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Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Tutu Wellfield Superfund Site Proposed Cleanup Plan Public Meeting SCHEDULED Thursday, August 23, 2018 7:00PM Grace Gospel Chapel St. Thomas, USVI *528394* 528394 Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Cecilia Echols – EPA Community Involvement Coordinator Caroline Kwan – EPA Project Manager Meeting Participants Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 EPA will present the conclusions of the Focused Source Remedial Investigation, Risk Assessment and Feasibility Study EPA will present and discuss the Proposed Plan for the cleanup of the contaminant source areas of the Tutu Site Public is encouraged to provide comments tonight and until Friday September 7, 2018 Meeting Objectives Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Meeting Agenda Superfund Overview Site Background Remedial Investigation Risk Assessment Feasibility Study Preferred Remedy Questions/Comments? Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Toxic waste disposal disasters prompted law passage by Congress in 1980 Provides Federal funds for cleanup of hazardous waste sites Allows EPA to respond to emergencies involving hazardous substances Empowers EPA to compel Potentially Responsible Parties to pay for or conduct site clean up Superfund Law Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Superfund Cleanup Process Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Meeting Agenda Superfund Overview Site Background Remedial Investigation Risk Assessment Feasibility Study Preferred Remedy Questions/Comments? Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Tutu Wellfield Superfund Site Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 1969 - Curriculum Center property owned by LAGA Industries Ltd. (LAGA), a textile manufacturing facility 1970 to 1978 – Purchased by Duplan Corporation and began dry cleaning operations using Tetrachloroethene (PCE) 1979 to 1981 - Purchased by Panex, sold to VIDE 1982 to 2017 - Multi-use building by VIDE Site History Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 • 1982 to 1989 - Multiple investigations by EPA and Potentially Responsible Parties (PRPs) • 1994 to 1995 - Remedial Investigation (RI) identified co-mingled plumes with chlorinated volatile organic compounds (CVOCs) and petroleum/gasoline components • September 1995 - Site listed on the National Priorities List (NPL) • Studies concluded that the CVOC plume with dichloroethene (DCE), tetrachloroethene (PCE), trichloroethene (TCE), and vinyl chloride (VC) originated at or near the Curriculum Center Site History Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 August 1996 - Operable Unit 1 (OU1) Record of Decision (ROD) selected groundwater extraction and treatment to restore groundwater • 2004 - Construction of the remedy completed and included two groundwater treatment systems to treat the CVOC plume • 2004 to 2013 - Groundwater treatment facilities operated by EPA; transferred to USVI in 2013 • April 2015 - Operable Unit 2 (OU2) created by EPA to investigate potential additional contaminant source areas Site History Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Status of OU1 Remediation  Current Remedy: Groundwater extraction, ex-situ treatment, discharge to Turpentine Run, and institutional controls  Groundwater treatment systems installed at the Curriculum Center property and near O’Henry Dry Cleaners  SVE system installed at the Curriculum Center and operated from 2004 to 2006; significant decrease in influent concentrations  Insufficient reduction of contamination at the Curriculum Center area Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Meeting Agenda Superfund Overview Site Background OU2 Remedial Investigation Risk Assessment Remedial Alternatives Preferred Remedy Questions/Comments? Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 OU2 Study Area - Curriculum Center Property Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 OU2 Focused Source RI Activities conducted at the Curriculum Center property April 2016 to June 2017 Surface geophysical survey Rock matrix diffusion sampling and analysis Monitoring well installation Borehole geophysical investigation Packer testing and sampling Groundwater sampling Groundwater level monitoring Dense non-aqueous phase liquid (DNAPL) monitoring Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 OU2 Groundwater Sampling Results Characterized bedrock aquifer; defined two hydraulically conductive zones DNAPL is present and will act as an ongoing source Dissolved phase CVOC contamination is present Contaminants present in the rock matrix will continue to back-diffuse into groundwater The degree of natural degradation varies throughout the Curriculum Center area The capture zone of the existing extraction system does not extend far enough in a downgradient direction Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Monitoring Well Exceedances Summary Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Conceptual Site Model Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Meeting Agenda Superfund Process Overview Site Background Remedial Investigation Risk Assessment Remedial Alternatives Preferred Remedy Questions/Comments Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 OU2 Risk Assessment Process Step 1 • Hazard Identification Step 2 • Exposure Assessment Step 3 • Toxicity Assessment Step 4 • Risk Characterization Drinking water use pathway Source: Thinkstock Photos Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 OU2 Risk Assessment Summary • Contaminated groundwater presents an unacceptable exposure risk. • VC, TCE, PCE and cis-1,2-DCE pose a lifetime cancer risk exceeding 1x10-4 • Vapor intrusion from PCE and TCE are also of potential concern to workers • Future use of the building is currently unknown Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Meeting Agenda Superfund Process Overview Site Background Remedial Investigation Feasibility Study Preferred Remedy Questions/Comments? Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Remedial Alternatives – Cleanup Options Alternative 1 – No Action Alternative 2 – Expand Existing Pump and Treat System Alternative 2A – Reinjection Alternative 2B – Air Sparging/ Soil Vapor Extraction (AS/SVE) Alternative 2C – In Situ Chemical Oxidation (ISCO) Alternative 2D – Surfactant Flushing Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Remedial Alternatives – Cleanup Options (continued) Alternative 3 – In Situ Thermal Treatment and Pump and Treat Alternative 4 – In Situ Steam Injection and Pump and Treat Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Alternative 1 – No Action • No Action to remediate the contaminated groundwater • No Institutional Controls Pros – Basis for comparison with other process options Cons – Contaminants in groundwater will continue to spread. Human health and environmental risks remain Costs- • Capital Cost: $0 • Annual operations and maintenance (O&M) Costs: $0 • Present-Worth Cost: $0 Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Remedial Alternatives – Common Elements for Alternatives 2, 3 and 4  Pre-Design Investigation (PDI)  Institutional Controls  Upgrade the current system  Long-term monitoring until clean up levels are achieved  Site Management Plan  Five Year Reviews Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Alternative 2 – Expand Existing Pump and Treat System • Expand existing system, add 2 new extraction wells downgradient • Upgrade current system capacity • Replace existing equipment • Alternate pumping from source area wells • Dual-phase extraction (DPE) / enhanced fluid recovery (EFR) from source area wells Pros - containment of plume; removal of DNAPL Cons - remedial timeframes are long Timeframe- • Estimated to be in excess of 30 years; • Pump and treat (P&T) and long term monitoring (LTM) costs estimated for 30 years. Costs- • Capital Cost: $4,616,924 • Annual operations and maintenance (O&M) Costs: $7,600,039 • Present-Worth Cost: $12,273,313 Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Alternative 2A – Reinjection Enhancement of Alternative 2 with reinjection of treated water downgradient through 2 new injection wells Pros- better hydraulic control and maintaining water balance Cons - additional hydrogeological analysis needed; reinjection wells will need maintenance; long remedial timeframes Timeframe - • Estimated to be in excess of 30 years; • P&T and LTM costs estimated for 30 years. Costs- • Capital Cost: $425,260 • Annual O&M Costs: $51,364 plus Alt 2 • Present-Worth Cost: $476,624 Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Alternative 2B – AS/SVE Enhancement of Alternative 2 with air sparging and soil vapor extraction (AS/SVE) in source areas; add 25 SVE and 30 AS wells Pros- mobilize residual DNAPL within the zone influenced by air sparging; may increase the mass removal rate reducing the timeframe of the P&T system Cons- air flow may not be uniform, depends on how well the injected air permeates from injection point, connectivity of fractures and groundwater mounding Timeframe- • The AS/SVE system at source area for 5 years; • Based on calculations, downgradient area will reach drinking water standards in 25 years; • LTM costs estimated for 30 years Costs - • Capital Cost: $1,710,790 • Annual O&M Costs: $169,501 plus Alt 2 • Present-Worth Cost: $1,880,291 Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Alternative 2C – ISCO Enhancement of Alternative 2 with in situ chemical oxidation (ISCO) cylinders in select source area wells; 64 cylinders in 12 monitoring wells; replaced yearly Pros- passive treatment for source area concentrations; less expensive Cons - will affect the bioactivity in the aquifer Timeframe - • ISCO at source area for 5 years; • Based on calculations, downgradient from treated source area will reach drinking water standards in 25 years; • LTM estimated for 30 years Costs- • Capital Cost: $93,920 • Annual O&M Costs: $98,620 plus Alt 2 • Present-Worth Cost: $192,540 Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Alternative 2D – Surfactant Flushing Enhancement of Alternative 2 with surfactant flushing in source areas; 2 deep injection wells, 5 shallow injection wells Pros - removal of source area concentrations and DNAPL Cons- effective only if there is contact; ability of the formation to accept a sufficient volume of surfactant solution is unknown Timeframe - • Surfactant flushing at source area for 1 year; • Based on calculations, downgradient from treated source area will reach drinking water standards in 25 years; • LTM estimated for 26 years. Costs - • Capital Cost: $1,222,799 • Annual O&M Costs: Same as Alt 2 • Present-Worth Cost: $1,222,799 Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Alternative 3 – In Situ Thermal Treatment and Pump and Treat System • In situ thermal treatment to target DNAPL in source areas and pump and treat for hydraulic control; 260 to 270 heater wells, co-located with 260 to 270 vacuum extraction points • Add 2 downgradient extraction wells and upgrade the current treatment system capacity and equipment Pros - ability to penetrate fractured rock matrix and to treat DNAPL and CVOCs Cons - high capital costs Timeframe - • Thermal at source area for 2 years; • Based on calculations, downgradient from