NCD981927502_19920430_Geigy Chemical Corporation_FRBCERCLA RA_Dispute Resolution Meeting-OCR

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DISPUTE RESOLUTION MEETING REGARDING THE
GEIGY CHEMICAL CORPORATION SITE
EPA REGION IV -ATLANTA, GEORGIA
APRIL 30, 1992
Olin Corporation
CIBA-GEIGY Corporation
Kaiser Aluminum & Chemical Corporation
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AREAS OF DISPUTE REGARDING EPA'S ACTIONS AT THE
GEIGY CHEMICAL CORPORATION SITE
Addition of On-Site Thermal Treatment Alternatives
• Space Requirements for Implementing On-Site Thermal Treatment Exceed
Available Area at the Geigy Site
• Thermal Desorption is an Unproven Technology with Significant
Implementation Difficulties
• Should Thermal Desorption Be Unsuccessful, On-Site Incineration Would Have
Even Greater Implementation Difficulties
• Testing and Design of the Thermal Treatment Remedy Will Significantly Delay
Remediation of the Greatest Potential Source of Risks, Site Groundwater
• Volume of Soil to be Treated is Insufficient to Mobilize Qualified Contractors
• Evaluation of Preferred Remedies by EPA is Insufficient and Inconsistent with
Requirements of the NCP
• Alternative 2 (Off-Site Treatment/Disposal) Offers Significant Advantages for
Overall Site Remediation
Application of Direct Contact Health-based Cleanup Levels to Subsurface Soils
• Application of Health-Based Standards to Subsurface Soils is Inappropriate,
Overly Conservative, and Without Basis in EPA Guidance
• Dismissal of Unsaturated Transport Modeling When Results Were Equivalent
to those Generated By EPA
Inclusion of Unreviewed Materials into PRP Documents Without Approval
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SPACE REQUIREMENTS AND PHYSICAL LIMITATIONS
Clearly, access will be limited for conducting on-site thermal desorption or on-site
incineration at the Geigy Site due to:
the limited area (approx. one acre) and its triangular configuration
the areas requiring excavation will be unavailable for siting of the treatment
units, support equipment, and staging areas
the proximity to State Highway 211 and the Aberdeen & Rockfish railroad line
and required setbacks (see typical layout, attached)
neighboring residences (50 feet away from the treatment unit) and commercial
establishments (225 feet away)
access agreements.
Attached is an aerial photo of the Geigy Site taken prior to the removal actions (the
warehouses have since been removed). Siting requirements for a typical thermal
desorption system are presented as an overlay for the Site. Also attached is a diagram
of a typical thermal desorption system ()(*TRAX System by Chemical Waste
Management).
Consequently, an on-site thermal treatment unit will not fit on the Geigy Site and must be
located on private property. Acquisition of adjacent private residential property will be
difficult due to planned use of the area and may involve zoning and regulatory (e.g.,
RCRA) issues. Siting of the unit, peripheral equipment, and staging areas will occupy the
State highway, Aberdeen & Rockfish railroad, and/or utility rights of way as well. Should
the contingent remedy, on-site incineration, be selected, a greater space would be
required due to the additional air pollution control and other process equipment.
ATTACHMENTS
1. Site Aerial Photograph
2. Site Layout with Overlay of Typical Layout of On-Site Thermal Desorption System
3. X*TRAX Thermal Desorption System (Typical Configuration)
----
Woods
I EGENP
---
Upchurch
Property
~ Highway 211 Right of Way (50 Feet From Centerline)
~ Railroad Right of Way (80 Feet From Centerline)
Powerline Right of Way (20 Feet From Centerline)
-0 Well Location
0 160 320 Feet
Approximate Scale
-- - -
0
- ---
1. Excavated Soil Storage (100' x 100')
2. aean Soil Staging (75' x 75')
3. Preparation/Handling (100' x 100')
4. Thermal Process (100' x 200')
5.
6.
7.
8.
9.
10.
Furniture
.E '.:;,
j tJ
Woods
Treated Soil Storage (60' x 200')
First Aid/Decon (150' x 150')
Bulk Fuel Storage (75' x 125')
Fire Water (50' x 50')
Control Room (50' x 50')
Parking (50' x 225')
Rental Storage
Building
0
-N --• C " a. • • Iii
Demolet Automotive
Cleaning Service
and Residence
Allred
Property
Residence
SIRRINE
ENVIRONMENTAL
CONSUL TAN TS
Typical Layout for On-Site
Thermal Desorption System
---.. --
PRODUCT DRYER
~~n~N~ UH('--.
PAOOUCT
CONY£YOAS
"-'
RAOIAl STACJ<:E'l
(FUTURE!
"--
F!LTEfl. PRESS
-
EOUCTOR SCRUDDEfl.
FEEDER
- - --
PHASE
SEPARATOR
,SLTER PRESS
FEED TANKS
-
PAIMAR'I' HEAT EXCHANGER
Conceptual Soil Treatment Facility
------
PROCESS VENT
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UNPROVEN THERMAL DESORPTION TECHNOLOGY
EPA considers thermal desorption to be an innovative technology for the treatment of
soils. While thermal desorption has been applied for the treatment of volatile organics
and petroleum hydrocarbons, there has been no full-scale application for the treatment
of pesticides. Areas of uncertainty for the Geigy Site include:
ability to attain the low Performance Standards for all pesticides
nature, extent and dispersion of air emissions
volume, nature and concentrations of treatment residues
volume of treatment residues requiring off-site disposal/treatment and the
availability of off-site facilities that could accept these residues
availability and reliability of full-scale equipment
cost-effectiveness
ability to allow mobilization and operation of the most qualified contractors
based on the limited volume of soils.
These factors would be aggravated by the size, limited buffer zone, and active
transportation routes at the Geigy Site. This site is a poor location to attempt
demonstration of EPA's preferred technologies:
Air emissions from a thermal desorption unit require consideration prior to selection of a
preferred remedy. Concentrations of toxic air pollutants listed in North Carolina Air Quality
Control Regulation 15A NCAC 2D .1104 need to be addressed to obtain an air permit for
a Thermal Desorption System. Depending on the location of the thermal desorption
system, and the stack parameters and emission rates, this may include concentrations
for the following:
• cavity effects
• building wake effects
• receptors in elevated and rolling terrain (terrain greater than 50% of stack
height)
• receptors in complex terrain (terrain greater than stack height)
• receptors at nearby critical locations, including residences, schools, rest
homes, and businesses.
Regardless of the location of the thermal desorption system, and the location of
contiguous property lines, state highway 211 and the Aberdeen and Rockfish Railroad are
areas of uncontrolled access which will need to be addressed in a air dispersion modeling
analysis. In addition, the many residences nearby (approximately 1200 residents live
within one mile of the• site), and the close proximity of several businesses on state
highway 211, indicate that many critical locations are near the site. These critical
locations will also need to be addressed in any modeling analysis.
According to the attached layout, the thermal desorption or incineration system would be
located adjacent to the site, partially on the Allred property residence. This property
should be considered ambient air, because the Geigy Site PRPs are not the owner. This
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would require concentrations be predicted at locations immediately adjacent to the
Thermal Desorption System. If the stack height is less than the cavity height, the cavity
concentrations in ambient air would need to be considered. If the stack height is less
than the maximum height of the building wake effects region, the effects of the building
wake would also need to be examined. If the stack height is less than approximately 120
fe,et, modeling analyses using simple and complex terrain models will need to be
performed.
Any requirements of the Federal Clean Air Act Amendments also need to be addressed,
as well as other activities at the site which may occur during remediation.
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ON-SITE INCINERATION AS THE CONTINGENCY ALTERNATIVE
The proposed plan states that on-site incineration is the contingency remedy, should the
innovative thermal desorption remedy be ineffective in attaining the low soil Performance
Standards. Accepting on-site thermal desorption at this point is equivalent to accepting
on-site incineration at any time in the future. On-site incineration would increase the
implementation difficulties and remedial schedule as compared with on-site thermal
desorption, as discussed below:
• greater space requirements for primary and peripheral equipment
• greater air emissions control and monitoring requirements
• greater setbacks required due to higher operating temperatures (e.g., ash
stockpile)
• greater preparation time prior to operation (e.g., trial burn, interim status for
burning, delisting of ash)
• State siting requirements, if an action-specific ARAR.
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EXTENDED TIME FOR IMPLEMENTATION
The duration of remedial activities is one of the greatest disparities between the choice
of on-site thermal desorption, with the contingent incineration, versus off-site landfilling
and/or incineration. The off-site removal action (outside the Southeast Compact) could
be accomplished within approximately two months following approval of the work plans
and the selection of a contractor. Assuming prompt review of submittals, the removal
action could be completed within six months following notice to proceed. Conversely,
treatability testing and a comprehensive Remedial Design effort (including 30/60/90/100
percent submittals) would be required prior to implementing either on-site thermal
desorption or on-site incineration. Treatability and design activities for thermal desorption
would require at least two years. Access agreements would have to be obtained prior
to mobilization. Incineration, with its attendant trial burn requirements, would add at least
one year to the remedial efforts. Site remediation would therefore be delayed
considerably should on-site thermal desorption or on-site incineration be selected as the
remedy.
The Baseline Risk Assessment determined that the greatest risks at the Geigy Site are
posed by potential ingestion of groundwater under a Mure residential scenario.
Conversely, the Proposed Plan states that Site soils are "within the acceptable range of
risk specified by the NCP". Site soils are therefore of lesser concern and groundwater
should be the focus of remedial efforts. Groundwater contamination at the site is located
directly below the soils to be excavated for remediation. Construction of the groundwater
remediation system could not begin until completion of the soil remediation. On-site
thermal treatment would delay implementation of the groundwater remedy for at least four
years following notice to proceed. Contaminated groundwater would continue to migrate
within this period and remain a potential risk. Conversely, the delay for soil remediation
would have little effect on Alternative 2, Off-Site Disposal/Treatment, since design of the
. groundwater system can proceed simultaneously with the removal action. Under
Alternative 2, implementation of the groundwater remedy could begin within approximately
18 months following notice to proceed. Also under Alternative 2, the groundwater
remediation system would be installed and operating for approximately two and a half
years before the equivalent system could be enacted under Alternative 4/5. The PRPs
are committed to implementing the selected groundwater remedy within the shortest
reasonable time frame.
ATTACHMENT
1. Remediation Schedule for Alternative 2 (Off-Site Disposal/Treatment) and Alternative
4/5 (On-Site Thermal Treatment)
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ALTERNATIVE 2
SOIL REMEDIATION
June 1992 O·
REMEDIAL DESIGN WORK PLAN
CONTRACT SUBCONTRACTORS
IMPLEMENT SOIL REMOVAL
CONFIRMATION SAMPLING
SOIL REMEDIATION COMPLETED
PERFORMANCE STOS. VERIF .
