NCD980729602_20030911_Jadco-Hughes_FRBCERCLA RA_Pilot Study for Injection of Reactive Materials 2001 - 2003-OCR

September 11, 2003
Memorandum
TO:
FROM:
RE:
File
Kyle R. Hagen 1/;t:/t: ~
Environmental Engineer
NC Superfund Section
DENR Meeting with EPA and the Jadco-Hughes Techincal Committee
concerning the Full Scale Ethyl Lactate Injection and Site Soils
Jadco-I-lughes NPL Site
NCO 980 729 602
Belmont, Gaston County, North Carolina
On 23 July 2003, representatives of the NC Superfund Section and NC Groundwater Section
participated in a meeting with the EPA RPM and Jadco-Hughes representatives to discuss the
full-scale implementation of the enhanced bioremediation of the chlorinated solvent plume using
ethyl lactate. Discussed the process for UIC approval and monitoring requirements and either
doing an ESD or ROD amendment fo[ this change in the remedy. We also discussed the
requirements for system shutdown and site closure. The final item discussed were the soils in
the former landfill area and the monitoring and institutional controls (deed restrictions) that
would be required if everything except the soil were cleaned up.
Attendees: Michael Townsend-EPA
Randy McElveen -NC Superfund
Kyle Hagen -NC Superfund
Arthur Mouberry-NC Groundwater Section Chief
Evan Kane -NC Groundwater Section, UJC Program Manager
Rob Hoag -Conestoga-Rovers & Associates
Jimmy Kirkland -King & Spalding LLP
Bill Howard -RJR Reynolds
The meeting agenda is attached to this memorandum.
Attachment
• •
AGENDA
JADCO-HUGHES TECHNICAL COMMITTEE MEETING
WITH USEPA AND NCDENR
NCDENR OFFICES
RALEIGH, NORTH CAROLINA
11:00 a.m. to 1:30 p.m.
JULY 23, 2003
1. Enhanced Bioremediation Program
• Application procedure with Underground Injection Control
• Monitoring requirements during implementation
• Explanation of Significant Differences (ESD) vs. Record of Decision (ROD)
Amendment (water injection already part of ROD)
2. Requirements for Shutdown of System and Site Closure
• Implications if groundwater quality does not reach cleanup criteria after
implementation of Enhanced Bioremediation Program
• Requirements for shutting down part or all of the collection systems
• Use of Risk-Based Corrective Action (RBCA) approaches
• Monitoring requirements following system shutdown (monitored natural
attenuation, frequency, number of locations)
3. Soils in Former Landfill Area
• Identify NCDENR's concerns regarding soils
• Most appropriate actions to address these concerns (deed restrictions. etc.)
4. Any Other Site-Related Issues
• Any other Site-related issues identified by USEPA and NCDENR
Page 1 of2
COMPARISON OF GROUNDWATER SAMPLE RESULTS
JADCO-HUGHES SUPERFUND SITE
GASTON COUNTY, NORTH CAROLINA
Concentratiou;(µ&!:_) Increase/Decrease f.!..om ROD Meets cn·ten·a? Effect of Ethyl Lactate
P,1ra111eter ROD Stage Dec-99' /an-03 Criteria to Dec-99 to Jan-03 Dec-99 Jan-03 011 Bioremediation
Acetone ND -140,563 ND -2,400 NR -NR 700 Decr~ase NA No NA Inhibits
Benzene ND -1,285 ND -300 ND -200 Decrease Decrease No No Inhibits
2-Butanone ND -64,000 ND -2,300 NR -NR 170 Decrease NA No NA Inhibits
Carbon Tetrachloride ND -26,118 ND -77,000 ND -19,000 0.3 Increase Decrease No No Enhances
Chlorobenzene ND -340 ND -980 ND -1,900 300 Increase Increase No No Inhibits • Chloroethane ND -15 ND -ND ND -ND 10 Decrease Decrease ~Yes:~;, f§,;:;S;Ye~-_:cl Minimal Effect
Chloroform ND -103,589 ND -4,400 ND -5,700 0.19 Decrease Decrease No No Enhances
1,1-Dichloroethane ND -110 ND -370 ND -350 0.3 Increase 11 Increase No No Enhances
1,2-Dichloroethane ND -5,531 ND -4,200 ND -420 0.3 Decrease Decrease No No Enhances
1, 1-Dichloroethylene ND -839 ND -48 ND -ND 7 Decrease Decrease No ~¥;AY_ef~ Inhibits
1,2-Dichloroethylene (total) ND -15,000 70 Decrease Decrease No
,.-,,,,,,.," ~-'t ·) Inhibits ND -460 ND -ND ~~es,fi;
1,2-Dichloropropane ND -0 ND -88 ND -ND 0.56 Increase Decrease No itJ!]J Inhibits
Ethylbenzene ND -1,268 ND -240 ND.-28 29 Decrease Decrease No Inhibits
2-Hexanone ND -1,800 ND -ND NR -NR 10 Decrease NA •=·~~ NA Inhibits ~$re!¼~
Methylene Chloride ND -10,981 ND -18;000 ND -2,200 5 Increase Decrease No No Enhances
4-Methyl-2-Pentanone ND -10,277 ND -3,400 NR -NR 350 Decrease NA No NA Inhibits
Tetrachloroethylene ND -13 ND -37. ND -29 0.7 Increase I I Increase No No Enhances
Toluene ND -98,808 ND -12,000 ND -110 1,000 Decrease Decrease No ~-cy-~ "'' Inhibits ~.~f~~]
1,1,1-Trichloroethane ND -672 ND -45 ND -ND 200 Decrease Decrease ~s "?,,"l W":~Yes~; Enhances
":'lt.<§1:,-l ... ~
1,1,2-T richloroethane ND -3 ND -ND ND -ND 3 Decrease Decrease ~iYes-:i•CitJ 11t" '"•,;;ij Enhances .. .A"'sYeslii' -;1
T richloroethy Jene ND -380 ND -830 ND -220 2.8 Increase Decrease No No Enhances
Vinyl Chloride ND -68,000 ND -8,900 ND -1,200 0.QJ5 Decrease Decrease No No Minimal Effect
Xylene ND -5,402 ND -420 ND -29 400 Decrease Decrease No l.}?.:j~Yes~M Inhibits • Benzoic Acid ND -4,800 NR -NR ND -ND 28,000 NA Decrease NA '1.fi!:Yes:;~~J Inhibits
Bis (2-chloroethyl) Ether ND -29,000 ND -62,000 ND -6,000 0.03 Increase Decrease No No Minimal Effect
Bis (2-ethylhexyl) Phthalate ND -270 ND -370 ND -0.65 4 Increase Decrease No ~7~ Inhibits ~Al~h,1
1,2-Dichlorobenzene ND -89 ND -ND ND-ND 620 Decrease Decrease IH!(i¥t''"~ iS~' -~~ Enhances ~;:%t~ris~t~a ~'t),'~s1.~5;1<:~
1,3-Dichlorobenzene ND -89 ND -13:() ND -ND 620 Increase Decrease ·~~Ye57:!f t~{R.:..Yes:a Enhances
1,4-Dichlorobenzene ND -590 ND -300 ND -800 1.8 Decrease Increase No No Enhances
Di-n-Butyl Phthalate ND , 680 ND -ND ND -ND 700 Decrease Decrease Inhibits
Phenol ND -1,700 ND -ND ND -ND 4,200 Decrease Decrease Inhibits
1,2,3-Trichlorobenzene ND -3,000 ND -200 ND -5.9 9 Decrease Decrease Enhances
CRA 3669 Present~tion-05/01 /03
COMPARISON OF GROUNDWATER SAMPLE RESULTS
JADCO-HUGHES SUPERFUND SITE
GASTON COUNTY, NORTH CAROLINA
Conce11tration _(µ&(L) lllcrease/Decrease from ROD
Parameter ROD Stage
Aluminum ND· 130
Antimony ND -0.39
Arsenic ND -0.09
B.irium ND -0.56
Beryllium ND -0.001
Cadmium ND -0.008
Chromium ND -0.76
lron 4.2 -200
Lead ND· 0.76
Manganese 0.24 -56
Nickel ND • 0.58
Vanadium ND -0.38
Zinc 0.004 -7.8
Notes:
ND -Not Detected.
NR -Not Reported
NA -Not Af plicable ! Concentration of parameter increased.
: Parameter meets criteria
CllA 3669 Pro.>s."!Lll;ition-05/01/03
Dec-99'
ND · 1,100
ND -ND
ND· ND
ND -40
ND -ND
ND -ND
ND· so"
ND -1,900
ND -ND
ND • 310
ND -ND
ND· ND
ND -160
Jan-03 Criteria to Dec-99 to fan-03
NR · NR 50 Increase NA
NR -NR 3 Decrease NA
ND -ND 50 Decrease Decrease
NR -NR 1,000 Inci'ease NA
NR -NR Decrease NA
NR -NR 5 Decrease NA
ND -0.Q3 50 Increase Decrease
NR -NR 300 Increase NA
ND -ND 15 Decrease Decrease
NR -NR 50 Increase NA
ND· 0.009 150 Decrease Decrease
NR -NR 20 Decrease NA
NR -NR 5000 Increase NA
Page 2 of 2
Meets Criteria? Effect of Ethyl Lactate
Dec-99 Jan-03 on Bioremediatiori
No NA NA
t~Yis~ NA NA }~,.-·.""f_•:". t~Yes5.-'".''J NA
:.-7'{ .><~-:,,Y-ii~~ NA NA ~f,>'Yes,n~
[-~ei~Jtt; NA NA
.,-"''t\¢-"'-"0.;iq.:fl NA • ~"".,tYes·•p~
NA NA
No NA NA
~Ws'zu"'ll ... ~~
NA
No NA
~~x~~7 NA ~i; ,Yes<'" 'l NA NA
~~~:;, NA NA ,, '""'1 --=-~~
•
~
-----PROPERTY UNE
SHALLOW MONITORING WELL
e Pzos SHALLOW PIEZOMETER
c::==;'.> GROUNDWATER FLOW DIRECTION
----650 GROUNDWATER CONTOUR (FT. AMSL)
(UOt) GROUNDWATER ELEVATION (APRIL 30. 1993)
~/ WATER LEVEL NOT MEASURED
C3669-JO(KANEOO\)GN-WA002 FEB 1412003
i
/
~
0 " 100ft
65()
figure 1
SHALLOW GROUNDWATER FLOW PATTERNS -APRIL 30, 1993
PRE-PUMPING CONDITIONS
ENHANCED BIOREMEDIATION PROGRAM
JADCO-HUGHES SITE
Gas.ton County, North Carolina
•
•
LEGEND
-----PROPERTY LINE
--~ ----TREATEDWATERDISCHARGELlNE
PIPELINE
----

-
--

-

-
-• PERIMETER COLLECTION TRENCH
e PWl EXTRACTION WELL
0 MH MANHOLE
■ MHS PUMP CHAMBER
___ L\_
03669·30(KANE001)GN-WA001 FEB 1412003
' " "''"
Ji
figure 2
GROUNDWATER EXTRACTION SYSTEM LAYOUT
ENHANCED BIOREMEDIATION PROGRAM
JADCO-HUGHES SITE
Gaston County, North Carolina
•
•
~
PROPERTY LINE SHALLOW MONITORING WELL LOCATION
SHALLOW PIEZOME1ER LOC1'TION
---·---PROPOSED HOOK-UP TO SEWER
PIPELINE
PERIMETER COLLECTION DRAIN
PUMP WELL
641----
GROUNDWATER ELEVATION (ft. AMSL) DECEMBER 12, 2000
GROUNDWA TEA CONTOUR
0 " 100ft
GROUNDWATER FLOW DIRECTION
0 MH MANHOLE
■ >,<H! PUMP CHAMBER
Ci!1 ss,. STREAM MONITORING LOCATION
03669.30(KANE001)GN•WAOOJ FEB 1 412003
f i
NOTE: 1. GROUNDWATER CONTOURS GENERATED UTILIZING
SURFER VERSION 6.04, SURFACE MAPPING SYSTEM,
KRIGING METHOD.
