmediate DesiE!n
Meet.in!! with USEPA ID Review Inter. Desie:n
Pre-Final/Final Desie:n
Prenare Pre-Final Desi!!n Reoort
Submit Pre-Final Oesi!!n Renart. to USEPA
USEPA RBview of Pre-Final Design Reoort
Prenare Final Desi0 n Renart
Submit Final Desi>'n Renart
USEPA Review of Final Desi"n Renart.
USEPA Aooroval of Final Desi,,-n Renort.
Remedial Action Work Plan
Prc,)are RA Work Plan
Submit RA Work Plan to USEPA
US~:PA Review or RA Work Plan
USE PA Am,roval of R.\ Work Plan
l\lont.hlv Pro<'ress Re•iorts
Q,IPROJ/0:J 13.02/EI.PASO.TLP
Start
Mar/0:3/98
Mar/09/!)8
Mar/09198
/vlar/09198
Mav/11/98
Mav/12198
Jun/11/()8
,Jun/22/!)8
,Jul/06198
,Jun/22/98
Au!!/ 1 :3/98
Oct/1:3198
Aue:/ 1:3/98
AuE!/13/DS
Oct/l:3/98
Oct/14/88
Nov/l:3/98
Oct/14/98
OctJI4/98
Dec/15/98
Dec/16/98
Decll6/98
Feb/22/99
Feb/23/99
Mar/26/99
Aor/26/!)9
Apr/2WJ9
l\fay/26/99
Mav/27/!J9
Mav/27/99
Jul/28/!)9
Jul/28/99
Aue:/:J0/99
Aor/l0/98
FIGURE 5-1
SCHEDULE FOR REMEDIAL DESIGN OF OU3
FCX-STATESVILLE SUPERFUND SITE
End 1998
Feb !\far Apr May Jun Jul Aug Sep Oct Nov Dec
Mar/0:3/98 ~
Mar/09/98 I,\;
,Junll l/98 ~--.::~· 'L/...LL..'.'.'Z_,·,-:~-:'..".L( ~:::.t.1
Mav/11/98 -
Li~ l\lay/11198
Jun/11/98 L
Jun/I 1/98 i:-" 9 OcrJI:3198 ~~/0"'777',;:··'" /,'/ / ,,,,i=i
Aui:,:/1:3/98
Oct/02/D8 ... . ... , r:
Oct/13198 ---~ OcUl3/98 L __ L Nov/13/98 C...::..,/ ,·'.,, LLL 23:1
Oct/l:l/D8
d.:'".L µ _,_,, C-L.C
~ OcrJI:3/98
Nov/13/98 '
Nov/1:3/98 1=1;
Dec/l?i/98 r,k.,, .. .,,~ '/,'L. . ..:.0..7
' Dec/14/98 ... . ... • i
Dec/15/98 G Ul
Jan Feb
Mav/26/99 5.z,E!---z.:.2/7777/;,:
; Fcb/22/99 ~ Feb/22/!)9
Mar/25/99 l
Anr/26/1)9
Aor/26/99
Mav/26/99
May/2G/99
Au!!/30/!)9
Jul/28/99
,Jul/28/99
Aue:/30/99
Au!!/30/99
Sen/l0/99
I Note: The ~hcdule is dependent on the m.:tuul duration of USE PA reviews and actual apJJrovnl dutes.
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1999
Mar Apr May Jun ,Jul Aug Sep oc,
,7?777;77 //777;;'77 ,7777;::77
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APPENDIXA
POTENTIAL SOURCE AREAS
IDENTIFIED DURING RI
\ \ TN\SYS\DATA \.PROJ'\0313.02\appendix coven.doc
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Southern Rall Line
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Existing Maintenance Shop _ __:_
Drain Pipe Area
Pollution Control Unit 1
Southern Rall Line
-
Storm Drain &
Sanitary Sewere,
--
Storm Drain & Sanitary Sewers
Other Off-Site Sources
(FCX), (Carnation), (Jim's Transmission)
Refuse Pile
liill 111!!!1 l!!IJ .. -
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Former A!!.ll Spur & Machlno Shop
------ft//-Former Dry Clsanlng Machine J\nHl
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Job No.
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Drawing
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RI Potential Source/Study Areas
FCX-Statesvllle Superfund Site, OU 3
StateGVllle, North CarolJna
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Legend
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APPENDIXB
SUPPLEMENTAL INFORMATION ON
NATURAL ATTENUATION
B-1 Natural Attenuation Overview
B-2 Draft Interim Final OSWER Monitored Natural Attenuation Policy
B-3 AFCEE Proposed Protocol for Natural Attenuation
B-4 The BIOSCREEN Computer Tool
B-5 · Kinetics ofBiotransformation
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B-1 NATURAL ATTENUATION OVERVIEW
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NATURAL ATTENUATION OVERVIEW
Natural attenuation, also referred to as intrinsic remediation, relies on the natural
restorative capacity of aquifers to control migration and reduce the masses of
constituents of concern. Processes at work with intrinsic remediation include
adsorption, diffusion, dispersion, volatilization, and degradation. These processes
must be scientifically evaluated and monitored to determine if site-specific cleanup
goals can be met. An understanding of the hydrogeological conditions, groundwater
quality, the properties of the constituents of concern, and bioparameters may
provide qualitative evidence of natural attenuation and indicate the extent to which
biodegradation contributes to natural attenuation. Through the use of modeling
techniques, the historical groundwater quality can be simulated and future
groundwater quality predicted.
The hydraulic conductivity, gradient, and porosity of the aquifer determine the rate
of groundwater flow. As the groundwater moves through the aquifer, mixing of
affected groundwater with clean groundwater occurs as a result of dispersion and, to
a lesser extent, diffusion. These processes result in somewhat lower constituent
concentrations and marginally broader plumes. As the constituents move through
the aquifer they adsorb to the aquifer materials, especially when appreciable organic
content is present, and subsequently desorb (dissolve). The adsorption/desorption
process retards the rate at which constituents move through the aquifer. As a
result, constituent migration is slower than otherwise would occur as a consequence
of groundwater flow through the aquifer: The processes of diffusion, dispersion, and
retardation moderate constituent concentrations but do not cause a reduction in
constituent mass.
Chemical and biological degradation reactions reduce both mass and concentration
of the degradable organic constituents. For chlorinated aliphatic hydrocarbons (e.g.,
PCE and TCE), the process of degradation in groundwater occurs largely through
anaerobic (in the absence of oxygen) biodegradation. The specific process is referred
to as reductive dechlorination. In this process, chlorine atoms of chlorinated ethenes
are sequentially replaced with hydrogen atoms as shown below.
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PCE ➔ TCE ➔ DCE ➔ Vinyl Chloride ➔ Ethene
Vinyl chloride and DCE can also be biodegraded aerobically.
EVALUATION PROCESS FOR NATURAL ATTENUATION
Reductive Dechlorination Process
The evaluation of natural attenuation requires an understanding of the biological
processes occurring at the site, groundwater quality, and transport mechanisms
based on the site hydrogeology. A detailed understanding of the mechanism of the
biodegradation component of natural attenuation requires an evaluation of several
parameters that are collectively known as biodegradation parameters. These
include electron acceptors, electron donors, nutrients, and geochemical indicators.
The process of reductive dechlorination involves both the oxidation of other organic
molecules and the reduction of the chlorinated compounds. The first process
requires the utilization of electron acceptors. Electron acceptors are utilized
preferentially in the order of oxygen, nitrate, manganese, iron, sulfate, and carbon
dioxide. First, oxygen is consumed during degradation of aerobically degradable
compounds. Sequentially, the other electron acceptors are utilized. Hydrogen is a
byproduct of some of these reactions. It is believed that the reaction of hydrogen and
chlorinated organic compounds in the presence of enzymes is the key step in the
reductive dechlorination of PCE and other chlorinated species.
Other conditions are important for the biodegradation processes. Nutrients are
required for microbial growth. In order for the bacteria that carry out the reductive
dechlorination process to be active, the pH must be near neutral, the ORP must be
relatively low, and oxygen must be absent.
Because electron acceptors are consumed during biodegradation, concentrations of
electron acceptors will be less within the plume than outside of the plume and
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should be lowest within the source area or immediately downgradient of the source
area. Dissolved oxygen, nitrate, and sulfate levels should be lower within the plume
than outside the plume. The more highly oxidized forms of iron and manganese
have very low solubility in water. When the oxidized forms of these metals are used
as. electron acceptors, they are reduced to lower oxidation states that are more
soluble in water than are the oxidized forms. Thus concentrations of reduced iron
[Fe (II)] and reduced manganese [Mn (II)] are usually elevated within the plume.
As a result of the reduction of the various electron acceptors, the oxidation/reduction
potential of the groundwater decreases, typically to negative values with respect to a
silver/silver chloride reference electrode. Thus the ORP values should be lower
within the plume than outside the plume.
Bioparameters and Ranking System
The bioparameters (also called biodegradation parameters) that can be used to
evaluate a site for reductive dechlorination are presented in Table 2-2.
Bioparameter data obtained from locations within and outside of the plume are
compared m order to identify the probable mechanism(s) for reductive
dechlorination. Along with the groundwater quality data, bioparameter data is used
for ranking the site according to the proposed protocol developed under development
by the U.S. Air Force Center for Environmental Excellence (AFCEE) (Wiedemeier,
et. al. 1997). The ranking is useful for comparing the evidence for reductive
dechlorination to that obtained at other chlorinated hydrocarbon impacted sites that
have been studied and documented.
While the ranking system is useful to put the site in perspective, it should be
appreciated that the presence of cis-1,2-DCE at sites where PCE and/or TCE has
been released is proof that reductive dechlorination has occurred. However, the
occurrence of reductive dechlorination is not by itself sufficient to predict whether
natural attenuation can meet the site-specific goals. This requires the use of a fate
and transport model.
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Fate and Transport Modeling
Several models are available to evaluate the contribution of natural attenuation and
to predict future groundwater quality. These models can be two-dimensional or
three-dimensional. One commonly used model is BIOSCREEN, a two-dimensional
model developed for the U.S. Air Force and USEPA (Newell, et. al., 1997). It is
particularly useful for initial screening efforts, where the aquifer has not been fully
characterized, where a detailed three dimensional model has not been developed, in
highly homogeneous aquifers, and where aquifer characteristics preclude
satisfactory modeling by more complex modeling techniques.
The use of BIOSCREEN and similar models reqmres sufficient data to estimate
seepage velocity, retardation coefficients for each constituent to be me,deled, a
preliminary estimate of degradation rates, plume dimensions, and groundwater
quality along the plume axis. Using this type of input, the model simulates
groundwater quality along the plume axis using three scenarios: no degradation,
first order kinetics, and instantaneous reaction between the constituents and
available electron acceptors. The latter two require that biodegradation parameter
data be available.
The model is first calibrated to the existing data and then used to simulate future
groundwater quality. The models are typically used after all of the necessary data
have been collected, but can also be useful for planning the placement of additional
monitoring wells.
BIOSCREEN and similar models simulate groundwater quality only in the presence
of a constant source or a source that decays from the time of the initial introduction
of the constituents into the aquifer. It does not simulate sites where a source control
measure has been implemented after several years of impact, as will be the case for
OU3. ECKENFELDER INC. has recently developed a model that can be used in
conjunction with BIOSCREEN or a similar model to simulate groundwater quality
downgradient of the groundwater collection system subsequent to its installation.
ECKENFELDER INC.'s model or a similar model or models with comparable
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capabilities will be used to approximate the potential affect of a source area remedy
on natural attenuation of the downgradient portion of the plume.
ADDITIONAL REFERENCE INFORMATION
The following documents provide background information for the evaluation process.
The first document provides an overview of USEPA's policy on natural attenuation.
The second document is a summary of the AFCEE proposed protocol. The third
document describes the BIOSCREEN model. The fourth document provides a range
of observed reductive dechlorination rates at a number of sites studied by the
USEPA.
Draft Interim Final OSWER Monitored Natural Attenuation Policy
(OSWER Directive 9200.4-17) "Use of Monitored Natural Attenuation at
Superfund, RCRA Corrective Action, and Underground Storage Tank
Sites", November 1997.
Wiedemeier, T. H., M. A. Swanson, D. E. Moutoux, J. T. Wilson, D. H.
Kampbell, J. E. Hansen, and P. Haas, "Overview of the Technical Protocol
for Natural Attenuation of Chlorinated Aliphatic Hydrocarbons in Ground
Water Under Development for the U.S. Air Force Center for Environmental
Excellence", Proceedings of the Symposium on Natural Attenuation of
Chlorinated Organics in Ground Water, Dallas, Texas, September 1996.
EPA/540/R-97-504, pp 37-61.
Newell, C. J., R. K McLeod, and J. R. Gonzales, "The BIOSCREEN
Computer Tool", Proceedings of the Symposium on Natural Attenuation of
Chlorinated Organics in Ground Water, Dallas, Texas, September 1996,
EP A/540/R-97 -504, pp 62-65.
Wilson, J. T., D. H. Kampbell, and J. W. Weaver, "Environmental
Chemistry and the Kinetics of Biotransformation of Chlorinated Organic
Compounds in Ground Water", Proceedings of the Symposium on Natural
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Attenuation of Chlorinated Organics in Ground Water, Dallas, Texas,
September 1996, EPA/540/R-97-504, pp 133-136 .
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B-2 DRAFT INTERIM FINAL OSWER
MONITORED NATURAL ATTENUATION POLICY
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&EPA
I b A •
United States
Environmental Protection
A9.ancy
DIRECTIVE NUMBER:
omce of
Solid Waste and
Emergency Response
9200.4-17
TITLE: Use of Monitored Natural Attenuation at Superfund, RCRA
Corrective Action, and Underground Storage Tank Sites
APPROVAL DATE:
EFFECTIVE DATE:
ORIGINATING OFFICE:
□ FINAL
~ DRAFT Interim Final
STATUS:
OSWER
REFERENCE (other documents):
9 4$ f 1,ti':!ff ; fi&fiR
OSWER
DIRECTIVE
OSWER OSWER
DIRECTIVE DIRECTIVE
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UNITli:D STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
Ori'ICI: 01'
!101,It) IQSTE AND JilClCRGl2'f'CY
P.ESPCll'SE
MEMORANDUM
SUBJECT: Draft Interim Final OS'WER Monitored Natural Attenuation Policy
(OS'WER Directive 9200.4-17)
FROM: Elizabeth Cotsworth, Acting Director
Office of Solid Waste
TO:
Purpose
Walter W. Kovalick, Jr., Director
Technology Innovation Office
Stephen D. Luftig, Director
Office of Emergency and Remedial Response
Anna Hopkins Virbick, Director
Office of Underground Storage Tanks
James E. Woolford, Director
Federal Facilities Restoration and Reuse Office
Addressees
This memorandwn accompanies a draft Interim Final Policy (OSWER Directive
9200.4-11) regarding the use of monitored natural attenuation for the remediation of ' contaminated soil and groundwater at sites regulated under all pro grams administered by EPA' s
Office of Solid Waste and Emergency Response (OSWER), including Superfund, RCRA
Corrective Action, and Underground Storage Tanks. The Directive incorporates extensive
comments received from EPA Regional and Headquarters reviewers (including the Office of
General Counsel), as well as state agencies and federal facility representatives.
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Summary or the Dtrec;ttve
This Directive clarifies the U.S. Environmental Protection Agency's (EPA) policy
regarding the use of Monitored Natural Attenuation for the remediation of contaminated soil and
groundwater at sites regulated under Office of Solid Waste and Emergency Response (OSWER)
programs. These include programs administered under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA or "Superfund"), the Resource
Conservation and Recovery Act (RCRA), the Office of Underground Storage Tanks (OUST), and
the Federal Facilities Restoration and Reuse Office (FFRRO). The Directive is intended to
promote consistency in how monitored natural attenuation remedies are proposed, evaluated, and
approved. Al; a policy document, it does not provide technical guidance on evaluating Monitored
Natural Attenuation remedies. This Directive is being issued as Interim Final and may be used
immediately. It provides guidance to EPA staff, to the public, and to the regulated community on
how EPA intends to exercise its discretion in implementing national policy on the use of
Monitored Natural Attenuation. The document does not, however, substitute for EP A's statutes
or regulations, nor is it a regulation itself and, thus, it does not impose legally-binding
requirements on EPA, States, or the regulated co=unity, and may not apply to a particular
situation based upon the circumstances. EPA may change this guidance in the future, as
appropriate.
Implero entatlon
This Directive is being issued in Interim Final form and should be used immediately as
guidance for proposing, evaluating, and approving Monitored Natural Attenuation remedies. This
Interim Final Directive will be available from the Superfund, RCRA, and OUST dockets and
through the RCRA, Superfund & EPCRA Hotline (800-424°9346 or 703-412-9810). The
directive will also be available in electronic format from EPA's home page on the Internet (the
address is http://www.epa.gov/swerustl/directiv/d92004l 7.htm). EPA will review and evaluate
additional comments received on this Interim Final version for a period of 60 days before issuing
the Final Directive.
Questiona/Commenta
lfyou need more information about the Directive please feel free to contact any of the
appropriate EPA staff listed on the attachment. ·
Addressees: Federal Facility Forum
attachment
Federal Facilities Leadership Council
Other Federal Facility Contacts
OSWER Natural Attenuation Workgroup
RCRA Corrective Action EPA Regional and State Program Managers
State LUST Fund Administrators
State LUST Program Managers
UST/LUST Regional Program Managers
UST/LUST Regional Branch Chiefs
State Superfund Program Managers
Superfund Regional Policy Managers
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Attachment
EPA Contacts
November 20, 1997
If you have any questions regarding this policy, please first call the RCRA/Superfund Hotline
at [phone]. If you require further assistance, please contact the appropriate staff from the list
below:
Headquarters:
· Allison Abernathy-Federal Facilities
Dianna Ymmg-Federal Facilities
Ken Lovelace-Superfund
Felicia Wright-Superfund
Guy Tomassoni-RCRA
Dana Tulis-UST
Hal White-UST
Linda Fiedler-Technology Innovation
Office of Research and Development:
John Wilson-RMRL, Ada, OK
Fran Kremer-NRMRL, Cincinnati, OH
Fred Bishop-NRMRL, Cincinnati, OH
Groundwater Forum:
Ruth Izraeli-RCRA, Superfund
Region 1
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
Joan Coyle-UST
Ernie Waterman-RCRA
Richard Willey-Superfund
(6 l 7) 573-9667
[phone]
[phone]
Bill Brandon-Federal Facilities
Meghan Cassidy-Federal Facilities
Region 2
Derval Thomas-UST
Ruth Izraeli-Superfund
Jon Josephs-ORD Technical Liaison
Carol Stein-RCRA
Region 3
Jack Hwang-UST
Kathy Davies-Superfund
Deborah Goldblwn-RCRA
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
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Region 4
David Ariail-UST
Kay Wischka=per-Technical Support
Donna Wilkinson-RCRA
Robert Pope--F ederal Facilities
Region 5
Gilberto Alvarez-UST
Tom Matheson-RCRA
Luanne V anderpool-Superfund
Region 6
Lynn Dail-UST
John Cemero--UST
Region 7
William F. Lowe,-RCRA
Dave Drake--Superfund
Region 8
Sandra Stavnes-UST
Randy Breeden-RCRA
Rieb Muza-Superfund
Region 9
Matt Small-UST
Katherine Baylor-RCRA
Herb Levine-Superfund
Ned Black-Superfund
Mark Filippini-Superfund
Region 10
Harold Scott-UST
David Dominge>-RCRA Permits Team
Mary Jane Nearman-Superfund
( 404) 562-9464
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone] _
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
( 415) 744-2395
[phone]
[phone]
[phone]
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USE OF MONITORED NATURAL ATTENUATION
AT SUPERFUND, RCRA CORRECTIVE ACTION,
AND UNDERGROUND STORAGE TANK SITES
U.S. Environmental Protection Agency
Office of Solid W a.ste and Emergency Response
Directive 9200.4-17
November, 1997
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OSWER Directive 9200.4-17
USE OF MONITORED NATURAL ATTENUATION
AT SUPERFUND, RCRA CORRECTIVE ACTION,
ANDUNDERGROUNDSTORAGETANKSITES
Contents
PURPOSE AND OVERVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Transformation Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Petroleum-Related Contaminants .' ...................................... , . 4
Chlorinated Solvents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Inorganics ............................ , , ............... , . . . . . . . . . . . . 6
Advantages and Disadvantages of Monitored Natural Attenuation ........... , , . . . 7
IMPLEMENTATION ..... ,,., ........................ , ..................... 8
Role of Monitored Natural Attenuation in OSWER Remediation Programs . . . . . . . . . 8
Demonstrating the Efficacy of Natural Attenuation through Site Characterization .... 1 O
Sites Where Monitored Natural Attenuation May Be Appropriate ........ , ....... 13
Reasonableness of Remediation Time Frame .................... , ........... 15
Remediation of Contamination Sources and Highly Contaminated Areas ........... 16
Performance Monitoring ............................................... 17
Contingency Remedies ............ , .................................... 18
SUMMARY ......................................................... , .... 19
REFERENCES CITED ................ , ..................................... 20
ADDmONAL REFERENCES ................................................ 22
OTHER SOURCES OF INFORMATION ................... , , ................... 25
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OSWER Directive 9200.4-17
NOTICE: This document provides guidance to EPA staff. It also provides
guidance to the public and to the regulated community on how EPA intends to
exercise its discretion in implementing its regulations. The guidance is designed to
implement national policy on these issues. The document does not, however,
substitute for EPA's statutes or regulations, nor is it a regulation itself. Thus, it
does not impose legally-binding requirements on EPA, States, or the regulated
community, and may not apply to a particular situation based upon the
circumstances. EPA may change this guidance in the future, as appropriate.
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OSWER Directive 9200.4-17
PURPOSE AND OVERVIEW
The purpose of this Directive is to clarify EPA's policy regarding the use of monitored
natural attenuation for the remediation of coDtaminated soil and groundwater at sites regulated
under Office of Solid Waste and Emergency Response (OSWER) programs. These include
programs administered under the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA or Superfund), the Resow-ce Conservation and Recovery Act (RCRA),
the Office of Underground Storage Tanks (OUST), and the Federal Facilities Restoration and
Reuse Office (FFRRO).
EPA remains fully committed to its goals of protecting human health and the environment,
remediating contaminated soils and groundwater, and protecting uncontaminated groundwaters
and other environmental resources1 at all sites being remediated under OSWER programs. EPA
does not consider monitored natural attenuation to be a "presumptive" or "default" remedy-it is
merely one option that should be evaluated with other applicable remedies. EPA advocates using
the most appropriate technology for a given site. EPA does not view monitored natw-al
attenuation to be a "no action" or "walk-away'' approach, but rather considers it to be an
alternative means of achieving remediation objectives that may be appropriate for a limited set of
site circumstances where its use meets the applicable statutory and regulatory requirements. As
there is often a variety of methods available for achieving a given site's remediation objectives2,
monitored natural attenuation may be evaluated and compared to other viable remediation
methods (including innovative technologies) during the study phases leading to the selection of a
remedy. NJ with any other remedial alternative, monitored natural attenuation should be selected
only where it meets all relevant remedy selection criteria, where it will be fully protective of
human health and the environment, and where it will meet site remediation objectives, within a
time frame that is reasonable compared to that offered by other methods. Io the majority of cases
where monitored natural attenuation is proposed as a remedy, its use may be appropriate as one
component of the total remedy, that is, either in conjunction with active remediation or as a
follow-up measure .. Monitored natural attenuation should be used very cautiously as the sole
remedy at contaminated sites. Furthermore, the availability of monitored natural attenuation as a
potential remediation tool does not imply any lessening ofEPA's longstanding commitment to
pollution prevention. Waste minimization, pollution prevention programs, and minimal technical
requirements to prevent and detect releases remain fundamental parts of EPA waste management
and remediation pro grams.
1 Environmental resources to bo protoctod includo groundwator, drinking water supplies, surface waters, ecosystems
and other media (air, soil and sediments) that could be impacted from site contamination.
'In this Directive, remediation objectives are the overall objectives that romedial actions are intended to accomplish
and arc not the same as chemical-specific cleanup levels. Remediation objectives could include preventing exposure to
contaminants, minimizing further migration of contaminant. from source areas, minimizing further migration of the
groundwater contaminant plume, reducing contllmination in soil or groundwater to specified cleanup levels appropriate
for currt11l or potential future uses, or other objectives.
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OSWER Directive 9200.4-17
Use of monitored natural attenuation does not signify a change in OSWER's remediation
objectives, including the control of source materials ahd restoration of contaminated
groundwaters, where appropriate (see Section 1, unddr "Implen;ientation"). Thus, EPA expects
that source control measures will be evaluated for all hites under consideration for any proposed
remedy. As with other remediation methods, selcctioh of monitored natural attenuation as a
remediation method should be supported by detailed Jite-specific information that demonstrates
the efficacy of this remediation approach. In additionl the progress of monitored natural
attenuation toward a site's remediation objectives should be carefully monitored and compared
with expectations. Where monitored natural attenuatitin's ability to meet these expectations is
uncertain and based predominantly on predictive analyses, decision makers should incorporate
contingency measures into the remedy.
The scientific understanding of natural attenuation processes continues to evolve rapidly.
EPA recognizes that significant advances have been niade in recent years, but there is still a great
deal to be learned regarding the mechanisms governing natural attenuation processes and their
ability to address different types of contamination problems. Therefore, while EPA believes
monitored natural attenuation may be used where circhmstances are appropriate, it should be used
with caution commensurate with the uncertainties ass6ciated with the particular application.
Furthermore, largely due to the uncertai.'1ty associatedlwith the potential effectiveness of
monitored natural attenuation to meet remedial objectives that arc protective of human health and
the environment, source control and performance Iiionitoring are fundamental components
of any monitored natural attenuation remedy
This Directive is not intended to provide detailed technical guidance on evaluating
monitored natural attenuation remedies. At present, there is a relative lack of EPA guidance
concerning appropriate implementation of monitored r\atural attenuation remedies. With the
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exception of Chapter IX in OUST's guidance manual (USEPA, 1995a), EPA has not yet
completed and published specific technical guidance to support the evaluation of monitored
natural attenuation for OSWER sites. However, techriical resource documents for evaluating
monitored natural attenuation in groundwater, soils, ar\d sediments are currently being developed
by EPA's Office of Research and Development (ORD). In addition, technical information
regarding the evaluation of monitored natural attenuation as a remediation alternative is available
from a variety of sources, including those listed at the bd of this Directive. "References Cited"
lists those EPA documents that were specifically cited [Within this Directivo. The list of
"Additional References" includes documents produced by EPA as well as non-EPA entities . • I
Finally, "Other Sources of Information" lists sites on the World Wide Web (Internet) where
information can be obtained. Although non-EPA docilinents may provide regional and state site
managers, as well as the regulated community, with usbful technical information, these non-EPA
guidances are not officially endorsed by EPA, and all 11arties involved should clearly understand
that such guidances do not in any way replace current EPA or OSWER guidances or policies
addressing the ren,edy selection process in the Superfilnd, RCRA, or UST programs.
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OSWER Directive 9200.4-17
BACKGROUND
The tenn "monitored natural attenuation", as used in this Directive, refers to tbe reliance
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on natural attenuation processes (within the context of a carefully controlled and monitored site
cleanup approach) to achieve site-specific remedial objectives within a time frame that is
reasonable compared to that offered by other more active methods. The "natural attenuation
processes" that are at work in such a remediation appioach include a variety of physical, chemical,
or biological processes that, under favorable conditiok, act without human intervention to reduce
the mass, toxicity, mobility, volume, or concentrationl of contaminants in soil or groundwater.
These in-situ processes include biodegradation; dispetsion; dilution; sorption; volatilization; and
chemical or biological stabilization, transformation, of destruction of contaminants. When relying
on natural attenuation processes for site remediation, 1EP A prefers those processes that degrade
contaminants, and for this reason, EPA expects that nionitored natural attenuation will be most
appropriate at sites that have a low potential for plum~ generation and migration (see Section 3 I
under "Implementation''). Other terms associated with natural attenuation in the literature include
"intrinsic remediation", "intrinsic bioremediation", "piissive bioremediation", "natural recovery",
and "natural assimilation". While some of these term~ are synonymous with "natural attenuation,"
others refer strictly to biological processes, excluding 'chemical and physical processes.
Therefore, it is recommended that for clarity and coruiistency, the term "monitored natural
attenuation" be used throughout OSWER remediatiori programs unless a specific process (e.g.,
reductive dehalogenation) is being referenced.
Natural attenuation processes are typically occurring at all sites, but to varying degrees of
effectiveness depending on the types and concentrati~ns of contaminants present and the physical,
chemical, and biological characterisucs of the soil and groundwater. Natural attenuation
processes may reduce the potential risk posed by site bontaminants in three ways:
( 1) The contaminant may be converted to la less toxic form through destructive
processes such as biodegradation or abiotic transformations;
(2)
(3)
Potential exposure levels may be reduJed by lowering-of concentration
levels (through destructive processes, 6r by dilution or dispersion); and
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Contaminant mobility and bioavailability may be reduced by sorption to the
soil or rock matrix.
Whc:re conditions are favorable, natural attenuation processes may reduce contaminant I mass or concentration at sufficiently rapid rates to be integrated into a site's soil or groundwater
' remedy (see Section 3 under "Implementation" for a discussion of favorable site conditions).
Following source control measures, natural attenuatio~ may be sufficiently effective to achieve
remediation objectives at some sites without the aid of other (active) remedial measures.
Typically, however, monitored natural attenuation will be used in conjunction with active
remediation measures. For example, monitored natur~l attenuation could be employed in lower
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OSWER Directive 9200.4-17
concentration areas of the dissolved plume and as a follow-up to active remediation in areas of
higher concentration. EPA also encourages the consideration of innovative approaches which
may offer greater confidence and reduced remediatio~ time frames at a modest additional cost
While monitored natural attenuation is often dlbbed "passive" remediation because it
occurs without human intervention, its use at a site d6es not preclude the use of"active"
remediation or the application of enhancers ofbiologital activity (e.g., electron acceptors,
nutrients, and electron donors). However, by definitibn, a remedy that includes the introduction
of an enhancer of any type is no longer considered to be ''natural" attenuation. Use of monitored
natural attenuation does not imply that activities (and :costs) associated with investigating the site
or selecting the remedy (e.g., site characterization, risk assessment, comparison of remedial
alternatives, performance monitoring, and contingency measures) have been eliminated. These
elements of the investigation and cleanup must still b~ addressed as required under the particular
OSWER program, regardless of the remedial approach selected.
Transformation Products
It also should be noted that some natural attenuation processes may result in the creation
' of transformation products3 that are more toxic than the parent contaminant (e.g., degradation of
trichloroethy!ene to vinyl chloride), The potential forlcreation of toxic transformation products is
more likely to occur at non-petroleum release sites (e.g., chlorinated solvents or other volatile
organic spill sites) and should be evaluated to determine if implementation of a monitored natural
attenuation remedy is appropriate and protective in thd Jong term. Additionally, some natural
attenuation processes may result in transfer of some c9ntaminants from one medium to another
(e.g., from soil to groundwater, from soil to air or surface water, and from groundwater to
surface water). Such cross-media transfer is not dcsir~le, and generally not acceptable except
under certain site-specific circumstances, and would likely require an evaluation of the potential
risk posed by the contaminant(s) once transferred to tliat medium. ·
Petroleum-Related Contaminants
Natural attenuation processes, particularly biological degradation, are currently best
documented at petroleum fuel spill sites. Under appropriate field conditions, the regulated
compounds benzene, toluene, ethyl benzene, and xylene (BTEX) may naturally degrade through
microbial activity and ultimately produce non-toxic en~ products (e.g., carbon dioxide and water).
Where microbial activity is sufficiently rapid, the dissolved BTEX contaminant plume may
stabilize (i.e., stop expanding), and contaminant conceptrations may eventually decrease to levels
below regulatory standards. Following degradation ofia dissolved BTEX plume, a residue
3The term "lrarufoIJDation products" in the Directive includes biotically wid abiotically formed products descnbed
above (e.g., TCE, DCE, vinyl chloride), decay chain daughter prod~cts from radioactive decay, and inorganic elements
that become methylated compounds (e.g., methyl mer<:ury) in ,oil arid sedimenL
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OSWER Directive 9200.4-17
consisting of heavier petroleum hydrocarbons of relatively low solubility and volatility will
typically be left behind in the original source (spill) arJa. Although this residual contamination
may have relatively low potential for further migratio~ it still may pose a threat to human health
or the environment either from direct contact with soils in the source area or by continuing to
slowly leach contaminants to groundwater. For these 1reasons, monitored natural attenuation
alone is generally not sufficient to remediate even a p~troleum release site. Implementation of • I
source control measures in conjunction with monitored natural attenuation is almost always
' necessary. Other controls (e.g., institutional controls4), in accordance with applicable state and
federal requirements, may also be necessary to ensure protection of human health and the
environment. Furth=ore, while BTEX contaminants tend to biodegrade with relative ease,
' other chemicals (e.g., methyl tertiary-butyl ether [MTBE]) that are more resistant to biological or
I other degradation processes may also be present in petrolewn fuels. In general, monitored natural
attenuation is not appropriate as a sole remediation option at sites where non-degradable and
nonattenuated contaminants are present at levels that pose an unacceptable risk to human health
or the environment. Where non-degradable contaminEints are present, all processes (listed on
page 4) which contribute to natural attenuation shouJdl be evaluated to ensure protection of
human health and the environment
Cblorinated Solvents
Chlorinated solvents, such as trichloroethylene, represent another class of co=on
contaminants that may also biodegrade under certain environmental conditions. Recent research
has identified some of the mechanisms potentially respbnsible for degrading these solvents, ' furthering the development of methods for estimating biodegradation rates of these chlorinated
compounds. However, the hydrologic and geochemic~I conditions favoring significant
biodegradation of chlorinated solvents may not often obcur. Because of the nature and the
distn1iution of these compounds, natural attenuation m~y not be effective as a remedial option. If
they are not adquately addressed through removal or ci>ntainment measures, source materials can
continue to contaminate groundwater for decades or eJen centuries. Cleanup of solvent spills is
also complicated by the fact that a typical spill includeslmultiple contaminants, including some that
are essentially non-degradable.i Extremely long dissolved solvent plumes have been documented
that may be due to the existence of subsurface conditio~s that are not conducive to natural
attenuation.
4 The term "irutitutional controls" refers to non-engineering measures-usually, but not always, legal controls--
intended to affect human activities in such a way as to prevent or reduce exposure to hazardous substances. Examples of
' institutional control, cited in the National Contingency Plan (USEP4'-, 1990a. p.8706) include land and resource ( e.g.,
water) use and deed rcstrictionB, well-drilling prohibitions, building permits, well use advisories, and deed notices.
5 For example, 1,4-dioxane, which is used as a ,tabilizer for soJe chlorinated solvents, is more highly toxic, less
likely to sorb to aquifer ,olids, and less biodegradable than are other 1solvents under the same environmen!Al conditions .
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OSWER Directive 9200.4-17
Inorganjcs
Monitored natural attenuation may, under certain conditions (e.g., through sorption or
oxidation-reduction reactions), effectively reduce the 1dissolved concentrations and/or toxic forms
I of inorganic contaminants in groundwater and soil. Both metals and non-metals (including
radionuclides) may be attenuated by sorption6 reactio~ such as precipitation, adsorption on the
surfaces of soil minerals, absorption into the matrix of soil minerals, or partitioning into organic
matter.· Oxidation-reduction (redox) reactions can trahsform the valence states of some inorganic
contaminants to less soluble and thus Jess mobile fomis (e.g., hexavalent uranium to tetravalent
uranium) and/or to less toxic forms (e.g., hexavalent dhromium to trivalent chromium). Sorption
and redox reactions are the dominant mechanisms responsible for the reduction of mobility,
toxicity, or bioavailability of inorganic contaminants. !It is necessary to know what specific
mechanism (type of sorption or redox reaction) is responsible for the attenuation of inorganics
because some mechanisms are more desirable than others. For example, precipitation reactions
and absorption into a soil's solid structure (e.g., cesiuln into specific clay minerals) are generally
stable, whereas surface adsorption (e.g., uranium on Jon-oxide minerals) and organic partitioning
(complexation reactions) are more reversible. Comp!e~ation of metals or radionuclides with
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carrier (chelating) agents (e.g., trivalent chromium with EDTA) may increase their concentrations
in water and thus enhance their mobility. Changes in1 a contaminant's concentration, pH, redox
potential, and chemical speciation may reduce a contalninant's stability at a site and release it into
the environment. Determining the existence and dem6nstrating the irreversibility of these
mechanisms are key components of a sufficiently profuctive monitored natural attenuation
rc:medy.
In addition to sorption and redox reactions, raqionuclides exhibit radioactive decay and,
for some, a parent-daughter radioactive decay series. For example, the dominant attenuating
mechanism of tritium (a radioactive isotopic form of hydrogen with a short half-life) is radioactive
decay rather than sorption. Although tritium does not generate radioactive daughter products,
those generated by some radionulides (e.g., Am-241 ahd Np-237 from Pu-241) may be more
toxic, have longer half-lives, and/or be more mobile ilian the parent in the decay series. It is
critical that the near surface or surface soil pathways bb carefully evaluated and eliminated as
potential sources of radiation exposure.
Inorganic contaminants persist in the subsurface because, except for radioactive decay,
they are not degraded by the other natural anenuation processes. Often, however, they may exist
in forms that are less mobile, not bioavailable, and/or non-toxic. Therefore, natural attenuation
6When a conmrninant is associated with a solid phase, it is usually not known if the contaminant is precipitated as a
three-<iimen>ional molecular coating on the ,urfacc of the solid, adi,orbed onto the surface of the solid, ab,orbed into the
,tructure of the solid, or partitioned into organic maner. "Sorption'j will be used in this Directive to describe, in a
generic sense (i.e., without regard to the precise mechanism) the partitioning of aqueous phase constituents to a solid
phase,
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,OSWER Directive 9200.4-17
of inorganic contaminants is most applicable to sites where immobilization or radioactive decay is
demonstrated to be in effect and the process/mechanisb is irreversible.
Advantages and Disadvantages of Monitored Natura! IAnenuatjon
Monitored natural attenuation bas several potltial advantages and disadvantages, and its
use should be carefully considered during site charact~rization and evaluation of remediation
alternatives. Potential advantages of monitored nattiral attenuation include:
•
•
•
As with any in situ process, generation of lesser volume of remediation
wastes, reduced potential for cross-media transfer of contaminants
commonly associated with ex situ treatinent, and reduced risk of human
exposure to contaminated media;
Less intrusion as few surface structures are required;
I Potential for application to all or part of a given site, depending on site
conditions and cleanup objectives;
• Use in conjunction with, or as a follow-up to, other (active) remedial
measures; and
• Lower overall remediation costs than those associated with active
remediation.
The potential disadvantages of monitored natural attenuation include:
•
•
•
•
•
•
Longer time frames may be required to achieve remediation objectives,
compared to active remediation;
Site characterization may be more com lex and costly;
Toxicity of transformation products mal exceed that of the parent
compound;
Long term monitoring will generally be ,necessary;
Institutional controls may be necessary ]to ensure long term protectiveness;
P 'al . fi . d . I . . . di di otentJ exists or contmue contammauon IIUgrallon, an or cross-me a
transfer of contaminants;
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OSWER Directive 9200.4-17
Hydrologic and geochemical conditions amenable to natural attenuation are
likely to change over time and could rekult in renewed mobility of
previously stabilized contaminants, advl:rsely impacting remedial
effectiveness; and
• More extensive education and outreacn efforts may be required in order to
gain public acceptance of monitored n~tural attenuation. ·
IMPLEMENTATION
The use of monitored natural attenuation is not new in OSWER programs. For example,
in the Super-fund program, selection of natural attenuation as an element in a site's groundwater
remedy goes as far back as 1985. Use of monitored nitural attenuation in OSWER programs has
continued since that time, slowly increasing with great~r program experience and scientific
understanding of the processes involved. Recent adv~ces in the scientific understanding of the
processes contributing to natural attenuation have resulted in a heightened interest in this
approach as a potential means of achieving soil and sriiundwater cleanup objectives. However,
complete reliance on monitored natural attenuation is Elppropriate only in a limited set of
circumstances at contaminated sites. The sections which follow seek to clarify OSWER program
I policies regarding the use of monitored natural attenuation. Topics addressed include site
characterization; the types of sites where monitored n~tural attenuation may be appropriate;
reasonable remediation time frames; the importance of1source control; performance monitoring;
and contingency remedies where monitored natural attenuation will be employed.
Roje of Monitored Natural Attenuation io OSWER Rebediation Prom
Under OSWER programs, remedies selected fol contaminated media (such as
contaminated soil and groundwater) must protect humiin health and the environment. Remedies
may achieve this level of protection using a variety of ihethods, including treatment, containment,
engineering controls, and other means identified during the remedy selection process.
The regulatory and policy frameworks for corrlctive actions under the UST, RCRA, and
Superfund programs have been established to implemcilt their respective statutory mandates and
to promote the selection of technically defensible, naticinally consistent, and cost effective
solutions for the cleanup of contaminated media. EPAlrecognizes that monitored natural
' attenuation may be an appropriate remediation option for contamir ted soil and groundwater
under certain circumstances. However, determining thb appropriaL mix of remediation methods
at a given site, including when .md how to use monitorbd natural attenuation, can be a complex
process. Therefore, monitored natural attenuation shoilld be carefully evaluated along with other
viable remedial approaches or technologies (including ilinovative technologies) within the
applicable remedy selection framework. Monitored n~tural attenuation should not be
considered a default or presumptive remedy at any contaminated site.
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OSWER Directive 9200.4-17
Each OSWER program has developed regulations and policies to address the particular
types of contaminants and facilities within its purview[" Although there are differences among
these programs, they share several key principles that should generally be considered during
selection of remedial measures, including:
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Source control actions should use treatment to address "principal threat"
wastes (or products) wherever practicable, and engineering controls such
as containment for waste (or products)\that pose a relatively low long-t=
threat, or where treatment is impracticable.8
Contaminated groundwaters should be letumed to "their beneficial uses9
wherever practicable, within a time frarhe that is reasonable given the
' particular circumstances of the site." When restoration of groundwater is
not practicable, EPA "expects to preve~t further migration of the plume,
prevent exposure to the contaminated groundwater, and evaluate further
risk reduction" (which may be appropri'ate).10
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Contaminated soil should be remediated to achieve an acceptable level of
risk to human and environmental recep/ors, and to prevent any transfer of
7Existing program guidwice wid policy regarding monitored natural attenuation can be obtained from tho following
sources: For Superfund, see "Guidance on Remedial Actions for Ccintaminatod Groundwater at Superfund Sites,"
(USEPA, I 988a; pp. 5-7 and 5-8); the Preamble to the 1990 Nation~! Contingency Plwi (USEPA, 1990a, pp.8733-34);
and "Presumptive Response Strategy and Ex-Situ Treatment Technologies for Contaminated Ground Water at CERCLA
Sites, Final Guidance" (USEPA, 1996a; p. 18), For the RCRA program, see the Subpan S Proposed Rule (USEPA,
1990b, pp.30825 and 30829), and the Advance Notice of Proposed flulemaking (USEP A, 1996b, pp.1945 l -52). For
tho UST program, refer to Chapter IX in "How to Evaluate Alternative Cleanup Technologies for Underground Storage
' Tank Sites: A Guide for Corrective Action Plan Reviewers;" (USEPA, 1995a).
8Principal threat wa&tes are those source materials (e.g., non-aqLous phase liquids [NAPL], saturated soils) thet are
highly toxic or highly mobile that generally cannot be reliably con tallied (USEPA, 1991 ). Low level threat W85tetl are
source materials that can be reliably contained or that would pose only a low risk in the event of exposure.
Contaminated groundwater is neither a principal nor a low-level threat waste.
9 Beneficial uses of groundwater could include uses for which \\lter quality standards have been promulgated, such
as a drinking wau,r supply, or as a source of recharge to surface wate~. or other uses. These or other types of beneficial
uses may be identified as part of a Comprehensive State Groundwatei Protection Program (CSGWPP). For more
infonnation on CSGWPPs, see USEP A, 1992a and 1997b, or contacl your state implementing agency .
I 10 This ii a general expecration for remedy selection in the Superpmd program, as statod in the National
Contingency Plan (USEPA, 1990a, §300.430 (aXl)(iiiXF)). Tho NGP Preamble also specifies that cleanup levels
appropriate for the expocted beneficial use (e.g., MCLs for drinking Jater) "should generally be attained throughout the
contaminated plume, or at and beyond the edge of the waste managen\ent .,-ea when waste is left in place."
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contaminants to other media (e.g., surface or groundwater, air, sediments)
that would result in an unacceptable riik or exceed required cleanup levels.
Consideration or selection of monitored naturli attenuation as a remedy or remedy
component does not in any_way change or displace th~se (or other) remedy selection principles.
Nor does use of monitored natural attenuation diminiJh EPA's or the regulated party's
responsibility to achieve protectiveness or to satisfy lting-term site cleanup objectives.
