Free Additional Attachments to Main Document - District Court of Arizona - Arizona

Table 5-23 (Continued)

Alternative 1 State
o Agency approval

Alternative 2

Alternative 3
0 Requires PQGWWP or

Alternative 4
o Requires PQGWWP or

Alternative 5.
o Requires FQGWWP or Type 2 water right o Potential adverse impact on other groundwater users

Alternative 6.
0 Requires PQGWWP or

unlikely
o Aquifer use monitored through ADHR

o Requires PQCWWP" or Type 2 water right

Type 2 water right
o High TDS eliminates

Type 2 water right:
o High TDS eliminates steam stripping, UV/ozone, etc.j thus
removal of MEK to

Type 2 water right

o High TDS eliminates
steam stripping, UV/ozone, etc.; thus removal of MEK to

permitting program

health advisory
levels may not be realized

steam stripping, UV/ozone, etc.; thus removal of MEK to health advisory

o Potential adverse
impact on other groundwater users

levels may not be realized
o Substantial permit requirements for
groundwater reinjection must be net o Approval from

health advisory levels may not be realized
o Substantial permit requirements for groundwater reinjection taust be met o Approval from

o Substantial permit
requirements for groundwater rein-

jection nuat be met
o Approval from agencies likely

o Substantial permit requirements for groundwater relnjection must be met
o Approval from

o Substantial permit requirements for groundwater reinJeetion must be met o Approval from agencies likely

agencies likely

agencies likely

agencies likely

Ul I -^1 CT>

Capital Coats

Annual Costs
Present Worth Costs

S 0 $ 30,000 5461,000

$2,583,000 $ 261,000 $5,861.000

$ 4,041,000 $ 576,000 $12,157,000

$ 9,138,000 $ 1,621,000 $27,407,000

$ 503,700 $ 97,000 $1,870,000
o Drinking water end use alternate may decrease capital cost, but sensitive to process instrumentation requirements

$ 514,000 $ 103,400 $2,000,000
o Drinking water end

use alternate may
decrease capital cost, but sensitive to process instrumentation requirements

o ARARs may not be achieved

o AEARs may not be achieved

o EPA target levels and ARARs baaed on MCLe for groundwater achieved at conclusion of remedial action o Meets ARARs for end use of recharge

o EPA target levels and ARARs based on HCI.o for groundwater

o ARARs based on MCLs

for groundwater
achieved at conclusion of remedial

achieved at conclusion of remedial action
o Meets ARARs for

action
o Meets ARARs toe reinjection to Subunit C aquifer o Meets ARARa for drinking water end use

o ARARs based on MCLs for groundwater achieved at conclusion of remedial action
o. Meets' ARAR'o for

reinjectlon to
Submit A aquifer

relnjection to
Subunit C aquifer o Meets ARARa for drinking water end
use

"PQGWWP-Poor Quality Groundmter Withdrawal Permit.

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Table 5-23 (Continued)
Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6

Overall Protection of Human Health and the Environment

o Riaks remain

o Risks remain

o Short-term risks are low with short Imple mentation times for treatment and pro cection of community and workers o Riska are reduced up to the point where extraction to capture TCE in excess of 100 ppb isocon occurs; pump ing to capture TCE to lower concentrations may not result in further risk reduction o Long-term permanent effectiveness i In order to remove HER to draft health advisory levels, additional extracttion and granular activated carbon treatment would be required; the extent of additional extraction has not been precisely calculated.

o Short-term risks are low with short imple mentation times for treatment and pro tection of community and workers o Risks are reduced up to the point where extraction to capture TCE in excess of 100 ppb isocon occurs; pump ing to capture TCE to lower concentrations may not result in further risk
reduction

o Short-term risks are low with short imple
mentation tlmea for treatment and pro

o Short-term risks are
low with short imple mentation times for treatment and pro

tection of cocnounity and workers o Risks are reduced with objectives met in 25 years

tection of community and workers
o Risks are reduced

o Risks to human health are reduced; contamination will still exist in Subunlt A at conclusion of remedial action Ul I -J

with objectives met in 25 years

o Long-term permanent effectiveness o In order to remove MEK to draft health advisory levels, additional extraction and granular activated carbon treatment would be
required; the extent

o Increase risks from migration of contaminants
o In order to remove MEK to draft health advisory levels,
additional extraction and granular

o Increase risks from
migration of

contaminants

activated carbon
treatment would be

required; the extent
of additional extrac-

of additional extraction has not been precisely calculated. Draft health advisory levels are not ARABe and may only be considered as water quality goals.

tion has not been precisely calculated.

Draft health advisory levels are not ARARs and may only be considered as water quality goals.

Draft health advisory levels are not ARARs and may only be considered as water quality goals.

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Table 5-24 -- DETAILED COST ANALYSIS FOR GROUNDWATER ALTERNATIVES ALTERNATIVE 2 1,000-GPM EXTRACTION/AIR STRIPPING/ VAPOR PHASE PHASE CARBON/ --

I I

I
B
IB B
fl B

m

GRANULAR ACTIVATED CARBON POLISHING/
REINJECTION

DIRECT COSTS
Groundwater Extraction System _

I
_ -- --

Nine wells, six of 115-gpm capacity and three of 100-gpm capacity, 7.5 hp, 231 feet of head at $22,000 each; six stainless steel pumps at 115 gpm, three pumps at 100 gpm at $6,000 each; FRP piping, 3-inch to 6-inchdiameter, total length of 10,700 feet at $329,200
Air Stripping System Two FRP air stripping towers, 8.0 feet

$ 567,000
_" _

"*
fl| B,

diameter by 20 feet total height with 15 feet polyethylene packing; 25.00 cfm blower
(30 hp), operating at G/L of 160, with liquid pumps (25 hp), flowmeters, valves piping, and fittings

390,000

Source:

Vendor Information

Vapor Phase Carbon System Skid-mounted vapor phase carbon system sized for 50,000 cfm gas flow, steam boiler, offgas chiller, knockout drum, and preheater Source; Vendor Discussions

I
-- 380,000 « B IB mm I w

Granular Activated Carbon Polishing System

Skid-mounted - two granular activated carbon beds, each 12 feet in diameter, 12 feet in height, containing 38,000 pounds granular activated carbon. Beds piped in series, upflow and backwashable. Includes backwash pumps, pipes, and fittings.
Source: Vendor Discussions

~ ^
"

m
B

244,000

m

Foundation Pad Dimensions: 50 feet by 100 feet x 6 inches with 6-inch curb. Concrete at $125/cubic yard. Float finish. Tanks Two 30,000-gallon epoxy-coated steel feed and treated water tanks One 10,000-gallon epoxy-coated tank

_ "--
15,500

B| B

| | _88,000 ·

I
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Table 5-24 (Continued)
ALTERNATIVE 2 (continued) DIRECT COSTS (continued)