PREPARE WORK PLAN
30% DESIGN
DRAFT-CONSTRUCTION SCHEDULE
PERFORMANCE STDS. VERIF.
DRAFT CONSTRUCTION QA PLAN
90%OESIGN
FINAL CONSTRUCTION SCHEDULE
CONSTRUCTION COST ESTIMATE
CONSTRUCTION QA PLAN
O&M PLAN
FINAL DESIGN
RA WORK PLAN
CONSTRUCTION MGT. PLAN
SELECT SUBCONTRACTOR
REMEDIAL CONSTRUCTION
ALTERNATIVE 4
TREAT ABILITY STUDY PLANS
TREAT ABILITY STUDY
RD PLANS
30% DESIGN (Soil/Groundwater)
60% DESIGN (Soil/Groundwaterl
■--••
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.......
--1--
1...1
1...1
1...1
1...1
1...1
1...1
June 1993
1
-
, .... ....
SCHEDULE FOR RD/RA ACTIVITIES FOR ALTERNATIVE 2 AND ALTERNATIVE 4
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E;jll • ~I II 6111
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■--
June 1994 2
- -
Elapsed Tune (Yoara)
June 1995 3 June 1996 4
DRAFT CONSTRUCTION SCHED. .1--■ .
June 199i
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• -+-+-+-+-+-+-++-+-+-+-+-++++-+-+-+--I
f-PCcE=.!R'.!F~O:e,:R!'Me,A"N:,,Ce,Ec:Se_Tc,O,oSc_._,V,cE,:,Re:IF.c_. -+++-+-+--f-f-j-j-j-j-+-{-f-f-f-+++-+-+--f-f-j-jl--j-j-,..·~•'l,-f-f-f-+++-+-+--f--f-j-j-jf-f-f-f-t-t-t-f-f-+ • -+--l--+-!-!-1--1--+-+-+-+-+-+-+--+--+--+-+-+--l
CRAFT CONSTRUCTION QA PLAN -■1111 r.~~~~~~~~~~~~J=tt1jj=t!1j=t!!j=tt!jj=tt1jjtt1jj:Ct1j=t••~-~•t1j=tt!lj=tt!ljj:• ~0% DESIGN (Soil/Groundwater)
FINAL CONSTRUCTION SCHEDULE . -i...i...li
CONSTRUCTION COST ESTIMATE -
CONSTRUCTION O&M PLAN 1-■I
FINAL DESIGN
RA WORK PLAN
CONSTRUCTION MGT. PLAN
CONSTRUCT. SAFETY/CONT. PN
SELECT SUBCONTRACTOR
REMEDIAL ACTION {Soil)
SOIL REMEDIATION COMPLETED
GW EXRACT. SYS. CONSTR.
ADDITIONAL TIME INCINERATION
r:,cn, "lnW.11.TFR . . "
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INSUFFICIENT VOLUME OF SOIL FOR ON-SITE THERMAL TREATMENT
The estimated volume of soils requiring remediation as determined in the Feasibility Study
was determined to be approximately 650 cubic yards. EPA has significantly increased the
volume of soils potentially requiring remediation, from 650 cubic yards in the FS to 2,200
cubic yards in the proposed plan using revised cleanup criteria. These volumes are
insufficient to warrant mobilization, site preparation, setup, startup, trial runs and operation
of a fully capable on-site thermal desorption or on-site incineration system. Experienced
contractors, such as Canonie and Chemical Waste Management, specified a minimum
volume of 5,000 to 10,000 cubic yards for mobilization. For this reason, on-site thermal
desorption and incineration were not considered under a detailed analysis in the
Feasibility Study. EPA's detailed evaluation of implementation of the processes at the
~eigy Site was not presented in the proposed plan and is unknown. Because of the
limited volume, startup and trial operation of a thermal desorption unit would consume a
significant portion of the total volume of site soils.
!vlobilization and demobilization charges for a capable (e.g., Canonie or CWM) thermal
desorption unit are on the order of $600,000. Similar charges for a transportable
incinerator are approximately $1,000,000. These figures are based on vendor quotes
solicited during April 1992. Based on the approximately 2,000 cubic yards of soils that
EPA estimates require remediation, these mobilization costs represent upfront costs of
$300 to $500 per yard before there is any treatment. These costs are out of proportion
to typical unit mobilization rates. Typical throughputs for transportable thermal treatment
units are 10 tons per hour at a 70 percent service factor. Site soils would therefore be
processed within approximately three weeks. This short operating period is insufficient
to warrant mobilization of transportable units. These factors underscore the argument
that seasoned vendors will not mobilize their heavily committed equipment to this limited
volume.
It is unclear what type of equipment EPA is using to base their evaluation of costs and
schedule. EPA gave the name of one thermal desorption contractor, Southdown Thermal
Dynamics of Houston, TX, to the PRPs as a potential contact for remediation. When
contacted, this vendor indicated that they would not have a transportable system for
another two years. Another vendor referred by EPA, TerraDyne, has no relevant
experience with pesticides or hazardous waste sites and stated that stabilization of site
soils would be required following thermal treatment to achieve the treatment levels. Their
unit is currently under construction and is permitted by the NCDEM only for petroleum
contaminated soils. The PRPs seriously question the qualifications of contractors who
would respond to EPA requests on such a limited volume of soils.
ATTACHMENTS
1. Communication report for Southdown Thermal Dynamics
2. Communication report for TerraDyne
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COMMUNICATION REPORT
Person Contacted: --"'M""'ik""'e'---"'B"'al"'la=rd-=-------Project No.: --=G,_--'-'10=2~4""". o=o'-------
Company: TOI (Southdown Thermal Dynamics) Date: 3/26/92 Time: 11 :30 AM
Address: 12235 FM 529 Client: -=G"'e""'ig,.,y'-----------
-----'-'Hc:oc=u=st_,_,o""n~TX_,.,__-"7-"7"°'0-"4__,_1 _______ Re: Thermal Desorption System for
Soil and Sludge .
Telephone No: [phone] Telephone Conversation: -~Xc.,_ __ _
Recorded By: -~G"'e"'-r-"'a"'ld'-'--F.'-'-'-M"'o"'rr'""o""n"'e'-----Office Conversation: _______ _
I contacted Mike Ballard of TOI for technical and economic information concerning TDl's thermal desorption system. Mr. Ballard was able to provide the following information:
The current system has been on-line continuously for approximately 4 years at a petrochemical refinery (Chevron) in El Segundo, TX. The system acts in line with a process train that once produced an oily waste sludge at approximately 60 tons/day. However, due to the thermal treatment, water and product (petroleum distillates) are recovered, and solids formed for ultimate disposal is significantly reduced. Mr. Ballard stated that Chevron was able to avoid the "derived from" rule, due to the on-line placement of the system, and therefore can legally claim they do not produce a hazardous waste. This, in conjunction with the solid reduction, has resulted in significant cost savings for this refinery. Based on information from the El Segundo refinery, operating costs are approximately $240 per ton.
Chevron has retained TOI to design and construct another system for their Port Arthur, TX facility, expected to be in operation in February 1993. Mr. Ballard states that TOI can design similar systems for commercial refineries and for hazardous waste treatment of soil and sludge containing petroleum chemicals, creosotes, pentachlorophenol, and K048 through K052 wastes. Typically, he says, a system can be designed in three to six months,
Currently, TOI does not have a mobile unit. However, Mr. Ballard stated that one can economically design and operate a unit for solid-material treatment if volumes
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COMMUNICATION REPORT -MIKE BALLARD
MARCH 30, 1992
PAGE TWO
are greater than 10,000 cubic yards. He said that TOI is working to construct a
mobile system within two to three years, and is currently working to permit and
develop the process for CERCLA remedial actions.
SEC DONOHUE INC.
Gerai'dF. Morrone
cc: Jim Cloonan
\gfm\ciba\geigy\desorp1 .mem
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COMMUNICATION REPORT
Person Contacted: =B""ill~B=r-'-'in-"-k=e"-r ________ Project No.: =G~1=0=24~-=o=o ___ _
Company: ~T=er~r=aD=y'"'n~e~--------Date: 4/27 /92 Time: 15:00 ~~~--
Address: Sanford NC Client: ___________ _
Re: ------------------------------
Telephone No: ____________ Telephone Conversation: -~X~---
Recorded By: --=J=im~C~lo=o=n~a=n~-----Office Conversation: ______ _
Mr. Brinker called me upon the recommendation of Mr. Curt Fehn (EPA) to discuss thermal desorption possibilities at the Geigy and Aberdeen sites. Their unit is under construction but has been permitted by the NCDEM for TPH and BTEX soils. Their permitaddresses air emissions. The TerraDyne thermal treatment unit will consist of the following equipment:
• primary kiln (300-1100 °F)
• cyclone(s)
• secondary combustion
• cooling tower
• bag house.
The unit will require approximately 100' by 100' and be transported by six trailers. The primary kiln would typically operate between 400-600°F for TPH soils. The throughput for their unit is up to 50 tons per hour for sandy soils.
TerraDyne has no experience with the treatment of pesticides or hazardous waste sites. Mr. Brinker stated that unit was state-of-the-art, I asked if their unit was similar to Soiltech's ATP unit being marketed by Canonie. He was unsure. I asked if there was an inert gas purge on the primary kiln to prevent combustion (a key element of thermal desorption) and how their unit differed from an incinerator. Mr. Brinker stated that he placed paper in a similar unit in Canada and he could read the paper when it came out, therefore there "was no ash" and their unit was not an incinerator. I reminded Mr. Brinker of the book "Fahrenheit 451" and he admitted that the paper test was not a good indicator of incineration.
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COMMUNICATION REPORT -BILL BRINKER
APRIL 27, 1992
PAGE TWO
I asked what TerraDyne's minimum mobilization volume would be. Mr. Brinker said they
don't have a minimum volume per se but would look for a minimum project value or
$400,000. For the Geigy Site, TerraDyne believes that some form of stabilization of
"pelletization" would be required following thermal desorption. to achieve the treatment
levels. [The Performance Standards for Geigy are not leachate-based so the benefit of
stabilization is unclear.] Mr. Brinker believes that TerraDyne could remediate 2,500 cubic
yards of soil at the Geigy Site for approximately $600,000. I asked if TerraDyne would
commit to a performance-based contract where they would only be paid for soils replaced
at the site 0.e. that met the Performance Standards}, if they were given all the analytical
data and representative soils for their own testing. Mr. Brinker would not commit to this
approach at this time. He will send me TerraDyne's qualifications package.
SEC Donohue Inc.
