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

o

Accelerated reduction of contamination to exceed ARARs--continued use of existing wells and nine additional extraction wells (Groundwater Alternative 6)

Alternatives 5 and 6 are associated with two groundwater level-of-treatment alternatives. The groundwater level-oftreatment alternatives for Subunit B/C are;
o Removal until water from monitoring wells is of a quality that meets ARARs

o

Removal until levels of VOCs in water from monitoring wells are below detection limits, which is the background quality of groundwater in the area

Water Treatment Technologies. The possible technologies identified to treat water are:

o o o o o o o o o o o

Air stripping Activated carbon Reverse osmosis Distillation Critical fluid extraction Liquid-liquid extraction Photolysis Aerobic biological treatment Anaerobic biological treatment Steam treatment Wellhead treatment

Water End Use Alternatives. The principal objective of a water end use alternative is to provide an implementable, effective, economical, and safe means of disposal for extracted groundwater. Alternatives for water end use fall into the following basic categories: o Agriculture--Treated water could be used for irrigation and crop production. Water may not require treatment prior to delivery to agricultural users. Industrial--Treated water could be used for industrial processes or washdown. Municipal--Treated water could be used by a municipality for domestic supply, groundwater recharge, or to satisfy water requirements or certain types of water rights.

o o

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o

Recreational--Treated water could be used for creating lakes, irrigating public parks and golf courses, and other recreational uses.

o

Reinjection--Treated water could be reinjected into the aquifer at various locations in the
vicinity of the site. Surface discharge--Treated water could be discharged to waste in the Agua Fria or Gila Rivers for diversion downstream for municipal or other use, or to waste in these channels.

o

A number of engineering constraints related to water end-use alternatives were identified, and they will affect the costeffectiveness of the end use alternatives. A summary of engineering constraints is presented in Table 5-6. Public health and environmental considerations by water use type were also evaluated, and these are presented in Table 5-7. Screening of Alternatives

As noted previously, under SARA and CERCLA, remedial actions are those responses to releases that are consistent with a permanent remedy to prevent or minimize the release of hazardous substances, pollutants, or contaminants so they do not migrate to cause substantial danger to present or future public health or welfare or the environment. Alternatives are screened based on their ability to meet the above-stated requirements, and those stated previously, and to meet the remedial response objectives for groundwater.
Based on the summary presented in Table 5-8, several alternatives were eliminated because they fail to satisfy the remedial response objectives. These include: o o o Construction of a containment slurry wall Groundwater pumping to control taminants beyond the 5 ppb TCE Groundwater pumping to control contamination beyond the areas migration of conboundary migration of the of detected TCE

Extraction Alternatives. A summary of the groundwater extraction alternatives is presented in Table 5-9. The alternative numbers correspond to those for the alternatives listed above. The alternatives were evaluated according to two criteria:

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Table 5-6
SUMMARY OF ENGINEERING CONSTRAINTS FOR WATER END USE ALTERNATIVES

Alternative
AGRICULTURAL USE

Conveyance Requirements

Physical Barriers

Hydraulic Requirements

^Storage Requirements

Buckeye Irrigation District

1 to 4 miles south,

depending on source
location

Southern Pacific Railroad and State Highway 85.

None--delivery point is downhill. Pressurize to permit sprinkler irrigation, demand. Supply will

None--Buckeye Canal contains waste discharge facilities.

Park Shadows Apartments

1/4 to 3 miles, depending on source location.
4 to 5 miles, depending

No significant

barriers.

Must provide storage due to periodic

likely exceed demand.
Roosevelt Irrigation District Interstate 10.

on source location.
INDUSTRIAL USE

20- to 65-foot elevation head. No pressure head required.

None--Waste capabilities currently in place.

Ui I

Loral Electronics

Varies, depending on source location. Varies, depending on

No significant

Elevate to existing

barriers.
No significant barriers. No significant barriers.

storage tank.
Elevate to storage tank, industry's demand. Elevate to storage tank, industry's demand.

Supply may exceed industry's demand.

a\

to

Phoenix-Goodyear Airport

Supply may exceed
Supply may exceed

source location.

Unidynamics, Inc.
RECREATIONAL USE

Varies, depending on source location.

Estrella Golf Course

2 to 4-1/2 miles, depending on source location.

Southern Pacific Railroad, Buckeye Irrigation District Canal, and Gila River.

Pressurize to irrigate; no elevation head.

Provide storage due to fluctuating demand.

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Table 5-6 (Continued)

Alternative
MUNICIPAL USE

Conveyance Requirements

Physical Barriers

Hydraulic Requirements

Storage Requirements

City of Buckeye

1 to 4 miles south,

depending on source location. Conveyance would be via Buckeye Canal. City of Avondale 1 to 3 miles, depending on source location.

Southern Pacific Railroad and State Highway 85.

None.

None--City has storage facilities.

Conveyance through developed areas of Goodyear and
Avondale; utility

Pressurize to city

standard or elevate to storage tank.

Requires storage facility.

relocation, easement, coordination with cities.
City of Litchfield Park Ul I

3 to 5 miles, depending on source location.

Interstate 10, Roosevelt Irrigation District Canal.
May require utility relocation, easement acquisition, and coordination with the city.

40 to 85 feet of elevation head, pressurize to city standard or elevate to city storage tank.

None--Existing storage facilities.

to

City of Goodyear

1/4 to 3 miles, depending on source location.

Pressurize water to city standard or deliver to existing storage tank.

Existing storage tank;

additional storage would be required.

RECHARGE

Reinjection or Ponding
SURFACE DRAINAGE

Varies, depending on recharge points.

None anticipated.

Possible pressurization
to inject to aquifer.

None anticipated.

Surface Discharge to Agua Fria River

Storm drain exists at site.

None.

None.

None.

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Table 5-7 PUBLIC HEALTH AND ENVIRONMENTAL CONSIDERATIONS BY WATER USE TYPE Water Uae Type Potential Public Health Impacts

Potential Environmental Impacts
Contact and/or ingestion of treated water by livestock.

Agriculture

Incidental contact and/or ingestion of treated water by agricultural labor.

Inhalation of volatile residual contaminants by agricultural labor or nearby residents.

Transport of residual contamination in Irrigated soils.
Transport of residual contamination to groundwater or surface-water systems. Uptake of residual contaminants by plants. Potential phytotoxicity of residual contaminants.

Industrial

Incidental contact and/or ingestion of treated water.
Inhalation of volatile residual contaminants.

Possible exceedance of industrial discharge requirements

to sewage treatment plants.

Municipal

Direct and/or incidental contact and Ingestion of treated water.

Potential phytotoxiclty of residual contaminants.

Inhalation of volatile residual contaminants.
Ul I
K> 00

Uptake of residual contaminants by plants, including those In residential gardens. Transport of residual contamination in irrigated soils. Potential aquatic toxicity of residual contaminants.
Transport of residual contamination to groundwater or

Direct and/or incidental ingestion of and contact with soil irrigated with the treated water. Recreational
Incidental Ingestion and contact with treated water by lake users. Inhalation of volatile residual contaminants.

surface-water systems.
Uptake of residual contaminants by aquatic plants and organisms.

Reinjection

Incidental contact and/or Ingestion of treated water, and humans. Inhalation of volatile residual contaminants.