treated source area will reach perimeter P&T wells in 10 years; • LTM estimated for 12 years. Costs- • Capital Cost: $79,015,003 • Annual O&M Costs: $4,094,323 • Present-Worth Cost: $83,221,216 Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Alternative 4 – In Situ Steam Injection and Pump and Treat • In situ steam injection in source areas to release DNAPL with pump and treat for hydraulic control, 60 steam injection wells and 30 multi-phase extraction wells • Add 2 downgradient extraction wells and upgrade the current treatment system capacity and equipment Pros - mobilize DNAPL which will be captured by the extraction wells Cons - effectiveness of steam injection relies on its ability to contact, heat, and physically displace contaminants; high capital costs Timeframe- • Steam treatment at source area for 2 years; • Based on calculations, downgradient from treated source area will reach drinking water standards in 25 years; • LTM estimated for 27 years Costs- • Capital Cost: $23,541,419 • Annual O&M Costs: $7,169,229 • Present-Worth Cost: $30,773,828 Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 EPA’s Nine Criteria for Selecting Cleanup Plans EPA uses nine criteria to evaluate remedial alternatives presented in the Feasibility Study and choose which to implement Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Threshold Criteria 1. Overall Protection of Human Health and the Environment: Will the plan protect people and the plant and animal life on and near the Site? EPA cannot and will not choose a plan that does not meet this basic criterion. 2. Compliance with Applicable or Relevant and Appropriate Requirements: Does the alternative meet all federal and state environmental statutes, regulations and requirements? The chosen cleanup plan must meet this criterion. Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Balancing Criteria 3. Long-Term Effectiveness and Permanence: Will the effects of the cleanup last or could it be ineffective and cause future risks? 4. Reduction in Toxicity, Mobility or Volume through Treatment: Does the alternative reduce the harmful effects, spread of, and amount of the contaminated material? 5. Short Term Effectiveness: How soon will site risks be reduced? Could the cleanup cause short-term hazards to workers, residents or the environment? 6. Implementability: Is the alternative technically feasible? Are the right goods and services (i.e. treatment machinery, space at an approved disposal facility) available to complete the plan? 7. Cost: What is the total cost of an alternative over time? EPA must choose a plan that gives necessary protection at reasonable cost. Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Modifying Criteria 8. State/Territory Acceptance: Do state/territory environmental agencies agree with EPA’s proposal? 9. Community Acceptance: Acceptance of preferred alternative by the impacted community will be assessed following the public comment period. Provide your comments. Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Remedial Alternatives Cost Estimates Alternative Capital Cost Annual Operation & Maintenance Periodic Cost Total Present Value 1 – No Action $0 $0 $0 $0 2 – Expand Existing Pump and Treat $4.6 million $433,315 (Years 1 to 30) $176,750 (Year 30) $12.2 million 2A – Reinjection $425,260 $11,500 (Years 1 to 30)* Same as Alt 2 (Year 30) $476,624 ** 2B – AS/SVE $1,710,790 $37,950 (Years 1 to 5)* Same as Alt 2 (Year 30) $1,880,291** 2C – ISCO $93,920 $22,080 (Years 1 to 5)* Same as Alt 2 (Year 30) $192,540** 2D – Surfactant Flushing $1,222,799 Included in Alt 2 (Years 1 to 26) Included in Alt 2 (Year 26) Included in Alt 2 3 – In Situ Thermal Treatment and Pump and Treat $79,015,003 $433,315 (Years 1 to 12) $176,750 (Year 12) $83,221,216 4 – In Situ Steam Injection and Pump and Treat $23,541,419 $433,315 (Years 1 to 27) $176,750 (Year 27) $30,773,828 Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Meeting Agenda Superfund Overview Site Background Remedial Investigation Remedial Alternatives Preferred Remedy Questions/Comments Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Preferred Remedy - Alternative 2 , Expand Existing Groundwater Extraction and Ex-Situ Treatment (Pump and Treat) with Alternative 2A, Reinjection Expansion of the existing pump and treat system to include downgradient extraction wells; Upgrade pump and treat system to higher flow rate; Upgrade all treatment equipment to accommodate additional flow and improve efficiency; Reinjection of treated water; Alternate pumping from existing monitoring wells with high contaminant concentrations; Dual phase extraction from source area wells; and Long-term groundwater monitoring. Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Contingency Remedy - Alternative 2 , Expand Existing Groundwater Extraction and Ex-Situ Treatment (Pump and Treat) with Alternative 2B, AS/SVE Expansion of the existing pump and treat system to include downgradient extraction wells; Upgrade pump and treat system to higher flow rate; Upgrade all treatment equipment to accommodate additional flow and improve efficiency; Air Sparging/SVE at source areas and Long-term groundwater monitoring. Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Questions and Comments? Please address written comments no later than Friday, September 7, 2018 to: Caroline Kwan US EPA 290 Broadway, 20th Floor New York, NY 10007-1866 Phone: (212) 637-4275 E-mail: kwan.caroline@epa.gov Region 2 serving the people of New Jersey, New York, Puerto Rico and the U.S. Virgin Islands 8/27/2018 Tutu Wellfield Superfund Site *** Public Meeting Thursday, August 23, 2018 Thank you! https://www.epa.gov/superfund/tutu-wellfield