Utilities Hookups 480V/3-phase 600-amp electrical service is provided to the process pad: $30,000 Gas: $9,000 Water: $6,000

45,000

Discharge System
Eighteen 60-gpm-capacity reinjection wells at $20,000/well with 14,000 feet of 8-inchdiameter pipe; includes trenching and

backfilling
Interunit Piping 8 percent of capital equipment cost

1,065,000 140,000

Instrumentation
12 percent of capital equipment cost (not to include discharge system) 140,000

Installation and Testing Mobilization/demobilization: $25,000 , Tank rigging and replacement: $33,000 Process piping: $75,000 Electrical: $25,000 Pressure and water testing: $3,500
Subtotal Direct Costs INDIRECT COSTS Engineering

161,500 $3,236,000

12 percent of total direct costs Startup One Engineer at 50 hours/week at $76/hour

$

345,000 14,000 15,000 43UOOO

Permits
Per onsite estimate

Contingency
15 percent of total direct costs
Subtotal Indirect Costs Total Capital Costs, Alternative 2 $ 805,000

$4,041,000

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Table 5-24 (Continued)
ALTERNATIVE 2 (continued)
ANNUAL COSTS

Monitoring
Groundwater Extraction System Electrical at $0.10/kWh: $43,000 Maintenance (pump and well) at $700/well: $6,300 Maintenance (piping repair) at 1 percent of withdrawal system capital cost: $6,700

$

30,000

56,000

Air Stripping System Electrical: $105,000 Biocide: $87,500 Maintenance at 3 percent of air stripping system capital cost: $11,700 Vapor Phase Carbon System Electrical: $62,500 Maintenance at 3 percent of vapor phase system capital cost $11,400
Granular Activated Carbon Polishing System Includes electrical, regeneration of 51,000 pounds carbon/year at $1.20/pound

204,000

73,900

70,000

Plant Operator 1/2 time to conduct maintenance, repair, and sampling activities
Sampling Two samples per week

15,000

10,000

Waste Disposal Recycling/incineration of concentrated liquid organic at approved facility

5,400
1,500

1 I I 1 I I I I I I 1 I

Tank Maintenance
Painting/cleaning/repair
Process Automation 2 percent of instrumentation capital costs plus periodic cleaning of probes Discharge System Well pump maintenance and pipe repair at 10 percent of discharge system capital costs
Total Annual Costs, Alternative 2
$

I

3,000

I

107.000 576,000

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1 1 1 1 1 1 1 1 1 1 I 1 1 1 1 1 I 1 1

Table 5-24 (Continued) ALTERNATIVE 3 3,000-GPM EXTRACTION /AIR STRIPPING/ VAPOR PHASE CARBON/

GRANULAR ACTIVATED CARBON POLISHING/ REINJECTION DIRECT COSTS

Groundwater Extraction System 24 wells at $20,000 per well; 24 stainless steel pumps, 125 gpm, 15 hp, 300 feet of head at $5,000 each; FRP piping, 3-inch to 14-inch diameter, total length of 20,000 feet: $775,000
Air Stripping System Two 14-foot-diameter by 20-foot-high FRP air

$1,375,000

stripping tower with 15 feet polyethylene
packing. 3,000-gpm liquid flow rate, approximately 60,000-cfm gas flowrate/ tower, TCE influent at 34,000 ppb, blower,

flowmeter, valves, piping, and fittings Vapor Phase Carbon System Skid-mounted, 120,000-cfm gas flow rate, steam boiler, off -gas chiller, knockout drum, and preheater

755,000

675,000

Granular Activated Carbon Polishing System Two parallel skid-mounted trains of two granular activated carbon upflow beds, connected in series, backwashable; containing 38,000 pounds granular activated carbon per bed; includes backwash pumps,
pipes, and fittings

488,000

Foundation Pad 100 feet by 100 feet by 6-inch reinforced concrete, #4 rebar each face, each way, concrete at $125/cubic yard, float finish Tanks Two 45,000-gallon epoxy-coated steel feed and treated water tanks; one 30,000-gallon epoxy-coated backwash tank
Utilities Hookups Includes gas, water, and electrical Interunit Piping 8 percent of capital equipment costs
Ins t rument at ion

28,000

128,000 60,000 164,000 260,000

12 percent of capital equipment costs

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Table 5-24 (Continued)
ALTERNATIVE 3 (continued)

DIRECT COSTS (continued)
Discharge System 48 - 65-gpm-capacity injection wells at $20,000 per well with 14,000 feet of 14inch-diameter pipe. Includes trenching and

backfilling.
Installation and Testing

3,059,000

Includes installation of tanks and interunit
piping, testing of well pumps and pipelines, mobilization, and demobilization Subtotal Direct Costs
180.000 $7,172,000

INDIRECT COSTS

Engineering 12 percent of total direct costs
Startup

^

861,000

One Engineer at 50 hours/week at $70/hour for 4 weeks Permits
Per onsite estimate ( S F )

14,000 15,000 -1.076.000 $1,966,000

Contingency 15 percent of total direct costs Subtotal Indirect Costs

Total Capital Costs, Alternative 3
ANNUAL COSTS

$9,138,000
s:====s=s====

Monitoring

$

30,000

Groundwater Extraction System Electrical at $0.10/kWh: $117,000 Maintenance (pump and well) at $700/well: $17,000 Maintenance (piping repair) at 1 percent of withdrawal system capital cost: $14,000

148,000

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I I I I I I I I I I I I I I I I I I I

Table 5-24
(Continued)
ALTERNATIVE 3 (continued)

ANNUAL COSTS (continued)

Air Stripping System
Electrical: $265,000

Biocide: $263,000 Maintenance at 3 percent of air stripping system capital cost: $23,000 Vapor Phase Carbon System
Electrical: $100,000

$

551,000

Maintenance at 3 percent of vapor phase

carbon system capital costs:

$20,000

120,000

Granular Activated Carbon Polishing System
Electrical: $75,000 Carbon regeneration at 228,000 pounds/year

at $1.20/pound: $274,000 Maintenance at 3 percent of granular activated carbon polishing system: $15,000 Discharge System Pipeline maintenance at 10 percent of discharge system capital costs

364,000

306,000 30,000 10,000

Plant Operator - Full-time Sampling Two samples per week
Waste Disposal

Recycling/incineration of concentrated liquid organic at approved facility Tank Maintenance Paint ing/cleaning/repairing
Process Automation 2 percent of instrumentation system capital

50,000 5,000

costs plus periodic cleaning of probes
Total Annual Costs, Alternative 3

7.000 $1,621,000

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Table 5-24 (Continued) ALTERNATIVE 4 40-GPM EXTRACTION/AIR STRIPPING/ GRANULAR ACTIVATED CARBON POLISHING/