Contact and/or ingestion of treated water by livestock

Potential risk to aquifers and surface-water systems.
Potential phytotoxicity of residual contaminants.

Surface-Water
Discharge

Direct and/or incidental contact and ingestion of

treated water.

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Table 5-8
SUMHARY OF THE SCREENING OF GROUNDWATER AQUIFER REMEDIAL ACTIONS

Conclusions Alternative Inrolementability
N/A

_______Effectiveness_____
N/A

1. No action. 2. Containment using slurry walla.

No action is retained as a baseline for comparison.

Extremely difficult installation

High cost and relatively
ineffective.

because of depth of the middle fine-grained unit.

3. Groundwater pumping to meet ARAR concentrations in the aquifer. » Remedial action would be applied to the target area above 5 ppb VOCs. 4. Groundwater pumping to meet ARAR concentrations in the aquifer at an accelerated rate. Remedial action would be applied to the target area above 5 ppb VOCs. Ol t [sj 10 5. Groundwater pumping to exceed the ARAR concentrations in the aquifer. This alternative would be applied to the target area above background for VOCs. 6. Groundwater pumping to exceed the ARAR concentrations in the aquifer at an accelerated rate. This alternative would be applied to the target area above background for VOCs. 7. Groundwater pumping to control migration of the contaminants beyond the S ppb VOC boundary.

A groundwater extraction system would be relatively easy to construct and implement.

The ability of the system to extract contaminants is fairly certain. The duration of the remedial action is unknown. The ability of the system to extract contaminants is fairly certain. The duration of the remedial action is unknown.

Medium
to High

A groundwater extraction system would be relatively easy to construct and implement.

Medium to High

A groundwater extraction system would be relatively easy to construct and implement.

This alternative would be more effective than Alternatives 3 and 4 in that a greater amount of the aquifer would be rehabilitated. This alternative would be more effective than Alternatives 3 and 4 in that a greater amount of the aquifer would be rehabilitated. This alternative is relatively ineffective because the restoration of the drinking water aquifer is not the objective and restoration is not achieved for a very long period of time. This alternative is relatively ineffective because the restoration of the drinking
water aquifer is not the

Medium to High

A groundwater extraction system would be relatively easy to construct and implement.

Medium to High

A groundwater extraction system would be relatively easy to construct and Implement.

Medium

Relatively ineffective
alternative.

8. Groundwater pumping to control migration of the contamination beyond the areas of detected VOCs.

A groundwater extraction system would be relatively easy to construct and Implement.

Medium to High

Relatively ineffective

alternative.

objective and restoration is not achieved for a very long period
of time.

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Table 5-9 SUMM&RY TABLE OF GROUNDWATER EXTRACTION ALTERNATIVES

Total
Number of
Alternative 1 3 4 5 6
Existing Wells

Number of Hew Wells
0 1

Pumping Rate (ac-ft/yr)

20 20 20 20 20

3 4 9

--

7,463 8,673 11,093 12,303 18,353

o

The ability of the selected well array to develop a hydraulic capture zone that extends throughout the target area

o

The relative rate of contaminant capture by the extraction wells

Evaluation of the five Subunit B/C remedial action alternatives for the PGA site are summarized in Tables 5-10 through 5-12.
The five proposed remedial action alternatives are retained because they offer a wide range in the desirability of the factors of effectiveness, implementability, and cost. In general, effectiveness and cost factors are inversely related, while implementability factors do not vary greatly per alternative. Increasing the area of capture of contaminated groundwater and reducing the time of capture requires increased capital and operation costs.

Treatment Alternatives. Table 5-13 presents an evaluation of the technologies for VOC removal and screens out those that are not applicable. Air stripping and activated carbon adsorption were retained for detailed evaluation. The other technologies identified were dropped from further consideration for a variety of reasons including poor, variable, or unproven performance, institutional and management constraints, or inapplicability to expected contaminant concentrations. Chapter 5 of the PGA Feasibility Study provides the methodology for the screening of treatment alternatives.

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Table 5-10
DETAILED ANALYSIS OF ALTERNATIVES--EFFECTIVENESS Alternative 3--

Alternative 1-Evaluation Criteria Short-Term Protectiycneaa

Reduction of Contamination
_____to Meet ARARs______

Alternative 4-- Accelerated Reduction of
Contamination to Meet ARARs

Ho Action

Alternative 5-Reduction of Contamination _____to Exceed ARARs_____

Alternative 6-- Accelerated Reduction of Contamination to Exceed ARAga

Reduction of Existing Risks

No reduction of risk occurs because of lack of wellhead treatment.

Risks can be substantially reduced. Two types of risks are identif-ied: point of use of groundwater and the zone(s) of contamination within aquifers of Subunits B/C. Treatment of potentially con taniinated water is designed for existing and additional extraction wells. Contaminants within the ARAR target area will eventually be captured in extraction wells. However, contaminants now occurring in the back ground target area will not be fully captured. Ground water contamination above background but below ARAR concentrations will continue to spread. Same as Alternative 1.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

No treatment of potentially contaminated waters is designed.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Contaminants in groundwater will be reduced by capture in extraction wells. However, not all of the ARAR or back ground target volumes will be captured. Groundwater contamination will continue to spread.

Contaminants within the ARAR target area will eventually be captured in extraction wells. However, contaminants now occurring in the back ground target area will not be fully captured. Ground water contamination above background but below ARAR concentrations will continue to spread. Same as Alternative 1.

Contaminants within the ARAR and background target area will be fully captured. The spread of groundwater contarn ination outside of the back ground target area will be eliminated.

Contaminants within the ARAR

and background target area will be fully captured. The spread of groundwater contain ination outside of the back ground target area will be eliminated.

Compliance with ARARs

Ul I U)

One location-specific ARAR, the Fish and Wildlife Coordination Act (FCWA) may be potentially applicable
within the FGA site.

Same as Alternative 1.

Same as Alternative 1.

Requirements of the FWCA will likely be met. Potential chemical-specific ARARs for the PGA site are listed in Table 2-5. ARARs ARARs for a number of potential contaminants are unlikely to be met at the place of use and within the groundwater target zones. Potential chemical-specific
ARARs for the PGA site are listed in Table 2-5. ARARs

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

ARARs for potential contaminants are likely to be met at the place of use during during the remedial action and within the target zone

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Table 5-10
(Continued)

Evaluation Criteria

Alternative 1-- No Action A waiver from the requirements of chemical-specific ARARs 18 not appropriate.

Alternative 3-- Reduction of Contamination
_____to Meet ARABS______

Alternative 4-- Accelerated Reduction of . Concaainatlon to Jfeet ARARs
Same as Alternative 1.

Alternative 5-- Reduction of Contamination
_____to Exceed ARAKa_____

Alternative 6-- Accelerated Reduction of Contamination to Exceed ARARs
Same as Alternative 1.

Compliance with ASARs (continued) Compliance with Other Criteria, Advisories,

Sane as Alternative 1.

Same as Alternative 1.

and Guidances
Protection of Community During Remedial Actlona

advisories, and guidances are not likely to be met. The risk to the community is
at the point of use of pumped

Requirements of criteria,

Requirements of criteria, advisories, and guidances are likely to be met. The risks to the community during the remedial action

Same as Alternative 3.
Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

groundwaters.

may result from accidents
associated with the construction operation and maintenance of the additional

groundwater wells and
treatment facilities.