Jim Cloonan (J
cc: Ms. Lorraine Miller
Mr. Keith harold
Mr. Lester Rapp
Mr. Howard Grubbs
Mr. Gerry Morrone
Project File
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INADEQUATE EVALUATION BY EPA OF THE PREFERRED REMEDIES
The PRPs asked EPA for their detailed evaluation regarding implementation of Alternatives
4 (On-Site Thermal Desorption) and 5 (On-Site Incineration) at the Geigy Site. The EPA
RPM stated that the evaluation was provided as the short descriptions given in the
proposed plan (EPA, March 1992). The PRPs have reviewed the Administrative Record
located at the Aberdeen Town Hall and confirmed that there is no additional information
regarding potential implementation of the thermal treatment alternatives. Without detailed
information regarding potential implementation and operation requirements, the State and
public do not have an adequate basis for the evaluation of on-site thermal treatment at
the Geigy Site. Such limited development of these alternatives questions EPA's ability to
proceed with selection of a remedy. EPA has been inconsistent with the National
Contingency Plan, which requires that a detailed evaluation be conducted for all remedial
alternatives before they can be presented within a proposed plan. EPA has failed to
provide an adequate evaluation of Alternatives 4 and 5 for public review and comment.
In fact, the only evaluation of Alternatives 4 and 5 other than what is presented in the
Proposed Plan fact sheet is contained within budgetary cost estimates appended to the
PRP's Feasibility Study document.
The proposed plan does not adequately address the following factors regarding
implementation of on-site thermal desorption or on-site incineration:
State requirements
community impacts, especially on neighboring residences and commercial
establishments
action-specific ARARs
present worth costs ( cost effectiveness)
long-term and short-term effectiveness
remedial design, mobilization and operation schedule
construction, utility, transportation, access and other implementation
considerations
potential air emissions and modeling requirements
ability to achieve the remediation levels that were established after the
development of alternatives
volume and nature of residuals to be generated and their ultimate disposal
and/or treatment
comparative assessment among alternatives of the overall period required for
implementation.
EPA is deferring resolution of these considerations to remedial design. The PRPs believe
that these considerations must be addressed and evaluated before the selection of
remedy, so that an appropriate and feasible remedy can be implemented. Forcing
implementation of inadequately evaluated remedies will most likely lead to design of a
faulty remedy, delay in the ultimate remediation of the site, or both.
The effects of 24 hour per day operation of the thermal treatment unit upon the
community have not been evaluated. For example, noise will be a significant·
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consideration for the neighboring residences. The sound level for a transportable
incinerator is approximately 107 dB at 3 feet. Distance to the Allred house based on the
overlay is approximately 50 feet. The resulting sound level at the Allred house would be
approximately 83 dB. Typical night time sound levels in residential areas are
approximately 33 dB. Because of the neighboring highway, night time levels at the Allred
residence are more likely on the order of 50 dB. Since the decibel scale is logarithmic,
the difference of 33 dB would represent an increase in noise level would be approximately
2,000 times the current levels.
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ALTERNATIVE 2 NOT GIVEN FULL CONSIDERATION BY EPA
Alternative 2, Off-Site Disposal/Treatment, was not given full consideration by EPA during
their evaluation of remedial alternatives. EPA has indicated the following reasons for their
dismissal of Alternative 2:
the alternative does not satisfy SARA's preference for permanent remedies
involving treatment
North Carolina requires on-site treatment.
SARA's preference for alternatives is exactly that, a preference. SARA does not require
treatment, especially when other remedies offer comparable protectiveness or allow a
more efficient remedy for the entire site. Alternative 2 does involve treatment, as soils
failing TCLP will be incinerated at a RCRA-approved off-site facility. Soils passing TCLP
would be landfilled at a RCRA-approved facility in full compliance with Federal and State
requirements. SARA's preference for treatment would also be satisfied through treatment
of the extracted groundwater (Alternative 3). Furthermore, Alternative 2 for soils would
allow expedited implementation of Alternative 3 for groundwater as compared with EPA's
preferred remedies.
North Carolina guidelines for evaluating off-site actions are presented in the letter of
March 8, 1991 from Edythe McKinney to Pat Tobin. North Carolina recommends on-site
treatment where practicable and where time allows. The off-site guidelines allow removal
under the following conditions:
· waste materials that can be removed by responsible parties will be removed
but must comply with RCRA requirements. (Alternative 2 would meet this
condition.]
in situ technologies should be implemented where possible. (In situ
technologies were evaluated in the Feasibility Study but determined to be
inappropriate for surficial soils at the site.]
residues from on-site treatment would be replaced at the site if sufficiently
treated. (Condensate from on-site thermal desorption could not be replaced
at the site and would require off-site disposaljtreatment. Activated carbon
used to treat air emissions and aqueous residuals would have to be sent
off-site as well. EPA's preferred remedy would therefore not be a true on-site
alternative. Should on-site incineration be required, the resulting ash may
have to be sent to an off-site landfill. These requirements minimize the off-site
distinctions between Alternative 2 and Alternatives 4/5.J
for sites that do not offer economy of scale for mobile treatment, as does the
Geigy Site, the State will consider combining sites. (The question was asked
at the Geigy Site public meeting whether the Geigy Site soils could be
combined with the other Aberdeen soils at the Fairway Six Site for treatment.
EPA responded that combining of the sites could not be conducted for
regulatory and liability reasons.]
containment remedies will be considered for sites where on-site treatment is
infeasible. [Capping was retained as an alternative in the Feasibility Study but
not selected by EPA.]
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off-site options are allowed when there is an immediate threat to public safety.
[While the Geigy Site does not represent an immediate threat nor is it likely to
in the near future, selection of Alternatives 4/5 would effect a delay of nearly
3 years in implementation of groundwater remediation. Site soils are a static
situation while groundwater continues to migrate. The accelerated
remediation of site groundwater would be a compelling reason for selection
of Alternative 2 that is consistent with the intent of North Carolina's off-site
guidelines.]
Off-site disposal/treatment under Alternative 2 would occur at the USPCI facility in
Waynoka, Oklahoma or Clyde, Utah (landfilling) and/or the Rollins facility in Deer Park,
Texas (incineration). Both of these facilities are outside of the Southeast Compact. For
the given reasons, Alternative 2 would support rather than be at variance with North
Carolina's off-site policy. The PRPs are committed to supporting North Carolina's off-site
policy with regards to the Geigy Site. Non-hazardous wastes (drill cuttings and mud) are
being disposed of within the State (Piedmont Landfill, Kernersville), as will the building
foundation, which complies with the State's program to foster in-state disposal.
Alternative 2 offers distinct advantages for remediation of the Geigy Site when compared
with EPA's preferred remedies, as follows:
demonstrated remedial option that has been successfully employed at the site
no need for treatability testing
avoids need for contingency remedy
straightforward, limited submittals for agency approval
. accelerated implementation
allows accelerated remediation of site groundwater
lesser potential for community impacts
more cost effective
can be readily implemented at site without community impacts or access
agreements.
A comparison of thermal desorption (Alternative 4) and off-site treatment/disposal
(Alternative 2) indicates a significant common element: Both are off-site options. Thermal
desorption will generate the same mass (albeit a smaller volume) of contaminants for
off-site disposal as will Alternative 2. There is therefore little practical difference in terms
of off-site disposal between Alternative 2 and Alternative 4. Thermal desorption operates
by separating pesticides from soil in a gaseous atmosphere at elevated temperatures.
A number of the pesticides (e.g., toxaphene) at the Geigy Site decompose at typical
operating temperatures and enter the gas stream as · free radicals. Under these
conditions, there exists a significant potential to form more toxic compounds that cannot
be received by any off-site facility. The absence of a permitted receiving facility may force
the treatment residuals to be left at the Geigy Site indefinitely.
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Thermal treatment remedies are most effective when applied towards concentrated waste materials. The great majority of pesticides at the Geigy Site have been removed during
the previous two removal actions. Toxaphene levels have been reduced by 99 percent
and .BHC isomers have been reduced by 91 percent. There are only eight discrete
sampling locations remaining at the site that exceed 100 mg/kg of total pesticides.
The PRPs agree that thermal desorption and incineration are appropriate and implementable remedies when the following circumstances exist:
• adequate area for operation and setback from residences and uncontrolled
public access
• setup and operation will not affect adjacent thoroughfares
• favorable air dispersion characteristics and ability to monitor emissions
• sufficient volume of soils (e.g., greater than 5,000 -10,000 cubic yards)
• testing and design period will not materially affect ability to implement overall
site remediation.
These factors do not apply to the Geigy Site. The PRPs understand that North Carolina
does not see Alternative being in violation of their on-site policy and prefers selection of Alternative 2. The remaining rationale for selection of Alternative 4/5 appears to be SARA's preference for permanent remedies involving treatment. Alternative 2 does involve treatment, in that soils failing the TCLP would be incinerated. Those soils passing TCLP, and thereby having the least need for treatment, would be landfilled at a secure facility in compliance with all ARARs. Furthermore, pesticides in groundwater will be adsorbed on carbon and that carbon will be incinerated o!f-site. While Alternative 4/5 would result in additional treatment of soils, the great majority of pesticides at the site have already been
sent off-site for treatment or disposal. The incremental increase in soils treatment through
Alternative 4/5 does not warrant the significant delay in groundwater remediation that
would occur, the additional design and remediation costs, and the additional impacts
upon the community that have yet to be evaluated. The preference (not mandate) for remedies involving treatment is insufficient cause to reject the more implementable, timely, and cost-effective remedy presented by Alternative 2.
ATTACHMENT
1. Detailed Cost Estimates for Alternatives 2, 4, and 5
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a
SUMMARY OF REMEDIAL ALTERNATIVE COSTS
PRESENT WORTH COSTS
ALTERNATIVE 2: Landfilling at USPCI (UT /OK) -$1,700,000
Incineration at Rollins (TX) -$5,300,000
ALTERNATIVE 4: On-Site Thermal Desorption -$3,300,000
ALTERNATIVE 5: On-Site Incineration -$5,300,000
I!!!!!!! iiiiil
PROJECT; CIBA-GEIGY (ABERDEEN, NC) Geigy Sile
NUMBER; G-1024.00
liilll - - - - -
OPINION OF PROBABLE COST
AL TERN. ·•· wi~~ 0;~8;,,;,;1 aiwiy,;6kii, 6kitoo~1e· c:o.>Uiati>
··• ·sJ;1diiiJ8~6;is tb•Pi~;;,.,,;;L;,'i,dii1i ikJ,riJ,~ifr~t•·r-ici·•·i•··•···•··
:(:ITEM/). -_ _.:_:_:·:,:i_:: ;:,=,,:.:, .. --·--------··----. .. ••·• tjrfl i•••··•··y·~-1-T>••
.. ... ... .·•·· .. ·•··•······· ;• ..... · .. > < I ir / •••• .;. ; ....