REINJECTION
DIRECT COSTS

Groundwater Extraction System One well of 40 gpm capacity at $20,000; one stainless steel pump, 40 gpm, 7-1/2 hp,
400 feet of head at $5,000; FRP piping, 2--

inch for 400 feet:
Air Stripping System

$3,800

$
^

28,800

One 1-1/2-foot-diameter by 17-foot-high FRP air stripping tower with 12 feet polyethylene packing, 40-gpm liquid flow rate, 535-cfm gas flow rate, 1-hp blower,
TCE influent at 21 ppb, flowmeter, valves,

__ __ 10,000 " = 17,800 _ Bi V ^ · M
8

piping, and fittings Granular Activated Carbon Polishing System Two 2,000-pound granular activated carbon beds connected in series, approximately 4 feet diameter by 11 feet high each, 40-gpm flow rate, TCE influent at <5.0 ppb, 99 percent removal Foundation Pad 50-foot by 100-foot by 6-inch reinforced
concrete with 6-inch curb, #4 rebar each

face, each way, float finish

concrete at $125/cubic yard, 15,500
~ 19,000 ~ 40,000

TM
9 ~ M

Tanks Two 5,000-gallon epoxy-coated steel feed and treated water tanks Two 1,125-gallon epoxy-coated backwash tanks

Utilities Hookups
480V/3-phase 400-amp electrical service transformer to process pad: $25,000 Gas: $9,000 Water: $6,000
Discharge System

m

· «
H

Two 20-gpm-capacity injection wells at
$20,000 each with 6,000 feet of 2-inch-

£ --

diameter pipe; includes trenching and backfilling Interunit Piping FRP piping 2-inch for 5,600 feet; includes trenching and backfilling, 8 percent of
capital equipment costs

150,000

·
^ ·

--
19,300 "

V

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Table 5-24 (Continued)

ALTERNATIVE 4 (continued)

DIRECT COSTS (continued) Instrumentation 12 percent of capital equipment costs
Installation and Testing 15 percent of capital equipment costs
Subtotal Direct Costs
INDIRECT COSTS
Engineering 12 percent of total direct costs Startup 44,000 29,000 36.300

$

365,700

10 percent of capital equipment costs

24,000
15,000 55.000

Permits Per onsite estimate (FS) Contingency 15 percent of total direct costs
Subtotal Indirect Costs
Total Capital Costs, Alternative 4

$ $

138,000 503,700

ANNUAL COSTS

Monitoring Groundwater Extraction System

$

30,000

Electrical at $0.10/kWh:

$5,000

Maintenance (pump and well) at $700/well: $700 Maintenance (piping repair) at 1 percent of withdrawal system capital cost: $2,900 Air Stripping System Electrical: $8,000 Biocide: $3,500 Maintenance at 3 percent of air stripping system capital cost: $500
GAG Polishing System

8,600

12,000

Includes electrical for 1-hp feed and backwash pump and periodic changeout and decommissioning (one bed per year)

4,000

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I
Table 5-24 . B

(Continued)
ALTERNATIVE 4 (continued) ANNUAL COSTS (continued)

·
m

Plant Operator 1/2 time of annual salary of $30,000

~t $

15,000 10,000
1 5 0 , 0

B TM

Sampling Two samples per week
Tank Maintenance Painting/cleaning/repair Process Automation 2 percent of instrumentation capital cost plus periodic cleaning of probes Discharge System 10 percent of discharge piping capital cost Total Annual Costs, Alternative 4 $ := -

Mt B
tt

1 0 0 , 0 15,000 97,000

··

B

I I I I

e i i i i
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*
B

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I I I I I I I I I I I I I I I I I I I

Table 5-24

(Continued) ALTERNATIVE 5
60-GPM EXTRACTION/AIR STRIPPING/ GRANULAR ACTIVATED CARBON POLISHING/ REINJECTION DIRECT COSTS Groundwater Extraction System One well of 60 gpm capacity at $20,000;

one stainless steel pump, 60 gpm, 7-1/2 hp, 400 feet of head at $5,000; FRP piping, 2inch for 400 feet: $3,800
Air Stripping System One 2-foot-diameter by 17-foot-high FRP air stripping tower with 12 feet polyethylene
packing, 60-gpm liquid flow rate, 960-cfm gas flow rate, 1-hp blower, TCE influent at

$

28,800

5 ppb, flowmeter, valves, piping, and fittings
Granular Activated Carbon Polishing System Two 2,000-pound granular activated carbon

10,000

beds connected in series, approximately 4 feet in diameter by 11 feet high each, 60gpm flow rate, TCE influent at <5.0 ppb, 99 percent removal 17,800

Foundation Pad
50-foot by 100-foot by 6-inch reinforced concrete with 6-inch curb, #4 rebar each

face, each way, concrete at $125/cubic yard, float finish
Tanks

15,500

Two 7,500-gallon epoxy-coated steel feed and treated water tanks two 2,000-gallon epoxy-coated backwash tanks

24,800
Utilities Hookups
480V/3-phase 400-amp electrical service

transformer to process pad: $25,000
Gas: $9,000 Water: $6,000

40,000

Discharge System Two 30-gpm-capacity injection wells at $20,000 each with 6,000 feet of 2-inchdiameter pipe; includes trenching and backfilling Interunit Piping
8 percent of capital equipment costs

150,000 19,800

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Table 5-24 (Continued)
ALTERNATIVE 5 (continued)

DIRECT COSTS (continued) Instrumentation 12 percent of capital equipment costs
Installation and Testing
, 29,700
37.000 $ 373,400

15 percent of capital equipment costs
Subtotal Direct Costs INDIRECT COSTS

Engineering 12 percent of total direct costs Startup

$

44,800 24,800 15,000 56.000

10 percent of capital equipment costs

Permits Per onsite estimate ( S F ) Contingency 15 percent of total direct costs
Subtotal Indirect Costs
$ $

140,600 514,000

Total Capital Costs, Alternative 5
ANNUAL COSTS

I I 1 I I 1 I 1 i I

Monitoring Groundwater Extraction System Electrical at $0.10/kWh: $7,500 Maintenance (pump and well) at $700/well: $700 Maintenance (piping repair) at 1 percent of withdrawal system capital cost: $2,900
Air Stripping System Electrical: $12,000 Biocide: $5,300 Maintenance at 3 percent of air stripping system capital cost: $500
Granular Activated Carbon Polishing System

$

30,000

I

11,100

I I

17,800

Includes electrical for 1-hp feed and backwash pumps and periodic changeout and decommissioning (one bed per year)

4,000

I I I

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Table 5-24 (Continued)
ALTERNATIVE 5 (continued)

ANNUAL COSTS (continued)
Plant Operator 1/2 time of annual salary of $30,000

$

15,000 10,000 1,500

Sampling Two samples per week
Tank Maintenance Painting/cleaning/repair
Process Automation

2 percent of instrumentation capital cost plus periodic cleaning of probes
Discharge System 10 percent of discharge piping capital cost
Total Annual Costs, Alternative 5