figure 3
SHALLOW GROUNDWATER FLOW PATTERNS -DECEMBER 12, 2000
ENHANCED BIOREMEDIATION PROGRAM
JADCO-HUGHES SITE
Gaston County, NC
•
•
LEGEND
-----•--PROPERTY LINE
-· ----••• --PROPOSED HOOK·UP TO SEWER
----·-----~-·-PERIMETER COLLECTION DRAIN
• " · PUMP WELL
0 "'H MANHOLE
■ '-'H~ PUMP CHAMBER
Ci ss,. STREAM MONliORING LOCATION
.,, ___ _
==:>
SHALLOW MONITORING WELL LOCATION
SHALLOW PIEZOMETER LOCATION
GROUNDWATER ELEVATION (It. AMSL) JANUARY 6. 2003
GROUNDWATER CONTOUR
GROUNDWATER FLOW DIRECTION
I NOTE~ 1. GROUNOWA TEA CONTOURS GENERA TEO UTIUZ!NG
SURFER VERSlON 6.04. SURFACE MAPPING SYSTEM,
KRIGING METHOD '
I
03669-30(KANED01)GN-WA005 APR 2912003
0 " 100ft
1
' ' t~,J,1,_, ,,._,,..,,._~...,,_;J._,<. >'"""-'""" ,.,,_ ~~ ... .,'\.:"""\_-~"~-,~~.,._, , ... ,,,.
.,,.,, ,;;-_ \,
-------'-il ;z --=a:::,-,? ---·
i: Li.
figure 4
SHALLOW GROUNDWATER FLOW PATTERNS
JANUARY 6, 2003
JADCO-HUGHES SITE
Gaston County, NC
•
•
LEGEND
-----PROPERTY LINE
-----· ---PROPOSED HOOK-UP TO SEWER
PIPELINE
------------PERIMETER COLLECTION DRAIN
PUMP WELL
MANHOLE
■ ,.,., PUMP CHAMBER
i'-1 • STREAM MONITORING LOCATION
I
/
03669-30jKANE00l)GN-WA004 FEB 1412003
(l MW6$1
SHALLOW MONITORING WELL LOCATION
SHALLOW PIEZOMETER LOCATION
INJECTION WELL LOCATION
PROPOSED INJECTION WELL
ELEVATED CHLORINATED SOLVENT CONCENTRATIONS
0 " '""
figure 5
PROPOSED INJECTION WELL LOCATIONS
ENHANCED BIOREMEDIATION PROGRAM
JADCO-HUGHES SITE
Gaston County, NC
•
•
VACUUM TRANSDUCER
LOCATED ON 4•,4• WOOD
POST (TYP)
LIMIT OF FORMER
LANDF!LL AREA
\
' ' ' ' ' \ ' ' \ ' ' \ I \
~--------~' \
I LIMIT OF NEW SOIL COVER
\ \
\ \ '
\ '
\ \, \ \
FORMER LANDFILL AREA
. " r r r u u u
ffi z z u u
~ ~ ~
0
as· "
---r---------'-''-----'--''---...:.;,_
l/4"0.PVC FEED TO STILLING WELLS (TYP.) f--~-,<'C
9" DEEP x 80' LONG
VAPOR EXTRACTION TRENCH
{TYPICAL OF 5)
03659-10{PRES001)GN-WA007 AUG 13!2002
\ \
\ \ .MW16S --
MW17S e
--
1 112•0 PVC POTABLE WATER SUPPLY
FOR FUTURE SOIL FLUSHING
e PW3
e MW17S
0 MH9
■ MH12
SOIL FLUSHING COLLECTION TRENCH WITH
6'0 PERFORATED HOPE COLLECTION
HEADER WITH POL VESTER SOCK
. r u ffi ~
--
CASON STREET
. .
r r ~ u z u u ~ ~
"
------
----
~
EXISTING FENCE
PROPERTY LINE
EXIT TRI BUT ARY
EXTRACTION WELL
MONITORING WELL
MANHOLE
PUMP CHAMBER
--
"
' r u z u ~
--
10" DlA. SCH 40 PVC SOIL VAPOR
EXTRACTION HEADER r;Jw
4"x4" SUPPORTS O 18" c/c
. r u z u " "
------.
i u z u ~
----
MWtBS •
9' DEEP x 100' LONG
' ' ' ' ' ' I' • /MW19S
// '
AIR !NFlL TRATJON TRENCH.
(TYPICAL OF 4)
ew,
SOIL FLUSHING COLLECTION TRENCH WlTH
6'0 PERFORATED HOPE COLLECTION
HEADER WITH POL VESTER SOCK
{SIOERQAD 2W$)
u!UVEl
EX. RAISED
CONCRETE PADS
CARBON VESSELS
SOIL VAPOR EXTRACTION
EQUIPMENT BUILT ON EX.
RAISED CONCRETE PAD
1 112"0 UOUIDNAPOR SEPARATOR
ORAIN LINE TO SOIL FLUSHING
CotLECTION SYSTEM
1 l
D ,.. .. COJ<CF>ETE
FOUNOATION
-1
3
SVE SYSTEM LAYOUT
JADCO-HUGES SITE
Gaston County, Nott/I carotina
•
•
FORMER LANDFILL AREA
I---------------------------------
' ' ' '
VACUUM TRANSDUCER
LOCATED ON 4"•4" WOOD
POST (TYP)
'\
LIMIT OF FORMER
LANDFILL AREA
\
\
f LIMIT ore NEW SOIL COVER
\
\ \
\
3'4"0 PVC FEED TO STILLING WELLS (TYP.)
9' DEEP• 80' LONG
N 0
" " " u u u z ~ ffi " ~ ~ ~
D ..
~ z " ~
VAPOR EXTRACTION TRENCH
(TYPICAL OF 5)
.MW16S --_.-
03669-1 O(PRES001)GN-WAOOB AUG 13/2002
--
MW17S e
l 1/2"0 PVC POTABLE WATER SUPPLY:
FOR FUTURE SOIL FLUSHING
e PWJ
e MW17S
0 MH9
■ MH\2
SOIL FLUSHING COLLECTION TRENCH WITH
6'0 ?ERFORATEO HOPE COLLECTION
HEADER WITH POL YEST ER SOCK
CASON STREET
"
. .
" ' " ' u u u u
.
" u
(SJDEROAD 20J6J
MW18S •
0 20
EX. RAISED
CONCRETE PADS
""
CARBON TANKS
z z z z ffi ' e MW19S
" " " " ~
-----
----
LEGEND
EXISTING FENCE
PROPERTY LINE
EXIT TRIBUTARY
EXTRACTION WELL
MONITORING WELL
MANHOLE
PUMP CHAMBER
~ ~
--
~ ' ~ ' //
' I!
Ii
,I , , ,
----
g· DEEP x 100' LONG
AIR INFILTRATION TRENCH,
(TYPICAL OF 4)
/
,w,
SOIL FLUSHING COLLECTION TRENCH WITH
6'0 PERFORATED HOPE COLLECTION
HEADER WITH POL YE STER SOCK
Ll
GRAVEL
SOIL VAPOR EXTRACTION
EQUIPMENT 8Ull T ON EX.
RAISED CONCRETE PAO
1 1/2"0 LIOUIDNAPOR SEPARATOR
DRAIN LINE TO SOlL FLUSHING
COLLECTION SYSTEM
r l
D ,. ...
L --7
I
J. -:;;
CONCRETE
FOUNDATION
SOIL FLUSHING LAYOUT
JADCO-HUGES SITE
Gaston County, North Carolina
•
•
• •
AGENDA
JADCO-HUGHES TECHNICAL COMMITTEE MEETING
WITH USEPA AND NCDENR
NCDENR OFFICES
RALEIGH, NORTH CAROLINA
11:00 a.m. to 1:30 p.m.
JULY 23, 2003
1. Enhanced Bioremediation Program
• Application procedure with Underground Injection Control
• Monitoring requirements during implementation
• Explanation of Significant Differences (ESD) vs. Record of Decision (ROD)
Amendment (water injection already part of ROD)
2. Requirements for Shutdown of System and Site Closure
3.
• Implications if groundwater quality does not reach cleanup criteria after
implementation of Enhanced Bioremediation Program
• Requirements for shutting down part or all of the collection systems
• Use of Risk-Based Corrective Action (RBCA) approaches
• Monitoring requirements following system shutdown (monitored natural
attenuation, frequency, number of locations)
Soils in Former Landfill Area
• Identify NCDENR's concerns regarding soils
• Most appropriate actions to address these concerns (deed restrictions. etc.)