•···· NUMBER .. · •·•···· ... I :RIPT" ~--C:0$1'($) , ..... ;)., /
CAPITAL COSTS
Direct Ca~ital Costs
:·-:· .. -":'"\u: 10 i(REA T.iuiii.ifv:ifESTiNG{ ,'. ·=
0.11 SAMPLE COLLECTION AND DELIVERY LS $2,300.00 Ass. 2 field techs@ $55/h; 20 h: $100 FED EX
0.12 PER DIEM DAY $180.00 Hotel at $80/nlght; per diem at $100/day
0.13 TREAT ABILITY STUDY WORK PLAN LS $35,000.00 Estimated from previous treatability.
0,14 TREAT ABILITY TEST AND REPORT LS $250,000.00 Estimated from previous treatability.
·::1.'of MOB_i_LiZAfi§N;p-EM(?B_i_L1zAT1~_N.\: •; .... i :·
1.01 EXCAVATION CONTRACTOR LS $40.000.00 Based on SECD experience at similar sites.
1.02 TREATMENT CONTRACTOR LS $1,000,000 Based on Canonie estimate (2/25/92)
i-.-.-·):{/1 :-1 n SITEW05t<ipf'iEf>ARATl()N /.··•·· ). . ........ : ,• : . .-.. _
1.11 UPGRADE ACCESSIBILITY LF $10.00 Based on SECD eXperience al similar sites.
1.12 INSTALL SITE FACILITIES, DEGON UNITS LS $10,000.00 Based on SECD experience at similar sites.
1.13 INSTALL NEW FENCING LF $15.00 Based on JJC estimate.
1.13a REMOVE OLD FENCING LF $1.45 Means 1992; 020 550 0700
1.14 CLEARING FOR TREATMENT UNIT AC $1,000.00 Means 1992; 021 108 0400
. rs .b.~M9t~_i_TIONip1_$#6.S~-l':_o"F .. COi•k·RETE-,SiAB-;
1.16 DEMOLITION SY $9,95 Means 1992: 020 550 1900
1.17 DISPOSAL
1.18 TRANSPORTATION LOAD $400.00 Hazardous material@ $4/mile for 100 miles;
Means 1991; 020 7171270.
1.19 DISPOSAL TON $45.00 FJB quote from Piedmont facllily.
1.19a WASTE CHARACTERIZATION LS $5,350.00 Based on 3 composites@ $1,450 and $1,000 for
obtaining samples.
;,<• •• , .,. ~1ieWQi'ikk:_i'iN_ifri'i(jcfi6N/•··•·•···.
1.21 CIVIL WORK
1.22 SHEET PILING INSTALLATION LS $100,000.00 Based on JJC estimate for Rt 211 site.
1.23 REMOVE, SEGREGATE, STAGE MATERIAL CY $11.00 Based on SECD experience at similar sites.
1.24 LOAD MATERIAL FOR TREATMENT TON $3.29 Based on Lobeco estimate (CWM).
---- --FILE: DISPOSE.WK 1
BY; GFM
DATE; 04/16/92
?t . / /SIJBC .• ..
•• ·•··· •· . ... ) ·\.\\: \, <.L. t'iJfAL(~) T()TAl($) ' ~ 111
0 Assume not required for off-site treatment. $0
0 Assume not required for off-site treatment. $0
0 Assume not required for off-site treatment. so
0 Assume not required for off-site treatment. so
1 $40,000
0 Not required. $0
300 Estimated from site map. $3,000
1 $10.000
2,500 Estimated from site map. $37,500
1,400 Based on ERM report for soil removal. $2,030
0.0 Assume 250'x250' required. $0
550 Estimated from site map. $5,473
19 Based on 11 tons/load, Burgess-Mannus esti $7.500
(3/31/92); estimate 9-lnch thickness.
206 Based on 1.5 tons per cubic yard. $9,281
1 $5,350
0 Assume not required. so
2,200 Based on EPA estimate of 2,200 cy (in situ) $24,200
with 0% additional for sidewall, etc.
0 $0
\g!m\ci ba\geigy\CO'S te s t\dis pose. w I:.
l!!!!!!!!I ---- --- --- ----PROJECT: CIBA-GEIGY (ABERDEEN, NC) Geigy Site
NUMBER: G-1024.00
OPINION OF PROBABLE COST
AL.TERN \wa~~ 6ilip6"al atW~yhcikei; 6KJT&iJ1e c&;Ui1h
sG;,cJi;,~ o~b;iSI() R i!3drri&rii u;w,rn;1ckJ1,;Jrtiii~f Ncj i
··1TEM. J~i"ti c:Bi+<s,2
1.25 TRANSPORT MATERIAL TO ROLLINS INCINER LOAD $4,000.00
IN PORT ARTHUR, TEXAS
1.29 INSTALL. MAINTAIN EROSION CONTROLS
1.30 BORROW CLEAN FILL
1.31 LOAD CLEAN FILL FOR TRANSPORT
1.32 HAUL CLEAN FILL TO SITE
1.33 BACKFILL, COMPACT CLEAN FILL
1.34 BORROW TOP SOIL
1.35 HAUL TOP SOIL
1.41 INSTALL TOPSOIL, FINE GRADE
1.42 SEED ANO FERTILIZE
1.43 30% REMEDIAL CONTR .. H&S. ETC.
1.44 CONSTRUCTION OVERSIGHT
WAYNOKA, OK OR TOOELE CO .. UT
1.51 LOADING, TRANSPORTATION, DISPOSAL
2.10 TEST BURNING, START-UP
2.20 THERMALLY TREAT MATERIAL
2.30 CONFIRMATION SAMPLING OF EXCAVATIONS
2.31 ANAL TYCAL AND LABOR
2.40 CONFIRMATION SAMPLING OF TREATMENT
2.41 ANALTYCAL
2.42 LABOR
LS
CY
TON
CY
CY
CY
CY
CY
SY
LS
DAY
TON
LS
TON
(020 7171270)] for 1000 miles.
$12,800.00 Based on GSST estimate.
$5.35 Common, 1-1/2cy. Means(0222164010) 2,200
$3.29 Based on Lobeco estimate (CWM). 2,970
$5.35 Means 1991(022226 1250); 20-cytruck; 10 mi. 122 Ass. 18 cy per 22-cytruck (nominal).
trip.
$5.00 Based on Lobeco estimate (CWM).
$14.00 Means 1990; 022 216 7010.
$2.13 12-cytruck: 20-mile round trip; Means 1991
122 266 0560.
$19.79 Based on GSST estimate.
$0.35 Based on Lobeco estimate (CWM).
$10,595 Use for Items 1.41 and 1.42.
$850.00 @ $65/h: 10 h/day plus $200 per diem
$21B.50 From USPCI estimate (1/15/92 and 4ll/92) for
combined costs of $210 load, trans (by rail),
and disp. + $6.50 disp. tax for reg'd waste.
Assume no stabilization requireq.
$50,000.00 Based on SEGO experience at similar sites.
$900.00 Based on VTVestimate. See FS, Table F.21.
2,200
1,613 Based on 2 acres and 6-inch depth of top soil.
1,613
1,613
9,680 Estimated from site map.
30 Based on 10 days each for site prep, exc., and
renovation (backfill, grade, revegetate).
2,970
0
0
LS $200,000.00 Based on SEGO experience at similar sites and
EA
LS
disc. w/ Ciba-Geigy after previous experience.
$450.00 Todd Scott est. for pesticide scan (2/25/92).
$20,000 Based on SECD experience at similar sites.
0 To be conducted off-site.
0 To be conducted off-site.
FILE: DISPOSE.'M(t
BY: GFM
DATE:
·/SUBc
TOTAL($)
$0
$12,800
$11,TT0
$9,n,
$654
$11,000
$22,587
$3,436
$31,928
$3,388
$10,595
$25,500
$643,005
$0
$0
$200,000
$0
$0
04/16/92
TOTAL($)
\glm\c)ba\ge igy\cos tes tld is pose. w~
==' iiiii
PROJECT: CIBA-GEIGY (ABERDEEN, NC) Geigy Site
NUMBER: G-1024.00
------OPINION OF PROBABLE COST
Al.TERN/ w~J~6is8~i ~i 01;:,;;i;a;6krfook1J cii :ufat\
.13J;1d1Ago~tiiilt6Piedllii>r\iliiridfill (K~iri~;Uiiie; NC)•ii
Subtotal, Direct Capital Costs
Indirect Capital Costs
Engineering Services and Related
·:·:. ; 7:00 ENGINEERiNG SERVICES \ .. _., •• _. i.\.
7.01 CONTRACT ASSISTANCE
7.02 SURVEYING SERVICES
7.10 DESIGN
7.11 EXTRACTION SYSTEM
7.12 TREATMENT PLANT DESIGN
7.13 CIVIL DESIGN
7.14 DRAINAGE DITCH DESIGN
8.10 REGULATORY ASSISTANCE
8.11 PERMITTING
8.12 DISPOSAL FACILITY/DEHNR
8.13 DISPOSAL FACILITY/OKLA.UTAH
8.14 TREATMENT WORK
8.17 FINAL REPORT WRITING
8.20 LICENSES
8.30 LEGAL SERVICES, INSURANCE
Subtotal, Indirect Capital Costs
TOTAL CAPITAL COSTS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
$282,692 Based on SEGO experience at similar sites.
$70,673 Assume 5% of Direct Capital Costs.
$750.00 Based on SEGO experience at similar sites.
$0
$0
$7,500.00 Required for excavation eval near RxA.
$0.00
$3,000.00 Based on SEGO experience at similar sites.
$3,000.00 Based on SEGO experience at simllar sites.
$25,000.00 Based on SEGO experience at similar sites.
$20,000.00 Based on SEGO experience at similar sites.
$56,538 4% of Direct Capital Cost; from Plant Design
and Economics for Chem. Engineers. p. 205.
$14,135 1 % of Direct Capital Cost: from Plant Design
and Economics for Chem. Engineers. p. 205.
$43,899 25% contingency of Items 7-9.
--- -
,r
1
1
1
1
1
1
1
1
1
0
1
1
: ._:•-···: :: ·.-:: ... ·.
: .
Required for site renovation.
---
·:-: _.-,.