Risks that remain and that U1 I
W

cannot'be readily controlled are the uncertainties associated with potential
groundwater contaminants within the aquifers of Subunlts B and C. Protection of Workers

Risks that remain and that cannot be readily controlled are the uncertainties associated with potential

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

groundwater contaminants
within the aquifers of Subunlts B and C.

to

During Remedial Actions

Not applicable.

The risks to workers during the remedial action include various levels of exposure to potential contaminants and accidents during all phases of the remedial action. All risks should be minimized

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

with appropriate preparation
and conscientious performance.

Sane aa Alternative 3.
The time required to reduce contamination to concentration goals is not definitely known. However, it is estimated that «t least 38 years

Sams as Alternative 3.

Same as Alternative 3.

Achieved

Time Until Protection is Hot applicable.

The tine required to reduce

contamination to concentration goals is not definitely
known. However, It is estimated that at least 90 years of pumping will ba required to reduce contaminant levels in the aquifer to below ARAR

ofl pumping will be! required to reduce contaminant levels In the aquifer to below ARAR

contamination to concentration goals la not definitely known. However, it Is estimated that at least 65 years
of pumping will be required to reduce contaminant levels in the aquifer to below ARAR

The time required to reduce

The time required to reduce contamination to concentration goals it not definitely known. However, it is estimated that at least 40 years of pumping will be required to reduce contaminant levels In the aquifer to below ARAR

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Table 5-10

(Continued) Alternative 3-- Reduction of Contamination
_____to Meet ARARs______ Alternative 4-- Alternative 5-- Alternative 6-- Accelerated Reduction of Contamination to Exceed ARARs

Alternative 1Evaluation Criteria

Accelerated Reduction of
Contamination to Meet ARARs

Ho Action

Reduction of Contamination
_____to Exceed ABARs______

Time Until Protection is Achieved (continued)

concentrations within the
ARAR target volume. This

concentrations within the
ARAR target volume. This alternative is not effective in flushing the aquifer in

concentrations within the
ARAR target volume. It is

concentrations within the
ARAR target volume. It is estimated that at least 108 years of pumping will be

alternative is not effective in flushing the aquifer in the background target area.

estimated that at least 158 years of pumping will be
required to reduce contaminant levels in the aquifer to

the background target area.

below background concentrations within the background
target volume.

required to reduce contaminant levels in the aquifer to below background concentrations within the background target volume.
Same as Alternative 3.

The tine when remedial activities will commence is not known. The time when remedial actions will be complete Is not known.
The risk or magnitude of the principal threat during the remedial action should be minimal if appropriate measures are followed. Long-Term Protectiveness Reduction of Future Risks

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

I OJ U) Not applicable.

The remaining sources of risk include potential groundwater contamination greater than ARAR and background concentrations both inside and outside the target cleanup areas. Unknown sources of risk that may remain after the remedial action include additional undiscovered sources of groundwater pollution and migration of potentially contaminated groundwaters that escape monitoring and remediation.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

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Table 5-10 (Continued)
Alternative 3--

Evaluation Criteria Loog-Term Reliability

Alternative 1No Action Not applicable.

Reduction of Contamination
____to Meet ARARs_____

Alternative 4-- Accelerated Reduction of Contamination to MeetARARs
Sane as Alternative 3.

Alternative 5-- Reduction of Contamination
_____to Exceed ARMis_____

Alternative 6-- Accelerated Reduction of Contamination to Exceed ARARs
Sane as Alternative 3.

The potential for failure of

Sane as Alternative 3.

tbe additional groundwater extraction well depends on
how accurately the target cleanup area(s) define the

actual spatial distribution of contamination and how
completely groundwater extraction can collect groundwater contamination from within the target

cleanup area(s).
The magnitude of the threats Sale as Alternative 3. Sane as Alternative 3. Same as Alternative 3.

or risk should remedial
action fail may range from minimal to severe. Nontreated, potentially contaminated waters used for municipal and industrial

U1 I
U)

*>·

purposes offer the greatest risk.
Compliance witb ARARs Not applicable.

Long-term requirements of location-specific and
chemical-specific ARARs,

Same as Alternative 3.

Same as Alternative 3,

Same as Alternative 3.

other criteria, advisories, and guidances are likely to be met.
Prevention of Future
Exposure to Residuals

Not applicable.

The likelihood of future exposure to residual contaminants is not known but may be present.

Same as Alternative 3.

Same as Alternative 3.

Sane as Alternative 3,

Should the remedial action fail, the threats or risks are likely limited to the

Same as Alternative 3.

Sane as Alternative 3.

Same as Alternative 3.

point of use of extracted
groundwater. Tbe magnitude

of these risks is not known.
Potential Need for
Replacement Not applicable.
tbe likelihood for needing

The likelihood for needing
replacement of the monitoring

replacement of the monitoring wells, extraction wells, and
pumps is very high.

wells, extraction wells, and
puop® is very high.

Tbe likelihood for needing replacement of the monitoring wells, extraction wells, and pimps is very high.

Tbe likelihood for needing replacement of tbe monitoring wells, extraction wells, and pumps is very high.

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Table 5-10 (Continued)
Alternative 3--

Alternative 4-~
Accelerated Reduction of Contamination to Meet ARARs

Alternative 1Evaluation Criteria Ho Action

Reduction of Contamination
_____to Meet ARARs______

Alternative 5-Reduction of Contamination
_____to Exceed ARARs____

Alternative 6-- Accelerated Reduction of Contamination to Exceed ARARs Same as Alternative 3.

Potential Need for Replacement (continued)

The required replacement of wells is anticipated to be every 40 years, pumps every 30 years. If rehabilitation of the wells occurs at regular intervals, risks associated with failure should be low. Replacement of monitoring wells should not present significant risk as long as the retired wells are prop erly sealed.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Reduction of Toxicity, Mobility, or Volume Permanent and Significant Reduction of Toxicity, Mobility, or Volume

Treatment is not designed.

Treatment of groundwater to remove potential groundwater contaminants is an essential design of the remedial action. All groundwater discharges from the additional extraction well and all operating wells within or near to either the ARAR and/or background target areas will be included in the treatment design. It is not known, quantita tively, to what extent the total mass of toxic contami nation within Subunits B/C will be reduced or destroyed. Significant reduction should occur, however, during the operation of the remedial action.

Same as Alternative 3.

Same as Alternative 3.

Same ad Alternative 3.

None of the groundwater is designated for treatment.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Ul I
CO

Ul
It is not known, quantita tively, to what extent the total mass of toxic contami nation within Subunits B/C will be reduced or destroyed. Significant reduction should occur, however, during the operation of existing extrac tion wells.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

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Table 5-10 (Continued) Alternative 3-« Reduction of Contamination
_____to Meet ABARs______

Evaluation Criteria Permanent and Significant Reduction of Toxicity, Mobility, or Volume (continued)

Alternative 1-___Ho Action _

Alternative 4-Accelerated Reduction of Contamination to Meet ARARs
Contaminants within the ARAR

Alternative 5« Reduction of Contamination ,____to.-Bxce.ed ARARs____ Contaminants within the ARAR and background target area
will be fully captured. The

Alternative 6~Accelerated Reduction of
Contamination to Exceed ARARe

Mobility of contaminants in groundwater will be reduced by capture in extraction wells. Howeveri not all of the ARAR or background target volumes will be captured. Groundwater contamination will continue to spread.