1,000 15.000 $ 105,400

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will be considered in construction plans. If pump failure were to occur, there would be no short-term release of contaminants pending repair that could pose a threat to public health or the environment. Air stripping with vapor phase carbon (Subunit A groundwater aquifer alternatives only) and granular activated carbon polishing achieve the desired goal of reducing volume and toxicity of the groundwater contaminants sufficiently to meet the applicable and appropriate requirements and will likely exceed those requirements. Treatment of contaminated groundwater by air stripping has been shown to be very effective with removals of organic contaminants often exceeding 99.9 percent. Granular activated carbon polishing for removal of MEK and acetone may be equally as effective. These procedures are relatively predictable, and they have been used successfully at a number of CERCLA sites. Equipment is relatively easy to operate once initial adjustments have been completed. Operator training will be required. Occasional attention for adjustment, monitoring, and testing will be required. With industrial-grade components and regular preventive maintenance, process integrity should be 10 years or more. Scaling of air stripping tower internals has been a problem at some sites. A small amount of antisealant, such as hypochlorite, would be required to remedy this. Also, spent carbon from the granular activated carbon beds will require periodic regeneration. If, in the implementation of the remedial action, EPA determines that air stripping cannot treat MEK to the level required by the ARARs, then hot air stripping and scale control methods will be employed unless EPA determines that the technology is impracticable. If the technology to treat
MEK is impracticable, EPA will waive compliance with the MEK ARAR pursuant to CERCLA Section 121(d)(4), and set an alternative limit that is protective of human health and the

environment. Numerous vendors are available to produce the process components. Conventional materials for construction are required.
All equipment items can be shop-fabricated and skid-mounted, making field erection easier. Construction for implementation of Alternatives 2 and 3 could take up to one year, and 6 months for Alternatives 4 and 5. Catastrophic failure of components is unlikely, and any threat to public health and the environment is relatively low.

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For the Subunit A groundwater treatment alternatives, air emission controls will be placed on the air stripping towers. SARA states that a remedy should reduce the toxicity, mobility, and volume of contaminants. The Maricopa County Air Pollution Control Board requires that all new plants with air emissions "will adequately dilute, reduce, or eliminate the discharge of air pollution to adjoining property." This requirement is also known as reasonably achievable control technology (RACT), and in this case, RACT is air emission controls such as activated carbon adsorption

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6.

REFERENCES

Doull, J., C. D. Klaassen, and M. D. Amdur. ogy. MacMillan. National Research Council (NRC). 1977.

1980.

Toxicol-

Drinking Water and

Health.

Vol 1. Washington, D.C. Drinking Water and

National Research Council (NRC). 1980. Health. Vol 3. Washington, D.C.
Sittig, M. 1981.

Handbook of Toxics and Hazardous Chemi-

cals.

Noyes Publications, Park Ridge, New Jersey.

UniDynamics Phoenix, Inc. 1 8 . Remedial Investigation/ 9 9 Feasibility Study. Phoenix-Goodyear Airport.
U.S. EPA. 1985a. Safe Drinking Water Act. 40 CFR 141, November 15, 1985.

U.S. EPA. 1985b. Chemical. Physical and Biological Properties of Compounds Present at Hazardous Waste Sites. Final

Report. Office of Waste Programs Enforcement, Office of Solid Waste and Emergency Response, Washington, D.C.

U.S. EPA. 1987a. Final Feasibility Study for Section 16 Operable Unit. Goodyear, Arizona. October 19, 1987. U.S. EPA. 1987b. Record of Decision Summary for Section 16 Operable Unit. Phoenix-Goodyear Airport Superfund site. September 25, 1987.
U.S. EPA. 1988. Federal Register. Drinking Water Regulations; Maximum Contaminant Level Goals and National Primary Drinking Water Regulations for Lead and Copper; Proposed Rule 40 CFR Parts 141 and 142. August 18, 1988. U.S. EPA. 1989a. Remedial Investigation/Feasibility Study.

Phoenix-Goodyear Airport. U.S. EPA. 1989b. Database. Integrated Risk Information System (IRIS)

U.S. EPA. 1989. Federal Register. National Primary and Secondary Drinking Water Regulations; Proposed Rule 40 CFR, Parts 141, 142, and 143.

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I I I I I I I I I I

Appendix A INDEX OF ADMINISTRATIVE RECORD

I

I

I I I I f I I
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1

I

Appendix A
INDEX OF ADMINISTRATIVE RECORD

I 1 I I 1 I I I I I I I I I I I
I

Date of Publication Sept. 1983 Ecology and Environment, Inc. Site Inspection Report. Goodyear Aerospace Corporation. September 1983.
Presents sampling results of community wells in the vicinity of the PhoenixGoodyear Airport. Identifies potential waste generators in the area.

June 1984

Ecology and Environment, Inc. Final Workplan RI/FS Litchfield Airport Area. Goodyear. Arizona. June 1984. Describes the activities to be carried out and the methodology for the remedial investigation and feasibility study of the Litchfield Airport Area (later renamed the Phoenix-Goodyear Airport).

June 1984

Unidyanamics Phoenix, Inc. Drv Well Soil Testing Project. Unidynamics Phoenix, Inc. Goodyear. Arizona. Prepared by Western Technologies, Inc. June 1984.

Describes volatile organic compound sampling and results of soil samples collected near dry wells at the Unidynamics facility.
Aug. 1984 Engineering-Science, Inc. Contamination Assessment Plan. August 1984.
Provides revised plan for assessment of groundwater contamination in the vicinity of the Goodyear Aerospace Corporation facility (currently owned by Loral Corporation). This was done as a requirement of Administrative Order 8402 issued by EPA, Region IX.

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Date of Publication
Oct. 1984 U.S. EPA. Final Community Relations Plan. Phoenix-Litchfield Airport Area. Prepared by CH2M HILL. October 1984. m |f

Prepared as part of Phase I of the RI/FS to provide a means of gathering background, site history, and a discussion of the concerns of interested parties.
Nov. 1984 U.S. EPA. Quality Assurance Project Plan. Indian Bend Wash and Phoenix-Litchfield Airport Area Sites. Prepared by Ecology and Environment, Inc. November 1984.

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Describes procedures for ensuring, quality control and reliability of sampling procedures, field measurements, equipment maintenance, analytical procedures, data management, and document control.
1985 City of Goodyear. Comprehensive Plan. of Goodyear. Arizona. 1985. _ City

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A TM

Presents expected future population growth, distribution, and land use.

Jan.

1985

Unidynamics Phoenix, Inc. Results of the First Phase of the Hydrogeologic Studies at the Unidynamics Phoenix« Inc., Goodyear Facility. Prepared by Dr. Kenneth D. Schmidt. January 1985.

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Provides results and hydrogeologic interpretations from the drilling and sampling of four monitoring wells at the Unidynamics site.
May 1985 Goodyear Aerospace Corporation. Evaluation of Soils and Shallow Groundwater Contamination. Prepared by Engineering-Science, Inc. Mav 1985. May 1985.

