THE GROUNDWATER REMEDIATION SYSTEM (GRS)
MONITORING AND OPERATIONS PROGRAM
SEMI-ANNUAL ENGINEERING REPORT
FOR THE PERIOD JANUARY 1, 2007 THROUGH JUNE 30, 2007
AT
LUVATA GRENADA LLC (OEM PLANT)
GRENADA, MISSISSIPPI
PURSUANT TO MISSISSIPPI DEPARTMENT OF ENVIRONMENTAL QUALITY
(MDEQ)
AGREED ORDER 2875-94
DATED JULY 19, 1994
FOR
LUVATA GRENADA LLC
GRENADA, MISSISSIPPI
HAZCLEAN Report No. 07.0306.52
October, 2007
THE GROUNDWATER REMEDIATION SYSTEM (GRS)
MONITORING AND OPERATIONS PROGRAM
SEMI-ANNUAL ENGINEERING REPORT
FOR THE PERIOD JANUARY 1, 2007 THROUGH JUNE 30, 2007
AT
LUVATA GRENADA LLC (OEM PLANT)
GRENADA, MISSISSIPPI
PURSUANT TO MISSISSIPPI DEPARTMENT OF ENVIRONMENTAL QUALITY
(MDEQ)
AGREED ORDER 2875-94
DATED JULY 19, 1994
FOR
LUVATA GRENADA LLC
GRENADA, MISSISSIPPI
______
E. Corbin McGriff, Ph.D., P.E.State of Mississippi Registered
President and Director of OperationsProfessional Engineer No. 5690
______
Michael A. Noone, RPGState of Mississippi Registered
Geological Services ManagerProfessional Geologist No. 0162
Prepared by
HAZCLEAN ENVIRONMENTAL CONSULTANTS, INC.
P. O. Box 16485
Jackson, Mississippi 39236-6485
(601) 922-0766
HAZCLEAN Report No. 07.0306.52
October, 2007
TABLE OF CONTENTS
Page
1.0INTRODUCTION...... 1
1.1Background...... 1
1.2Remedial System Review and Modification...... 2
2.0GROUNDWATER REMEDIATION SYSTEM (GRS) DESIGN SUMMARY.....4
3.0OPERATIONS, MAINTENANCE AND MONITORING ACTIVITIES...... 6
3.1Operations and Maintenance...... 6
3.2GRS Performance Summary...... 6
3.3NPDES Influent and Effluent Sampling Summary...... 7
4.0GROUNDWATER SAMPLING SUMMARY...... 8
4.1Monitoring Well Sampling Activities Summary...... 8
4.2Groundwater Levels and Vacuum Readings...... 12
5.0SITE RESPONSE TO TREATMENT ...... 13
5.1Total TCE Mass Removed (Vapor and Groundwater) ...... 13
5.2TCE Mass Removed from Groundwater...... 13
5.3TCE Mass Removed as Vapor...... 14
5.4GRS Treatment Summary...... 14
6.0REMEDIAL PROGRESS EVALUATION...... 15
6.1Operations Summary...... 15
6.2Findings...... 16
TABLES:
Table 1:Groundwater Elevation Summary Monitoring and
Recovery Wells (June, 2007)...... 17
Table 1-1:Groundwater Elevation Summary Monitoring and
Recovery Wells (Stratigraphic Layer 1)
(June, 2007)...... 24
Table 1-2:Groundwater Elevation Summary Monitoring and
Recovery Wells (Stratigraphic Layer 2)
(June, 2007)...... 26
Table 1-3:Groundwater Elevation Summary Monitoring and
Recovery Wells (Stratigraphic Layer 3)
(June, 2007)...... 29
Table 1-4:Groundwater Elevation Summary Monitoring and
Recovery Wells (Stratigraphic Layer 4)
(June, 2007)...... 32
TABLE OF CONTENTS
(Continued)
Page
Table 1-5:Groundwater Elevation Summary Monitoring and
Recovery Wells (Stratigraphic Layer 5)
(June, 2007)...... 35
Table 2:Laboratory Analytical Report Summary
Argus Analytical, Inc. (June, 2007)...... 37
Table 2-1:Laboratory Analytical Report Summary
(Stratigraphic Layer 1) (June, 2007)...... 44
Table 2-2:Laboratory Analytical Report Summary
(Stratigraphic Layer 2) (June, 2007)...... 46
Table 2-3:Laboratory Analytical Report Summary
(Stratigraphic Layer 3) (June, 2007)...... 49
Table 2-4:Laboratory Analytical Report Summary
(Stratigraphic Layer 4) (June, 2007)...... 52
Table 2-5:Laboratory Analytical Report Summary
(Stratigraphic Layer 5) (June, 2007)...... 55
Table 3:Historical (Original to Current) TCE Groundwater
Analytical Summary - All Wells ...... 57