Contaminants within the ARAR target area will eventually be captured in extraction wells. However* contaminants now occurring in the background target area will not be fully captured. Groundwater contamination above background but below ARAR concentrations will continue to spread.
The time required to reduce

target area will eventually be captured in extraction wells. However* contaminants now occurring in the background target area will not be fully captured. Groundwater contamination above background but below ARAR oticent rat ions will continue

spread of groundwater contamination outside of the background target area will be eliminated.

Contaminants within the ARAR and background target area will be fully captured. The spread of groundwater contamination outside of the background target area will be

eliminated.

to spread.
The time required to reduce contamination to concentration goals is not definitely known. However, it Is estimated that at least 38 years of pumping will be required to reduce contaminant levels in the aquifer to below ARAR concentrations within the ARAR target volume. This alternative is not effective in flushing the aquifer in the background target area.
The time required to reduce

This alternative is not effective in reducing concentrations Co below ARARa throughout the target volume.

contamination to concentration goals io not definitely known. However, it is estimated that at least 90 years of pumping will be required to reduce contaminant levels in the aquifer to below ARAR concentrations within the ARAR target volume» This alternative is not effective in flushing the aquifer in the background target area*

contalmlnatlon to concentration goals is not definitely known. However, it is estimated that at least 65 years of pumping will be required to reduce contaminant levels in the aquifer to below ARAR concentrations within the ARAR target volume. It is estimated that at least 158 years of pumping will be required to reduce contaminant levels in the aquifer to below background concentrations within the background target volume.

The time required to reduce contamination to concentration goals is not definitely known. However* it Is estimated that at least 40 years of pumping will be required to reduce contaminant levels
In the aquifer to below ARAR

concentrations within the ARAR target volume. It is estimated that at least 108 years of pumping will be required to reduce contaminant levels in che aquifer to below background concentrations within the background target volume. Same as Alternative 5.

en I u>

To what extent the overall threats are reduced is not known.

There will be permanent and significant reduction of Toxicity, Mobility and Volume by removing the contamination to meet ARARa.

us Alternative 3.

There will be permanent and significant reduction of Toxicity, Mobility and Volume by removing the contamination to exceed ARARs.

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Table 5-11
DETAILED ANALYSIS OF ALTESMATIVES--IHPLEHENTABILITY

Alternative 3-- Alternative 1Evaluation Criteria
Short-Term Technical Feasibility Ability to Construct

Alternative 4--
Accelerated Reduction of Contamination to Meet ABARs

Alternative 5--

No Action

Reduction of Contamination to Meet ARARs_____

Reduction of Contamination
to Exceed ARARs

Alternative 6-- Accelerated Reduction of Contamination to Exceed ARARs

Not applicable.

Technology

No serious difficulties are anticipated with construction of the extraction and monitoring wells. The unknowns related to construction are the spatial variability in llthology and potential groundwater contamination.

Sane as Alternative 3.

Sane as Alternative 3.

Sane as Alternative 3.

Short-Term Reliability of Technology

Not applicable.

Ul U>

The likelihood is high that groundwater extraction well and surface treatment technologies will meet required process efficiencies or performance specifications. The likelihood that technology problems will lead to schedule delays Is not known.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Compliance with Some
Action-Specific ARARs

Not applicable.

All action-specific ARARS are

Sane as Alternative 3.

Sane as Alternative 3.

Same as Alternative 3.

likely to be met.

Long-Term Technical
Feasibility

Ease of Undertaking
Additional Remedial Action, if Necessary

Not applicable.

The likely future remedial action that nay be anticipated is the need for additional extraction wells to capture potentially contaminated groundwater, both within and outside of the target cleanup areas: It should not be difficult to Implement additional remedial actions if required.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

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Table S-ll

(Continued) Alternative 3~
Evaluation Criteria
Ability to Monitor Effectiveness of Remedy Alternative 1No Action Not applicable.
Reduction of Contamination ____to Meet ARABs______

Alternative *-Accelerated Reduction of
Contamination to Meet ARABs
Same as Alternative 3.

Alternative S-- Reduction of Contamination ____to Exceed ABARs_____
Same as Alternative 3.

Alternative 6-- Accelerated Reduction of Contamination to Exceed ARABs
Sane as Alternative 3.

Migration pathways of potentially contaminated groundwater nay occur along
relatively narrow "shoestring" permeable units. These units nay miss monltoring efforts. Exposure

pathways are Halted to point of use of extracted groundwater. Points of use can be
easily monitored.

Risk of exposure due to monitoring that Is insufficient

to detect failure most likely
will occur dowild ip from the western boundaries of the
U1 I U> CO

target cleanup areas. Anticipated contaminant concentrations should be on the
sane order of magnitude as

AMR concentrations. Ability to Perform Operation and Maintenance
Functions Not applicable. Difficulties associated with long-tern operation and maintenance include the finite design life of extraction wells. Monitoring wells/ pumps, and treatment
Same as Alternative 3. Same as Alternative 3. Same as Alternative 3.

facilities.
Unknowns related to long-term

operation and maintenance include the ability of groundwater flux to cleanse pollutants fro* the aquifer and
the time of the working life of wells, pumps, and conveyance systems.

RD/R51/012-2

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Table 5-11 (Continued)

Alternative 1Evaluation Criteria

No Action

Alternative 3-- Reduction of Contamination to Meet ARAfis

Alternative 4-- Accelerated Reduction of
Contamination to Meet ARARs

Alternative 5--
Reduction of Contamination to Exceed ARARs

Alternative 6-- Accelerated Reduction of Contamination to Exceed ARARs

Administrative

Feasibility
Ability to Obtain Approvals fro* Other
Agencies

Not applicable.

Specific approvals frog other agencies include Arizona Department of Hater Resources
(ADHR)--poor water quality

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

withdrawal pemlt and Arizona Department of Environmental
Quality (ADEQ)--concurrence with remedial actions as

required by SARA.

It is likely approval froa agencies Mill be obtained.
Likelihood of Favorable

Community Response

The community response is likely to be highly unfavorable to "no action." The technical basis for the highly unfavorable response is valid--possible exposure to contaminated groundwater.

Ul I

The community response is likely to be mixed. It will likely be favorable to the complete cleanup of contamination above ARARs and unfavorable to the incomplete cleanup of contamination below ARARs. The technical basis for the unfavorable response may be valid.

Same as Alternative 3.

The community response is likely to be favorable to the total cleanup of contamination within the target cleanup areas. The high costs of the cleanup nay be unfavorably received by the communityr however.

Sane as Alternative 5.

Coordination with Other Agencies

Not applicable.

Creating a plan for groundwater management of the target cleanup areas is a step that requires coordination with other agencies. Long-term or future coordination among agencies requires a designated agency to oversee the groundwater
management at the site.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

Compliance with Some
Location-Specific ARARs

Not applicable.

All location-specific ARARs are likely to be met.