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Date of Publication
Presents test locations, methods, and results of the soil sampling and piezometer installation program conducted at the Goodyear Aerospace facility. July 1985 Unidynamics Phoenix, Inc. Results of Continued Remedial Investigation of the Unidynamics-Phoenix. Inc. site. Prepared by Dames and Moore. July 1985.
Presents results for the drilling and
sampling of onsite monitoring wells,

aquifer testing, and water level measurements.

Aug.

1985

Goodyear Aerospace Corporation. Remedial Investigation, Phase I Results, Contamination Assessment Report. Goodyear Aerospace Corporation. Litchfield Park. Arizona. Prepared by Engineering-Science, Inc. August 1985. Presents results of Phase I drilling and depth-specific monitoring well installation. Includes water quality and aquifer testing results.

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Jan.

1986

U.S. EPA. Task 5.3 Phase I Data Summary/ Report. Phoenix-Litchfield Airport Area Remedial Investigation. 2 Volumes. Prepared by Ecology and Environment, Inc. January 17, 1986.

Presents data regarding aquifers, soil materials, and contamination beneath the PGA area. Jan. 1986 U.S. EPA. Task 4.0 Source Verification. Field Investigation. Phoenix-Litchfield Airport Area Remedial Investigation. 2 Volumes. Prepared by Ecology and Environment, Inc. January 31, 1986.

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Date of Publication
Provides a history of hazardous waste disposal practices, assessment of known and suspected contaminant source areas, and a determination of other potential sources .
Feb. 1986
Unidynamics Phoenix, Inc. Soil Gas Investigation Report. Unidynamics Phoenix, Inc., Goodyear. Arizona. Prepared by Tracer Research Corporation. February 1986.

Discusses soil gas sampling and mobile analysis conducted at the Unidynamics facility.

m

·

Apr. 1986

U.S. EPA. PLA Sampling Plan. Prepared by Ecology and Environment, Inc. March 19, 1986.
Provides objectives, methods, and procedures for semiannual well water sampling and analysis. Sampling was done in April 1986.

Oct. 1986

U.S. EPA. Superfund Public Health Evaluation Manual. Office of Emergency and Remedial Response, Office of Solid Waste and Emergency Response, Washington, D.C. October 1986.

Establishes framework for public health evaluations at Superfund sites.
Oct. 1986
U.S. EPA. Technical Memorandum; Results of Soil Gas Sampling and Analysis. PhoenixLitchfield Airport Remedial Investigation Phase II, Stage 1. Prepared by CH2M HILL. October 3, 1986. Discusses soil gas sampling and mobile analysis conducted at the PGA superfund site from July 17 to 25, 1985.

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Date of Publication
Dec. 1986

Goodyear Aerospace Corporation. Evaluation of Logging and Depth-Specific Sampling of Goodyear Aerospace Corporation Production Wells. Prepared by Engineering-Science, Inc. December 1986. Presents results and interpretations of geophysical logging and sampling of production wells at the former GAG facility.

Feb. 1987

U.S. EPA. Soil Gas Technical Memorandum RI/FS. Phoenix-Goodyear Airport. Prepared by CH2M HILL. February 27, 1987.
Discusses soil gas and mobile analysis conducted at the PGA Superfund site from January 3 to 22, 1987.

June 1987

U.S. EPA. Soil Sampling Plan. PhoenixGoodyear Airport RI/FS. Prepared by CH2M HILL. June 29, 1987. Presents locations, rationale, and methodology for soil samples collected from the southern portion of the study area.

July 1987

Unidynamics Phoenix, Inc. Soil Sampling Plan for Unidynamics Facility. Prepared by Dames and Moore. July 1987.

Presents the locations, rationale and methodology for sampling and analysis of the Phase I soil sampling.
July 1987

U.S. EPA. Interim Guidelines on Compliance with Applicable or Relevant and Appropriate Requirements. July 9, 1987.

Provides new guidance on selection of ARARs and MCLs as cleanup standards for Superfund sites. Incorporates SARA.

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Date of Publication
Sept. 1987

.U.S. EPA. Record of Decision Summary for Section 16 Operable Unit. Phoenix-Goodyear Airport Superfund Site. Prepared by CH2M HILL. September 25, 1987. Presents EPA's preferred remedy for the Section 16 Operable Unit.

Oct. 1987

Loral Corporation. Environmental Audit Sampling Results. Loral Systems Division, Litchfield Park, Arizona. Prepared by Moretrench Environmental Services. October 1987.
Presents analytical methods, QA/QC procedures and results for 15 soil samples collected at the former Goodyear Aerospace facility.

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Oct. 1987

U.S. EPA. Technical Memorandum Results of the PGA Soils Investigation. Prepared by CH2M HILL. October 5, 1987.
Presents the results of soil samples collected from the south portion of the study area during June and July, 1987.

~

Oct. 1987

U.S. EPA. Final Feasibility Study for Section 16 Operable Unit. Goodyear, Arizona. Prepared by CH2M HILL. October 19, 1987.

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Discusses and screens remedial actions for providing an expedited cleanup of the Section 16 Operable Unit.
Jan. 1 8 9 8 U.S. EPA. Final Air Sampling Plan. PhoenixGoodyear Airport RI/FS. Prepared by CH2M HILL. January 1 8 . 9 8

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Presents locations, rationale, methodology, and analytical protocol for ambient air samples collected from the southern portion of the study area.

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1 I I I

Date o£ Publication Jan. 1988 U.S. EPA. Field Sampling Plan for Geophysical Logging and Depth Specific Sampling. Phoenix-Goodyear Airport Site. Prepared by CH2M HILL. January 20, 1988.

Details procedures for logging and sampling of three production wells within the PGA site boundaries.
March 1988 Goodyear Tire and Rubber Company. Phase II Remedial Investigation Report PhoenixGoodyear Airport Site. Prepared by Engineering-Science, Inc. March 1988.

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Discusses the installation and sampling of 19 monitoring wells, logging and sampling of 6 production wells, and sampling of sewers. Presents water quality results.

April 1988

Arizona Department of Environmental Quality. Air Toxics Monitoring Study of Phoenix Urban Area. April 1988. Presents findings of an air monitoring program conducted in and around the Phoenix metropolitan area.

April 1988

U.S. EPA. Technical Memorandum Installation of Phase II. Stage 2. Groundwater Monitoring Wells. Phoenix-Goodyear Airport RI/FS. Prepared by CH2M HILL. April 25, 1988.

Discusses the installation of monitoring wells installed at the PGA site from March 15, 1987, to January 1988. Presents results of geophysical logging, aquifer testing, and water quality sampling.