Monitored natural attenuation is an appropriate temedlatlon method only where its use
will be protective of human health and the enviro~ment and it will be capable of achieving
site-specific remediation objectives nithin a time frame that Is reasonable compared to
other alternatives. The effectiveness of monitored ciltural attenuation in both near-tc:rm and ' long-term time frames should be demonstrated to EP t (or other regulatory authority) through:
1) sound technical analysis which provides confidence in natural attenuation's ability to achieve
remediation objectives; 2) performance monitoring; arid 3) backup or contingency remedies where
appropriate. In summary, use of monitored natudl attenu,ition does not imply that EPA or ' the responsible parties are "walking away" from the cleanup or financial responsibility
obligations at a site.
It also should be emphasized that the selection of monitored natural attenuation as a
remedy does not imply that active remediation measures are infeasible, or are "technically ' impracticable." Technical impracticability (T!) determinations, which EPA makes based on the
inability to achieve required cleanup levels using availJbJe remedial technologies and approaches,
are used to justify a change in the remediation objecti✓1es at Superfund and RCRA sites (USEPA,
1993a). A TI determination does not imply that there ;,vill be no active remediation at the site, nor
that monitored natural attenuation will be used at the site. Rather, a TI determination simply
indicates that the cleanup levels and objectives which iould otherwise be required cannot
practicably be attained within a reasonable time frame 1sing available remediation technologies.
In such cases, an alternative cleanup strategy that is fully protective of human health and the
environment must be identified. Such an alternative strategy may still include engineered
remediation components, such as containment for an al-ea contaminated with dense non-aqueous
phase liquids (DNAPL), in addition to approaches intehded to restore to beneficial uses the
portion of the plume with dissolved contaminants. Se~eral remedial approaches could be
appropriate to address the dissolved plume, one of which could be monitored natural attenuation
under suitable conditions. However, the evaluation of'natural attenuation processes and the
decision to rely ~~on monitored ~atural atten~ation forlthe diss_olved p_lume ~hould be distinct
from the recogrutJ.on that restorauon ofa portion ofthe
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p!ume 1s technically unpractrcable (i.e.,
monitored natural attenuation should not be viewed as a direct or presumptive outcome of a
technical impracticability determination.)
Demonstrating the Efficacy of Natural Attenuation through Site Characterjz,ation
Decisions to employ monitored natural atteJuation as a remedy or remedy
component lihould be thoroughly and adequately shpported with site-specific
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characterlzadon data and analysis. In general, the level of site characterization necessary to
support a comprehensive evaluation of natural attenwition is more detailed than that needed to
support active remediation. Site characterizations for!natural attenuation generally warrant a
quantitative understanding of source mass; groundwati:r flow; contaminant phase distribution and
partitioning between soil, groundwater, and soil gas; r~tes of biological and non-biological
transformation; and an understanding of bow all of thbse factors are likely to vary with time. This
informati1:m is generally necessary since contaminant b1ehavior is governed by dynamic processes
which must be well undastood before natural attenuation can be appropriately applied at a site. . ' Demonstrating the efficacy ofthis remediation approach likely will require analytical or numerical
simulation of complex attenuation processes. Such an~lyses, which are critical to demonstrate
natural attenuation's ability to meet remedial action objectives, generally require a detailed
conceptual site model as a foundation 11 • I
Site characterization should include collecting data to define (in three spatial dimensions
over time) the nature and distribution of contaminatiori sources as well as the extent of the
groundwater plume and its potential impacts on receptbrs. However, where monitored natural
attenuation will be considered as a remedial approach; Fertain aspects of site characterization may
require more detail or additional elements. For example, to assess the contributions of sorption,
dilution, and dispersion to natural attenuation of contartlinated groundwater, a veiy detailed
understanding of aquifer hydraulics, recharge and discharge areas and volumes, and chemical
properties is required. Where biodegradation will be ai;sessed, characterization also should
include evaluation of the nutrients and electron donors land acceptors present in the groundwater,
the concentratiom of co-metabolites and metabolic by-products, and perhaps specific analyses to
identify the microbial populations present. The finding~ of these, and any other analyses pertinent
to characterizing natural attenuation processes, should be incorporated into the conceptual model
of contaminant fate and transport developed for the sitd.
M 'edtural . b I. di'l .. orutor na attenuation may not e appropnate as a reme a option at many sites
for technological or economic reasons. For example, inl some complex geologic systems,
technological limitations may preclude adequate moniuiring of a natural attenuation remedy to
11 A conceptual site model i, a three-dimensional representation that conveys what is known or suspected about
conlJltnination sources, release mechanisma, end the transport end fati: of those conuirninants. The conceptual model
provides the basis for assessing potential remedial technologies at th~, site. "Conceptual site model" is not synonymous
with "computer model;" however, a computer model may be helpful for understanding and visualizing current site
conditions or for predictive simulations of potential future conditions.I Computer models, which simulate site processes
mathematically, should in turn be based upon sound conceptual site rriodels to provide meaningful infonnation.
Compuoor models typically require a lot of data, end the quality ofthe\output from computer models is directly related to
the quality of the input data. Because of the complexity of natural sysr,ems, models necessarily rely on simplifying
assumptions that may or may nor accurately represent the dynamics of the natural 5)'Stem. Calibration and sensitivity
analyse. are important step, in appropriate we of models. Even so, ttie results of computer model, should be carefully
interpreted and continuowly verified with adequate field data. Numetou, EPA references on models are liste<l in the
"Additional References" section at the end of this Directive.
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ensure with a high degree of certainty that potential receptors will not be impacted. This situation
typically occurs in many karstic, structured, and/or frlu:tured rock aquifers where groundwater
moves preferentially through discrete channels (e.g., Jolution channels, foliations, fractures,
joints). The direction of groundwater flow through shch heterogeneous (and often anisotropic)
materials can not be predicted directly from the hydra.Wic gradient, and existing techniques may
not be capable of identifying the channels that carry cbntaminated groundwater through the
subsurface. Monitored natural attenuation will not g~nerally be appropriate where site
complexities preclude adequate monitoring. Although in some situations it may be technically
feasible to monitor the progress of natural attcnuatioti, the cost of site characterization and long-
term monitoring required for the implementation of!rtonitored natural attenuation is high
' compared to the cost of other remedial alternatives. Under such circumstances, natural
attenuation would not necessarily be the low-cost altetnative.
A related coLSideration for site characterizatiol is how other remedial activities at the site
could affect natural attenuation. For example, the capbing of contaminated soil could alter both
the type of contaminants leached to groundwater, as well as their rate of transport and
degradation. Therefore, the impacts of any ongoing ot proposed remedial actions should be
I factored into the analysis of natural attenuation's effectiveness. Wben considering source
containment/treatment together with natural attenuatirin of chlorinated solvents, the potential for
cutting off sources of organic carbon (which are criticil to biodegradation of the solvents) should
be carefully evaluated.
Once the site characterization data have been collected and a conceptual model developed,
the next step is to evaluate the efficacy of monitored niitural attenuation as a remedial approach.
I Three types of site-specific information or "evidence" should be used in such an evaluation:
(1) Historical groundwater and/or soil chelstry data that demonstrate a clear
and meaningful trendn of decreasing cohtaminant mass and/or
concentration over time at appropriate rilonitoring or sampling points. (In
the case of a groundwater plume, decre1+5ing concentrations should not be
solely the result of plwne migration. In the case of inorganic contaminants,
the primary attenuating mechanism shorild also be understood.);
(2) Hydrogeologic and geochemical data thlt can be used to demonstrate
indirectly the type(s) of natural anenuadon processes active at the site, and
the rate at which such processes will red~ce contaminant concentrations to
required levels. For example, characteriiation data may be used to quantify
the rates of contaminant sorption, dilutidn, or volatilization, or to •
12 For guidance on the .tatistical analysis of environmental data, please see USEPA, 1989 and 1992b, listed in the
"References Ched" section at tho end of this Directive.
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OSWER Directive 9200.4-17
demonstrate and quantify the rates ofbiologieal degradation processes
occurring at the site;
Data from field or microcosm studies (conducted in or with actual
contaminated site media) which directly demonstrate the occurrence of a
particular natural attenuation process ~t the site and its ability to degrade
the contaminants of concern (typically1 used to demonstrate biological
degradation processes only).
Unless EPA or the implementing state agency determines that historical data
(Number 1 above) are of ,ufficient quality and dtiratlon to support a decision to use
monitored natural attenuation, EPA expects that 1data characterizing the nature and rates
of natural attenuation processes at the site (Num~er 2 above) should be provided. Where
the latter are also inadequate or inconclusive, dat~ from microcosm studies (Number 3
above) may also be necessary. In general, more supporting information may be required to
demonstrate the efficacy of monitored natural attenuation tt those sites with contaminants which
do not readily degrade through biological processes (li.g., most non-petroleum compounds,
inorganics), at sites with contaminants that transform futo more toxic and/or mobile forms than
the parent contaminant, or at sites where monitoring hil.s been performed for a relatively short
period of time. The amount and type of information nbeded for such a demonstration will depend
upon a number of site-specific factors, such as the size1 and nature of the contamination problem,
the proximity of receptors and the potential risk to thoke receptors, and other physical
characteristics of the environmental setting (e.g., hydrtigeology, ground cover, or climatic
conditioru,). I
Note that those parties responsible for site c~terization and remediation should ensure
that all data and analyses needed to demonstrate the efficacy of monitored natural attenuation ' are collected and evaluated by capable technical specialists with expertise in the relevant sciences.
' Further, EPA expects that the results will be provided in a timely manner to EPA or to the state
implementing agency for evaluation and approval.
Sjtes Where Monitored Natura) Attenuation May Be Appropriate
Monitored natural attenuation is appropriate as i remedial approach only where it can be
demonstrated capable of achieving a site's remedial obj6ctives within a time frame that is
reasonable compared to that offered by other methods aild where it meets the applicable remedy ' selection criteria for the particular OSWER program. EPA expects that monitored natural
attenuation will be most appropriate when used In t:onJunction with active remediation
measures (e.g., source control), or as a follow-up to ~ctive remediation measures that have
already been Implemented
In detennini.ng whether monitored natural attenuation is an appropriate remedy for soil or
groundwater at given site, EPA or other regulatory auth~rities should consider the following:
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OSWER Directive 9200.4-17
Whether the contaminants present in soil or groundwater can be effectively
remediated by natllla.l attenuation proce~ses;
Whether the resulting transformation prJducts present a greater risk than
do the parent contaminants;
The nature and distribution of sources of: contamination and whether these
• I sources have been or can be adequately controlled;
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Whether the plume is relatively stable or is still migrating and the potential
for environmental conditions to change 6ver time;
Th . f . . d d .I d' . th e unpact o existing an propose active reme 1at1on measures upon e
monitored natural attenuation component of the remedy;
Whether drinking w~ter supplies, other skundwaters, surface waters,
ecosystems, sediments, air, or other envitonmental resources could be
adversely impacted as a consequence of JeJecting monitored natural
attenuation as the remediation option;
Whether the estimated time frame ofremediation is reasonable (see below)
compared to time frames required for oth~r more active methods (including
the anticipated effectiveness of various relnedial approaches on different
portions of the contaminated soil and/or b-oundwater);
Current and projected demand for the afflcted aquifer over the time period
that the remedy will remain in effect (inchiding the availability of other
water supplies and the loss of availability 1of other groundwater resources
due to contamination from other sources)! and
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Whether reliable site-specific vehicles for implementing institutional
controls (i.e., zoning ordinances) are available, and if an institution
responsible for their monitoring and enfortement can be identified..
For example, evaluation of a given site may deteiine that, once the source area and
higher concentration portions of the plume are effective!~ contained or remediated, lower
concentration portions of the plume could achieve cleanup standards within a few decades
through monitored natural attenuation, if this time frame is comparable to those of the more
aggressive methods evaluated for this site. Also, rnonitor~d natural attenuation would more likely
be appropriate if the plume is not expanding, nor threatening downgradient wells or surface water
bodies, and where ample potable water supplies are availJble. The remedy for this site could
include source control, a pump-and-treat system to mitigate only the highly-contaminated plume
areas, and monitored natural attenuation in the lower contentration portions of the plume. In
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combination, these methods would maximize groundwater restored to beneficial use in a time
frame consistent with future demand on the aquifer, wliile utilizing natural attenuation processes
to reduce the reliance on active remediation methods (imd reduce cost).
I Of the above factors, the most important considerations regarding the suitability of
I monitored natural attenuation as a remedy include whether the groundwater contaminant plume is
growing, stable, or shrinking, and any risks posed to hupian and environmental receptors by the
contamination. Monitored natural attenuation should not be used where such an approach
would result in significant contaminant migration 6r unacceptable impacts to receptors.
Therefore, sites where the contaminant plumes are no l6nger increasing in size, or are shrinking in
size, would be the most appropriate candidates for rnoriitored natural attenuation remedies.
Reasonableness of Remediation Time Frame
The longer remediation time frames typically associated with monitored natural
' attenuation should be compatible with site-specific land and groundwater use scenarios.
Remediation time frames generally should be estimated 1ror all remedy alternatives undergoing
detailed analysis, including monitored natural attenuatioh 13• Decisions regarding the
"reasonableness" of the remediation time frame for any given remedy alternative should then be
evaluated on a site-specific basis. While it is expected that monitored natural attenuation may
require somewhat longer to achieve remediation objecti~es than would active remediation, the
overall remediation time frame for a remedy which re!iek in whole or in part on monitored natara1
attenuation should not be excessive compared to the oilier remedies considered. Furthermore,
subsurface conditions and plume stability can change o✓er the extended timeframes that are
necessary for monitore<l natural attenuation.
Defining a reasonable time frame is a complex and site-specific decision. Factors that
should be considered when evaluating the length of timd appropriate for remediation include:
• Classification of the affected resource (e,k., drinking water source,
agricultural water source) and value ofilie resource14;
13 EPA recognizes that predictions of remediation time frames may involve significant uncertainty; however, such
predictions are very useful when comparing two or more remedy alteriiatives.
1' In determining whether an· exlended remediation time frame mt be appropriate for the site, EPA and otho,-
rogulatory authorities ,hould consider state groundwater resource clasSifica.tion.9, priorities and/or valuations where
available, in addition to relevant federal guidelines.
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Relative time frame in which the affected portions of the aquifer might be
needed for future water supply (includirig the availability of alternate
supplies);
Uncertainties regarding the mass of contaminants in the subsurface and
predictive analyses (e.g., remediation ~e frame, timing of future demand,
and travel_ time for contaminants to reach points of exposure appropriate
for the site);
Reliability of monitoring and of institutional controls over long time
periods;
Public acceptance of the extended time for remediation; and
Provisions by the responsible party for a~equate funding of monitoring and
performance evaluation over the period tequired for remediation.
Finally,' individual states may provide informatidn and guidance relevant to many of the
factors discussed above as part of a Comprehensive Stile Groundwater Protection Program
(CSGWPP). (See USEPA, 1992a) Where a CSGWPP\has been developed, it should be
consulted for groundwater resource classification and other information relevant to determining
I required cleanup levels and the urgency of the need for the groundwater. Also, EPA remediation
programs generally should defer to state deterrninations1 of current and future groundwater uses,
when based on an EPA-endorsed CSGWPP that has prdvisions for site-specific decisions
(USEPA, 1997b).
Thus, EPA or other regulatory authorities shoula consider a number of factors when
' evaluating reasonable time frames for monitored natural attenuation at a given site. These factors,
on the whole, should allow the regulatory agency to det6rmine whether a natural attenuation
remedy (including institutional controls where applicablJ) will fully protect potential human and
environmental receptors, and whether the site remediaticin objectives and the time needed to meet
them are consistent with the regulatory expectation that bontaminated groundwaters will be
returned to beneficial uses within a reasonable time frarn1e. When these conditions cannot be met
using monitored natural attenuation, a remedial altemati~e that does meet these expectations
should be selected instead.
Remediation of Contamjnation Sources and Hishly Contaminated Areas
The need for control measures for contamination sources and other highly contaminated
areas should be evaluated as part of the remedy decision ,process at all sites, particularly where
monitored natural attenuation is under consideration as the remedy or as a remedy component.
Source control measures include removal, treatment, or dontainrnent measures (e.g., physical or
hydraulic control of areas of the plume in which NAPLs 1are present in the subsurface). EPA
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prefers remedial options which remove or treat contaminant sources when such options are
technically feasible.
Contaminant sources which are not adequate!~ addressed complicate the long-term
cleanup effort. For example, following free product recovery, residual contamination from a
petroleum fuel spill may continue to leach significant quantities of contaminants into the
groundwater. Such a lingering source can unacceptab\y extend the time necessary to reach
remedial objectives. This leaching can occur even while contaminants are being naturally
attenuated in other parts of the plume. If the rate of attenuation is lower than the rate of
replenishment of contaminants to the groundwater, thd plume can continue to expand and
threaten downgradicnt receptors.
Control of source materials is the most effective means of ensuring the timely attainment
ofremediation objectives. EPA, therefore, expects that source control measures will be evaluated
for all contaminated sites and that source control meashres will be taken at most sites where
practicable.
Performance Monitoring
Performance monitoring to evaluate remedy effectiveness and to ensure protection of
human health and the environment is a critical element bf all response actions. Performance
' monitoring is of even greater importance for monitored natural attenuation than for other types of
remedies due to the longer remediation time frames, po\ential for ongoing contaminant migration,
' and other uncertainties associated with using monitored natural attenuation. This emphasis is
underscored by EPA' s reference to "monitored natural ~ttenuation".
The monitoring program developed for each sitJ should specify the location, frequency,
and type of samples and measurements necessary to evaluate remedy performance as well as
define the anticipated performance objectives of the retriedy. In addition, all monitoring programs
should be designed to accomplish the following:
• Demonstr?'e that natural attenuation is occurring according to
expectations;
• Identify any potentially toxic transformation products resulting from
biodegradation;
• Determine if a plume is expanding (either downgradient, laterally or
vertically);
• Ensure no impact to downgradient receptors;
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Detect new releases of contaminants to1 the environment that could impact
the effectiveness of the natural attenuation remedy;
Demonstrate the efficacy of institutionJi controls that were put in place to
protect potential receptors;
Detect changes in environmental conditions (e.g., hydro geologic,
geoch=ical, microbiological, or other thanges) that may reduce the
efficacy of any of the natural attenuatioi processes15; and
Verify attainment of cleanup objectives .
Performance monitoring shonld continue as long as contamination remains above
required cleanup level!!. Typically, monitoring is continued for a specified period (e.g., one to
three years) after cleanup levels have been achieved to bsure that concentration levels are stable
and remain below target levels. The institutional and ful.ancial mechanisms for maintaining the
monitoring program should be clearly established in thd remedy decision or other site documents,
as appropriate.
Details of the monitoring program should be provided to EPA or the State implementing
agency as part of any proposed monitored natural attentation remedy. Fur.her information on the
types of data useful for monitoring natural attenuation performance can be found in the ORD
publications (e.g., USEPA, 1997a, USEPA, 1994a) list~d in the "References Cited" section of this ' Directive, Also, USEPA (1994b) published a detailed ~ocument on collection and evaluation of
performance monitoring data for pump-and-treat remediation systems.
Contingency Remedies
A contingency remedy is a cleanup technology or approach specified in the site remedy
decision document that functions as a "backup" remedy 1in the event that the "selected" remedy
fails to perform as an~cipated. A contingency remedy rriay specify a technology (or technologies)
that is (are) different from the selected remedy, or it may
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simply call for modification and
enhancement of the selected technology, if needed. Contingency remedies should generally be
flexiblf>-allowing for the incorporation of new information about site risks and technologies.
Contingency remedies are not new to OSWER pl grams. Contingency remedies should
be employed where the selected technology is not provei\ for the specific site application, where
15Detection of changes will depend on the proper siting w,d construction of monitoring wells/points. Although the
siting of monitoring wells is • concern for any remediation technology! it is of even greater concern with monitored
natural attenuation because of the lack of engineering controls to contrbl contaminant migration.
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there is significant uncertainty regarding the nature and extent of contamination at the time the
remedy is selected, or where there is uncertainty regariiing whether a proven technology will
perform as anticipated under the particular circumstances of the site.
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It is also recommended that one or more criteria ("triggers") be established, as ' appropriate, in the remedy decision document that will signal unacceptable performance of the
selected remedy and indicate when to implement contiligency measures. Such criteria might
include the following: ·
•
•
•
Contaminant concentrations in soil or groundwater at specified locations
exhibit an increasing trend;
Near-source wells exhibit large concentration increases indicative of a new
or renewed release; 1
· Contaminants are identified in sentry/s tine! wells located outside of the
original plume boundary, indicating ren~wed contaminant migration;
C ' . d I . ffi . I 'd ontammant concentrations are not ecreasmg at a su c1ent y rap1 rate
to meet the remediation objectives; and
• Changes in land and/or groundwater use will.adversely affect the
protectiveness of the monitored narural ~ttenuation remedy.
In establishing triggers or contingency remediJ, however, care is needed to ensure that
sampling variability or seasonal fluctuations do not set t>ff a trigger inappropriately. For example,
an anomalo.us spike in dissolved concentration(s) at a JeU(s), which may set off a trigger, might
not be a true indication of a change in trend.
EPA recommends that remedies employing monitored natural attenuation be evaluated to
determine the need for including one or more contingedcy measures that would be capable of
achieving remediation objectives. EPA believes that a dontingency measure may be particularly
appropriate for a monitored narura! attenuation remedy -lvruch has been selected based primarily
on predictive analysis (second and third lines of evidende discussed previously) as compared to
narura! attenuation remedies based on historical trends cif actual monitoring data ( first line of
evidence).
SUMMARY
The use of monitored narura! attenuation does not signify a change in OSWER's
remediation objectives; monitored natural attenuation s!iould be selected only where it will be
' fully protective of human health and the environment. EPA does not view monitored natural ' attenuation to be a "no action" remedy, but rather considers it to be a means of addressing
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contamination under a limited set of site circumstances where its use meets the applicable
statutory and regulatory requirements. Monitored natural attenuation is not a "presumptive" or
"default" remediation alternative, but rather shot.Id bd evaluated and compared to other vi.able ' remediation methods (including innovative technologies) during the study phases leading to the
selection of a remedy. The decision to implement mo1nitored natural attenuation should include a
comprehensive site characterization, risk assessment 1here appropriate, and measures to control
sources. Also, monitored natural attenuation should riot be used where such an approach would
result in significant contaminant migration or unaccep
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table impacts to receptors and other
environmental resources. In addition, the progress of1natural attenuation towards a site's
remediation objectives should be carefully monitored and compared with e;,:pectations to ensure
that it will meet site remediation objectives within a tiine frame that is reasonable compared to
time frames associated with other methods. Where mbnitored natural attenuation's ability to meet ' these eXpectations is uncertain and based predominantly on predictive analyses, decision-makers
should incorporate contingency measures into the rembdy,
EPA is confident that monitored natural attenultion will be, at many sites, a reasonable
and protective component of a broader remedial strategy. However, EPA believes that there will
be many other sites where uncertainties too great or a need for a more rapid remediation will
preclude the use of monitored natural attenuation as a hand-alone remedy, This Directive should
I help promote consistency in how monitored natural attenuation remedies are proposed, evaluated,
and approved.
REFEREl'lCES CITED
United States Environmental Protection Agency (USEPA), 1988a, Section 5J.3J. Natural
attenuation with monitoring, Guidance on remedial aqtions for contaminated groundwater at
Superfand sites, OSWER Directive 9283.1-2, EP A/540/G-88/003, Office of Solid Waste and
Emergency Response. Washington, D.C,
United States Environmental Protection Agency, 1989. Methods for evaluation attainment of
' cleanup standards, Vol, 1: Soils and solid media, EP A/230/02-89-042, Office of Solid Waste.
Washington, D,C.
United States Environmental Protection Agency. 1990a, National oil and hazardous substances
pollution contingency plan (NCP); final rule, Federal Rkgister 55, no. 46:8706 and 8733-34,
Washington, D,C.
United States Environmental Protection Agency, 1990b. Corrective action for releases from
solid waste management units at hazardous waste manakement facilities; proposed rule, Federal
Register 55, no, 145:30825 and 30829. Washington, I:J,C.
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OSWER Directive 9200.4-17
United States Environmental Protection Agency. 1991. A guide to principal threat and low level
threat wastes, Superfund Publication 9380.3-06FS (FS:ct Sheet), Office of Emergency Remedial
Response. Washington, D.C.
United States Environmental Protection Agency. 1992a. Final comprehensive state ground
' water protection program guidance, EPA 1 00-R-93-001, Office of the Administrator.
Washington, D.C.
United States Environmental Protection Agency. 1992b. Methods for evaluating attainment of
cleanup standards, Vol. 2: Ground water, EP N230-Rl92-014, Office of Solid Waste.
Washington, D.C.
United States Environmental Protection Agency. 1993a. Guidance for evaluating the technical
impracticability of ground-water restoration, OSWERl Directive 9234.2-25, EP N540-R-93-080,
Office of Solid Waste and Emergency Response. Washington, D.C.
United States Environmental Protection Agency, 1994l. Proceedings of Symposium on natural I . attenuation of groundwater, EP A/600/R-94/162, Office of Research and Development.
Washington, D.C.
United States Environmental Protection Agency. 1994b. Methods for monitoring pump-and-
treat performance, EPN600/R-94/123, Office ofRese!irch and Development. Washington, D.C.
United States Environmental Protection Agency. 1995l Chapter IX: Natural attenuation. How
to evaluate alternative cleanup technologies for underground storage tank sites: A guide for
corrective action plan reviewers, EPA 51 0-B-95-007, Office of Underground Storage Tanks.
Washington, D.C.
United States Environmental Protection Agency. 1996~, Presumptive response strategy and
ex-situ treatment technologies for contaminated groundl water at CERCLA sites, Final Guidance,
OSWER Directive 9283.1-12, EPA 540-R-96-023, Office of Solid Waste and Emergency
Response. Washington, D.C .
United States Environmental Protection Agency. 1996b. Corrective action for releases from
solid waste management units at hazardous waste mana~ement facilities; advance notice of
proposed rulemaking, Federal Register 61, no. 85:19451-52.
United States Environmental Protection Agency. 1997a.l Proceedings of the symposium on
natural attenuation of chlorinated organics in groundwciter; Dallas, Texas, September 11-13,
EPN540/R-97/504, Office of Research and Developmerit. Washington, D,C.
21
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OSWER Directive 9200.4-17
United States Environmental Protection Agency. 1997b. The role ofCSGWPPs in EPA
remediation programs, OSWER Dim:tive 9283.1-091
, EPA F-95-084, Office of Solid Waste and
Emergency Response. Washington, D.C.
ADDmONAL REFERENCES
American Academy ofEnvironmental Engineers. 19~5. Innovative site remediation technology,
Vol. J; Bioremediation, ed. W.C. Anderson. Annapolis, Maryland.
American Society for Testing and Materials. (Forthcdming). Provisional standard guide for
accelerated site characterization for confirmed or suipected petroleum releases, ASTM PS 3-95.
Conshohocken, Pennsylvania.
American Society for Testing and Materials. (Forthcoming). Standard guide for remediation of
groundwater by natural attenuation at petroleum relehse sites. Conshohocken, Pennsylvania.
Black, H. 1995. Wisconsin gathers evidence to suppdrt intrinsic bioremediation. The
bioremediation report, August:6-7.
Borden, R.C., C.A. Gomez, and M.T. Becker. 1995. Geochemical indicators of intrinsic
bioremediation. Ground Water 33, no.2:180-89.
Hinchee, R.E., J.T. Wilson, and D.C. Downey. 1995. Intrinsic bioremediation. Columbus,
Ohio: Battelle Press.
Klecka, GM., J.T. Wilson, E. Lutz, N. Klier, R. West, J. Davis, J. Weaver, D. Kampbell, and B.
Wilson. 1996. Intrinsic remediation of chlorinated solvents in groundwater. Proceedings of
intrinsic bioremediation conference, London Wl, Unitbd Kingdom, March 18-19.
McAllister, P.M., and C.Y. Chiang. 1993. A practical \approach to evaluating natural attenuation
of contaminants in groundwater. Groundwater Monitoting & Remediation 14, no.2:161-73. ·
New Jersey Depanment ofEnvirurunental Protection. 1996. Site remediation program,
technical requirements for site remediation, proposed rbadoption with amendments: N.J.A.C.
7:26E, authorized by Robert J. Shinn, Jr., Commissiond.
Norris, R.D., R.E. Hinchee, R.A. Brown, P.L: McCarty! L. Semprini, J.T. Wilson, D.H.
Kampbell, M. Reinhard, E.J. Bouwer, R.C. Borden, T.M. Vogel, J.M. Thomas, and C.H. Ward.
1994. Handbook of bioremediatio11. Boca Raton, Flori~a: Lewis Publishers.
Salanitro, J.P. 1993. The role ofbioattenuation in the lanagement of aromatic hydrocarbon
I
plumes in aquifers. Groundwater Monitoring & Remediation 13, no. 4:150-61.
22
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OSWER Directive 9200.4-17
United States Department of the Anny. 1995. Interim Anny policy on natural attenuation for
environmental restoration, (12 September) Memorandlirn from the Assistant Chief of Staff for
Installation Management Washington, D.C.: the Pendgon.
United States Environmental Protection Agency. 19781. Radionuclide interactions with soil and
rock media, Vol. 1: Element chemistry and geochemistry, EPA 520/6-78-007, Office of Research
and Development. Washington, D.C.
United States Environmental Protection Agency. 1988b. Groundwater modeling: an overview
and status report, EPA/600/2-89/028, Office ofReseari:h and Development. Washington, D.C.
United States Environmental Protection Agency. 19921. Quality assurance and control in the
' development and application of ground-water models, EPA/600/R-93/011, Office of Research
· and Development Washington, D.C.
United States Environmental Protection Agency. 1993b. Compilation of ground-water models,
EP A/600/R-93/118, Office of Research and Developmeht. Washington, D.C.
United States Environmental Protection Agency. 1994J. The hydrocarbon spill screening model
(HSSM}, Vol. 1: User's guide, EPA/600/R-94-039a, Office of Research and Development ·
Washington, D.C.
United States Environmental Protection Agency. 1994~. Assessment framework for ground-
water model applications, OSWER Directive 9029.00, EPA 500-B-94-003, Office of Solid Waste
and Emergency Response. Washington, D.C.
United States Environmcntal Protection Agency. 1994e. Ground-water modeling compendium,
EPA 500-B-94-004, Office of Solid Waste and Emergenty Response. Washington, D.C.
United States Environmental Protection Agency. l 994f. A technical guide to ground-water
model selection at sites contaminated with radioactive substances, EPA 402-R-94-012, Office of
Air and Radiation. Washington, D,C.
United States :Environmental Protection Agency. 1994g., Guidance for conducting external peer
review of environmental models, EPA 100-B-94-001, Office of Air and Radiation. Washington,
D.C.
United States Environmental Protection Agency. 1994h. Report of the agency task force on
environmental regulatory modeling, EPA 500-R-94-001, Office of Air and Radiation. ·
Washington, D.C.
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OSWER Directive 9200.4-17
United States Environmental Protection Agency. 1995a. The hydrocarbon spill screening model I (HSSM), Vol. 2: Theoretical background and source codes, BP A/600/R-94-039b, Office of
Research and Development. Washington, D.C.
United States Environmental Protection Agency. 1~96c. Documenting ground-water modeling
at sites contaminated with radioactive substances, EPA 540-R-96-003, Office of Air and
Radiation. "Washington, D.C.
United States Environmental Protection Agency. 1996d. Three multimedia models used at
hazardous and radioactive waste sites, EPA 540-R-96-004, Office of Air and Radiation.
Washington, D.C.
United States Environmental Protection Agency. ! 996e. Notes of Seminar--Bioremediation of
hazardous waste sites: Practical approaches to impl~mentation, EPA 51 0-B-95-007, Office of
Research and Development. Washington, D.C.
United States Environmental Protection Agency. 1997c. (Draft) Geochemical processes ' affecting sorption of selected contaminants, Office of Radiation and Indoor Air. Washington,
D.C.
United States Environmental Protection Agency. l 99i7d. (Draft) The Kd model and its use in
contaminant transport modeling, Office of Radiation and Indoor Air. Washington, D.C.
I United States Environmental Protection Agency, Air Force, Army, Navy, and Coast Guard.
1996a. Commonly asked questions regarding the use\ofnatural attenuation for chlorinated
solvent spills at federal facilities, Fact Sheet, Federal Facilities Restoration and Re-Use Office.
Washington, D.C.
United States Environmental Protection Agency, Air Force, Army, Navy, and Coast Guard.
1996b. Commonly asked questions regarding the use~of natural attenuation for petroleum
contaminated sites at federal facilities, Fact Sheet, Federal Facilities Restoration and Re-Use
Office. Washington, D.C.
Wiedemeier, T.H., J.T. Wilson, D.H. Kampbell, R.N. Niiller, and J.E. Hansen. 1995. Technical
protocol for implementing intrinsic remediation with l&ng-term monitoring for natural
attenuation offael contamination dissolved in ground..:Vater. United States Air Force Center for
Environmental Excellence, Technology Transfer Divisibn, Brooks Air Force Base, San Antonio,
Texas.
Wiederneier, T.H., J.T. Wilson, D.H. Karnpbell, J.E. Hansen, and P. Haas. 1996. Technical
; .rotocol for evaluating the natural attenuation of chlo~ated ethenes in groundwater.
Proceedings of the petroleum hydrocarbons and organic chemicals in groundwater: Prevention,
detection, and remediation conference, Houston, Texa~. November 13-15.
24
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OSWER Directive 9200.4-17
Wilson, J.T., D.H. Kampbell, and J. Armstrong. 1993. Natural bioreclamation of alky!benzenes
(BTEX) from a gasoline spill in methanogenic grouhdwater. Proceedings of the second
international symposium on in situ and on site biorkmediation, San Diego, California, April 5-8.
Wisconsin Department ofNatural Resources. 1993] ERRP issues guidance on natural ·
biodegradation. Release News, Emergency and Reriiedial Response Section, February, vol. 3, no.
1.
OTHER SOURCES OF INFORMATION
IJSEPA Internet Web Sjtes
http://www.epa.gov/ORD/W ebPubs/biorem/
Office of Research and Development, information on passive and active bioremediation
http://www.epa.gov/ada/kerrlab.html
Office of Research and Development, RS. Kerr Environmental Research Laboratory
http://www.epa.gov/OUST/cat/natatt.htm
Office of Underground Storage Tanks, information on natural attenuation
http://www.epa.gov/swerffi:r/chlorine.htm
Federal Facilities Restoration and Reuse Office, fact sheet on natural attenuation of
chlorinated solvents
http://www.epa.gov/swerffi:r/petrol.htm
Federal Facilities Restoration and Reuse Office, Fact sheet on natural attenuation of
petroleum contaminated sites
http://www.epa.gov/hazwaste/ca/subparts.htm
Office of Solid Waste, information on RCRA Subpart S
http://www.epa.gov/swerosps/bf/
Office of Outreach Programs, Special Projects, and Initiatives, information on Brown.fields
Oth11r Internet Web Sites
http://clu-in.com
Technology Innovation Office, information on hazardou.s site cleanups
25
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B-3 AFCEE PROPOSED PROTOCOL FOR
NATURAL ATTENUATION
\ \TN\SYS'\DATA l'HOJ\0JJ:1.02\nppendix rnwr~.doc
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Overview of the Technical Protocol for Natural Attenuation of Chlorinated
I Aliphatic Hydrocarbons in Ground Water Under Development for the
I
U.S.Air Force Center for Environmental Excellence
Todd H. Wiedemeier, Matthew A. Swanson, and David E. Moutoux
Parsons Engineering Science, lhc., Denver, Colorado I
John T. Wilson and Donald H. Kampbell
I
U.S. Environmental Protection Agency, National Risk Management Research Laboratory, I Ada, Oklahoma
I • Jerry E. Hansen and P1atrick Haas
U.S. Air Force Center for Environmental Excellence, Technology Transfer Division,
Brooks Air Fprce B~se, Texas
Introduction
Over the past several years, natural attenuation has
become increasingly accepted as a remedial alternative
for organic compounds dissolved in ground water. The
U.S. Environmental Protection Agency's (EPA) Office of
Research and Development and Office of Solid Waste and
Emergency Response define natural attenuation as:
The biodegradation, dispersion, dilution, sorption,
volatilization, and/or chemical and biochemical sta·
bilization of contaminants to effectively reduce con·
taminant toxicity, mobility, or volume to levels that
are protective of human health and the ecosystem.
In practice, natural attenuation has several other names,
such as intrinsic remediation, intrinsic bioremediation, or
passive bioremediation. The goal of any site charac·
terization effort is to understand the fate and transport
of the contaminants of concern over time in order to
assess any current or potentiar threat to human health
or the environment. Natural attenuation processes, such
as biodegradation, can often be dominant factors in the
fate and transport of contaminants. Thus, consideration
and quantification of natural attenuation is essential to
more thoroughly understand contaminant fate and
transport.
This paper presents a technical protocol for data col lee·
tion and analysis in support of remediation by natural
attenuation to restore ground water contaminated with
chlorinated aliphatic hydrocarbons and ground water
37
contaminated with mixtures of fuels and chlorinated ali·
phatic hydrocarbons. In some cases, the information
coll~cted using this protocol will show that natural at·
tenu~tion processes, with or without source removal, will
redu1ce the concentrations of these contaminants to be·
low 1risk·based corrective action criteria or regulatory
standards before potential receptor exposure pathways
are tompleted. The evaluation should include consid·
eratibn of existing exposure pathways as well as expo•
sure! pathways arising from potential future use of the
ground water.
This I protocol is intended to be used within the estab·
lished regulatory framework. It is not the intent of this
I • document to replace existing EPA or state-specific guid·
anc~ on conducting remedial investigations.
ovJrview of the Technical Prctocol
NatJal attenuation in ground-water systems results
froml the integration of several subsurface attenuation
mechanisms that are classified as either destructive or
' nondestructive. Biodegradation is the most important
destluctive attenuation mechanism. Nondestructive at·
tenuktion mechanisms include sorption, dispersion, di·
lutioh from recharge, and volatilization. The natural
atte~uation of fuel hydrocarbons is described in the
Tecljnical Protocol for Implementing Intrinsic Remedia·
lion With Long· Term Monitoring for Natural Attenuation
of FJel Contaminatio.~ Dissolved in Groundwater recently
publikhed by the U.S. Air Force Center for Envir~nmental
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Excellence (AFCEE) (1 ). This document differs from the
tecbnical protocol for intrinsic remediation of fuel hydro-
carbons because the individual processes of chlorinated
aliphatic hydrocarbon biodegradation are fundamentally
different from the processes involved in the biodegrada-
tion of fuel hydrocarbons.
For example, biodegradation of fuel hydrocarbons, es-
pecially benzene, toluene, ethylbenzene, and xylenes
(BTEX), is mainly limited by electron acceptor availabil-
ity, and biodegradation of these compounds generally
will proceed until all of the contaminants are destroyed.
In the experience of the authors, there appears to be an
inexhaustible supply of electron acceptors in most, if not
all, hydrogeologic environments. On the other hand, the
more highly chlorinated solvents (e.g., perchloroethene
and trichloroethene) typically are biodegraded under
natural conditions via reductive dechlorination, a proc-
ess that requires both electron acceptors {the chlorin-
ated aliphatic hydrocarbons) and an adequate supply of
electron donors. Electron donors include fuel hydrocar-
bons or other types of anthropogenic carbon (e.g., land-
fill leachate, BTEX, or natural organic carbon). If the
subsurface environment is depleted of electron donors
before the chlorinated aliphatic hydrocarbons are re-
moved, reductive dechlorination will cease, and natural
attenuation may no longer be protective of human health
and the environment. This is the most significant differ-
ence between the processes of fuel hydrocarbon and
chlorinated aliphatic hydrocarbon biodegradation.
For this reason, it is more difficult to predict the long-term
behavior of chlorinated aliphatic hydrocarbon plumes
than fuel hydrocarbon plumes. Thus, it is important to
have a thorough understanding of the operant natural
attenuation mechanisms. In addition to having a better
understanding of the processes of advection, disper-
sion, dilution from recharge, and sorption, it is necessary
to better quantify biodegradation. This requires a thor-
ough understanding of the interactions between chlorin-
ated aliphatic hydrocarbons, anthropogenic/natural
carbon, and inorganic electron acceptors at the site.
Detailed site characterization is required to adequately
understand these processes.
Chlorinated solvents are released into the subsurface
under two possible scenarios: 1) as relatively pure sol-
vent mixtures that are more dense than water, or 2) as
mixtures of fuel hydrocarbons and chlorinated aliphatic
hydrocarbons which, depending on the relative propor-
tion of each, may be more or less dense than water. I These products commonly are · referred to as
"nonaqueous-phase liquids," or NAPLs. If the NAPL is
more dense than water, the material is referred to as a
I "dense nonaqueous-phnse liquid," or DNAPL. If the
NAPL is less dens, :han water, the material is referred
to as a "light nonaqueous-phase liquid," or U-JAPL. In I general, the greatest mass of contaminant is associated
I
38
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with these NAPL source areas, not with the aqueous
I phase.
I As ground water moves through or past the NAPL
sourcb areas, soluble constituents partition into the
movi~g ground water to generate a plume of dissolved
contahiination. After further releases have been
I stopp1ed, these NAPL source areas tend to slowly
weat~er away as the soluble components, such as
BTEX or trichloroethene, are depleted. In cases where
sourde removal or reduction is feasible, it is desirable to
remo~e product and decrease the time required for com-
plete I remediation of the site. At many sites, however,
mobile NAPL removal is not feasible with available tech-
nology. In fact, the quantity of NAPL recovered by com-
monly used recovery techniques is a trivial fraction of
the t~tal NAPL available to contaminate ground water.
Mobile NAPL recovery typically recovers less than 1 O
perc~nt of the total NAPL mass in a spill.
Com~ared with conventional engineered remediation
technologies, natural attenuation has the following
I advantages:
• oJring natural attenuation, contaminants are .ultimately
trar,sfonned to innocuous byproducts (e.g., carbon di-
oxide, ethene, and water), not just transferred to an-
other phase or location in the environment.
N I I . . . . • atura attenuation Is nonintrus1ve and allows con-
tinl.iing use of infrastructure during remediation.
• E~gineered remedial technologies can pose greater
risk to potential receptors than natural attenuation
be1cause contaminants may be transferred into the
atlnosphere during remediation activities.
• NJtural attenuation is less costly than currently avail-
able remedial technologies, such as pump-and-treat.
• NJtural attenuation is not subject to the limitations of
mechanized remediation equipment (e.g., no equip-
ment downtime).
• T~ose compounds that are the most mobile and toxic
ar~ generally the most susceptible to biodegradation.
Natula1 attenuation has the following limitations:
N I I . . b" . • atura attenuation Is su Ject to natural and anthro-
pdgenic changes· in local hydrogeologic conditions,
intluding changes in ground-water gradients and ve-
lotity, pH, electron acceptor concentrations, electron
ddnor concentrations, and/or potential future con-
talninant releases.
• AJuifer heterogeneity may complicate site charac-
terization and quantification of natural attenuation.
• Tile frames for complete remediation may be rela-
• I 1 t1vely ong.
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• Intermediate products of biodegradation (e.g., vinyl
chloride) can be more toxic than the original contaminant.
This document describes those processes that bring
about natural attenuation, the site characterization ac-
tivities that may be performed to support a feasibility
study to include an evaluation of natural attenuation,
natural attenuation modeling using analytical or numeri-
cal solute fate-and-transport models, and the post-
modeling activities that should be completed to ensure
successful support and verification of natural attenu-
ation. The objective of the work described herein is to
quantify and provide defensible data in support of natu-
ral attenuation at sites where naturally occurring subsur-
face attenuation processes are capable of reducing
dissolved chlorinated aliphatic hydrocarbon and/or fuel
hydrocarbon concentrations to acceptable levels. A
comment made by a member of the regulatory commu-
nity (2) summarizes what is required to successfully
implement natural attenuation:
A regulator looks for the data necessary to deter-
mine that a proposed treatment technology, if prop-
erly installed and operated, will reduce · the
contaminant concentrations in the soil and water to
legally mandated limits. In this sense the use of
biological treatment systems calls for the same level
of investigation, demonstration of eff, tiveness, and
monitoring as any conve_ntional [remediation] system.
To support remediation by natural attenuation, the pro-
ponent must scientifically demonstrate that degradation
of site contaminants is occurring at rates sufficient to be
protective of human health and the environment. Three
lines of evidence can be used to support natural attenu-
ation of chlorinated aliphatic hydrocarbons, including:
• Observed reduction in contaminant concentrations
along the flow path downgradient from the source of
contamination.
• Documented loss of contaminant mass at the field
scale using:
-Chemical and geochemical analytical data (e.g.,
decreasing parent compound concentrations, in-
creasing daughter compound concentrations, de-
pletion of electron acceptors and donors, and
increasing metabolic byproduct concentrations).
-

A

conservative tracer and a rigorous estimate of
residence time along the flow path to document
contaminant mas·; reduction and to calculate bio-
logical decay rates at the field scale·.
• 1'1icrobiological laboratory data that support the oc-
currence of biodegradation and give rates of biode-
gradation.
At a minimum, the investigator must obtain the first two
lines of evidence or the first and third lines of evidence.
The second and third lines of evidence are crucial to the
39
naiulal attenuation de~onstration because they provide
biod~gradation rate constants. These rate constants are
used in conjunction with the other fate-and-transport
parahieters to predict contaminant concentrations and
to assess risk at downgradient points of compliance.