FILE: DISPOSE.VvK 1
BY: GFM
DATE: 04/16/92
SUB
TOTAL($)
$282,692
$1,413,460
$70,673
$750
$0
$0
$7,500
so
$3,000
$3,000
$0
$20,000
$56,538
$14,135
$43,899
$219,495
TOTAL($)
\g1mlcib a\g e!gy\cos !es tld ispos e. w l
&ii iiiii liii -PROJECT: CIBA-GEIGY (ABERDEEN, NC) Geigy Site
NUMBER: G-1024.00
:xi:+iii;.;;•·· .••iniine/~ii&h·J;·.·r:fo111hs•·ckortiiitk~i;•mt·•••:••···
-----OPINION OF PROBABLE COST
sGiiEiri~ BJiiiiJfil Piiiiiiiib;(ti.!M-.iliiii ik~irW/;tiiie'. NC{i
.,
CAPITAL COSTS
Direct Capital Costs
0.11 SAMPLE COLLECTION AND DELIVERY
0.12 PER DIEM
0.13 TREAT ABILITY STUDY WORK PLAN
0.14 TREAT ABILITY TEST AND REPORT
:~_<$_Bf~i~ii9N7P-~ij9.~:,:~!#fi()N//?:c·
1.01 EXCAVATION CONTRACTOR
1.02 TREATMENT CONTRACTOR
1.11 UPGRADE ACCESSIBILITY
1.12 INSTALL SITE FACILITIES, DEGON UNITS
1.13 INSTALL NEW FENCING
1.13a REMOVE OLD FENCING
1.14 CLEARING FOR TREATMENT UNIT
: ••••• :·•·•.•·•··•>1.i 5 6Ei.10U.f1i>N_/DISf'9SALi:ifi::6~cR_ET(sL..:a•·•:•
1.16 DEMOLITION
1.17 DISPOSAL
1.18 TRANSPORTATION
1.19 DISPOSAL
1.19a WASTE CHARACTERIZATION
1.21 CIVIL WORK
1.22 SHEET PILING INSTALLATION
1.23 REMOVE. SEGREGATE, STAGE MATERIAL
1.24 LOAD MATERIAL FOR TREATMENT
LS
DAY
LS
LS
LS
LS
LF
LS
LF
LF
AC
SY
LOAD
TON
LS
I
$2,300.00 Asa. 2 field techs@ $55/h; 20 h; $100 FED EX
$180.00 Hotel at $80/nlght; per diem at $100/day
$35,000.00 Estimated from previous treatability.
$250,000.00 Estimated from previous treatability.
$40,000.00 Based on SEGO experience at similar sites.
$1,000,000 Based on Ganonie estimate (2/25/92)
$10.00 Based on SEGO experience at similar sites.
$10,000.00 Based on SEGO experience at similar sites.
$15.00 Based on JJC estimate.
$1.45 Means 1992; 020 550 0700
$1,000.00 Means 1992; 021108 0400
$9.95 Means 1992: 020 550 1900
$400.00 Hazardous material @ $4/mile for t 00 miles;
Means 1991; 020 7171270.
$45.00 FJB quote from Piedmont facility.
$5,350.00 Based on 3 composites @ $1,450 and $_1,000 for
obtaining samples.
LS $100,000.00 Based on JJC estimate for At 211 site.
CY $11.00 Based on SEGO experience at similar sites.
TON $3.29 Based on Lobeco estimate (GWM).
----
0 Assume not required for off-site treatment.
O Assume not required lor off-site treatment.
O Assume not required for off-site treatment.
O Assume not required for off-site treatment.
O Not required.
300 Estimated from site map.
1
2,500 Estimated from site map.
1,400 Based on ERM report tor soil removal.
0.0 Assume 250'x250' required.
550 Estimated from site map.
19 Based on 11 tons/load, Burgess-Manous esti
(3/31/92); estimate 9--inch thickness.
208 Based on 1.5 tons per cubic yard.
1
i
0 Assume not required.
2,200 Based on EPA estimate of 2,200 cy (in situ)
with 0% additional for sidewall, etc.
2,970 Assume density of 1.35 lons/cy.
--FILE:
BY:
DATE:
-INCOFF .Vv'K 1
GFM
04/10/92
TOTAL_($) TOTAL($).
$0
$0
$0
$0
$40,000
$0
$3,000
$10,000
$37,500
$2,030
$0
$5,473
$7,500
$9,281
$5,350
$0
$24,200
$9,TT1
\gfm\clba\ge lgy\cos 1es tlln coll. wk 1
1!!!11 iiiiii --- ------ ---PROJECT: CIBA-GEIGY (ABERDEEN, NC) Geigy Site
NUMBER: G-1024.00
Al.TERN ihfiheiaW,riiiiRJiiiHiii/:>drtArtAGi; m
OPINION OF PROBABLE COST
TS COST($)
1.25 TRANSPORT MATERIAL TO ROLLINS INC IN EA LOAD
IN POAT ARTHUR, TEXAS
1.29 INSTALL, MAINTAIN EROSION CONTROLS
1.30 BORROW CLEAN FILL
1.31 LOAD CLEAN FILL FOR TRANSPORT
1.32 HAUL CLEAN FILL TO SITE
1.33 BACKFILL, COMPACT CLEAN FILL
1.34 BORROW TOP SOIL
1.35 HAUL TOP SOIL
1.41 INSTALL TOPSOIL, FINE GRADE
1.42 SEED AND FERTILIZE
1.43 30% REMEDIAL CONTR .. H&S, ETC.
1.44 CONSTRUCTION OVERSIGHT
WAYNOKA, OK OR TOOELE CO., UT
1.51 LOADING, TRANSPORTATION. DISPOSAL
2.10 TEST BURNING. START-UP
2.20 THERMALLY TREAT MATERIAL
2.30 CONFIRMATION SAMPLING OF EXCAVATIONS
LS
CY
TON
CY
CY
CY
CY
CY
SY
LS
DAY
TON
LS
TON
$4,000.00 Hazardous material et $4/loeded mi. jMeans 19{
(020 7171270)1 for 1000 miles.
122 Ass. 18 cy per 22-cy truck (nominal).
$12,800.00 Based on GSST estimate. 1
$5.35 Common, 1-1/2cy. Means(0222164010) 2,200
$3.29 Based on Lobeco estimate (CWM). 2,970
$5.35 Means 1991 (022 226 1250); 20-cy truck; 10 mi. 122 Ass. 18 cy per 22-cy truck (nominal).
trip.
$5.00 Based on Lobeco estimate (CWM).
$14.00 Means 1990; 022 216 7010.
$2.13 12-cy truck: 20-mile round trip; Means 1991
122 266 0560.
$19.79 Based on GSST estimate.
$0.35 Based on Lobeco estimate (CWM).
$10,595 Use for Items 1.41 end 1.42.
$850.00 @ $65/h; 10 h/day plus $200 per diem
$216.50 From USPCI estimate (1/15/92 and 4n/92) for
combined costs of $210 load, trans (by rail),
and disp. + $8.50 disp. tax for reg'd waste.
Assume no stabilization required.
$50,000.00 Based on SECO experience et similar sites.
$900.00 Based on VTVestimate. See FS, Table F.21.
2,200
1,613
1,613
1,813
9,680
1
30
0
0
2,970
Based on 2 acres and 6-inch depth of top soil.
Estimated from site map.
Based on 10 days each for site prep, exc., and
renovation {backfill, grade, revegetate).
2.31 ANAL TYCAL AND LABOR LS $200.000.00 Based on SECD experience at similar sites and
2.40 CONFIRMATION SAMPLING OF TREATMENT
2.41
2.42
ANALTYCAL
LABOR
EA
LS
disc. w/ Ciba-Geigy after previous experience.
$450.00 Todd Scott est. for pesticide scan (2/25/92).
$20,000 Based on SECD experience at similar sites.
0 To be conducted off-site.
0 To be conducted off-site.
FILE:
BY:
DATE:
$488.889
$12.800
$11,770
$9,771
$654
$11,000
$22.587
$3,436
$31,928
$3,388
$10,595
$25,500
$0
$0
$2,673,000
$200,000
$0
$0
INCOFF.\.\oKl
GFM
04/10/92
TOTAL($)
\gtm\ciba\gelgy\costest\lricoH. wt; 1
- - ----PROJECT: CIBA-GEIGY (ABERDEEN, NC) Geigy Site
NUMBER: G-1024.00
-- ---OPINION OF PROBABLE COST
•• Al. iE~N..... lriti~eiatib~£\B9I iiM (Port :O:rthur;TX) ··•·• · ..
•·sti1diriiibJh;ii;•"t6Pliidiri6riil.~A8/iiiikJ,;;J/~iiiJ)•··~z;••·····•t••·••·•············•····•··•
•ITEM•
NUMBER
Subtotal, Direct Capital Costs
Indirect Capital Costs
Engineering Services and Related
7.01 CONTRACT ASSISTANCE
7.02 SURVEYING SERVICES
7.10 DESIGN
7.11 EXTRACTION SYSTEM
7.12 TREATMENT PLANT DESIGN
7.13 CIVIL DESIGN
7.14 DRAINAGE DITCH DESIGN
8.00 O_THER SERVICES••· .
8.10 REGULATORY ASSISTANCE
8.11 PERMITTING
8.12 DISPOSAL FACILITY/DEHNA
8.13 DISPOSAL FACILITY/OKLA. UTAH
8.14 TREATMENT WORK
8.17 FINAL REPORT WRITING
8.20 LICENSES
8.30 LEGAL SERVICES, INSURANCE
Subtotal, Indirect Capital Costs
TOTAL CAPITAL COSTS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
$914,856 Based on SEGO experience at similar sites.
$228,714 Assume 5% of Direct Capital Costs.
$750.00 Based on SECO experience at similar sites.
$0
$0
$7.500.00 Required for excavation eval near RxA.
$0.00
$3,000.00 Based on SEGO experience at similar sites.
$3,000.00 Based on SEGO experience at similar sites.
$25,000.00 Based on SEGO experience at similar sites.
$20,000.00 Based on SEGO experience at simllar sites.
$182,971 4% of Direct Capital Cost: from Plant Design
and Economics for Chem. Engineers. p. 205.
$45.743 1% of Direct Capital Cost; from Plant Design
and Economics for Chem. Engineers. p. 205.
$128,419 25% contingency of Items 7-9.
- - --
Required for site renovation.