4. Any Other Site-Related Issues
• Any other Site-related issues identified by USEPA and NCDENR
Pagel of2
COMPARISON OF GROUNDWATER SAMPLE RESULTS
JADCO-HUGHES SUPERFUND SITE
GASTON COUNTY, NORTH CAROLINA
Concentratio11j(pg(!:;) Increase/Decrease [!om ROD Meets Criteria? Effect of Etltyl Lactate
Parameter ROD Stage Dec-99: Jan-03 Criteria to Dec-99 to ]an-03 Dec-99 Jan-03 on Bioremediation
Acetone ND -140,563 ND -2,400 NR -NR 700 Decrease NA No NA Inhibits
Benzene ND -1,285 ND -300 ND -200 Decrease Decrease No No Inhibits
2-Butanone ND -64,000 ND -2,300 NR -NR 170 Decrease NA No NA Inhibits
Carbon Tetrachloride ND -26,118 ND -77,000 ND -19,000 0.3 Increase Decrease No No Enhances
Chiurobenzene ND -340 ND • 980 ND · 1,900 300 Increase Increase No No Inhibits • Chloroethane ND -15 ND -ND ND -ND 10 Decrease Decrease ~y~ ~;Y~S~~rJJ Minimal Effect
Chloroform ND -103,589 ND· 4,400 ND • 5,700 0.19 Decrease Decrease No No Enhances
1, 1-Dichloroethane ND -110 ND -370 ND -350 0.3 Increase I I Increase No No Enhances
1,2-Dichloroethane ND· 5,531 ND· 4,200 ND • 420 0.3 Decrease Decrease No No Enhances
1,1-Dichloroethylene ND -839 ND· 48 ND -ND 7 Decrease Decrease No Inhibits
1,2-Dichloroethylene (total) ND -15,000 ND · 460 ND -ND 70 Decrease Decrease No Inhibits
1,2-Dichloropropane ND -0 ND -88 ND -ND 0.56 Increase Decrease No Inhibits
Ethylbenzene ND· 1,268 ND · 240 ND.-28 29 Decrease Decrease No Inhibits
2-Hexanone ND -1,800 ND· ND NR -NR 10 Decrease NA rar::Yetf.J:J Inhibits
Methylene Chloride ND -10,981 ND • 18;000 ND · 2,200 5 Increase Decrease No No Enhances
4-Methyl-2-Pentanone ND • 10,277 ND · 3,400 NR -NR 350 Decrease NA No NA Inhibits
T etrachloroethylene ND -13 ND -37, ND -29 0.7 Increase I I Increase No No Enhances
Toluene ND -98,808 ND · 12,000 ND· 110 1,000 Decrease Decrease No ~':/;N es~, Inhibits
~h:,Y_eS~A ~-} ~-::;1(.; "}SC Enhances
1, 1, 1-Trichloroethane ND • 672 ND -45 ND· ND 200 Decrease Decrease f,i:'i..\Yes~'-r ~-.-, ... ,,. f~·r--s-,,!'J' Enhances
1,1,2-Trichloroethane ND -3 ND· ND ND· ND 3 Decrease Decrease ~.Yes~r:J ~Yes¥'-!1
Trichloroethylene ND • 580 ND · 830 ND -220 2.8 Increase Decrease No No Enhances
Vinyl Chloride ND -68,000 ND · 8,900 ND -1,200 0.DJ5 Decrease Decrease No No Minimal Effect
Xylene ND -5,402 ND -420 ND -29 400 Decrease Decrease No WffGYEis~~ Inhibits
Benzoic Acid ND -4,800 NR -NR ND -ND 28,000 NA Decrease NA ~:m] Inhibits • Bis (2-chloroethyl) Ether ND· 29,000 ND · 62,000 ND -6,000 0.03 Increase Decrease No No Minimal Effect
Bis (2-ethylhexyl) Phthalate ND· 270 ND -370 ND -0.65 4 Increase Decrease No ~Y£tj~ Inhibits
1,2-Dichlorobenzene ND· 89 ND -ND ND· ND 620 Decrease Decrease a.,.,JX~ ,,_,:~sb'"-. Enhances ~~? ,~-7-Jfy
1,3-Dichlorobenzene ND -89 ND -13:() ND· ND 620 Increase I Decrease .~~~~Yes~~~~ -5_· .. YeS-/.,, Enhances
1,4-Dichlorobenzene ND -590 ND • 3(X) ND· 800 1.8 Decrease I Increase No No Enhances
Di-n-Butyl Phthalate ND -680 ND-ND ND -ND 700 Decrease Decrease ;;;,·,,cYeslJ u··"-y -~Pl Inhibits
Phenol ND · 1,700 ND -ND ND -ND 4,200 Decrease Decrease -~-'"i"'-"¥4:-i;ij ~~:~j}··. Inhibits fr-~iy es' ;ri l:I,,h~tY.es;,,4:j
ND · 200 9 Decrease No ~"'•'"'·" Enhances
1,2,3-T richlorobenzene ND -3,000 ND -5.9 Decrease ;Yes, -2:';1 =-
CRA 3669 Pr.es.entMion-05/01 /03
COMPARISON OF GROUNDWATER SAMPLE RES UL TS
JADCO-HUGHES SUPERFUND SITE
GASTON COUNTY, NORTH CAROLINA
Concentratiori i(µg/L) Increase/Decrease [rom ROD
Parmneter
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Iron
Le.id
Manganese
Nickel
Vanadium
Zinc
Notes:
ROD Stage
ND -130
ND -0.39
ND -0.09
ND -0.56
ND -0.001
ND· 0.008
ND -0.76
4.2 -200
ND -0.76
0.24 -56
ND -0.58
ND • 0.38
0.004 -7.8
ND· Not Detected.
NR -Not Reported
NA -Not Af plicable
/ Concentration of parameter increased.
· .· .. ·" Parameter meets criteria
CRA 3669 Pres."nt~tion-05/0l/03
Dec-99· Jan-03
ND -1,100 NR -NR
ND -ND NR -NR
ND -ND ND -ND
ND -40 NR -NR
ND -ND NR -NR
ND -ND NR -NR
ND -Sci ND • 0.03
ND -1,900 NR -NR
ND -ND ND -ND
ND -310 NR -NR
ND -ND ND -0.009
ND -ND NR -NR
ND -160 NR -NR
Criten·a to Dec-99 to Jan-03
50 Increase NA
3 Decrease NA
50 Decrease Decrease
1,000 Increase NA
1 Decrease NA
5 Decrease NA
50 Increase Decrease
300 Increase NA
15 Decrease Decrease
50 Increase NA
150 Decrease Decrease
20 Decrease NA
5000 Increase NA
Page 2 of 2
Meets Criteria? Effect of Ethyl Lactate
Dec-99 Jau-03 on Bioremediation
No NA NA
&~WeSJ~ NA NA
~l~~Yesf~~ ~"'?[Yesf~~ NA
~.<::.';,._-,-i-; •. 11'(,..d\ ~-"----tp·1J ~~t'::f. NA NA
*.;~Y€s~:t·1 NA NA
n'.;,.}~ ,--:"",,A,.¥ NA NA ~-~·>Yes{!::J
NA ~~~ NA ~-..,,., • No NA NA
~YeSw::8 ~$/~~i NA
No NA NA
~'!);;y.;~~ ~Ye'sfil'.~ NA
~'.ves1'f~ NA NA •?~•e•"~ ~*tse'~}:i:-~ l NA NA
•
il.fil.!:ill.
-----PROPERTY LINE
SHALLOW MONITORING WELL
• Pzos SHALLOW PIEZOMETER
==e>, GROUNOWA TEA FLOW DIRECTION
----650 GROUNDWATER CONTOUR (FT. AMSL)
r--nJ GROUNDWATER ELEVATION (APRIL 30, 1993)
(M() WATER LEVEL NOT MEASURED
/
03669-30(KANE001 )GN-WA002 FEB 1412003
.. 100ft
figure 1 ·
SHALLOW GROUNDWATER FLOW PATTERNS -APRIL 30, 1993
PRE-PUMPING CONDITIONS
ENHANCED BIOREMEDIATION PROGRAM
JADCO-HUGHES SITE
Gaston County, North Carolina
•
•
~
-----PROPERlY UNE
-~ ~ ----lREATEDWATEROISCHARGELINE
-----· PIPELINE
---

-
---

-
--

-
PERIMElER COLLECTION TRENCH
e PWl EXlAACllON WELL
0 MH MANHOLE
■ MH5 PUMP CHAMBER
)_\_
03669.JO(KANEOOl)GN•WAOOl FEB 1412003
I
I
0 " 100ll
1i
··----•----.: ..
figure 2
GROUNDWATER EXTRACTION SYSTEM LAYOUT
ENHANCED BIOREMEDIATION PROGRAM
JADCO-HUGHES SITE
Gaston County, North Carolina
•
•
LEGEND
PROPERTY LINE SHALLOW MONITORING WELL LOCATION
SHALLOW PIEZOMETER LOC,t.,TJON
PROPOSED HOOK-UP TO SEWER
PIPELINE
-·-----~-PERIMETER COLLECTION DRAIN 651----
GROUNDWATER ELEVATION (It. AMSll DECEMBER 11, 2000
GROUNDWATER CONTOUR
0 "'
J.. PUMP WELL ==C> GROUNDWATER FLOW DIRECTION
0 ""' MANHOLE
■ '"'b PUMP CHAMBER
Ci! ssu STREAM MONITORING LOCATION
03669-30(KII.NE001)GN-WA003 FEB 14/2003
I
NOTE: 1. GROUNDWATER CONTOURS GENERATED UTILIZING
SURFER VERSION 6.04, SURFACE MAPPING SYSTEM,
KRIGING METHOD.
figure 3
SHALLOW GROUNDWATER FLOW PATTERNS -DECEMBER 12, 2000
ENHANCED BIOREMEDIATION PROGRAM
JADCO-HUGHES SITE
Gaston County, NC
•
•
~
-·---PROPERTY LINE
-· ----· --PROPOSED HOOK-UP TO SEWER
SHALLOW MONITORING WELL LOCATION
SHALLOW PIEZOMETER LOCATION
.PIPELINE
----·-------·-PER!Mf:TtA COLLECTION DRAIN
GROUNOW,\TER ELEVATION (II. AMSL) .JANUARY 6, 2003
GROUNDWA TEA CONTOUR
PUMP WELL ==(> GROUNDWATER FLOW DIRECTION
0 "'H MANHOLE
■ "H' PUMP CHAMBER
Cii1 ss,, STREAM MONITORING LOCA T\ON
/
03669•30IKANE001 )GN-WAOOS APR 2'l/2003
I NOTE: 1 GROUNDWATER CONTOURS GENERATED UTILIZING
SURFER VERSION 6.04. SURFACE MAPPING SYSTEM.
KRIGING METHOD.
,t
0 " 100ft
~ -~ .. \ .)
(_vi;}~ _-,;..J-J---A..~ ~,.,..,.,__.......__,,.,.,.>~-_,'\.:~\•,._~-..,,._) )-~ •
----------~-.:... .,,__. ~-· .
' '' LL
figure 4
SHALLOW GROUNDWATER FLOW PATTERNS
JANUARY 6, 2003
JADCO-HUGHES SITE
Gaston County, NC
•
•
LEGEND
-------PROPERTY LINE
•• ------PROPOSED MOOK.UP TO SEWER
PIPELINE
------------PERIMETER COLLECTION ORAIN
! .-,-. PUMP WELL
MANHOLE
11 1' . PUMP CHAMBER
,,;: :-_.-, STREAM MONITORING LOCATION
03669-30(KANE001)GN-WA004 FEB 1412003
i
!
I
(I l.lWOSI
SHALLOW MONITORING WELL LOCATION
SHALLOW PIEZOMETER LOCATION
INJECTION WELL LOCATION
PROPOSED INJECTION WELL
ELi:::VA TEO GHLORINA TEO SOLVENT CONCENTRATIONS
0 " 100ft
figure 5
PROPOSED INJECTION WELL LOCATIONS
ENHANCED BIOREMEDIATION PROGRAM
JADCO-HUGHES SITE
Gaston County, NC
•
•
FORMER LANDFILL AREA
.----------------------------
' ' ' '
VACUUM TRANSDUCER
LOCATED ON 4"x4" WOOD
POST (TYP)
LIMIT OF FORMER
LANDFILL AREA
\
\
I
' \ ' ' \ ' ' I ' ' ----------~\ \~ I LIMIT OF :-.!EW SOIL COVER ~ \
\ \ \
\ \ \
'
3/4"0.PVC FEED TO STILLING WELLS (TYP.)
"
SOIL FlUSHING COLLECTION TRENCH WfTH
6'0 PERFORATED HOPE CQl.LECTION
HEADER WITH POL VESTER SOCK
CASON STREET
10" DIA. SCH 40 PVC SOIL VAPOR
EXTRACTION HEADER c/W
4"x4" SUPPORTS O 16' c/e
-31 -------1
~ ' .
ii " " u u u
ci z ci ffi " ~ ~ " ~ e
'
" ---------------------------
"' MW18S •
----
9' DEEP x 100'LONG
' ' ' ' ' ' I' • f MW19S
// ' PW
1o·x5•
REDUCER
.MW16S .,-..-
AIR lNFIL TAATION TRENCH
(TYPICAL OF 4)
9' DEEP x 60' LONG
VAPOR EXTRACTION TRENCH
(TYPICAL OF 5)
03669-10(PRES001)GN-WA007 AUG 1312002
--
MWl7S e
1 112"0 PVC POTABLE WATER SUPPLY
FOR FUTURE SOIL FLUSHING
e PWJ
e MW17S
0 MH9
■ MH12
LEGEND
EXISTING FENCE
PROPERTY LINE
EXIT TRIBUTARY
EXTRACTION WELL
MONITORING WELL
MANHOL::
PUMP CHAMBER
/
SOIL FLUSHING COLLECTION TRENCH WITH
6"0 PERFORATED HOPE COLLECTION
HEADER WITH POL YEST EA SOCK
(SIOEROAD 2035)
OFU.VEL
0 20
EX. RAISED
CONCRETE PADS
""
CARSON VESSELS
SOIL VAPOR EXTRACTION
EQUIPMENT BUil T ON EX.