Same as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

RD/R51/012-3

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Table 5-11

(Continued)
Alternative 3~
Evaluation Criteria

Alternative 1No Action

Reductlon of Contamination

to Meet ARARs

Alternative 4-- Accelerated Reduction of Contamination to Meet ARARs

Alternative 5-- Reduction of Contamination to Exceed ARARs

Alternative 6-- Accelerated Reduction of Contamination to Exceed ARARs

Availability
Availability of Treat-

Nat applicable.

Adequate treatment, storage,

Same as Alternative 3.

Sane as Alternative 3.

Same as Alternative 3.

Bent, Storage, and Disposal Services and Capacity

and disposal services and
capacity are available per

design.
No additional capacity is necessary unless the target cleanup areas require
·edification.

Availability of Necessary Equipment and Specialists

Not applicable.

The necessary eguipnent and specialists should be avail-

Sane as Alternative 3.

Same as Alternative 3.

Same as Alternative 3.

able to construct, operate,
and maintain the operation of the remedial action.
Ul I
O

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Table 5-12
DETAILED ANALYSIS OF ALTERHATIVES--Cost

Evaluation Criteria Capital Costa

Alternative 1No Action

Alternative 3-Reduction of Contamination
_____to Meet ARARs_____

Alternative 4-Accelerated Reduction of Contamination to Meet ARARe

Alternative 5-- Reduction of Contamination
_____to Exceed ARARs____

Alternative 6-Accelerated Reduction of Contamination to Exceed ARARs

Estimated Capital Costs for Development and Construction Direct Costa Not applicable.
25 Monitoring wells

at $25,000 each 1 Extraction well single caaing at $39,000 Telescoped casing
Ul I

$625,000

25 Monitoring wells at $25,000 each $625,000 3 Extraction wells single casing at $39,000 each 1 Telescoped casing at $58,000 3 Well pumps at
$25,000 each

50 Monitoring wells
at $25,000 each $1,250,000

50 Monitoring wells

at $25,000 each

$1,250,000

39,000

117,000 58,000
75.000 $7,0 8500

3 Extraction wells single casing at $39,000 each 1 Telescoped casing at $58,000 4 Well pumps at $25,000 each

9 Extraction wells single casing at 117,000
58,000
$39,000 each

351,000

0

Telescoped casing 9 Well pumps at $25,000 each

0

1 Well pump at $25,000

25.000
$689,000

__ 100.000

$1.525,000

$1,826,000

Indirect Costa

Not applicable.

Other Capital and Short- Not applicable. Term Costs until Remedial Action la in Place Annual Operating Costa Estimated Annual Costs of Operation and Maintenance for as long as Necessary Operating Labor Maintenance, Materials and Labor Hot applicable. Not applicable, Well and pump rehabilitation, 26 wells, $10,000/10 years/ well - $260,000/10 years Well and pump rehabilitation 10-year design, 28 wells, $10,000/well/10 years $280,000/10 years Well and pump rehabilitation 10-year design, 54 wells, SlO.OOO/well/10 years $540,000/10 years Well and pump rehabilitation 10-year design, 59 wells, $10,000/well/10 years $590,000/10 years

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TabZe 5-12 (Continued). Alternative 3-Alternative 4-Accelerated Reduction of Contamination to Meet ARARs Electrical power costs for pumping extraction wells, 3 extraction wella: Alternative 5-- Reduction of Contamination ____to Exceed ARARa_____ Alternative 6-Accelerated Reduction of Contamination to Exceed AHARa

Evaluation Criteria
Annual Operating Costa (continued) Operation Materials and Energy

Alternative 1No Action Not applicable.

Reduction of Contamination
_____to Meet ARARs_____

Electrical power costs for pumping extraction wella, 1 extraction well:

Electrical power costs for pumping extraction wells, 4 extraction wella: Irrigation--7.5c/kWh,
$b2,500/purap - $210,000;

Electrical power costs for pumping extraction wells, 9 extraction wells: Irrigation--7.5c/kWh,
$52,500/pump « $472,500;

Irrigation--7.5c/kWh,
$52,500/pump;

Irrigation--7.SC/kWh,
$52,500/pui»p « $157,500;

water supply--llc/kWh,
$77*000 per pump

water aupply--llC/kWh, $77,000/punp · $231,000 1 man-year required at
560,000/year « $60,000

water aupply--llc/kWh,
$77,000/pump - $308,000

water supply-»lic/kWh,
$77,000/pump « $693,000

Administration Taxes and Insurance

Not applicable.

1 roan-year required at
$60,000/year * $60,000 Not applicable.

1 man-year required at $60,000/year » $60,000 Not applicable. Not applicable.

1 man-year required at
560,000/year * $60,000

Not applicable.

Not applicable.
Hot applicable.

Not applicable. Not applicable.

Maintenance Reserve and Not applicable. Contingency
Monitoring Costs

Not applicable.

U1 I

Water Level Monitoring

Not applicable.

Monthly measurement, A mandays/month - $l,BOO/raonth «

$21,600/year
Water Quality Sampling Not applicable.

Monthly measurement, 4 mandays/month · $l,800/month $21,600/year Quarterly sampling, 15 mandays/quarter « $6,750/ quarter » $27,000/year

Monthly measurement, 4 man(layu/month * $l,800/tnonth »

$21,600/year

Monthly measurement, 4 mandays /month * $l,800/month -

$21,600/year
Quarterly sampling, 28 mandays/quarter » S12.600/ quarter * $50,400/year Methods 601 and 602, BO" wells, 1 sample/well * $230/ well * $18,400/quarter * $73,600 year Yearly Inorganic, 80* wells, 1 sample/well » $270/well ·= $21,600/year 9 Extraction wells, 40-year design, $39,000/well/40 years * $351,000/40 years 50; Monitoring, iwellsj 4;0-year' design, $25,000/Hell/4b years « $1,250,000/40 years 9 Pumps, 30-year design, $25,000/pump/30 years > $225,000/30 years

Quarterly sampling, IS mandaya/quarter · $6,750/ quarter * $27,000/year Methods 601 and 602, 47* wella, 1 sample/veil » $230/uell - $lO,800/quarter
- $43,200/year

Quarterly sampling, 25 mandays /quarter = $11,300/ quarter - $45,000/year Methods 601 and 602, TJ" wella, 1 sample/well - $230/ well * $17,300/quarter * $69,000/year

Analysis of Hater

Quality Sampling

Not applicable.

wells, 1 sample/well -

Methods 601 and 602, 49" $230/well - $U,300/quarter

- $45,100/year
Yearly Inorganic, 49* wells, 1 sample/well * $270/well

Yearly Inorganic, 47*

wella, 1 sample/well <*
$270/well - $12,700/year Replacement Coeta

Yearly inorganic, 75* wella,
1 sample/well * $270/well - $20,300/yesr 4 Extraction wells, 40-year design, $39,000/well/40

- $13,200/year 3 Extraction wells, 40-year
design, $39,000/well/40 years » $117,000/40 years 25 Monitoring wells, 40-year design, $25,000/well/40j years > $625,000/40 years 3 Pumps, 30-year design, $25,000/pump/30 years « $75,000/30 years

Not applicable.