Table 3-1:Historical (Original to Current) TCE Groundwater
Analytical Summary (Stratigraphic Layer 1)...... 65
Table 3-2:Historical (Original to Current) TCE Groundwater
Analytical Summary (Stratigraphic Layer 2)...... 67
Table 3-3:Historical (Original to Current) TCE Groundwater
Analytical Summary (Stratigraphic Layer 3)...... 70
Table 3-4:Historical (Original to Current) TCE Groundwater
Analytical Summary (Stratigraphic Layer 4)...... 73
Table 3-5:Historical (Original to Current) TCE Groundwater
Analytical Summary (Stratigraphic Layer 5)...... 76
Table 4:Composite Historical TCE Groundwater Analytical Summary
Monitoring and Recovery Wells - All...... 78
Table 4-1:Composite Historical TCE Groundwater Analytical Summary
Monitoring and Recovery Wells (Stratigraphic Layer 1)...... 86
Table 4-2:Composite Historical TCE Groundwater Analytical Summary
Monitoring and Recovery Wells (Stratigraphic Layer 2)...... 89
Table 4-3:Composite Historical TCE Groundwater Analytical Summary
Monitoring and Recovery Wells (Stratigraphic Layer 3)...... 92
Table 4-4:Composite Historical TCE Groundwater Analytical Summary
Monitoring and Recovery Wells (Stratigraphic Layer 4)...... 96
Table 4-5:Composite Historical TCE Groundwater Analytical Summary
Monitoring and Recovery Wells (Stratigraphic Layer 5)...... 100
Table 5:GRS Operational Summary
(March, 2000 through June, 2007)...... 102
TABLE OF CONTENTS
(Continued)
Page
GRAPH:
Graph 1:Cumulative Volatile Organic Compounds (VOCs) Removed
(March, 2000 to June, 2007)...... 111
FIGURES:
Figure 1:Site Layout...... 113
Figure 2-1:Groundwater Elevation Contour Map (Stratigraphic Layer 1)....115
Figure 2-2:Groundwater Elevation Contour Map (Stratigraphic Layer 2)....117
Figure 2-3:Groundwater Elevation Contour Map (Stratigraphic Layer 3)....119
Figure 2-4:Groundwater Elevation Contour Map (Stratigraphic Layer 4)....121
Figure 2-5:Groundwater Elevation Contour Map (Stratigraphic Layer 5)....123
Figure 3-1:TCE Concentration Map (Stratigraphic Layer 1)...... 125
Figure 3-2:TCE Concentration Map (Stratigraphic Layer 2)...... 127
Figure 3-3:TCE Concentration Map (Stratigraphic Layer 3)...... 129
Figure 3-4:TCE Concentration Map (Stratigraphic Layer 4)...... 131
Figure 3-5:TCE Concentration Map (Stratigraphic Layer 5)...... 133
Figure 4:System Recovery Well(s) Vacuum Readings
(Stratigraphic Layers 1 and 2, June, 2007)...... 135
APPENDICES:
Appendix A:GRS Monthly Laboratory Analytical Reports (Effluent and Influent) (January through June, 2007)
Appendix B:Argus Analytical, Inc. Laboratory Reports,
Semi-Annual Groundwater Sampling Event (June, 2007)
1
HAZCLEAN REPORT NO. 07.0306.52PAGE 1
1.0 INTRODUCTION
1.1Background
As part of a Comprehensive Groundwater Investigation (pursuant to Mississippi Department of Environmental Quality [MDEQ] Agreed Order 2875-94, dated July 19, 1994), presently ongoing at the Luvata Grenada LLC (OEM Plant) facility, Grenada, Mississippi, HAZCLEAN ENVIRONMENTAL CONSULTANTS, INC. (HAZCLEAN), has prepared a Groundwater Remediation System (GRS) monitoring and operations program semi-annual engineering report for the facility for the second semi-annual period of the seventh year of operation (January1, 2007 – June30, 2007). This semi-annual report was compiled from HAZCLEAN’s field and operations/maintenance data and from laboratory analytical data reported to HAZCLEAN by Argus Analytical, Inc., Ridgeland, Mississippi.