RAISED CONCRETE PAD
1 112"0 LIOUIDNAPOA SEPARATOR
DRAIN LINE TO SOIL FLUSHING
COLLECTION SYSTEM
r l
L --7
I
I
CONC'1EIT
FOUNDATION
SVE SYSTEM LAYOUT
JADCO-HUGES SITE
Gaston County, North Carolina
•
•
FOAMER LANDFILL AREA
I------------------------------•--
::a :=a
VACUUM TRANSDUCER
LOCATED ON 4"x4" WOOD
POST (TYP)
LIMIT OF FORMER
LANDFILL AREA
\
I
' ' ' ' ' ' ' ' ' ' ' I I '
Ir! L-,M-,,-,-o-,-N-E_W_S_O_\L_C_O_V_E_R_1 '. ~\
. f-,l---""'' \ '
\ ' \ \ \
\ '
\
\ \
\
3/4"0 PVC FEED TO STILLING WELLS (TYP.)
9'0EEP x 80'LONG
VAPOR EXTRACTION TRENCH
(TYPICAL OF 5)
•
------
MW17S e
1 112"0 PVC POTABLE WATER SUPPLY :
FOR FUTURE SOIL FLUSHING
O3669·1O(PRESOO1)GN-WAOO8 AUG 1312002
e PW3
e MW17S
0 MH9
■ MH12
ii z w ~
SOIL FLUSHING COLLECTION TRENCH WITH
6'0 PERFORATED HOPE COLLECTION
HEADER WITH POL YE STER SOCK
CASON STREET
,,
-0 ' .
r r r r
u u u u z ffi z z w w w s ~ ~ ~
•
• r u
ffi ~
•
(SIDEROAD20MJ
MW18S • ' e MW19S
I I
I! C
' // PWO
Ii
,I
' ' '
-----------
----
_ :WO CONCA HE CVLVUH
-=: = = ---
LEGEND
EXISTING FENCE
PROPERTY LINE
EXIT TRIBUTARY
EXTRACTION WELL
MONITORING WELL
MANHOLE
PUMP CHAMBER
9' DEEP x 100' LONG
AIR INFILTRATION TRENCH.
{TYPICAL OF 4)
/
SOIL FlUSHlNG COLLECTION TRENCH WJTH
6'0 PERFORATED HOPE COLLECTION
HEADER WITH POL YE STER SOCK
EX. RAISED
CONCRETE PADS
Gl'IAVEL
SOIL VAPOR EXTRACTION
EQUIPMENT BUILT ON EX.
RAISED CONCRETE PAD
1 112·0 LIOUIONAPOR SEPARATOR
DRAIN LINE TO SOIL FLUSHJNG
COLLECTION SYSTEM
, l
L --I
I
J. :s
CONCRETE
FO\JNOATION
SOIL FLUSHING LAYOUT
JADCO·HUGES SITE
Gaston County, North Carolina
•
•
• • •
April 22, 2003
Memorandum
TO:
FROM:
RE:
File
Randy McElveen
Environmental Engineer
NC Superfund Section
Meeting with EPA and PRP Rep to discuss Full Scale Ethyl Lactate Injection
Jadco-Hughes NPL Site
NCD 980 729 602
Belmont, Gaston County, North Carolina
On IO December 2002, a representative of the NC Superfund Section participated in a meeting
with the EPA RPM and Jadco-Hughes representatives to discuss the results of the ethyl lactate
injection Pilot Study in shallow groundwater (MW-6S) at the Jadco-Hughes Superfund Site
located in Belmont, Gaston County, North Carolina. We also discussed and approved full-scale
implementation of ethyl lactate treatment of the chlorinated solvent plume at the Site. The
Division of Water Quality Underground Injection Control branch of the Groundwater Section
was suppose to participate but was unable to do so due to recent damage to his home from severe
weather conditions. We also completed a site overview and update and discussed the potential
timing of the full-scale application of the ethyl lactate technology.
The meeting agenda and attendance list is attached to this memorandum.
Attachment
cc: Dave Lown, NC Superfund Section
RA
• •
Meeting to Discuss
UIC Regulatory
Requirements
Jadco-Hughes Superfund Site
Gaston County, NC
December 10, 2002
Meeting Objective
■ Determine the NCDENR
application, approval and
operating requirements for an UIC
groundwater remediation system
• •
Site Overview
■ 1971-1975 solvent reclamation
and waste storage
■ 1975 site closed
■ 1986 site listed on NPL
■ groundwater contamination
includes voes and SVOCs
Site Remediation
■ Groundwater treatment system
includes an aeration tank with
vapor-phase treatment with
discharge to POTW
■ 1996 began groundwater
treatment
2
• •
System Performance
■ 5.4 x 106 gallons treated to date in
2002
■ 37.9 x 106 gallons treated since
startup
■ 166 pounds voe removed since
startup
Groundwater System
■ Operating as designed
■ groundwater contained on-site
■ limited natural attenuation
3
• •
Steering Committee
■ Objective to remediate site
expeditiously
■ CRA conducted pilot study to
evaluate use of ethyl lactate to
accelerate remediation
■ results showed groundwater
improvement
■ evaluating possible large scale
application
Regulatory Requirements
■ Need to understand:
-APPLICATION PROCESS
-TECHNICAL ISSUES
-PERMIT/APPROVAL PROCESS
-TIMING FOR APPROVAL
-COORDINATION WITH EPA
4
No...W\.,~
NcbENK
~=-/47 -k_.. 7::-c/4c" I L$~-~"
~·,.;ct., c;f<lj J
Ce.A
L) :::, t. ·p ?\ .
•
. (§)-------------------1651 Colby Drive. WaterlOO, Ontario, Canada N2V 1C2
Telephone: 519·884·0510 Facsimile: 519·884·0525
CONESTOGA-ROVERS www.CRAworld.com
& ASSOCIATES
December 10, 2001 Reference No. 3669
... _..,,. .. Mr: Mark Pritz! . I '.' (\'' 1~2 \\ \;f/ rC \~-~------
Underground Injection Control Program (UICP) \· i) \;; ,,, .. ~, -· "ll\
North Carolina Department of Environment & Natural Resources (NCDENR\ \ \\ ~
2728 Capital Boulevard ',', \ \ · DEC 1 7 2001 \ 1 •
Raleigh, North Carolina _ 27604 ,., , .. L __________ J
1 ::~~~ .. ,.:··,: ~·:· r· ·1 \ON
. ~~·~.).:.' .• ~:-~~:.~ .. ~·-~·:_~~--:::~-~-,J Dear Mr. Pritz!:
Reactive Material Pilot Study
--7 __ .......JT"'a"'d""co,,-"'-H.,_u,,_i;~hceee;s,__,S,,,u"lp,c,ee,r,cfun""-"d"---"'S,.,it"'e'-'. G"""ase.,te,o,.,nc.,C,,,o,,.,un"'-"ty=, .,,;N,.,o,.r_,,th"--'=C"'a""ro"'l"'in=a
Re:
()n behalf of the Jadco--Hughes Steering Committee, Conestoga-Rovers & Associates (CRA) is
proposing to perform a Pilot Study at the Jadco-Hughes Superfund Site in Gaston County,
North Carolina to determine if reactive materials can be injected into the groundwater in order
to facilitate remediation at the Site. Randy McElveen of NCDENR has spoken to you about the
Pilot Study in the past two weeks.
The Pilot Study is being performed under a United States Environmental Protection Agency
(USEPA) Unilateral Administrative Order (UAO) at a Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) Site. A formal permit from NCDENR is not
required for the following reasons:
• the work is being performed entirely on-Site pursuant to Section XVI of the UAO;
• only 250--gallons of fluids containing reactive material will be injected into the well as a
"one-shot" injection. This small volume means that only the groundwater within 10 to
20 feet of the injection well will be affected by the injection;
• no process control equipment will be employed. It is anticipated at this time that only
one injection will occur, however, changes to the Pilot Study may need to be made in the
field as the study progresses depending on the conditions encountered during the study;
and ·
• it is not intended at this point that the test injection well become a permanent
component of any large-scale injection of reactive materials.
Although a formal permit from NCDENR is not required, the Steering Committee wishes to
ensure that the substantive requirements of the permitting process are met so that UICP is
aware of the Pilot Study. The following items will provide the necessary information for UICP
to review the Pilot Study proposal: ·
AIIIIIUID lf•PUI
ISO 9001
Worldwide Enginoarlng, Environmental, Con■tructlon, and IT Sorvlco
CONESTOGA-ROVERS
& ASSOCIATES
December 10, 2001
• •
Reference No. 3669
-2-
· ·--1-. --· Attachment A-"Proposal for Pilot Study;InjectioiYof-Reactive Materials", dated
November 12, 2001. This letter provides the Scope of Work and schedule for the
proposed Pilot Study. The letter includes information on how the proposed reactive
material (ethyl lactate) functions, provides the location and details of the proposed Pilot
Study area configuration and injection method, and describes the groundwater sampling
program that will be implemented to monitor the progress of the Pilot Study;
2. Attachment B -Provides product information for the ethyl lactate reactive material as
required by the permitting process; and
3. Attachment C -Provides geologic and well construction information for the Pilot Study
area, which is expected to be limited to an area within 10 to 20 feet of the injection well.
The stratigraphic log provides geologic information for monitoring well MW-6S, which
will be the central well location for the 10-foot transect of three wells, including the
injection well. The construction details of the injection well will be similar to MW-6S,
except that 4-inch diameter well·screen and riser will be used. The screened interval for
the injection well will be identical to that of MW-6S.
The Steering Committee wishes to proceed with the Pilot Study as soon as possible. We
respectfully request that you provide us with verbal authorization to proceed with the Pilot
Study as soon as you are able.
Should you have any questions or comments on the above, please do not hesitate to contact us.
Yours truly,
CONESTOGA-ROVERS & ASSOCIATES
--ek~
Rob S. Hoag, M.Sc., P.Eng., P.E.
RH/ca/1
Encl.
c.c. Michael Townsend, USEPA
Reuben Bussey, USEPA
Jadco-Hughes Technical Committee
Jimmy Kirkland, King & Spalding
Randy McElveen, NCDENR
Steve Quigley, CRA
John Uteck, CRA
• •
A TI ACHMENf A
PROPOSAL TO USEPA FOR PILOT STUDY
CRA 3669Prit-1-1T'
• •
~-------------------,, 651 Colby Drive, Waterloo. Ontario. Canada N2V 1C2
Telephone: 519·884·0510 Facsimile: 519·884:0525
CONESTOGA-ROVERS I CAA Id & ASSOCIATES www. wor .com
November 12, 2001 ·
Mr. Michael Townsend
United States Environmental Protection Agency (USEPA)
Region IV
Atlanta Federal Center
100 Alabama Street SW
11th Floor
Atlanta, Georgia 30303
Dear Mr. Townsend:
Re: Proposal for Pilot Study
Injection of Reactive Materials
Jadco-Hughes Superfund Site (Site)
Remedial Design/Remedial Action (RD/RA)
1.0 . INTRODUCTION
Reference No. 3669
This letter proposes a pilot study for the potential use of an innovative technology at the Site.