I
The first line of evidence is simply an observed reduction
in the concentration of released contaminants down-
gradient from the NAPL source area along the ground-
watJr flow path. This line of evidence does not prove
that tontaminants are being destroyed because the re-
duction in contaminant concentration could be the result
of advection, dispersion, dilution from recharge, sorp-
tion, land volatilization with no loss of contaminant mass
(i.e.,lthe majority of apparent contaminant loss could be
due to dilution). Conversely, an increase in the concen-
tratidns of some contaminants, most notably degrada-
tion products such as vinyl chloride, could be indicative
of natural attenuation.
To sLpport remediation by natural attenuation at most
sites! the investigator will have to show that contaminant
mass is being destroyed via biodegradation. This is
don~ using either or both of the second or third lines of
evidJnce. The second line of evidence relies on chemi-
cal a'nd physical data to show that contaminant mass is
being destroyed via biodegradation, not just diluted. The
second line of evidence is divided into two components:
• uJing chemical analytical data in mass balance cal-
culations to show that decreases in contaminant and
elktron acceptor and donor concentrations can be
di/ectly correlated to increases in metabolic end
prbducts and daughter compounds. This evidence
I can be used to show that electron acceptor and do-
ndr concentrations in ground water are sufficient to
facilitate degradation of dissolved contaminants. Sol-
ute fate-and-transport models can be used to aid
mass balance calculations and to collate information
or/ degradation.
• uJing measured concentrations of contaminants
arid/or biologically recalcitrant tracers in conjunction
' with aquifer hydrogeologic parameters, such as
se'epage velocity and dilution, to show that a reduc-
tioh in contaminant mass is occurring at the site and
to !calculate biodegradation rate constants.
The third line of evidence, microbiological laboratory
data,I can be used to provide additional evidence that
indigenous biota are capable of degrading site contami-
nants at a particular rate. Because it is necessary to
sho1 that biodegradation is occurring and to obtain
biodegradation rate constants, the most useful type of
micrcibiological laboratory data is the microcosm study.
This ~aper presents a technical course of action that
allow~ converging lines of evidence to be used to scien-
tifically document the occurrence and quantify the rates
of nat~ral attenuation. Ideally, the first two lines of evidence
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should be used in the natural attenuation demonstration.
To further document natural attenuation, or at sites with
complex hydrogeology, obtaining a field-scale biodegra·
dation rate may not be possible; in this case, microbi-
ological laboratory data can be used. Such a
"weight-of-evidence" approach will greatly increase the
likelihood of successfully implementing natural attenu-
ation at sites where natural processes are restoring the
environmental quality of ground water.
Collection of an adequate database during the iterative
site characterization process is an important step in the
documentation of natural attenuation. Site charac-
terization should provide data on the location, nature,
and extent of contaminant sources. Contaminant sour-
ces generally consist of hydrocarbons present as mobile
NAPL (i.e., NAPL occurring at sufficiently high satura-
tions to drain under the influence of gravity into a well)
and residual NAPL (i.e., NAPL occurring at immobile,
residual saturation that is unable to drain into a well by
gravity). Site characterization also should provide infor-
mation on the location, extent, and concentrations of
dissolved contamination; ground-water geochemical
·data; geologic information on the type and distribution
of subsuriace materials; and hydrogeologic parameters
suc:i as hydraulic conductivity, hydraulic gradients, and
potential contaminant migration pathways to human or
ecological receptor exposure points.
The data collected during site characterization can be
used to simulate the fate and transport of contaminants·
in the subsuriace. Such simulation allows prediction of
the future extent and concentrations of the dissolved
contaminant plume. Several models can be used to
simulate dissolved contaminant transport and attenu-
ation. The natural attenuation modeling effort has three
primary objectives: 1) to predict the future extent and
concentration of a dissolved contaminant plume by
simulating the combined effects of advection, disper-
sion, sorption, and biodegradation; 2) to assess the po·
tential for downgradient receptors to be exposed to
contaminant concentrations that exceed regulatory or
risk-based levels intended to be protective of human
health and the environment; and 3) to provide technical
supoort for the natural attenuation remedial option at
pas ·,,odeling regulatory negotiations to help design a
more accurate verification and monitoring strategy and
to help identify early source removal strategies.
Upon completion of the fate-and-transport modeling ef-
fo;·., model predictions can be used in an exposure
pathways analysis. If natural attenuation is sufficient to
mitigate risks to potential receptors, the proponent of
natural attenuation has a reasonable basis for negotiat-
ing this option with regulators. The exposure pathways
analysis allows the proponent to show that pot.~ntial
exposure pathways to receptors will not be completed.
40
The !material presented herein was prepared through
I the joint effort of the AFCEE Technology Transfer Divi-
sion:! the Bioremediation Research Team at EPA's Na-
tion'\\ Risk Management Research Laboratory in Ada,
Oklahoma (NRMRL), Subsurface Protection and Reme-
diatic\n Division; and Parsons Engineering Science, Inc.
(Padons ES). This compilation is designed to facilitate
implementation of natural attenuation at chlorinated ali-
phatic hydrocarbon-contaminated sites owned by the
U.S. !Air Force and other U.S. Department of Defense
agencies, the U.S. Department of Energy, and public
inter~sts.
ovJrview of Chlorinated Aliphatic
Hydrocarbon Biodegradation
BecJuse biodegradation is the most important process
acting to remove contaminants from ground water, an
accurate estimate of the potential for natural biodegra-
datioh is important to obtain when determining whether
grouhd-water contamination presents a substantial
thre~t to human health and the environment. This infor-
mation also will be useful when selecting the remedial
alter~ative that will be most cost-effective in eliminating
or abating these threats should natural attenuation
alone not prove to be sufficient.
I Over
1
the past two decades, numerous laboratory and
field studies have demonstrated that subsurface micro·
orgarisms can degrade a variety of hydrocarbons and
chlorinated solvents (3-23). Whereas fuel hydrocarbons
are biodegraded through use as a primary substrate
(electron donor), chlorinated aliphatic hydrocarbons
may I undergo biodegradation through three different
pathways: through use as an electron acceptor, through
I •
use as an electron donor, or through co-metabolism,
where degradation of the chlorinated organic is fortui·
tous 1and there is no benefit to the microorganism. At a
giveri site, one or all of these processes may be operat-
' ing, although at many sites the use of chlorinated ali-
phatic hydrocarbons as electron acceptors appears to
be niost important under natural conditions. In general,
but iri this case especially, biodegradation of chlorinated
aliphktic hydrocarbons will be an electron-donor-limited
process. Conversely, biodegradation of fuel hydrocar·
bonsl is an electron-acceptor-limited process.
In a ~ristine aquifer, native organic carbon is used as an
election donor, and dissolved oxygen (DO) is used first
as the pri:·,1e electron acceptor. Where anthropogenic
I carbon (e.g., fuel hydrocarbon) is present, it also will be
used! as an electron donor. After the DO is consumed,
anaerobic microorganisms typically use additional elec·
tron kcceptors (3s available) in the following order of
prefe1rence: nitrate, ferric iron oxyhydroxide, sulfate, and
finally carbon dioxide. Evaluation of the distribution of
these electron acceptors can provide evidence of where
and how cl,lorinated aliphatic hydrocarbon biodegradation
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is occurring. In addition, because chlorinated aliphatic
• hydrocarbons may be used as electron acceptors or
electron donors (in competition with other acceptors or
donors), isopleth maps showing the distribution of these
compounds can provide evidence of the mechanisms of
biodegradation working at a stte. As with BTEX, the driving
force behind oxidation-reduction reactions resulting in
chlorinated aliphatic hydrocarbon degradation is elec-
tron transfer. Although thermodynamically favorable,
most of the reactions involved in chlorinated aliphatic
hydrocarbon reduction and oxidation do not proceed
abiotically. Microorganisms are capable of carrying out
the reactions, but they will facilitate only those oxidation-
reduction reactions that have a net yield of energy.
Mechanisms of Chlorinated Aliphatic
Hydrocarbon Biodegradation
Electron Acceptor Reactions (Reductive
Dechlorination)
Th·e most important process for the natural biodegrada-
tion of the ·more highly chlorinated sol•.'ents is reductive
dechlorination. During this process, the chlorinated hy-
drocarbor, is used as an electron acceptor, not as a
source of carbon, and a chlorine atom is removed and
replaced with a hydrogen atom. In general, reductive
dechlorination occurs by sequential dechlorination from
perchloroethene to trichloroethene to dichloroethene to
vinyl chloride to ethene. Depending on environmental
conditions, this sequence may be interrupted, with other
processes then acting on the products. During reductive
dechlorination, all three isomers of dichloroethene can
theoretically be produced; however, Bouwer (24) reports
that under the influence of biodegradation, c,s-1,2-di-
chloroethene is a more common intermediate than
lrans-1,2-dichloroethene, and that 1, 1-dichloroethene is
the least prevalent intermediate of the three dichlo-
roethene isomers. Reductive dechlorination of chlorin-
ated solvent compounds is associated with all
accumulation of daughter products and an increase in
the concentration of chloride ions.
Reductive dechlorination affects each .of the chlorinated
ethenes differently. Of these compounds, perchlo-
roethene is the most susceptible to reductive dechlori-
nation because it is the most oxidized. Conversely, vinyl
chloride is the least susceptible to reductive dechlorina-
tion because it is the least oxidized of these compounds.
The rate of reductive dechlorination also has been ob-
served to decrease as the degree of chlorination de-
creases (24, 25). Murray and Richardson (26) have
postulated that this rate decrease may explain the ac-
cumulation of vinyl chloride in perchloroethene and
trichloroethenc plumes that are undergoing reductive
dechlorination.
41
ReLctive dechlorina;ion has been demonstrated under
nitrkte-and sulfate-reducing conditions, but the most
rap.id biodegradation rates, affecting the widest range of
chlorinated aliphatic hydrocarbons, occur under methane-
' genie conditions (24). Because chlorinated aliphatic hy-
' dro~arbon compounds are used as electron acceptors
during reductive dechlorination, there must be an appro-
' priate source of carbon in order for microbial growth to
occ'ur (24). Potential carbon sources include natural
orgknic matter, fuel hydrocarbons, or other organic com-
poJnds such as those found in landfill leachate.
E/Jctron Donor Reactions I . Murray and Richardson (26) write that microorganisms
are !generally believed to be incapable of growth using
tric~loroethene and perchloroethene as a primary sub-
strate (i.e., electron donor). Under aerobic and some
ana1erobic conditions, the less-oxidized chlorinated ali-
phatic hydrocarbons (e.g., vinyl chloride) can be used as
the primary substrate in biologically mediated redox re-
actions (22). In this type of reaction, the facilitating micro-
org~nism obtains energy and organic carbon from the
I degraded chlorinated aliphatic hydrocarbon. This is the
process by which fuel hydrocarbons are biodegraded.
I In contrast to reactions in which the chlorinated aliphatic
hyd(ocarbon is used as an electron acceptor, only the
least oxidized chlorinated aliphatic hydrocarbons can be
used as electron donors in biologically mediated redox
I reactions. McCarty and Semprini (22) describe investi-
gatibns in which vinyl chloride and 1,2-dichloroethane
wer~ shown to serve as primary substrates under aero-
bic conditions. These authors also document that dichlo-
' romethane has the potential to function as a primary
subJtrate under either aerobic or anaerobic environ-
ments. In addition, Bradley and Chapelle (27) show
evidbnce of mineralization of vinyl chloride under iron-
' reducing conditions so long as there is sufficient
bioa\lailable iron(lII). Aerobic metabolism of vinyl chlo-
rid,, !may be characterized by a loss of vinyl chloride
mass and a decreasing molar ratio of vinyl chloride to
othet chlorinated aliphatic hydrocarbon compounds.
Co-~etabolism
Whe'.n a chlorinated aliphatic hydrocarbon is biode-
graded via co-metabolism, the degradation is catalyzed
I by ar e_nzyme or cofactor that is fortuitously produced
by t~e organisms for other purposes. The organism
recei~es no known benefit from the degradation of the
chlorinated aliphatic hydrocarbon; in fact, the co-metabolic
degr~dation of the chlorinated aliphatic hydrocarbon
may be harmful to the microorganism responsible for the
prodUction of the enzyme or cofactor (22).
Co-~etabolism is best documented in aerobic environ-
ments, although it could occur under anaerobic condi-
tions! It has been reported that under aerobic condilions
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chlorinated e:henes, with the exception of perchlo-
roethene, are susceptible to co-metabolic degradation
(22, 23, 26). Vogel (23) further elaborates that the co-
metabolism rate increases as the degree of dechlorina-
tion decreases. During co-metabolism, trichloroethene
is indirectly transformed by bacteria as they use BTEX
or another substrate to meet their energy requirements.
Therefore, trichloroethene does not enhance the degra-
dation of BTEX or other carbon sources, nor will its co-me-
tabolism interfere with the use of electron acceptors
involved in the oxidation of those carbon sources.
Behavior of Chlorinated Solvent Plumes
Chlorinated solvent plumes can exhibit three types of
behavior depending on the amount of solvent, the
amount of biologically available organic carbon in the
aquifer, the distribution and concentration of natural
electron acceptors, and the types of electron acceptors
being used. Individual plumes may exhibit all three types
of behavior in different portions of the plume. The differ-
ent types of plume behavior are summarized below.
Type 1 Behavior
Type 1 behavior occurs where the primary substrate is
anthropogenic carbon (e.g., BTEX or landfill leachate),
and this anthropogenic carbon drives reductive dechlori-
nation. When evaluating natural attenuation of a plume
exhibiting Type 1, behavior the following questions must I be answered:
1. Is the electron donor supply adequate to allow
microbial reduction of the chlorinated organic
I compounds? In other words, will the microorganisms
"strangle" before they "starve"-will they run out of
chlorinated aliphatic hydrocarbons (electron
I acceptors) before they run out of electron donors?
2. What is the role of competing electron acceptors
(e.g., DO, nitrate, iron(III), and sulfate)? I 3. Is vinyl chloride oxidized, or is it reduced?
Type 1 behavior results in the rapid and extensive deg-
I radation of the highly chlorinated solvents such as per-
chloroethene, trichlnroethene, and dichloroethene.
I
Type 2 Behavior
Type 2 behavior dominates· in areas that are charac-
terized by relatively high concentrations of biologically
available native organic carbon. This natural carbon
I source drives reductive dechlorination (i.e., is the pri-
mary substrate for microorganism growth). When evalu-
ating natural attenuation of a Type 2 chlorinated solvent
I plume, the same ~uestions as those posed for Type 1
behavior must be answered. Type 2 behavior generally
results in slower biodegradation of the highly chlorin-1 atcd solvents t11an Type 1 behnvior, but under the right
I
42
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conditions (e.g., areas with high natural organic carbon
contJnts) this type of behavior also can result in rapid
I • degradation of these compounds.
Typl 3 Behavior
Type\ 3 behavior dominates in a;eas that are charac-
terized by low concentrations of native and/or anthropo-
genid carbon and by DO concentrations greater than
1.0 rrtilligrams per liter. Under these aerobic conditions,
reduttive dechlorination will not occur; thus, there is no
remo\lal of perchloroethene, trichloroethene, and dichlo-
roethkne. The most significant natural attenuation
I mechanisms for these compounds is advection, disper-
sion, [and sorption. However, vinyl chloride can be rap-
idly oxidized under these conditions.
MixJd Behavior
A sin61e chlorinated solvent plume can exhibit all three
types]of behavior in different portions of the plume. This
can ~e beneficial for natural biodegradation of chlori-
nated aliphatic hydrocarbon plumes. For example,
Wiedrmeier et al. (28) describe a plume at Plattsburgh
Air Force Base, New York, that exhibits Type 1 behavior
in th~ source ·area and Type 3 behavior downgradient
from the source. The most fortuitous scenario involves
a plulne in which perchloroethene, trichloroethene, and
dichlciroethene are reductively dechlorinated (Type 1 or
2 behavior). then vinyl chloride is oxidized (Type 3 be-
haviot) either aerobically or via iron reduction. Vinyl
chloride is oxidized to carbon dioxide in this type of
I •
plume and does not accumulate. The following se-
' quence of reactions occurs in a plume that exhibits this
type df mixed behavior:
I Perchloroethene ---> Trichloroethene ---,
Dicroroethene---> Vinyl chloride---> Carbon dioxide
The trichloroethene, dichloroethene, and vinyl chloride
may ~ttenuate at approximately the same rate, and thus
these ]reactions may be confused with simple dilution.
Note that no ethene is produced during this reaction.
Vinyl thloride is removed from the system much faster
under[these conditions than it is under vinyl chloride-re-
ducing conditions.
A lessldesirable scenario-but one in which all contami-
nants may be entirely biodegraded-involves a plume
in whith all chlorinated aliphatic hydrocarbons are re-
ductiv~ly dechlorinated via Type 1 or Type 2 behavior.
Vinyl dhloride is reduced to ethene, which may be further
I reduced to ethane or methane. The following sequence
of reattions occurs in this type of plume:
I Perchloroethene ---> Trichloroethene ....,
Diehl• roethene ---> Vinyl chloride ---> Ethene ---> Ethane
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This sequence has been investigated by Freedman and
-Gossett (13). In this type of plume, vinyl chloride de-
grades more slowly than trichloroethene and thus tends
to accumulate.
Protocol for Quantifying Natural
Attenuation During the Remedial
Investigation Process
The primary objective of the natural attenuation investi-
gation is to show that natural processes of contaminant
degradation will reduce contaminant concentrations in
ground water to below risk-based corrective action or regu-
latory levels before potential receptor exposure pathways
are completed. This requires a projection of the potential
e,:tent and conc,:-ntration of the contaminant plume in time
and space. The projection should be based on historic
variations in, and the current extent and concentrations
of, the contaminant plume, as well as the measured
rates of contaminant attenuation. Because of the inher-
ent uncertainty associated with such predictions, the
investigator must provide sufficient evidence to demon-
strate that the mechanisms of natural attenuation will
reduce contaminant concentrations to acceptable levels
before potential receptors are reached. This requires the
use of conservative solute fate-and-transport model in-
put parameters and numerous sensitivity analyses so
that consideration is given to all plausible contaminant
migration scenarios. When possible, both historical data
and modeling should be used to provide information that
collectively and consistently supports the natural reduc-
tion and removal of the dissolved contaminant plume.
Figure 1 outlines the steps involved in the natural at-
tenuation demonstration. This figure also shows the
important regulatory decision points in the process of
implementing natural attenuation. Predicting the fate of
a contaminant plume requires the quantification of sol-
ute transport and transformation processes. Quantifica-
tion of contaminant migration and attenuation rates and
successful implementation of the natural attenuation re-
medial option requires completion of the following steps:
1. Review available site data, and develop a preliminary
conceptual model.
2. Scr~en the site, and assess the potential for natural
attenuation.
3. Collect additional site characterization data to support
natural attenuation, as required.
4. Refine the conceptual model, complete premodeling
colculations, and document indicators of natural
attenuation.
5. Simulate natural attenuation using analytical or
numerical solute fa:e-and-transport models that allow
incorpomtion of a biodegradation term, as necessary.
43
I 6. Identify potential receptors, and conduct an
I • exposure-pathway analysis.
I 7. ~valuate the practicability and potential efficiency of
fupplemental source removal options.
B. If natural attenuation with or without source removal
i;s acceptable, prepare a long-term monitoring plan.
9. Present findings to regulatory agencies, and obtain
approval for remediation by natural attenuation.
Re~iew Available Site Data, and Develop a
Preliminary Conceptual Model
ExJting site characterization data should be reviewed
andlused to develop a conceptual model for the site. The
preliminary conceptual model will help identify any
sho(icomings in the data and will allow placement of
additional data collection points in the most scientifically
adv~ntageous and cost-effective manner. A conceptual
model is a three-dimensional representation of the
I gro~nd-water flow and solute transport system based on
available geological, biological, geochemical, hydrologi-
cal, 1plirnatological, and analytical data for the site. This
type
1
of conceptual model differs from the conceptual site
models that risk assessors commonly use that qualita-
tively consider the location of contaminant sources, re-
leas~ mechanisms, transport pathways, exposure
poinfs, and receptors. The ground-water system con-
ceptual model, however, facilitates identification of these
risk-kssessment elements for the exposure pathways
analysis. After development, the conceptual model can
be used to help determine optimal placement of addi-
tion~! data collection points (as necessary) to aid in the
natutal attenuation investigation and to develop the sol-
1 ute fate-and-transport model.
Con/racting and management controls must be flexible
I enough to allow for the potential for revisions to the
conc1eptual model and thus the data collection effort. In
case~ where few or no site-specific data are available,
all future site characterization activities should be de'
signJd to collect the data necessary to screen the site
to dJtermine the potential for remediation by natural
atten1uation. The additional costs incurred by such data
collettion are greatly outweighed by the cost savings
that fill be realized if natural attenuation is selected.
lvlorepver, most of the data collected in support of natu-
ral attenuation can be used to design and support other
remedial measures.
Table! 1 contains the soil and ground-water analytical
protopol for natural attenuation of chlorinated aliphatic
hydr~carbons and/or fuel hydrocarbons. Table 1 A lists a
standard set of methods, while Table 1 B lists methods
I that ~re under development and/or consideration. Any
plan to collect additional ground-water and soil quality
data Jhould include targeting the analytes listed in Table
I • 1 A, and possibly Table 1 B.
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Review Available Site Data and
Develop Preliminary Conceptual Model
Screen the Site using the Procedure
Presented in Figure 3
I
Collect More Screening Data
I
NO
NO ►Y.:.;E~S::._ __ -4.i Engineered Remediation Required,
Implement Other Protocols
Perform Site Characterization
I to Support Remedy Decision Making
Evaluate Use ot1 '>-"NC:0'-----41 Selected Additional 1(:-----,
Remedial Options
,0'.)ng with I
Natural Attenuation
Perform Site Characterization
to Support Natural Attenuation
Refine Conceptual McxJel and
Complete Pre-McxJeling
Calculations
Simulate Natural Attenuation
Using Solute Fate and
Transport Models
Initiate Verification ot
Natural Attenuation
using Long-Term Monitoring
Use Results of Modeling and
Site-Specific Information in an
Exposure Pathways Analysis
YES
NO
Vacuum
Dewatering
I
Develop Dratt Plan tor
Point-Of-Compliance
Monitoring Wells and Lona-Ter · ·
Present Findings
and Proposed
Remediation Strategy
o Regulatory Agencies
Figure 1. Natural attenuation o1 chlorinated solvents flow chart.
44
Reactive
B;irrie-r
NO
Assess Potential For
Natural Attenuation
With Remediation
System Installed
Refine Conceptual Model and
Complete Pre-Modeling
Calculations
Simulate Natural Attenuation
Combined with Remedial
Option Selected Above
Using Solute Transport Model
Initiate Verification of
Natural Attenuation
using Long-Term Monitoring
Use Results of Modeling and
Site-Specific Information in
an Ex osure Assessment
ised Re
tegy Meet Re
bjectives Wrtho
nacceptable
To Paten
e
YES
I Table 1 A. Soll and Ground-Water Analytical Protocol11
Recommended Sample Volume, Field or
I
Frequency of Sample Container, Fixed-Base
Matrix Analysis Method/Reference b--e Comments1·g Data Use Analysis Sample Preservation Laboratory
Soil Volatile SW8260A Handbook Useful for determining Each soil Collect 100 g of soil Fixed-base
organic method the extent of sbil sampling round in a glass container
0 compounds modified for contamination, lthe with Teflon-lined cap;
field extraction contaminant mass cool to 4°C
of so!I using present, and the need
methanol for source rembval
I I
Soil Total SW9060, modified Procedure Toe amount of 1TOC At initial Collect 100 g of soil Fixed-base
organic for soil samp~es must be in the aquifer matrix sampling in a glass container
carbon accurate over influences I with Teflon-lined cap;
(TOG) the range of contaminant migration cool to 4°C
I 0.5 to 15%' and biodegradcition
TOG
Useful for deteLning Soil o,, co, Field soil gas At initial Reuseable 3-L Field
gas analyzer bioactivity in the sampling and Tedlar bags • vadose 2one I respiration
testing
Soil Fuel and EPA Method Useful for determining At initial 1-L Summa canister Fixed-base
gas chlorinated T0-14 the distribution 'of sampling
I volatile chlorinated andj BTEX
organic compounds in soil
compounds
Method of anaitis for
I
Water Volatile SW8260A Handbook Each sampling Collect water Fixed-base
organic method; BTEX and chlofinated round samples in a 40-ml
compounds analysis may solvents/byprodllcts volatile organic
be extended to analysis vial; cool to
higher 4°C; add hydrochloric
I molecular-acid to pH 2
weight alkyl
benzenes
Water Polycyclic Gas chromatography/ Analysis PAHs are components As required by Collect 1 L of water Fixed-base
I aroma!ic mass spectroscopy needed only of fuel and are I regutalions in a glass container;
hydro-Method SW82708; when required typically ana1yz~d for cool to 4°C
carbons high-performance for regulatory regulatory compliance
(PAHs) liquid chromatography compliance
I (opliona!; IJethod SW8310
intended
for diesel
and other
heavy oils)
I Water Oxygen DO meter Refer to Concentrations less Each sampling Measure DO on site Field
Method A4500 than 1 mg/L gen'craHy round using n flow-through
for a indicate an ana9robic cell
comparable pathway
I laboratory
procedure
Water Nitrate Iron chromatography Method E300 Substrate for microbial Each sampling Collect up to 40 ml Fixed-base
I
IJ\ethod E30D; anion is a handbook respiration if oxy9en round of water in a glass or
method method; also is depleted plastic container; add
provides H2 SO4 to pH less
chloride data 1han 2; cool 10 4 °c
I Water lron(II) Colorimetric HACH Filler if turbid tllay indicate an Each sampling Collecl 100 ml of Field
(Fc'2) Method 8146 anaerobic degradation round water in a glass
process due to I container
depletion of oxygen,
nilrate, and
I manganese
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D Table 1A. Soll and Ground-Water Analytical Protocol' (Continued)
Recommended Sample Volume, Field or
Frequency of Sample Container, Fixed-Base
D Matrix Analysis M ethod/Refe renceb•e Comments1·g Data Use Analysis Sample Preservation Laboratory
Water Sulfate Iron chromatography Method E300 Substrate for I· Each sampling Collect up to 40 ml E300 =
(SO4-2) Method E300 or is a handbook anaerobic microbial ,ound of water in a glass or Fixed-base
D HACH Method 8051 method, HACH respiration plastic container; cool
Method 8051 to 4°C HACH
is a Method
colorimetric 8051 = Field
I
method; use
one or the
other
Water Methane, Kampbell et al. (35) Method The presence of ICH4 Each sampling Collect water Fixed-base
I ethane, or SW3810, modified published by suggests round samples in SO-ml
and ethene EPA biodegradation of glass serum bottles
re!':earchers organic carbon via with butyl
methanogensis; I gray/Teflon-lined
ethane and ethane caps; add H2S04 to
I are produced during pH less than 2; cool
reductive to 4°C
dechlorination
Water Alkalinity HACH alkalinity test Phenolphtalein Water quality Each sampling Collect 100 ml of Field
I kit Model AL AP MG-L method parameter used to round water in glass
measure the buttering container
capacity of ground
water; can be used to
I estimate the amoUnt
of CO2 produced I
during biodegradation
Water Oxidation-A2580B Measurements The oxidation-\ Each sampling Collect 100 to Field
I reduclion made with reduction potential round 250 ml of water
potential electrodes, of ground water in a glass container
results are influences and is
displayed on a influenced by the
meler, protect nature of the
I samples from biologically mediated
exposure to degradation of I
oxygen; repor1 contaminants; the
results against oxidation-reduction
I a silver/silver polential of groun~
chloride water may range from
reference more than 800 mV to
electrode less than -400 mVI
I Water pH Field probe with Field Aerobic and Each sampling Collect 100 to Field
direct reading meter anaerobic processes round 250 ml of water
are pH-sensitive in a glass or plastic
container; analyze
I
immediately
Water Temperature Field probe with Field only Well development Each sampling Not applicable Field
direct reading meter round
I Waler Conductivi1y E120.1/SW9050, Protocols/ Water quality Each sampling Collect 100 to 250 Field
direct reading meter Handbook parameter used as
1
a round ml of water in a
methods marker to verify that glass or plastic
sile samples are \ conlainer
obtained from the
I same ground-water
system
V.'ater Chloride t..-1ercuric nitrate !on Final product of Each sampling Col!ect 250 ml of Fixed-base
titration /..,4500-c1· C chroma1ography chlorinated solvent round water in a glass
I Method E300; reduction; can be container
Method used lo csHmale
SW9050 may dilulion in calculation
also be used of rate constant
I
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I
0 Table 1 A. Soll and Ground-Water Analytical Protocol' (Continued)
Recommended Sample Volume, Field or
u Frequency of Sample Container, Fixed-Base
Matrix Analysis Method/A eferenceb•e Comments1·g Data Use Analysis Sample Preservation Laboratory
I
Water Chloride HACH chloride test Silver nitrate As above, and to Each sampling Collect 100 ml of Field
I (optional; kit Model 8-P titration guide selection Of round waler in a glass
see data additional data Points container
use) in real time while in
the field
I Water Total SW9060 laboratory Used to classify Each sampling Collect 100 ml of Laboratory
organic plumes and to round water in a glass
carbon determine whether container; cool
anaerobic metab101ism
of chlorinated solvents
I is possible in the1
absence of [
anthropogenic ~rbon
I
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a Analyses other than those listed in this table may be required for regulatory qompliance.
b "SW" refers to the Test Methods for Evaluating Solid Waste, Physical, and Chemical Methods (29).
c "E" refers to Methods for Chemical Analysis of Water and Wastes (30). I
d "HACH" refers to the Hach Company catalog (31 ).
0 "A" refers to Standard Methods for the Examination of Water and Wastewate'i (32).
1 "Handbook" refers to the AFCEE Handbook to Support the Installation Restoration Program (!RP) Remedial Investigations and Feasibility
Studies (RVFS) (33). I .
9 "Protocols" refers to the AFCEE Environmental Chemistry Function Installation Restoration Progra0 Analytical Protocols (34).
I
I Table 1 B. Soll and Ground•Water Analytical Protocol: Special Analyses Under Development aildlor Consideration8•b
Recommended Sample Volume, Field or
I
Frequency Container, Fixed•Base
Matrix Analysts Method/Reference Comments Data Use of Analysis Preservation Laboratory
To predict th~ Soil Biologically Under development HCI One round of Collect minimum Laboratory
I available iron(III) extraction possible extent of sampling in 1·inch diameter
followed by iron reductiol in five borings, core samples into
quantification an aquifer five cores a plastic liner; cap
of released from each and prevent
iron(l11) boring aeration
I Water Nutritional Under developmenl Spectra-To determine the One round of Collect 1,000 ml Laboratory
quality of native photometric extent of redUctive sampling in in an amber glass
organic matter method dech!orlnatiorl two to five container
allowed by the wells
I supply of e!eciron
donor I
Water Hydrogen {H2) Equilibration with Specialized To determine lhe One round of Sampling a1 well Field
gas in the field; analysis terminal elec\ron sampling head requires the
I determined with a accepting prdcess; production of 100
reducing gas predicts the I ml per minute of
detector possibility forl water for 30
reductive minutes
I dechlorina lion
Waler Oxygenates SW82G0IB015' Laboratory Con1-,minanl 1or At least one Collect 1 L of Laboratory
{including electron dondrs sampling water in a glass
methyl-/Cr!-buty1 for dechlorina'.tion rc:::~md or as container:
I ether, ethers, of solvents determined preserve with HCI
acetic acid, by regulators
methanol, and
acetone)
I :, Analyr.c:s other th::in those listed in this table may be required for regu!;:itory cofTipliance.
t, Site characlcrirnlion £:ho"Jld no\ be delayed if these methods are unavailable. I
c: MSV,f' refers to Test !Acttic,ds /or Evaluating Solid W,1ste, Physical and Chemical Methods (29).
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Screen the Site, and Assess the Potential for
Natura, Attenuation
After reviewing available site data and developing a
preliminary conceptual model, an assessment of the
potential for natural attenuation must be made. As stated
previously, existing data can be useful in detenmining
whether natural attenuation will be sufficient to prevent
a dissolved contaminant plume from completing expo-
sure pathways, or from reaching a predetermined point
of compliance, in concentrations above applicable regu-
latory or risk-based corrective action standards. Deter-
mining the likelihood of exposure pathway completion is
an important component of the natural attenuation in-
vestigation. This is achieved by estimating the migration
and future extent of the plume based on contaminant
properties, including volatility, sorptive properties, and
biodegradability; aquifer properties, including hydraulic
gradient, hydraulic conductivity, porosity, and total or-
ganic carbon (TOC) · content; and the location of the
plume and contaminant source relative to potential re-
ceptors (i.e., the distance between the leading edge of
the plume and the potential receptor exposure points).
These parameters (estirpated or actual) are used in this
section to make a preliminary assessment of the effec-
tiveness of natural attenuation in reducing contaminant
concentrations.
If, after completing the steps outlined in this section, it
appears that natural attenuation will be a significant
factor in contaminant removal, detailed site charac-
terization activities in support of this remedial option
should be performed. If exposure pathways have al-
ready been completed and contaminant concentrations
exceed regulatory levels, or if such completion is likely,
othei remedial measures should be considered, possi-
. bly in conjunction with natural attenuation. Even so, the
I ·collection of data in support of the natural attenuation
option can be integrated into a comprehensive remedial
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plan and may help reduce the cost and duration of other
remedial measures, such as intensive source removal
operations or pump-and-treat technologies. For exam-
ple, dissolved iron concen_trations can have a profound
influence on the design of pump-and-treat systems.
Based on the experience of the authors, in an estimated
80 percent of fuel hydrocarbon spills at federal facilities,
natural attenuation alone will be protective of human
health and the environment. For spills of chlorinated
aliphatic hydrocarbons at federal facilities, however,
natural attenuation alone will be protective of human
health and the environment in an estimated 20 percent
of the cases. Wi•h this in mind, it is easy to understand
why an accurate assessment of the potential for natural
biodegradation of chlorinated compounds should be
made before investing in a detailed study of natural
attenuation. The "~reening process presented in this
section is outlined in Figure 2. This approach should
48
allol the investigator to determine wheth.er natural attenu-
1 ation is likely to be a viable remedial alternative before
add~ional time and money are expended. The data re-
quir~ to make the preliminary assessment of natural
attehuation can also be used to aid the design of an
engi?eered remedial solution, should the screening proc-
ess suggest that natural attenuation alone is not feasible.
I The following infonmation is required for the screening
I process:
• nle chemical and geochemical data presented in
Table 2 for a minimum of six samples. Figure 3
shows the approximate location of these data collec-
tidn points. If other contaminants are suspected, then
d~ta on the concentration and distribution· of these
cdmpounds also should be obtained.
• Ldcations of source(s) and receptor(s).
• A~ estimate of the contaminant transport velocity and
direction of ground-water flow ..
OncJ these data have been collected, the screenin'g
I •
process can be undertaken. The following steps sum-
mariie the screening process:
1. otermine whether biodegradation is occurring using
geochemical data. If biodegradation is occurring,
prbceed to Step 2. If it is not, assess the amount and
types of data available. If data are insufficient to
determine whether biodegradation is occurring,
I collect supplemental data. ·
2. oliermine ground-water flow and solute transport
p~rameters. Hydraulic conductivity and porosity may
b~ estimated, but the ground-water gradient and flow
dilection may not. The investigator should use the
highest hydraulic conductivity measured at the site
du'ring the preliminary screening because solute
I plumes tend to follow the path of least resistance
(Lt highest hydraulic conductivity). This will give the
''wbrst case" estimate of solute migration over a
, I • given penod.
3. Lohate sources and receptor exposure points.
I 4. Estimate the biodegradation rate constant. Bio-
degradation rate constants can be estimated using
a conservative tracer found . commingled with the
cohtaminant plume, as described by Wiedemeier et
al. I (36). When dealing with a plume that contains
only chlorinated solvents, this procedure will have to
be I modified to use chloride as a tracer. Rate
constants derived from microcosm studies can also
be [ used. If it is not possible to estimate the
biodegradation rate using these procedures, then
us~ a range of accepted literature values for
biodegradation of the contaminants of concern.
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Analyze Available Site Data 1
to Determine tt Biodegradation MC----◄ Collect More Screening Data
is Occurring I
No or
Insufficient
Data
Determine Groundwater Flow and
Solute Transport Parameters using
Site-Specific Data; Porosity and
Dispersivity May be Estimated
Locate Source(s)
and Rece tor s
Estimate Biodegradation
Rate Constant
Compare the Rate or Transport
to the Rate or Attenuation using·
Analytical Solute Transport Model
Yes
Per1orm Site Characterization
to Support Natural Attenuation
Proceed to
Figure 1
No
Figure 2. Initial screening process flow chart.
Yes
I Evaluate use of Selected
Additional Remedial Options
along with Natural Attenuation
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49
Engineered
Remediation Required,
Implement Other
Protocols
Proceed to
Figure 1
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Table 2. Analytical Parameters and Weighting tor Preliminary ScreenlnJ
Ana!yte
Oxygen!\
Oxygen8
Nitrate8
Iron (II)'
Su!fate11
Sulfide8
Methane8
Oxidation reduciion
poten1ial11
pH'
DOC
Temperature8
Carbon dioxide
Alkalinity
Chloride"
Hydrogen
Hydrogen
Volatile fatly acids
BTEX8
Perchloroethene11
Trichloroethcne8
Dichloroethene8
Vinyl chloride11
Ethcnc/Ethane
Chloroe1hanc11
1, 1, 1-Trich\oroclhanc8
1, 1-dichloroethcncri
Concentration In Most
Contaminated Zone
< 0.5 mg/L
> 1 mg/L
< 1 mg/L
> 1 mg/L
< 20 mg/L
> 1 mg/L
> 0.1 mg/L
> 1
<1
< 50 mV against Ag/AgCI
5 <pH< 9
> 20 mg/L
> 20"C
> 2x background
> 2x background
> 2x background
> 1 nM
< 1 nM
> 0.1 mg/L
> 0.1 mg/L
< 0.1 mg/L.
Interpretation I
Tolerated; suppre~es reductive dechlorination at higher
concenlrations I
Vinyl chloride may be oxidized aerobically, but reductive
dechlorination will not occur
I
May compete with reductive pathway at higher
concentrations j
Reductive pathway possible
May compete wit~ reductive pathway at higher
concentralions \
Re_ductive pathway possible
Ultimate reductive1 daughter product
Vinyl chloride acJmulates
I
Vinyl chloride oxidizes
Reductive pathwat possible
Toleraled range J reductive palhway
I Carbon an_d energy source; drives dechlorination; can be
natural or ar(·-ropogenic
At T > 20Ec, bioc~emical process is accelerated
Ultimate oxidative baughter product
Results from interJclion of carbon dioxide with aquifer
minerals I
Daughter product of organic chlorine; compare chloride
in plume to backgrbund conditions
Reductive pathway;\! possible; vinyl chloride may
accumulate
Vinyl chloride oxidized ·
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Intermediates resulting from biodegradalion of aromatic
compounds; carborl and energy source
Carbon and energ) source; drives dechlorination
Material released I
Material released or daughter product of perchloroethene
rAateria! released a~ daughter product of trichloroethene;
if amount of ci.9-1,2ldichloroethene is greater than 80%
of total dichloroethene, it is likely a daughter product of
trichloroethene I
tJ.atcrial released or daughter product of dich!oroethenes
I
Daughter product of\ vinyl chloride/ethene
Daughter product of vinyl chloride under reducing
conditions
f/iaterial released
Daughter product all trichloroethene or chemical reaction
of 1, 1, 1-trich1oroeth9ne
Points
Awarded
3
-3
2
3
2
3
2
3
< 50 mV = 1
<·100 mV=2
2
2
3
2
2
2'
> 0.01 mg/L= 2
> 0.1 = 3
2
0 Required analysis. I
b Points aw.:irdcd only if ii can be shown that 1he compound is a daughter product (i.e., not a constituent of the source NAPL).
50
D . .,......-Helps Dol'ina
lf Lateral Ex111nt
_ NAPL F of Contamination
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soe,ceA;•-qip ~~,:!~~1~~i~"'
Dire-d.lon of
Plume MigraUon
LEGEND
® Re,q uirod Dale Coled.Jon Polnl
NOl To Scale
'D~olved
Contaminant
Plum&
Figure 3. Data collectlon points required for screening.
5. Compare the rate of transport to the rate of attenuation,
using analytical solutions or a screening model such
as BIOSCREEN.
6. Determine whether the screening criteria are met.
Each of these steps is described in detail below.
Step-1: Determine Whether Biodegradation Is
Occurring
The first step in the screening process is to sample at
least six wells that are representative of the contaminant
flow system and to analyze the samples for the parame-
ters listed in Table 2. Samples should be taken 1) from
the most contaminated portion of the aquifer (generally
in the area where NAPL currently is present or was
present in the past); 2) downgradient from the NAPL
source area but still in the dissolved contaminant plume;
3) downgradient from the dissolved contaminant plume;
and 4) from upgradient and lateral locations that are not
affected by the plume.
Samples collected in the NAPL source area allow deter-
mination of the dominant temninal electron-accepting
processes at the site. In conjunction with samples col·
lected in the NAPL source zone, samples collected in
the dissolved plume downgradient from the NAPL
source zone allow the investigator to determine whether
the plume is degrading with distance along the flow path
and what the dUribution of electron acceptors and do-
nors and metabolic byproducts might be along the flow
path. The sample collected downgradient from the dis-
solved plume aids in plume delineation and allows the
investigator to determine whether metabolic byproducts
are present in an area of ground water that has been
remediated. The upgradient and lateral samples allow
delineation of the plume and indicate background con-
centrations of the electron acceptors and donors.
After these samples have been analyzed for the pa-
rameters listed ,n Table 2, the investigator should ana-
lyze the data to determine wr..3ther biodegradation is
occurring. The right-hand column of Table 2 contains
51
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scoring values that can be used for this task. For exam-
ple,lif the DO concentration in the area of the plume with
the highest contaminant concentration is less than 0.5
milligrams per liter, this parameter is awarded 3 points.
Table 3 summarizes the range of possible scores and
giv~s an interpretation for each score. If the site scores
a total of 15 or more points, biodegradation is probably
occLrring, and the investigator can proceed to Step 2.
Thii method relies on the fact that biodegradation will
cause predictable changes in ground-water chemistry.
TabJ 3. Interpretation of Points Awarded During Screening Step 1
I Score
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6 to 14
15 J 20
> 20
Interpretation
Inadequate evidence for biodegradation
of chlorinated organics
Limited evidence for biodegradation of
chlorinated organics
Adequate evidence for biodegradation of
chlorinated organics
Strong evidence for biodegradation of
chlorinated organics
CoJider the following two examples. Example .1 con-
tains: data for a site with strong evidence that reductive
dechlorination is occurring. Example 2 contains data for
a sitJ with strong evidence that reductive dechlorination
' is nor occurring.
Example 1 Strong Evidence for Biodegradation of
I
· Chlorinated Organics
Concentration In Most Points
Ana11e Contaminated Zone Awarded
DO I 0.1 mg/L 3
Nitrate 0.3 mg/L 2
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lmn(II) 10 mg/L 3
I Sulfate 2 mg/L 2
I Methane 5 mg/L 3
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Oxidation-reduction -190 mV 2
potential I
Chloride 3x background 2
I Perchloroethene 1,000 µg/L 0
(rclcaSed)
. I I Trich oroethcne 1,200 µg/L 2
(none 1rcleased)
c,9-1, 2~Dich1oroethene 500 pg/L 2
(none released)
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Vinyl chloride 50 µg/L 2
(none released)
I Total points awarded 23
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In this example, the investigator can infer that biodegra-
dation is occurring and may proceed to Step 2.
Example 2. Blodegradation of Chlorinated Organics Unlikely
Concentration In Most Points
Analyte Contaminated Zone Awarded
DD 3 mg/L ·3
Nitrate 0.3 mg/L 2
lron(II) Not detected 0
Sulfate 10 mg/L 2
Methane ND 0
Oxidation-reduction 100 mV 0
potential
Chloride Background 0
Trichloroethene 1,200 µg/L 0
{released)
c,'.9-1,2-Dichlo·roethene Not detected 0
Vinyl chloride ND 0
Total points awarded
I In this example, the investigator can infer that biodegra-
dation is probably not occurring or is occurring too slowly
to be a viable remedial option. In this case, the investi-
1 gator cannot proceed to Step 2 and will likely have to
implement an engineered remediation system.
I Step 2: Determine Ground-Water Flow and Solute
Transport Parameters
I Affer biodegradation has been shown to be occurring, it
is important to quantify ground-water flow and solute
transport parameters. This will make it possible to use
a solute transport model to quantitatively estimate the
I concentration of the plume and its direction and rate of
travel. To use an analytical model, it is necessary to
know the hydraulic gradient and hydraulic conductivity
I for the site and to have estimates of the porosity and
dispersivity. The coefficient of retardation also is helpful
to know. Quantification of these parameters is discussed
I by Wiedemeier et al. (1).