0
--FILE:
BY:
DATE:
$914,856
$4.574.279_
$228,714
$750
$0
$0
$7.500
$0
$3,000
$0
$25,000
$20,000
$182.971
$45.743
$128,419
$642,097
-INCOFF .'NI< 1
GFM
04/10/92
\g !m\ciba\ge lgy\costes t\in co!L wk 1
- - ----PROJECT: CIBA-GEIGY (ABERDEEN, NC) Geigy Site
NUMBER: G-1024.00
--- ---OPINION OF PROBABLE COST
ALTERN,. • · 6ri,s$li~ Jh~r~~l tj~sorpiiod; tjisp?saf ?f $9il~i~gi>·• ·•· ·•oebris'•t<JPiedindni1..a:ridtiil/KernersVille{NC)i•····· .·
CAPITAL COSTS
Direct Capital Costs
0.11 SAMPLE COLLECTION AND DELIVERY
0.12 PER DIEM
0.13 TREAT ABILITY STUDY WORK PLAN
0.14 TREAT ABILITY TEST AND REPORT
1.01 EXCAVATION CONTRACTOR
1.02 TREATMENT CONTRACTOR
1.11 UPGRADEACCESSIBILITY
1.12 INSTALL SITE FACILITIES, DEGON UNITS
1.13 INSTALL NEW FENCING
1.13a REMOVE OLD FENCING
1.14 CLEARING FOR TREATMENT UNIT
} i)' 1'•1s. DEMoU'r1ONll)IS!'OSAtfoF'.c.o.NcRETEsLAEl _\
1.16 DEMOLITION
1.17 DISPOSAL
1.18 TRANSPORTATION
1.19 DISPOSAL
1.19a WASTE CHARACTERIZATION
1.21 CIVIL WORK
1.22 SHEET PILING INSTALLATION
1.23 REMOVE. SEGREGATE, STA~E MATERIAL
1.24 LOAD MATERIAL FOR TREATMENT
LS
DAY
LS
LS
LS
LS
LF
LS
LF
LF
AC
SY
LOAD
TON
LS
$2,300.00 Ass. 2 field techs@ $55/h; 20 h; $100 FED EX
$180.00 Hotel at $80/night; per diem at $100/day
$25,000.00 Estimated from previous treatability.
$250,000.00 Estimated from previous treatabilily.
$40,000.00 Based on SECD experience at similar sites.
$600,000 Based on Canonie estimate (2/25/92)
$10.00 Based on SECD experience at similar sites.
$10,000.00 Based on SECD experience at similar sites.
$15.00 Based on JJC estimate.
$1.45 Means 1992; 020 550 0700
$1,000.00 Means 1992; 021 108 0400
$9.95 Means 1992; 020 550 1900
$400.00 Hazardous material@ $4/mile for 100 miles;
Means 1991; 020 717 1270.
$45.00 FJB quote from Piedmont facility.
$5,350.00 Based on 3 composites@ $1,450 and $1,000 for
obtaining samples.
LS $100,000.00 Based on JJC estimate for At 211 site.
CY $11.00 Based on SECD experience at similar sites.
TON $3.29 Based on Lobeco estimate (CWM).
- - -
300 Estimated from site map.
1
2,500 Estimated from site map.
-
1,400 Based on ERM report for soil removal.
1.5 Assume 250'x250' required.
550 Estimated from site map.
19 Based on 11 tons/load, Burgess-Mannus esti
(3/31/92); estimate 9-lnch thickness.
206 Based on 1.5 li:ms per cubic yard.
0 Assume not required.
2,200 Based on EPA estimate 2,200 cy (in situ)
with 0% additional for sidewall, etc.
2,970 Assume density ol 1.35 tons/cy.
-- -
FILE: DES2200.\M<.1
BY: GFM
DATE: 04/08192
. SUBC. . .
.+o+,;:c1$1 .TOTAL($)
$2,300
$180
$25,000
$250.000
$40,000
$600.000
$3,000
$10,000
$37,500
$2,030
$1,500
$5,473
$7,500
$9.281
$5,350
$0
$24,200
$9.771
\glm\ciba\ge lgy\cos iest\d es2200. wk:.
-- ------ - ---PROJECT: CIBA-GEIGY (ABERDEEN, NC) Geigy Site
NUMBER: G-1024.00
OPINION OF PROBABLE COST
AL TERN:\ On:-SiteTlierma.1·_oescirpti6ri:Dispiisal ofBuildi_ri!l?'. ·.
····oebiisfo piedmo111iiandiili/kernefs~i11e/t-ii::JX
ITEM·'
NUMBER
1.25 TRANSPORT MATERIAL TO TREATMENT SITE
1.29 INSTALL, MAINTAIN EROSION CONTROLS
1.30 LOAD MATERIAL FOR TRANSPORT
1.31 TRANSPORT TREATED MAT'L TO ORIGIN
1.32 BACKFILL, COMPACT TREATED MATERIAL
1.33 BORROW CLEAN FILL
1.34 BORROW TOP SOIL
1.35 HAUL TOP SOIL
1.41 INSTALL TOPSOIL, FINE GRADE
1 .42 SEED AND FERTILIZE
1.43 30% REMEDIAL CONTR., H&S, ETC.
1.44 CONSTRUCTION OVERSIGHT
2.10 TESTBURNING,START-UP
2.20 THERMALLY TREAT MATERIAL
2.30 CONFIRMATION SAMPLING OF EXCAVATIONS
2.31 ANALTYCAL AND LABOR
2.40 CONFIRMATION SAMPLING OF TREATMENT
2.41 ANALTYCAL
2.42 LABOR
3.01 MODEL AND LOCATE STATIONS
3.02 LEASE AND INSTALL MONITORING STATIONS
UNITS
LOAD
LS
TON
LOAD
CY
CY
CY
CY
CY
SY
LS
DAY
LS
TON
LS
EA
LS
LS
LS
$52.00 Means 1991(0207171270) plus 30%
for H&S.
$12,800.00 Based on GSST estimate.
$3.29 Based on Lobeco estimate (CWM).
$52.00 Means 1991(020717 1270) plus 30%
for H&S.
$5.00 Based on Lobeco estimate (CWM).
$5,35 Common, 1-1/2cy. Means(0222164010)
$14.00 Means 1990: 022 216 7010.
$2.13 12-cy truck; 20-mile round trip; Means 1991
122 266 0560.
,$19.79 Based on GSST estimate.
$0.35 Based on Lobeco estimate (CWM).
$10,595 Use for Hems 1.41 and 1.42.
$850.00 @ $65/h: 10 h/day plus $200 per diem
$50,000.00 Based on SECD experience at simllar sites.
$250.00 Based on Canonie est. (2/25/92) and disc. w/
Ciba-Geigy following previous experience.
$200,000.00 Based on SECD experience at similar sites and
disc. w/ Ciba-Geigy alter previous experience.
$450.00 Todd Scott est. for pesticide scan (2/25/92).
$20,000 Based on SECD experience at similar sites.
$7,900.00 Incl. prelim. siting by modeling and in-the-field
location of 5 stations.
$33,500.00 Incl. construction, install power and meters,
--- - ---
0 Assume on-site treatment.
0
0
2,200
0
1,613
1,613
1,613
9,680
55
2,970
22
Based on 2 acres and 6-inch depth of top soil.
Estimated from site map.
Based on 10 days site prep/exc .• treatment at
5 T/h w/70% serv. factor; 10 days renovation.
Assume one per 100 cy treated.
FILE: DES2200.V\<K 1
BY: GFM
DATE: 04/08/92
SUB-.·
TOTAL($)
$0
$12,800
$0
$0
$11.000
$0
$22,587
$3,436
$31,928
$3.388
$10,595
$47,054
$50,000
$742.500
$200,000
$9,900
$20,000
$7,900
$33.500
:•:TOTAL($)
\gfm\clba\geJ gy\c~ tes tld es2200. w~
&iii iiii iiii --PROJECT: CIBA-GEIGY (ABERDEEN, NC) Geigy Site
NUMBER: G-1024.00
---- --OPINION OF PROBABLE COST
AL TERN ... C)rii.§itf Jh~ffua1 pesoipiiMT pi~~C>si1 cff Byi1~ifig'•· . ·•0Jbiis18iPiedmonlLahdiii1 (Ketilersville;JiC) >• ..
ITEM
3.03 CALIBRATE AND AUDIT STATIONS
3.04 ANALYTICAL COSTS
3.05 OPERATING LABOR
7.01
7.02
7.10
7.11
7.12
7.13
7.14
7.15
8.10
8.11
8.12
8.14
8.15
8.17
8.20
Subtotal, Direct Capital Costs
Indirect Capital Costs
Engineering Services and Related
CONTRACT ASSISTANCE
SURVEYING SERVICES
DESIGN
EXTRACTION SYSTEM
TREATMENT PLANT DESIGN
CIVIL DESIGN
DRAINAGE DITCH DESIGN
AIR MONITORING
REGULATORY ASSISTANCE
PERMITTING
DISPOSAL FACILITY/DEHNR
TREATMENT WORK
AIR MONITORING
FINAL REPORT WRITING
LICENSES
UNITS COST($)/
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
MET logger, labor, space rental.
$4,000.00 Ass. 2 field techs for initial calibration: 1 tech
for audit at mid-way point of project.
$33,000.00 Assume 1/wk for 2 weeks; 1/day for 1 week: and
1/wk for 13 weeks; 5 sta.; partic. and pestic.
$0.00 Assume trained employee to inspect, sample.
$569,168 Based on SEGO experience at similar sites.
$142,292 Assume 5% of Direct Capital Costs.
$750.00 Based on SECD experience at similar sites.
$0.00
$0.00
$7,500.00 Assume evaluation for excavation.
$0.00
$8,500.00 For preparation of monitor plan and progress
reports.
$3,000.00 Based on SECD experience at similar sites.
$25,000.00 Based on SECD experience at similar sites.
$5,000.00 Based on SECD experience at similar sites.
$20,000.00 Based on SECD experience at similar sites.
$113,834 4% of Direct Capital Cost: from Plant Design
--- -
Required for site renovation.
-- -
FILE: DES2200.1t..K1
BY: GFM
DATE: 04/08192
SUB-
TOTAL ($) TOTAL($)>
$4,000
$33,000
$0
$569,168
$2,845.840
$142.292
$750
$0
$0
$7,500
$0
$8,500
$3,000
$25,000
$5.000
$20,000
$113,834
·\g1m\clba\gel ~\= te s t\d !!S2200. w'<.
-PROJECT: CIBA-GEIGY (ABERDEEN, NC) Geigy Site
NUMBER: G-1024.00
iiii ----OPINION OF PROBABLE COST
Al TERN: ()(1.::site jtiefrria.l Desorption;Dispos11I of13Uilciing .·.
· . cieriris tci pieiirhont 1..andtiiri1<einersvii1e; NC) .
ITEM·
8.30 LEGAL SERVICES, INSURANCE LS
. 10.00· 25% CONTINGENC'tlNDIRECTCAPITALCOSTS, LS
Subtotal, Indirect Capital Costs
TOTAL CAPITAL COSTS
and Economics for Chem. Engineers. p. 205.
$28,458 1 % of Direct Capital Cost: from Plant Design
and Economics for Chem. Engineers. p. 205 .