1 Extraction well, 40-year design, 539,000/well/

40 years
25 Monitoring wells, 40-year

years - $156,000/40 years
SO Monitoring wells, 40-year dwign), $25,000/wellMo years * $1,250,000/40 years 4 Pumpfl, 30-year design, $25,000/punp/30 yean * $100,000/30 years

design, $25,000/weU/40

years - $625,000/40 years 1 Pump, 30-year design, $25,000/pump/30 years

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Table 5-12 (Continued)

Alternative 1-Evaluation Criteria
Present North

Alternative 3-Reduction of Contamination
_____to Meet ARARs_____
90 YEARS OF REMEDIAL ACTION:

Alternative 4-Accelerated Reduction of
Contamination to Meet ARARs
38 YEARS OF REMEDIAL ACTION: $ 875,000

Alternative 5-Reductlon of Contamination _____to Exceed ARARa_____
65 YEARS OF REMEDIAL ACTION: $1,525,000 5,230,000

No Action

Alternative 6-- Accelerated Reduction of Contamination to Exceed ARARa
40 YEARS OF REMEDIAL ACTION: $1,826,000 9,000,000

Capital Costs

Not applicable. Not applicable.

$

689,000

Power Costs, Administration, Water Level Monitoring, Water Quality Sampling Analysis Hell and Pump Rehabilitation (10 years)
Well Replacement (40 years) Pump Replacement (30 years)
Ul I

2,420,000

3,870,000

Not applicable. Not applicable. Not applicable. Not applicable.

366,000 32,000 13.500 $11,200,000

Total Present Worth

*» U)

"Includes 21 existing monitoring wells completed entirely within Subunits B and/or C. "Present worth of all costs adjusted to end of year zero (10 percent annual rate).

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Table 5-13
SUMMARY OF VOC REMOVAL TECHNOLOGIES SCREENING

Process Description
Air Stripping

State of
Development Commercial

Ability to Heet

performance
Record tow

Relative Costs
Capital Operation Haste Streams

Discharge Standards
exceeding 9 . percent 99

Additional Contents
Commonly used for removal of VOCs

Retained for Further Analysis Yes

Capable of VOC removal Excellent

Low to moderate

Air exhaust (can be
carbon treated)

at low concentrations. Not typically used for this type
of application; can also remove NH and H S from wastewater.
3 2

Steam Stripping

Commercial

Capable of VOC removal Excellent exceeding 9 . percent 99

Moderate

High

Small air exhaust. condensate with organics Carbon containing organics requires regeneration or
replacement

No -- not well demonstrated for removal

of low concentrations
of VOCs

Activated Carbon Adsorption

Commercial

Capable of VOC removal Excellent exceeding 9 . percent 99

Low

Moderate to high

Relatively poor carbon utilization Yes--useful for vapor for treatment of streams with very and aqueous phase VOC low organic concentrations. removal Generally used for removal of salts and high molecular weight organics.
Generally used for treatment of concentrated streams where high degree of separation is required.
No--poor performance

Reverse Osmosis

Commercial

Relatively poor
performance for VOCs

Poor for VOC

High

High

removal

Produces a concentrate stream that requires additional treatment

for VOC removal

Distillation

Commercial

cm

Capable of achieving very high VOC removal

Good on high

Moderate

concentration
streams; not

appropriate for
low concentration streams
Liquid-Liquid Limited High Unknown -- polishing is Good, but usually required ability to meet discharge requirements is unknown

Very high Snail air exhaust, organic liquid, condensate with organics

No--not appropriate

for low levels of
contaminants

Extraction

Commercial

Very high Solvent with extracted Produces a solvent stream with organics organics that requires additional
treatment; requires use of

No--ability to meet

discharge requirements is unknown

potentially hazardous solvents; residual solvent in treated water. Moderate to high High ' None None
No--poor performance for this application

Critical Fluid

Limited

Extraction

Commercial

Unknown-- although unlikely to reduce
below 100 ppb

Limited--few

Very High

large-scale applications Variable i performance
for VOCs

Aerobic Biological Commercial

Some compounds not
readily biodegradable

High

Sludge produced that requires disposal
Sludge produced

May not be stable, susceptible to shock, temperature-dependent, acclimation is Important. May not be stable, susceptible to shock, temperature-dependent, acclimation is important.
High power requirements, many oxidants are toxic; potential for toxic breakdown products to be formed.

No--variable performance No--variable performance
No--Toxic breakdown

Anaerobic Biological Chemical Oxidation

Commercial

Hay not consistently aeet standards Capable of achieving very high VOC removal

Variable performance for VOCs

High

High

Commercial

Applicable to High low concentrations

High

Co plus byproducts

products can be
formed

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End Use Alternatives. Water end use alternatives were screened based on the evaluation of engineering constraints, statutory considerations, and public health and environmental considerations. Only one alternative,

recreational end use, was eliminated. In this case, distance, physical barriers, absence of storage facilities, and seasonal demand tend to be the major disadvantages for potential end use by the only recreational user to express interest in treated water from the project, the Estrella Golf Course.
Evaluation of Alternatives

No Action Alternative. The no action alternative would allow the groundwater contamination to spread over an everwidening area and would likely have continuing adverse environmental and health consequences. These include exposure to carcinogens and other harmful contaminants through ingestion of water and soil and inhalation of soil gas and gas released from pumped groundwater.

Extraction Alternatives. The pumping alternatives accomplish the objective of stopping migration of contaminants at the airport site. When coupled with treatment, they also will reduce the volume, mobility, and toxicity of the groundwater contaminants. Pumping to extract contaminated groundwater would prevent migration of contaminants from the chosen pumping area. This technology has been demonstrated to be successful in other areas. However, aquifer restoration estimations are based on hydrogeologic principles and regional flow characteristics. There is some uncertainty as to the time required for restoration. Analysis of water samples from monitoring wells for contaminant levels will indicate aquifer cleanup. Operation is relatively simple and is not expected to significantly affect the alternative's reliability. It is likely that during the remedial action, some components will require maintenance or replacement. No impediments to well construction are foreseen, and no significant safety hazards are expected during construction. If pump failure occurs, there would be no short-term release of contaminants that could pose a threat to public health or the environment.
Treatment Alternatives. Both air stripping and activated carbon adsorption achieve the desired goal of reducing volume and toxicity of the groundwater contaminants suffi-

ciently to meet the applicable and appropriate requirements and will likely exceed these requirements. Treatment of

5-45
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contaminated groundwater, either by air stripping or the use of granular activated carbon, has been shown to be very effective with removals of organic contaminants often exceeding 99.9 percent. These processes 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 an antiscalant, such as hypochlorite, would be required to remedy this.

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 of either process could be completed within 2 years. The startup period may take several days. Catastrophic failure of components is unlikely, and any threat to public health and the environment is relatively low.

The costs associated with every treatment alternative are summarized in Tables 5-14 through 5-16.

Air emission controls were considered as part of the air stripping alternative for two reasons. First, SARA states that a remedy should reduce the toxicity, mobility,-and volume of contaminants. Second, the Maricopa County Air Pollution Control Board requires all new plants with air emissions to employ reasonably achievable control technology to reduce emissions and "will adequately dilute, reduce, or eliminate the discharge of air pollution to adjoining property." The following Maricopa County and ADHS standards would apply to ambient releases of VOCs from an air stripper:
Maximum Release (Ib per day) Maricopa County ADHS
** A permit is required if this level is exceeded.