To make modeling as accurate as possible, the investi-
gator must have site-specific hydraulic gradient and hy·
I draulic conductivity data. To determine the ground-water
flow and solute transport direction, the site must have at
least three accurately surveyed wells. The porosity and
I clispersivity are generally estimated using accepted lit-
erature values for the types of sediments found at the
site. If the investigator does not have TOC data for soil,
tl1c coefficient of retardation can be estimated; however,
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assuming that the solute transport and ground-water
veloclties are the same may be more conservative.
Step \3: Locate Sources and Receptor Exposure
I Points I To determine the length of flow for the predictive model-
ing conducted in Step 5, it is important to know the
distance between the source of contamination, the
downgradient end of the dissolved plume, and any po·
tential downgradient or cross-gradient receptors.
Step 4: Estimate the Biodegradation Rate
Constant
Biodegradation is the most important process that de-
grades contaminants in the subsurface; therefore, the
biodegradation rate is one of the most important model
input parameters. Biodegradation of chlorinated ali·
phatic hydrocarbons can commonly be represented as
a first-order rate constant. Site-specific biodegradation
rates generally are best to use. Calculation of site-spe·
cific biodegradation rates is discussed by Wiedemeier
et al. (1, 36, 37). If determining site-specific biodegrada·
tion rates is impossible, then literature values for the
biodegradation rate of the contaminant of interest must
be used. It is generally best to start with the average
value and then to vary the model input to predict "best
case" and "worst case" scenarios. Estimated biodegra-
dation rates can be used only after biodegradation has
been shown to be occurring (see Step 1 ).
Step 5: Compare the Rate of Transport to the
Rate of Attenuation
At this early stage in the natural attenuation demonstra-
tion, comparison of the rate of solute transport to the rate
of attenuation is best accomplished using an analytical
model. Several analytical models are available, but the
BIOSCREEN model is probably the simplest to use.
This model is nonproprietary and is available from the
Robert S. Kerr Laboratory's home page on the Internet
(www.epa.gov/ada/kerrtab.html). The BIOSCREEN
model is based on Domenico's solution to the advection-
dispersion equation (38), and allows use of either a
first-order biodegradation rate or an instantaneous reac-
tion between contaminants and electron acceptors to
simulate the effects of biodegradation. To model trans-
port of chlorinated aliphatic hydrocarbons using
BIOSCREEN, only the first-order decay rate option
should be used. BIOCHLOR, a similar model, is under
development by the Technology Transfer Division of
AFCEE. This model will likely use the same analytical
solution as BIOSCREEN but will be geared towards
evaluating transport of chlorinated compounds under
the influence of biodegradation.
The primary purpose of comparing the rate of transport
with the rate of attenuation is to determine whether the
B residence time along the flow path is adequate to be
• protective of human health and the environment (i.e., to
0 qualitatively estimate whether the contaminant is attenu-
ating at a rate fast enough to allow degradation of the
contaminant to acceptable concentrations before recep-
0 tors are reached). It is important to perform a sensitivity
analysis to help evaluate the confidence in the prelimi-
nary screening modeling effort. If modeling shows that
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receptors may not be exposed to contaminants at con-
centrations above risk-based corrective action criteria,
then the screening criteria are met, and the investigator
can proceed with the natural attenuation feasibility study.
Step 6: Determine Whether the Screening Criteria
Are Met
Before proceeding with the full-scale natural attenuation
feasibility study, the investigator should ensure that the
answers to all of the following criteria are ''yes":
• Has the plume moved a distance less than expected,
based on the known (or estimated) time since the
contaminant release and the contaminant velocity, as
calculated from site-specific measurements of hydrau-
lic conductivity and hydraulic gradient, as well as esti-
mates of effective porosity and contaminant
retardation?
• Is it likely that the contaminant mass is attenuating
at rates sufficient to be protective of human health
and the environment at a point of _discharge to a
sensitive environmental receptor?
• Is the plume going to attenuate to concentrations
less than risk-based corrective action guidelines be-
fore reaching potential receptors?
Collect Additional Site Characterization Data
To Support Natural Attenuation, As Required
I Detailed site characterization is necessary to c'0cument
the potential for natural attenuation. Review of existing
site characterization data is particularly useful before
initiating sile characterization activities. Such review
I should allow identification of data gaps and guide the most
effective placement of additional data collection points.
There are two goals during the site characterization
I phase of a natural attenuation investigation. The first is
to collect the data needed to determine whether natural
mechanisms of contaminant attenuation are occurring
I at rates sufficient to protect human health and the envi-
ronment. The second is to provide sufficient site-specific
data to nllow prediction of the future extent and concen-
tration of a contaminant plume through solute fate-and-
• transporl modeling. Because the burden of proof for
natural iiltcnuation is on the proponent, detailed site
charZ1ctcrizatic,n is required to achieve these goals and I to_ support this remedial option. Adequate site charac-
I 53
terization in support of natural attenuation requires that
the following site-specific parameters be determined:
• The extent and type of soil and ground-water
contamination.
• The location and extent of contaminant source area(s)
(i.e., areas containing mobile or residual NAPL).
• The potential for a continuing source due to leaking
tanks or pipelines.
• Aquifer geochemical parameters.
• Regional hydrogeology, including drinking water
aquifers and regional confining units.
• Local and site-specific hydrogeology, including local
drinking water aquifers: location of industrial, agricul-
tural, and domestic water wells; patterns of aquifer
use (current and future): lithology; site stratigraphy,
including identification of transmissive and nontrans-
missive units; grain-size distribution (sand versus silt
versus clay): aquifer hydraulic conductivity; ground-
water hydraulic information: preferential flow paths;
locations and types of surface water bodies: and
areas of local ground-water recharge and discharge.
• Identification of potential exposure pathways and
receptors.
The following sections describe the methodologies that
should be implemented to allow successful site charac-
terization in support of natural attenuation. Additional infor-
mation can be obtained from Wiedemeier et al. (1, 37).
Soil Characterization
To adequately define the subsurface hydrogeologic sys-
tem and to determine the amount and three-dimensional
distribution of mobile and residual NAPL that can act as
a continuing source of ground-water contamination, ex-
tensive soil characterization must be completed. De-
pending on the status of the site, this work may have
been completed during previous remedial investigation
activities. The results of soils characterization will be
used as input into a solute fate-and-transport model to
help define a contaminant source term and to support
the natural attenuation investigation.
The purpose of soil sampling is to determine the subsur-
face distribution of hydrostratigraphic units and the dis-
tribution of mobile and residual NAPL. These objectives
can be achieved through the use of conventional soil
borings or direct-push methods (e.g., Geoprobe or cone
penetrometer testing). All soil samples should be col-
lecte, ·, described, analyzed, and disposed of in accord-
ance with local, state, and federal guidance. Wiedemeier
et al. (1) present suggested procedures for soil sample
collection. These procedures may require modification
to comply with local, state, and federal regulations or to
accommodate site-specific conditions.
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The analytical protocol to be used for soil sample analy•
sis_ is presented in Table 1. This analytical protocol
includes all of the parameters necessary to document
natural attenuation, including the effects of sorption and
biodegradation. Knowledge of the location, distribution,
concentration, and total mass of contaminants of regu-
latory concern sorbed to soils or present as residual
and/or mobile NAPL is required to calculate contaminant
partitioning from NAPL into ground water. Knowledge of
the TOC content of the aquifer matrix is important for
sorption and solute-retardation calculations. TOC sam•
pies should be collected from a background location in
the stratigraphic hoiizon(s) where most contaminant
transport is expected to occur. Oxygen and carbon di·
oxide measurements of soil gas can be used to find
areas in the unsaturated zone where biodegradation is
I occurring. Knowledge of the distribution of contaminants
in soil gas can be used as a cost-effective way to
estimate the extent of soil contamination.
I Ground-Water Characterization
I To adequately determine the amount and three-dimen·
sional distribution of dissolved contamination and to
document the occurrence of natural attenuation,
ground-water samples must be collected and analyzed. I Biodegradation of organic compounds, whether natural
or anthropogenic, brings about measurable changes in
the chemistry of groun•J water in the affected area. By
I measuring these changes, documentation and quantita·
live evaluation of natural attenuation's importance at a
site are possible.
I Ground-water sampling is conducted to determine the
concentrations and distribution of contaminants, daugh•
ter products, and ground-water geochemical parame·
I ters. Ground-water samples may be obtained from
monitoring wells or with point-source sampling devices
such as a Geoprobe, Hydropunch, or cone penetrome·
ter. All ground-water samples should be collected in I accordance with local, state, and federal guidelines.
Wiedemeier et al. (1) suggest procedures for ground·
water sample collection. These procedures may need to
I be modified to comply with local, state, and federal
regulations or to accommodate site-specific conditions.
I The analytical protocol for ground-water sample analy·
sis is presented in Table 1. This analytical protocol in•
eludes all of the parameters necessary to document
natural attenuation, including the effects of sorption and
l biodegradation. Data obtained from the analysis of
ground water for these analytes is used to scientifically
document natural attenuation and can be used as input
•
into a solute fate-and-transport model. The following
Paragraphs describe each ground-water analytical pa-
rameter and the use of each analyte in the natural
.attenuation demonstration.
I
54
Volatile organic compound analysis (by Method
SW8260a) is used to determine the types, concentra-
tions, and distributions of contaminants and daughter
products in the aquifer. DO is the electron acceptor most
thermodynamically favored by microbes for the biode·
gradation of organic carbon, whether natural or anthro•
pogenic. Reductive dechlorination will not occur,
however, if DO concentrations are above approximately
0.5 milligrams per liter. During aerobic biodegradation of
a substrate, DO concentrations decrease because of
the microbial oxygen demand. After DO depletion, an·
aerobic microbes will use nitrate as an electron ac·
ceptor, followed by iron(III), then sulfate, and finally
carbon dioxide (methanogenesis). Each sequential re·
action drives the oxidation-reduction potential of the
ground water further into the realm where reductive
dechlorination can occur. The oxidation-reduction po·
tential range of sulfate reduction and methanogenesis is
optimal, but reductive dechlorination may occur under
nitrate• and iron(lll)-reducing conditions as well. Be·
cause reductive dechlorination works best in the sulfate·
reduction and methanogenesis oxidation-reduction
potential range, competitive ·exclusion between micro-
bial sulfate reducers, methanogens, and reductive
dechlorinators can occur.
After DO has been depleted in the microbiological treat·
ment zone, nitrate may be used as an electron acceptor
for anaerobic biodegradation via denitrification. In some
cases iron(III) is used as an electron acceptor during
anaerobic biodegradation of electron donors. During this
process, iron(III) is reduced to iron(II), which may be
soluble in water. lron(II) concentrations can thus be used
as an indicator of anaerobic degradation of fuel com·
pounds. After DO, nitrate, and bioavailable iron(III) have
been depleted in the microbiological treatment zone,
sulfate may be used as an electron acceptor for an aero•
bic biodegradation. This process is termed sulfate re•
duction and results in the production of sulfide. During
methanogenesis (an anaerobic biodegradation proc•
ess), carbon dioxide (or acetate) is used as an electron
acceptor, and methane is produced. Methanogenesis
generally occurs after oxygen, nitrate, bioavailable
iron(III), and sulfate have been depleted in the treatment
zone. The presence of methane in ground water is
indicative of strongly reducing conditions. Because
methane is not present in fuel, the presence of methane
in ground water above background concentrations in
contact with fuels is indicative of microbial degradation
of fuel hydrocarbons.
The total alkalinity of a ground-water system is indicative
of a water's capacity to neutralize acid. Alkalinity is
defined as "the net concentration of strong base in
excess of strong acid with a pure CO,-water system as
the point of reference" (39). Alkalinity results from the
presence of hydroxides, carbonates, and bicarbonates
of elements such as calcium, magnesium, sodium, po•
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tassium, or ammonia. These species result from the
-dissolution of rock (especially carbonate rocks), the
transfer of carbon dioxide from the atmosphere, and the
respiration of microorganisms. Alkalinity is important in
the maintenance of ground-water pH because it butters
the ground-water system against acids generated dur-
ing both aerobic and anaerobic biodegradation.
In general, areas contaminated by fuel hydrocarbons
exhibit a total alkalinity that is higher than that seen in
background areas. This is expected because the micro-
bially mediated reactions causing biodegradation of fuel
hydrocarbons cause an _increase in the total alkalinity in
the system. Changes in alkalinity are most pronounced
during aerobic respiration, denitrification, iron reduction,
and sulfate reduction, and are less pronounced during
methanogenesis (40). In addition, Willey et al. (41) show
that short-chain aliphatic acid ions produced during
biodegradation of fuel hydrocarbons can contribute to
alkalinity in ground water.
The oxidation-reduction potential of ground water is a
measure of electron activity and. an indicator of the
relative tendency of a solution to accept or transfer
electrons. Redox reactions in ground water containing
organic compounds (natural or anthropogenic) are usually
biologically mediated; therefore, the oxidation-reduction
potential of a ground-water system depends on and
influences rates of biodegradation. Knowledge of the
oxidation-reduction potential of ground water also is
important because some biological processes operate
only within a prescribed range of redox conditions. The
oxidation-reduction potential of ground water generally
ranges from -400 to 800 millivolts (mV). Figure 4 shows
th& typical redox conditions for ground water when dif-
ferent electron acceptors are used.
Oxidation-reduction potential can be used to provide
real-time data on the location of the contaminant plume,
especially in areas undergoing anaerobic biodegrada-
. tion. Mapping the oxidation-reduction potential of the
ground water while in the field helps the field scientist to
determine the approximate location of the contaminant
plume. To periorm this task, it is important to have at
least one redox measurement (preferably more) from a
well located upgradient from the plu: :ie. Oxidation-re-
duction potential measurements should be taken during
well purging and immediately before and after sample
Redox Potential (Eh")
in Millivolts @ .P,H = 1
andT=25C
Figure 4.
1000·
Aerobic O, + 4H" + 4&· ---,. 2H,O (E; = + 820)
2ND; + 12H" + 10<>·---,. N, + 6H,O (E, = + 740)
Anaerobic
500 --MnO,(s) + HCO; + 3H" + 2e --;, MnCO,(s) + 2H,O
(E; = + 520)
PoMible Range
for R&ductive
O,x;hlorlnation
0
Optimal Range I for Reductive
Oedilorination
-500
Modified From Bouwer ([994)
Rcdox potentials for various electron .icccptor&,
55
FoOOH(•) + HCO; + 2H" + •· --;, Fe CO,+ 2H,O
(E,,' = -50)
so,1·+9H"+a,,·---,. HS"+4H,O
col+ 8H' + 8 o· ----+ CHI + 2Hl0
(E, = -220)
(I;,' = • 240)
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acquisition using a direct-reading meter. Because most
well purging techniques can allow aeration of collected
ground-water samples (which can affect oxidation-reduction
potential measurements), it is important to minimize
potential aeration.
Dissolved hydrogen concentrati0ns can be used to de-
termine the dominant tenminal electron-accepting proc-
ess in an aquifer. Because of the difficulty in obtaining
hydrogen analyses commercially, this parameter should
be considered optional at this time. Table 4 presents the
range of hydrogen concentrations for a given terminal
electron:accepting process. Much research has been
done on the topic of using hydrogen measurements to
delineate terminal electron-accepting processes (42-
44). Because the efficiency of reductive dechlorination
differs for methanogenic, sulfate-reducing, iron(ll !)-re-
ducing, or denitrifying conditions, it is helpful to have
hydrogen concentrations to help delineate redox condi-
tions when evaluating the potential for natural attenu-
ation of chlorinated ethenes in ground-w•1ter systems.
Collection and analysis of ground-water samples for
Table 4. Range of Hydrogen Concentrations for a Given
Termlnal Electron-Accepting Process
Terminal
Electron-Accepting Process
Denitrification
lron(lll) reduction
Sulfate reduction
Methanogenesis
Hydrogen Concentration
(nanomoles per liter)
< 0.1
0.2 lo 0.8
1 to 4
>5
dissolved hydrogen content is not yet commonplace or
standardized, however, and requires a relatively expen-
sive field laboratory setup.
Because the pH, temperature, and conductivity of a
ground-water sample can change significantly shortly
following sample acquisition, these parameters must be
measured in the field in unfiltered, unpreserved, '1resh"
water collected by the same technique as the samples
taken for DO and redox analyses. The measurements
should be made in a clean glass container separate from
those intended for laboratory analysis, and the meas-
ured values should be recorded in the ground-water
sampling record.
The pH of ground water has an effect on the presence
I and activity of microbial populations in the ground water.
This is especially true for methanogens. Microbes capa-
ble of degrading chlorinated aliphatic hydrocarbons and
I petroleum hydrocarbon compounds generally prefer pH
values varying from 6 to 8 standard units. Ground-water
temperature directly affects the solubility of oxygen and
other geochemical species. The solubility of DO is tern-
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perature dependent, being more soluble in cold water
than in warm water. Ground-water temperature also affects
the metabolic activity of bacteria. Rates of hydrocarbon
biodegradation roughly double for every 1 0'C increase
in temperature ("0",0 rule) over the temperature range
between S'C and 25'C. Ground-water temperatures
less than about 5'C tend to inhibit biodegradation, and
slow rates of biodegradation are generally observed in
such waters.
Conductivity is a measure of the ability of a solution to
conduct electricity. The conductivity of ground water is
directly related to the concentration of io'ns in solution;
conductivity increases as ion concentration increases.
Conductivity measurements are used to ensure that
ground water samples collected at a site are repre-
sentative of the water in the saturated zone containing
the dissolved contamination. If the conductivities of
samples taken from different sampling points are radi-
cally different, the waters may be from different hydro-
geologic zones.
Elemental chlorine is the most abundant of the halo-
gens. Although chlorine can occ•.tr in oxidation states
ranging from er to c1•7 , the chloride form (Gr) is the only
form of major significance in natural waters (45). Chlo-
ride forms ion pairs or complex ions with some of the
cations present in natural waters, but these complexes
are not strong enough to be of significance in the chem-
istry of fresh water (45). The chemical behavior of chlo-
ride is neutral. Chloride ions generally do not enter into
oxidation-reduction reactions, form no important solute
complexes with other ions unless the chloride concen-
tration is extremely high, do not form salts of low solu-
bility, are not significantly adsorbed on mineral surfaces,
and play few vital biochemical roles (45). Thus, physical
processes control the migration of chloride ions in the
subsurface.
Kaufman and Orlob (46) conducted tracer experiments
in ground water and found that chloride moved through
most of the soils tested more conservatively (i.e., with
less retardation and loss) than any of the other tracers
tested. During biodegradation of chlorinated hydrocar-
bons dissolved in ground water, chloride is released into
the ground water. This results in chloride concentrations
in the ground water of the contaminant plume that are
elevated relative to background concentrations. Be-
cause of the neutral chemical behavior of chloride, it can
be used as a conservative tracer to estimate biodegra-
dation rates using methods similar to those discussed
by Wiedemeier et al. (36).
Field Measurement of Aquifer Hydraulic
Parameters
The properties of an aquifer that have the greatest im-
pact on contaminant fate and transport include hydraulic
cor.ductivity, hydraulic gradient, porosity, and dispersiv-
D ity. Estimating hydraulic conductivity and gradient in the
D _ field is fair1y straightforward, but obtaining field-scale
information on porosity and dispersivity can be difficult.
Therefore, most investigators rely on field data for hy-
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draulic conductivity and hydraulic gradient and on litera-
ture values for porosity and dispersivity for the types of
sediments present at the site. Methods for field meas-
urement of aquifer hydraulic parameters are described
by Wiedemeier et al. (1, 37).
Microbiological Laboratory Data
Microcosm studies are used to show that the microor-
ganisms necessary for biodegradation are present and
to help quanti"y rates of biodegradation. If proper1y de·
signed, implemented, and interpreted, microcosm stud-
ies can provide very convincing documentation of the
occurrence of biodegradation. Such studies are the only
"line of evidence" that allows an unequivocal mass bal-
ance determination based on the biodegradation of en-
vironmental contaminants. The results of a well-designed
microcosm study will be easy for decision-makers with
nontechnical backgrounds to interpret. Results of such
studies are strongly influenced by the nature of the
geological material submitted for study, the physical
properties of the microcosm, the sampling strategy, and
the duration of the study. Because microcosm studies
are time-consuming and expensive, they should be un-
dertaken only at sites where there is considerable skep-
ticism concerning the biodegradation of contaminants.
Biodegradation rate constants determined by micro-
cosm studies often are much greater than rates
achieved in the field. Microcosms are most appropriate
as indicators of the potential for natural bioremediation
and to prove that losses are biological, but it may be
inappropriate to use them to generate rate constants.
The preferable method of contaminant biodegradation
rate-constant detenmination is in situ field measurement.
The collection of material for the microcosm study, the
procedures used to set up and analyze the microcosm,
and the interpretation of the results of the microcosm
study are presented by Wiedemeier et al. (1 ).
Refine the Conceptual Model, Complete
Premodeling Calculations, and Document
Indicators of Natural Attenuation
Site invest[gation data should first be used to refine the
conceptual model and quantify ground-water flow, sorp-
tion, dilution, and biodegradation. The results of these
calculations are used to scientifically document the occur-
rence and rates of natural attenuation and to help simulate
naturnl attenuation over time. Because the burden of
proof is on the proponent, all available data must be
integrated in such a way that the evidence is sufficient to
support the conclusion that natural attenuation is occurTing.
57
Conceptual Model Refinement
Conceptual model refinement involves integrating newly
gathered site characterization data to refine the prelimi-
nary conceptual model that was developed based on
previously existing site-specific data. During conceptual
model refinement, all available site-specific data should
be integrated to develop an accurate three-dimensional
representation of the hydrogeologic and contaminant
transport system. This conceptual model can then be
used for contaminant fate-and-transport modeling. Con-
ceptual model refinement consists of several steps, in-
cluding preparation of geologic logs, hydrogeologic
sections, potentiometrtc suriace/water table maps, con-
taminant contour (isopleth) maps, and electron acceptor
and metabolic byproduct contour (isopleth) maps. Re-
finement of the conceptual model is described by
Wiedemeier et al. (1).
Premodeling Calculations
Several calculations must be made prior to implementa-
tion of the solute fate-and-transport model. These cal-
culations include sorption and retardation calculations,
NAPUwater-partitioning calculations, ground-water flow
velocity calculations, and biodegradation rate-constant
calculations. Each of these calculations is discussed in
the following sections. Most of the specifics of each
calculation are presented in the fuel hydrocarbon natural
attenuation technical protocol by Wiedemeier et al. (1 ),
and all will be presented in the protocol incorporating
chlorinated aliphatic hydrocarbon attenuation (37).
Biodegradation Rate Constant Calculations
Biodegradation rate constants are necessary to simu-
late accurately the fate and transport of contaminants
dissolved in ground water. In many cases, biodegrada-
tion of contaminants can be approximated using first-or-
der kinetics. To calculate first-order biodegradation rate
constants, the apparent degradation rate must be nor-
malized for the effects of dilution and volatilization. Two
methods for determining first-order rate constants are
described by Wiedemeier et al. (36). One method in-
volves the use of a biologically recalcitrant compound
found in the dissolved contaminant plume that can be
used as a conservative tracer. The other method, pro-
posed by Buscheck and Alcantar (47) involves interpre-
tation of a steady-state contaminant plume and is based
on the one-dimensional steady-state analytical solution
to the advection-di0 oersion equation presented by Bear
(48). The first-order biodegradation rate constants for
chlorinated aliphatic hydrocarbons are also presented
(J. Wilson et al., this volume).
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Simulate Natural Attenuation Using Solute
Fate-and-Transport Models
Simulating natural attenuation using a solute fate-and-
transport model allows prediction of the migration and
attenuation of the contaminant plume through time. Natu-
ral attenuation modeling is a tool that allows site-specific
data to be used to predict the fate and transport of
solutes under governing physical, chemical, and biologi-
cal processes. Hence, the results of the modeling effort
are not in themselves sufficient proof that natural attenu-
ation is occurring at a given site. The results of the
modeling effort are only as good as the original data
input into the model; therefore, an investment in thor-
ough site characterization will improve the validity of the
modeling results. In some cases, straightforward ana-
lytical models of contaminant attenuation are adequate
to simulate natural attenuation.
Several well-documented and widely accepted solute
fate-and-transport models are available for simulating
the fate-and-transport of contaminants under the influ-
ence of advection, dispersion, sorption, and biodegra-
dation. The use of solute fate-and-transport modeling in
the natural attenuation investigation is described by
Wiedemeier et al. (1).
Identify Potential Receptors, and Conduct an
Exposure-Pathway Analysis
After the rates of natural attenuation have been docu-
mented and predictions of the future extent and concen-
trations of the contaminant plume have been made
using the appropriate solute fate-and-transport model,
the proponent of natural attenuation should combine all
available data and information to negotiate for imple-
mentation of this remedial option. Supporting the natural
attenuation option generally will involve performing a
receptor exposure-pathway analysis. -This analysis in-
cludes identifying potential human and ecological recep-
tors and points of exposure under current and future
land and ground-water use scenarios. The results of ·
solute fate-and-transport modeling are central to the
exposure pathways analysis. If conservative model in-
put parameters are used, the solute fate-and-transport
model should give conservative estimates of contami-
nant plume 1··.igration. From this information, the poten-
tial for impacts on human health and the environment
from contamination present at the site can be estimated.
Evaluate Su, plemental Source Removal
Lptions
Source removal or reduction may be necessary to re-
duce plume expansion if the exposure-pathway analysis
suggests that one or more exposure pathways may be
completed before natural attenuation can reduce chemi-
cal concentrations below risk-based levels of concern.
Further, some regulators may require source removal in
58
conjunction with natural attenuation. Several technolo-
gies suitable for source reduction or removal are listed
in Figure 1. Other technologies may also be used as
dictated by site conditions and local regulatory require-
ments. The authors' experience indicates that source
removal can be very effective at limiting plume migration
and decreasing the remediation time frame, especially
at sites where biodegradation is contributing to natural
attenuation of a dissolved contaminant plume. The im-
pact of source removal can readily be evaluated by
modifying the contaminant source term if a solute fate-
and-transport model has been prepared for a site; this
will allow for a reevaluation of the exposure-pathway
analysis.
Prepare a long-Term Monitoring Plan
Ground-water flow rates at many Air Force sites studied
to date are such that many years will be required before
contaminated ground water could potentially reach Base
property boundaries. Thus, there frequently is time and
space for natural attenuation alone to reduce contami-
nant concentrations in ground water to acceptable lev-
els. Experience at 40 Air Force sites contaminated with ·
fuel hydrocarbons using the protocol presented by
Wiedemeier et al. (1) suggests that many fuel hydrocar-
bon plumes are relatively stable or are moving very
slowly with respect to ground-water flow. This informa-
tion is complemented by data collected by Lawrence
Livermore National Laboratories in a study of over 1,100
leaking underground fuel tank sites performed for the
California State Water Resources Control Board (49).
These examples demonstrate the efficacy of long-term
monitoring to track plume migration and to validate or
refine modeling results. There is not a large enough
database available at this time to assess the stability of
chlorinated solvent plumes, but in the authors' experi-
ence chlorinated solvent plumes are likely to migrate
further downgradient than fuel hydrocarbon plumes be-
fore reaching steady-state equilibrium or before receding.
The long-term monitoring plan consists of locating
ground-water monitoring wells and developing a
ground-water sampling and analysis strategy. This plan
is used to monitor plume migration over time and to
verify that natural attenuation is occurring at rates suffi-
cient to protect potential downgradient receptors. The
long-term monitoring plan should be developed based
on site characterization data, the results of solute fate-
and-transport modeling, and the results of the exposure-
pathway analysis.
The long-term monitoring plan includes two types of
monitoring wells: long-term monitoring wells are in-
tended to determine whether the behavior of the plume
is changing; point-of-compliance wells are inlended to
detect movements of the plume outside the negotiated
perimeter of containment, and to trigger an action to
I manage the risk associated with such expansion. Figure
_5 depicts 1) an upgradient well in unaffected ground I water, 2) a well in the NAPL source area, 3) a well
downgradient of the NAPL source area in a zone of
anaerobic treatment, 4) a well in the zone of aerobic
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Anaoroblc Tra2tmont Zone
LNAPL .miiiii!iifflliffli Ex1ont of Dt:sso!vctl SOurtll Al'tt•,'li . • BTEX Plume
0 . 0 0
" Dh?ct!on or ) . Aerobic Treatment
Plume M~rfl!ioo Zone
illillill
O ~rJ\.oJ..Co~lance Mon~.omg Woll
O Long-Term Monitoring IN::fl Not To Scale
t,hto: Ca~ln d.M ~ ,.~ "'°" ..,10. Thi 6,o,1 n,.,,-t,er •nd ,,__,,..... oh<Ud bo 11.,....,o,d In -,,..-,ct,<,n
M~ the •w,:,p<'lolo "';J!,M'll;,n
•
•
•
I Figure 5. Hypothetical long-term monitoring strategy.
treatment, along the periphery of the plume, 5) a well
I located downgradient from the plume where contami-
nant concentrations are below regulatory acceptance
levels and soluble electron acceptors are depleted with
I respect to unaffected ground water, and 6) three point-
of-compliance wells.
Although the final number and placement of long-term
I. monitoring and point-of-compliance wells is determined
· through regulatory negotiation, the following guidance is
recommended. Locations of long-term monitoring wells
I,_ are based on the behavior of the plume as revealed
during the initial site characterization and on regulatory
considerations. Point-of-compliance wells are placed
500 feet downgradient from the leading edge of the
I plume or the distance traveled by the ground water in
2 years, whichever is greater. If the property line is less
• than 500 feet downgradient, the point-of-compliance
I wells are placed near and upgradient from the prop-
erty line. The final number and location of point-of-
compliance monitoring wells also depends on regulatory
I considerations.
The results of a solute fate-and-transport model can be
used to help site the long-term monitoring and point-of-
1 compliance wells. To provide a valid monitoring system,
, all monitoring wells must be screened in the same hy-
drogeologic unit as the contaminant plume. This gener-
ally requires detailed stratigraphic correlation. To I facilitate accurate stratigraphic correlation, detailed vis-
ual descriptions of all subsurface materials encountered
during borehole drilling should be prepared prior to I monitoring-well installation.
A ground-water sampling and analysis plan should be
I
, prepared in conjunction with point-o!-cornp!iancc and
long-term moniloring well placement. For long-term
I 59
monitoring wells, ground-water analyses should include
volatile organic compounds, DO, nitrate, iron{II), sulfate,
and methane. For point-of-compliance wells, ground-
water analyses should be limited to determining volatile
organic compound and DO concentrations. Any state-
specific analytical requirements also should be ad-
dressed in the sampling and analysis plan to ensure that
all data required for regulatory decision-making are col-
lected. Water level and LNAPL thickness measurements
must be made during each sampling event. Except at
sites with very low hydraulic conductivity and gradients,
quarterly sampling of long-tenm monitoring wells is rec-
ommended during the first year to help determine the
direction of plume migration and to detenmine baseline
data. Based on the results of the first year's sampling,
the sampling frequency may be reduced to annual sam-
pling in the quarter showing the greatest extent of the
plume. Sampling frequency depends on the final place-
ment of the point-of-compliance monitoring wells and
ground-water flow velocity. The final sampling frequency
should be determined in collaboration with regulators.
Present Findings to Regulatory Agencies, and
Obtain Approval for Remediation by Natural
Attenuation
The purpose of regulatory negotiations is to provide
scientific documentation that supports natural attenu-
ation as the most appropriate remedial option for a given
site. All available site-specific data and information de-
veloped during the site characterization, conceptual
model development, premodeling calculations, biode-
gradation rate calculation, ground-water modeling,
model documentation, and long-term monitoring plan
preparation phases of the natural attenuation investiga-
tion should be presented in a consistent and comple-
mentary manner at the regulatory negotiations. Of
particular interest to the regulators will be proof that
natural attenuation is occurring at rates sufficient to
meet risk-based corrective action criteria at the point of
compliance and to protect human health and the envi-
ronment. The regulators must be presented with a
"weight-of-evidence" argument in support of this reme-
dial option. For this reason, all model assumptions
should be conservative, and all available evidence in
support of natural attenuation must be presented at the
regulatory negotiations.
A comprehensive long-term monitoring and contingency
plan also should be presented to demonstrate a com-
mitment to proving the effectiveness of natural attenu-
ation as a remedial option. Because long-term
monitoring and contingency plans are very site specific,
they should be addressed in the individual reports gen-
erated using this protocol.
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References
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Borden, T.M. Vogel, J.M. Thomas, and C.H. Ward, eds. Hand-
book of bioremcdiation. Boca Raton, FL: Lewis Publishers.
24. Bouwer, E.J. 1994. Bioremediation of chlorinated solvents using
alternate electron acceptors. In: Norris, R.D., R.E. Hinchee, R.
Brown, P.L McCarty, L. Semprini, J.T. Wilson, D.H. Kampbel!, M.
Reinhard, E.J. Bouwer, R.C. Borden, T.M. Vogel, J.M. Thomas,
and C.H. Ward, eds. Handbook of bioremediation. Boca Raton,
FL: Lewis Publishers.
25. Vogel, T.M., and P.L. McCarty. 1985. Biotransformation of
tetrachloroelhylene lo trichloroethylene, dichloroethylene, vinyl
chloride, and carbon dioxide under methanogenic conditions.
Appl. Environ. Microbial. 49(5):1080-1083.
26. Murray, W.D., and M. Richardson. 1993. Progress toward the
biological treatment of C1 and C2 halogenated hydrocarbons.
Grit. Rev. Environ. Sci. Technol. 23(3):195-217.
27. Bradley, P.M., and F.H. Chapelle. 1996. Anaerobic mineralization
of vinyl chloride in Fe(lll)-reducing aquifer sediments. Environ.
Sci. Technot. 40:2084-2086.
28. Wicdemeier, T.H., L.A. Benson, J.T. Wilson, D.H. Kampbell, J.E.
Hansen, and R. Miknis. 1996. Patterns of natural attenuation of
chlorinated aliphatic hydrocarbons at Plattsburgh Air Force Base,
New York. Platform abslracts presented at the Conference on
Intrinsic Remediation of Chlorinnted Solvents, Salt Lake Ci1y, UT,
April 2.
29. U.S. EPA. 1986. Tes1 met!"lods for evaluating solid wasle, physical
and chemical methods, 3rd ed. SW-846. Washington, DC.
30. U.S. EPA. i983. Methods for chemical analysis of water and
wastes. EPA/16020-07-71. Cincinnati, OH.
31. Hach Co. 1990. Hach <;::ompany Catalog: Products for Analysis.
Ames, IA.
32. American Public Health Association. 1992. Standard melhods for
the examination of water and wastewater, '18th ed. Washington,
DC.
33. AFC EE. i 993. Handbook lo suppor1 the lnstalla1ion Restoration
Program (lRP) remedial investigations and 1easibility s1udies
(r-11/FS). U.S. f..ir Force Center for Environmental Excellence.
September. Brooks Air Force Base, TX.
34. /,FCEE. 1992. Environmenlal chemistry lunc1ion lns\allzition Res-
loration Progrc:im analytical protocols. June.
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35. Kampbell, D.H., J.T. Wilson, and S.A. Vandegrift.1989. Dissolved
oxygen and methane in water by a GC headspace equilibrium
technique. Int. J. Environ. Ana!. Chem. 36:249-257.
36. Wiedemeier, T.H., M.A. Swanson, J.T. Wilson, D.H. Kampbefl,
R.N. Miller, and J.E. Hansen. 1996. Approximation of biodegra-
dation rate constants for monoaromatic hydrocarbons (BTEX) in
groundwater. Ground Water Monitoring and Remediation. In
press.
37. Wiedemeier, T.H., M.A. Swanson, D.E. Moutoux, J.T. \Nilson,
O.H. Kampbell, J.E. Hansen, P. Haas, and F.H. Chapelle. 1996.
Technical protocol for natural attenuation of chlorinated solvents
in groundwaler. San Antonio, TX: U.S. Air Force Center for En-
vironmental Excellence. In Preparatioii.
38. Domenico, P.A. 1987. An analytical model for multidimensional
transport of a decaying contaminant species. J, Hydrol. 91 :49-58.
39. Domenico, P.A., and F.W. Schwartz. 1990. Physical and chemical
hydrogeology. New York, NY: John Wiley and Sons.
40. More!, F.M.M., and J.G. Hering. 1993. Principles and applications
of aquatic chemistry. New York, NY; John Wiley & Sons,
41. Willey, L.M., Y.K. Kharaka, T.S. Presser, J.B. Rapp, and I. Barnes,
1975. Short chain aliphatic acid anions in oil field waters and their
contribution to the measured alka!ini1y. Geochim. Cosmochim.
Acta 39:1707-1711.
42. Lovley, D.R., and S. Goodwin. 1988. Hydrogen concentrations
as an indicator of the predominant terminal electron-accepting
reac1ion in aquatic sediments. Geochim. Cosmochim. Acta
52:2993-3003.
61
43. Lovley, D.R., F.H. Chapelle, and J.C. Woodward. 1994. Use of
dissolved H2 concentrations to determine distribution of micro-
bially catalyzed redox reactions in anoxic groundwater. Environ.
Sci. Technol. 28(7):1205-1210.
44. Chapelle, F.H., P.B. McMahon, N.M. Dubrovsky, R.F. Fujii, E.T.
Oaksford, and D.A. Vroblesky. 1995 .. Deducing the distribution of
terminal electron-accepting processes in hydrologically diverse
groundwater systems. Water Resour. Res. 31 :359-371.
45. Hem, J.D. 1985. Study and interpretation of the chemical char-
acteristics of natural water. U.S. Geological Survey Water Supp!y
Paper 2254.
46. Kaufman, W.J., and G.T. Orlob, 1956. Measuring ground water
movement with radioactive and chemical tracers. A·m. Water
Works Assn. J. 48:559-572.
47. Buscheck, T.E., and C.M. Alcantar. 1995. Regression techniques
and analytical solutions to demonstrate intrinsic bioremediation.
In: Proceedings of the 1995 Battelle lntemationat Conference on
In-Situ and On s:te Bioreclamation. April.
48. Bear, J. 1979. Hydraulics of groundwater. New York, NY:
McGraw-Hill.
49. Rice, D.W., A.O. Grose, J.C. Michaelsen, B.P. Dooher, D.H. Mac-
Queen, S.J. Cullen, W.E. Kastenberg, L.G. Everett, and M.A.
Marino. 1995. California leaking underground fuel lank (LUFT)
historical case analyses, California Stale Water Resources Con-
trol Board,
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B-4 THE BIOSCREEN COMPUTER TOOL
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The B/OSCREEN Computer Tool
Charles J. Newell and R. Kevin McLeod
Groundwater Services, Inc., Houston, Texas
James R. Gonzales
U.S. Air Force Center for Environmental Excellence, Brooks Air Force Base, Texas
Introduction
BIOSCREEN is an easy-to-use screening tool for simu-
lating the natural attenuation of dissolved hydrocarbons_
at petroleum fuel release sites, The software, pro-
grammed in the Microsoft Excel spreadsheet environ-
ment and based on the Domenico analytical solute
transport model (1 ), has the ability to simulate advection,
dispersion, adsorption, and aerobic decay, as well as
anaerobic reactions that have been shown to be the
dominant biodegradation processes at many petroleum
release sites, BIOSCREEN includes three different
model types: solute transport without decay, solute
transport with biodegradation modeled as a first-order
decay process (simple, lumped-parameter approach),
and solute transpo.-t with biodegradation modeled as an
"instantaneous" biodegradation reaction (the approach
used by BIOPLUME models) (2),
Intended Uses for BIOSCREEN
BIOSCREEN attempts to answer two fundamental
questions regarding intrinsic remudiation (3):
• How far will the plume extend if no engineered control
or source zone reduction is implemented?
BIOSCREEN uses an analytical solute transport model
with two options for simulating in situ biodegradation:
first order decay and instantaneous reaction, The
model predicts the maximum extent of plume
migration, which may then be compared with the
distance to potential points of exposure (e,g,, drinking
water wells, ground-water discharge areas, or
property boundaries),
• How long will the plume persist until natural attenu-
ation processes cause it to dissipate?
BIOSCREEN uses a simple mass balance approach,
based on the mass of dissolvable hydrocarbons in the
62
source zone and the rate of hydrocarbons leaving the
source zone, to estimate the source zone concentration
versus time, Because an exponential decay in source
zona concentration is assumed, the predicted plume
lifetimes can be large, usually ranging from 5 to 500
years, Note that this is an unverified relationship (there
are little data showing source concentrations versus
long periods), and the results should be considered
order-of-magnitude estimates of the time to dissipate
the plume,
BIOSCREEN is intended to be used in two ways:
• As a screening model to determine whether intrinsic
remediation is feasible at a given site, In this case,
BIOSCREEN is used early in the remediation process
and before site characterization activities are com-
pleted, Some data, such as electron acceptor concen-
trations, may not be available, so typical values are
used, The BIOSCREEN results are used to determine
whether an intrinsic remediation field program should
be implemented to quantify the natural attenuation oc-
curring at a site, In addition, BIOSCREEN is an excel-
lent communication and teaching tool that can be used
to present information in a graphical manner and help
explain the concepts behind natural attenuation,
• As the primary intrinsic remediation ground-water
model at smaller sites, The U,S, Air Force Intrinsic
Remediation Protocol describes how intrinsic reme-
diation models may be used to help verify that natural
attenuation is occurring and to help predict how far
plumes might extend under an intrinsic remediation
scenario, At large, high-effort sites, such as Super-
fund and Resource Consc,vation and Recovery Act
sites, a more sophisticated intrinsic remediation
model is probably more appropriate, At smaller,
lower-effort sites, such as service stations, BIOSCREEN
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may be sufficient to complete the intrinsic remedia-tion study.
BIOSCREEN Input and Output
To run BIOSCREEN, the user enters site data in the following categories: hydrogeologic, dispersion, adsorp-tion, biodegradation, general infomiation, source char-
acteristics, and observed data. For several parameters (e.g., seepage velocity), the user can either enter the value directly or use supporting data (hydraulic conduc-tivity, hydraulic gradient, and effective porosity) to calcu-late the value. Figure 1 shows the actual input screen. BIOSCREEN output includes plume centerline graphs, three-dimensional color plots of plume concentrations,
and mass balance data showing the contaminant mass removal by each electron acceptor (instantaneous reac-tion option). Figures 2 and 3 show the two output screens. The input and output screens have on-line help built into the software. A detailed user's manual is also available (4).
BIOCH .. OR: A BIOSCREEN for Chlorinated Solvents
While BIOSCREEN was originally designed to simu-
late intrinsic remediation at petroleum release sites, the system can be modified to simulate intrinsic reme-diation of chlorinated hydrocarbons. Current plans call
for converting the BIOSCREEN model to BIOCHLOR.
Key changes are:
• Biodegradation using first-order decay only: Micro-
bial constraints on kinetics are much more important
for chlorinated solvents than for petroleum com-pounds. Therefore, the first-order decay approach will be emphasized in both the BIOCHLOR software and manual. A detailed survey of solute decay data
and source decay data from existing sites and the literature will be provided.
• More detailed information on source terms: Chlorin-ated solvents are associated with the presence of free-phase and residual dense nonaqueous phase liquids (DNAPLs) rather than residual light nonaqueous phase liquids (LNAPLs) such as gaso-line and JP-4. The source terms will be discussed in more detail to ensure that model input data and pre-liminary calculations are representative of DNAPL sites.
• Evaluation of biodegradation products: The genera-tion of products of chlorinated solvent biodegradation
will be discussed. Simple analytical tools may be developed and incorporated into BIOCHLOR.
BIOSCREEN is available by contacting EPA's Center for Subsurface Modeling Support (CSMoS), NRMRUSPRD,
P.O. Box 1198, Ada, OK 74821-1198, telephone 405-436-
8594, fax [phone], bulletin board 405-436-8506
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I 63
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Figure 2. BIOSCREEN centerline output screen.
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I Figure 3. BIOSCREEN concentration array output screen.
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(14,400 baud, 8 bits, 1 stopbit available, no parity), and Internet http://www.epa.gov/ada/kerrlab.html. Electronic
manuals will be available in .pdf format; the Adobe
Acrobat Reader is necessary to read and print .pdf files.)
References
1. Domenico, P.A. 1987. An analytical model for multidimensional
1ransport of a decaying contaminant species. J. Hydro. 91 :49-58.
2. Rifai, H.S., P.8. Bedient, R.C. Borden, and J.F. Haasbeek. 1987. BIOPLUME II-computer model of two-dimensional transport un-der the influence of oxygen limi1ed biodegrada1ion in ground water, Usef'~s manual, Ver. 1.0. Rice Unlversi1y, Houston, TX.
65
3. Newell, C.J., J.W. Winters, H.S. Rifai, R.N. Miller, J. Gonzales, and T.H. Wiedemeier. 1995. Modeling intrinsic remediation wi1h mu!!i-
ple electron acceptors: Results from seven sites. In: Proceedings
of the Petroleum Hydrocarbons and Organic Chemicals in Ground Water Conference, Houston, TX, November. National Ground Waler Associalion. pp. 33-48.
4. Newell, C.J., R.K. Mcleod, and J.R. Gonzales. 1996. BIOSCREEN Natural Attenua1ion Decision Support System, Ver-sion 1.3, U.S. Air Force Center for Environmen1al Excellence, Brooks AFB, San Anton·10, TX.