Initial assessment activities at the OEM facility were conducted from 1989 – 1992. Assessment activities were requested by the Mississippi Department of Environmental Quality (MDEQ) pursuant to the discovery of elevated levels of Trichloroethene (TCE) in the groundwater monitoring wells (GWMWs) located on the east adjoining property (Koppers Industries, Inc.).
Luvata contracted HAZCLEAN to prepare a Work Plan (Report No. 93.1.306.20.256; December7, 1993) for a preliminary groundwater investigation and to develop a report on historical waste management practices (Report No.93.1.306.20.286; December14, 1993) as part of the Work Plan.
Initial assessment activities were completed in 1995 and in November, 1997, a “Groundwater Remediation System and Monitoring Program Design for the Comprehensive Groundwater Investigation Program (Revised)”; Report No. 96.1.306.27.447, was submitted to the MDEQ.
From November, 1999 through February, 2000, installation of monitoring wells, recovery wells, and the groundwater remediation system were completed. The GRS was initially started in March, 2000. Except for periods of adjustments and maintenance to improve the recovery efficiency, the system has operated continuously.
The following report incorporates a summary of the GRS monthly Operations and Maintenance (O&M), semi-annual groundwater sampling event and reporting activities for the second semi-annual period of the seventh year of operation (January1, 2007 – June30, 2007).
The site has been characterized as consisting of five (5) identified water-bearing layers and referred to as Stratigraphic Layers: 1, 2, 3, 4 and 5. Notably, after careful review of historical data, Stratigraphic Layer 3/4, which had only one (1) well (MW-52-30) placed within this layer, will no longer be recognized as a distinct layer. This well has been placed in Stratigraphic Layer 3.
1.2Remedial System Review and Modification
Lennox International, Heatcraft’s former parent company, initiated a voluntary project review in November 2003 to evaluate all phases of the overall program including site characterization, system efficacy, system operational components, and system efficiency. Available site characterization and remediation system documentation was reviewed and evaluated to determine the extent to which the objectives stated in the Order/Voluntary Agreement between MDEQ and Heatcraft OEM had been and were being met.
In an effort to more quantitatively evaluate the current GRS groundwater capture zone and, thus, system effectiveness a numerical groundwater modeling assessment was conducted. After successful quantitative statistical calibration of the steady-state groundwater flow model, the finite element grid was modified to accommodate the addition of pumping nodes so that, in addition to evaluating current system effectiveness, a variety of alternative scenarios could be evaluated. Results of the simulations demonstrated that complete capture has not been achieved. However, aggregate site data do show that natural processes, including dispersion, diffusion, sorption, and intrinsic biological processes, have attenuated downgradient plume migration.
The results of that review recommended retaining the current system’s concept and objectives, but re-designing the mechanical aspects of the system. MDEQ concurred with this recommendation and the groundwater extraction-and-treatment system is being reconfigured to provide better capture of the more highly contaminated portions of the plume and by separating the SVE system to help ensure capture of the vapor plume and more efficient removal of contaminant mass from the vadose zone. The modified groundwater remediation system has been designed to contain the source zone and to prevent further migration of the plume (greater than or equal to 1 mg/L) off site. Based on hydrogeologic modeling, high concentration plume capture will be achieved with 30 wells, and eight of these wells will be existing GRS recovery or monitoring wells the others are newly drilled wells. These well locations were selected through groundwater modeling performed on data from a series of slug tests performed on existing deep and shallow wells. These locations are designed to provide capture of the dissolved-phase plume and protect against off-site migration.
The SVE system will utilize a dedicated blower rather than the existing liquid ring pump; this is expected to result in improved efficiency and the ability to better control and monitor the system. The SVE system will also use dedicated extraction wells to accommodate collection of accurate vapor-flow measurements, accurate measurement of contaminant concentrations in the vadose, and accurate vacuum measurements. With this information, resources can be reassigned and the vadose source can be more aggressively attacked and more quickly treated.
Installation of the new groundwater extraction-and-treatment and SVE system is currently underway and is to be completed in the fall of 2007.