40* 70

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I

I

I

Table 5-14 ·TREATMENT SYSTEM COSTS AIR STRIPPING
Alternative

·reatment Level

ARARs

ARARs

ARARs

Background

6 ARARs

Background

§

_________Item______ pital Cost ite Preparation
Includes clearing, utilities, roads,

$

57,000 $ 60,500 $ 57,000 $ 169,000

$ 60,500 $

176,500

«£ence, and ·foundation)

»

Air Stripping

System tartup

232,700 10,000 242,700 60,675 80,900 72,810
457,085

294,300 10,000
304,300 76,075 101,433 91,290

232,700 10,000 242,700
60,675

737,925 10,000 747,925 186,982 249,308 244,378

294,300 10,000 304,300 76,075 101,433 91,290
573,098

958,050 10,000 968,500
242,013 322,683

Direct Costs

·Fee and Expenses

Engineering Contingency
ital I Capital Cost

80,900 72,810

290,415
1,823,161
124,700 43,680 48,403

573,098
38,823 14,560 15,215

457,085 1,408,592

Operating Cost ·power JLabor iflaint enanc e Other · Includes JP?.nalytical, insurance,

18,716 14,560 12,135 18,571

19,731

18,716 14,560 12,135 18,571

74,478 43,680 37,396 56,086

38,823 14,560 15,215 19,731

60,232

and administration)
Contingency

19,195 83,176 24,270

26,499 114,827 30,430

19,195

63,492

26,499

83,104

3tal Operating Cost mobilization

83,176 24,270

275,133 74,793

114,827 30,430

360,118 96,805

IWorth Present oject
3

1,502,792 2,015,569 1,502,792 4,865,541

2,015,569

6,347,514

I Present worth is calculated

assuming a 20-year period and a 5 percent rate of return.

t I 1 I
Case 2:03-cv-02226-ROS Document 81-7 Filed 06/27/2006 Page 24 of 31
RDD\R82\019.50
5-47

Table 5-15
TREATMENT SYSTEM COSTS ACTIVATED CARBON

Alternative 3
Treatment Level:
4 5 5 6 6

ARARs

ARARs

ARARs

Background

ARARs

Background

Item
Capital Cost $ 90,500 Site Preparation (Includes clearing, utilities, roads, fence , and foundation) Activated Carbon System Startup Direct Costs
$ 102,500 $ 90,500

$ 267,000

$

102,500

$ 295,000

1,196,121 10,000
1,206,121 301,530 398,020 361,836 2,267,508 124,565 18,200 17,273 36,184 36,675

2,034,057 10,000 2,044,057 511,015 674,539 613,217 3,842,828 232,392 18,200 35,820 61,322 52,428

1,196,121 10,000 1,206,121 301,530 398,020 361,836 2,267,508 125,871 18,200 17,273 36,184 36,675

4,156,067 10,000 4,166,067 1,041,517 1,374,802 1,249,820 7,832,207 473,473 54,600 68,722 124,982 120,322

2,034,057 10,000 2,044,057 511,015 674,539 613,217 3,842,828 241,304 18,200 35,820 61,322 52,428

5,937,784 10,000 5,947,784 1,486,946 1,962,769 1,784,335 11,181,835 739,285 54,600 115,077 178,434 153,818

Fee and Expenses Engineering Contingency
Ul I *>
00

Total Capital Cost
Operating Cost Carbon Replacement Labor Power Maintenance Other (Includes analytical, insurance, and administration) Contingency

69,869 302,766 120,612 6,086,098

120,049 520,211 204,406 10,402,850

70,261 304,464
120, 6^2

252,630 1,094,729 416,607 21,631,969

122,722 531,796 204,406 10,547,225

372,364 1,613,578 594,778 31,514,744

Total Operating Cost
Demobilization

Project 0Present Worth

6,107,262

a

Presenl worlh is calculated assuming a 20-year period and a S percent rale of return.

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Table 5-16 TOTAL TREATMENT COSTS Alternative

Treatment Level:
ARARs Item ARARs
ARARs Background

ARARs

Background

Air Stripping Pipeline Cost Present Worth Treatment System Cost Present Worth
Total Cost Present Worth Activated Carbon Pipeline Cost Present Worth Treatment System Cost Present Worth Total Cost Present Worth

$1,517,794 1,502,792
3,020,586

$ 2,267,102 2,015,569

$ 764,000 1,502,792

$ 3,774,393 4,865,541

$ 2,367,137 2,015,569

$ 5,653,202 6,347,514

4,282,671

2,266,792

8,639,934

4,382,706

12,000,716

ui I
*» IO

1,517,794 6,086,098 7,603,892

2,267,102 10,402,850 12,669,952

764,000 6,107,262 6,871,262

3,774,393 21,631,969 25,406,362

2,367,137 10,547,225 12,914,362

5,653,202 31,514,744 37,167,946

Note: All present worth costs assume a 20-year period and a 5 percent rate of return.

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Currently, Maricopa County is considering lowering its standard to 2 pounds per day. In addition, EPA has established guidance on the control of air emissions from air strippers used at Superfund sites. This guidance suggests the adoption of emission controls at sites located in nonattainment areas, even if they are not mandated by Federal or State laws and regulations or indicated by a cancer risk analysis. A nonattainment area is an area that does not meet the National Ambient Air Quality Standards for ozone. The EPA guidance suggests that sources most in need of controls are those with an actual emission rate of 15 pounds per day or more. For all the alternatives considered here for Subunit B/C, the VOC air emissions are estimated at 1 pound per day or lower Concentrations of VOCs in the air would be difficult to measure without sophisticated air monitoring equipment. The cost of installing an air emission control unit on the air stripper will increase the project costs by two to three times that of the air stripper alone. Considering all regulations and guidance, the low emission rate from the air strippers will have a negligible effect on air quality or public health. Therefore, air emission controls have been deleted from the design of the air stripping equipment because they provide little benefit for the cost involved. This requirement may change in the future.

· ]p Jf » · ^ · * flf H 11 te jg m

End Use Alternatives. A number of end use alternatives are considered feasible based on the evaluation conducted in the Feasibility Study. These include:
o Delivery of treated water to nearby municipalities

o
o

Reinjection of treated water
Delivery of treated water to irrigation or surface water · * ft *

End use alternatives for treated groundwater must be consistent with ADWR Active Management Area plans and goals.