As discussed with you during telephone conversations on May 1 and June 21, 2001, the Steering
Committee has evaluated the performance of the remedial systems that have been operating _at
· the Site. Based on.this evaluation, the Steering Committee believes that recent advances in site
remediation that did not exist or were unproven when the Feasibility Study (FS) was completed
in 1990 may shorten the timeframe for remediation. These new remedial technologies could
potentially be used to augment the existing remedial technologies at the Site (natural soil
flushing and groundwater extraction).
Based on a review of the available technologies, the Steering Committee believes the injection of
reactive agents could significantly accelerate the remediation of the Site. The reactive agents
will accelerate the natural biodegradation process by supplying oxygen and/ or nutrients to the
microorganisms that feed on the chemicals of concern at the Site. The reactive agents
considered by the Steering Committee are Hydrogen-Releasing Compound (HRC),
Oxygen-Releasing Compound (ORC), nitrate, molasses, ethyl lactate, and potassium
permanganate. The reactive materials can be tailored to suit the specific chemicals of concern.
The pilot study will be used to determine if reactive materials are suitable for the Site. The pilot
study will also assist in the selection of the most appropriate reactive material. The purpose of
this letter is to describe the pilot study methodology. The well installation and groundwater
•u111un c1■ ,111
ISO 9001 , .. ,.,, ........ Q.
CONESTOGA-ROVERS
&ASSOCIATES
November 12, 2001 2. Reference No. 3669
sampling activities will be performed in accordance with the USEPA~approved Health and
Safety Plan (HASP), dated January 1994, and the Sampling and Analysis Plan (SAP) and the
Quality Assurance Project Plan (QAPP) contained in the Remediation Goal Verification Plan,
dated January 1994.
2.0 INSTALLATION OF INJECTION AND MONITORING WELLS
The pilot study will be performed in the vicinity of monitoring well MW-6S. · Thislocation was
selected due to the high concentrations of dichloroethene and dichloroethane isomers as shown
in Table 1. The monitoring network for the pilot study will consist of one new injection well
and two downgradient monitoring wells (one new and one existing) at the locations shown on .
Figure 1. The wells will be spaced approximately S feet apart in order to ob.serve the effects of
the reactive agents in a relatively short timeframe. Existing well MW-GS.will be used as the_
middle well since several rounds of groundwater samples have been collected from this well.
The other monitoring well will be installed 5 feet downgradient of MW-6S.
The new monitoring well will be installed using 4¼-inch inside diameter (ID) hollow-stem
augers (HSA). The new monitoring well will be installed to a depth of 20 feet below ground
surface and screened from approximately 9.5 to 19.5 feet bgs to match the screened interval at
MW-6S. The monitoring well will be constructed from 2-inch diameter PVC riser pipe and
2-inch diameter slot-10 PVC screen.
The injection well will be installed using 8-½ ID HSA. The well will be constructed from 4-inch
diameter PVC riser pipe and 4-inch diameter slot-10 PVC screen. The injection well will be
installed to a depth of 20 feet below ground surface and screened from approximately 9.5 to
19.5 feet bgs to match the screened interval of the monitoring wells.
The wells will be developed following installation using a submersible pump. A total of five
well volumes will be purged from each well. Field measurements of turbidity, conductivity,
pH, and temperature will be collected after each well volume is removed.
3.0 BASELINE GROUNDWATER QUALITY SAMPLING
Prior to injection of the reactive material, baseline groundwater quality samples will be
collected from the injection well and the downgradient monitoring wells. The baseline
groundwater quality data will be used to evaluate the effect of the injection of reactive materials
on the chemicals that are present in the Site groundwater. The wells will be purged prior to
sampling using a peristaltic or submersible pump. A minimum of three well volumes will be
CONESTOGA-ROVERS
&ASSOCIATES
November 12, 2001
• •
Reference No. 3669
purged from the wells prior to sample collection. Field measurements of turbidity,
conductivity, pH, temperature, and dissolved oxygen will be collected after each well voiume.
The samples will be collected after these field-measured parameters stabilize, consistent with
the procedures used in the Remedial Investigations and Remedial Action-activities that were
performed at the Site. ·
Groundwater samples will be collected using a new disposable Teflon bailer at each well, except
for the filtered ( dissolved) parameters, which will be collected using a submersible pump and
inline flow filters; The groundwater quality samples will be analyzed for volatile organic
compounds (VOCs), semi-volatile organic compounds (SVOCs), pH, PO, redox potential,
dissolved iron·and manganese, chloride ion concentration, TOC), ethene, ethane, and methane.
· Groundwater quality samples will be shipped in iced coolers under chain-of-custody to
Analytical Services Inc. (AS!) in Norcross, Georgia. ·
4.0 INJECTION OF REACTIVE MATERIAL
The analytical data for MW-6S from the December 2000 groundwater quality monitoring event
are provided in Table 1, Based on the chemicals present and their associated concentrations,
CRA determined that ethyl lactate is the most appropriate reactive material to test in the pilot
study. Ethyl lactate creates a reducing environment that results in the destruction of
chlorinated compounds by several methods. Ethyl lactate is· readily biodegradable and can be
used as a source of carbon and energy to enhance microbial activities. It also acts as an oxygen
scavenger to enhance anaerobic microbial activity and the initiation of reductive dechlorination.
· Ethyl lactate is hydrolyzed by soil microbial enzymes to produce ethanol and lactic acid, which
are then fermentatively metabolized through multiple steps to form carbon dioxide, water, and
molecular hydrogen. The molecular hydrogen enhances the reductive dechlorination of ·
chlorinated compounds such as the dichloroethene and dichloroethane isomers that are present
in the Site groundwater to non-toxic compounds such as ethene. Since ethyl lactate is an
oxygen scavenger, the degradation of BTEX compounds is impeded, however, these
compounds are generally either not present or are present at comparatively low concentrations
in the Site groundwater.
Ethyl lactate is well suited to the Site conditions and possible large-scale application. Ethyl
lactate is easy to mix and the solution can be readily prepared in and gravity-injected from a
truck-mounted tank. Ethyl lactate will also be more mobile within the formation. Ethyl lactate
will deplete more rapidly than HRC and may require a greater number of applications, but
ethyl lactate is significantly more cost-effective.
CONESTOGA-ROVERS
& ASSOCIATES
November 12, 2001 4
•
Reference No. 3669
The target.concentration for the ethyl lactate will be approximately 3 to 5 percent in potable
water. In order to treat the pore water within the 10-foot deep by 10-foot radius test zone, the
injection will consist of 100 pounds of ethyl lactate mixed with 250 gallons of water. The ethyl
lactate solution will be mixed in a truck-mounted polyethylene tank and injected using the
following method:
1. Approximately 100 pounds of ethyl lactate will be poured into the tank;
2. Approximately 250 gallons of water from a high pressure hose will be used to dissolve
and.mix the solution; ·
3. A short length of 2-inch diameter hose will be !owe.red into· the injection well .. A PVC.
ball valve will be installed at the base-of the tank to regulate the flow rate of the solution
into the injection well; and
4. The level of the solution will be raised to within 1 foot of the top of the riser. The time
required to drain the polyethylene tank will be recorded so that the average injection
rate can be determined.
Following injection of the solution, 250 gallons of potable w~ter will be injected using the
method described above in order to force the ethyl lactate solution into the formation and
prevent fouling of the injection well.
5.0 ADDITIONAL GROUNDWATER QUALITY SAMPLING
Groundwater quality samples will be collected from the injection well and two downgradient
wells at the following intervals:
1. One week following injection;
2. Two weeks following injection;
• 3. Four weeks following injection; and
4. Eight weeks following injection.
The groundwater quality samples will be collected using the method described in Section 3.0.
The groundwater quality samples will be analyzed for pH, DO, redox potential, chloride ion,
TOC, VOCs, SVOCs, and dissolved iron and manganese, ethene, ethane and methane. Normal
tum-around-times will be requested for all samples.
CONESTOGA-ROVERS
& ASSOCIATES
November 12, 2001
6.0 REPORTING
•
5 Reference No. 3669
Following completion of the pilot study, the Steering Committee will prepare a letter report for
submission to USEP A and North Carolina Department of Environment and Natural Resources
(NCDENR). The letter report will describe the installation of the injection and monitoring-
wells, the injection of the ethyl lactate solution, and the results of the groundwater quality
-sampling events. The analytical data collected in conjunction with the pilot study will be
submitted to USEP A and NCDENR. The letter report will summarize the findings of the pilot
study and provide conclusions for the large-scale use of reactive materials at the Site.
7.0 SCHEDULE
Following approval to proceed from USEPA and NCDENR, the Steering Committee.will
proceed with the pilot study. The Steering Committee respectfully requests to commence the -
pilot study 3 weeks following your approval of this proposal A permit from NCDENR is not
required to perform the pilot study since it is being performed under a USEPA Unilateral
Administrative Order (UAO) at a Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) Site. The work is being conducted entirely on the Site, so pursuant to
Section XVI of the UAO, a permit is not required. CRA will ensure that the substantive
requirements of the NCDENR permitting process are met prior to starting the pilot study,
including submission of this work plan, the layout of the test area, the well construction details,
and a description of the reactive material to be used. The schedule will be as follows:
1. Week 1 install and develop injection and monitoring well;
-baseline groundwater quality sampling;
-inject ethyl lactate solution;
2. Week2 -first round of post-injection groundwater quality sampling;
3. Week3 -second round of post-injection groundwater quality sampling;
4. WeekS -third round of post-injection groundwater quality sampling;
5. Week9 -fourth round of post-injection groundwater quality sampling; and
6. Week 12 -submission of pilot study report and recommendations.
Changes to the pilot study may need to be made in the field as the study progresses depending
on the conditions encountered during the study.
CONESTOGA-ROVERS
& ASSOCIATES
November 12, 2001 6
•
Reference No. 3669
If you have any questions, please do not hesitate to contact me. We respectfully request that
you approve of this pilot study work plan in writing.
Yours truly,
CONESTOGA-ROVERS & ASSOCIATES.
4vb---
§cstephe~~: ;;,i~ ·
RH/jdh/123
· c.c.. Reuben Bussey, USEP A Region IV
Randy McElveen, NCDENR
Jimmy Kirkland, King & Spalding
Jadco-Hughes Steering Committee
· Rob Hoag, CRA (Waterloo)
John Uteck, CRA (Charlotte)
LEGEND
---·---PROPERTY LINE
-· ··~ ----· -· -· PROPOSED HOOK-OP TO SEWER ··---··· -----·---PERJMETERCOL.L.ECTIONDRAIN
,. . ..,, PUMP WEll
OMH MANHOLE
■-PUMPCHNr.lBER
aa1• STREAM MONITORING LOCATION
,
i
0315811-00(TOWN12l)GN-WA001 NOV 091'2001
. '""
SHAU.OW MONITORING WELL LOCATION
SIWJ..OW~LOCATION
PROPOSED INJECTION WB.L LOCATION
PROPOSED MONITORING WELL I.OCAllON
SCALE! ......
.. 100ft
figure 1
INJECTION AND MONITORING WELL LOCATIONS
PILOT STUDY
JADCO-HUGHES SITE
Gaston County, NC
•
•
• •
ATTACHMENTB
ETHYL LACTATE PRODUCT INFORMATION
CRA 3669Prit•l-1P
•
Brenntag Canada Inc. B REN NT AG -+¥illiiWi,
St:innes Logistics 1m}tt@
MATERIAL SAFETY-DATA SHEET
ETHYL LACTATE, LIQUID
1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION
WHMIS Number: 00064332
Index: HCI3189/01 A
Brenntag Canada Inc.