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Date of Publication
August 1988

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Unidynamics Phoenix, Inc. Results of the Phase II Groundwater Investigation.
Unidynamic s RI / FS . Prepared by Dames &

Moore. August 2, 1988.
Discusses installation of nine monitor-

ing wells near the Unidynamics facility. Includes water quality data, water level data, and results of geophysical logging and aquifer testing. December 1988 U.S. EPA. Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sites. Office of Emergency and Remedial Response. December 1988. This guidance focuses on policy and decisioninaking issues associated with
the development, evaluation, and selection of groundwater remedial actions at Superfund sites.

January 1989 Arizona Department of Health Services. Letter from Norman J. Peter son to Peterson t Jess A. Brown. January 3, 1989.

A

This letter explains the rationale and lists the ADHS health-based soil cleanup guidance levels for specific VOCs and pesticides.
June 1989 U.S. EPA. 9 volumes. Phoenix-Goodyear
Airport Remedial Investigation/Feasibility

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Study. Public Comment Draft. Volumes I through VI prepared by CH2M HILL. Volumes VII and VIII prepared by Unidynamics Phoenix, Inc. Volume IX prepared by the Arizona Department of Water Resources. June 7, 1989. Presents the results of the remedial investigation and contaminant transport modeling efforts. Develops and evaluates alternatives for remedial action at the site.

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Date of Publication
June 1989

U.S. EPA. Reporter*s Transcript of Proceedings Phoenix-Goodyear Airport Area Superfund Site Final Remedy. Prepared by Brush and Terrell, P.C. June 21, 1989.

This is a transcript of the proceedings of the Public Meeting held by EPA on June 21, 1989, at 7:00 p.m. in the Goodyear Community Center to discuss the PGA final remedy. July 1989
Unidynamics Phoenix, Inc. Letter from William Donahue to Mr. Jeff Rosenbloom, U.S. EPA, including attachments. July 17, 1989.
Discusses technical issues associated with the EPA preferred alternative for the northern portion of the PGA site in · the vicinity of the Unidynamics facility.

August 1989

Unidynamics Phoenix, Inc. Letter from Michele B. Corash, Counsel to Unidynamics to Hugh Barroll, Esq. and Jeff Rosenbloom, U.S. EPA, including attachments. August 1, 1989.
Discusses legal issues associated with the EPA preferred alternative for the northern portion of the PGA site in the vicinity of the Unidynamics facility.

August 1989

U.S. EPA. Memorandum from CH2M HILL to EPA and the PGA Project Committee, including attachments. August 24, 1989.

This memo includes an estimate of the mass of VOCs in the vadose zone and the estimate of migration of VOCs from the vadose zone to the groundwater.

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1
Date of Publication August 1989
Unidynamics Phoenix, Inc. Letter from Michelle Corash, Counsel to Unidynamics Hugh Barroll, Esq., U.S. EPA. August 25,
1989.

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Discusses ARARs for the PGA Superfund site.

August 1989

State of Arizona. Letter froriTLinda Pollock, Assistant Attorney General to Hugh Barroll, Esq. and Jeff Rosenbloom, U.S. EPA. August 30, 1989, including an enclosure.

Response to Unidynamics discussion of ARARs for the PGA Superfund site. September 1989
U.S. EPA. Memorandum from CH2M Hill to EPA, including attachments. September 7, 1989.
This memo presents responses to the Unidynmaics technical comments submitted July 17, 1989.

September 1989

U.S. EPA. Memorandum to the file, including attachments. September 22, 1989.
This memorandum is a response to legal issues regarding the PGA Record of Decision.

September 1989 Currently being updated

Record of Decision. CH2M Hill. Technical Data Management II computerized data base located in CH2M Hill's Phoenix and Redding offices.
Contains all water elevation and quality data from ADHS, potential responsible parties, and EPA sampling. =1981-present

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The following items are not included in the Administrative Record File since they are included in the "Compendium of CERCLA Response Selection Guidance Documents" located at EPA Region IX headquarters at 215 Fremont Street, San Francisco,
California 94105.

Sept. 1984

U.S. EPA. Health Effects Assessment Documents. ORD, OHEA, ECAO.

September 1, 1984.

I I

October 1985

U.S. EPA. CERCLA Compliance with Other Environmental Statutes. Porter, J. W. Office of Solid Waste and Emergency Response. October 2, 1985. U.S. EPA. Guidelines for Exposure Assessment. Federal Register. September 24, 1986, page 34042. U.S. EPA. Superfund Public Health Evaluation Manual. Office of Emergency and Remedial Response. October 1, 1986. U.S. EPA. Interim Guidance on Superfund Selection of Remedy. Porter, J. W. Office of Solid Waste and Emergency Response. December 24, 1986.

Sept. 1986

I
October 1986

I I I I I I
May 1987
Date of Publication December 1986

May 1987

U.S. EPA. Final Guidance for the Coordination of ATSDR Health Assessment Activities with the Superfund Remedial Process. Porter, J. W. OSWER, OERR, ATSDR. May 14, 1987. U.S. EPA. EPA's Implementation of the Superfund Amendments and Reauthorization Act of 1986. Thomas, L. M. May 21, 1987. U.S. EPA. Alternate Concentration Limit Guidance Part 1. ACL Policy and Information Requirements. Office of Solid Waste, Waste Management Division. July 1, 1987. U.S. EPA. Superfund Exposure Assessment Manual. Office of Emergency and Remedial Response. April 1, 1988.

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July 1987

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May 1988

U.S. EPA. Interim Guidance on Potentially Responsible Party Participation in Remedial Investigations and Feasibility Studies. Porter, J. W. Office of Solid Waste and Emergency Response. May 16, 1988. U.S. EPA. Community Relations in Superfund; A Handbook (Interim Version). Office of Emergency and Remedial Response. June 1, 1988. U.S. EPA. CERCLA Compliance with Other Laws Manual. Office of Emergency and Remedial Response. August 8, 1 8 . 9 8
U.S. EPA. Integrated Risk Information System (IRIS). Office of Health Effects Assessment.

June 1988

August 1988

None

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Appendix B RESPONSE SUMMARY

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Appendix B
RESPONSE SUMMARY

1

PHOENIX-GOODYEAR AIRPORT REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS) OVERVIEW

I

i I I I i i i i i t i i i i i

EPA received comments during the public comment period for the June 1989 Draft RI/FS report. The public comment period was held from June 7 through July 7, 1989. Comments were received from state agencies, potentially responsible parties, and members of the community. EPA also received comments at the Public Meeting held on June 21, 1989, at the Goodyear Community Center. All comments received are responded to herein.
COMMENTS AND EPA RESPONSES

COMMENTS FROM ADEQ

Volume I
1. CHAPTER 2. PAGE 2-27. PARAGRAPH 3

In order to be consistent, provide the sampling depths for the results for Sludge Bed No. 2.
RESPONSE

The sampling results and depths for both sludge beds are presented in Figure 2-11 on page 2-29.
2. TABLE 2-8