$88,584 25% contingency of Items 7-9.
--- --- -
FILE: OES2200.Vv1<. 1
BY: GFM
DATE: 04/08/92
SUB-
TOTAL($) · TOTAL($)
$28,458
$88,584
$442,918
SJ:288,158
\g1 mlei ba\ge lgy\cos test\d es 2200. w',.
111111 iiiii liiii --PROJECT: CIBA-GEIGY (ABERDEEN, NC) Geigy Site
NUMBER: G-1024.00
-----OPINION OF PROBABLE COST
AL TERN .· _ 6n.,:Site Incineration;· Disposal Of Building ·-·· · ·•-· _•0JbiiJl8piJi1r½oii1•.Laridiffi /k~r'nersVi11e. Nc)t•···
ITEM·•
NUMBER
CAPITAL COSTS
Direct Capital Costs
0.11 SAMPLE COLLECTION AND DELIVERY
0.12 PERD1EM
0.13 TREAT ABILITY STUDY WORK PLAN
0.14 TREAT ABILITY TEST AND REPORT
1.01 EXCAVATION CONTRACTOR
1.02 TREATMENT CONTRACTOR
1.11 UPGRADE ACCESSIBILITY
1.12 INSTALL SITE FACILITIES, DEGON UNITS
1.13 INSTALL NEW FENCING
1.13a REMOVE OLD FENCING
1.14 CLEARING FOR TREATMENT UNIT
_ 1.15 c:iEMOLii'IONIOISPOSAL. ()F CONCRETE SLAB
1.16 DEMOLITION
1.17 DISPOSAL
1.18 TRANSPORTATION
1.19 DISPOSAL
1.19a WASTE CHARACTERIZATION
1.21 CIVIL WORK
1.22 SHEET PILING INSTALLATION
1.23 REMOVE, SEGREGATE, STAGE MATERIAL
1.24 LOAD MATERIAL FOR TREATMENT
LS $2,300.00 Ass. 2 field techs@ $55/h; 20 h; $100 FED EX
DAY $180.00 Hotel at $80/night; per diem at $100/day
LS $35,000.00 Estimated from previous treatability.
LS $250.000.00 Estimated from previous treatability.
LS $40,000.00 Based on SECD experience at similar sites.
LS $1,000,000 Based on Canonie estimate (2/25/92)
LF $10.00 Based on SEGO experience at sfmilar sites.
LS $10,000.00 Based on SECD experience at similar sites.
LF $15.00 Based on JJC estimate.
LF $1.45 Means 1992; 020 550 0700
AC $1,000.00 Means 1992; 021 108 0400
SY $9.95 Means 1992; 020 550 1900
LOAD $400.00 Hazardous material@ $4/mile for 100 miles:
Means 1991; 020 7171270.
TON $45.00 FJB quote from Piedmont facility.
LS $5,350.00 Based on 3 composites@ $1,450 and $1,000 for
obtaining samples.
LS $100,000.00 Based on JJC estimate for Rt 211 site.
CY $11.00 Based on SEGO experience at similar sites.
TON $3.29 Based on Lobeco estimate (CWM).
-- - -
300 Estimated from site map.
2.500 Estimated from site map.
1,400 Based on ERM report for soil removal.
1.5 Assume 250'x250' required.
550 Estimated from site map.
19 Based on 11 tons/load, Burgess-Mannus esti
(3/31/92); estimate 9-inch thickness.
206 Based on 1.5 tons per cubic yard.
O Assume not required.
2,200 Based on EPA estimate of 2,200 cy (in situ)
with 0% additional for sidewall. etc.
2,970 Assume density of 1.35 tons/cy.
--FILE:
BY:
DATE:
.. suss
-INC2200. Y/K 1
GFM
04/08192
JOTAL ($) TOTAL($)
$2,300
$180
$35,000
$250,000
$40.000
$1,000,000
$3,000
$10,000
$37,500
$2,030
$1,500
$5,473
$7,500
$9,281
$5,350
$0
$24,200
$9,771
\gfm\ciba\geigy\cos tes t\!nc2200. wk
.. -----PROJECT: CIBA-GEIGY (ABERDEEN, NC) Geigy Site
NUMBER: G-1024.00
-- - - --OPINION OF PROBABLE COST
AL TERN: .. •· bh~Site)nciriEJration; ·.tJispos~fo(Buildirig{/i .• .. ··· ·.··.··.·.· ···········•oeBris id Pfedmoni Landriii /keirneisJfiief f:.ici••• ···
~-llilWlk~I x ·••r· ;, x ,,··· · > ( G~~~ Ig~~;r1B, •·•··
1.25 TRANSPORT MATERIAL TO TREATMENT SITE LOAD $52.00 Means 1991(020717 1270) plus 30%
for H&S.
1.29 INSTALL, MAINTAIN EROSION CONTROLS
1.30 LOAD MATERIAL FOR TRANSPORT
1.31 TRANSPORT TREATED MAT'L TO ORIGIN
1.32 BACKFILL, COMPACT TREATED MATERIAL
1.33 BORROW CLEAN FILL
1.34 BORROW TOP SOIL
1.35 HAUL TOP SOIL
1.41 INSTALL TOPSOIL, FINE GRADE
1.42 SEED AND FERTILIZE
1.43 30% REMEDIAL CONTR., H&S, ETC.
1.44 CONSTRUCTION OVERSIGHT
2.10 TEST BURNING. START-UP
2.20 THERMALLY TREAT MATERIAL
2.30 CONFIRMATION SAMPLING OF EXCAVATIONS
2.31 ANALTYCAL AND LABOR
2.40 CONFIRMATION SA~PllNG OF TREATMENT
2.41 ANALTYCAL
2.42 LABOR
3.00 AIR MONITORING
3.01 MODEL AND LOCATE STATIONS
3.02 LEASE ANO INSTALL MONITORING STATIONS
LS $12,800.00 Based on GSST estimate.
TON $3.29 Based on Lobeco estimate (CWM).
LOAD $52.00 Means 1991(0207171270) plus 30%
CY
CY
CY
CY
CY
SY
LS
DAY
LS
TON
LS
EA
LS
LS
LS
for H&S.
$5.00 Based on Lobeco estimate (CWM).
$5.35 Common. 1-1/2 cy. Means (022 216 4010)
$14.00 Means 1990: 022 216 7010.
$2.13 12-cy truck: 20-mile round trip: Means 1991
122 266 0560.
$19.79 Based on GSST estimate.
$0.35 Based on Lobeco estimate (CWM).
$10.595 Use for Items 1.41 and 1.42.
$850.00 @ $65/h; 10 h/day plus $200 per diem
$50,000.00 Based on SEGO experience at similar sites.
$500.00 Based on Canonie est. (2/25/92) and disc. w/
Ciba-Geigy following previous experience.
$200,000.00 Based on SEGO experience at similar sites and
disc. w/ Ciba-Geigy alter previous experience.
::$450.00 Todd Scott est. for pesticide scan (2/25/92).
$20,000 Based on SEGO experience at similar sites.
$7,900.00 Incl. prelim. siting by modeling and in-the-field
location of 5 stations.
$33,500.00 Incl. construction, install power and meters,
- ---- --
O Assume on-site treatment.
1
0
0
2.200
0
1,613 Based on 2 acres and 6-inch depth of top soil.
1,613
1,613
9,680 Estimated from site map.
1
38 Based on 10 days site prep/axe., treatment at
10 T/h: 70% serv. factor; 10 days renovation.
1
2,970
22 Assume one per 100 cytreated.
1
FILE:
BY:
DATE:
$0
$12,800
$0
so
$11,000
$0
$?2,587
$3,436
$31,928
$3,388
$10,595
$32.027
$50,000
$1.485.000
$200,000
$9,900
$20,000
$7,900
$33,500
lNC2200.V.'I<. 1
GFM
04/08/92
·· TOTAL($).;
\gfm\ciba\g elgy\c.05 test\lnc2200. w~
------PROJECT: CIBA-GEIGY (ABERDEEN, NC) Geigy Site
NUMBER: G-1024.00
-- ----OPINION OF PROBABLE COST
AL TERN: Oi\t.?/iejhci~~r-~li?n; P\f PP~11 §I ~.uil.di.Qg :: .
•'bebristo Piedmon(Lancitili (Kemersville;•NC)
3.03 CALIBRATE ANO AUDIT STATIONS
3.04 ANALYTICAL COSTS
3.05 OPERATING LABOR
Subtotal, Direct Capital Costs
Indirect Capital Costs
Engineering Services and Related
-·-· E'NG1NEE"Ri;;i(fSEA-YicES:,, ·.
7.01 CONTRACT ASSISTANCE
7.02 SURVEYING SERVICES
7.10 DESIGN
7.11 EXTRACTION SYSTEM
7.12 TREATMENT PLANT DESIGN
7.13 CIVIL DESIGN
7.15 AIR MONITORING
' ~
8.10 REGULATORY ASSISTANCE
8.11 PERMITTING
8.12 DISPOSAL FACILITY/DEHNR
8.13 TREATMENT WORK
8.15 AIR MONITORING
8.17 FINAL REPORT WRITING
8.20 LICENSES
8.30 LEGAL SERVICES, INSURANCE
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
MET logger, labor. space rental.
$4,000.00 Ass. 2 field techs for initial calibration: 1 tech
for audit at mid-way point of project.
$33,000.00 Assume 1/wk for 2 weeks: 1/day for 1 week; and
1/wk for 13 weeks; 5 sla.; partic. and pestic.
$0.00 Assume trained employee to inspect, sample.
$1.191,055 Based on SECD experience at similar sites.
$230,260 Assume 5% of Direct Capital Costs.
$750.00 Based on SECD experience at similar sites.
$0
$0
$7.500.00 Assume evaluation for excavation.
$8,500.00 For preparation of monitor plan and progress
$3,000.00 Based on SECD experience at sifTlilar sites.
$25,000.00 Based on SECD experience at similar sites.
$5,000.00 Based on SECD experience at similar sites.
$20,000.00 Based on SECD experience at similar sites.
$184,208 4% of Direct Capital Cost; from Plant Design
and Economics for Chem. Engineers. p. 205.