43 Jutland. Road.
Etobicoke, Ontario
M8Z .2G6
[phone]
Effective Date: 2001 F°ebruary 23
Date of Revision: 2001 February 23
EMERGENCY TELEPHONE NUMBERS
Toronto, ON [phone]
Edmonton, AB [phone]
PRODUCT IDENTIFICATION
Montreal·, QC .[phone]
Calgary, AB [phone]
Product Name: Ethyl Lactate, Liquid.
Chemical Nrune: Propionic Acid, 2-hydroxy-, ethyl ester.
Winnipeg, MB
Vancouver, BC
[phone].
[phone]
Synonyms: Lactic Acid, Ethyl Ester; 2-Hydroxypropanoic Acid, Ethyl Ester; Actylol;
Solactol.
Chemical Family: Oxygenated Aliphatic Hydrocarbon.
Molecular Formula: CSH1003.
Product Use: Industrial solvent, cleaner, degreaser.
CAS J, 97-64-3.
WliMIS Classification / ·symbol: B-3: Combustible Liquid, D-2B: Toxic (Skin and Eye
Irritant).
RE!U) THE ENTIRE MSDS FOR THE COMPLETE HAZARD EVALUATION OF THIS PRODUCT.
2. HAZARDS IDENTIFICATION
EMERGENCY OVERVIEW: Causes skin and eye irritation. Vapours are irritating to eyes and
respiratory tract. High vapour concentrations may cause drowsiness. May cause central
nervous system (CNS) depression. Combustible liquid and vapour. May cause flash fire or
explosion. Can· decompose at high temperatures forming toxic gases. Contents may develop
pressure on prolonged exposure to heat.
POTENTIAL HEALTH EFFECTS
Inhalation: Product is irritating to the nose, throat and respiratory tract.
Skin Contact: Skin contact can cause irritation, especially under the finger nails (and
other confined spaces such as Under rings or watch bands). May cause defatting, drying and
cracking of the Skin. Prolonged ~nd rePe_ated contact may lead to dermatitis.
Skin Absorption: May be absorbed through intact skin. See· "Other Health Effects" Section.
Eye Contact: Vapours from this product are irritating to the eyes. This product causes
irritation, redness and pain.
Ingestion: This product causes irritation, a burning sensation of the mouth and throat and
Ethyl Lactate, Liquid.
WHMIS Number, 00064332
abdominal pain. See "Other Health Effects• .Section.
• Brenntag Canada Inc.
Date of Revision: 2001 February 23
Page 2
Other Health Effects: Effects (irritancy) an the skin and eyes may be delayed, and damage may
occur without the sensation or onset of pain·. Strict adherence to first aid measures
following any exposure is essential. This product may cause central nervous system (CNS)
depression. CNS depression is characterized by headache, diziiness, drowsiness, nausea,
vomiting and incoordination. Severe overexposures may lead to coma and possible death due'
to respirat?ry failure.
3. COMPOSITION, INFORMATION ON INGREDIENTS
_Hazardous Ingredients
Ethyl Lactate
4. FIRST AID MEASURES
FIRST AID PROCEDURES_
CAS No.
000097-64-3
ACGIH TLV
Not Listed. 100
Inhalation: Move Victim-to fresh air. Give artificial respiration ONLY. if breathing has
stopped. Give cardiopulmonary resuscitation (CPR) if there is.no breathing AND no pulse.
Obtain medical attention IMMEDIATELY. .
Skin Contact: Start flushing while removing contaminated clothing. Wash affected areas
thoroughly with soap and water. If irritation, redness, or a burning.sensation develops
and persists, obtain me?ical advice.
Eye Contact: Immediately flush
eyelids open during flUshing.
attention IMMEDIATELY ..
eyes with running water for a minimum of 20 minutes. Hold
If.irritation persists, repeat flushing. Obtain medical
Ingestion: Do not attempt to give anything by mouth to an unconscious person. If victim is
alert and not convulsing; rinse mouth out and give 1/2 to 1 glass of water to dilute
material. IMMEDIATELY contact local Poison Control Centre. Vomiting should only be
induced under the direction of a physician or a poison control centre. If spontaneous
vomiting occurs, have victim lean forward with head down to avoid breathing in of vomitus,
rinse mouth and administer more water. IMMEDIATELY transport victim to an emergency
facility.
Note to Physicians: This product contains materials that may cause severe pneumonitis if
aspirated. If ingestion has occurred less than 2 hours· earlier, carry out careful gastric
lavage; use endotracheal cuff if available, to prevent aspiration. Observe patient for
respiratory difficulty from aspiration pti'ewnonitis. Give artificial resuscitation and
appropriate chemotherapy if respiration is depressed.
Medical conditions that may be aggravated by exposure to this product include neurological,
cardiovascular and skin diSorders, diseases of the skin, eyes or respiratory tract.
5. FIRE FIGHTING MEASURES
FLAMMABLE PROPERTIES
Flammability Class (WHMIS): B-3: Combustible
Flash Point (TCC, Deg. Celsius): 47. (3)
Autoignition Temperature (Deg. Celsius): 400.
Flammability Limits in Air (%): LEL: 1.55.
Liquid.
(4)
(3) UEL, 11. 4. (4)
Hazardous Combustion Products: Thermal decomposition products are toxic and may include
oxides of carbon.
Unusual Fire or Explosion Hazards: Vapours from this product are heavier than air, and may
"travel• to a source of ignition (eg. pilot lights, heaterS, electric motors) some distance
away, and then "flash back~ to the point of product discharge causing an explosion and
fire. Closed containers exposed to heat may explode. Rags.and other materials containing
• Ethyl Lactate, Liquid
WHMIS Number: 00064332
this product may heat and spontaneously_ ignite if
similar material in metal cans with tight'fitting
and contact surfaces to.become slippery.
• Brenntag Canada Inc.
Date of Revision: 2001 February 23
Page 3
exposed to air. Store wiping rags and
lids. Spilled material may cause floOrs
Sensitivity to Mechanical Impact: Not available. Not expected to be sensitive to mechanical
impact.
Rate of Burning: Not available.
Explosive Power: Not available.
_______ sensitivity to Static Di"scharge: Not available.-Expected to be sensitive to static
discharge when vapours are present between the lower and upper explosive limits.
EXTINGUISHING MEDIA
Fire Extinguishing Media: Alcohol resistant foam. Dry Chemical, Carbon dioxide or water
spray.
"FIRE FIG~TING INSTRUCTIONS
Instructions to the Fire Fighters: Use water spray to cool fire-exPosed containers· or
structures. Use water spray t9 ·disperse vapours; ·re-ignition is possible. Spilled
mate~ial may cause floors and contact surfaces_to become slippery.
Fire Fighting Protective Equipment: Use s·elf-conta.ined brea~hing apparatus and protective
clothing.
6. ACCIDENTAL RELEASE MEASURES
Information in· this section is for respondi_ng to spills, leaks or releases
or minimize the adverse effects on persons, property and the environment.
specific reporting requirements associated with spills, leaks or releases,
region to region.
in order to prevent
There may be
which change from
Containment and Clean-Up Procedures: In all cases of leak·or spill contact vendor at
Emergency Number shown on the front page of this MSDS. Wear protective clothing. Do not
use combustible·materials such as sawdust as an absorbent. Eliminate all sources of
ignition. Collect product for recovery· or disposal. For release to land, or storm water
runoff, ·contain discharge by constructing dykes or applying inert absorbent; for release
to water, utilize damming and/or water diversion to minimize the spread of contamination.
Ventilate enclosed spaces. Notify applicable goverrunent.authority if release is reportable·
or could adversely affect the environment. ·
7. HANDLING AND STORAGE
HANDLING
Handling Practices: Ground and bond equipment and containers to prevent a static charge
buildup. Use spark-resistant tools and avoid ftsplash-filling" of containers. Use normal
"good" industrial hygiene and housekeeping practices. Containers which have been exposed
to heat may be under internal pressure. These should be cooled and carefully vented before
opening. A f~ce shield and apron should be worn. Enforce NO SMOKING rules in area of use.
Ventilation Requirements:
respiratory.protection.
Do not use in poorly ventilated or confined areas without proper .
Ventilation should be explosion proof.
Other Pre·cautions: Use only with adequate ventilation and avoid breathing vapours or mists.
Avoid contact with eyes, skin or ·clothing. Wash thoroughly with soap and water after
handling. Wash contaminated clothing thoroughly before re-use. Do not use cutting or
welding torches on empty drums that contained this material/product.
Clothing and footwear that dissipates static electrical charges should be worn when
handling flammable materials. Natural fibers (cotton, wool-, leather and linen) should be
selected in favour of synthetic materials (rayon, nylon and polyester}.
STORAGE
Storage Temperature (Deg Celsius}: See below.
Ethyl Lactate, Liquid
WHMIS Number: 00064332
• Brenntag Canada Inc.
Date of Revision: 2001 February 23
Page 4
Ventilation Requirements: Ventilation should be explosion proof.
Storage Requirements: Store in a cool,
and flames. Keep containers closed.
40 Deg, Celsius. Protect from direct
well-ventilated area. Keep away from heat, sparks
Do not expose s_ealed containers to temperatures above
sunligh~.· Protect against physical damage.
Special Materials ta be Used for Packaging or Containers: Confirm suitability of any
material before using.
8. EXPOSURE CONTROLS/ PERSONAL PROTECTION
Recommendations listed in this section indicate the type of equipment which will provide
protection against overexposure to this product. Conditions of use, adequacy of engineering or
other control .measures, and actual exposures will dictate the need for specific protective
devices at your workplace.
ENGINEERING CONTROLS
Engineering Controls: Local exhaust ventilation required. Ventilation should be explosion
proof. Make up air should-be supplied to balance air that is removed by local or general
exhaust ventilation. Ventilate low lying areas such as sumps or pits where dense vapours
may collect.
For personnel· entry into confined spaces (i.e. bulk storage tanks) a proper procedure must
be followed. It must include consideration of, among other things, ventilation, testing of
tank atmosphere, provision and maintenance of SCBA, a~d emergency rescue.
PERSONAL PROTECTIVE EQUIPMENT (PPE)
Eye Protection: Safety glasses with side shields are recommended to prevent eye contact.
Use full face-shield or chemical safety goggles when-there iS potential for contact.
Contact lenses should not be worn when working with this material:
Skin Protection: Gloves and protective clothing made from rubber, neoprene or viton should
·be impervious under conditions of use. Discard contaminated gloves. Prior .to use, user
should confirm impermeability.
Contact with skin, eyes and mucous membranes can contribute to the overall exposure and may
invalidate the TLV. Consider measures to prevent absorption by these routes.
Respiratory Protection: No specific guidelines available. Do not use compressed oxygen in
hydrocarbon atmospheres. A NIOSH/MSHA-approved air-purifying respirator ·equipped with
organic vapour cartridges for concentrations up to 1,000 ppm organic vapours.. An
air-supplied respirator if concentrations are highef or unknown.
Other Personal Protective Equipment: Wear an impermeable apron and boots. Locate safety
shower and eyewash station close to chemical handling area. Take all precautions to _avoid
personal contact.
Clothing and footwear that is fire retardant and dissipates static electrical charges
should be worn when handling flammable materials. Natural fibers (cotton, wool-, leather
and linen) should be selected in favour of synthetic materials (rayon, nylon and
polyester).
EXPOSURE GUIDELINES
Recommended Exposure Limit: I None established for this product.
9. PHYSICAL AND CHEMICAL PROPERTIES
Physical State: Liquid.
Appearance and _Odour: Clear, colourless liquid. Mild odour.
Odour Threshold {ppm): Not available.
Boiling Range (Deg Celsius): 154.
Melting/Freezing Point (Deg Celsius): -25.
Vapour Pressure (mm Hg at 20 Deg. Celsius): Not available.
Ethyl Lactate, Liquid
WHMIS Number: 00064332
Vapour Density (Air= 1.0): 4.07.
Relative Density (gm/cc, Water= 1.0): 1.02 to 1.04.
Bulk Density: 1,020 to 1,040 Kg/M3.
Viscosity: 2.61 cP (20 Degrees Celsius).
Evaporation Rate (Butyl Acetate = 1.. 0): Not available.
Solubility: Soluble in water.
% Volatile by Volume: 100.
pH: Not available.
• Brerultag Canada Inc.
Date of Revision: 2001 February 23
Page 5
___ C_o_e_ffi_c_i_e_!!_t_of Water /Oil Distribution: Not available.
Volatile Organic Compounds {VOC): Not available:==~----
10. STABILITY AND REACTIVITY
CHEMICAL STABILITY
Under Normal ·Conditions: Stable.
Under Fiie Conditions: Flammable.
Hazardous Polymerization: Will not occur.
Conditions to Avoid: High temperatures, sparks, open flames and all other sources.of
ignition.
Materials to Avoid: Strong oxidizers. Lewis or mineral acids. Strong Acids.
Decomposition or Combustion Products: Thermal decomposition products are toxic and may
include oxides of carbon.
11. TOXICOLOGICAL INFORMATION
Toxicol~gical Data:
~thyl Lactate LOSO (Oral, Rat)
LOSO (Dermal, Rabbit)
Above· S,000 mg/Kg (1)
Above 5,000 mg/Kg (1)
Carcinogenicity Data: The ingredient{s) of this product is (are) not classed as carcinogenic
by ACGIH, IARC ,· OSHA or NTP.
Reproductive Data: No adverse reproductive effects are anticipated.
Mutagenicity.Data: No adverse mutagenic effects are anticipated.
Teratogenicity Data: No advers·e teratogenic effects are anticipated.
Respirator·y / Skin Sensitization Data: None known ..
Synergistic Materials: None known.
Other Studies Relevant to Material: None known.
·12. ECOLOGICAL INFORMATION
Ecotoxicity: Harmful to aquatic. life at low concentrations.·
Ethyl Lactate: Fish toxicity: 96-hour TLm =· 100 to 1,000 ppm. (3)
Environmental Fate: Not available. May be hazardous if allowed to enter drinking wat'er
intakes. Do not contaminate domestic or irrigation water supplies, lakes, ~treams, ponds,
or rivers.
13. DISPOSAL CONSIDERATIONS
Deacti vatin.g Chemicals: None required.
Waste Disposai Methods: This information applies to the material as manufactured. Dispose
of waste material at an approved {hazardous) waste treatment/disposal facility in
accordance with applicable local, provincial and federal regulations. oo·not dispose of
.waste with normal garbage, or to sewer systems. Reevaluation of the product may be
required by the user at the time of disposal since the product uses, transformations,
• Ethyl Lactate, Liquid Brenntag Canada Inc.
WHMIS Nurober: 00064332 Date of Revision: 2001 February 23
Page 6
mixtures and processes may influence waste classification.
Safe Hand~ing of Residues: Empty containers retain product residue and can be hazardous.
Disposal of Packaging:· Empty containers retain product
expose s·uch containers to heat, flame, sparks, static
ignition; they may explode and cause injury or death.
the product.
14. TRANSPORTATION INFORMATION
CANADIAN TOG ACT SHIPPING DESCRIPTION:
Ethyl Lactate,.Class 3, UN1192, Pk Gp III ..
Label(s)/Placard(s): Flammable Liquid.
residue and can be hazardous. Do not
electricity, or other sources of
Treat package in the same ma~ner as
Regulated Limit {9.2): Not applicable. Exemptions: This product not· regulated in container
size less than ·454 L.
U.S. DOT CLASSIFICATION:
Ethyl Lactate, Class 3, UN1192, Pk Gp III.
Label(s)/Placard(s): Flammable Liquid.
Reportable Quantity (CERCLA-RQ): Not available. Exemptio.ns: This product not regulated in
container size less than 454 L.
15. REGULATORY INFORMATION
CANADA
CEPA -NSNR: This material.is included on the DSL under the CEPA.
CEPA -NPRI: Not included.
Controlled Products Regulations Classification (WHMIS): B-3:, Combustible Liquid, D-28:
Toxic (Skin and Eye Ir~itant).
USA
Environmental Protection Act: This material is included·on the TSCA Inventory.
OSHA Hazard Communication (29CFR 19!°0.1200) Classification: Combustible Liquid, Skin and Eye
Irritant.
NFPA: 2 Health, 2 Fire, 0 Reactivity. (3_)
INTERNATIONAL: The following component or components of this product appear on the Europea_n
Invelltory of Existing Commercial Chemical Substances: Ethyl Lacta_te.
16. OTHER INFORMATION
ADDITIONAL INFORMATION AND SOURCES USED
1. RTECS-Registry of Toxic Effects of Chemical Substances, Canadian Centre for Occupational
Health and Safety RTECS database.
2. Clayton, G.D. and Clayton, F.E., Eds., Patty's Industrial Hygiene and Toxicology, 3rd ed.,
Vol. IIA,B,C, John Wiley and Sons, New York, 1981.
3. Supplier's Material Safety Data Sheet(s).
·4. "CHEMINFO", through •ccINFOdisc•, Canadian Centre for Occupational Health-and Safety,
Hamilton, Ontario, Canada.
5. Guide to Occupational Exposure Values, 1999, American Conference of Governmental
I_ndustrial Hygienists, Cincinnati, 1999.
The information contained herein is offered only as a guide to the handling of this specific
material and has been prepared in good faith by technically knowledgeable personnel. It is not
intended to be all-inclusive and the manner and conditions of use and handling may involve
other and additional considerations. No warranty of any kind is given or implied and Brenntag
Canada Inc. will not be liable for any damages, losses, injuries or consequential damages which
may result from the use of or reliance-on any information contained heiein. This Material
Safety Data Sheet is valid for three years.
Ethyl Lactate, Liquid
WHMIS Nwnberc 00064332
• Brenntag Canada Inc.
Date of Revision: 2001 February 23
Page 7
To obtain revised copies of this or other Material Safety Data Sheets, contact your nearest
Brenntag Canada Inc. ~egional office.
British Columbia: 20333-1028 Avenue, Langley, BC', VlM 3Hl
Phone: [phone] Facsimile: [phone]
Alberta: 6628 -45 th. Street, Leduc, AB, T9E 7C9
Phone: [phone] Facsimile: [phone]
Manitoba: 681 Plinquet Street, Winnipeg, MB, R2J 2X2
Phone: [phone] Facsimile: (204) 233~7005
Ontario: 43 Jutland Road, Etobicoke, ON, MBZ 2G6
Phone: [phone] Facsimile:· [phone]
QuebeC: 2900 Jean Baptiste Des., Lachine, PQ, HST lCB
Phone: [phone] Facsimile: [phone]
Atlantic: A-105 AkerleY Boulevard, Dartmouth, NS, ·BJB 1R7
Phone: [phone] Facsimile: [phone]
Prepared By: Regulatory Affairs Group, Brenntag Canada Inc .. , [phone].
•
ATTACHMENT C
STRATIGRAPHIC AND WELL COMPLETION DETAILS
CRA J6691'rit-l-TI'
•
STRATIGRAPlilC AND INSTRUMENTATION LOG
(OVERBURDEN)
. CL-ID)
PROJECT NAME: JADCO-HUGHES
PROJECT NO.: 2427
CLIENT:
LOCATION:
JADCO-HUGHES STEERING COMMITTEE
BELMONT, NORTH CAROLINA
OEPlH STRATIGRAPHIC DESCRIPTION c!c REMARKS
ft BGS
REFERENCE POINT (Top Of Casing)· GROUND SURFACE
(SC) SAND, .medium grained, clayey, some silt, _ blue-gray· ,
~ 4.0
-8.0
-12.0
~ 16.0
(ML-SM) SILT, some sond, little clay, blue-grai to red-brown
SAPROU TE. extreme! y weathered dlorite. red-brawn .
No recovery . . Same, except saturated
Some, except white and brown
~ 20.0 END OF HOLE O 19.0 FT. BGS
-24.0
-28.0
-32.0
~ 36,0
-40.0
-44.0
>-48.0
-52.0
NOTES: 1. MW6S and MWBD .are nested wells and stratigraphy Is based an MWBO. 2. No HNu readings above background.
cl.EVATiot
ft AMSL
661:l;.J
659.76
640.B
HOLE DESIGNATION: MW6S
' DA TE COMPLETED: NOVEMBER ·19. 1988
DRIWNG METHOD: HSA
CRA SUPERVISOR: B. SANDBERG
· MONITOR
INSTALLATION
SCREEN DETAILS:
Screened lntenial:
651.76' to 64-1.76' AMSL
Length -10• ·
Diameter -2•
Slot # 10
Material -Stainless Steel
Sand pack Interval:
655. 76' to 640. 76' AMS
Material -55mm
SAMPLE
N· s u T ... A B T . E E
D
1SS
2SS
JSS
455
55S
6SS
7SS >< -ass )< --9SS >< -10SS iC>
·u
A L u E
JS
20
5
J
7
9
8
12
5
NOTES: MEASURING POINT ELEVATIONS MAY CHANGE; REFER TO CURRENT ELEVATION TABLE
GRAIN SIZE ANALYSIS O WATER FOUND SZ . STATIC WATER LEVEL I (12/16/B8)
•
~------------------~I 651 Colby Drive, Waterloo, Ontario, Canada N2V 1C2
Telephone: 519·884·051 0 Facsimile: 519·884-0525
CONESTOGA-ROVERS I www.CRAworld.com & ASSOCIATES
November 12, 2001
Mr. Michael Townsend
United States Environmental Protection Agency (USEPA)
Region IV
Atlanta Federal Center
100 Alabama Street SW
11th Floor
Atlanta, Georgia 30303
Dear Mr. Townsend:
Re:
1.0
Proposal for Pilot Study
Injection of Reactive Materials
Jadco-Hughes Superfund Site (Site)
Remedial Desii;n/Remedial Action (RD/RA)
INTRODUCTION
Reference No. 3669
This letter proposes a pilot study for the potential use of an innovative technology at the Site.
As discussed with you during telephone conversations on May 1 and June 21, 2001, _the Steering
Committee has evaluated the performance of the remedial systems that have been operating at
the Site. Based on this evaluation, the Steering Committee believes that recent advances in site
remediation that did not exist or were unproven when the Feasibility Study (FS) was completed
in 1990 may shorten the timeframe for remediation. These new remedial technologies could
potentially be used to augment the existing remedial technologies at the Site (natural soil
flushing and groundwater extraction). ·
Based on a review of the available technologies, the Steering Committee believes the injection of
reactive agents could•significantly accelerate the remediation of the Site. The reactive agents
will accelerate the natural biodegradation process by supplying oxygen and/ or nutrienls to the
microorganisms that feed on the chemicals of concern at the Site. The reactive agents
considered by the St~-ering Committee are Hydrogen-Releasing Compound (HRC),
Oxygen-Releasing Compound (ORC), nitrate, molasses, ethyl lactate, and potassium
permanganate. The reactive materials _can be tailored to suit the specific chemicals of concern.