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B-5 KINETICS OF BIOTRANSFORMATION
\ \TN\SYS' IJAT,\'\l'RO,J\Q;!J:L02\npp,•ndi~ t·ov,:rs.drx:
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Environmental Chemistry and the Kinetics of Biotransformation of
Chlorinated Organic Compounds in Ground Water
John T. Wilson, Donald H. Kampbell, and James W. Weaver
U.S. Environmental Protection Agency, National Risk Management Research Laboratory,
R.S. Kerr Research Center, Ada, Oklahoma
Introduction
Responsible management of the risk associated with
chlorinated solvents in ground water involves a realistic
assessment of the natural attenuation of these com-
pounds in the subsurface before they are captured by
ground-water production wells or before they discharge
to sensitive ecological receptors. The reduction in risk is
largely controlled by the rate of the biotransformation of
the chlorinated solvents and their metabolic daughter
products. These rates of oiotransformation are sensitive
parameters in mathematical models describing the trans-
port of these compounds to environmental receptors.
Environmental Chemistry of
Biodegradation of Chlorinated Solvents
[This section is designed specifically for engineers and
mathematical modelers who have little or no chemistry
background; other readers may wish to proceed directly
to the next section.]
The initial metabolism of chlorinated solvents such as
tetrachloroethylene, trichloroethylene, and carbon tetra-
chloride in ground water usually involves a biochemical
process described as sequential reductive dechlorina-
tion. This process only occurs in the absence of oxygen,
and the chlorinated solvent actually substitutes for oxy-
gen in the physiology of the microorganisms carrying out
the process.
The chemical term "reduction" was originally derived
from the chemistry of smelting metal ores. Ores are chemi-
cal compounds of metal atoms coupled with other materi-
als. As the ores are smelted to the pure element. the
weight of the pure metal are reduced compared with the
weight of the ore. Chemically, the positively charged metal
ions receive electrons to become the electrically neutral
pure metal. Chemists generalized the term "reduction"
133
to any chemical reaction that added electrons to an
element. In a similar manner, the· chemical reaction of
pure metals with oxygen results in the removal of elec-
trons from the neutral metal to produce an oxide. Chem-
ists have generalized the term "oxidation" to refer to any
chemical reaction that removes electrons from a mate-
rial. For a material to be reduced, some other material
must be oxidized.
The electrons required for microbial reduction of chlorin-
ated solvents in ground water are extracted from native
organic matter, from other contaminants such as the
benzene, toluene, ethylene, and xylene compounds re-
leased from fuel spills, from volatile fatty acids in landfill
leachate, or from hydrogen produced by the fermenta-
tion of these materials. The ele_ctrons pass through a
complex series of biochemical reactions that support the
growth and function of the microorganisms that carry out
the process.
To function, the microorganisms must pass the electrons
used in their metabolism to some electron acceptor. This
ultimate electron acceptor can be dissolved oxygen,
dissolved nitrate, oxidized minerals in the aquifer, dis-
solved sulfate, a dissolved chlorinated solvent, or carb-
on dioxide. Important oxidized minerals used as electron
acceptors include iron and manganese. Oxygen is re-
duced to water, nitrate to nitrogen gas or ammonia,
iron(III) or ferric iron to iron(II) or ferrous iron, manga-
nese(IV) to manganese(II), sulfate to sulfide ion, chlo-
rinated solvents to a compound with one less chlorine
atom, and carbon dioxide to methane. These processes
are referred to as aerobic respiration, nitrate reduction,
iron and manganese reduction, sulfate reduction, reduc-
tive dechlorination, and methanogenesis, respectively.
The energy gained by the microorganisms follows the
sequence listed above: oxygen and nitrate reduction
provide a good deal of energy, iron and manganese
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reduction somewhat less energy, sulfate reduction and
dechlorination a good deal less energy, and methano-
genesis a marginal amount of energy. The organisms
carrying out the more energetic reactions have a com-
petitive advantage; as a result, they proliferate and ex-
haust the ultimate electron acceptors in a sequence.
Oxygen and then nitrate are removed first. When their
supply is exhausted, then other organisms are able to
proliferate, and manganese and iron reduction begins.
If electron donor supply is adequate, then sulfate reduc-
tion begiris, usually with concomitant iron reduction,
followed ultimately by methanogenesis. Ground water
where oxygen and nitrate are being consumed is usually
referred to as an oxidized environment. Water where
sulfate is being consumed and methane is being pro-
duced is generally referred to as a reduced environment.
Reductive dechlorination usually occurs under sulfate-re-
ducing and methanogenic conditions. Two electrons are
transferred to the chlorinated compourid being reduced.
A chlorine atom bonded with a carbon receives one of
the electrons to become a negatively charged chloride
ion. The second electron combines with a proton (hydro-
gen ion) to become a hydrogen atom that replaces the
chlorine atom in the daughter compound. One chlorine
at a time is replaced with hydrogen; as a result, each
transfer occurs in sequence. As an example, tetrachlo-
roethylene is reduced to trichlorethylene, then any of the
three dichloroethylenes, then to monochloroethylene
(commonly called vinyl chloride), then to the chlorine-
free carbon skeleton ethylene, then finally to ethane.
Kinetics of Transformation in Ground Water
Table 1 lists rate constants for biotransformation of
tetrachloroethylene (P.E.), trichloroethylene (TCE),
cis-dichloroethylene (cis-DCE), and vinyl chloride
extrapolated from field-scale investigations. In some
cases, a mathematical model was used to extract a rate
constant from field data; however, many of the rate
constantswere calculated by John Wilson from publish-
ed raw data. In several cases, the primary authors did
not choose to calculate a rate constant or felt that their
data could not distinguish degradation from dilution or
dispersion.
The data were collected or estimated to build a statistical
picture of the distribution of rate constants, in support of
a sensitivity analysis of a preliminary assessment using
published rate constants. They serve as a point of ref-
erence for "reasonable" rates of attenuation; applying
them to other sites without proper site-specific validation
is inappropriate.
Table 1. Apparent Attenuation Rate Constants (Field Scale Estimates)
Distance Time From Residence Vinyl
Location Reference From Source Source Time TCE cis-OCE Chloride
(meters) (years) (years) Apparent Loss Coefficient (1/year)
St. Joseph, Ml 1-3 130 to 390 3.2 to 9.7 6.5 0.38 0.50 0.18
390 to 550 9.7 to 12.5 2.8 1.3 0.83 0.88
550 to 855 12.5 to 17.9 5.4 0.93 3.1 2.2
240 to 460 2.2 to 4.2 2.0 1.4 Produced Produced
Picatinny 4, 5 320 to 460 2.9 to 4.2 1.3 1.2 Produced Produced
Arsenal, NJ 240 to 320 2.2 to 2.9 0.7 1.6
O to 250 0.0 to 2.3 0.5
Sacramenlo,CA 6 70 to 300 0.5 to 2.3 1.8 1.1 0.86 3.1
Neece Park, NY 7 0 to 570 0.0 to 1.6 1.6 0.7
Oto 660 o.o to 1.8 1.8 0.7
Plattsburgh Weidemeider, Oto 300 0.0 to 6.7 6.7 1.3 Produced Produced
AFB, NY this volume 300 to 380 6.7 to 8.6 1.9 0.23 0.6 1.16
380 to 780 8.6 to 17.7 9.1 Absent 0.07 0.47
TibbiU's Road, NH B. Wilson, a to 24 0.0 to 2.4 2.4 0.21 Produced
!his volume Oto 40 o.o to 6.4 6.4 0.42 0.68 a to 55 a.a to 10 10 0.73 > 0.73
San Francisco 8 4.4 5.11
Bay Area, CA
Per1h, Australia 9 O to 600 a.a to 14 0.32
Eiclson AFB, AK 10 0.73
2.3
No1 identified 11 0.8 0.8 0.8
Cecil Field Chapelle, 0 !O 140 0.0 to 1.2 1.2 3.3 to 7.3 3.3 to 7.3
NAS, FL this volume
134
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The estimates of rates of attenuation tend to cluster
within an order of magnitude. Figure 1 compares the
rates of removal of TCE in those plumes that demon-
strated evidence of biodegradation. Most of the first-or-
der rates are very close to 1.0 per year, equivalent to a
half life of 8 months. Table 1 also reveals that the rate
of removal of P.E., TCE, and cis-DCE, and vinyl chloride
are similar; they vary by little more than one order of
magnitude.
Table 2 lists first-order and zero-order rate constants
determined in laboratory microcosm studies. The rates
of removal in the.laboratory microcosm studies are simi-
lar to estimates of removal at field scale for TCE, cis-
DCE, and vinyl chloride. Rates of removal of
1, 1, Hrichloroethane (1, 1, 1-TCA) are similar to the rates
of removal of the chlorinated alkenes.
Summary
The rates of attenuation of chlorinated solvents and their
less chlorinated daughter products in ground water are
slow as humans experience time. If concentrations of
chlorinated organic compounds near the source are in
the range of 10,000 to 100,000 micrograms per liter,
then a residence time in the plume on the order of a
decade or more will be required to bring initial con-
centrations to current maximum contaminant levels for
~ ~ 'C
TCE Removal ln Field
~6 _11 ............... ~~ ..............
' i ~ ~ \ • I I O 10 11 '2 ll 1' •I It '.1
Sites
Figure 1. The first-order rate constant tor biotransformation of
TCE in a variety of plumes of contamination in ground
water.
drinking water. Biodegradation as a component of natu-
ral attenuation can be protective of ground-water quality
in those circumstances where the travel time of a plume
to a receptor is long. In many cases, it will be necessary
to supplement the benefit of natural attenuation with
some sort of source control or plume management.
Table 2. Apparent Attenuation Rate Constants From Laboratory Microcosm Studies
Distance Time
Location of From From Incubation Vinyl
Material Reference Source Source Time TCE cis-DC_E Chloride 1,1,1-TCA
Apparent First-Order Loss (1/year)
(meters) (years} (years) Apparent Zero Orderloss (µg/C daj/)_
Laboratory Microcosm Studies Done on Material From Field-Scale Plumes
Pica tinny 12 240 2.2 0.5 0.64 0.52
Arsenal, NJ 13 320 2.9 0.5 0.42 9.4
460 4.2 0.5 0.21 3.1
St. Joseph, Ml 14 0.12, 0.077 1.8, 1.2
Traverse City, Ml 15 300 1.8 1.8
Tibbitts Road, NH 16 At Source 4.8
Laboratory Microcosm Studies Done on Material Not Previously Exposed to the Chlorinated Organic Compound
Norman
Landfill, OK
FL
17
18
16
19
Aerobic
material
Sulfate
reducing
MethanM
ogenic
Reducing
Reducing
4.2
10
1.28
1.62 1.75
1.20
1.65 1.42
3.6
0.012
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References
1. Semprini, L, P.K. Kitanidis, D.H. Kampbe!I, and J.T. Wilson. An-
aerobic Transformation of chlorina1ed aliphatic hydrocarbons in
a sand aquifer based on spatial chemical distributions. Water
Resour. Res. 31(4):1051-1062.
2. Weaver, J.W., J.T. Wilson, D.H. Kampbell, and M.E. Randolph.
1995. Field derived transformation rates for modeling natural
bioattenuation of trichloroethene and its degradation products. In:
Proceedings: Nex1 Generation Environmental Models and Com-
putational Methods, August 7-9, Bay City, Ml.
3. Wilson, J.T., J.W, Weaver, D.H. Kampbell. 1994. Intrinsic biore-
mediatian of TCE in ground water at an NPL site in St. Joseph,
Michigan. In: U.S. EPA. Symposium on Natural Attenuation of
Ground Water, Denver, CO, August 30-September 1. EPA/600/R-
94/162. pp. 116-119.
4. Ehlke, T.A., B.H. Wilson, J.T. Wilson, and T.E. lmbrigiotta. 1994.
In-situ biotransformation of trichloroethylene and cis-1,2-dichlo-
roethy!ene at Picatinny Arsenal, New Jersey, In: Morganwalp,
D.W., and D.A. Aronson, eds. Proceedings of the U.S. Geological
Survey Toxic Substances Hydrology Program, Colorado Springs,
Colorado, September 20-24, 1993. Water Resources Investiga-
tions Report 94-4014. In press.
5. Martin, M., and T.E. lmbrigiot1a. 1994. Co'ntamination of ground
water with trichloroethylene at the Building 24 site at Picatinny
Arsenal, New Jersey. ln: U.S. EPA. Symposium on Natural At-
1enuation of Ground Water. Denver, CO, August 30-September
1. EPN600/R·94/162. pp. 109·115.
6. Cox, E., E. Edwards, L. Lehmicke, and D. Major. 1995. Intrinsic
biodegradation of trichloroethylene and trichloroethane in a se-
quential anaerobic-aerobic aquifer. In: Hinchee, R.E., J.T. Wilson,
and D.C. Downey, eds. Intrinsic bioremediation. Columbus, OH:
Batte!le Press. pp. 223-231.
7. Lee, M.D., P.F, Mazierski, R.J. Buchanan, Jr., O.E. Ellis, and L.S.
Sehayek. 1995. Intrinsic and in situ anaerobic biodegradation of
chlorinated solvents at an industrial landfill. In: Hinchee, R.E., J.T.
Wilson, and D.C. Downey, eds. Intrinsic bioremedialion. Colum-
bus, OH: Battelle Press. pp. 205-222.
8. Buscheck, T., and K. O'Reilly. 1996. Intrinsic anaerobic biodegra-
dation of chlorinated solvents at a manufaciuring plant. Abstract
presented at lhe Conference on ,lritrinsic Remediation of Chlorin-
ated Solvents, Salt Lake Ci!y, UT, April 2. Columbus, OH: Battelle
Memorial Institute.
9. Benker, E., G.B. Davis, S. Appleyard, D.A. Berry, and T.A. Power.
1994. Groundwater contamination by trichforoe1hene (TCE) in a
residen1ial area of Penh: Distribution, mobility, and impfica1ions for
management. In: Proceedings of the Waler Down Under 94, 25th
Congress of IAH, Adelaide, South Australia, November 21-25.
136
10. Gorder, K.A., R.R. Dupont, D.L. Sorensen, and M.W. Kem-
blowski. 1996. ln1rinsic remediation of TCE in cold regions. Ab-
stract presented al the Conference on Intrinsic Remediation of
Chlorina!ed Solvents, Salt Lake City, UT, April 2. Columbus, OH:
Battel!e Memorial Institute.
11. De, A., and D. GraVes. 1996. Intrinsic bioremediation of chlorin-
ated aliphatics and aromatics at a complex industrial site. Ab-
stract presented a1 the Conference on Intrinsic Remediation al
Chlorinated Solvents, Salt Lake City, UT, April 2. Columbus, OH;
Battelle Memorial Institute.
12. Ehlke, T.A., T.E. !mbrigiotta, B.H. Wilson, and J.T. Wilson. 1991.
Biotransformation of cis-1,2-dichloroethylene in aquifer material
from Picatinny Arsenal, Morris County, New Jersey. In: U.S. Geo-
logical Survey Toxic Substances Hydrology Program-Proceed-
ings of the Technical Meeting, Mon1erey, CA, March 11-15. Water
Resources Investigations Repon 91-4034. pp. 689-697.
13. Wilson, B.H., T.A. Ehlke, T.E. lmbigiotta, and J.T. Wilson. 1991.
Reductive dechlorination of trichloroe1hylene in anoxic aquifer
malerial from Pica tinny Arsenal, New Jersey. !n; U.S. Geological
Survey Toxic Subs1ances Hydrology Program-Proceedings of
the Technical Meeting, Monterey, CA, March 11-15. Water Re-
sources Investigations Report 91-4034. pp. 704-707.
14. Haston, Z.C., P.K. Sharma, J.N.P. Black, and P.L. McCany. 1994.
Enhanced reductive dechlorination of chlorinated ethenes. In:
U.S. EPA. Proceedings of the EPA Symposium on Bioremediation
ot Hazardous Wastes: Research, Development, and Field Evalu-
ations. EPNSOO/A-94/075. pp. 11-14. .
15. Wilson, B.H., J.T. Wilson, D.H. Kampbefl, B.E. Bledsoe, and J.M.
Armstrong. 1990. Biotransformation of monoaromatic and chlo-
rinated hydrocarbons at an avia1ion gasoline spil! si1e. Geomicro-
biol. J. 8:225·240.
16. Parsons, F., G. Barrio Lage, and R. Rice. 1985. Biotransformation
of chlorinated organic solvents in static microcosms. Environ.
Toxicol. Chem. 4:739-742.
17. Davis, J,W., and C.L. Carpen1er. 1990. Aerobic biodegradation
of vinyl chloride in groundwater samples. Appl. Environ, Microbial.
56(12):3878-3880.
18. Klecka, G.M., S.J. Gonsior, and D.A. Markham. 1990. Biological
transformations of 1, 1, 1-trich!oroethane in subsurface soils and
ground water. Environ. Toxicol. Chem. 9:1437-1451.
19. Barrio-Lage, G.A., F.Z. Parsons, R.M. Narbaitz, and P.A. Lorenzo.
1990. Enhanced anaerobic biodegradation of vinyl chloride in
ground waler. Environ. Toxicol. Chem. 9;403-415.
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ATTACHMENT 1
PILOT TEST WORK PLAN
\ \ TN\SYS\DATA \PROJ\.0313.02\nppendix cover11.doc
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PILOT TEST WORK PLAN
FOR OPERABLE UNIT THREE (OU3)
FCX-STATESVILLE SUPERFUND SITE,
STATESVILLE, NORTH CAROLINA
F: \DAT A\ p roj'\0313. 02\ptwp•covcr .doc
Prepared for:
EL PASO ENERGY CORPORATION
1001 Louisiana Street
Houston, TX 77002
Prepared by:
ECKENFELDER INC.®
227 French Landing Drive
Nashville, Tennessee 37228
[phone]
May 1998
0313.02
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TABLE OF CONTENTS
Table of Contents
List of Tables
List of Figures
1.0 INTRODUCTION
2.0 TECHNOLOGIES DESCRIPTION
3.0 PILOT TEST OBJECTIVES
4.0 PILOT TEST PROCEDURES
4.1 Well and Monitoring Probe Installation
4.2 Equipment Set-Up and Testing
4.3 Test Operation and Sequencing
4.3.1 Pilot Test Part 1
4.3.2 Pilot Test Part 2
4.3.3 Pilot Test Part 3
4.3.4 Pilot Test Part 4
4.3.5 Pilot Test Part 5
4.3.6 Pneumatic Permeability Test
4.4 Monitoring Procedures
4.5 Effluent and Residuals Treatment
5.0 DATA REDUCTION AND EVALUATION
6.0 PILOT TEST SCHEDULE
APPENDICES
Appendix A-Well Cross-Sections Intercepting Monitoring Well W-9
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11
11
1-1
2-1
3-1
4-1
4-1
4-2
4-4
4-4
4-5
4-6
4-6
4-6
4-7
4-7
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LIST OF TABLES
Follows
Table No. Title Page No.
3-1 Objectives of Pilot Test 3-1
4-1 Summary of Pilot Test Part 1 (SVE Only), Target Operating
Conditions and Data Collection 4-4
4-2 Summary of Pilot Test Part 2, Target Operating Conditions and
Data Collection 4-4
4-3 Summary of Pilot Test Part 3, Target Operating Conditions and
Data Collection 4-4
4-4 Summary of Pilot Test Part 4, Target Operating Conditions and
Data Collection 4-4
4-5 Summary of Pilot Test Part 5, Target Operating Conditions and
Data Collection 4-4
LIST OF FIGURES
Figure No. Title
4-1 Proposed Location for Pilot Test
4-2 Proposed Layout of Pilot Test Wells and Monitoring Probes
4-3 Configuration of Pilot Test Wells and Monitoring Probes
4-4 Flow Diagram of Pilot Test System
6-1 Schedule for OU3 Pilot Test
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Page No.
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4-1
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LO INTRODUCTION
The Pilot Test Work Plan (PT Work Plan) describes the design, implementation, and
evaluation of an air sparging and soil vapor extraction (SVE) pilot test. The pilot
test results will be used to determine the design parameters and site-specific
limitations of SVE alone and air sparging with SVE (AS/SVE). The PT Work Plan is
organized as follows:
Section 2.0 Technologies Description
Section 3.0 Pilot Test Objectives
Section 4.0 Pilot Test Procedures
Section 5.0 Data Reduction and Evaluation
Section 6.0 Pilot Test Schedule
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2.0 TECHNOLOGIES DESCRIPTION
The technologies to be evaluated during the pilot test are air spargmg and SVE.
Monitored natural attenuation may be used in conjunction with these technologies
as part of the remedial action. The Remedial Design Work Plan (RD Work Plan)
contains more detailed descriptions of air sparging and SVE. These two technologies
can be summarized as follows:
Air Sparging: Pressurized air is injected into the aquifer through wells
screened over narrow intervals located near the bottom of the aquifer. The
air transfers volatile organic compounds (VOCs) from the saturated zone to
the unsaturated or vadose zone.
SVE: Air is extracted under reduced pressure from wells screened across a
portion of the unsaturated zone. The VOCs originally present in the
unsaturated zone and the VOCs introduced to the unsaturated zone from
the saturated zone by air sparging are extracted with the SVE air flow.
The off-gas treatment is dependent on site-specific emissions and
regulatory requirements.
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3.0 PILOT TEST OBJECTIVES
The pilot test objectives are to investigate and determine the physical characteristics
of the soil in the vadose and saturated zones in relationship to the operation of air
sparging and SVE. Information obtained will include the approximate dimensions of
the zone of influence of the air sparging and SVE wells, whether SVE can capture
the air injected through air sparging, and other engineering design data for use in
designing a full-scale system. The pilot test has been organized into five parts and
Table 3-1 lists the objectives to be addressed by each part. The information obtained
from the pilot test will be used in conjunction with existing data to determine the
site-specific limitations of air sparging and SVE either alone or in conjunction with
other technologies such as monitored natural attenuation. In addition to the five
part pilot test, a pneumatic permeability test of the vadose zone beneath the
Burlington textile plant will be performed using an SVE well located inside the
building.
Pilot Test Part 1 has been designed as an SVE-only test to collect data on the
physical performance of SVE. These physical performance parameters are the air
flow/pressure relationship, i.e., the range of flow rates and pressures or vaccua that
can be achieved; the pneumatic permeability of the vadose zone; the radius of
influence of an SVE well relative to the air flow rates achievable; the groundwater
upwelling due to SVE and relative to the air flow rates; and the spatial influence of
SVE at various depths and distance from the SVE well, i.e., the homogeneity of the
response of the system to SVE.
The information obtained from Pilot Test Part 1 will be used to tailor Pilot Test
Parts 2 and 3 to the actual field conditions. Parts 2 and 3 have been designed as
air-sparging and SVE (AS/SVE) tests to collect data on the physical performance of
the combined AS/SVE system. Part 2 will be performed using a shallow air sparging
well; Part 3 will be performed using a deeper air sparging well. The physical
performance parameters to be measured in Parts 2 and 3 are: the air flow/pressure
relationship, i.e., the range of air flow rates and pressures or vaccua that can be
achieved; the radius of influence of an air sparging point relative to the injection
F: \DAT A \proj\0313 .02,p twp.doc 3-1
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TABLE 3-1
OBJECTIVES OF PILOT TEST
FCX-STATESVILLE SUPERFUND SITE'OU3
Pilot Test Part Number
Pilot Test Objectives
Physical Characteristics
SVE Data Objectives
Flow/Pressure Relationship
Pneumatic Permeability ofVadose Zone
Radius oflnfluence Versus Flow
Groundwater Upwelling versus Flow
Homogeneity of Response to SVE
Air Sparging Data Objectives
Flow/Pressure Relationship
Radius of Influence versus Flow
Groundwater Upwelling versus Flow
Homogeneity of Response to Air
Sparging
VOC Characteristics
Vadose Zone
Concentration versus Time for SVE
Mass Removal versus Time
Rebound
Groundwater
Concentration versus Time for AS/SVE
Mass Removal versus Time
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
•Part 2 will be conducted with a shallow air sparging well; Part 3 will be conducted with a deeper air
sparging well.
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flow rates used; the groundwater upwelling due to arr spargmg and SVE and
relative to the air flow rates; and the spatial influence of air sparging with SVE, i.e.,
the homogeneity of the response of the system to air sparging with SVE. Part 3 is
basically a repeat of Part 2 using a deeper air sparging well. Part 3 will be
performed after a prescribed period of "down time" which will allow the system to
stabilize after the Part 2 test.
The results of Pilot Test Parts 2 and 3 will be evaluated to determine which arr
sparging well, i.e., the shallow or the deeper, will be used for Pilot Test Parts 4 and
5. Parts 4 and 5 have been designed to collect data on the voe characteristics of the
vadose zone and the groundwater as air sparging with SVE is performed. Vapor
samples will be collected at the beginning of Part 4, before air sparging begins, to
assess the removal of voes from the vadose zone by SVE. Parts 4 and 5 will provide
data on the concentration of voes in the extracted vapor versus time and on the
mass removed versus time for voes in the vadose zone and in the groundwater.
Part 5 is basically a repeat of Part 4 after a prescribed period of "down time" which
will allow for the collection of voe concentration data that will assist in
determining the rebound time of the system, i.e., the change of voe concentration in
the vadose zone and groundwater after the system has been shut down for a period
of time then restarted. The concentrations of voes in the extracted vapor will be
monitored with portable field instruments during the performance of Parts 4 and 5.
Vapor samples will also be collected for laboratory analysis during these two tests.
The pneumatic permeability test of an SVE well inside the building will be
performed separately from the Pilot Test Parts 1 through 5. This test will be
conducted during the "down time" between Pilot Test Parts 2 and 3 or Parts 4 and 5.
The main objective of the pneumatic permeability test is to collect physical data on
the relationship between air flow rates and vacuua in the vadose zone underneath
the building.
F:\DAT A \proj\0313.02\ptwp.doc 3-2
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4.0 PILOT TEST PROCEDURES
The AS/SVE Pilot Test will be performed in five consecutive parts at the Site. A
summary of the procedures that will be implemented during the pilot test follows.
4.1 WELL AND MONITORING PROBE INSTALLATION
The proposed location of the pilot test in OU3 is shown in Figure 4-l. Figure 4-2
shows the proposed layout of the air sparging wells, SVE wells, and monitoring
probe clusters. The proposed location of the pilot test was determined based on
accessibility, presence of VOes in groundwater, depth to groundwater, and depth to
bedrock. To the extent practical, the test area is representative of a significant area
of the OU3 Site.
Monitoring wells W-9s and W-9i are in the immediate area of the proposed pilot test.
Appendix A contains monitoring well cross-sections B-B' and D-D' from the RI.
Groundwater samples ·from the shallow well, W-9s, should be representative of the
voes in the groundwater that will be sparged during the pilot test. During the
Remedial Investigation (RI), several VOes were identified in OU3, however, the only
voe identified in W-9s was tetrachloroethylene (PeE), which was present at a
concentration of 6,800 µg/L. The soil gas survey also identified PeE at vapor
concentrations as high as 6,463 µg/L in the area of the proposed pilot test.
Trichloroethylene (TeE) was detected at 9 µg/L during the soil gas survey. Since
PeE and TeE are primary contaminants on site, the location chosen for the pilot
test should provide chemical data that is representative of the site.
The design configurations for the air sparging wells, SVE wells, and monitoring
probe clusters are shown in Figure 4-3. The "shallow" air sparging injection well
(AS-1) will be installed to an estimated depth of 55 feet with a two-foot screened
interval located in the saprolite formation; the "deep" air sparging injection well
(AS-2) will be installed at an estimated depth of 72 feet with a two-foot screened
interval located in the saprolite formation immediately above the bedrock surface.
V:'\DAT A \11 roj\0313 ,02\pt "'JI .doc 4-1
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z-..... -r-
~ Proposed Locotion for Pilot Test
• Shallow Monitoring Well Location
e Intermediate Monitoring
Well Location
o Deep Monitoring Well Location
ii! Extraction Well Location
D Proposed Deep Monitoring Well Location
Tetrochloroethene (PCE) Shallow
Groundwater lsoconcentration Contour
(Dashed where Inferred)
0313
FIGURE 4-1
PROPOSED LOCATION FOR
PILOT TEST
FCX-STATESVlLLE SUPERFUND SITE
STATESVILLE, NORTH CAROLINA
4/98
k--==-=t-
ECKENFELDER INC.•
Noshvine, T ennenee
Mon .. cn, New Jersey
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I 0 0 N
II
I -
w _J
i'i (/)
I f-0 _J a_
I OJ "' c-
en
w
I f-<OC 0
N
I
I " I n
n 0
I 0 2
<.:)
2
j;
I iJ: 0
2d
N
d ,,,·····
d/2 /
/
LEGEND:
~ Air Sparging Well
I
0 SVEWell
A Monhoring Probe Cluster
NOTE:
6" Storm Drain
Burlington
Textile Plant
~
SVE-2
(location inside building
is to be determined)
See Figure 4-1 for propcsed location for pilot test.
d Distance from Depth of Water Table to Bottom of Air Sparging Well
0313
FIGURE 4-2
PROPOSED LAYOUT OF
PILOT TEST WELLS AND
MONITORING PROBES
FCX-STATESVILLE SUPERFUND SITE
STATESVILLE. NORTH CAROLINA
5/98
~ Ncshvilln, Tennessee
~ahwoh, New Jersey ECKENFEWER INC."
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w _,
i'i
VJ
f-'3 a.
n
I " I ,,,
n
0
0 z
~
!
0
~35'
Typical
Monitoring Probe Cluster
ABCD
Grout
Bentonite
A~30'
B ~39'
C ~53'
D ~70'
AS-2 AS-1 SVE-1 SVE-2
3'to 4'
(typ)
~72'
~55'
FIGURE 4-3
CONFIGURATION OF PILOT TEST
WELLS AND MONITORING PROBES
FCX-STATESVILLE SUPERFUND SITE
STATESVILLE, NORTH CAROLINA
0313
~
ECKENFELDER INC.'
5/98
Nashville, Tenne,~ee
Mahwah, New Jer.,ey
~)
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The SVE extraction well for the pilot test (SVE-1) will be installed to an estimated
depth of 35 feet with the base of the 20-foot screen at the water table and will be
placed in close proximity to the air sparging wells (within approximately three to
four feet horizontally).
Monitoring probes will be installed in both the vadose and saturated zones and will
be placed in clusters of four at varying distances and directions from the air
sparging wells (Figure 4-2). As illustrated in Figure 4-3, each monitoring probe
cluster will consist of a multi-screen completion with one probe screened in the
vadose zone (Probe A), a second probe screened just below the groundwater level
(Probe B), a third probe at a depth of approximately 53 feet (Probe C), and a fourth
probe at a depth of approximately 70 feet (Probe D).
A second SVE well (SVE-2) will be installed inside the Burlington textile plant. This
well will have a 15 foot screened section whose lower end is at approximately 20 feet
in the vadose zone which is approximately 15 feet above the water table. This SVE
well will be used to test the pneumatic permeability of the vadose zone underneath
the building.
The Addendum to the Field Sampling Plan (FSP) contains instructions for the
installation of the wells and monitoring probes. The Addendum to the FSP is
Attachment 2 of the RD Work Plan.
4.2 EQUIPMENT SET-UP AND TESTING
Figure 4-4 is a flow diagram of the pilot test system. The system will be operated by
injecting air into the groundwater through the air sparging well and simultaneously
extracting vapors from the vadose zone via the SVE well. Air may be supplied from
the Burlington plant air system or from an air compressor. The air supply should be
sufficient for the pilot test with an estimated capacity of 30 cfm at 100 psi. The
plant air, if used, will be routed to the pilot test system using compressed air hose
and/or Schedule 80 PVC piping. The air supply will be fitted with a pressure
F:\DAT A \proj\031 J. 02\ptwp. doc 4-2
s "-
v I v
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"'
"' 0
-------------------
r------------7
I I
I ~~ I
I Plant Air --pic11----1 Air
I (or compressor) Pressure Filter
I Regulator I L ____________ ....J
Air Supply
Monttoring Probe
(Typical)
AS-2
Well
,--------~leoo~aiv~-------------1
I Vacuum Relief Discharge I
I I
I T I
I .----P I I .-----. -~~ ·~ .... ~ I r----i-➔.J Liquid 1----1 Air 1-..._ __ -fl► I
Separator Filter I
SVE-1
Well
AS-1
Well d/2 -~* d
I ....__;;;;;;-~ ,-J. I I -Blower · Activated Carbon I
I I
1--------------------------~
)I
0
SVE Unit
LEGEND:
Extracted gas flow
Injected air flow
Elow element, ]:ressure element, Iemperature element,
and Sample port
Vaive
_j-72' FIGURE 4-4
FLOW DIAGRAM OF
PILOT TEST SYSTEM
FCX-STATESVILLE SUPERFUND SITE
STATESVILLE, NORTH CAROLINA
0313
l--,., a
ECKENFELDER INC!
5/98
Noshvilte, Tenriessee
Mohwoh. New Jeruey
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regulator to control the spargmg rate and a filter to remove oil. The well head
assemblies and monitoring probes will be fitted with the instrumentation shown in
Figure 4-4.
During the pilot test, vapors from the vadose zone will be extracted and routed to
the SVE unit using a blower with an estimated capacity of 200 cfm at 5 inches
mercury. The estimated flow and pressure ratings of the equipment will meet or
exceed that anticipated for the pilot test. The extracted vapors will pass through a
liquid separator, an air filter, and the blower. Because the discharge from the
blower will be near workers, the extracted vapors will also pass through two
activated carbon canisters in series prior to discharge for the health and safety of
the workers. A flow indicator will be located between the liquid separator and air
filter. The SVE piping from the SVE well to the discharge port will be 3-inch or
4-inch Schedule 40 PVC.
The carbon canisters will each contain 170 pounds of virgin granular activated
carbon, which is a strong absorber for PCE and TCE (the VOCs anticipated at the
test location). The canisters have a maximum rated flow of 300 cfm. Sample ports
will be located after each carbon canister so that measurements can be made with
an organic vapor analyzer (OVA) during operations to check for VOC breakthrough
of the first carbon canister. Should VOC breakthrough occur, the blower would be
shut down, the second canister would be relocated to the first position, and a new
canister would be installed at the second position.
The pilot system will be checked for correct operations and air leaks after the
equipment is in place, the piping is connected, and instrumentation is installed, but
prior to final connection of the piping to the air sparging well and SVE well. Any
deficiencies that are identified will be corrected prior to beginning the pilot test.
Once the pilot system is checked out and· ready for the pilot test, a round of pre-test
groundwater samples will be collected and analyzed from the two air sparging wells
and from an estimated 10 of the monitoring probes that are in the saturated zone.
The groundwater samples will be collected according to the procedure in the
F: \DAT A \proj\0313 ,02\ptwp .doc 4-3
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document, "Field Sampling Plan, FCX Statesville Operable Unit 3, Iredell County,
North Carolina," prepared by Aquaterra, Inc. and dated February 1994. This
document will be referred to as the Aquaterra FSP. The groundwater samples will
be analyzed in the field for the natural attenuation field parameters and in the
labora:ory for VOCs and other parameters according to the Addendum to the
Quality Assurance Project Plan (QAPP), which is included as Attachment 3 of the
RD Work Plan.
4.3 TEST OPERATION AND SEQUENCING
The pilot test will be conducted in five parts, each taking an estimated 6 to 10 hours
to perform. Parts 1, 2, and 3 are intended to provide physical performance data for
SVE and air sparging. Parts 4 and 5 are intended to provide data related to VOC
removal by air sparging and SVE (refer to Table 3-1 for test objectives). Tables 4-1
through 4-5 present the target operating conditions and data collection for each part
of the pilot test.
4.3.1 Pilot Test Part 1
During Part 1, the SVE extraction well will be operated at three different extraction
flow rates (Qmax, 2/3 Qmax, and 1/3 Qmax) to determine the SVE radius of influence as a
function of extraction flow rate (refer to Table 4-1). The extraction flow rate, vapor
temperature, and vacuum will be recorded and vapors will be monitored for VOCs
with an OVA. Air sparging will not be performed during the Part 1 testing. The
maximum flow rate (Qmax) attainable from the SVE well will be determined and is
expected to fall within the range of 20 to 100 cfm. Vacuum readings will be
measured at each of the vadose zone monitoring probes as a function of time. Water
levels will be measured at the air sparging well and at the five upper
groundwater-monitoring probes (B) as indicated in Table 4-1. Data will also be
collected from the SVE unit instrumentation.
F:\DAT A \proj\0313. 02\ptwp .doc 4-4
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TABLE 4-1
SUMMARY OF PILOT TEST PART 1 (SVE ONLY)
TARGET OPERATING CONDITIONS AND DATA COLLECTION
FCX-STATESVILLE SUPERFUND SITE OU3
Parameter
Target Operating Conditions
SVE Flow Rate(s)
Air Sparging Flow Rate(s)
Test Duration(s)
Data Collection
SVE Well (SVE-1)
Air Sparging Wells
(AS-1 and AS-2)
Monitoring Probes:
Lower Vadose Zone (A)
Upper Groundwater (B)
Intermediate Groundwater (C)
Lower Groundwater (D)
SVE Pilot Test Unit
F: \DAT A \proj\0313. 02\l040 I pt.doc
Description
Maximum flow rate (Qmn,), 2/3 Qmn,, & 1/3 Qmn,
NA (air sparging not operated)
Operate SVE for 90 min. at each flow rate
Measure SVE flow, temperature, and vacuum
prior to startup
at t=l, 15, & 30 min. then at 30 min. intervals for each flow
Monitor SVE vapors with OVA
prior to SVE startup
at t=5, 10, & 30 min. then at 30 min. intervals
Measure water table level
prior to startup
just prior to end of each test condition
Measure vacuum at probe locations
prior to startup
at t=5, 10, & 30 min. then at 30 min. intervals for each flow
Measure water table level at probe locations
prior to startup
just prior to end of each test condition
NA (air sparging not operated)
NA (air sparging not operated)
Measure vacuums, pressures, flows, and temperatures
prior to SVE startup
at startup then at 30 min. intervals
before and after flow adjustments
Measure effluent from carbon for breakthrough with OVA
at startup then at 60 min. intervals
PagC!loft
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TABLE 4-2
SUMMARY OF PILOT TEST PART 2
TARGET OPERATING CONDITIONS AND DATA COLLECTION
FCX-STATESVILLESUPERFUND SITE OU3
Parameter
Target Operating Conditions
SVE Flow Rate(s)
Air Sparging Flow Rate(s)
Test Duration(s)
Helium (He) Injection
Data Collection
SVE Well (SVE-1)
Air Sparging Well (AS-1)
~·: \OAT A \11roj\OJ l J.02\t0402pt. doc:
Description
Flow rate to be determined following pilot test part 1
Determine air sparge flow rates for AS-1
Maximum flow rate (Qm.,), 2/3 Qmax, and 1/3 Qmax, start with
lowest flow rate and end with Qmax
Operate SVE until steady state flow and vacuums
Then operate air sparging for 60 min. at each flow rate
Inject He into air sparging well for 5 min. during each flow rate
Measure SVE flow, temperature, and vacuum
prior to SVE startup
at 15 min. intervals until steady state
at 30 min. intervals after air sparging startup
Monitor SVE vapors with OVA
prior to SVE startup
at t=5, 10, & 30 min. then at 30 min. intervals
Measure He
prior to He injection
at 5 min. intervals until He concentration peaks and then
monitor decrease in He
Measure pressure and flow
prior to air sparging startup
at 15 min. intervals after startup
Pag,•lof2
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TABLE 4-2 (Continued)
SUMMARY OF PILOT TEST PART 2
TARGET OPERATING CONDITIONS AND DATA COLLECTION
FCX-STATESVILLE SUPERFUND SITE OU3
Parameter
Data Collection (Continued)
Monitoring Probes:
Lower Va dose Zone (A)·
Upper Groundwater (B)
Intermediate Groundwater (C)
Lower Groundwater (D)
SVE Pilot Test Unit
F:\DAT A \p roj\03 l 3.02\l0402pt. doc
Description
Measure vacuum at probe locations
prior to SVE startup
immediately prior to air sparging startup
at t=5, 10, & 30 min. then at 30 min. intervals for each flow
Measure He at probe locations
prior to He injection
at 15 min. intervals until He concentration peaks and
dissipates
Measure water table level, He, DO, and pressure at probe
locations
prior to startup
at end of each test condition
Measure He at probe locations
prior to He injection
at 15 min. intervals until He concentration peaks and
dissipates
Measure He at probe locations
prior to He injection
at 15 min. intervals until He concentration peaks and
dissipates
Measure He at probe locations
prior to He injection
at 15 min. intervals until He concentration peaks and
dissipates
Measure vacuums, pressures, flows, and temperatures
prior to SVE startup
at startup then at 30 min. intervals
before and after flow adjustments
Measure effluent from carbon for breakthrough with OVA
at startup then at 60 min. intervals
TABLE 4-3
SUMMARY OF PILOT TEST PART 3
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TARGET OPERATING CONDITIONS AND DATA COLLECTION
FCX-STATESVILLE SUPERFUND SITE OU3
Parameter
Target Operating Conditions
SVE Flow Rate(s)
Air Sparging Flow Rate(s)
Test Duration(s)
I Helium (He) Injection
I Data Collection
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SVE Well (SVE-1)
Air Sparging Well (AS-2)
\ \TN\SYS\DATA \PHOJ\0313.02\ T0403PT.DOC
Description
Flow rate to be determined following pilot test part 1
Determine air sparge flow rates for AS-2
Maximum flow rate (Qm.,), 2/3 Qm,x, and 1/3 Qm,x, start with
lowest flow rate and end with Qmox
Operate SVE until steady state flow and vacuums
Then operate air sparging for 60 min. at each flow rate
Inject He into air sparging well for 5 min. during each flow rate
Measure SVE flow, temperature, and vacuum
prior to SVE startup
at 15 min. intervals until steady state
at 30 min. intervals after air sparging startup
Monitor SVE vapors with OVA
prior to SVE startup
at t=5, 10, & 30 min. then at 30 min. intervals
Measure He
prior to He injection
at 5 min. intervals until He concentration peaks and then
monitor decrease in He
Measure pressure and flow
prior to air sparging startup
at 15 min. intervals after startup
Page I of2
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TABLE 4-3 (Continued)
SUMMARY OF PILOT TEST PART 3
TARGET OPERATING CONDITIONS AND DATA COLLECTION
FCX-STATESVILLE SUPERFUND SITE OU3
Parameter
Data Collection (Continued)
Monitoring Probes:
Lower Vadose Zone (A)
Upper Groundwater (B)
Intermediate Groundwater (C)
Lower Groundwater (D)
SVE Pilot' Test Unit
\. \. TN\SYS\DAT A \PROJ\031 J .02\. '1'01 OJPT. DOC
Description
Measure vacuum at probe locations
prior to SVE startup
immediately prior to air sparging startup
at t=5, 10, & 30 min. then at 30 min. intervals for each flow
Measure He at probe locations
prior to He injection
at 15 min. intervals until He concentration peaks and
dissipates
Measure water table level, He, DO, and pressure at probe
locations
prior to startup
at end of each test condition
Measure He at probe locations
prior to He injection
at 15 min. intervals until He concentration peaks and
dissipates
Measure He at probe locations
prior to He injection
at 15 min. intervals until He concentration peaks and
dissipates
Measure He at probe locations
prior to He injection
at 15 min. intervals until He concentration peaks and
dissipates
Measure vacuums, pressures, flows, and temperatures
prior to SVE startup
at startup then at 30 min. intervals
before and after flow adjustments
Measure effluent from carbon for breakthrough with OVA
at startup then at 60 min. intervals
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TABLE 4-4
SUMMARY OF PILOT TEST PART 4
TARGET OPERATING CONDITIONS AND DATA COLLECTION
FCX-STATESVILLE SUPERFUND SITE OU3
Parameter
Target Operating Conditions
SVE Flow Rate(s)
Air Sparging Flow Rate(s)
Test Duration(s)
Description
Flow rate to be determined following pilot test part 3
Determine which air sparging well to use (AS-1 or AS-2)
Flow rate to be determined following pilot test part 3
Operate SVE until steady-state then
Operate air sparging until steady state
I Data Collection
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SVE Well (SVE-1)
Air Sparging Well
(either AS-1 or AS-2)
\ \TN\SYS\DATA \PROJ\0313.02\T0'1MPT.DOC
Measure SVE flow, temperature, and vacuum
prior to SVE startup
at 15 min. intervals until steady state
at 60 min. intervals after steady state
Monitor SVE vapors with OVA
prior to SVE startup
at t=5, 10, & 30 min. then at 30 min. intervals
Collect Tedlar bag vapor samples for VOC analysis
at time the OVA reading peaks
immediately prior to air sparging startup
after air sparging steady state
just prior to AS/SVE shutdown
Measure pressure and flow
prior to air sparging startup
at 15 min. intervals until steady state
at 60 min. intervals after steady state
Collect Tedlar bag vapor sample after steady state
Pagel of2
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TABLE 4-4 (Continued)
SUMMARY OF PILOT TEST PART 4
TARGET OPERATING CONDITIONS AND DATA COLLECTION
FCX-STATESVILLE SUPERFUND SITE OU3
Parameter
Data Collection (Continued)
Monitoring Probes:
Lower Vadose Zone (A)
Upper Groundwater (B)
Intermediate Groundwater (C)
Lower Groundwater (D)
SVE Pilot Test Unit
'\ \TN\SYS\DATA '\PROJ'\0313.02\T0-104PT.DOC
Description
Measure vacuum at probe locations
prior to SVE startup
immediately prior to air sparging startup
at t=5, 10, & 30 min. then at 30 min. intervals
Measure water table level at probe locations
prior to SVE startup
prior to air sparging startup
just prior to AS/SVE shutdown
Measure water table level at probe locations
prior to SVE startup
prior to air sparging startup
just prior to AS/SVE shutdown
Measure water table level at probe locations
prior to SVE startup
prior to air sparging startup
just prior to AS/SVE shutdown
Measure vacuums, pressures, flows, and temperatures
prior to SVE startup
at startup then at 30 min. intervals
before and after flow adjustments
Measure effluent from carbon for breakthrough with OVA
at startup then at 60 min. intervals
P11g(' 2 of2
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TABLE 4-5
SUMMARY OF PILOT TEST PART 5
TARGET OPERATING CONDITIONS AND DATA COLLECTION
FCX-STATESVILLE SUPERFUND SITE OU3
Parameter
Target Operating Conditions
SVE Flow Rate(s)
Air Sparging Flow Rate(s)
Test Durati9n(s)
Description
Flow rate to be determined following pilot test part 3
Use same air sparge well as pilot test part 4
Flow rate to be determined following pilot test part 3
Operate SVE until steady-state then
Operate air sparging until steady state
I Data Collection
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SVE Well (SVE-1)
Air Sparging Well
(either AS-1 or AS-2)
\ \ TN\SYS\DAT A \l'HOJ\0313 .02 \ T0405 PT .DOC
Measure SVE flow, temperature, and vacuum
prior to SVE startup
at 15 min. intervals until steady state
at 60 min. intervals after steady state
Monitor SVE vapors with OVA
prior to SVE startup
at t=5, 10, & 30 min. then at 30 min. intervals
Collect Tedlar bag vapor samples for VOC analysis
at time the OVA reading peaks
immediately prior to air sparging startup
after air sparging steady state
just prior to AS/SVE shutdown
Measure pressure and flow
prior to air sparging startup
at 15 min. intervals until steady state
at 60 min. intervals after steady state
Collect Tedlar bag vapor sample after steady state
Pagl\ I of 2
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TABLE 4-5 (Continued)
SUMMARY OF PILOT TEST PART 5
TARGET OPERATING CONDITIONS AND DATA COLLECTION
FCX-STATESVILLE SUPERFUND SITE OU3
Parameter
Data Collection (Continued)
Monitoring Probes:
Lower Vadose Zone (A)
Upper Groundwater (B)
Intermediate Groundwater (C)
Lower Groundwater (D)
SVE Pilot Test Unit
\ \ TN\SYS\DAT A \I'll( ),f\.O:J 13 .02 \ T0405PT .DOC
Description
Measure vacuum at probe locations
prior to SVE startup
immediately prior to air sparging startup
at t=5, 10, & 30 min. then at 30 min. intervals
Measure water table level at probe locations
prior to SVE startup
prior to air sparging startup
just prior to AS/SVE shutdown
Measure water table level at probe locations
prior to SVE startup
prior to air sparging startup
just prior to AS/SVE shutdown
Measure water table level at probe locations
prior to SVE startup
prior to air sparging startup
just prior to AS/SVE shutdown
Measure vacuums, pressures, flows, and temperatures
prior to SVE startup
at startup then at 30 min. intervals
before and after flow adjustments
Measure effluent from carbon for breakthrough with OVA
at startup then at 60 min. intervals
1'111:"e 2 of2
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4.3.2 Pilot Test Part 2
Air sparging will be initiated with SVE in Pilot Test Part 2 using the upper air
sparging well AS-1 (refer to Table 4-2). The SVE system will be started and
operated at an extraction flow rate to be selected after review of the Pilot Test Part 1
data. Air sparging well AS-1 will be operated at three different injection flow rates
(Qmux, 2/3 Qmux, and 1/3 Qmax) to determine the air sparging radius of influence as a
function of injection flow rate (refer to Table 4-2). The injection flow rates for air
sparging will be determined based on the procedure in the Addendum to the FSP.