The soil volumes calculated in this table differ significantly from the volumes calculated by ICF Technologies, Inc., in the Chrome Sludge Drying Bed Feasibility Study. How were the volumes calculated? Provide a page of calculations or a description of the methodology utilized.
RESPONSE

Appendix K of PGA RI/FS details the methodology used to derive the soil volumes presented in Table 2-8. Only the EPA RI soil data were available at the time this

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estimate was prepared. ICF Technologies, Inc., collected additional samples as part of their work at the sludge drying beds. They used this additional information to calculate their volume estimates. The ' only volume presented in the chrome sludge bed FS is for the soil contaminated above ADHS levels. ICF estimated this volume to be 4,800 cubic yards for soils above the chromium level. The estimate in the RI/FS is 2,200 cubic yards.
3. CHAPTER 2. PAGE 2-51. PARAGRAPH 6

Is there a possible explanation for the anomalously high value for cadmium in boring 21-EP-3?
RESPONSE

There could be a number of reasons for the cadmium value, but explanations at this point would be purely speculative. Data gathered during the RI suggest that outside of the area around the former sludge drying beds, cadmium is not a problem.
CHAPTER 2. PAGE 2-62. PARAGRAPH 4 _ -------------------------- -------------------- Please describe the sanitary wastewater bed. Has it been referred to before? Is it the same as the existing wastewater ponds, or the sludge drying beds?

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RESPONSE

The sanitary wastewater bed is an existing facility on the former GAG property. It is labeled as the wastewater sludge bed on Figure 1-7, page 1-21.
CHAPTER 3. PAGE 3-32. TABLE 3-10

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The table repeats starting with well (B-1-D16AAB5 (GMW-8) to the end of the table.
RESPONSE

£
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Comment noted.
the +-aVi1 a table.
t-t-id

The repetition has been removed from

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6.

CHAPTER 3. PAGE 3-40. FIGURE 3-11

Carbon tetrachloride has been identified as a contaminant in the groundwater and in concentrations exceeding SDWA/MCLG. Should it be included in this table?
RESPONSE

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Carbon tetrachloride is the seventh entry on the table.
7. CHAPTER 3. PAGE 3-41. TABLE 3-12

The title should read "Applicable or Relevant and Appropriate". The ARAR exceeded by chromium (total) is the MCL not the MCLG.
RESPONSE

Table 3-12 is revised to reflect these changes.
8 . CHAPTER 3. PAGE 3-94. PARAGRAPH 5

There seems to be a disagreement between statements made here and on page 3-38, paragraph 5, as to the amount of discharge contributed by the MFU during pumping of well RID 5.6W, 3.5N.
RESPONSE

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The amount of discharge contributed by the MFU during pumping of the well is more accurately stated as 25 percent as it is on page 3-94. Refer to pages 0-547 to 0-567 in Appendix 0 for a complete discussion, including the zones of water production, for well RID 5.6W, 3.5N.
9. CHAPTER 3. PAGE 3-110. TABLE 3-31

Table 3-3 indicates one well exceeds the ARAR TCE concentration of 5 ug/1 but is not included in this listing.
RESPONSE More than one well listed in Table 3-3 exceeds the ARAR value for TCE. None of these are appropriate to include in Table 3-31 since Table 3-31 is a listing of wells with unknown screened intervals that exceed detection limits for all contaminants. The information

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presented in Table 3-3 is unrelated to information in Table 3-31. Volume II
1. CHAPTER 5. PAGE 5-16. PARAGRAPH 5 I

What constitutes "significant" groundwater contamination? If only one monitoring well exists in the MFU, then how can a determination be made in relation to the impact of the site on the MFU? A brief discussion of the lack of data would clarify the statement that the MFU is "believed" to be free from adverse impact by the PGA site.
RESPONSE

The term "significant" as used here implies the contamination is high enough to cause adverse environmental or public health impacts or is above ARARs. The current data available on the MFU are limited, but include information from wells other than just the monitoring well. See pages 3-100 to 3-105 -for a discussion of the MFU data gathered during the RI. It is not anticipated at this time that remedial actions for this unit will be required.
2. CHAPTER 5. FIGURE 5-1 Inconsistencies exist between this figure and the supporting text for identification and screening of technologies for soils. Typographical errors are common in this figure.

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Biological treatment as a remedial technology has been screened out, yet the figure indicates that it is potentially viable. An additional comment to support the decision to drop the alternative from further consideration would be beneficial.
The figure indicates that removal of soils is potentially viable but the alternative is not discussed in the text. RESPONSE

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The typographical errors are corrected on the figure. The figure correctly shows biological treatment as being screened out. The screening comments are changed

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to reflect that biological treatment is not a proven technology for use with the contaminants present at the site. The excavation technology is retained for further analysis and is discussed in Chapter 6 in the development of alternatives.
CHAPTER 5. FIGURE 5-2. GROUNDWATER END USE RECHARGE/REINJECTION

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In accordance with the Environmental Quality Act, Title Section 49-243.B.2 and 3, subsurface and surface discharges cannot degrade an aquifer that is protected for drinking water use. Since the Environmental Quality Act protects all aquifers for drinking water use (A.R.S. Title Section 49-224.B.), treated water would be required to meet drinking water standards or aquifer water quality standards prior to recharge or

reinjection. Further, if the water is reinjected or
recharged offsite (outside the study area boundaries) then an Aquifer Protection Permit/Groundwater Quality Protection Permit will be required for the activity.
DISTILLATION & EVAPORATION

·

Any additional comments supporting the screening out of distillation and evaporation would be helpful. RESPONSE

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4.

If reinjection is part of the selected remedy, then the

appropriate treatment levels will be required. Pages 5-32 and 5-34 expand on the reasons behind the screening of the distillation and evaporation option.
CHAPTER 5. PAGE 5-23. PARAGRAPH 5

I I

Also note that if the treatment alternative results in increased concentrations of constituents (i.e., higher TDS), then the treated water could not be re-introduced to the aquifer. (In accordance with A.R.S. Title Section 49-243.B.2 and 3, the aquifer cannot be degraded with respect to aquifer water quality standards.) RESPONSE

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The paragraph states that no degradation of aquifer quality is acceptable.

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5.

CHAPTER 5. FIGURE 5-3

In order to meet the substantive requirements of the Aquifer Protection Permit/Groundwater Quality Protection Permit Program, in-flow and out-flow meters might be required on the system to measure and record quantities of treated water.
RESPONSE

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m

These items may be included during the remedial design phase. No change to Figure 5-3 has been made.
6. CHAPTER 5. PAGE 5-28. PARAGRAPH 3

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I

Could air-stripping result in a waste stream from accumulation of scaling deposits or from precipitate formation? If so, this could be an added disadvantage.
RESPONSE -

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The text does refer to the possibility that cleaning of scaling and/or deposits may be required. This would likely create a waste stream requiring disposal but the nature of the waste stream and the problems associated with disposal cannot be predicted without actual field operating experience.
7. CHAPTER 5. PAGE 5-28. PARAGRAPH 5 _

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Is the handling of spent carbon prior to disposal or regeneration a potential hazard? Would the material be regulated by the Resource, Conservation and Recovery Act (RCRA) (See #14)?
RESPONSE

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Handling of spent carbon could present a hazard and would require the same health and safety procedures as handling of other hazardous wastes. However proper design can minimize the handling required. The spent carbon would be regulated under RCRA since it would contain a listed hazardous waste.
8. CHAPTER 5. PAGE 5-31 .