The pilot study will be used to determine if reactive materials are suitable for the Site. The pilot
study will also assist in the selection of the most appropriate reactive material. The purpose of
this letter is to describe the pilot study methodology. The well installation and groundwater
ISO 9001
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CONESTOGA-ROVERS
& ASSOCIATES
November 12, 2001 2
•
Reference No. 3669
sampling activities will be performed in accordance with the USEPA-approved Health and
Safety Plan (HASP), dated January 1994, and the Sampling and Analysis Plan (SAP) and the
Quality Assurance Project Plan (QAPP) contained in the Remediation Goal Verification Plan,
dated January 1994.
2.0 INSTALLATION OF INJECTION AND MONITORING WELLS
The pilot study will be performed in the vicinity of monitoring well MW-6S. This location was
selected due to the high concentrations of dichloroethene and dichloroethane isomers as shown
in Table 1. The monitoring network for the pilot study will consist of one new injection well
and two downgradient monitoring wells (one new and one existing) at the locations shown on
Figure 1. The wells will be spaced approximately 5 feet apart in order to observe the effects of
the reactive agents in a relatively short timeframe. Existing well MW-6S will be used as the
middle well since several rounds of groundwater samples have been collected from this well.
The other monitoring well will be installed 5 feet downgradient of MW-6S.
The new monitoring well will be installed using 4¼-inch inside diameter (ID) hollow-stem
augers (HSA). The new monitoring well will be installed to a depth of 20 feet below ground
surface and screened from approximately 9.5 to 19.5 feet bgs to match the screened interval at
MW-6S. The monitoring well will be constructed from 2-inch diameter PVC riser pipe and
2-inch diameter slot-10 PVC screen.
The injection well will be installed using 8-½ ID HSA. The well will be constructed from 4-inch
diameter PVC riser pipe and 4-inch diameter slot-10 PVC screen. The injection well will be
installed to a depth of 20 feet below ground surface and screened from approximately 9.5 to
19.5 feet bgs to match the screened interval of the monitoring wells.
The wells will be developed following installation using a submersible pump. A total of five
well volumes will be purged from each well. Field measurements of turbidity, conductivity,
pH, and temperature will be collected after each well volume is removed.
3.0 BASELINE GROUNDWATER QUALITY SAMPLING
Prior to injection of the reactive material, baseline groundwater quality samples will be
collected from the injection well and the downgradient monitoring wells. The baseline
groundwater quality data will be used to evaluate the effect of the injection of reactive materials
on the chemicals that are present in the Site groundwater. The wells will be purged prior to
sampling using a peristaltic or submersible pump. A minimum of three well volumes will be
Worldwide Enginooring, Environmental, Construction, and IT Services
CONESTOGA-ROVERS
& ASSOCIATES
November 12, 2001 3
•
Reference No. 3669
purged from the wells prior to sample collection. Field measurements of turbidity,
conductivity, pH, temperature, and dissolved oxygen will be collected after each well volume.
The samples will be collected after these field-measured parameters stabilize, consistent with
the procedures used in the Remedial Investigations and Remedial Action activities that were
performed at the Site.
Groundwater samples will be collected using a new disposable Teflon bailer at each well, except
for the filtered (dissolved) parameters, which will be collected using a submersible pump and
inline flow filters. The groundwater quality samples will be analyzed for volatile organic
compounds (VOCs), semi-volatile organic compounds (SVOCs), pH, DO, redox potential,
dissolved iron and manganese, chloride ion concentration, TOC), ethene, ethane, and methane.
Groundwater quality samples will be shipped in iced coolers under chain-of-custody to
Analytical Services Inc. (AS!) in Norcross, Georgia.
4.0 INJECTION OF REACTIVE MATERIAL
The analytical data for MW-6S from the December 2000 groundwater quality monitoring event
are provided in Table 1. Based on the chemicals present and their· associated concentrations,
CRA determined that ethyl lactate is the most appropriate reactive material to test in the pilot
study. Ethyl lactate creates a reducing environment that results in the destruction of
chlorinated compounds by several methods. Ethyl lactate is readily biodegradable and can be
used as a source of carbon and energy to enhance microbial activities. It also acts as an oxygen
scavenger to enhance anaerobic microbial activity and the initiation of reductive dechlorination.
Ethyl lactate is hydrolyzed by soil microbial enzymes to produce ethanol and lactic acid, which
are then fermentatively metabolized through multiple steps to form carbon dioxide, water, and
molecular hydrogen. The molecular hydrogen enhances the reductive dechlorination of
chlorinated compounds such as the dichloroethene and dichloroethane isomers that are present
in the Site groundwater to non-toxic compounds such as ethene. Since ethyl lactate is an
oxygen scavenger, the degradation of BTEX compounds is impeded, however, these
compounds are generally either not present or are present at comparatively low concentrations
in the Site groundwater.
Ethyl lactate is well suited to the Site conditions and possible large-scale application. Ethyl
lactate is easy to mix and the solution can be readily prepared in and gravity-injected from a
truck-mounted tank. Ethyl lactate will also be more mobile within the formation. Ethyl lactate
will deplete more rapidly than HRC and may require a greater number of applications, but
ethyl lactate is significantly more cost-effective.
Worldwide Enginoering, Envlronmontal, Construction, and IT Sorvlcol!I
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& ASSOCIATES
November 12, 2001 4
•
Reference No. 3669
The target concentration for the ethyl lactate will be approximately 3 to 5 percent in potable
water. In order to treat the pore wa_tei within the 10-foot deep by 10-foot radius test zone, the
injection will consist of 100 pounds of ethyl lactate mixed with 250 gallons of water. The ethyl
lactate solution will be mixed in a truck-mounted polyethylene tank and injected using the
following method: ·
1. Approximately 100 pounds of ethyl lactate will be poured into the tank;
2. Approximately 250 gallons of water from a high pressure hose will be used to dissolve
and mix the solution;
3. A shc>rt length of 2-inch diameter hose will be lowered into the injection well. A PVC
ball valve will be installed at the base of the tank to regulate the flow rate of the solution
into the injection well; and
4. The level of the solution will be raised to within 1 foot of the top of the riser. The time
required to drain the polyethylene tank will be recorded so that the average injection
rate can be determined.
Following injection of the solution, 250 gallons of potable water will be injected using the
method described above in order to force the ethyl lactate solution into the formation and
prevent fouling of the injection well.
5.0 ADDITIONAL GROUNDWATER QUALITY SAMPLING
Groundwater quality samples will be collected from the injection well and two downgradient
wells at the following intervals:
l. One week following injection;
2. Two weeks following injection;
3. · Four weeks following injection; and
4. Eight weeks following injection.
The groundwater quality samples will be collected using the method described in Section 3.0.
The groundwater quality samples will be analyzed for pH, DO, redox potential, chloride ion,
TOC, VOCs, SVOCs, ,md dissolved iron and manganese, ethene, ethane and methane. Normal
turn-around-times will be requested for all samples.
Worldwido Engineering, Environmental, Construction, and IT Sarvicos
CONESTOGA-ROVERS
& ASSOCIATES
•
November 12, 2001 5 Reference No. 3669
6.0 REPORTING
Following completion of the pilot study, the Steering Committee will prepare a letter report for
submission to USEPA and North Carolina Department of Environment and Natural Resources
(NCDENR). The letter report will describe the installation of the injection and monitoring
wells, the injection of the ethyl lactate solution, and the results of the groundwater quality
sampling events. The analytical data collected in conjunction with the pilot study will be
submitted to USEPA and NCDENR. The letter report will summarize the findings of the pilot
study and provide conclusions for the large-scale use of reactive materials at the Site.
7.0 SCHEDULE
Following approval to proceed from USE!' A and NCDENR, the Steering Committee will
proceed with the pilot study. The Steering Committee respectfully requests to commence the
pilot study 3 weeks following your approval of this proposal. A permit from NCDENR is not
required to perform the pilot study since it is being performed under a USEPA Unilateral
Administrative Order (UAO) at a Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) Site. The work is being conducted entirely on the Site, so pursuant to
Section XVI of the UAO, a permit is not required. CRA will ensure that the substantive
requirements of the NCDENR permitting process are met prior to starting the pilot study,
including submission of this work plan, the layout of the test area, the well construction details,
and a description of the reactive material to be used. The schedule will be as follows:
1. Week 1 install and develop injection and monitoring well;
-baseline groundwater quality sampling;
-inject ethyl lactate solution;
2. Week 2 first round of post-injection groundwater quality sampling;
3. Week3 -second round of post-injection groundwater quality sampling;
4. Weeks -third round of post-injection groundwater quality sampling;
5. Week 9 fourth round of post-injection groundwater quality sampling; and
6. Week 12 -submission of pilot study report and recommendations.
Changes to the pilot study may need to be made in the field as the study progresses depending
on the conditions encountered during the study.
Worldwide Engineering, Environmental. Construction, and IT Sorvicru1
tS
CONESTOGA-ROVERS
& ASSOCIATES
November 12, 2001
•
6 Reference No. 3669
If you have any questions, please do not hesitate to contact me. We respectfully request that
you approve of this pilot study work plan in writing.
Yours truly, .
CONESTOGA-ROVERS & ASSOCIATES .
~~M~
RH/jdh/123
c.c. Reuben Bussey, USEPA Region IV
Randy McElveen,·NCDENR
Jimmy Kirkland, King & Spalding
Jadco-Hughes Steering Committee
Rob Hoag, CRA (Waterloo)
John Uteck, CRA (Charlotte)
Worldwide Enginooring, Environmental, Construction, ond IT Sorvlco:s
. l "
CRA 3669Towl\l23-Tl
• TABLEl
CONCENTRATION OF SELECT voes
JADCO-HUGHES SUPERFUND SITE
GASTON COUNTY, NORTH CAROLINA
Groundwater MW-6S
Compormd Cleanup Criteria Dec-00
1,1-Dichloroethane 0.3 2.8
1,2-Dichloroethane 0.3 8000
1,2-Dichloroethene (total) . 70 5500
1,2-Dichloropropane 0.56 3.7
2-Butanone 170 ND 10
4-Meth y 1-2-pen tarione 350 ND 10
Acetone 700 ND 10
Benzene l ND2
Carbon tetrachloride 0.3 ND 0.3
Chlorobenzene 300 ND5
Chloroform 0.19 0.24
Methylene chloride 5 ND 5
Tetrachloroethene 0.7 ND 0.7
Toluene 1000 43
Vinyl chloride 0.015 930
Xylenes (total) 400 20
Noles:
ND -Not Detected at the associated detection limit.
Concentrations reported in ppb.
LEGEND
_,._ ----PROPERTY LINE
------•-PROPOSED HOOK-UP TO SEWER
PIPELINE
---·---------PERIMETER COLLECTION DRAIN
A ''"'' PUMP WELL
oMH MANHOLE
■ Mtts PUMP CHAMBER
181 ss1◄ STREAM MONITORING LOCATION
~!Bl!':••9Y '!)' ----
I
03669-00(TOWN123)GN-WA001 NOV 09/2001
I I
:fil
I
I
• MW6S
• PZSS
I
I/
.....____L___ ---
SHALLOW MONITORING WELL LOCATION
SHALLOW PIEZOMETER LOCATION
PROPOSED INJECTION WELL LOCATION
PROPOSED MONITORING WELL LOCATION
CASONSTREET
SPRING 0
r--,MW6S~ ~-~ I 5' I 5' I
SCALE 1 "=500'
0 50 100ft
I ,(
I
I
) i ,_____\_
figure 1
INJECTION AND MONITORING WELL LOCATIONS
PILOT STUDY
JADCO-HUGHES SITE
Gaston County, NC