$46,052 1 % of Direct Capital Cost; from Plant Design
--- -
" .·;,...; 1 Ill
1
1 Required for site renovation.
1
1
1
1
1
1
1
1
1
1
---FILE:
BY:
DATE:
TOTAL($)
$4,000
$33,000
$0
$1,191,055
$4,605,201
$230,260
$750
so
$0
$7.500
$8,500
$3,000
$25,000
$5,000
$20,000
$184,208
$46,052
INC2200.\M<. 1
GFM
04/08/92
.TOTAL($)•
\gfm\cibalgelgy\costest\lnc2200.wk
------PROJECT: CIBA-GEIGY (ABERDEEN, NC) Geigy Site
NUMBER: G-1024.00
-- - ---OPINION OF PROBABLE COST
AL TERN.·· . On-sii~ 1bdn~r~tiCJ[l:}=>isp9~a.Lo(l3uil~i?g•·•<·:·:·-•·:•·. ii· .. :· >·. .. •. ·•·oebris to Plednionfla:ndfill (Keinefsville;NC:) i .. · .. ·.
· ITEM
NUMBER
Subtotal, Indirect Capital Costs
TOTAL CAPITAL COSTS
and Economics for Chem. Engineers. p. 205.
$132,568 25% contingency of ltems7-9.
-- --- - -
FILE: INC2200.WY-1
BY: GFM
DATE: 04/08/92
TOTAL($)
$132,568
$662.838
. $5,268,038
\g1mlclbalge igy\c05 te s tlin c2200. w~
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
DISMISSAL OF UNSATURATED TRANSPORT MODELING
The basis for establishing subsurface soil remediation requirements was presented
through the VIP transport modeling. This approach was accepted by EPA at another NPL
site in North Carolina (Macon-Dockery, Rockingham, NC) and was initially accepted for
the Geigy Site. The PRPs discussed the model attributes and input parameters with
EPA's RPM and ESD personnel in a conference call in January, 1992. The model was
then accepted for the Geigy site with the exception that the degradation term for
toxaphene be changed from 4 to 10 years (letter from Giezelle Bennett dated January 31,
1992). The 4 year half-life was established through review of the literature and
site-specific calibration, factors that EPA technical personnel have agreed are essential
to accurate modeling. The degradation term is a critical input parameter for transport
modeling and cannot be modified arbitrarily. No explanation for changing the degradation
term was given in EPA's letter and the PRPs sought to establish a technical dialogue to
further discuss the modeling approach. EPA requested numbers from the VIP modeling
based on a 10 year half-life. The PRPs were willing to comply with this request so long
as the EPA's rationale could be explained and discussed within a technical context. While
resolution of this issue was pending, ESD was instructed to conduct their own transport
modeling for the Geigy Site. Mr. Mansour Zakakhani ran EPA's MULTIMED model and
determined that site soils would pose no significant impact on groundwater, based on the
stringent North Carolina groundwater standards. Mr. Zakakhani concluded that this result
was incorrect, since site groundwater contained pesticides. He then ran the model with
no degradation term and arrived at low (ppb) soil remediation levels. At this point, EPA
decided to dismiss both transport models and apply health-based surficial levels to depth.
The PRPs feel that the VIP model and the MULTIMED model are based on sound
technical relationships, have generated equivalent and correct results for the Geigy site,
and should be retained in the evaluation of potential remediation requirements. EPA's
initial modeling effort was not incorrect, since current groundwater concentrations are the
result of pre-removal soil concentrations. Pesticides existed in site soils for over 40 years,
in concentrations above 10 percent (100,000 mg/kg). The majority of site pesticides were
removed during the two re111oval actions, such that toxaphene levels have been reduced·
by 99 percent and total BHC levels by 91 percent. Transport modeling must be based
on existing conditions at the site.
ESD sent SEC Donohue a copy of MULTIMED for use in unsaturated transport modeling.
SEC Donohue subsequently became familiar with operation of the model and discussed
the selection of input parameters with Mr. Zakakhani. Results of the VIP and MULTIMED
models were then compared using different degradation rates at the Geigy Site. The
results are attached. Both models were run using equivalent input parameters and with
the groundwater standards given in the Proposed Plan as the basis for remediation.
ConseNative half-lives were used for toxaphene (10 years) and BHC isomers (2 years),
which exceed those used in the Feasibility Study (4 and 1 years, respectively). In
summary, the comparison showed that:
• the VIP and MUL TIMED models are based on similar transport equations and
provide similar results
I
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• VIP predicts no impact on groundwater at the Geigy Site based on existing
conditions for a toxaphene half-life of 10 years and a BHC half life of 2 years
• MULTIMED predicts no impact from residual BHC levels on groundwater
based on a half-life of 2 years
• MULTIMED predicts a slight exceedance of the groundwater remediation level
for toxaphene using a half-life of 10 years. Subsurface soils would not impact
groundwater if all concentrations greater than 100 mg/kg of toxaphene were
removed.
• site-specific calibration using MULTIMED determined that the half-life of
toxaphene at the Geigy Site is actually less than 10 years.
These results have been confirmed by EPA technical personnel, who stated in a meeting
with EPA in Atlanta regarding the Geigy Site on March 18, 1992 that there was "no dispute
between the models or their results". With this justification of the technical approach and
the results, the PRPs feel that dismissal of the substantiated transport modeling is
arbitrary and that substitution of health-based remediation levels to depth is capricious .
. ATTACHMENT
1. Summary memo regarding comparison of the VIP and MULTIMED transport models
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/
TO:
FROM:
DATE:
RE:
Jim Cloonan
Akram Hossain ~
April 27, 1992
Vadose Zone Transport Modeling for Geigy Chemical
Corporation Site at North Carolina
Vadose zone transport modeling for the Geigy Chemical Corporation Site was performed
by utilizing both VIP and MULTIMED. The objectives of this modeling exercise were to
evaluate equivalence between VIP and EPA's MULTIMED model and to evaluate half life
of toxaphene.
In performing the modeling it was assumed that contaminants are uniformly distributed in
the top 12 feet of the unsaturated soil and average depth to the groundwater table is
approximately 35 feet. Distribution coefficients for both toxaphene and BHC isomers were
approximated to be 5 ml/gm. Net infiltration was assumed to be 1.67 feet/year._
EPA in their effort to develop soil remediation levels by employing MULTIMED assumed
that the distribution coefficient was approximately 13 ml/gm. Based on organic carbon
content of the site soil as reported in RI Report (ERM Southeast, September 1991), and
soil sorption coefficients published in Groundwater Chemicals Desk Reference
(Montgomery & Welkom, 1990), SEC determined that the distribution coefficients could be
at most 5 ml/gm.
Furthermore, EPA assumed that toxaphene and BHC isomers do not undergo any
degradation during transport through the unsaturated soil. A literature survey, however,
revealed that these chemicals do undergo degradation. SEC obtained degradation half life
for BHC isomers from Handbook of Environmental Degradation Rates (Howard et al, 1991)
and that for toxaphene from Hazardous Substance Data Base (MEDLARS, 1991). The
longest half life for BHC isomers was reported to be 413 days. Half life for toxaphene was
reported to span over a range of 1-14 years. ·
In an attempt to approximate the half life for toxaphene, SEC calibrated the VIP model
with preremoval source concentrations that should correspond to the existing concentration
in groundwater. Half life for toxaphene thus approximated was 4 years. EPA, however,
disputed 4 years to be too short and requested that the model be run for 10 years as half
life. EPA did not provide any basis for selecting this half life.
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Memo to Jim Cloonan
April 27, 1992
Page Two
SEC employed EPA's MULTIMED model to predict source concentration of toxaphene
which would correspond to the current groundwater concentration of 10 µg/1. For a half
life of 10 years the source concentration was approximated to be 95 mg/kg. The preremoval
site wide average concentration for toxaphene was, however, estimated to be 1100 mg/kg
which should correspond to a groundwater concentration of 115 µg/1. Toxaphene must,
therefore, have undergone degradation at a higher rate. Consequently, the half life of
toxaphene must be shorter than 10 years.
Please note that VIP and MULTIMED were utilized to predict water phase concentrations
at the bottom of the unsaturated zone. Groundwater concentrations were then
approximated by employing the VHS model. MULTIMED's ability to predict groundwater
concentrations was not utilized. Groundwater concentrations predicted by MULTIMED,
often times, are erroneous and unconservative.
Fate and transport of toxaphene were analyzed for half lives of 4 years and 10 years. BHC
isomers were analyzed for the longest reported half life of 2 years. Results of the analyses
are summarized in the attached table entitled Results of Modeling. An analysis of the
results presented in the attached table reveals that the two models predictions are more or
less the same. Minor variations in the models' output may be attributed to the different
solution techniques used in developing the models. Both the models predict that
groundwater will not be impacted by existing concentrations of BHC isomers in the
unsaturated soil. VIP leads to the same conclusion for toxaphene. MULTIMED, however,
predicts that site groundwater will be slightly impacted by the existing levels of unsaturated
zone toxaphene concentrations. If sources containing more than 100 mg of toxaphene per
kg of soil are r~moved, MULTIMED does not predict any impact on the groundwater.
Therefore, it can be concluded that:
1.
2.
3.
4.
VIP and MULTIMED produce equivalent results for the Geigy
Site
The site specific half life of toxaphene is shorter than 10 years
Site groundwater will not be impacted by the existing levels of
BHC isomers present in the unsaturated soil
Site groundwater may be slightly impacted by the existing
source concentrations of toxaphene as predicted by
MULTIMED. However, there will not be any impact if sources
containing more than 100 mg toxaphene per kg of soil are
removed.
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Memo to Jim Cloonan
April 27, 1992
Page Three
EPA essentially came to the same conclusion that site groundwater will not be impacted by
the existing levels of chemical concentrations in the unsaturated soil. EPA, however, came
to a negative conclusion with regard to biodegradation of toxaphene and BHC isomers. I
believe that EPA did not consider the preremoval concentrations in their modeling. The
existing concentrations of toxaphene and BHC isomers in groundwater correspond to the
preremoval source concentrations in the unsaturated soil.
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Toxaphene
BHC
Isomers
I NOTE:
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Source
Concentration
(Current Average)
7.57 mg/kg
0.31 mg/kg
TABLE 1
RESULTS OF MODELING
Predicted Concentration
in Groundwater (µg/L)
Half Life MULTIMED VIP
4 Years 0.0004 <0.137
10 years 1.050 <0.480
2 Years 0.000 <0.001
Groundwater
Remediation
Level (µg/L)
1.00
0.05
Groundwater remediation levels were obtained from the Proposed Plan Fact sheet for Geigy
Chemical Corporation Site.
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INCLUSION OF UNREVIEWED MATERIALS INTO PAP DOCUMENTS
Cost estimates were added to the PAP Feasibility Study document contained in the
information repository with review or approval of the PRPs. This action presumes
acceptance of the insertion and of the accuracy of the costs by the PRPs. The PRPs
accept neither. These items should be removed from the PAP documents and clearly
labelled as to their source, notably EPA Region IV. The PRPs also request that EPA
declare any additional materials generated outside of the PAP documents (i.e., the RI, RA
and FS) that have been placed in the information repository.