Air pressure to the air sparging well will be adjusted to the pressure required to
displace the water in the well and then will be gradually increased until flow is
initiated. The Qmux for air injection will not be allowed to exceed 1/3 Qmax of the SVE
extraction in order to provide an adequate excess recovery of air so that all of the air
that is injected is recovered. The Qmax for an injection may also be limited by the
saturated zone flow resistance. The injection flow rate, extraction flow rate, vapor
temperature, and vacuum will be recorded and vapors will be monitored for VOCs
with an OVA. Vacuum readings will be measured at each of the lower vadose zone
monitoring probes (A) as a function of time. Water levels will be measured at the air
sparging wells and at the five upper groundwater-monitoring probes (B) as indicated
in Table 4-2. Data will also be collected from the SVE unit instrumentation.
A helium tracer test will be conducted during Pilot Test Part 2. This will be
accomplished by injecting pulses of helium into the air sparging stream at each of
the three air injection flow rates and then measuring the response times and helium
concentrations at the SVE well (SVE-1) and at the monitoring probes. The helium
tracer test will provide data on the degree of subsurface homogeneity and radius of
influence of the pilot test air sparging system. Helium concentrations will be
measured in monitoring probes located in both the vadose and saturated zones. The
helium concentrations will be determined using a portable helium detector.
F: \.DAT A \p rof\0313. 02'\ptwp .doc 4-5
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4.3.3 Pilot Test Part 3
Pilot Test Part 3 (refer to Table 4-3) will be a repeat of the Part 2 test using the deep
air sparging well AS-2 instead of AS-1. The injection flow rates for air sparging
using AS-2 will be determined based on the procedure in the Addendum to the FSP.
Adjustments will be made similar to the Part 2 test. Once Part 3 is completed, the
data from Parts 2 and 3 will be compared and an air sparging well will be chosen for .
use in test Parts 4 and 5.
4.3.4 Pilot Test Part 4
After review of the Parts 2 and 3 data, a flow rate for the SVE extraction well and a
flow rate and air sparge well for the air sparging well will be selected for the Part 4
test. The SVE system will be started and operated until vacuum readings at the
extraction well and monitoring probes reach steady state. Next, airflow to the air
sparging well will be initiated (refer to Table 4-4). The data collection will be
performed as indicated in Table 4-4. Vapor samples will be collected four times from
the SVE well and once from the air injection well for voe analysis. The vapor
samples from the SVE well will be collected when the OVA reading peaks,
immediately prior to startup of the air sparging, after the air sparging reaches
steady state (as indicated by steady-state vacuum readings), and just prior to
shutdown of the air sparging and SVE system. The voe analytical data will
provide a measure of the mass removal of PeE and other VO es that may be present
during SVE and air sparging. The vapor samples will be collected according to the
Addendum to the FSP and will be analyzed for voes according to the Addendum to
the QAPP.
4.3.5 Pilot Test Part 5
Pilot Test Part 5 (refer to Table 4-5) will be a repeat of the Part 4 test after the
system has been shut down for at least 12 hours. By repeating the Part 4 testing, a
measure of the voe concentration rebound can be measured. In addition, the test
F:\DATA \p1,ij\0313.02\ptWJ1.doc 4-6
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will provide a degree of added quality assurance/quality control (QA/QC) as a
replicate of the Part 4 test.
Upon completion of Pilot Test Part 5, post-test groundwater samples will be collected
and analyzed from the two air sparging wells and from an estimated 10 of the
monitoring probes that are in the saturated zone. The groundwater samples will be
collected according to the Aquaterra FSP. The groundwater samples will be
analyzed in the field for the. natural attenuation field parameters and in the
laboratory for VOCs and other parameters according to the Addendum to the QAPP.
4.3.6 Pneumatic Permeability Test
A pneumatic permeability test will be conducted using the SVE well located inside
the building, SVE-2. This test will be conducted using the pilot test blower or a
portable blower and activated carbon for worker health and safety. At least three ·
air flow rates will be used, Qmax, 2/3 Qmax, and 1/3 Qmax, to develop performance
curves of flow rate versus vacuum.
4.4 MONITORING PROCEDURES
During the pilot test, the data collection will be at the time intervals described in
Tables 4-1 through 4-5. The physical (or process) data that will be collected and the
measurement devices that will be used include:
Pressure and vacuum (gages and manometers),
Temperature (thermocouples and thermometers),
Flow rate (rotometer, pitot tube, and/or venturi flow meter), and
Liquid level (continuity probe).
These data will be directly read from the measurement devices and will be recorded
on data sheets by the field personnel at the times and frequencies prescribed for
each pilot test part.
F: \DAT A "-11roj\03 13 .02\i,t wp. doc 4-7
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A portable OVA will be used to monitor VOC concentrations and a portable helium
detector will be used to monitor helium concentrations during the pilot test. The
monitoring locations and frequencies are provided in Tables 4-1 through 4-5. An
OVA or a photoionization detector (PID) will be used to inspect the general area
around the pilot test for worker safety. Field personnel will use the manufactures'
procedures for these monitors.
4.5 EFFLUENT AND RESIDUALS TREATMENT
For worker health and safety during performance of the pilot test, off-gas will be
treated using activated carbon prior to discharge. The off-gas from the SVE system
will be treated with two activated carbon canisters placed in series. Activated
carbon will also be used for the pneumatic permeability test. An air permit from
North Carolina is not required for this pilot test as the regulations state that "The
following activities do not need a permit or permit modification under this
Subchapter ... activities exempted because of size and production rate ... any
facility without an air pollution control device whose actual emissions of particulate,
sulfur dioxide, nitrogen oxides, volatile organic compounds, or carbon monoxide are
each less than five tons per year, whose potential emissions of all hazardous air
pollutants are below their lesser cutoff emission rates, and which is not required to
have a permit under Section .0500 of this Subchapter" [NC / Title 15A,
2Q.0102(b)(2)(E)(ii)].
A small quantity of personal protective equipment (PPE) waste will be generated
during the vapor sampling activities. This PPE waste will be managed with the
Investigation Derived Waste (IDW) from installation of the new wells and
monitoring probes. The Addendum to the FSP contains instructions for the well and
probe installation including handling of IDW.
F: \DAT A \p roj\0313. 02\11t wp.doc 4-8
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5.0 DATA REDUCTION AND EVALUATION
The pilot test data will be evaluated quantitatively and through the use of published
computer models. The models will provide an estimate of radius of influence for
both air sparging and SVE as well as pressures and air flow rates for both air
injection and air recovery. Pilot test data will also provide the basis for air
modeling. The heterogeneity of soils, variability in depth to groundwater and
bedrock, and wide range of VOC concentrations, will be considered in the evaluation
of the data from the pilot test area relative to the other areas of the site.
F: \DAT A \p roj'\0313.02\pt wp .doc '5-1
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6.0 PILOT TEST SCHEDULE
A schedule for the PT Work Plan is provided in Figure 6-1. The schedule includes
start and end dates for the tasks including the pilot test performance, sample
analysis, data reduction and evaluation, and reporting.
F:\J)ATA\µroj\OJ 13.02· ptWp.doc 6-1
------------------
Task Name
USl•:PA Ann.-oval of' RD Work Plan
J nstall and Samnle Wells
Pilot Test Well Installation
Pre-Test Groundwater SamolinE!
FIGURE 6-1
SCHEDULE FOR OU3 PILOT TEST
FCX-STATESVILLE SUPERFUND SITE
Start End l '.)88
,Jun Jul Aug
,Jun/l 1/98 Jun/ll/98 !
Jul/0G/98 AuE!/1:3/98 7 4'.~£.,.'.LdL,.:::-·,,,,,, L"LL-:L::.,::.::.-2:--:J ~~-l-=, ,Jul/06/98 ,Jul/17/98 L_, ,Jul/27/98 ,Jul/28/98 ~•1 Post-Test Groundwater Samnlin" Atw/12/98 Aull/13/98 I I rll
Sep Oct
Pilot Tost ,Jun/22/98 Oct/02/98 Li~7' 27Z.'Y,Z::'.Z_7•-::-$ CLL.L...,:./_r :./-~~ l:,)777):/ ,'0._'///,'L...//// /,·>//_~2L&2-Z2i:] Procure Materials Jun/22/98 ,Jul/l0/98 ! Lai I Inst.all SV8 Unit ,Jul/ I 3/98 Ju 1/17 /\)8 ! Connect Air Sunnlv Jul/20/98 Jul/21/98 f I ·-.11 '!
I Perform Svstem Check ri j Jul/22/98 ,Jul/21/()8 ',itj Conduct Pilot Test Jul/29/98 Au11:/ll/(J8 L
Perform Laboratorv Analysis ,Jul/29/98 Sen/18/98 c C
I Pnrform Data Validation Scn/21/98 Oct/02/98
L--., Prcoarc Prelim. Dcsi,m Renart Section /\ug/13/98 Oct/13/98 I Submit Prehm. Design Renort Oct/13/98 Oct/l3/1J8 G Ll
(l:/Pl{OJ/0:l i :J.!WELP ASOPT.TLP Milestone Ii Summary CLL:_-:L..J
Note: ThP 1,1chcdule i~ dependent on t.he net.uni <l1:1tc of USEPA approval oft.he HDWP.
-
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APPENDIXA
WELL CROSS-SECTIONS INTERCEPTING
MONITORING WELL W-9
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A GREAT LAKES CHEMICAL CORPORATION COMPANY
Author
EVC
Job No.
3107709
'T'itl•
Project
Drawing
31077-1A
Revision
7-15-96"h
layers
0,3,4
Figure
6
Well Locatlon Map
FCX-Stetesvflle Super1und Site, OU 3
Steteevllle, North Carollna
Date
11-17-93
Scale
1" = 200'
, ,
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Shallow Monitoring Well Localion
Intermediate Monitoring
Well Location
Deep Monitoring Well Location
Extraction Well Location
Cross-Section Line
Approximale Localion of Stream
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Revision No, :___l___ Date:~7~L2-J~t2~6~ Approved By: 6VT'}"-
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Scale
200 Feet
l,J-1811
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400 Feet
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1000-_
950 c-
:
900 c--
850 =-
,
West
® W-f>s ~-9i r Ground Surtace ----· --· ----· ···-······ .•.... ---------·' ~L-,.-1-------------
······· -·-..... t. .... -······· --------· ------·-
l= Silt, Clayey and Sandy
~ SILT, Silty Clay E and Silty SAND
~ µ ~ ~ * ~ = ----: = = ---= --: = -- = ---= -= -=~ -: : =t!
c 6
C ~
Revision No.:_i__
Sill Clayey and Sandy
SILT, Silty CLAY
and Silty SAND
Date: 7/2}/96
Fractured Rock
(Gneiss)
Approved By: (&)JC):>
-_ 1000
East
®
:
:
-= 950
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. '
~aauaTerra
A GREAT LAKES CHElLICAL CORPORATION COMPANY
Author
EVC
Job Na.
3107709
1\tle
Project
b
Dra.wi.ng La.yers
31077-C2 o. 1, 12
Revision Fi.gure
7-16-96/th 8
Cross-Section B -B'
FCX Statasville
Statesville, North Carolina
Bar Scale
100
Horizontal Sea.le is f' = 00'
Vertica.l Sea.le is f' = 20'
lfu!e 3-16-95
Scala
As Shown
200
Legend
-.'7. -December 29, 1995
Shallow Water Level
December 29, 1995
Intermediate Watar Level
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r 950
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Top of
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W-8s W-8i
1 Ground Surtace
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SILTw/ Mica
and Quartz Fragments
----.. -. -.
W-9s
--------.'L-... -__ -.: .-:-:__· ... -... ------
Bentonite
Fill---
W-8i
Core #1
82-92' 94% ROD
Core #2
92-102' 94% ROD
Revision No.:~
Fractured Rock
(Gneiss)
--
Date: 7/23/96 Approved By:
W-2;
Core #1
80-89' 0% ROD
Core #2
89-99' 16% ROD
Core #3
99-109' 35% ROD
Core #4
109-119' 55% ROD
Core #5
119-129' 20% ROD
Core 116
129-139' 51% ROD
Core lfT
W-2i
139-148.5' 71% ROD
PT),
W-2s MW-4
Bentonite
RII
South
@
MW-8
Scale
o feet 100 feet
Horizontal Sea.le Is f' = ro· Verticle Scale ls As Shown
200 feet
-.-J -Shallow WalJiJr LJ,vel December 29, 1995.
-_J -Intermediate Wetar Level December 29, 1995.
Title
Cross Section D -D'
Project FCX Statesville
Statesville, North Carolira
Author Drawing Layers Date
EVC 31077-C4 0, 1 3-26-95
Job No. evision Figure Scale
3107709 7-16-96/th 10 As Shown
~aauaTerra
A GREAT LAKES CHEMICAL CORPORATION COllPANY
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u
I F:\DATA \PROJ\0313.02\appendix covers.doc
ATTACHMENT 2
ADDENDUM TO THE
FIELD SAMPLING PLAN
(FSP)
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I q: \p ruj\O:I 13. 02 \fap•cov,:r .d,,c
ADDENDUM TO THE
FIELD SAMPLING PLAN (FSP)
FOR OPERABLE UNIT THREE (OU3)
FCX-STATESVILLE SUPERFUND SITE,
STATESVILLE, NORTH CAROLINA
Prepared for:
EL PASO ENERGY CORPORATION
1001 Louisiana Street
Houston, TX 77002
Prepared by:
ECKENFELDER INC.®
227 French Landing Drive
Nashville, Tennessee 37228
[phone]
May 1998
0313.02
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LO INTRODUCTION
This .addendum to the Field Sampling Plan (FSP) for the Remedial Design Work
Plan (RD Work Plan) amends the document, "Field Sampling Plan, FCX Statesville
Operable Unit 3, Iredell County, North Carolina" prepared by Aquaterra, Inc.
(Aquaterra) on behalf of El Paso Natural Gas Company and Burlington Industries,
Inc., February 1994, as part of the Remedial Investigation and Feasibility Study
(RI/FS). This addendum describes the additional procedures, sampling, analysis,
and monitoring to be performed in support of the work described in the RD Work
Plan. The FSP prepared by Aquaterra will be used as the FSP except where
changes or additions are noted in this addendum.
Section 2.0 describes the revisions to the Aquaterra FSP. Section 3.0 describes the
procedure for interval packer testing; potable water supply sampling; well and
probe installation for the air sparging and soil vapor extraction (AS/SVE) pilot test;
and vapor sampling for the AS/SVE pilot test. Appendix A contains a sample
ECKENFELDER INC. chain of custody form; Appendix B contains the Standard
Operating Procedures (SOPs) that are in addition to the SOPs contained in the
Aquaterra FSP.
{j:\prnj\o:i IJ.0i\f11p.doc l · l
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2.0 REVISIONS TO THE AQUATERRA FSP
This section describes revisions to the Aquaterra FSP. The FSP shall remain the
same with no further modifications with the exception of the general revisions listed
below:
Throughout the Aquaterra FSP, references and examples of forms for data
documentation and quality assurance/quality control (QA/QC) purposes are
presented. Herein, ECKENFELDER INC. will utilize its versions of these
documentation forms.
Wherever Aquaterra is referred to in the FSP, it should be changed to read
ECKENFELDER INC.
Field QA/QC samples will be collected according to the document
"Environmental Investigations Standard Operating Procedures and
Quality Assurance Manual," May 1996, USEPA Region 4.
Chain of Custody forms will be those used by ECKENFELDER INC. as
contained in Appendix A.
C/:\proj\O:I J :J.02 '· fN1>.duc 2-1
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3.0 ADDITIONAL PROCEDURES
This section describes the procedures that will be needed m addition to those
included in the Aquaterra FSP.
3.1· INTERVAL PACKER TESTING
Interval packer testing will be performed during the installation of the new
monitoring wells as described in Section 2.2 of the RD Work Plan. The procedure
for interval packer testing is included as Appendix B-1 of this Addendum to the
FSP. The monitoring well installation will be according to the Aquaterra FSP.
Procedures for sample analyses, including QA/QC and data validation, are in the
Aquaterra Quality Assurance Project Plan (QAPP) and the Addendum to the QAPP
(Attachment 3 of the RD Work Plan).
3.2 POTABLE WATER SUPPLY SAMPLING
Potable water supply sampling of residential drinking water wells will be performed
during the Pre-Design Investigation as described in Section 2.3 of the RD Work
Plan. Appendix B-2 of this Addendum to the FSP provides the sampling procedure
for sampling potable water supply sources. The samples will be analyzed according
to the Addendum to the QAPP (Attachment 3 of the RD Work Plan).
3.3 INSTALLATION OF WELLS AND PROBES FOR THE PILOT TEST
Wells and probes will be installed for the AS/SVE pilot test. Two air sparging wells
and two SVE wells will be installed. Five clusters of monitoring probes will also be
installed. Appendix B-3 contains the procedure for installation of these wells and
probes. The locations of these wells and probes is included in the Pilot Test Work
Plan (PT Work Plan), which is Attachment 1 of the RD Work Plan.
3.4 VAPOR SAMPLING DURING THE PILOT TEST
The PT Work Plan defines the locations and frequencies for the collection of vapor
samples during the performance of the pilot test. Appendix B-4 of this Addendum
F:\DATA \11rnj\03 I 3.02\fSP.doc 3-1
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3.4 VAPOR SAMPLING DURING THE PILOT TEST
The PT Work Plan defines the locations and frequencies for the collection of vapor
samples during the performance of the pilot test. Appendix B-4 of this Addendum
to the FSP provides the SOP for collection of the vapor samples. Two Tedlar bags
will be filled for each vapor sample. The bags will be labeled A and B and will be
shipped separately. The bags labeled "A" will be used for analysis; the bags labeled
"B" will be used as necessary for back-up. Field QA/QC samples will consist of
5 percent replicate samples and 5 percent blank ambient air samples. Vapor will be
analyzed for VOCs. Procedures for the analysis are in the Addendum to the QAPP
(Attachment 3 of the RD Work Plan).
3.5 AIR SPARGING WELL PERFORMANCE TEST
. The PT Work Plan includes determining the air sparge flow rate to be used in the
AS/SVE Pilot Test. Appendix B-5 of this Addendum to the FSP provides the test
protocol for determining the air sparge flow rate.
F:\DJ\Ti\ \proj\0313.02\f.~p.doc 3-2
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APPENDIX A
ECKENFELDER INC. CHAIN OF CUSTODY FORM
F:'\DAT A \PROJ\0313. 02\FSP .doc
--------------ECKENFELDER INC. CHAIN OF CUSTODY RECORD
Send Results lo: Send Invoice To:
Name Name ------------
Company __________ _ Company
Address -----------Address __________ _
City & State ________ _ City & State ________ _
Phone Phone ------------------------Fax Purchase Order -------------
Sam lcrs Si nature
-----N" 15 3 5 7
Details:
Pagc __ of __
Cooler No.
Date Shipped
of
Shipped By _______ _
Turnaround
(Routinc-10-15 business tfays/ll1crc may
be a surchar e for RUSH-contact L..ab
Date
Sam led
Time Comp./
Grab
Sample Location/Description Sample Field Field ANALYSIS REQUIRED No. of
Bottles Matrix Cond.
Sample Kit Prcp'd by: (Signature) Oate/fimc Recei.ved By: (Signature) REMARKS
Relinquished by: (Signature) Date/rime Received By: (Signature)
Relinquished by: (Signature) Date/I'imc Received By: (Signature)
Dislrihution: Original and yellow copies accompany s.1mple shipment lo l;iborntory: l'ink retained by samplers
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APPENDIXB
STANDARD OPERATING PROCEDURES
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APPENDIX B-1
PROCEDURE FOR INTERVAL PACKER TESTING
F:\IJATA \!'HOJ ,0313.02\FSP.doc
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INTERVAL PACKER TESTING
Interval packer pressure testing will be used to develop a vertical hydraulic
conductivity profile of the open interval of each newly installed bedrock monitoring
well. The results of these tests will aid in the identification of target screen
intervals.
The interval packer pressure tests isolate a section of the borehole and monitor the
flow rate in! , the bedrock formation at a constant pressure head. Interval packer
pressure testing will be conducted on all proposed bedrock monitoring wells. To
isolate the individual sections of the borehole, a single or double packer assembly
will be used. The packer assembly will consist of a five-foot section of perforated
pipe positioned below the single packer or between double packer assemble. Tests
will be conducted at five-foot intervals within the open portion of the bedrock
borehole.
During the test, the packers will be inflated with ni1:rogen to isolate the zone to be
tested from the remainder of the borehole. Potable water will be pumped into the
borehole to maintain a constant head within the isolated bedrock interval.
A pressure gauge (ranged Oto 120 psi) will be used to monitor head pressures at the
surface. The pressure will be controlled by a standard in-line ball valve. Total
volume of flow into the formation will be measured with an in-line, totalizing flow
meter monitoring with the ability to measure flows to the nearest 0.05 gallons.
The pressure used in each test will be determined by taking the depth of the upper
packer from ground surface (in feet) and multiplying this value by 70 percent.
Previous experiences in similar sites have indicated that this pressure selection
yields hydraulic conductivity values that are considered representative of bedrock
conditions for the site.
F:\DATA \l'HOJ\0.'J l 3.02\ll0320,DOC 1
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Hydraulic conductivity values will be calculated uEing the following equation:
K = Cp Q/H Equation 1
Where: K hydraulic conductivity
Cp = packer coefficient (shape factor for test section length and borehole
diameter and appropriate unit conversion factors)
Q rate of flow
H total calculated head (H = Pp+ Ph-Pf, where: Pp = the pressure at
which water was pumped, Ph = pressure differential between the
height of the water column within t.he test system and the height of
the piezometric surface corresponding to the bottom of the test
interval, and Pf= pressure losses of the test system).
F:\DATA '\l'!lQJ, 03 l 3.02'\Ito:J20.DOC 2
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APPENDIX B-2
PROCEDURE FOR POTABLE \VATER SUPPLY SAMPLING
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POTABLE WATER SUPPLY SAMPLING
The same sampling techniques used for groundwater, etc. (including thorough
documentation of location, date, time, etc.) are to be used during potable water
supply sampling of residential drinking water wells. There are certain additional
procedures which apply.
Sampling Site Selection
The following should be considered when choosing the location to collect a potable
water sample:
Taps selected for sample collection should be supplied with water from a
service pipe connected directly to a water main in the segment of interest.
Whenever possible, choose the tap closest to the water source, and prior to
the water lines entering the residence, office, building, etc. and also prior to
any holding or pressurization tanks.
The sampling tap must be protected from exterior contamination associated
with being too close to a sink bottom or to the ground. Contaminated water
or soil from the faucet exterior may enter the bottle during the collection
procedure since it is difficult to place a bottle under a low tap without
grazing the neck interior against the outside faucet surface. If the tap is
too close to the ground for direct collection into the appropriate container, it
is acceptable to use a smaller (clean) container to transfer sample to a
larger container.
Leaking taps that allow water to discharge from around the valve stem
handle and down the outside of the faucet, or taps in which water tends to
run up on the outside of the lip, are to be avoided as sampling locations.
~·:\JlATA \proj\03 l 3.02\IW320ll.doc 1
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' Disconnect any hoses, filters, or aerators attached to the tap before
sampling. These devices can harbor a bacterial population if they are not
routinely cleaned or replaced when worn or cracked.
Taps where the water flow is not constant should be avoided because
temporary fluctuation in line pressure may cause clumps of microbial
growth that are lodged in a pipe section or faucet connection to break loose.
A smooth flowing water stream at moderate pressure without splashing
should be used. The sample should be collected without changing the water
flow. It may be appropriate to reduce the flow for the volatile organic
compounds aliquot to minimize sample agitation.
Obtain the name(s) of the resident or water supply owner/operator, the resident's
exact mailing address, and the resident's home and work telephone numbers. The
information is required so that the residents or water supply owner/operators can
be informed of the results of the sampling program.
Sampling Technique
The following procedures should be followed when collecting samples frorn_ potable
water supplies:
1. Purge the system for at least 15 minutes. Ideally, the sample should be
collected from a tap or spigot located at or near the well head or pump house
and before the water supply is introduced into any storage tanks or treatment
units. If the sample must be collected at a point in the water line beyond a
pressurization or holding tank, a sufficient volume of water should be purged
to provide a complete exchange of fresh water into the tank and at the location
when the sample is collected. If the sample is collected from a tap or spigot
located just before a storage tank, spigots located inside the building or
structure should be turned on to prevent any backf1ow from the storage tank to
the sample tap or spigot. It is generally advisable to open as many taps as
l':\lli\Ti\ l'J{[J,/ rn1:1.0'.!\H03W!Ul()C 2
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possible during the purge, to ensure a rapid and complete exchange of water in
the tanks.
2. After purgmg for 15 minutes, measure thE, turbidity (if appropriate), pH, I specific conductivity, and temperature of the water. Continue to monitor these
parameters until three consistent readings are obtained.
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3. After three consistent readings have been obtained, samples may be collected.
F: \I JA TA\ l 'HOJ ,Q:J 13. 02 \HO:l 2011. doc 3
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APPENDIX B-3
INSTALLATION PROCEDURES FOR PILOT TEST WELLS AND
MONITORING PROBES
F:\DATA \proj\O:J J :l.02\f,,p.doc:
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INSTALLATION OF PILOT TEST WELLS
AND MONITORING PROBES
The AS/SVE pilot test will require the installation of two air sparging wells, two
vapor extraction wells, and five monitoring probe clusters. The installation methods
and procedures are discussed in detail in the following sections.
Air Sparging Wells Installation
The air sparging wells (AS-1 and AS-2) will be installed in general accordance with
the North Carolina Well Construction standards (15 NCAC 2C.0100). Initially, air
sparging well (AS-2) soil boring will be advanced to a depth of approximately 72 feet
or to the top of the underlying bedrock unit, using 4¼-inch ID hollow stem augers.
Continuous soil samples will be collected using a 2-inch diameter split spoon
sampler, driven with a 140-pound hammer, following the procedures of the Standard
Penetration Test (ASTM Method D-1586).
Upon completion of the boring, the air sparging well will be constructed through the
augers with 2-inch ID PVC Schedule 40 well casing. Two-feet of machine slotted
2-inch diameter 0.010-inch slot Schedule 40 PVC well screen will be placed at the
base of the boring. Schedule 40 PVC riser pipe will be installed from the screen to
the ground surface.
Clean washed silica sand, appropriately sized for the screen, will be placed in the
annulu. from 0.5 feet below the base of the screen up to approximately 1 feet above
the top of the screen while retracting the augers. A bentonite seal, 3 feet in
thickness, will be placed above the sand, followed by cement/bentonite grout (Type I
Portland with 2 percent to 4 percent bentonite by weight, e.g., 14 to
15 pounds/gallon) to the surface. A flush-mount protective casing with a 3-foot by
3-foot concrete pad will be installed. Drill cuttings will be placed in DOT-approved
containers for appropriate disposal.
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Air sparing well AS-1 soil boring will be advanced to a depth of approximately 55
feet. Upon completion of the boring, AS-1 will be constructed following the
procedures for AS-2.
Upon completion of the air sparging wells, a construction logs will be prepared from
field log notes. The construction logs will include the elevation, drill method, depth
of boring, well material type, amount of annular fill material, etc. Additionally, Well
Construction Records forms (GW-1) will be submitted to the NCDEHNR, Division of
Environmental Management, Groundwater Section. and copies will be submitted to
the USEPA.
SVE Wells Installation
The SVE wells (SVE-1 and SVE-2) will be installed. in general accordance with the
North Carolina Well Construction standards (15 NCAC 2C.0100) .. Initially SVE-1
soil boring will be advanced to a depth of approximately 35 feet or to the top of the
water table, using 6 ¼-inch ID hollow stem augers.
Upon completion of the boring, the SVE-1 will be constructed through the augers
with 4-inch ID PVC Schedule 40 well casing. Twenty feet of machine slotted 4-inch
diameter 0.010-inch slot Schedule 40 PVC well screen .vill be placed at the base of
the boring. Schedule 40 PVC riser pipe will be installed from the screen to the
ground surface.
Clean washed silica sand, appropriately sized for the screen, will be placed in the
annulus from 0.5 feet below the base of the screen up to 2 to 3 feet above the top of
the screen while retracting the augers. A bentonite seal, 3 feet in thickness, will be
placed above the sand, followed by cement/bentonite grout (Type I Portland with
2 percent to 4 percent bentonite by weight, e.g., 14 to 15 pounds/gallon) to the
surface. A flush-mount protective casing with a 3-foot by 3-foot concrete pad will be
installed. Drill cuttings will be placed in DOT-approved containers for appropriate
disposal.
F:\DATA\proj\0313,02\pilot tc~t.dnc 2
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The SVE-2 soil boring will be advanced to a depth of approximately 20 feet, using 6
¼-inch ID hollow stem augers.
Upon completion of the boring, the SVE-2 will be constructed through the augers
with 4-inch ID PVC Schedule 40 well casing. Fifteen feet of machine slotted 4-inch
diameter 0.010-inch slot Schedule 40 PVC well screen will be placed at the base of
the boring. Schedule 40 PVC riser pipe will be installed from the screen to the
ground surface.
Clean washed silica sand, appropriately sized for the screen, will be placed in the
annulus from 0.5 feet below the base of the screen up to 2 feet above the top of the
screen while retracting the augers. A bentonite seal, 2 feet in thickness, will be
placed above the sand, followed by cement/bentonite grout (Type I Portland with
2 percent to 4 percent bentonite by weight, e.g., 14 to 15 pounds/gallon) to the
surface. A flush-mount protective casing with a 3-foot by 3-foot concrete pad will be
installed. Drill cuttings will be placed in DOT-approved containers for appropriate
disposal.
Upon completion of the SVE wells, a construction logs will be prepared from field log
notes. The construction logs will include the elevation, drill method, depth of boring,
well material type, amount of annular fill Il)aterial, etc. Additionally, Well
Construction Records forms (GW-1) will be submitted to the NCDEHNR, Division of
Environmental Management, Groundwater Section ;;nd copies will be submitted to
the USEPA.
Monitoring Probe Installation
The monitoring probes will be installed in clusters of four probes in each location. In
each cluster, one probe will be screened in the vadose zone (Probe A), a second probe
will be screened just below the water table (Probe B), a third will be approximately
in the middle of the saturated zone (Probe C), and a forth probe will be screened at a
depth of approximately 70 feet (Probe D). The monitoring probes will be installed in
general accordance with the North Carolina Well Con.struction standards (15 NCAC
1-':\DAT A \proj\0313,02\pilot tii11t.doc. 3
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ZC.0100). Initially a soil boring will be advanced to a depth of approximately
70 feet, using 6¼-inch ID hollow stem augers.
Upon completion of the boring, the monitoring probes will be constructed through
the augers with 1-inch ID PVC Schedule 40 well riser and screen. The screen will
consist of a two feet of machine slotted 1-inch diameter 0.010-inch slot Schedule
40 PVC well screen.
The deepest monitoring probes will be placed at the base of each boring. Clean
washed silica sand, appropriately sized for the screen, will be placed in the annulus
from the base of the screen up to 0.5 foot above the top of the screen while retracting
the augers. A bentonite seal, 14.5 feet in thicknern, will be placed above the sand
interval while retracting the augers.
The second monitoring probes will then be installed to a depth of approximately 53
feet. Clean washed silica sand, appropriately sized for the screen, will be placed in
the annulus from the base of the screen up to 0.5 foot above the top of the screen
while retracting the augers. A bentonite seal, 11.5 feet in thickness, will be placed
above the sand, while retracting the augers.
The third monitoring probes will then be installed to a depth of approximately 39
feet. Clean washed silica sand, appropriately sized for the screen, will be placed in
the annulus from the base of the screen up to 0.5 foot above the top of the screen
while retracting the augers. A bentonite seal, 7 feet in thickness, will be placed
above the sand, while retracting the augers.
The forth monitoring probes will then be installed to a depth of approximately 30
feet. Clean washed silica sand, appropriately sized for the screen, will be placed in
the annulus from the base of the screen up to 1 foot above the top of the screen while
retracting the augers. A bentonite seal, 3 feet in thickness, will be placed above the
sand, followed by cement/bentonite grout (Type I Portland with 2 percent to
4 percent bentonite by weight, e.g., 14 to 15 pounds/gallon) to the surface. A flush-
!<':'\DATA \proj\0313.02'\pilot l1'9t.cloc 4
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rnount protective casing with a 3-foot by 3-foot concrete pad will be installed. Drill
cuttings will be placed in DOT-approved containers for appropriate disposal.
Upon completion of the monitoring probes, construction logs will be prepared from
field log notes. The construction logs will include the elevation, drill method, depth
of boring, well material type, amount of annular fill material, etc. Additionally, Well
Construction Records forms (GW-1) will be submitted to the NCDEHNR, Division of
Environmental Management, Groundwater Section and copies will be submitted to
the USEPA.
l•':\DATA\proj\031.'J.02\pilot t•i11Uloc 5
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ATTACHMENT 3
ADDENDUM TO THE
QUALITY ASSURANCE PROJECT PLAN
(QAPP)
F:\.OAT A \PROJ\.0313 .02\appendi:c: cover.s.doc
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ADDENDUM TO THE
QUALITY ASSURANCE PROJECT PLAN (QAPP)
FOR OPERABLE UNIT THREE (OU3)
FCX-STATESVILLE SUPERFUND SITE,
STATESVILLE, NORTH CAROLINA
Prepared for:
EL PASO ENERGY CORPORATION
1001 Louisiana Street
Houston, TX 77002
F: \DAT A \11roj\0313. 02\.QAPP •covr.r, doc
Prepared by:
ECKENFELDER INC.®
~:27 French Landing Drive
Nashville, Tennessee 37228
[phone]
May 1998
0313.02
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1.0 INTRODUCTION
This addendum amends the document, "Quality Assurance Project Plan, FCX
Statesville Operable Unit 3, Iredell County, North Carolina," prepared by
Aquaterra, Inc. (Aquaterra) on behalf of El Paso Natural Gas Company, Inc. and
Burlington Industries, Inc., February 1994 as part of the Remedial
Investigation/Feasibility Study (RI/FS) for the site. This addendum describes the
quality assurance and analytical methodologies to be performed during the Pre-
Design Investigation as described in the Remedial Design Work Plan (RD Work
Plan). The Quality Assurance Project Plan (QAPP) prepared by Aquaterra will be
referred to as the Aquaterr1 QAPP.
Section 2.0 of this Addendum to the QAPP gives a brief overview of the work to be
performed and the test parameters, analytical procedures, and the data quality
objectives (DQOs) for the analyses.
F:\J)AT A \prnj\03 I 3.02\r111pp11.doc C-1
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2.0 ANALYTICAL PROCEDURES
The objectives, locations, and methods for sampling., analyses, and monitoring to be
performed during the Pre-Design Investigation are described Section 2 of the RD
Work Plan, the Aquaterra Field Sampling Plan (FSP), and the Addendum to the
FSP. The Aquaterra FSP was prepared by Aquaterra and is entitled, "Field
Sampling Plan, FCX Statei,ville Operable Unit 3, Iredell County, North Carolina,"
February, 1994. The Pre-Design Investigation includes collection and analysis of
groundwater samples and vapor samples. Analytical methodologies not included in
this Addendum will be performed according to the Aquaterra QAPP.
Groundwater samples will be analyzed for various parameters for plume definition,
metals, and natural attenuation. Table 2-1 provid,"s a summary of the chemical
analyses and analytical references for the groundwater samples. The RD Work
Plan describes which samples will be analyzed for which parameters. The DQO
Level for each test or analytn parameter is also given in the table.
The Pilot Test Work Plan dEScribes the collection of both groundwater samples and
vapor samples. Groundwater samples from the pilot test will be analyzed for
various parameters by field measurements and by laboratory analysis according to
Table 2-2. The DQO level for each test or analyte parameter is also given in the
table. The vapor samples will be analyzed for VOCs by the laboratory according to
USEPA method 5030 modified/8260 and with DQO level IV.
Data reduction, validation, and reporting for samples with DQO level IV will be
CLP or CLP-type data packages such that the data can be reviewed and validated
by an independent firm. Data validation protocols will be those specified by the
Aquaterra QAPP or the most current USEPA and NCDEHNR-approved methods.
F: \D,\ TA \l'rnf\03 13 .02 \qappn .rloc C-2
--- ------- - - --- -
TABLE 2-1
SUMMARY OF CHEMICAL ANALYSES AND ANALYTICAL METHOD REFERENCES
FOR GROUNDWATER SAMPLES FROM THE MONITORING WELLS
Sample Parameter
Plume Definition
Metals
Natural Attenuation
Field Measurements:
Laboratory Analyses:
Chemical Test/Analyte Parameter
TCLVOCs
TCL pesticides
TAL metals
TAL metals only
Carbon dioxide
Iron (II)
Manganese (11)
Sulfide
Conductivity
Oxidation-reduction potential (ORP)
pH
Dissolved oxygen (DO)
Temperature
Ammonium nitrogen
Chloride
Iron (total)
Manganese (total)
Nitrate/nitrite
Phosphate (total)
Sulfate
Total Kjeldahl Nitrogen (TKN)
Ethane, ethene, and methanee
TCLVOCs
Alkalinity (carbonate/bicarbonateif
Dissolved total organic carbon (TOC)
Volatile fatty acids
Analytical Reference Method a
Aquaterra QAPP Table 2
Aquaterra QAPP Table 2
Aquaterra QAPP Table 3
Aquaterra QAPP Table 3
Hach KitC
H ~"h Tf";+.r.
Hach KitC
Hach KitC
ASTM Method D-1125-82
ASTM Method D-1498-76
ASTM Method D-1293-84
Hach KitC
NAd
USEPA Method 350.3
USEPA Method 325.2
Aquaterra QAPP Table 3
Aquaterra QAPP Table 3
USEPA lviethod 353.2
USEPA Method 365.2
USEPA Method 375.4/9038
USEPA Method 351.4
USEPA Method 8015-Modified
Aquaterra QAPP Table 2
Standard Methods 2320B
USEPA Method 415.1
Standard Methods 5560C
- -
DQO Levelb
IV
IV
IV
IV
II
11
II
I
II
II
II
II
II
Ill
Ill
IV
JV
Ill
Ill
III
Ill
III
IV
Ill
Ill
Ill
aSample preservatives, when required by the method, will be added to sample containers at the analytical laboratory prior to sampling.
Contract Required Detection Limits (CRDLs) will be according to the contract laboratory procedure (CLP) methods referenced in the
Aquaterra QAPP Tables 2 and 3.
bDQOs and QA/QC frequencies per "Environmental Investigations Standard Operating Procedures and Quality Assurance Manual",
May 1996, USE PA Region 4. Level I = Field Screening; Level II = Field Analyses; Level III = Screening Data with Definitive Confirmation;
Level IV= Definitive Data.
CMethod will be per manufacture's procedures.
dNot Applicable.
e/rnalysis will be subcontracted to Specialized Assays, Nashville, Tennessee.
fsamples to be collected in zero headspace containers to prevent exchange of carbon dioxide between the samples and the atmosphere.
F:\DATA\proj\0313.02\qappto201.doc Page I of I
-
------- --- -- - --TABLE 2-2
SUMMARY OF CHEMICAL ANALYSES AND ANALYTICAL METHOD REFERENCES
FOR GROUNDWATER SAMPLES FROM THE PILOT TEST WELLS
Sample Evaluation
Field Measurements:
Laboratory Analyses:
Chemical TestJAnalyte Parameter
Carbon dioxide
Iron (II)
Manganese (II)
Sulfide
Conductivity
Oxidation-reduction potential (ORP)
pH
DissolvP.rl nyye1=n (DO)
Temperature
Chloride
TCL voes
Alkalinity (carbonate/bicarbonate)e
Dissolved total organic carbon (TOC)
Volatile fatty acids
Analytical Reference Methoda
Hach Kitc
Hach Kitc
Hach K.itC
Hach K.itC
ASTM Method D-1125-82
ASTM Method D-1498-76
ASTM Method D-1293-84
TT--1-TT•,,-. .l.lcll..:U .i\...1.l,'-'
NAd
USEPA Method 325.2
Aquaterra QAPP Table 2
Standard Methods 2320B
USEPA Method 415.l
Standard Methods 5560C
-- -
DQO Levelb
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III
IV
III
III
III
asample preservatives, when required by the method, will be added to sample containers at the analytical laboratory prior to sampling.
Contract Required Detection Limits (CRDLs) will be according to the contract laboratory procerlure (CLP) methods referenced in the
Aqu::itcrrn Ql\PP Tables Z atn.l 3. ,
bDQOs and QA/QC frequencies per "Environmental Investigations Standard Operating Procedures and Quality Assurance Manual",
May 1996, USEPA Region 4. Level I= Field Screening; Level II= Field Analyses; Level III= Screening Data with Definitive Confirmation;
Level IV= Definitive Data.
CMethod will be per manufacture's procedures.
dNot Applicable.
esamples to be collected in zero headspace containers to prevent exchange of carbon dioxide between the samples and the atmosphere.
F:'\DAT A \J'RO.f\03 l 3.02\qappto202.doc Page 1 of I
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ATTACHMENT 4 ·
HEAL TH AND SAFETY PLAN
(HASP)
\ \TN\SYS\DATA \PRO.f\0313.02\appendix coveu.dx;
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HEAL TH AND SAFETY PLAN
FOR OPERABLE UNIT THREE (OU3)
PRE-DESIGN FIELD ACTIVITIES,
FCX-STATESVILLE SUPERFUND SITE,
STATESVILLE, NORTH CAROLINA
F: \DATA\ I' R()J\0 31 3. 0 2 \I IASI' .DOC
Prepared for:
EL PASO ENERGY CORPORATION
1001 Louisiana Street
Houston, Texas 77002
Prepared by:
ECKENFELDER INC.@
227 French Landing Drive
Nashville, Tennessee 37.228
[phone]
April 1998
0313.02
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Approvals:
Robert E. Ash, IV, P.E.
Project Director
ECKENFELDER INC.
Kenton H. Oma, P.E.
HEAL TH AND SAFETY PLAN
FOR OPERABLE UNIT THREE (OU3)
PRE-DESIGN FIELD ACTIVITIES,
FCJC-STATESVILLE SUPERFUND SITE
STATESVILLE, NORTH CAROLINA
Date
Date
Date
Date
This document has been prepared for the express use of ECKENFELDER INC. and its
employees and may be used as a guidance document by properly trained and
experienced subcontracton:. Due to the hazardous nature of this site and the
activity occurring as part of the corrective action on-site, it is not possible to
discover, evaluate, and provide protection for all possible hazards which may be
encountered and this document does not guarantee the health and safety of any
person entering this site. Strict adherence to the health and safety guidelines
presented herein will reduce, but not eliminate, the possibility for injury at this site.
Guidelines presented herein are site specific and should not be used for other sites
without research and evaluation by a qualified health and safety specialist.
F: \DAT A 'WRO.T\0313. 02 '-HASP .DOC
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TABLE OF CONTENTS
Approvals
Table of Contents
List of Tables
List of Figures
1.0 Site Information and Acknowledgements
2.0 Project Information
3.0 Physical Hazards Information
4.0 Chemical Hazards Information
5.0 Hazard Communication Program
6.0 Confined Space Entry
7.0 Emergency Information
8.0 Personnel Training Record:,
9.0 Protective Equipment List
10.0 Decontamination Procedure
11.0 Safe Work Practices
12.0 Employee Acknowledgements
13.0 Subcontractor Acknowledgements
14.0 Attachments (Supplemental Information)
F:\DATA \prnj\03 \ 3.02\IIASJ>-TOC.DOC
Page No.
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ATTACHMENTS
Attachment A -
Attachment B -
Attachment C -
Attachment D -
Attachment E -
Attachment F -
Attachment G -
Attachment H -
TAiBLE OF CONTENTS (Continued)
Site Description and Background Information
Decontamination Procedures
Site-Spec,fic Tasks, Hazards, and Controls
General Requirements for Contractors in Burlington Plants
Personal Protection Daily Log
Accident/Incident Report Form
Contractor Acknowledgement Form
Supplemental Information
F': \DATA \proj \0:1 I J. 02\l lASl'-TOC.DOC 11
Page No.
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LIST OF TABLES
Title
Table No.
4-1 Identified Site Contaminants
Figure No.
2-1
7-1
7-2
LIST OF FIGURES
Title
Project Organization for Remedial Design for OU3
Emergency EEcape Route and Staging Area
Route from Site to Hospital
I-': \DAT A \proj\0313. 02\JfASl'-TOC.DOC lll
Follows
Page No.
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Follows
Page No.
2
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ECKENFELDER INC.®
SITE HEAL TH AND SAFETY PLAN
CLIENT NAME: El Paso Energy Corporation (El Pano)
PROJECT NAME: Remedial Design for OU3, FCX-Statesville Superfund Site
STREET ADDRESS: South of intersection of Yadkin and Phoenix Streets (Plant is on west side
of Phounix Street)
CITY, STATE: Statesville, North Carolina
SITE CONTACT: Gene Swift (Burlington)
Nancy I(. Prince (El Paso)
Jim Wright (Burlington)
PHONE NUMBER: [phone]
1713) 757-3306
[phone]
ECKENFELDER INC.
PROJECT DIRECTOR: Robert E. Ash, IV, P.E. ,108 NUMBER: 0313.02
0 PROJECT MANAGER: Kenton H. Oma, P.E. F\EVISION:
SITE HEALTH & SAFETY OFFICER: Kenton H. Oma, P.E.
ALTERNATE SITE HEALTH & SAFE'TY OFFICER: M. M. Maria Megehee, Samuel P. Williams,
Gregory L. Christians
PLAN APPROVED BY: DATE:
Project Health & Safety Ma.1ager:
Project Manager:
Ann N. Clarke, Ph.D., ANC & Associates, Inc.
Kenton H. Oma, P.E.
PREPARED BY: Ann N. Clarke, Ph.D. DATE: 4/24/98
(1) WILL POTENTIAL HAZAF\DS TO ON-SITE PERSONNEL EXIST? (YES)
(21
Physical:
Chemical:
Yes
Yes
Confined space entry: No
(If yes, see Section 3)
(If yes, see Section 41
(If yes, see Section 6)
SITE CLASSIFICATION: (check all that apply)
Hazardous (CERCLA) X
Active X
(3) PURPOSE AND DATE($) OF FIELD VISIT($):
[see (4) Tasks).
Perform field tasks May through November 1998,
(41 TASKS:
Monitoring well install. X
Surf. soil & sed. samp. X
Groundwater sampling X
F:\DAT A \proj\0313. 02"-l !ASP .DOC
Soil/Air permeabil. meas. X
Soil boring and sampling X
Collection of physical data X
1
Other Pilot testing of
air sparging and
SVE
Project No. 0313.02
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15) ON-SITE ORGANIZATION
ECKENFELDER INC. Personnel Responsibilities
Kenton H. Oma P.E.* Project Manager
M. Maria Megehee Pilot Testing
Gregor~ L. Christians Pre-design Investigation
Samuel P. Willi11ms Sampling of groundwater
{see Project Organization Chart
for additional information)
NOTE: Identify on-site fiold leader/supervisor with an asterisk I*). Figure 2-1 presents the
project organization for the remedial design of OU3.
NOTE: This Health and Safety Plan !HASP) has been prepared for use by ECKENFELDER INC.
employees. ECKENFELDER INC. claims no responsibility for this plan use by others. The
plan is written for the spe,:ific site conditions, purposes, dates, and personnel specified and
must be amended if these conditions change.
Contractors and subcontrnctors whose work will be performed on-site, or who otherwise
could be exposed to healt.1 and safety hazards, will be advised of known hazards through
distribution of site information obtained by ECKENFELDER INC. from others, and this HASP.
They shall be solely responsible for the health and safety of their employees and shall
comply with all applicable laws and regulations. All contractors and subcontractors are
responsible for: 11) providing their own personal protective equipment; 12) training their
employees in accordance with applicable Federal, State and local laws; 13) providing
medical surveillance and obtaining medical approvals for their employees; 14) ensuring their
employees are advised of and meet the minimum requirements of this HASP and any other
additional measures requirc:d by their site activities; 15) designating their own site safety
officer, and 16) receiving si·,e-specific training to be provided by Burlington, the site owner,
prior to entering the facility.
(6) BACKGROUND INFORMATION Iattach existing description and map if available)
See Attachment A
'~E~®N133Hffi~s1c~tt1HA'ZAR!fs!i111!£0J,M~iio1i(t\;l-~51i~;:,1H!ii:: _·-. _-:i ~:?]?~!?~~14'.< .::: •:?:~!?1':f'?~~;t'.S.
( 1) IDENTIFY POTENTIAL PHYSICAL. HAZARDS TO WORKERS:
Steep/uneven terrain On ground piping
Heavy equipment Heilt stress
Moving parts Cold stress
Swampy terrain Noise
Describe other unsafe enviror,ments Slips, trips, and falls
(2) PROTECTIVE EQUIPMENT REQUll'IED? Yes
If yes, see Section 9.
Q:\proj\0313.02\I !ASP .DOC 2 Project No. 0313.02
I
I USEPA REGION IV
REMEDIAL PROJECT MANAGER
I MclCENZIE MALLA.RY
I KL PASO ENERGY
TECIINICAL COMMl'ITEE
PROJECT COORDINA'IOR
I NANCY K. PRINCE,. CC.WP
ALTERNATE PROJECT COORDINATOR
MARC R. FERRIES
I PBOJECr DIRECTOR
ROBERT E. ASH IV, P.&
I
I
TECHNICAL ADVJBORS TRAN!IITION SUPPORT
ROBERT D. NORRIS, Ph.D. PROJECT MANAOEB.
SHARON MYERS JEFFREY L. PINTENICH, P .E., CHMM KENTON H. OMA, P .E , AQUATERRA, INC.
RONALD A. BURT, Ph.D~ P.G.
I
TASK LIWlER TASK LEADER TASK LIWlER
I l'R&-lllmGN INVl!llTIGATION AS/SVB PILOT TE!rr REMEDIAL D1!'81GN
GREGORY L. CHRISTIANS, P .0. M. MARIA MEGEHEE KENTON Ii OMA, P .E.
I -WELL INBrALLATION -ELECI'RICAL DEBIGN
GEOLOGIC EXPLORATION, INC. SMITH SF.CKMAN REID, INC.
I -CllBMICAL ANALYBJB
I
II ~ D. RICK DA VIS --ECKENFELDER, INC. PJIOJlOCT f!r An w _,
i'i STEPHEN A. BATISTE, E.LT.
</) JONATHAN P. MILLER, E.LT.
I
SAMUKL P. WJT.l,lAMS, P.G. >-0 DATA VALIDATION OTIIER TECHNICAL AND _, '---~ a_ ENVIRONMENTAL DATA SUPPORT STAFF AS
SERVICES APPROPRIATE
I aJ
o!:
t::
"' w
I >-ci
FIGURE 2-1 -
I
I PROJECT ORGANIZATION FOR N I REMEDIAL DESIGN OF OU3 ,,, -,,,
0
I 0 FCX-STATESVILLE SUPERFUND SITE
2 STATESVILLE, NORTH CAROLINA
<.:) 0313 5/98 2
I
3: k~ 0:
Noohville, TonmlU9MI rr
0 E'CKENFELDER INC." Mohwoh. New Jersey
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(3) SAFETY EQUIPMENT REQUIRED:
__ Harnesses __ Stretcher x.._Lights
__ Explosimeter x.._Eye wash __ Lights-emergency
__ Blower __ Shower x.._safety cones
__ Lifeline x_Jlarrier tape __ Communications -on-site
__ Ladder x__fire extinguisher __ Communications -off-site
L_first aid kit __ Emergency air horn
Describe other: Hearing1 head and e','e Qrotection to be worn at all times when working
near drilling eguiQment or b',' Qilot Qlant comQressor/b\ower; hard hat; safe!',' shoes; goggles
or safe!',' glasses with side shields; ear Qiugs or muffs
(4) See Section 11 for additional safe work practices.
,. _, __ ~~~~w .. _, __ 'I'"'" m~·i•::t::!i"!<':~---;J---"':.,--,-·----""·il.tl'''."m··F¥"'1"J ,,,_.., r ~ ,--,~~·r~:•·1"'-· ~,..,.,.,,.. ... ~ ··t'; -· ,,_,,_ _$ E. CT LQ N 4: l <': l:l l;I\/IL C e.!1..1:!~Z~ R 1:1.$ .[N F,Q_fl 1\/1~ ffilQ NJ]; a» :ll':!!!'1. lliJ,1,;:iC.-::..:,L'l..1l':X :il.!2.ii;;f!t,,::i,iMa','.?till6,:i,:1t'l!
( 1 ) IDENTIFIED CONTAMINANTS
Known or suspected hazardous/toxic materials (see attached tabulated data).
Media Substances Involved Characteristics Estimated Concentration
See Table 4-1 See Material SafetJ'. Data See Table 4-1
Sheets jMSDS). MSDSs for
substances listed in
Table 4-1 will be maintained
on-site during work activities
and will be accessible to all
. field personnel
Media types: GW (groundwater), SW (surface wa-ter), WW (wastewater), Al (air), SL
(soil), SD (sediment), LE (leachate), WA (waste), OT (other), WL (waste,
liquid), WS (waste, solid), WD (Waste, sludge), WG (waste, gas)
Characteristics: CA (corrosive, acid), CC (corrosive, caustic), IG (ignitable), RA (radioactive),
VO (volatile), TO (toxic), RE (reactive), UN (unknown), OT (other, describe)
(2) DESCRIBE POTENTIAL HAZARDS FOR EACH MEDIA TYPE:
General chemical hazards expected to be medium to low from contaminated soils, surface and
ground waters. Site workers should avoid inhalation of vapors, avoid direct dermal contact,
and avoid accidental ingestion through eating, drinking, or smoking while on site.
(3) SITE RECONNAISSANCE PERFORMED? Yes X No
DATE ~/3/98
14) OVERALL SITE HAZARD LEVEL:
Serious X Moderate X Low Unknown
fo': \DAT A \l'ROJ\ 0313. 0 2\1 IASI'. DOC 3 Project No. 0313.02
I
TABLE 4-1
I IDENTIFIED SITE CONTAMINANTS
I
Substance Media• Characteristics8 Highest Concentration
I (mg/L) (mg/kg)
1,2-DCE (cis & trans) SL, GW, SWSD VO, TO, JG 0.87 0.0245
I Ethylbenzene SL VO, TO, JG 1.8
PCE SL,GW,SW VO,TO 0.388 4.5-5
Toluene SL, GW, SWSD VO, TO, JG 0.067
I TCE SL, GW, SW, SD VO, TO, JG 0.063 0.044
Xylenes (TOT) SL VO, TO, JG 0.0082 15
1,1-DCA GW,SW VO, TO, JG 0.36
I 1,1-DCE GW,SW VO, TO, JG 0.076
1,1,1-TCA GW VO, TO, JG 0.13 0.002
vc GW, SW, SD VO, TO, JG
1,2-dichloropropane GW, SW, SD VO, TO, IG 0.0175
I Acetone SW VO, TO, JG 0.55
Chloroform SW VO, TO, JG 0.01 0.002
1,2-DCA SW VO, TO, JG 0.00244
I Methylene Chloride SW,SD VO, TO, JG 0.0295
Carbon Tetrachloride GW VO,TO 0.065
4,4'-DDT SD TO 0.0041 830
I PAHs SL TO 210
Pesticides GW,SW TO 0.013 318
Aroclor 1254 SL, SD TO
Heptachlorepoxide GW TO 0.000084 0.063
I A]b SL, GW, SD TO 54 42,000
As SL, GW, SD TO 11
Ba SL, GW, SW, SD TO 0.5 510
I Ca SL, GW, SW, SD 30 170,000
Co SL, GW, SW, SD TO 0.52 llO
Pb SL, GW, SD TO 0.061 3,500
I Mg SL, GW, SW, SD TO ll 23,000
Mn SL, SW, SD TO 2.4 3,100
Hg SL,GW TO 0.0007 5.7
K SL, GW, SW, SD TO 0.2 13,000
I Zn SL, GW, SW, SD TO 0.24 3,900
Cr GW, SW, SD TO 0.084 1,200
. Cu GW,SD TO 0.059 900
I Fe GW, SW, SD TO llO 99,000
Se GW TO 6.3
Ni GW, SW,SD TO 0.06 120
Na GW, SW,SD 70 680
I V GW,SW,SD TO 0.099 330
Be SD TO 0.0068 2.2
I ,sec Section 4(1), IDENTIFIED CONTAMINANTS, for abbreviations. MSDSs will be maintained
on-site during work activities and accessible to all field personnel.
I "Metals listed were determined to be present at twice or greater the corresponding background level.
Q:\proj\0313.02\tM0 Ldoc P11ge I of I
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(5) SITE MONITORING REQUIRED? Yes X No
If yes, identify monitoring equipment below:
HNU meter (11.7 eV lamp)
Organic vapor analyzer (OVA)
Describe other:
Monitoring equipment is to be calibrated according to manufacturer's instructions. Record
measured levels in log book.
Describe method of surveillance (e.g., continuous, periodic, etc.). Indicate action levels and
PPE required (total vapors, oxygen, LEL, radiation, other).
1. Monitoring of bore holes and samples, if detect a "hit" then monitor breathing zone.
2. Breathing zone to be monitored for volatile vapor,; and any sustained reading over 5 ppm
above background for 5 minutes will necessitate use of respiratory protection.
(6) PROTECTIVE CLOTHING REQUIRED? Yes _x __ No
If yes, complete protective equipment form (Section 9).
17) RESPIRATORS REQUIRED? Yes X No
If yes, complete Section 9.
'.~E91ilQNllt1~fi'.4z'l(rfciI¢1:iM_r.iiO:!\!.IG~I~9Jil1eRQ.gR!f l'{l'iiJJ.i~:i'17i~ •.. .;~~~;,~;iit~;1.t~.~\~~~~:~f;:E~~i.tit{~:::t
For each chemical introduced to the site by ECKENFELDER INC. (e.g., decontamination liquids),
Material Safety Data Sheets (MSDSs) will be maintained on-site during field activities and will be
accessible for review by all field personnel. These chemicals may include the following:
lsoQrOQanol (Decontamination solvent}
Alconox (Decontamination) Methane (Calibration Gas)
Deet (Insect reQellentl fJitric acid (Decontamination/Preservative}
Hexane (Calibration gas) Sodium hydroxide (Preservative)
H','drochloric acid (Preservative) Sulfuric acid (Preservative}
H','drogen (Calibration gas) TECHNU Poison IV',' Cleanser
lsobut','lene (Calibration gas) TECHNU Poison IV',' Protectant
-~~~J:Ji!Q~J[f.@N _FJ~EJ~JJ._ijAC_~I tNi~Y~~IJ!¥~~tB~~K:tfff~{~~/ . ~; ~:~ir.r:,.;~t·~r~ -· .. ,,~: --:;, .. ~:~;. :~:~~ :.-· .,
I 1 l WILL CONFINED SPACE ENTRY TAKE PLACE? Yes No X
If yes, complete Attachment I, the Confined Space Entry Permit, prior to entering each
confined space, each work shift. The Confined Space Permit must be posted outside the
confined space. I
Q :\proj\0313. 02 \HASP. DOC 4 Project No. 0313.02
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SEc:r1oillj7,r;:·EMERGEiiicv~flilF.0FiiviA:r10N•~~~~w,""i!:l;;-~~?;s{:, ~\11~':'r''i:'\~~,,:;~m'.f~'.'i~iii;.· :. , _ ~ _ .... .:i.,. _ ., •. -• ----· --~--· _,.,;_ ----~ ·-"· · . '"' u,-,. ,,.. .., ~ · · 4""'"-~-'" """'""' "11
TO BE POSTED IN SITE-TRAILER/OFFICE OR IN FIELD VEHICLES
( 1 I EMERGENCY ESCAPE ROUTES (see Figure 7-1 for map): Take 12lant road to Phoenix Street.
Gather in the oarkina lot across street from olant for head count and until all clear is aiven.
NOTE: When site is evacuated due to on-site emergency, personnel shall not re-enter until:
a. The conditions resulting in the emergency have been corrected.
b. The hazards have been reassessed.
c. The HASP has been reviewed.
d. Site personnel have been briefed on any change:; in the HASP.
121 LOCAL RESOURCES
Hospital: Iredell Memorial Hos12ital Phone: 1704} 873-5661
Police: Phone: 911
Fire Dept.: Phone: 911
Onsite Clinic: Phone:
Onsite Police/Fire Phone:
(3) CORPORATE RESOURCES
ECKENFELDER INC. Phone: [phone] (Nashville, TN) 1-(800)-899-2783
Phone: [phone] (Mahwah, NJ)
Robert E. Ash, IV, P.E. Project Director Ext. 477 615-591-2318 (hi
Kenton H. Oma, P.E. Project Manager Ext: 402 615-758-6630 (hi
Ann N. Clarke, Ph.D. Project Health & Safety Mgr. Ext. 401 615-371-9883 (h)
(4) NATIONAL/REGIONAL RESOURCES
Dr. Elayne Theriault EMR, Occupational Medicine Phone: [phone]
Spill Response INFOTRAC Phone: [phone]
EPA RCRA Superfund Hotline Phone: [phone]
Chemtrec (24 Hours) Phone: [phone]
Bureau of Explosives (Associates of American Railroads) Phone: [phone]
Communicative Disease Center Phone: [phone]
National Response Center, NRC (Oil/Hazardous Substances) Phone: [phone]
DOT (Regulatory Matters) Phone: [phone]
North Carolina Motor Vehicle Division Phone: [phone]
U.S. Coast Guard (Major Incidents) Phone: [phone]
National Agricultural Chemical Association Phone: [phone]
(5) DIRECTIONS TO NEAREST HOSPITAL (see Figure 7-2 for map): Turn right on Phoenix
Street go to Front Street. Turn left onto Front Street. Take Front Street to Davie Avenue.
Veer left onto Davie Avenue to Brookdale Drive. Turn left on Brookdale Drive. Hos~ital is on
the corner of Brookdale Drive and Hartness Road !see Finurel
--
161 WHOM TO NOTIFY IN CASE OF ACCIDENT: (Complete and submit the attached Accident/Incident Report.I
Office !Extension} Home
Gene Swift 704-872-0941 (255) 704-871-0853
Nancy K. Prince, CGWP 713-757-3306 71:1-839-1106
Jeffrey L. Pintcnich, P.E. 615-255-2370 (407) 61 ~i-832-4943
Robert E. Ash, IV, P.E. 615-255-2370 (477) 6Hi-591-2318
Ann N. Clarke, Ph.D. 615-255-2288 (401) 61 fi-371-9883
615-373-2005
17) DESIGNATED SITE SAFETY OFFICER DIRECTLY RESPONSIBLE TO THE MANAGER FOR
SAFETY RECOMMENDATIONS IS: Kenton H. Oma P.E.
Jo': \DAT A \1' llOJ\0313 .02 \11 ASI '. DOC 5 Project No. 0313.02
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Textne Plant
Warehouse
Textile Plant
,
__ <'.::__;:;=~:::-.-i
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0313
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Legend
Escape Route
FlGURE 7-1
EMERGENCY ESCAPE ROUTE
AND STAGING AREA
FCX-STATESVILLE SUPERFUNO SITE
STATESVILLE. NORTH CAROLINA
ECKENFELDER INC.•
5/98
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0 0 N
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FIGURE 7-2
ROUTE FROM SITE
TO HOSPITAL
FCX-STATESVILLE SUPERFUND SITE
STATESVILLE, NORTH CAROLINA
k--=--------3-
1 .•
4/98
ECKENFELDER INC." Mohwoh, New Jer,ey
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ri-•--..•---;v.~'IIW'.1-~----•-•·•-· .. •-•·-•.-·•-• ... --·-.. ~·· } -• ,-¢"",:;-f'".-..-_,--,,.._ •·• ,SEGit!..OJ'Ml.~E.B§.QJ.,IJ~!;!:_\·J:ll/:\IIIIIN_G:,111:collD_s:~:_i~,(,:iii.,q;:;:'.!;10.: ~-~::J.~£j~ff.ifil;l~Jl~1Jig~:~Wff
Medical Haz. Waste Supv. Fit Test
Name Current Training Training Current
{date} {date} {date} {include ty1,e & date}
Gregory L. Christians 4/27/98 4/27/98 3/20/91 FF-4/1 5/97
M. Maria Megehee 9/29/97 4/27 /98 8/10/93 FF-4/15/97
Kenton H. Oma, P.E. 4/23/98 11/21/97 4/9/91 FF-10/24/96
Samuel P. Williams 6/24/97 4/27/98 3/1 3/91 FF-3/20/96
'sEa'm01iij_~ROiTEC;Jj_l'liffi;OOIP.i~fENf~ITisi;•;1~f-i,);~!~\%"~,wi(r:·. ~--·-='-'-----l('~_::,i_.., ""~--••. -------· , __ ., _____ ... _:)_..., .;r.;i __ ~--•1.•••.l..! ••. .r ..... . j~£.i f~~~!.K~;~~~:£.1I~i~tf~i.~lii~.)
Respirators
Task & Cartridge Clothing Gloves Boots Other
Drilling NA C or T T s L H E
Well Installation NA T T s L H E
Water SamQling NA T T s G H E
Pilot Test NA C or T NA s L H E
UQgrade as needed C with C T T s G, H, E
aAction levels: Breathing zone concentration of 5 ppm above background for 5 minutes.
RESPIRATORS CARTRIDGE CLOTHING GLOVES BOOTS OTHER
B = SCBA OV = Organic Vapor T = Tyvek B = Butyl F = Firemans F = Face shield
C = Cartridge A_G = Acid gas p = PE Tyvek L = Latex L = Latex G = Goggles
E = Escape As = Asbestos s = Saranex N = Neoprene N = Neoprene L = Glasses
p = Particulate IN-95) C = Coveralls T = Nitrile s = Safety H = Hardhat
C = Combination V = Viton E = Ear Plugs
OV&P or Muffs
NA = Not Applicable
See Attachment C for a more detailed task analysis.
eeern10N~it,O:JijDEC::0NrftAMIN1\-=rt10N]P.Rb"GEDIJRESffl1~~~~:,i',:::_?i~-lF7;\~~~tC'SivJ';.~}.~f~~;k'.~(1.t?~~~1~.~~1~i~ ---. :=..:-' ' ' .. ____ --__ ..... -~-~-. ••.• "'--~...:...:.r.--' ..,.,..., __ .,._.;..,.\, ....
EQUIPMENT: Equipment decontamination procedures for drilling equipment, well
construction materials, and sampling and monitoring devices are presented in Attachment C.
PERSONNEL: Wash grossly contaminated clothing in an Alconox solution followed by a
clean water rinse. Remove disposable outer garments and place into disposal drums. Thoroughly
wash and rinse respirators and allow to air dry. Wash hands in clean soapy water before eating.
Shower as soon as practical and wash work clothing separately from other clothing.
F: \DAT A \PRO,J\0313. 02 \I !ASP. DOC 6 Project No. 0313.02
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1'si:c1:ioK1,,,,"'iTs"AF.E~wOFii<''eFi·A"cT1cEs·,'"~,·'·',fa,1•·:cs,.·•,'~-,-:,·,~·,"· ~ ___ ,..:.;l.;._ lll.:-2;:.i.•~.;.,.; .c ,. __ ~_., ...... -~. ;.,"···•--u1t· "'::s.~aJa!vl.,.;::.._i:.:. ... ,~.uS-.;•,;-,,..: ;·. ··., ::t f;:;;.~:tLl2~~~fi~-~~-f~~;,2_;:~~-r,
THE FOLLOWING WORK PRACTICES MUST BE FOLLOWED BY PERSONNEL ON-SITE
1. Smoking, eating or drinking are forbidden while on-site.
2. No open flames or ignition of flammable liquids within or through improvised heating
devices (e.g., barrels).
3. Minimize contact with samples, excavated materials, or other contaminated materials.
4. Use of contact lenses is prohibited.
5. Do not kneel on the ground when collecting samples.
6. If drilling equipment is involved, know where the "kill switch" is.
7. All electrical equipment must be plugged into ground fault interrupter (GFI) protected
outlets.
8. Use extreme caution when working on or near roadways and their right-of-way.
9. Wear hearing protection when working on or near drilling equipment.
10. Replenish lost body fluids with non-alcoholic and non-caffeinated beverages.
'.§_1;_~ifi!:f~2}~E~_e,g9~~r,:(cfK N'ciY.'-'.i!.~i:>GM _1;!')1.Is1t~bl1rFl'Y'&¥'1 • · -/.-:.t,;;j:'fk:~~t:~JfifuJ!~~tft'ltJ:;.:: ;;:,;
I acknowledge that I have reviewed the information on this HASP and the MSDSs. I understand
the site hazards as described and agree to comply with the contents of this HASP.
EMPLOYEE (print) SIGNATURE DATE
§J;!;:;]J9~t.;f~'.:1f.:'.s§B_c_qJ·Ji1ER~.9.'tqflY.i;\'¢_i<[il_qw.i®-'.G MEN(s,i!flift~I ... ::·~J.::;ri~~il;~l:;.J_ir:r::'ltrjJ?~~•.,~l~·:
I acknowledge that I have reviewed the information on this HASP and the MSDSs. I understand
the site hazards as described and agree to comply with the contents of this HASP.
EMPLOYEE (print) COMPANY NAME DATE
·s1:ctT01iF,Th',"<KuA'cWivi1:riiiiS:11 sli"""1emeniailin1orm'aHcirii'"'if.-1:-•. ,. -~-;.o.;.,..,_ ----~:.a....:.,'k .... -... ·••-•·••-:.!C. ····-··-··:1 ... PP.'_·•----·····--, ... ···• -···--• --· -·•·-.. ti;i .. ___ .,_ . t ~ :1tt!h\~)~fi~}t:'i~tf1~~~:{ff~~~r~~
Attachments E through H provide the following: Personal Protection Daily Log, Accident/Incident
Report Form, Contractor Acknowledgement Form, and Supplemental Information.
1':\ll,\TA \proj\O:l l 3.02\J IASP.DOC 7 Project No. 0313.02
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ATTACHMENT A
SITE DESCRIPTION AND BACKGROUND INFORMATION
Q :'\I' HO,J\0313. 02'\HASl' •CO\'ERS.doc
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A.l Site Description
Physical Layout of Site and Sources
SOURCE: Feasibility Study Report
FCX Statesville OU3
July 23, 1996
610489
Page 1-1
The OU3 site is located in Iredell County approximately 1.5 miles west of downtown
Statesville, North Carolina near the intersection of Yadkin and Phoenix Streets (see
Figure A-1). The OU3 site consists of the impacted ground waters to the north of the
FCX Operable Unit 1 (OUl) site area. The OU3 site consists of the ground water
beneath Burlington's textile plant extending to the north.
The study area is located within the City of Statesville. The textile plant, currently
owned by Burlington, has been used for industrial purposes since the original textile
plant was constructed in 1927. Land immediately surrounding the Site is
predominantly industrial with a variety of other uses ranging from commercial to
residential with associated school and church facilities (see Figure A-1). Further
from the site, rural land in the Statesville area is used for timber farming, farming
of grain crops, and dairy farming.
During RI field activities, 11 potential source areas were evaluated. In most cases
these source areas represent general areas of concern. Sufficient data does not exist
to identify specific sources ofreleases. The 11 potential source areas are:
• Former Rail Spur Line and Machine Shops (Rail Spur Area)
• Former Dry Cleaning Machine and Truck Offloading Area (Dry Cleaning
Area)
• Mop Pit (Mop Pit Area)
• Fuel Oil Underground Storage Tanks (Tank Area)
• Pollution Control Unit 2 and Existing Maintenance Shop Area (PCU 2
Area)
• Pollution Control Unit 1 (PCU 1 Area)
• Southern Railroad Line (Railroad Line)
• Storm Drains and Sanitary Sewers (Storm Drain Area)
• · Other Industrial Facilities in the Area (Other Industrial Facilities)
FCX
Industrial Facilities to the West
Transmission Repair Facility
Revision No.: _1_ Date: 7/23/96
~T~YS\DATA'urni\0313 02~U~
Approved By:. ____ _
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A.1.1 Geology
SOURCE: Feasibility Study Report
FCX Statesville OU3
July 23, 1996
610489
Page 1-2
The OU3 study areas are located in. the Inner Piedmont Physiographic Province of
North Carolina. The regional geology for the area consists of interlayered
amphibolite and biotite gneiss with minor layers and lenses of hornblende gneiss,
metagabbro, mica schist and granitic. rock. The general geology of the Inner
Piedmont typically consists of saprolite and weathered rock overlying crystalline
bedrock. Bedrock was encountered by Aquaterra during the installation of
intermediate wells at the Site.
In general, soils encountered during drilling activities at the OU3 study areas were
predominantly red brown to tan clayey and sandy silts (ML) according to the Unified
Soil Classification System (ASTM D 2488-84). These saprolitic soils have been
derived from weathering of the underlying bedrock, which is a hornblende gneiss
with quartz and feldspar rich pegmatite layers.
The hornblende gneiss in the vicinity of FCX and the OU3 study areas is overlain by
saprolite which ranges in thickness from 16 to 100 feet. Saprolite was thinnest near
the northern most well location (W-20) and thickest at the western edge of the
Carnation facility and the northwestern edge of the textile facility'.
During bedrock coring, competent bedrock (as indicated by 80% Rock Quality
Designation (RQD) values) was encountered at depths ranging from 85 feet at well
W-13i to 148 feet at W-2i. The hornblende gneiss underlying the Site was
interlayered with highly fractured and weathered areas of quartz and feldspar
pegmatite. Bedrock fracture orientations ranged from 10 to 90 degrees from
horizontal'. Bedrock elevations were the highest on the south side of the Carnation
facility and the southeastern portion of the textile plant. Bedrock highs are located
near W-15i at the Carnation plant and at W-5i south of the textile plant and W-13i
east of the textile plant.
Depth to fractured bedrock was greatest along the western edge of the Carnation
facility and northwest of the textile plant warehouse. There appears to be a bedrock
fracture orientation (see Figure 12 of the FRIR) from W-2i through W-9i to W-8i
(slightly west of north-slightly east of south orientation). A reflection in the form of
a bedrock low is seen at W-2i and W-9i. The bedrock surface appears to slope to the
north northwest from W-9i to W-8i and is flat or slightly sloping toward the south
from W-9i to W-2i. Streams to the north and northwest of the textile facility are
oriented north-south and northeast-southwest. These stream orientations may also
reflect areas of more highly fractured bedrock.
Revision No.: _1_ Date: 7/23/96 Approved By: ____ _
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SOURCE: Feasibility Study Report
FCX Statesville OU3
July 23, 1996
610489
Page 1-3
Bedrock to the south of the Site slopes southeast. Depth to bedrock ranges from
52 feet at W-27s to 65 feet at W-29i. A southeasterly oriented stream begins near
W-29i.
The bedrock highs and lows, the slope direction for the bedrock, and the fracture
orientation potentially will influence the contaminant and ground water movement
in the vicinity of the Site. The high degree of fracturing in the bedrock, means there
is a permeable pathway for migration.
A.1.2 Hydrogeology
Ground water in the Statesville area is found in the clayey and sandy soil which is
residual weathered material (saprolite), and in underlying weathered and fractured
bedrock. Water occurs between individual mineral grains in the saprolite and
weathered rock, and within fractures in the underlying bedrock.
The surface of the water table usually occurs in the saprolite and is often a subdued
replica of the topography. Water table elevations are usually highest beneath
hilltops, which are recharge areas, and lowest in the stream valleys, which are
discharge areas. There are noticable fluctuations in the water table with the
changing seasonal climatic conditions. The water table usually begins to decline in
April or May with the onset of the plant growing season. This decline in water levels
continues until the end of the growing season in November and December.
The ground water regime at the Site consists of the saprolite and underlying bedrock
together forming a single ground water reservoir. There are small differences in
aquifer properties and flow directions between the two rock types. It is useful
therefore to consider the two as separate units to evaluate ground water flow at the
site.
Saprolite forms the uppermost hydrogeologic unit at the site. Ground water occurs
within the pore spaces of the saprolite under water table conditions. The base of the
saprolite hydrogeologic unit coincides with the fractured bedrock surface at a depth
ranging from 16 to 90 feet. The fractured bedrock hydrogeologic unit is in turn
underlain by the competent bedrock hydrogeologic unit, which was encountered at
82 feet in W-8i and 80 feet in W-13i. Based on stream orientations and top of
bedrock contouring, fracture zones which may influence bedrock ground water flow
at the site appear to have north-south and northwest-southeast orientations. The
ground water surface in the vicinity of the OU3 study areas occurs in the saprolite at
depths ranging from approximately 4 feet above land surface in the artesian well
W-29i to 45 feet below the land surface. Subsurface conditions encountered to date
at the site are typical for the Piedmont Province.
Revision No.: _1_ Date: 7/23/96 Approved By: ____ _
\ \TN\SYS\PATA'vroi'0'll3 02'nttnchA doc
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SOURCE: Feasibility Study Report
FCX Statesville OU3
July 23, 1996
610489
Page 1-4
Based on the presently available data, a ground water divide appears to extend from
the Carnation plant site (W-15s) to MW-4 across to the southern side of the textile
plant (W-5s) in about the same location as the top of fractured bedrock high
described above. Shallow ground water appears to flow in southerly and northerly
directions with horizontal gradients ranging from 0.01 7 to 0.029 foot/foot,
respectively.
Based on presently available data, the intermediate depth ground water appears to
form a high or mound in the potentiometric levels extending from W-15i through
W-2i toward W-13i. The potentiometric mound generally parallels the top of
bedrock. Ground water in fractured bedrock flows to the south and north from this
potentiometric level ridge under horizontal gradients ranging from 0.012 to 0.027
foot/foot, respectively.
Vertical gradients for the Site were calculated for the September 1994, January,
April, June, September, and December 1995, and March 1996 measuring events (see
Tables 6 and 7 of the FRIR). All calculated vertical gradients for the seven events
were downward, with the exception of the September 1994 gradient for well nest
W-8 and the December 1995 and March 1996 gradients for well nest MW-ll/W-24s.
Based on the data collected during the pumping test, the average K value for the
saprolite hydrogeologic unit was calculated to be 2. 7 ft.I day. The average K of the
fractured bedrock hydrogeologic unit was 3.87 ft./day. The average porosity used in
the calculation of ground water velocities at the site was 25 percent for the shallow
aquifer materials and 20 percent for the intermediate aquifer materials. Average
ground water linear velocities for the saprolite and fractured bedrock were
calculated to be 65 ft./year to the south and 110 ft./year to the north, and 85 ft./year
to the south and 190 ft./year to the north, respectively.
The bedrock surface and any fractures in the bedrock will influence the movement of
contaminants and ground water; especially, the intermediate depth movement. It
appears that the shallow ground water is flowing northward from the vicinity of the
Rail Spur Area, Dry Cleaning Area, Tank Area, PCU 1 Area, and Storm Drain Area
and, southeasterly from the Mop Pit Area, PCU 2 Area, Drain Pipe Area, and
Railroad Line.
The intermediate depth ground water appears to be moving northerly from portions
of the Rail Spur Area, Dry Cleaning Area, and Railroad Line, and all of the Tank
Area and Storm Drain Area. There is a southeasterly movement direction from
portions of the Rail Spur Area, Dry Cleaning Area, and Railroad Line and all of the
Mop Pit Area, PCU 2 Area, Drain Pipe Area, and PCU 1 Area.
The intermediate depth bedrock high appears to direct potential ground water
movement to the northwest and southeast from W-2i such that contamination could
Revision No.: _1_ Date: 7 /23/96 Approved By: ____ _
ill™::rillAT.&1/rvfalJ:l I il 02\ottnchA..d.2'
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SOURCE: Feasibility Study Report
FCX Statesville OU3
July 23, 1996
610489
Page 1-5
move northwestward along the fracture orientation shown by W-2i, W-9i, and W-8i
and southeastward, possibly toward MW-5d and MW-11.
A.2 Site History
A textile plant (Plant) was constructed at the OU3 Site in 1927. From 1955 to 1977,
the Plant was operated by Beaunit Mills, later known as Beaunit Corporation
(Beaunit). In 1967, Beaunit became a subsidiary of El Paso. In April 1977, Beaunit
sold substantially all of its assets, including the Plant, to Beaunit II, Inc. As a part
of that transaction, Beaunit changed its name to BEM Holding Corporation (BEM),
and Beaunit II, Inc. changed its name to the Beaunit Corporation. In July 1978, the
Plant was sold by the Beaunit Corporation (formerly Beaunit II, Inc.) to Beaunit
Fabrics Corporation (Beaunit Fabrics). In 1981, Burlington purchased certain
assets, including the Plant, from Beaunit Fabrics. Burlington operated the Plant
until its closure in May 1994.
It is believed that at various times the plant processed several kinds of yarns and
fibers, including cotton, nylon, rayon, elastic nylon, wool, and polyester. It is also
believed that at various times the Plant may have performed single, double, and
circular knitting, as well as weaving, dyeing, finishing, and heat transfer printing.
In 1986, after FCX declared bankruptcy, environmental assessment activities
conducted by a potential purchaser and the North Carolina Department of
Environment, Health, and Natural Resources (NCDEHNR) Superfund Section
identified ground water contamination at the former FCX property. The EPA then
became involved at the inactive site which was placed on the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA)
National Priority List in November 1990.
Revision No.: _1_ Date: 7/23/96 Approved By: ____ _
illfil.SYS\DATA ',prgj'\Q'l13 02\ottochA doc
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FIGURc
SITE LOCATION MAP
FCX-STATESVILLE SUPERFUNO SITE
STATES\\, .. c, NORTH CAROLINA
0313.02
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ECKENFELDER INc.•
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ATTACHMENT B
DECONTAMINATION PROCEDURES
Q: \PHO,J\0313. 02 \ 1 !A.'31 '-COVERS.doc
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DECONTAMINATION PROCEDURES
General
In order to avoid contaminating the borings or wells with foreign materials or cross-
contaminating from sample location to location, the drilling equipment used over the
borehole, well construction materials, sampling, and monitoring devices will be
cleaned according to these procedures.
Prior to entry onto the site, and after completion of the soil boring program, the drill
rig will be pressure washed with steam/hot tap water. Any visible residues
remaining after the water wash will be cleaned with phosphate free detergent and
tap water and then rinsed with tap water. Decontamination will be conducted
within a bermed concrete decontamination area, lined with polyethylene plastic
(minimum of 10 mil) to be constructed on site. The fluids and sediments will be
containerized, labeled, and stored in an adjacent drum storage area.
The following decontamination procedures will be performed on all sample collection
equipment between sampling events.
Field Decontamination of Stainless Steel or Metal Sampling Equipment
Follow this procedure:
1. If necessary, steam clean to remove heavy soil or clay.
2. Wash with phosphate-free soap and tap water.
3. Tap water rinse.
4. Distilled/deionized water rinse.
5. Solvent rinse with pesticide grade isopropyl alcohol.
6. Distilled/deionized water rinse.
7. Air dry and wrap sampling equipment in aluminum foil with the shiny side
away from the equipment
F:\DATA \l'ROJ\0:l I 3,02\.s11mpli11g plnn.doc B-1
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Laboratory Decontamination of Teflon® and Glass Sampling Equipment
Follow this procedure:
1. Phosphate-free soap in deionized water wash.
2. Distilled/deionized water rinse.
3. 10 percent nitric acid rinse.
4. Distilled/deionized water rinse.
5. Isopropanol rinse.
6. Second isopropanol rinse.
7. Distilled/deionized water rinse.
8. Air dry and wrap sampling equipment in aluminum foil with the shiny side
away from the equipment.
Teflon® hailers will be decontaminated by the analytical laboratory.
Field Decontamination of Teflon® and Glass Sampling Equipment
Follow this procedure:
1. Phosphate-free soap in deionized water wash.
2. Distilled/deionized water rinse.
3. Isopropanol rinse.
4. Distilled/deionized water rinse.
5. Air dry and wrap sampling equipment in aluminum foil with the shiny side
away from the equipment.
Other Equipment
Sampling equipment that does not come in direct contact with the soil sample, such
as the shovel, bucket auger stems, and wheelbarrow will be decontaminated by:
?.\DATA \proj\03 I 3,02\.snm11lint: plnn.do,: B-2
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1. Steam cleaning
2. Phosphate-free soap and a tap water rinse
3. Tap water rinse
The non-dedicated electric submersible pump not used in sample collection will be
cleaned after each well is purged per the following procedure.
Required materials:
1. phosphate-free detergent
2. deionized water supply
3. tap water supply
4. spray bottles
5. storage rack
6. aluminum foil
7. vinyl/latex gloves
8. safety glasses or goggles
9. scrub brushes
10. isopropyl alcohol, and
11. tall upright containers
Procedure:
1. Put on a new pair of vinyl gloves and safety glasses.
2. Clean the exterior pump and column with a phosphate-free detergent and
tap water.
3. Rinse with tap water until all suds are removed.
4. Attach the tubing or column to the pump.
5. Fill an upright 2 to 5 gallon or larger tank, if necessary, to the fill line with
a phosphate-free soap and tap water.
6. Lower the pump into the cleaning solution. Start the pump and pump a
minimum of one gallon of soap and water through the pump and column.
7. Fill the upright tank with tap water.
F:\DATA \proj\0313.02\immplini:-plan.doc B-3
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8. Submerge the pump into the tap water and pump water through the tubing
and pump until all suds are removed.
9. Fill the upright tank with deionized water.
10. Put the pump in the tank and rinse 2 gallons of deionized water through
the pump and hose.
11. Disconnect the pump and tubing and wrap the pump with aluminum foil,
shiny side out.
12. If a purge pump comes up coated with oil and grease or other substance, or
demonstrates an organic odor or high OVA reading, the pump will be
disassembled and cleaned usmg isopropyl alcohol in addition to the
phosphate-free detergent.
F:\Di\'l',\ \ 1•:··,j'.03 I3.tl2\~umplini: plan.doc B-4
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DECONTAMINATION SOLUTIONS
The following chart can be used as a guideline for selecting solutions for the type of
hazard identified:
1. Inorganic acids, metal processing wastes -Solution A
2. Heavy metals: mercury, lead, and cadmium -Solution B
3. Pesticides, chlorinated phenols, dioxins, and PCBs -Solution B
4. Cyanides, ammonia, and other nonacidic inorganic wastes -Solution B
5. Solvents and organic compounds such as trichlorethylene, chloroform, and
toluene -Solution A or C
6. Oily, greasy, nonspecific wastes not suspected to be contaminated with
pesticides -Solution C
7. Inorganic bases, alkali, and caustic wastes -Solution D
8. Radioactive materials -Solution E
9. Etiologic materials -Solution F
Solution A 5% sodium carbonate and 5% trisodium phosphate. Mix
4 pounds of commercial grade trisodium phosphate and
4 pounds of sodium carbonate with 10 gallons of water.