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Capping alternatives are broken down into costs. Why wasn't the same approach used for the treatment alte rnat ive s ?

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RESPONSE

Capping is not discussed on page 5-31. Page 5-31 discusses treatment technologies for groundwater. No costs are given in Chapter 5 for any technologies. Chapter 6 provides relative costs for all alternatives. Order-of-magnitude cost estimates for the alternatives are provided in Chapters 7, 8, 9, and 10.
9. CHAPTER 5. PAGE 5-31. PARAGRAPH 3

Does bed backwashing generate a waste stream? please discuss the possible ramifications. RESPONSE

If so,

Backwashing may be required if suspended solids in the influent water are high enough to build up over the life of the carbon bed such that they plug the bed prior to exhausting the carbon capacity. Backwashing
of the bed is usually avoided if possible either through careful sizing of the bed or through installation of a separate upstream filter. Any suspended solids collected would be a waste stream requiring disposal. Generally, the suspended solids would consist of clay and silt particles which may or may not retain detectable quantities of contaminants.

The disposition of the waste cannot be determined
without actual field operating experience.
10. CHAPTER 5. PAGE 5-37

It seems reasonable to combine reverse osmosis with
other treatment methods to remove chromium. RESPONSE

Chromium concentrations can be reduced using reverse osmosis and other treatment techniques; however, there is no apparent need to treat chromium at the site above and beyond the Section 16 Operable Unit Remedial Action.
11. CHAPTER 6. PAGE 6-25. PARAGRAPH 3

This section evaluates chemical-specific ARARs. Do any
action- or location-specific ARARs apply to potential remedial actions for groundwater? (For example,

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remedial actions performed "onsite" are only required to satisfy the substantive requirements of permits. If, however, water were to be recharged outside the study area boundaries, then the CERCLA permit exemption would no longer apply and an Aquifer Protection Permit/Groundwater Quality Protection Permit would be required for the activity.)
RESPONSE -

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There are action- and location-specific ARARs ~for all the potential remedial action alternatives. A complete evaluation of ARARs appears in Appendix I. Only the chemical-specific ARARs are discussed on page 6-25 since they are pertinent to the discussions defining target areas which follow in Chapter 6.
12. CHAPTER 7. PAGE 7-8. PARAGRAPH 2 ,

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It would be expected that the estimated total mass of VOCs in the soils for Target Area 2 should be greater than that for Target Area 1 and less than Target Area 3. Is the 104,400 pounds correct?

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RESPONSE

_

Page 7-8 of the Public Comment Draft RI/FS is the back of Figure 7-3 and has no text. Page 7-18 of a previous draft (Project Committee Draft, March 1989) contained an error in the estimated mass of VOCs present in Target Area 2. This error was corrected, but estimated masses of VOCs for each target area were not included in the Public Comment Draft. This was done since the total estimate of VOC mass in the vadose zone is being revised based on discussions with the PGA Project Committee. Revised mass estimates will be distributed to the project committee when they are available.

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13.

CHAPTER 7, PAGE 7-16. PARAGRAPH 6

_.

Are carbon regeneration facilities subject to RCRA or Air Quality regulations?
RESPONSE . -

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Generally, Superfund sites are exempt from obtaining permits for operation within the site boundaries; however, they must comply with the substance of the law.

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Offsite discharges do require that all necessary permits and regulations be obtained. Specifically, any onsite carbon regeneration facility would need to comply with the provisions of RCRA if the spent carbon were determined to be a listed hazardous waste, as is expected, but would not need to be permitted -as a TSD facility. Any air emissions from the facility would have to comply with all federal, state,

and local air quality regulations and would also have to meet all permitting and monitoring requirements.
14. CHAPTER 7. PAGE 7-28. PARAGRAPH 2

The ponds should be examined to determine= if leakage and infiltration are occurring regardless of the soils alternative selected.
RESPONSE

The area around the former sludge drying beds, including the ponds, is being considered separately for remedial action. Goodyear Tire and Rubber is conducting that work. It is agreed that pond liner integrity must be assessed regardless of the remedial action chosen, and that the ponds may have an effect on the sitewide soils and groundwater remedial actions. Therefore, there is a strong interest to determine that the ponds are not leaking and allowing infiltration. These concerns have been expressed to Goodyear during review of their chromium sludge bed FS.
15. CHAPTER 7. PAGE 7-44

Should this be labeled as Table 7-9 not 7-1?
RESPONSE

Yes.
16.

Table number is revised.

CHAPTER 7. TABLE 7-8 AND 7-9

Capital costs calculated in Table 7-9 are not the same as those listed in Table 7-8. Why do these differ? RESPONSE

Capital costs listed in Table 7-9 are only the estimated construction costs. Table 7-8 lists the total

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capital costs which include construction, mobilization/demobilization, permitting and legal, bid and scope contingencies, services during construction, and engineering and design costs.
17. CHAPTER 8. FIGURES 8-10. 8-12. AND TABLE 8-2_

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Calculations of rates of aquifer restoration to ARAR concentrations indicate remedial action Alternative 4 is more effective than Alternatives 5 and 6 which utilize more wells. This suggests that the location of the new extraction wells has more of an impact on the clean-up time than the number of wells.
RESPONSE

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Alternatives 5 and 6 were developed for the restoration of the aquifer to background concentrations. This requires extraction of a larger volume of water than required to restore the aquifer to ARARs. The wells considered in Alternatives 5 and 6 were placed to achieve capture of this larger volume of water. The figures show that Alternatives 5 and 6 are effective for the ARAR target area, but not as effective as Alternative 4, which was developed specifically for restoration of the aquifer to ARARs. It is not appropriate to draw conclusions about extraction impacts by comparing Alternatives 5 and 6 to 3 and 4 since they were developed for different target areas.
18. CHAPTER 8. PAGES 8-40. 8-41. TABLE 8-6 _

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TIME UNTIL PROTECTION IS ACHIEVED

The time required to reduce the contaminant levels in the aquifer to below ARAR concentrations for Alternatives 4, 5, and 6 is incorrect. Table 8-5 and Figures 8-10 and 8-12 indicate time is 38, 65, and 40 years, respectively.
RESPONSE

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Table 8-6 has been revised to correct the typographical error.
19. CHAPTER 8. PAGE 8-4. TABLE 8-6 PERMANENT AND SIGNIFICANT REDUCTION OF TOXICITY, MOBILITY, OR VOLUME

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