2.0GROUNDWATER REMEDIATION SYSTEM (GRS) DESIGN SUMMARY
The GRS was installed and started operations in March, 2000. The system is a Dual Phase Vapor Extraction (DPVE) type and was manufactured by Ejector Systems, Inc., Addison, Illinois. The GRS incorporates a 50 horsepower Travaini Liquid Ring Vacuum Pump (LRVP) to produce a vacuum to recover Volatile Organic Compounds (VOCs), specifically, Trichloroethene (TCE) impacted groundwater from a system of 27recovery wells. Extracted groundwater and soil vapors are drawn into the GRS’s primary air-water separator (knock-out tank) which separates vapors from recovered groundwater. The vapors are drawn though the LRVP and a secondary air/moisture separator prior to discharge to the atmosphere. The groundwater is pumped from the primary knockout tank, utilizing a pump which has been designed to operate under vacuum conditions, for treatment through a series of three (3) separate air stripper units.
The GRS utilizes a central four-inch (4") Schedule 40 PVC piping network to apply a vacuum to the vadose and saturated zones surrounding the recovery wells. Soil vapors and groundwater are delivered to the GRS via a single four-inch (4") piping network. In order to produce groundwater from deeper wells (greater than 30 feet in depth), a dedicated one-inch (1") PVC air line delivers compressed air to each applicable well. By utilizing vacuum assisted air-lift, downhole mechanical pumps are eliminated, thereby, reducing maintenance and/or replacement costs. Influent piping, effluent piping and GRS components are routed as illustrated on Figure 1, Site Layout.
The GRS major system components include the following:
a.A series of three (3) separate air strippers consisting of one (1) 2tray air stripper system and two (2) separate 4tray air stripper systems rated for up to 50gallons per minute (gpm) liquid influent. Each tray contains approximately twelve (12) aeration tubes for water treatment. Each stripper discharges the residual Volatile Organic Compound (VOC) vapors through separate exhaust stacks.
b.One (1) – fifty (50) horsepower Liquid Ring Vacuum Pump (LRVP). The GRS has been designed in order to combine maximum groundwater recovery and maximize vapor recovery at the facility. By combining both, the overall time required for remediation of the facility is minimized.
c.Hour run-time meter (wired to the LRVP).
d.Remote telemetry system with restart and monitoring capabilities.
e.Phase reversal monitor and relay to protect electrical hardware from spontaneous phase reversals, utility maintenance errors, etc.
f.Voltage overload protection relays to protect electrical hardware from voltage spikes due to lightning strikes, etc.
g. Air/water and air/air heat exchanger.
h.Ten (10) horsepower rotary screw air compressor with 110 psi capacity for continuous duty operation with filtration system and gauges to provide air lift in the deeper recovery wells (RW-2-60, RW-2-118, RW460, RW-5-60, RW13-60, RW-14-60, RW-15-60, RW-19-60, and RW-20-60).
i.8.5' W x 28.5' L x 9.5' H aluminum hull building with removable walls.
The GRS unit and components are enclosed in a cyclone fenced compound to protect the unit and components from vandalism, damage from traffic and to protect the general public in accordance with MDEQ regulations.
3.0 OPERATIONS, MAINTENANCE AND MONITORING ACTIVITIES
3.1Operations and Maintenance
HAZCLEAN visits the facility a minimum of two (2) times per month for scheduled O&M activities, to collect system influent and effluent water samples under the National Pollutant Discharge Elimination System (NPDES) permit and to record the groundwater remediation system (GRS) data. System data to be recorded consists of the following:
▪Runtime hours;
▪Stripper blower values;
▪Totalizing flowmeter gallons;
▪AWS-1 vacuum;
▪AWS transfer and other pump readings;
▪Liquid ring exhaust and liquid ring pump temperatures.
O&M activities for the semiannual period include maintenance on the flow meter totalizer, installation of various system gauges, scheduled lubrication of all motors, cleaning of the AWS1 and AWS2 tanks and conductance probes, repairs to Blowers 1 and 2, replacement of drop tubes in recovery wells, repair leaking make-up water pump, cleaning of air strippers and other routine GRS maintenance activities. HAZCLEAN conducts unscheduled visits as needed.
3.2GRS Performance Summary
During this performance period (January1, 2007 – June30, 2007), the GRS processed a combined total volume of 1,126,731gallons of groundwater and make-up waters. The ratio of make-up water to groundwater has never been determined, but a ratio of 1:4 is reasonable, based on previous meter readings. The GRS operated a total of 3,716 of 4,344hours for an operating efficiency of 85.5percent (%).