Table 5-17 presents a summary of cost estimates for the various extraction quantities and distribution options considered in the evaluation of water end use alternatives.
The City of Goodyear was chosen as the primary recipient of treated water because of its proximity to the site and the fact that the water extracted from the contaminated B/C aquifer will be in Goodyear *s use area. Water utilized by

· m
f|

m

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^^^H ^B^B

>^^^^^ i^^^^^

-^BJBB

^^^^M

^^^^^

^^^^H

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MIHB ^^^^^

j^mi
Table 5-17 HJD USE ALTERNATIVES COST SUWARY

Extraction and Treatment Alternative 3. Reduction of VOC Contamination to
Meet ARARs

Alternative Extraction Target Area Contamination greater than ARARs

Alternative Distribution City of Goodyear
96-inch Storm Drain

Total Capital Cost ($) 1,895,000
414,000 4,633,000

Annual Operation and Maintenance Cost (S)
3% 133,000 22,000 249,000 5% 133,000 22,000 248,000 10%
131,000 22 ,000 246 ,000

Present Worth of Operation and Maintenance ($) 5% 10% 3%
2,613,000 429,000 4,886,000 2,040,000 1,059,000
335,000

Total Project Cost (S) 3% 10% 5%
4,508,000 842,000 9,519,000 3,935,000 748,000 8,447,000 2,954,000 587,000

174,000 1,981,000

Roosevelt Irrigation District Buckeye Irrigation District Main Canal Reinfection (east) Reinfection (west) 4. Accelerated Reduction of Contamination to Meet ARARs Contamination greater than ARARs City of Goodyear 96-Inch Storn Drain Roosevelt Irrigation District Buckeye Irrigation District Main Canal Reinjection (east) Reinfection (west) 5. Reduction of VOC Contamination to Exceed ARARS Contamination greater than background City of Goodyear 96-inch Stom Drain

3,814,000

6,614,000

3,111,000

78,000

78,000

77 ,000

1,532,000

1,196,000

621,000

4,642,000

4,307,000

3,732,000

3,794,000 4,229,000 2,196,000 270,000 5,313,000

230,000 250,000 158,000 26,000 289,000

229,000 249,000 157,000 26,000 287,000

227 ,000 247 ,000 156 ,000 26 ,000 285 ,000

4,500,000 4,900,000 3,095,000 510,000 5,659,000

3,517,000

1,831,000

8,293,000 9,129,000 5,290,000

7,311,000 8,059,000

5,625,000 6,222,000 3,450,000 476,000 7,607,000

3,830,000 1,993,000 2,416,000 398,000 4,418,000 1,254,000 207,000 2,294,000

4,612,000 668,000 9,731,000

779,000 10,972,000

1 O1 I-1

3,468,000

73,000

73,000

72 ,000

1,432,000

1,119,000

581,000

4,900,000

4,587,000

4,049,000

4,311,000 4,786,000 2,341,000 290,000 5,677,000

249,000 268,000 178,000 27,000 268,000

248,000 267,000 177,000 27,000 266,000

246 ,000 265,000 175 ,000 26 ,000 264 ,000

4,875,000 5,247,000 3,480,000 526,000 5,246,000

3,810,000

1,983,000

9,186,000

8,121,000 6,294,000 8,887,000 6,920,000 5,057,000 700,000 9,774,000 3,751,000 503,000 7,804,000

4,101,000 2,134,000 10,033,000 2,716,000 411,000 4,096,000 1,410,000 213,000 2,127,000 5,820,000 816,000
10,924,000

Roosevelt Irrigation
District Buckeye Irrigation District Main Canal Reinjection (east) Reinjection (west)

3,655,000

35,000

35,000

35 ,000

695,000

543,000

283,000

4,350,000

4,199,000 3,938,000

4,585,000 5,053,000

222,000 231,000

221,000 230,000

220 ,000 229 ,000

4,352,000 4,529,000

3,402,000 1,771,000 3,541,000 1,843,000

8,937,000 9,582,000

7,988,000

6,357,000

8,594,000 6,897,000

RDD/R103/008-1

Case 2:03-cv-02226-ROS

Document 81-7

Filed 06/27/2006

Page 28 of 31

Table 5-17 (Continued)

Extraction and
Treatment

Annual Operation and Alternative Extraction
____Target Area Alternative Distribution

Present Worth of
Operation and Maintenance ($)
3% 5% 10% 3%

Total Capital
Cost ($1

Alternative

Maintenance Cost ($) 5% 3* 10%

Total Project Cost ($1
5% 10%

6. Accelerated
Reduction of VOC

Contamination greater City of Goodyear
than background 96-inch Storm Drain

2,414,000 384,000 70700 ,4,0

193,000 42,000 4800 3,0

192,000 41,000 4600 3,0

190,000 4,0 100 4200 3,0

3,781,000 816,000 85700 ,7,0

2,953,000 637,000 66600 ,9,0

1,534,000 331,000 34700 ,7,0

6,195,000 12000 ,0,0 1,2,0 56300

5,367,000 1,021,000 1,4,0 37300

3,948,000 714,000 10,523,000

Contaalnation to
Exceed ARARs

Roosevelt Irrigation
District

Buckeye Irrigation District Main Canal
Reinjection (east) Reinfection (west)

4,310,000

8,0 600

8,0 600

85,000

1,692,000

1,322,000

687,000

6,002,000

5,631,000

4,997,000

56400 ,0,0 6,192,000

337,000 360,000

336,000 358,000

334,000 356,000

6,613,000 7,052,000

5,167,000 5,510,000

2,687,000 2,866,000

12,216,000 13,244,000

10,771,000 11,702,000

8,291,000 9,057,000

Ul I Ul
( 0

RDD/B103/008-2

Case 2:03-cv-02226-ROS

Document 81-7

Filed 06/27/2006

Page 29 of 31

I

I

the City o£ Goodyear will need to be treated to drinking water standards.

E I I I f I I I I I I 1 I 1 1 I I

UNIDYNAMICS PHOENIX. INC.. FACILITY SOILS

Listing of Alternatives

A wide range of technologies was identified for VOC-contaminated soil and groundwater for the UniDynamics Phoenix, Inc. (UPI) facility. For soil, the technologies were screened to identify alternatives that would prevent migration of TCE to subunit A and, if necessary, to preserve uses of Subunit C groundwater. For groundwater, the technologies were screened to identify alternatives that would preserve the current uses of Subunit C groundwater and protect future uses. Various processes were combined to form a range of reasonable treatment options to meet the soil objective. The remedial alternatives to be evaluated for soils are: 'o o o o No action Containment through the construction of a cap Collection and onsite treatment Partial removal and treatment/disposal

The selected processes were assembled into options that would satisfy the specific objectives for the UPI site. The options represent combinations, either singly or jointly, of the general response actions and their selected representative processes. These alternatives were evaluated based on effectiveness and implementability; cost was also evaluated but to a lesser extent than other parameters. A range of action levels, determined through analyzing the applicable and relevant or appropriate requirements, was also evaluated for three areas delineated by the level of soil contamination:
o Target Area A is the area where analyses of soil samples collected identified levels of TCE or other VOCs significantly in excess of ADHS-suggested health-based cleanup levels for soil contaminants.

5-53
EDD\R225\027.50

Case 2:03-cv-02226-ROS

Document 81-7

Filed 06/27/2006

Page 30 of 31

o

Target Area B is the area in which analyses of soil samples identified VOC contamination above background levels in vadose zone soils.
Target Area C is defined by soil gas analyses that quantified VOCs in soil gas in concentrations greater than 1 ug/1.

o

Target Areas A, B, and C appear on Figure 5-7.
The evaluation process is summarized in Table 5-18. The resulting potential remedial action alternatives considered for screening were:

o
o
o

No action
Removal by excavation and treatment of soils in Target Area A, B, or C
Soil vapor extraction of VOCs with vapor phase carbon treatment applied in Target Area A, B, or C

Screening of Alternatives

Alternatives were screened based on their ability to meet the above-stated requirements and to meet the remedial response objectives for each media.

B W

Based on the screening of the above-mentioned alternatives, the option for excavation and onsite treatment was originally eliminated based on implementability, effectiveness, and cost factors. However, this alternative may be necessary for effective removal of soil contaminated with methyl ethyl ketone (MEK) and acetone since soil vapor extraction is not effect