Solution B Solution of 10% calcium hypochlorite. Mix 8 pounds of calcium
hypochlorite with 10 gallons of water.
Solution C A solution of water and 5% trisodium phosphate which can also
be used as a general purpose rinse.
Solution D Mix 1 pint of concentrated HCI into 10 gallons of water (always
add acid to water, never add water to acid) to produce a dilute
solution of hypochlorous acid -HCI0 (a very weak acid). Stir
with wood or plastic stirrer.
Solution E A concentrated solution of detergent and water. Mix into a
paste and scrub with a brush. Rinse with water.
Solution F A solution of 1 cup household bleach for every 1 0 cups of water
OR 1 cup of hydrogen peroxide (3 -4%) for every 10 cups of
water.
Caution: The decontamination solutions listed above are recommended for general groups of
hazardous materials. Always seek expert assistance from manufacturers, a poison control center,
or medical specialist, etc., to determine the best solution to use.
\ITN\SYS'DA TA'Pf!OJDJ13 O:rdeconsol doc B-5
ATTACHMENT C
SITE-SPECIFIC TASKS, HAZARDS, AND CONTROLS
Q:\PRO,J\0:l 13,02\IJASJ>.COVJ<:RS.dnc
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Specific Task
1) Installation of Monitoring
Wells/Probes (oversight only)
Q:'\proj'\0313.02\attachm('nt c.doc
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ATTACHMENT C
SITE-SPECIFIC TASKS, HAZARDS, AND CONTROLS FOR FIELD WORK
AT OPERABLE UNIT 3, FCX-STATESVILLE SUPERFUND SITE
Potential Hazards
a. noise level in excess of 90 dBA
b. carbon monoxide from drilling
ng
c. hazard from overhead utility
wires
d. underground utility services
may be ruptured or damaged
during drilling
e. moving parts on drill rig/auger
may catch through clothes; free
falling parts may injure head,
eyes, etc.
f. movement of rig over uneven
terrain may cause it to roll over
or become stuck
a.
b.
C.
d.
e.
f.
g. high pressure hydraulic lines g.
and air hoses may be hazardous
if incorrectly assembled or poorly
maintained
Control Measures
wear noise reducing PPE
provide flag to indicate wind
direction; stand upwind of rig
exhaust
determine location and nature
of lines before drilling; do not
raise rig mast within 15 feet of
lines
thoroughly search records
before drilling
stand clear of units when
operating; secure loose clothing
review path alternatives; select
least uneven option
inspect daily for problems,
weak spots, frays, etc.
l!!!!!I l!!l!!I 11!!!1
PPE Required
Modified Level D -Work clothes,
safety toed boots, hard hats, safety
glasses with side shields or goggles;
ear muffs and/or plugs; rainsuits or
coveralls as required.
Pate I of3
l!!!!!!!!!I I!!!!!! 11!!1!!!1 l!!!I!! l!!l!!l!!l
Specific Task
l!!!!!!!!I I!!!!! !!!11!!1 !!!!!I -I!!!!!!! I!!!!! I!!!!!! 1!!1115
ATTACHMENT C
SITE-SPECIFIC TASKS, HAZARDS, AND CONTROLS FOR FIELD WORK
AT OPERABLE UNIT 3, FCX-STATESVILLE SUPERFUND SITE (Continued)
Potential Hazards Control Measures
1!!1115 ~
PPE Required
2) Groundwater (well) Sampling a. organic vapors (when opening a. monitor breathing zone; keep Level C -includes Task 1 PPE items
well head) face away from well head plus disposable Tyvek® coveralls (or
equivalellt), disposable boot covers
b. back strain from lifting hailers b. use proper lifting/bailing (with good tread), organic vapor
or pumps from down well; techniques; get assistance, if cartridge respirators (use based on
moving equipment to well necessary monitored level in excess of 5 ppm
locations above background)
C. slip potential due to wet, muddy C. place all purged water into
area around well from spills or drums for removal
inclement weather
d. electrical hazard from use d. use ground fault interrupters
around water or wet surfaces on electrical equipment used in
or around wet conditions
e. groundwater splashed into eyes, e. wear eye and face protection
onto skin
f. exposure to preservative f. handle with care; maintain
chemicals during sampling and only volume of chemicals
decontamination needed on site; wear
appropriate PPE
3) Soil Sampling a. Contact with skin a. sample carefully in order to Level C -as described in Task 2
minimize spillage
b. contact with organic vapors b. keep face away from soil;
monitor breathing zone; stand
upwind; install flag to indicate
wind direction
Q:'\proj'\0313.02\attachment c.doc Page 2 of3
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Specific Task
4) Pilot Testing and Vapor
Sampling
Q;\.proj\0313.02\attachment c.doc
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ATTACHMENT C
SITE-SPECIFIC TASKS, HAZARDS, AND CONTROLS FOR FIELD WORK
AT OPERABLE UNIT 3, FCX-STATESVILLE SUPERFUND SITE (Continued)
Potential Hazards
a. noise from operating air
compresors/fans
b. exposure to heat/cold
c. reduced vision during night
operations
d. slips, trips, falls because of
aboveground piping
e. exposure to organic vapors
during sampling
f. explosion/fire
g. electrical hazards during rain
storms
Control Measures
a. insulate processes generating
elevated noise levels wherever
possible
b. have access to temperature
controlled environment if
temperature stress becomes too
great; have access to fluid
replenishment in
noncontaminated area
c. provide adequate illumination
for nighttime and inclement
weather operations
d. mark with tap, flags, etc.
piping along the ground
e. wear appropriate PPE
(upgrade to Level C if
necessary)
f.
g.
operate system at 20 percent of
LEL or less; use intrinsically
safe materials and equipment
use ground fault interrupters
for all electrical equipment;
ground pilot unit against
lightning strikes
PPE Required
Modified Level D as described in
Task 1
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ATTACHMENT D
GENERAL REQUIREMENTS FOR
CONTRACTORS IN BURLINGTON PLANTS
Q: \l'JtOJ\0:1 13.02 \I I A.<.; I' .COVERS .doc
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PART ONE -GENERAL
DIVISION 1
GENERAL REQUIREMENTS
SECTION 01250 SAFETY RULES AND PRACTICES
FOR
CONTRACTORS IN BURLINGTON PLANTS
1.1 DESCRIPTION
1.1.1 York Included; Hold periodic meetings for review of safety rules and practices to provide systematic discussion of problems relating to construction safety.
1.2 QUALITY-ASSURANCE
1.2.1 It is the policy of Burlington Industries, Inc. to conduct operations in all '·facilities in the safest ma_nner feasible. This policy extends to all company employees ·and to non-company employees who perform work on Burlington Industries premises.
1.2.2 Hence, a contract with Burlington Industries to perform work on BI premises constitutes a requirement that:
1.2.2.1 Contractor employees adhere to BI Safety Rules and Practices for Contractors while on BI premises.
1.2.2.2 The contractor employer enforce BI Safety Rules and Practices for Contractors in addition to Contractor safety rules, as they apply to work by contractor employees while on BI premises.
1.2.2.3 The contractor provide all their subcontractors a copy of these rules and practices and ensure the subcontractor's.compliance.
1.2.3 Yithout in any way relieving the contractor of full responsibility to comply with all appropriate safety requirements, whether or not specified herein, Burlington will designate a representative for each contract project (project manager) with responsibility, among others, for monitoring contractors adherence to the safety rules for the project. The project manager will keep management advised of safety compliance by the contractor and will recommend termination of any contract for continuing flagrant violations of the Burlington Industries Safety Rules and Practice·s for Contractors.
1.2.3.l General: All contractor's equipment and work methods must comply with the Occupational Safety·and Health 1910 General Industry or 1926 Construction Industry Standards depending on the type of work being performed.
1.2.3.2 Special hazards from plant processes are to be identified to the contractor by the Project Manager/Plant Engineer.
01250-01 Rev. 7/91
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PART TWO -PRODUCTS
Not Applicable.
PART THREE -EXECUTION
3.1 HARDHATS AND OTHER PROTECTIVE EQUIPMENT
3.1.1 · In general, contractor employees will wear hardhats on the job
unless it can be demonstrated that no head hazards exist. The contractor
will post signs to indicate where hardhats are to be worn.
3.1.2 · Contractor employees working in company areas where hearing, eye,
respiratory protection, etc., is mandatory for BI employees will be required
to wear equivalent protection.
3.1.3 Personal protective equipment that may be necessary for any
particuiar special work that contractor employees may be doing will be decided
upon by the contractor employer after consultation with the BI project
manager.
3.1.4 All personal protective equipment are to be provided by the
contractor.
3.2 HOUSEKEEPING AND WORK J...\YOUT
3.2.1 The perimeter of the contractor work area will be roped off or
similarly defined to the extent feasible to deter unauthorized access by
non-contractor personnel.
3.2.2 All areas in which contractor employees are working shall be kept
neat, free of trash, and ·in a generally good state of housekeeping.
3.3 FIRE PREVENTION AND WELDING
3.3.1 Smoking in general is not permitted in BI plants except at
authorized locations such as smoking booths. In areas of renovation or new
construction, smoking may be permitted by agreement with the project manager.
3.3.2 Gasoline and similar flammable materials used in the plant must be
kept in approved safety containers.
3.3.3 Compressed gas fuel cylinders in storage must be kept at least 20
feet from oxygen cylinders and "No Smoking or Open Flames" signs must be
prominently displayed.
3.3.4 A daily permit is required for any welding or open flame work.
Permits must be obtained from the BI representative in charge of the project
and returned on a daily basis.
3.3.5 To the extent feasible, welding screens will be used.
01250-02 Rev. 7/91
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3.3.6 Welding in confined space generally will not be done. If such
welding is absolutely necessary, it will be done only after the contractor
determines that the confined space contains no explosive atmospheres and has
sufficient ventilation to prevent oxygen deficiency or excessive fume, smoke,
etc., exposures to welders.
3.3.7 Where contractors are working in non-operating plants, or areas of
plants that may not have fire protection coverage, or new. construction, the
contractor will be responsible for a fire protection plan and must submit this
plan to the project manager.
3.3.8 On each construction project the contractor will identify to the
project manager the person to whom the responsibility of "Fire Marshall" has
been delegated.
3.4 WORKING OVERHEAD OR IN EXCAVATIONS
3.4.1 Contractor scaffolds and ladders will be designed and used in
compliance with OSHA regulations as a minimum.
3.4.2 When performing work in high places, safety belts and a practice of
"tying-off" will be followed to the extent possible.
3.4.3 When work must be done over, or at a level above operating areas or
personnel, provisions shall be made to protect personnel and equipment from
being injured or damaged by falling materials, etc.
3.4.4 When working in excavations, the contractor
standard guardrail or similar protection is installed
excavation and that proper "shoring" is installed.
3.5 CONTRACTOR VEHICLES
wil"i ensure that a
at the top of the
3.5.1 Contractor vehicles and personal vehicles of contractor employees
will be parked only in areas designated by the BI representative in charge of
the project.
3.5.2 Powered industrial trucks brought into BI plants by contractors will
be of the type approved for use in the "class" hazardous location in which
they are to be operated. Operators of these vehicles mus.t be trained.
3.5.3 The number of vehicles with internal combustion engines used in any
one area of the plant will be kept at a minimum to prevent carbon monoxide
build-up. No internal combustion engine shall be used inside a plant area
unless proper ventilation is provided.
3.6 COMPRESSED GAS CYLINDERS
3.6.1 Compressed gas cylinders shall be stored with safety caps in place,
away from heat or flame, and secured to a solid support.
01250-03 Rev. 7 /91
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3.6.2 Compressed gas cylinders in use shall be secured to a solid
support.
3.7 CONTRACTOR TOOLS AND EQUIPMENT
3.7.1 Contractor employees shall not "borrow" tools or equipment from BI
employees or vice-versa.
3.7.2 All contractor electrically powered handtools shall be properly
grounded, be double insulated, or be operated through a ground fault circuit
interrupter.
3.8 CONFINED SPACE ENTRY
3.8.1 Entry into confined spaces such as tanks, pits, etc., shall be made
only after it has been established that there is at least a 19% oxygen
atmosphere with no excessive toxic ,vapors, gases, etc.
3.8.2 Entry will be made only with a life-line, and the contractor will
designate one of his employees as a "safety guard" who will maintain visual
or life-line contact with those in the confined space.
3.8.3 Forced air ventilation or air supplied respirators will be provided
as necessary to ensure safety for employees in the confined space.
3.9 ASBESTOS INSUUTION REMOVAL
See General Requirements Section 01275
4.1 UTILITIES
4.1.1 The contractor will not connect to or use any plant utility without
approval of the plant engineer.
4.1.2 Any such connection must be inspected and approved by the plant
engineer before such connection is placed in use.
4.1.3 Any "Temporary connection" to a utility will be removed by the
contractor at the termination of use of such connection.
4.1.4 Locking out and/or tagging procedures as defined by the plant
engineer will be followed.
5.1 FIRST AID AND ACCIDENTS
5.1.1 The contractor will assure that first aid and medical facilities
are available to construction personnel while on the job site. Plant medical
facilities may be made available as covered in the pre-construction
conference.
01250-04 Rev. 7/91
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5.1.2 Contractor is responsible for immediately reporting in written form to the Project Manager, Construction Manager or Plant Engineer any accident involving personnel or equipment.
6.1 CLEANING FLUIDS
6.1.1 Gasoline, fuel-oil or carbon tetrachloride shall not be used for cleaning purposes.
7.1 RIDING ON EQUIPMENT •
7.1.1 Riding•in the bucket of a front end loader, or riding on any equip-ment where passenger seats have not been provided, is prohibited.
7.1.2 No person shall remain inside of or on a truck when it is being loaded by power equipment.
7.1.3 No person is permitted to ride on a sling or load being hoisted by material handling equipment unless authorized by the Project Manager or his appointed representative.
8.1 CHEMICALS
8 .1.1 Contractors shall provide to Burlington Project Manager or desig-nated representative a list of all chemicals and hazardous materials to be brought on site. Information on how the chemicals or hazardous materials are to be used/stored/disposed of/etc. shall also be provided.
8 .1. 2 The contractor shall be responsible for providing all chemicals and hazardous materials to be used by its employees to complete the project.
8.1.3 The contractor will be responsible for training his employees in the safe use, transport, disposal, etc. of all chemicals and hazardous materials used on the project.
9.1 MSDS SHEETS
9.1.1 It shall be the contractor's responsibility to supply the Owner with Material Safety Data Sheets for all materials that the contractor brings to or uses at the job site.
10.1 SUBSTANCE ABUSE
·10.1.1 Contractor/subcontractor must develop, administer and enforce a policy promoting a drug free workplace.
10 .1. 2 \,lhile on Burlington property abide by Burlington's drug policy which states that:
(1) The use, sale, manufacture, possession, distribution, or unauthorized presences in·the body of illicit drugs or controlled substances is prohibited.
01250-05 Rev. 7/91
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(2) The possession, sale, offer for sale, consumption or being under
the influence of intoxicating beverages is prohibited.
10.1.3 Violations could be grounds for termination of contract.
01250-06 Rev. 7/91
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ATTACHMENT E
PERSONAL PROTECTION DAILY LOG
Q:\PHOJ\0,113.02\JIASl'-COVlm.S.doc
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ECKENFELDER INC.
Project:
Client:
Location:
Date:
Weather Conditions:
Personnel On Site:
Site Instrument Readings:
HNU or OVA Other ________ _
Calibration Date:
Reading Time
Background:
Perimeter Areas:
Active Work Area:
Explosion Meter:
Reading Time
Perimeter Areas:
Active Work Area:
Oxygen Meter:
Reading
Perimeter Areas:
Active Work Area:
Other Readings:
Work Planned:
Work Area:
F:\DATA '\proj\031:1.02\JJl'rllonnd pr,,t,•r.tion.t.lm:
PERSONNEL PROTECTION
DAILY LOG
Job No. _______________ _
Instrument Readings & Specifications by:
Hazards Noted:
Chemical:
Level of Protection:
Dress of the Day:
Changes During the Day:
Decontamination Procedures: ______ _
Remedial Actions Taken:
Date Remedial Action Complete:
Site Safety Officer:
Name:
Signature:
Title:
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ATTACHMENTF
ACCIDENT/INCIDENT REPORT FORM
Q:\PHO,1\03 ! 3.02\J IASP-COVlmS.doc
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ECKENFELDER INC.
ACCIDENT I INCIDENT REPORT
Individual Reporting: ___________________ _ Date:
Time:
Location of Accident/Incident: _________________________ _
Nature of Accident/Incident and Cause: ___________________ _
Chemical Compounds Involved:
Electrical Apparatus Involved: _________________________ _
Individuals Involved: ____________________________ _
Supervised by:--------------------------------
Type of Emergency Actions Required:
Performed by:
Equipment Used:
Emergency Organizations Notified:
First Aid Provided To:
Nature and Extent of Injury:
Number of Work Hours Missed by Jndividual(s): __________________ _
Duration Work Area Closed: ________________________ _
Actions Required to Prevent Reoccurrence of Accident/Incidents: ________ _
Actions Initiated to Prevent Reoccurrence: __________________ _
This report must be submitted within ten working days to the Corporate Health and Safety
Officer.
F-1 Project No. 0313.02
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ATTACHMENT G
CONTRACTOR ACKNOWLEDGEMENT FORM
Q :\.PROJ\0313.02 \11 AS £'-COVERS. doc
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CONTRACTOR ACKNOWLEDGMENT
TO BE SIGNED AND RETURNED TO
ECKENFELDER INC. SITE SAFETY OFFICER
I have received, carefully read, and have signed the Site HASP for the Operable Unit 3 FCX-
Statesville Superfund Site (Site) and the general requirements -Section 01250 Safety Rules and
Practices for Contractors in Burlington Plants (see Attachment D). I agree to abide by these safety
rules, regulations, and guidelines while working at the Site, and understand that a violation of these
rules may result in my removal from the Site.
I have received and completed training in the subjects listed below that address specific hazards
associated with hazardous waste site work.
• Work Rules and Safety Requirements
• Personal Protective Equipment IPPE)
• Potentially Hazardous Chemicals
• Emergency Equipment
• Reporting of Injuries and Illnesses
• Emergency Procedures
• Job Assignment
• Personal Hygiene
• Motor Vehicle Equipment
• Standard Operating Procedures
affirm that I have received 24 or 40 hours of initial HAZWOPER Training (or equivalent) per 29
CFR 1910.120(e). This training included the proper use and fitting of an appropriate respirator. I
have received my initial training or 8 hours of anriual refresher HAZWOPER training within the last
12 months.
I affirm that I have received a medical examination per 29 CFR 1910.12011) within the past 24
months certifying my fitness for duty. This. exam assessed my ability to wear respirators and other
required personal protective equipment that may be required under work site conditions.
Signature ___________________ Date
Print Name
Employer Name
* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
reviewed the training and medical documents provided by the above named individual and have
found them to be within the time frames specified by 29 CFR 1910.120.
ECKENFELDER INC. SITE SAFETY OFFICER
Signature ___________________ Date
Print Name
F: \DAT A \p roj\0313.02 \HASP .DOC G-1 Project No. 0313.02
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Q: \PROJ\0313 .02\I IASI'-COVERS .doc
ATTACHMENT H
SUPPLEMENTAL INFORMATION
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1.0
2.0
3.0
4.0
5.0
6.0
7.0
ATTACHMENT H
SUPPLEMENTAL INFORMATION
TABLE OF CONTENTS
Heavy Equipment Hazards
Sampling and Measurement Hazards
Unanticipated Hazards
General Safety Procedures
Documentation in Field Log-Book
Biological Hazards
6.1 Lyme Disease Prevention
6.2 Poison Ivy, Oak and Sumac Prevention
6.2.1 Signs and Symptoms
6.2.2 First Aid
Procedures for Temperature-Related Problems
7.1 Heat Related Illness
7.2 Worker Monitoring for Heat Related Illness
7.3 Cold Related Illness
F: \DAT A \PROJ ,Q:l l 3.o2 \I ISPSF -AT. doc
Page No.
H-1
H-2
H-3
H-4
H-5
H-5
H-6
H-6
H-7
H-7
H-7
H-7
H-9
H-13
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SUPPLEMENTAL INFORMATION
This document has been prepared for the express use of ECKENFELDER INC. and
its employees and may be used as a guidance document by properly trained and
experienced subcontractors. Due to the hazardous nature of this site and the
activity occurring as part of the corrective action on-site, it is not possible to
discover, evaluate, and provide protection for all possible hazards which may be
encountered and this document does not guarantee the health and safety of any
person entering this site. Strict adherence to the health and safety guidelines
presented herein will reduce, but not eliminate, the possibility for injury at this site.
Guidelines presented herein are site specific and should not be used for other sites
without research and evaluation bv a aualified health and safety specialist.
1.0 HEAVY EQUIPMENT HAZARDS
Physical hazards generally associated with equipment (blowers, hammer drills,
pressure washers, manlifts, etc.) operations include the following:
Naise levels exceeding the OSHA action level of 85 dBA may be a hazard
and also a hindrance to personal communication.
Carbon monoxide fumes from the operation of fossil fueled equipment.
Falls from the elevated manlift platform.
Particles which may be dispersed into the air causing eye inj'-!ries.
Movement af equipment over uneven terrain may cause the equipment to
roll over or become stuck in a rut.
Hazard Prevention
All equipment will be inspected daily by operators for associated problems.
Approved ear muffs and ear plugs will be used to reduce noise levels below
an 85 dBA action level.
F: \J)AT A \J' ROJ, 0313.02\I ISPSF -AT2 .DOC H-1
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Hard hats must be worn at all times when working in a Secure Zone during
heavy equipment operations. Loose clothing will be secured, and the
clearances will be checked prior to approaching the drill rig.
All persons will wear approved safety glasses whenever near equipment
operations. Use of safety face shields may be reuqired during operations
that generate lots of particle,s
2.0 WELL SAMPLING AND MEASUREMENT HAZARDS
Potential hazards associated with well sampling and measurement are listed below:
The potential exposure to volatile organic vapors.
Back strain due to lifting hailers and moving equipment to well locations.
The potential to slip on wet, muddy, or snow-covered surfaces created by
spilled water or inclement weather.
Electrical hazards associated with the use of electrical equipment around
water or wet surfaces.
The potential for water to be splashed into the eyes during sampling.
The potential exposure to preservative chemicals during sampling and
decontamination.
Exposure to deer ticks and contact with poison ivy/oak in grassy or wooded
areas.
Hazard Prevention
To mm1m1ze inhalation of volatile vapors when the wellhead is initially
opened, stand up-wind and allow the well to vent before sampling or taking
measurements. The area of the breathing zone will also be monitored with
F:\DAT A \l'HOJ\03 J 3 .02\l !Srs~· · A T2.DOC H-2
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electronic direct-reading instruments. Wear adequate protective clothing
to minimize direct skin contact with the groundwater.
Back strain can be prevented by employing proper lifting and bailing
techniques. Heavy equipment will be lifted using proper lifting procedures.
Lift with the legs, and when needed, get the help of others.
Slipping on wet surfaces will be prevented by placing purged water in
drums for removal. A boot with a good tread for traction will be used to
minimize the potential of slipping.
Ground fault interrupters will be used when pumps are operated m or
around wet conditions.
Appropriate eye protection (goggles) will be worn to prevent water
splashing into the eyes.
Gloves and other PPE should be worn, as required, to prevent contact with
preservative and decontamination chemicals.
Stay on trails when possible to avoid ticks and poisonous plants. Know
what they look like, wear long sleeves, long pants, and tick repellent on
your clothing.
3.0 UNANTICIPATED HAZARDS
The following conditions, situations, or activities are not anticipated at this site and,
therefore, safety procedures appropriate to them are not included in this Plan. If
these items are encountered or discovered, the Site Safety Officer will immediately
contact the ECKENFELDER INC.'s Project Health and Safety Manager to define a
response. Work in this area must stop until a response is received.
The need to handle, open, sample, or ship drums or containers of hazardous
substances (other than collected samples identified in the Project Work
Plan).
I-': \DA TA \I' HOJ\.0313, 02\I ISPSF-A T2. DOC H-3
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The need to handle, enter, open, sample, or ship hazardous substances.
Activities requiring personal protective equipment greater than Level C.
Field work in non-illuminated areas during periods of darkness. Work
areas must be lighted to at least the minimum illumination intensities
specified in Table H-102.1 of 29 CFR 1910.120(m).
4.0 GENERAL SAFETY PROCEDURES
The following general safety rules must be followed by project personnel:
Safety equipment and protective clothing will be worn at all times by all
persons, in conformance with this Plan and the requirements of
29 CFR 1910.120.
Unnecessary contact with contaminated surfaces or with surfaces
suspected of being contaminated should be avoided.
Eating, drinking, chewing gum or tobacco, smoking, or such pyactices that
increases the probability of hand-to-mouth transfer and ingestion of
material is prohibited in any secure or exclusion zones.
Certain medicines and alcohol can potentiate the effects of toxic chemicals
in exposure situations and should not be used by employees while working
on site. Personnel who must be on medication should advise their
supervisor and the Site Safety Officer prior to beginning work on site.
Hands and face must be thoroughly washed upon leaving the work area
and before eating, drinking, or other activities.
Personnel should shower as soon as possible after protective clothing is
removed and after the end of the work activity.
Jo': \DAT A \PROJ\0313 .02 \I ISPSF-A 1'2.DOC H-4
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5.0 DOCUMENTATION IN FIELD LOG BOOK
Details of site activities whether part of the site inspection or of data collection must
be recorded in the bound field log book which should have numbered and water
resistant pages. All pertinent information regarding the site and data collection
procedures must be documented. Notations should be made in log book fashion,
noting the time and date of all entries. Information recorded in this notebook
should include, but not be limited to, the following:
Name and exact location of site of investigation or interest
Date and time of arrival and departure
Affiliation of persons contacted
Name of person keeping log
Names of all persons on,site
Purpose of visit
Description of data collection plan
Field instrument calibration information
Location of sampling points
Number and volume of samples taken
Method of sample collection and any factors that may affect its quality
Date and time of sample collection
Name of collector
Description of samples
Weather conditions on the day of sampling and previous 48-hours.
6.0 BIOLOGICAL HAZARDS
The potential to encounter various reptiles, insects, and poison ivy in the course of
completing the work plan covered by this HASP is considered highly probable. The
geographic location, the climate, the biota, and the location of the site tend towards
the creation of a suitable habitat for snakes, insects, and poison ivy. Precautions
will be taken by all on site personnel to avoid prime snake and insect habitats, to
protect oneself, and assist other personnel from attack or encounter. (Note: An
encounter with a poisonous snake requires immediate professional medical
attention.)
F:\DAT A \PROJ ,OJ 13.02 \HSPSF-A T'l .DOC H-5
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Ants, bees, and wasps are considered to be the most common insects that may be
encountered. Although their bite is not considered life-threatening, an allergic
reaction to these bites could occur. Avoid insect habitats whenever possible.
If bitten by insects, remove the stinger by gently scrapmg it out (do not use
tweezers). Apply ice to the affected area. Instant ice packs are to be kept in the
· work area. If the worker is bitten by an insect, immediately apply an ice pack to the
affected area and wash area with soap, apply antiseptic. If an allergic reaction
occurs, transport worker to the closest medical facility for treatment.
6.1 LYME DISEASE PREVENTION
The prevention of Lyme Disease is important during spring, summer and fall
months. Lyme Disease is a bacterial infection transmitted by the bite of a deer tick.
About 50 percent of deer ticks carry the Lyme Disease bacteria.
To prevent the bite of a deer tick, avoid grassy areas when possible. Wear
protective clothing (light colored) with long sleeves and pants tucked inside of socks.
Apply repellent containing "Permethrin" or "Deet" to clothing and not directly on
the skin. Make a habit of self inspection after exposure to areas which may contain
deer ticks.
Symptoms: headache, flu-like symptoms, a spreading ring-like rash,
swelling and pain of the joints.
Tich Removal: Remove attached tick immediately. Use tweezers to grasp
the tick's head, near the skin, and slowly pull straight out. If possible, save
the tick for laboratory analysis.
Report any incidents involving deer tick bites to ECKENFELDER INC.'s Project
Health and Safety Officer.
6.2 POISON IVY, OAK AND SUMAC PREVENTION
Poison ivy may be encountered in the grassy/wooded areas on this site. Precautions
include wearing gloves when clearing brush and staying on pathways when
F:\DATA \PHOJ\0:J I J,02\l lSl'SF-AT2.DOC H-6
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possible. Poison ivy, oak, and sumac plants cause contact dermatitis or an allergic
reaction in about 90 percent of all adults. To prevent contact wear protective
clothing (Tyvek, long sleeves, gloves). Remove clothing without touching the outside
of the garments that may have come in contact with the plants.
6.2.1 Signs and Symptoms
Mild reaction: some itching.
Mild to moderate reaction: itching and redness.
Moderate reaction: itching, redness, and swelling.
Severe: itching, redness, swelling, and blisters.
A day or two is the usual time between contact and the onset of signs and
symptoms.
6.2.2 First Aid
Those knowing that they have contacted a poisonous plant should take immediate
action within five minutes. The action includes rinsing with brown soap and water
or using alcohol. During the acute or weeping and oozing stage, sodium bicarbonate
(baking soda) solution should be used.
If symptoms are severe, contact the Project Health and Safety Officer for
instructions for treatment by a physician.
7.0 PROCEDURES FOR TEMPERATURE-RELATED PROBLEMS
7.1 Heat Related Illness
When coveralls made of Tyvek or Saranex are worn, body ventilation and
evaporation are greatly reduced. Frequent breaks will be scheduled for personnel
wearing coveralls during hot or humid conditions as noted in the Heat Index Chart
(see Table H-1). Employees will be advised of the effects of heat stress, be provided
with adequate drinking water while on site, and be instructed to observe each other
for signs of heat stress during hot weather. Signs of heat stress are noted below.
F: \DAT A \I'ROJ'\031 :!. 02 \.l lSl'SF-A TI. DOC H-7
-- ------ ---- -- -
TABLE H-1
COMPARISON OF HEAT STROKE AND HEAT EXHAUSTION
Definition:
History:
Differential
Symptoms:
Treatment:
Heat Stroke
(911 -Medical Emergency)
A condition or derangement of the heat-control centers
due to exposure to the rays of the sun or very high
temperatures. Loss of heat is inadequate or absent.
Exposure to sun or extreme heat
Face:
Skin:
Temperature:
Pulse:
Respirations:
Muscles:
Eyes:
Red, dry, and hot
Hot, dry, and no sweating
High, 106° to ll0°F (41.1 ° to 43.3°C)
Full, strong, bounding
Audible, labored, difficult, loud
Tense and possible convulsions
Pupils are dilated, but equal
Absolute rest with head elevated; keep body cool by any
means available until hospitalized, but do not use alcohol
applied to skin. Take temperature every 10 minutes, and
do not allow it to fall below 101 °F (38.5°C).
Drugs: Allow no stimulants; give infusions of
normal saline (to force fluids).
Source: Taber's Cyclopedic Medical Dictionary, 17th Edition, 1993.
F:\DATA'\PROJ\0313.02\HSPSF-AT2.DOC H-8
Heat Exhaustion
A state of very definite weakness produced by the excess
loss of normal fluids and sodium chloride in the form of
sweat.
Exposure to heat; person usually works indoors
Face:
Skin:
Temperature:
Pulse:
Respirations:
Muscles:
Eyes:
Pale, cool, and moist
Cool, clammy, with profuse sweating
Subnormal
Weak, thready, and rapid
Shallow and quiet
Tense and contracted
Pupils are normal; eye balls may be soft
Keep patient quiet; head should be lowered; keep body
warm to prevent onset of shock.
Drugs: Salty fluids and fruit juices should be given
frequently in small amounts. Intravenous
isotonic saline will be required if patient is
unconsc10us.
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Heat Exhaustion -Acute reaction to heat exposure with symptoms of weakness,
dizziness, fainting, nausea, headache, cool and clammy skin, profuse sweating, slurred
speech, weak pulse, and dilated pupils.
First Aid Treatment includes moving patient to a cool place, loosen clothing, and place
them in a head-low position.
Heat Stroke -A life-threatening, dangerous, and acute reaction to heat exposure with
failure of the heat-regulating mechanisms of the body. Symptoms include high body
temperature, cessation of sweating, dry skin, headache, numbness, tingling, confusion,
fast pulse, rapid and loud breathing, convulsion, and unconsciousness leading into
coma.
First Aid Treatment requires the evacuation and removal of the patient to the Support
Area, removal of protective clothing, followed by the rapid cool down of the patient in
cold water, with the head and shoulders slightly elevated. Heat stroke is a medical
emergency. If anyone shows signs of heat stroke, immediately take emergency
precautions, contact medical personnel, and transport them to a medical facility as soon
as possible (refer to emergency numbers and hospital route in Section 7).
These signs can be distinguished from those associated with chemical hazards which are
characterized by behavioral changes, breathing difficulties, change in complexion or skin color,
coordination difficulties, coughing, dizziness, drooling, diarrhea, fatigue or weakness, and
irritability.
7.2 Worker Monitoring For Heat Related Illness
Monitoring for heat stress per the current ACGIH guidelines will be implemented when the
ambient temperature reaches 70°F (21 °C) for workers wearing splash resistant clothing (Tyvek
or Saranex coveralls). To monitor the worker, measure:
Heart rate. Count the radial pulse during a 30-second period as early as possible in the
rest period. If the heart rate exceeds 110 beats per minute at the beginning of the rest
period, shorten the next work cycle by one-third and keep the rest period the same. If
the heart rate still exceeds llO beats per minute at the next rest period, shorten the
following work cycle by one-third.
F: \DAT A \l'ROJ\0313.02 \HSPSF -A 'I".! .DOC H-9
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Oral temperature. Use a clinical thermometer (three minutes under the tongue) or
similar device to measure the oral temperature at the end of the work period (before
drinking). If oral temperature exceeds 99.6°F (37.6°C), shorten the next work cycle by
one-third without changing the rest period. If oral temperature still exceeds 99.6°F
(37.6°C) at the beginning of the next rest period, shorten the following work cycle by
one-third.
Do not permit a worker to wear a semi-permeable or impermeable garment when
his/her oral temperature exceeds 100.4°F (38°C).
Monitor body water loss, if possible. Measure weight on a scale accurate to ±0.25 pound
at the beginning and end of each work day to see if enough fluids are being taken to
prevent dehydration. Weights should be taken when wearing similar (or lack of)
clothing. Daily body water loss should not exceed 1.5 percent of total body weight in a
single work day. Also, being thirsty is not a good indicator of potential dehydration.
Fluid replacement should consist primarily of water, fruit juices, and other non-caffeinated
beverages. The consumption of alcoholic drinks to replenish lost fluids is not recommended due
to its diuretic effect.
Caution should be exercised when working in hot conditions for the first time or following a
prolonged break (such as vacations) until your body becomes acclimatized to the hot conditions.
NIOSH recommends a progressive 6-day acclimatization period to allow people to become
accustomed to hot conditions with only 50% workload on the first day and an additional 10%
added each following day.
Every effort should be established so that the majority of the work day schedule will be
completed before the ambient air temperatures reach their highs for the day. Rotation of
personnel into jobs requiring the wearing of semi-permeable clothing is also an effective
administrative control to reduce the effects of heat stress.
The frequency of individual physiological monitoring depends on the ambient air temperature,
solar radiation, wind speed, humidity, acclimatization, and the level of physical work activity as
indicated in the above paragraphs. When semi-permeable, splash resistant clothing is added,
the prevention of heat stress through monitoring and work/rest cycles should begin above
temperatures of 70°F as shown below.
F: \DATA \l'HOJ\0:I J :I. 02 \l !Si'SF -A T2 .DOC H-10
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SUGGESTED FREQUENCY OF PHYSIOLOGICAL MONITORING and
WORK/REST CYCLES FOR FIT and ACCLIMATIZED WORKERSa
Heat Index Temperatureb
90'F (32.2°C) or above
87.5'-90'F
(30.8°-32.Z'C)
82.5'-87.5°F
(28.1' -30.8'C)
77.5'-82.5'F
(25.3°-28.1 'C)
72.5'-77.5'F
(22.5'-25.3'C)
Normal Work EnsembleC Semi-Permeable Clothing
After each 45 minutes of work After each 15 minutes of work
After each 60 minutes of work After each 30 minutes of work
After each 90 minutes of work After each 60 minutes of work
After ea.ch 120 minutes of work After each 90 minutes of work
After each 150 minutes of work After each 120 minutes of work
•For work levels of 250 kilocalories/hour (light to moderate work level).
LAdjust temperature for the effect of sunshine by this equation: Heat Index (ta)°F + (13 x % sunshine).
Measure air temperature (ta) with a standard mercury.in.glass thermometer, with the bulb shielded
from radiant heat. Estimate percent sunshine by judging what percent time the sun is not covered by
clouds that are thick enough to produce a shadow. (100 percent sunshine= no cloud cover and a sharp,
distinct shadow; 0 percent sunshine = no shadows.)
CA normal work ensemble consists of cotton coveralls or other cotton long sleeve and pants clothing.
F:\DATA \PROJ\o:i 13.02\HSl'Sl-'-A1'2.DOC H-11
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Heat Index Chart or "\Vhat it Feels Like"
AIR TEMPERATURE
70° 75° 80° 85° 90° 95° 100° 105° 110° 115° 120°
Relative Humidity Apparent Temperature•
0% 64° 69° 73° 78° 83° 87° I 91° 95° 99° 103° 107°
10% 65° 70° 75° 80° 85° I 90° 95° 100° 105° 111° 116°
20% 66° 720 77° 87° I 93° 105° 112° 120° 130°
30% 67° 73° 78° 84° 90° 96° 104° 113° 123° 135° 148°
40% 68° 74° 79° 86° 93° 101° 110° 122° 137° 151°
50% 69° 75° 81° 88° 96° 107° 120° 135° 150°
60% 70° 76° 82° 90° 100° 114° 132° 149°
70% 70° 77° 85° 93° 106° 124° 144°
80% 71° 78° 86° 97° 113° 136° 157°
90% 71° 79° 88° 102° 122° 150° 170°
100% 72° 80° I 91° 108° 133° 166°
*Degrees in
fahrenheit
HOW TO USE HEAT INDEX: Source: National Weather Service
1. Across top (Air Temperature) locate today's predicted high temperature
2. Down left side (Relative Humidity) locate today's predicted humidity
3. Follow across and down to find "APPARENT TEMPERATURE" orf'WHAT IT FEELS LIKE"
HEAT INDEX 90° -100°:
Sunstroke, heat cramps & heat
exhaustion are possible with
prolonged exposure & physical
acti\'ity.
KNOW THESE ...
Heat Disorders
SUNBURN
HEAT CRAMPS
HEAT EXHAUSTION
HEATSTROKE
F:\DATA \l'HOJ\0313.02\HSPSF-AT'l.DOC
APPARENT TEMPERATURE DANGERS
POSED BY HEAT STRESS:
HEAT INDEX 105° -129°: HEAT INDEX 130° or higher:
Sunstroke, heat cramps & heat
exhaustion likely. Heatstroke possible
with prolonged exposure and physical
activity.
Heatstroke or sunstroke imminent.
Symptoms First Aid
Redness & pain ... in severe cases Ointments for mild cases. If blisters appear, do
swelling of skin ... blisters ... fever.. not break. If they do break, apply dry sterile
headaches dressing. Serious burn cases should be seen by a
nhvsician.
Painful spasms usually in mu.Sclcs of Firm pressure on cramping muscles then gentle
legs & abdomen, possible heavy massage to relieve spasm. Give sips of salt water
sweatin!! (1 teasooon ner vJm1s) everv 15 minutes.
Heavy sweating ... weakness .. Get victim out of sun ... lie victim down ... loosen
dizziness ... skin cold ... pale & clammy. clothes ... apply cool cloths. Fan or move victim to
Pulse steady ... normal temperature .. air-cooled room. Sips of salt water every
possible fainting & vomiting l 5 minutes for l hour. If victim vomits .. no
fluids, get medical attention.
High body temperature (IOG" or I-lent stroke is a severe medical problem. Help or
higher) ... hot red dry skin ... rapid & gel victim to hospital immediately. Delay can be
strong pulse ... possible fatal. Move victim to cooler area. Reduce body
unconsciousness temperature with cold bath or sponging. Use fans
and air conditioning.
ECKENFELDER Nnshvillc, Tennessee
INC. Mahwah, New Jersey
H-12
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7.3 Cold Related Illness
Factors affecting the potential development of cold weather related symptoms include
ambient air temperature, wind speed, ambient humidity, perspiration, contact with surface
water or metal, clothing, age, and general health conditions. The Wind Chill Index (see
attached) shows the equivalent temperature on exposed flesh resulting from the combined
effects of ambient temperature and wind speed. It should be noted that high humidity
conditions and cold temperatures also have the effect of rapidly removing heat from the
body.
Cold temperature clothing will be provided to ECKENFELDER INC. personnel required to
work in temperatures below 40°F. This clothing may include insulated coveralls, gloves,
boots, wind breakers, and hard hat liners. Outer and inner garments will be selected that
allows perspiration to be drawn away from the skin.
Work rate should not be so high as to cause heavy sweating when the Wind Chill Index
falls below 10°F. If heavy work must be done, arrangements should be made to provide a
heated warming shelter for rest periods. Work should also be arranged to minimize sitting
or standing still for long periods of time.
Hypothermia is a general term describing the lowering (cooling) of the body core
temperature. Initially, blood flow is restricted to the skin, hands, and feet and
conserved for the body core and brain. Stages of hypothermia include shivering (a
response that generates heat), apathy, decreased muscle function, decreased level
of consciousness, a glassy stare, possible freezing of the extremities, and decreased
vital signs with slow pulse and slow respiration rate.
Severe hypothermia results in a rapid decline in the body core temperature and is an acute
emergency requiring immediate medical attention. Keep the patient as warm and dry as
possible until professional medical attention is available.
Frostbite is the effect of freezing a body part such as the ears, cheeks, nose,
fingers, or toes. Symptoms are first noticed as local tingling and redness, followed
by paleness and numbness. Initial stages are described as frostnip or incipient
frostbite, and characterized by sudden blanching or a whitening of the skin.
Superficial frostbite is where the skin has a waxy or white appearance and is firm
F:\DAT A \I'ROJ'\03 ! 3.02\I IS!'SF-AT2.DOC H-13
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to the touch, but the tissue beneath is resilient. Deep frostbite, is where the tissues
are cold, pale, and solid; this is an extremely serious condition that requires
immediate medical attention.
First Aid Treatment of frostbite is to gradually warm up the affected body part. If
numbness and/or pain does not subside and if deep frostbite is evident, medical
attention should be obtained as soon as possible.
Prevention of frostbite can be accomplished through the replacement of wet clothing
with dry clothing, drinking of warm fluids in the Support Zone, and frequent warm-
up breaks.
Work will be suspended during any weather conditions that are sufficiently extreme to
potentially affect· the adequacy of the HASP or the integrity of equipment, such as heavy
rains, heavy snow fall, electrical storms, or extreme heat or cold. The Site Safety Officer is
. responsible for determining when to suspend work.
F: \DAT A \P ROJ\03 J 3 ,02 \I ISl'SF ·AT2 .DOC H-14
---
Estimated Wind
Speed (in mph)
calm
5
10
15
20
25
30
35
40
{Wind speeds
greater than
40 mph have little
additional effect.)
-
50
50
48
40
36
32
30
28
27
26
-----------
I 40 I 30
40 30
37 27
28 16
22 9
18 4
16 0
13 -2
11 -4
10 -6
LITTLE DANGER
Cooling Power of Wind on Exposed Flesh
Expressed as an Equivalent Temperature
(under calm conditions)
Actual Temperature Reading (°F)
I 20 10 I 0 I -10 -20 I -30
Equivalent Chill Temperature (°F)
20 10 0 -10 -20 I -30
.. 16 6 -5 -15 -26 -36
4 -9 -24 I -33 -46 -58
-5 -18 I -32 -45 . -58 -72
-10 -25 -39 -53 ·.57 I -82
-15 -29. ,-44 -59 -74 -88
"
-18 -33 '48 -63 · -79 -94
-20 -35 -51 -67 ' -'82 -98
-21 -37 -53 -69 -85 -100
INCREASING DANGER
-
-40 -50 -60
.
-40 -50 -60
-47 -57 -68
I .-.-;< ...
-70 -83 -95
I -85 -~9 '. -112
-96 . -110 '121 ...
:-. '."':"
-104 •0118 ,, '' • -133 ,,
-109 '. -125 '-140 ·
,,·.
-113 -129 -. -145
-116 -132 -148
GREAT DANGER
In < 1 hr with dry skin Danger from freezing of exposed Flesh may freeze within 30 seconds.
Maximum danger of false sense of security. flesh within one minute.
' Trenchfoot and immersion foot may occur. at any point on this chart.
'
-
Developed by U.S. Army Research Institute of Environmental Medicine. Natick, MA
F:'\DAT A \PRO.f'-0313.02\HSPSF -AT2. DOC H-15
ECKENFELDER
INC.
Nashville, Tennessee
Mahwah, New Jersey
---