Since the GRS start-up in March, 2000, the GRS has extracted approximately 42,526,840gallons of groundwater and make-up water (Note: groundwater plus make-up waters will be referred to as groundwater throughout this report). The GRS has operated a total of 54,340hours of 64,032 calendarhours for an operating efficiency of 84.9percent (%).
3.3NPDES Influent and Effluent Sampling Summary
Since system start-up and monthly thereafter, National Pollutant Discharge Elimination System (NPDES) groundwater permit sampling has been conducted. The NPDES Permit No. MS0001368 was issued in 1998, reissued September16, 2003, and expires August31, 2008. The permit requires bimonthly monitoring of:
- Flow Rate
- Biochemical Oxygen Demand (5-Day)
- Total Suspended Solids
- Trichloroethene (TCE)
- Vinyl Chloride
- Oil and Grease
- pH
As required by the NPDES Permit, on a monthly basis, all influent and effluent samples are analyzed for certain Volatile Organic Aromatics (VOAs), - specifically targeting: Benzene; Carbon Disulfide; 1,1-Dichloroethene (1,1-DCE); CIS-1,2-Dichloroethene (CIS-1,2-DCE); Trans1,2Dichloroethene (Trans-1,2-DCE); Ethylbenzene, Styrene; Toluene; Trichloroethene (TCE), Vinyl Chloride and Xylenes (Total). Additionally, once per month, the effluent system discharge water is analyzed for Oil and Grease and Total Suspended Solids (TSS). The effluent water pH is field measured and provided to the laboratory (see Appendix A, GRS Monthly Laboratory Analytical Reports [Effluent and Influent]). In September, 2003, the NPDES Permit was modified and BOD5 was removed from the analysis criteria.
During the course of the GRS start-up evaluation (March 8 through July 1, 2000), the GRS was subjected to several operating scenarios to determine the optimal removal and treatment of VOC impacted soils and groundwater. Discharged TCE ranged from below method detection limits (BMDL) to a maximum of 0.082milligrams per liter (mg/l). Upon receipt and review of analytical results yielding TCE effluent concentrations above the method detection limit, the GRS was adjusted to reduce TCE effluent concentrations. During portions of April, 2000 and May, 2000, the GRS discharged TCE in concentrations above method detection limits (0.006 mg/l - 0.082mg/l); however, the levels were within the discharge limitations (no stated permit levels) in the MDEQ, NPDES Permit Number MS0001368.
Since May, 2000, all monitored effluent chemicals of concern concentrations have been in compliance with the NPDES Permit.
4.0GROUNDWATER SAMPLING SUMMARY
4.1Monitoring Well Sampling Activities Summary
Sampling of groundwater monitoring/recovery wells for the second semi-annual period (January1, 2007 – June30, 2007) of the seventh year of operations was performed in June, 2007, in accordance with Quality Assurance Protocols detailed in the United States Environmental Protection Agency (USEPA), Region IV, Environmental Investigations Standard Operating Procedure and Quality Assurance Manual (EISOPQAM) (November, 2001).
Polyethylene-Based Equilibrator Passive Diffusion Bag (PDB) disposable samplers and disposable bailers were used to obtain groundwater samples which were submitted for laboratory analysis for Volatile Organic Compound (VOC) concentrations. PDB samplers are suitable for obtaining concentrations of VOCs in groundwater and are a suggested method for long-term monitoring of VOCs in groundwater monitoring wells at well-characterized sites. The effectiveness of the use of a single PDB sampler in a monitoring well is dependent upon horizontal flow through the well screen and that the quality of the water is representative of the groundwater in the aquifer directly adjacent to the well screen.
A typical PDB sampler consists of a low-density polyethylene lay-flat tube closed at both ends which is filled with deionized water prior to installation within the monitored well. The sampler is positioned within the well bore, approximately 8” – 12” from the well bottom. The amount of time that the PDB sampler is left in the monitoring well prior to recovery depends on the time required by the PDB sampler to equilibrate with localized groundwater and the time required for the environmental disturbance caused by sampler deployment to return to ambient conditions. The rate that the deionized water within the PDB sampler equilibrates with localized groundwater depends on multiple factors, including the type of compounds being sampled and the water temperature. The samplers are left in place long enough for the localized groundwater, contaminant distribution, and flow dynamics to restabilize following PDB sampler deployment. Laboratory, field data and pilot studies support that a minimum of two to three (23) weeks is adequate time for equilibration for VOCs. From May30 – 31, 2007, the PDB samplers were installed in monitoring wells located at the following stations: