3-24-11 ISCO Pilot Test Report-Rev3

Chevron Perth Amboy Refinery
1200 State Street

Perth Amboy, NJ 08861

IN-SITU CHEMICAL OXIDATION (ISCO) PILOT TEST REPORT
FOR SWMU 43
CHEVRON PERTH AMBOY REFINERY
PERTH AMBOY, NEW JERSEY

NOVEMBER 2009

URS PROJECT NO. 11130492

PREPARED BY:

URS CORPORATION
201 Willowbrook Boulevard
Wayne, New Jersey 07474
ISCO Pilot Test Report
Chevron Perth Amboy Refinery November 2009

i
TABLE OF CONTENTS

Page
EXECUTIVE SUMMARY .......................................................................................................1
1.0 INTRODUCTION .................................................................................................................. Z
1.1 Overview ..................................................................................................................... Z
1.2 Organization ............................................................................................................... Z
2.0 SITE DESCRIPTION AND BACKGROUND .................................................................. 8
2.1 Site Description .......................................................................................................... 8
2.2 Geology ....................................................................................................................... 8
2.3 Hydrogeology ............................................................................................................. 9
2.4 Nature and Extent of Contamination..................................................................... 10
2.5 SWMU 43 Characteristics ...............................................................................16
3.0 SUMMARY OF ISCO BENCH TEST ............................................................................. 19
4.0 OBJECTIVES AND SCOPE OF ISCO PILOT TEST .................................................... 25
5.0 ISCO TREATMENT SYSTEM DESCRIPTION ............................................................ 2
5.1 Technology Overview ............................................................................................. 2
5.1.1 FR ISCO Chemistry ................................................................................ 2
5.1.2 ISCO Pilot Test Equipment .................................................................... 2Z
6.0 ISCO PILOT TEST PROCEDURES ................................................................................. 29
6.1 ISCO Pilot Test Summary ...................................................................................... 29
6.2 Pre-Treatment Soil and Groundwater Sampling Event ...................................... 30
6.3 Injection Points and Piezometer Installation ........................................................ 32
6.4 Mobilization ............................................................................................................. 33
6.5 Site Preparation and Staging .................................................................................. 33
6.6 Chemical Preparation .............................................................................................. 31
6.7 Chemical Injection ................................................................................................... 31
6.8 Field Screening ........................................................................................................ 35
6.9 Post-Treatment Soil and Groundwater Sampling Events ................................... 35
7.0 RESULTS AND DISCUSSION ......................................................................................... 3Z
7.1 ISCO System Operations ........................................................................................ 3Z
7.2 Problems Encountered and Resolved .................................................................... 3Z
7.3 Field Screening Parameters Results ...................................................................... 38
7.4 Soil Sampling Results ......................................................................................... 1211
7.5 Groundwater Sampling Results ............................................................................. 50
7.6 Radius of Influence.................................................................................................. 55
7.7 Petroleum Hydrocarbon Mass Reduction ......................................................... 585Z
8.0 CONCLUSIONS .................................................................................................................. 3
9.0 REFERENCES .................................................................................................................. Z8

ii
LIST OF TABLES
Page
3.1 ISCO Jar Test Results Soil 1 ................................................................................... 20
3.2 ISCO Jar Test Results Soil 2 ................................................................................... 21
3.3 ISCO Soil Column Test Aqueous Results Soil 2 .................................................... 23
3.4 ISCO Soil Column Test Soil Results Soil 2 ........................................................... 24
7.1 Summary of Changes in Field Screening Parameters ....................................................
7.2 ISCO Pilot Test Soil Sampling Results ..................................................................... 44
7.3 Volume Reduction for Soil Modeling Results ........................................................... 49
7.4 ISCO Pilot Test Groundwater Sampling Results ....................................................... 51
7.5 Volume Reduction for Groundwater Modeling Results ............................................ 54
7.6 ISCO Pilot Test Percentage Concentration Reduction Results......................................
7.7 ISCO Pilot Test Petroleum Hydrocarbon Mass Reduction in Soil ............................ 58
7.8 ISCO Pilot Test Mass Petroleum Hydrocarbon Mass Reduction in Groundwater .... 59
7.9 Mass Reduction for Soil and Groundwater Modeling Results .................................. 61

LIST OF FIGURES

1. USGS Site Vicinity Map
2. Summary of AOCs, SWMUs and PAOCs Location Map
3. Chevron Sitewide Groundwater Shallow Contours 2-21-07
4. ISCO Pilot Test System Process Flow Diagram
5. SWMU 43 ISCO Pilot Test Location Map
6. ISCO Pilot Test Pre and Post Treatment Results
7. ISCO Pilot Test Radius and Area of Influence and Percentage Concentration
Reductions

LIST OF APPENDICES

A - ISCO Pilot Test Logs
A1 - Soil Boring Logs
A2 - Piezometer and Injection Wells Construction Logs, and NJDEP Certification Forms
As and Bs
A3 - Process Data Logs
A4 - Field Screening Data Logs and Charts
A5 - Groundwater Sampling Logs
B - ISCO Pilot Test Figures
C - ISCO Pilot Test Pictures


iii


iv
LIST OF ACRONYMS AND ABBREVIATIONS

AOC Area of Concern
AOI Area of Investigation
ASARCO American Smelting and Refining Company

bgs Below Ground Surface
BTEX Benzene, Toluene, Ethylbenzene, and Xylene

C Degrees Celsius
CAMU Corrective Action Management Unit
CEA Classification Exception Area
CFR Code of Federal Regulations
CEMC Chevron Environmental Management Company
cm/s Centimeters per Second
CM Corrective Measure
CMS Corrective Measures Study
COC Contaminant of Concern
CVOC Chlorinated Volatile Organic Compound
CY Central Yard
cu yd Cubic Yard

DNAPL Dense Non-Aqueous Phase Liquid
DO Dissolved Oxygen
DRO Diesel Range Organic

EPA Environmental Protection Agency
EY East Yard

F Degrees Fahrenheit
FR Fentons Reagent

gpm Gallons Per Minute
GWQS Groundwater Quality Standard

HSWA Hazardous and Solid Waste Amendments

IP Injection Point
IRM Interim Remedial Measure
ISCO In-Situ Chemical Oxidation

LDR Land Disposal Restriction
LEL Lower Exposure Limit
LNAPL Light Non Aqueous Phase Liquid
LRM LNAPL Removal Measure

v
LTTD Low Temperature Thermal Desorption

MDL Method Detection Limit
mg/kg Milligrams per Kilogram (ppm)
MNA Monitored Natural Attenuation
MPE Measuring Point Elevation
MSL Mean Sea Level
mV Millivolts
MY Main Yard

NA Not Applicable
NAPL Non Aqueous Phase Liquid
NCP National Contingency Plan
NF North Field
NFA No Further Action
NFE North Field Extension
NJDEP New Jersey Department of Environmental Protection
NRDCSCC Non-Residential Direct Contact Soil Cleanup Criteria
NRDCSCS Non-Residential Direct Contact Soil Cleanup Standard

O&M Operation and Maintenance
ORP Oxidation/Reduction Potential
OVM Organic Vapor Monitor
OSHA Occupational Health and Safety Administration

PAH Polycyclic Aromatic Hydrocarbon
PCOC Principal Contaminant of Concern
PDI Pre-Design Investigation
PID Photo Ionization Detector
PPE Personal Protective Equipment
ppm Parts Per Million
PQL Practical Quantitation Level
psig Pounds per Square Inch Gauge
PVC Poly-Vinyl Chloride

QA/QC Quality Assurance/Quality Control

RCRA Resource Conservation Recovery Act
RFI RCRA Facility Investigation
ROI Radius of Influence

SRFI Supplemental RFI
SVOC Semi-Volatile Organic Compound
SWMU Solid Waste Management Unit

TCLP Toxicity Characteristic Leaching Procedure

vi
TEL Tetra-Ethyl Lead
TOS Top of Screen
TPH Total Petroleum Hydrocarbons

ug/L Micrograms per Liter (ppb)
URS URS Corporation
U.S. United States
USCS Unified Soil Classification System
USEPA United States Environmental Protection Agency

VOC Volatile Organic Compound

1
EXECUTIVE SUMMARY

This report presents the results of an In-Situ Chemical Oxidation (ISCO) Pilot Test
conducted at the Chevron Perth Amboy Refinery in Perth Amboy, New Jersey (Site). The
report covers the testing performed from September 17th through October 2nd, 2008 in the
Solid Waste Management Unit (SWMU) 43. URS Corporation (URS) conducted this work
for Chevron Environmental Management Company (CEMC) and in general accordance with
the Request for Authorization of Discharge to Groundwater by Permit-by-Rule Proposed In-
Situ Chemical Oxidation Pilot Test for Treatment of Impacted Soil and Groundwater dated
July 29, 2008 (URS. 2008a).

The Chevron U.S.A. Products Company (Chevron) Perth Amboy Refinery site is located at
1200 State Street, Perth Amboy, New Jersey. The Site is primarily located in the industrial
zone of Perth Amboy and is bounded to the east by the Arthur Kill. A small portion of the
Site extends into Woodbridge Township. A United States Geological Survey (USGS) Site
Vicinity Map is shown in Figure 1.

SWMU 43 is a former below grade surface impoundment located in the northern portion of
the Main Yard, approximately 280 feet long and 254 feet wide, which was in service from
approximately 1955 to 1975. The unit was designed to manage oily stormwater, process
water and solids associated with process waters. Dredged material from the Surge Pond
(SWMU 2), No. 4 Separator (SWMU 35), and the Old Pond (SWMU 40) also may have been
placed in SWMU 43 between late 1956 and early 1957. SWMU 43 also was reportedly used
as a spent catalyst disposal area in the mid 1950s. During the course of its usage, SWMU 43
received RCRA-listed hazardous wastes F037, F038, K051, and K052. The impoundment
was taken out of service and filled in 1977 (URS. 2007b).

The volume of SWMU 43 contaminated soil is estimated to be 33,200 cubic yards based on
the area of SWMU 43 and the depth to native soil. As a result of the fill material being
mixed in with the residual sludges from hazardous wastes, the entire volume of SWMU 43 is
considered to be potentially listed hazardous waste under the United States Environmental
Protection Agency (USEPA) contained-in rule.

URS conducted an ISCO bench test in March, 2008 in order to evaluate the applicability of
ISCO to remediate the organic contamination in the soil and groundwater at the Site.

In order to further evaluate the effectiveness of ISCO in treating the organic contaminated
soil and groundwater at the Site, a pilot test was performed in SWMU 43 in the vicinity of
URS Corporation (URS)
(URS. 2008a).
(URS. 2007b)
URS conducted

2
soil sample location S2249, the area with the best ISCO bench test results, as well as the only
area in SWMU 43 with a benzene concentration exceedence of both its New Jersey
Department of Environmental Protection (NJDEP) Non-Residential Direct Contact Soil
Cleanup Criteria (NRDCSCC), as well as its USEPA Toxicity Characteristic Leaching
Procedure (TCLP) Characteristic Hazardous Waste Regulatory Level.

The duration of the pilot test was two weeks (10 days). Based on the results of the bench
test, Fentons Reagent (FR) was the selected oxidant for the pilot test.

The scope of work for the ISCO pilot test consisted of the following activities: 1) pre-pilot
test sampling, 2) installation of injection points and a piezometer, 3) mobilization, 4)
injection of ISCO chemicals, 5) post-pilot test sampling, and 6) preparation of an ISCO Pilot
Test Report.

The ISCO pilot test was conducted over a 10 day period from September 17
th
to October 2
nd
,
2008. Prior to the start of the test, a pre-treatment sampling event was conducted on June
19
th
and 23
rd
, 2008, in order to obtain baseline soil and groundwater samples. Three soil
borings were advanced by East Coast Drilling, Inc. (ECDI) using a truck mounted Geoprobe
rig under the supervision of a URS geologist. Two boring locations were completed as
injection point (IP) 1 (monitoring well (MW) 278) and piezometer (PZ) 0018. One soil
sample was collected from each of these borings. Additionally, groundwater samples were
collected from monitoring wells MW-0061 and MW-0062. The soil and groundwater sample
locations were selected based on their proximity to the ISCO bench test location, soil sample
S2249, the SWMU 43 location with the highest total and TCLP benzene concentrations in
the soil.

During the course of the ISCO pilot test, the following chemicals and corresponding
quantities were injected into the SWMU 43 area soil and groundwater: 1) 550 pounds of
ferrous sulfate heptahydrate as an aqueous solution, 2) 2,990 gallons of 25% hydrogen
peroxide solution, and 3) 1,280 gallons of 75% phosphoric acid solution. A number of soil
vapor and groundwater quality parameters were measured during the injection activities to
monitor the progress of the ISCO reactions and ensure safe conditions were being
maintained.

Following injection activities, two post-treatment sampling events were conducted to
demonstrate the effectiveness of the ISCO pilot test and determine its radius of influence in
the SWMU 43 area soil and groundwater. The first post-treatment sampling event was
conducted on October 15, 2008, approximately two weeks following the completion of
f a URS geologist.

3
injection activities. Five soil borings were advanced by ECDI in a similar fashion as the pre-
treatment sampling event. One soil sample was collected from each of these borings.
Additionally, groundwater sample were collected from monitoring wells MW-0061 through
MW-0063.

The second post-treatment sampling event was conducted on March 18-19, 24-25, and April
1, 2009, approximately five months following the first post-treatment sampling event. Ten
soil borings were advanced by ECDI in a similar manner as the pre-treatment sampling
event. One soil sample was collected from each of these borings. Additionally, groundwater
samples were collected from monitoring wells MW-0060 through MW-0062, and MW-0065.

Based on the results presented in Section 7, the ISCO pilot test was very effective in
achieving its objectives including: 1) to confirm the effectiveness of ISCO in treating the
organic contaminated soil and groundwater at the Site, specifically benzene in soil at
concentrations above 13 mg/kg and groundwater at concentrations above 100 ug/L, TCLP
benzene at concentrations above 0.5 mg/L, and benzo(a)pyrene in soil at concentrations
above 10 mg/kg, and 2) to obtain engineering data to support the design of a full scale ISCO
remediation system including the injection flow rates of the reagents, the injection pressures,
the radius of influence around the injection points, and the duration of treatment.

Total regulated volatile organic compounds (VOCs) and semi-volatile organic compounds
(SVOCs) masses/concentrations in soil were reduced by 34.8% and 46.5%, respectively, with
a total mass/concentration reduction of VOCs and SVOCs of 38.2%. Additionally, 1,255 kg
of VOCs and 693 kg of SVOCs, for a total of 1,948 kg of regulated organic contaminants in
the soil were destroyed during the test, including 54.9 kg of benzene and 26.0 kg of
benzo(a)pyrene, the organic principal contaminants of concern (PCOCs). Further, the
mass/concentration reductions for benzene and benzo(a)pyrene in soil were 57.3 and 70.1% ,
respectively. Also, the concentration reduction for TCLP benzene was 69%. Finally, the
average concentrations of benzene, TCLP benzene and benzo(a)pyrene in the soil within the
area of influence of the ISCO pilot test following the second post-treatment sampling event
are 6.18 mg/kg, 0.098 mg/L, and 1.63 mg/kg, respectively. Each of these concentrations are
below the criteria, regulatory level, and action level for benzene, TCLP benzene, and
benzo(a)pyrene of 13 mg/kg, 0.5 mg/L, and 10 mg/kg, respectively, as given in the
Corrective Measures Study (CMS) Final Report (URS. 2008c).

Total regulated VOCs and SVOCs masses/concentrations in groundwater were reduced 0%
and 94.1%, respectively, with a total mass/concentration reduction of VOCs and SVOCs of
82%. Additionally, 0 kg of VOCs and 6.67 kg of SVOCs, for a total of 6.67 kg of regulated
(URS. 2008c).

4
organic contaminants in the groundwater were destroyed during the test, including 0.227 kg
of benzene and 0.082 kg of benzo(a)pyrene. Further, the mass/concentration reductions for
benzene and benzo(a)pyrene in groundwater were 54.9 and 92.2%, respectively. Finally, the
average concentration of benzene in the groundwater within the radius of influence of the test
following the second post-treatment sampling event is 50.6 ug/L, below the action level of
100 ug/L of benzene for recommending ISCO as a corrective measure for contaminated
groundwater as shown in Table 7.1 of the CMS Final Report (URS. 2008c).

Significant mass/concentration reductions of benzene and benzo(a)pyrene in exceedence of
their respective criteria and action level were also achieved. Benzene and benzo(a)pyrene
exceedences in soil were reduced by 46.4 and 100%, respectively, with a combined mass
reduction in soil of 53.9%. Additionally, 6.27 kg of benzene and 2.20 kg of benzo(a)pyrene
exceedences, for a combined mass of 8.47 kg of organic PCOCs, were destroyed during the
test. Also, benzene exceedences in groundwater were reduced by 32.5%, with a benzene
exceedence mass reduction of 0.032 kg as a result of the test. Finally, 100% of the TCLP
benzene exceedences were destroyed during the test.

The minimum groundwater horizontal radius of influence for the ISCO pilot test is 120 feet,
or the distance from injection point IP-02, the approximate center of the injection area, and
well MW-0060, which had a benzene concentration reduction of 60%. Additionally, the
minimum soil horizontal area of influence was calculated to be approximately 10,600 square
feet, or the area inside a rectangle that encompasses all of the soil sampling locations (see
Figure 7). Each of the sampling results for these locations showed concentration reductions
greater than 20% for VOCs, SVOCs, benzene, and/or benzo(a)pyrene. In fact, the soil
sampling location furthest from IP-02, S2221, had concentration reductions of VOCs,
benzene, and TCLP benzene of 99%, 99.7%, and 77.3% respectively. S2221 is located
approximately 141 feet from IP-02. Finally, the minimum soil horizontal area of influence is
consistent with visual observations of ISCO byproducts seeping from the surface soil during
and immediately after injection activities. These byproducts seeps were photo documented
and are displayed in Appendix C.

The results of the field analytical parameters monitored during the course of injection
activities demonstrate further evidence of ISCO reactions occurring in the subsurface soil and
groundwater within the ISCO pilot test area including the following: 1) significant increases
in the soil vapor carbon dioxide and VOC concentrations, 2) significant increases in the
dissolved oxygen (DO) and oxidation/reduction potential (ORP) of the groundwater, and 3) a
significant decrease in the pH of the groundwater. The carbon dioxide concentrations, which
are a product of the ISCO reactions, showed an increase of up to 62,400% in the soil vapor
(URS. 2008c)

5
during the course of the peroxide/acid solution injection activities. Additionally, the ORP
concentrations of the groundwater changed from reductive (as indicated by the negative
values) to oxidative (as indicated by the positive values) during the course of the
peroxide/acid solution injection activities. These changes occurred at distances of up to 52
feet from the respective injection points. No monitoring point (wells or piezometers) were
monitored at distances greater than 52 feet from an injection point.
Critical engineering data was obtained during the course of the ISCO pilot test to support the
design of a full scale ISCO remediation system including the following: 1) injection flow
rates of the ISCO reagents, 2) injection pressures, 3) the duration of treatment, and 4) the
radius of influence around the injection points.
The ISCO reagents injection flow rates ranged from 1 to 15 gpm. Additionally, injection
pressures generally ranged from 2 to 30 psig. Also, the duration of the ISCO pilot test was
10 days with an average volume of FR solutions injected per day of 672 gallons. This
volume would be expected to increase during the full scale ISCO application. Finally, the
radius of influence around the injection points was discussed above.
The volumes of contaminated soil and groundwater media demonstrated to be remediated to
levels below their respective criteria and action level for the organic PCOCs as a result of the
ISCO pilot test are 4,910 yd
3
and 12,100 yd
3
, respectively.
As demonstrated above, ISCO has been shown to be an effective CM for both groundwater
and soil contaminated media, including both vadose zone and saturated zone soils. Three of
the 10 soil samples collected in the pre-treatment and second post-treatment sampling events
were collected in the vadose zone (S2582, S2087, and S2221). The average concentration
reductions for VOCs, SVOCs, and TCLP benzene in the sampling results for these vadose
zone locations were 99.3%, 53.2%, and 88.2%, respectively.
Based on the aforementioned conclusions, the ISCO pilot test confirmed the
recommendations made in the CMS Final Report regarding its selection as a CM for the
following contaminated media: 1) SWMU 43 and non-SWMU 43 hazardous soil for
characteristically hazardous benzene areas, 2) non-hazardous soil for benzene and other
organic contaminated soil in exceedence of its respective criteria/standard, and 3)
groundwater with benzene concentrations >100 ug/L. Further, ISCO is no longer necessary
as a CM in SWMU 43 because the characteristically hazardous benzene areas were
eliminated as a result of this test. Finally, a follow up ISCO pilot test would not be
recommended for vadose zone soils, based on the effectiveness demonstrated in this test for
ISCO to remediate these soils. However, it would be recommended to consider changing the

6
CM for benzo(a)pyrene >10 mg/kg impacted soil from excavation, ex-situ stabilization, and
disposal in the CAMU to ISCO based on the results of this test to effectively reduce this
contaminated media.


7
1.0 INTRODUCTION

1.1 Overview

This report presents the results of an In-Situ Chemical Oxidation (ISCO) Pilot Test
conducted at the Chevron Perth Amboy Refinery in Perth Amboy, New Jersey (Site). The
report covers the testing performed from September 17th through October 2nd, 2008 in the
Solid Waste Management Unit (SWMU) 43. URS Corporation (URS) conducted this work
for Chevron Environmental Management Company (CEMC) and in general accordance with
the Request for Authorization of Discharge to Groundwater by Permit-by-Rule Proposed In-
Situ Chemical Oxidation Pilot Test for Treatment of Impacted Soil and Groundwater dated
July 29, 2008 (URS. 2008a).

1.2 Organization

This document is organized as follows:

Section 1.0 provides an overview of the test and organization of the report;
Section 2.0 includes a Site description and background for the project;
Section 3.0 gives a summary of the ISCO bench test results;
Section 4.0 includes the objectives and scope for the project;
Section 5.0 gives a description of the ISCO treatment system;
Section 6.0 presents the description of the pilot test procedures followed;
Section 7.0 provides a discussion of the results;
Section 8.0 contains the conclusions for the test based on the results;
Section 9.0 gives the recommendations for follow-up actions based on the
conclusions for the test; and
Section 10.0 provides a list of references used in the preparation of this report.

URS Corporation (URS) conducted
(URS. 2008a).

8
2.0 SITE DESCRIPTION AND BACKGROUND

2.1 Site Description

The Chevron U.S.A. Products Company (Chevron) Perth Amboy Refinery site is located at
1200 State Street, Perth Amboy, New Jersey. The Site is primarily located in the industrial
zone of Perth Amboy and is bounded to the east by the Arthur Kill. A small portion of the
Site extends into Woodbridge Township. A United States Geological Survey (USGS) Site
Vicinity Map is shown in Figure 1.

Chevron purchased the facility in 1946 from Barber Asphalt Company who had owned and
operated the facility since 1911. The Chevron facility operated as a full scale petroleum
refinery from 1946 to 1983. Its operation included the production of liquefied petroleum gas,
gasoline, fuel oil, and asphalt. In 1983, Chevron reduced its operations to refining asphalt
and continued operations as a petroleum terminal and continues with this operation today.

2.2 Geology

The general stratigraphy of the Refinery consists of six major units which overly the bedrock,
including fill; organic clay and peat (Clay Horizon A); glacial till and outwash; and three
members of the Raritan Formation the Woodbridge Clay (Clay Horizon B), Farrington
Sand (Sand Horizon B), and Raritan Fire Clay (Clay Horizon C). The stratigraphic units
beneath the Refinery were first identified and described by Woodward-Clyde (1981). The
following summarizes the geologic characteristics of each Yard of the Site previously
described in the CMS Final Report dated November 2008.

Main Yard
In general, the Main Yard lithology is composed of the following stratigraphic progression:
fill overlying a discontinuous peat layer, gray clay (Clay Horizon A) and glacial till.
Groundwater throughout the Main Yard was detected in the fill layer. The fill contains
varying amounts of sands, silts and clay, and ranges in thickness from 3 to 15 feet. The clay
is described as Clay Horizon A and can be as much as 30 feet thick in close proximity to the
Woodbridge Creek. The glacial till appears to be continuous in the Main Yard and can
extend to a thickness of about 40 feet in some areas.

SWMU 43 is a former surface impoundment located in the northern portion of the Main
Yard.


9
East Yard
In general, the East Yard lithology is composed of the following stratigraphic progression:
fill overlying a discontinuous peat layer, gray clay (Clay Horizon A) and glacial till.
Groundwater throughout the East Yard was detected in the fill layer. The fill contains
varying amounts of sands, silts and clay, and is encountered throughout the entire East Yard
at depths ranging from 4 to 29 feet bgs. Discontinuous lenses are found at the base of the
clay at depths ranging from 15 to 25 feet bgs (SAIC. 2008). Also, beneath Clay Horizon A
and glacial till is clay Horizon B, the Woodbridge Clay. Borings conducted in previous
investigations have shown this clay to be from 20 to 30 feet thick in the East Yard.

Central Yard
In general, the Central Yard lithology is composed of the following stratigraphic progression:
fill overlying gray clay (Clay Horizon A) and glacial till. Groundwater throughout the
Central Yard was detected in the fill layer perched on the native clay and till. The fill
contains varying amounts of sands, silts and clay.

The thickness of the fill layer varies from 7 to 19 feet, and beneath this layer is native clay
(Clay Horizon A), the thickness of which varies between 3 to 19 feet. Intermittent layers of
till were observed within the clay layer.

2.3 Hydrogeology

The shallow groundwater in the Refinery is mainly observed in the unconfined fill layer,
perched on native clay, peat and till. Shallow groundwater elevation contours are shown on
Figure 3.

Main Yard
As indicated by the groundwater elevation contours on Figure 3, generally the groundwater
flow direction is in a northeasterly to southeasterly direction from a high at MW-0039 of 9.56
feet above mean sea level (MSL) to a low of -1.75 feet above MSL at NF-13 along the
Woodbridge Creek.

Hydraulic gradients were determined by drawing equipotential elevation lines perpendicular
to the flow line and dividing the drop in elevation between flow lines by the distance between
these two lines. The hydraulic gradients measured across the Main Yard ranged from 0.05 to
0.016 ft/ft.


10
East Yard
flow direction is in a northeasterly direction from a high at MW-129 (State Street parking lot)
of 22.51 feet above MSL to a low of 3.46 feet above MSL in MW-254. The contours
suggests a ridge of groundwater trending northeast-southeast through the central portion of
the East Yard.

In the central portion of the East Yard the gradient was estimated to be 0.21 while in the
outer boundaries (southwest, northeast & northwest) of the East Yard the hydraulic gradient
ranged from 0.014 to 0.0125 ft/ft. To the north of this ridge, the groundwater flows in a
northeasterly direction; while to the south of this ridge the groundwater flows in a
southeasterly direction.

Central Yard
flow direction is in a north to northeasterly direction north of well MW-110, while it is
southeasterly south of well MW-230. Additionally, the groundwater flow direction is in a
westerly direction west of both wells.

The hydraulic gradients measured across the Central Yard vary significantly from the
northern portion of the Site to the southern portion. In the north, gradients range from 0.18 to
0.02 ft/ft, while in the south, the average gradient is 0.01 ft/ft, except in the immediate
vicinity of the Garretson Avenue right-off-way. In this area, the native surface dips to the
east or southeast. The hydraulic gradient in this area between wells MW-169R and MW-191
was gauged at approximately 0.03 ft/ft in 2005 (Chevron, 2005).

2.4 Nature and Extent of Contamination

Numerous environmental investigations have been performed at the Site over the last 13
years. These investigations have documented the nature and extent of the soil and
groundwater contamination of the Site. This section of the report summarizes the
information presented in the latest environmental investigation report, the CMS PDI.

Based on the distribution of petroleum hydrocarbons in the Site soil and groundwater, it
appears that the Site soil and groundwater contamination is related to its proximity to
tetraethyl lead (TEL) burial areas, historical waste management practices, and operational
and storage areas. The surface releases of hydrocarbons in these areas migrated down
through surface and subsurface soils and into the groundwater. This migration was largely

11
vertical, and there is little evidence of lateral migration of hydrocarbons through the vadose
zone. Petroleum hydrocarbons still present in the vadose zone may continue to leach to
groundwater. Additionally, light non-aqueous phase liquid (LNAPL) is found on top of the
groundwater table in several areas of the Site. While significant LNAPL was present at the
Site in the past, only relatively small, discontinuous areas of LNAPL are currently present.

As expected at a refinery site, the primary contaminants encountered at the Site are
petroleum constituents and associated compounds. These include volatile organic
contaminants such as benzene, polycyclic aromatic hydrocarbons such as benzo(a)pyrene,
and metals such as lead. Impacts have been observed in both soil and groundwater. The
SWMUs are the remnants of historic waste managements units that are no longer used by the
Refinery.

The AOCs consist of suspected petroleum discharge locations, areas with stained soils,
aboveground storage tank basins, and fill areas. The SWMUs mostly consist of suspected
tetraethyl lead (TEL) burial sites and former stormwater or wastewater ponds or basins. The
contaminants of concern (COCs) are petroleum products and associated volatile organic
compounds (VOCs), lead and other metals, and some polynuclear aromatic hydrocarbons
(PAHs). However, based on extensive soil and groundwater sampling and an evaluation of
the relative toxicities of the contaminants present, the primary COCs (PCOCs) present at the
Site are benzene, lead, TEL, benzo(a)pyrene, and arsenic. The PCOCs also serve as indicator
compounds for their broader analytical parameter category, such as volatile organic
compounds (VOCs), semi-volatile organic compounds (SVOCs), and metals, because
exceedences of other COCs are generally found in the presence of exceedences of the PCOCs
within the same samples.

Benzene and several PAHs comprise the majority of facility-related exceedences in the soil
and groundwater. An analysis of the numerous Site soil samples revealed benzene and
benzo(a)pyrene as the primary indicator analytes for VOCs and SVOCs, respectively, in the
Refinery soils. The occurrence of benzo(a)pyrene site-wide is primarily sporadic with the
exception of the northwestern corner and north-central portion of the Main Yard, where it is
more common. Various metals have also been noted in exceedence of their soil evaluation
criteria; however, with the exception of lead found at TEL sites and to a lesser degree
antimony, the presence of metals does not appear to correlate well to areas impacted by
historic operations. During the SRFI, frequent occurrences of arsenic were found in the soils
in the southeastern portion of the East Yard. Investigations conducted by the American
Smelting and Refining Company (ASARCO) revealed similar results on their property in the
area adjacent to the Chevron EY. Since ASARCO once operated a smelter on their property

12
with large stacks, the Site arsenic contamination is most likely from dispersion and
deposition of emissions from past operations on the ASARCO site.

A summary of the overall results of the latest investigation from the CMS PDI by
contaminated media is discussed below.

Hazardous Soil
In general, except for the arsenic contamination, the occurrence of hazardous soil
contamination is related to its proximity to former TEL burial areas, historical waste
management practices, and operational and storage areas. The refinery related hazardous soil
contamination does not extend off-site.

The total volume of soil found to be characteristically hazardous for lead, as determined by
TCLP lead testing, was delineated and estimated to be 3,000 cubic yards. The total volume
of soil found to be characteristically hazardous for benzene, as determined by TCLP benzene
testing, was delineated and estimated to be 800 cubic yards.

The volume of SWMU 43 contaminated soil is estimated to be 33,200 cubic yards based on
the area of SWMU 43 and the depth to native soil. As a result of the fill material being
mixed in with the residual sludges from hazardous wastes, the entire volume of SWMU 43 is
considered to be potentially listed hazardous waste, if excavated, under the USEPA
contained-in rule. SWMU 43 received RCRA-listed hazardous wastes F037, F038, K051,
and K052.

Non-Hazardous Soil
In general, except for the arsenic contamination, the occurrence of non-hazardous soil
contamination is related to its proximity to former TEL burial areas, historical waste
management practices, and operational and storage areas. The Refinery related non-
hazardous soil contamination does not extend off-site.

The soil contaminated areas with benzene in concentrations >13 mg/kg were delineated
during the CMS PDI. The cross-sections along transects in the soil benzene contaminated
areas illustrated that the depth of benzene contamination varied from 0.5 to 15.5 feet below
ground surface (bgs). With the exception of the SWMU 8 area, the results showed that
benzene contamination throughout the Refinery has been found primarily in the fill material.
The total volume of soil benzene contamination >13 mg/kg was estimated to be 38,800 cubic
yards.


13
The soil lead contaminated areas at the Site were delineated during the CMS PDI. The cross-
sections along transects in the soil lead contaminated areas illustrated that the depth of lead
contamination in concentrations above its NJDEP NRDCSCS of 800 mg/kg varied from 0.5
to 32 feet bgs. The results showed that lead contamination throughout the Refinery has been
found primarily in the fill material. However, cross-sections along transects in the soil lead
contaminated areas of the East Yard and Central Yard showed lead contamination extending
to the native material underneath the fill. The total volume of soil lead contamination >800
mg/kg was estimated to be 17,700 cubic yards.

Arsenic Impacted Soil
The SRFI delineated the extent of soil with arsenic contamination in concentrations
exceeding its NJDEP NRDCSCC of 20 mg/kg. This area was estimated to be 41,900 square
yards. This contamination is located predominantly in the southeastern portion of the East
Yard and is associated with deposition of stack emissions from past operations performed at
the ASARCO smelting facility. Additionally, SWMU 39 in the Main Yard had arsenic
concentrations in surface soil (0 2 feet bgs) greater than 20 mg/kg.

Benzo(a)pyrene >10mg/kg Impacted Soil
The contoured areas of soil contaminated with benzo(a)pyrene in concentrations greater than
10 mg/kg were quantified and found to be consistently contaminated with residual non-
aqueous phase liquid (NAPL) based on observances of NAPL in boring logs at these sampled
locations. The total volume of soils contaminated with benzo(a)pyrene in concentrations
greater than 10 mg/kg is estimated to be 6,600 cubic yards.

LNAPL Impacted Soil
The LNAPL areas at the Site were estimated in the 2005, 2006 and 2007 Stabilization
Measures Status Reports based on the average LNAPL thickness found in numerous Site
monitoring and recovery wells. The LNAPL areas estimated in 2007 are 3,300, 6,800 and
500 square yards for LNAPL thicknesses >0.01' and <0.1', >0.1' and <0.5', and >0.5' and <1',
respectively.

Shallow Contaminated Groundwater
The groundwater contaminated areas at the Site were evaluated during various investigations.
Historical groundwater results showed that, in general, the occurrence of groundwater
contamination is related to the migration of soil contamination from former TEL burial areas,
historical waste management practices, and operational and storage areas. With the
exception of the groundwater contamination delineated during the CMS PDI in SWMU 8 in

14
the East Yard and AOCs 22 and 36 in the Central Yard, groundwater contamination in the
Refinery was found not to extend off-site.

The groundwater contamination was evaluated in the shallow water bearing zone within the
unconfined fill layer, which is perched on native clay, peat and till. The delineated
contaminated groundwater includes the following estimates based on modeling of
groundwater sampling results during the CMS PDI: 1) a volume of 850,000 cubic yards of
groundwater contaminated with benzene in concentrations from 1 to 100 ug/L (outside the
source areas soil contamination), and 122,000 cubic yards contaminated with benzene at
concentrations greater than 100 ug/L (within the source areas soil contamination), and 2) a
volume of 68,000 cubic yards of groundwater contaminated with lead in concentrations from
5 to 50 ug/L (outside the source areas soil contamination), and 19,000 cubic yards of
groundwater contaminated with lead at concentrations greater than 50 ug/L (within the
source areas soil contamination). In general, the groundwater flows to the northeast in the
Refinery. However, the delineated groundwater contamination plumes are not migrating into
the water bodies bordering the northern and eastern boundaries of the Site where the
groundwater discharges, but are stable within the boundaries of the refinery with minor off-
site migration in the SWMU 8 and AOCs 22 and 36 areas, as mentioned above.

2.5 SWMU 43 Characteristics

SWMU 43 is a former below grade surface impoundment located in the northern portion of
the Main Yard, approximately 280 feet long and 254 feet wide, which was in service from
approximately 1955 to 1975. The unit was designed to manage oily stormwater, process
water and solids associated with process waters. Dredged material from the Surge Pond
(SWMU 2), No. 4 Separator (SWMU 35), and the Old Pond (SWMU 40) also may have been
placed in SWMU 43 between late 1956 and early 1957. SWMU 43 also was reportedly used
as a spent catalyst disposal area in the mid 1950s. During the course of its usage, SWMU 43
received RCRA-listed hazardous wastes F037, F038, K051, and K052. The impoundment
was taken out of service and filled in 1977 (URS. 2007b).

During closure activities associated with the north field basin (NFB) and surge pond, a
concrete containment cap was installed on top of most of the SWMU 43 area. The pad was
constructed of reinforced concrete to support the closure activities (SAIC. 2003). SWMU 43
is also one of the 17 LNAPL areas identified at the Site. The unit has been undergoing
interim remedial measures (IRMs) using belt skimmers since October 2000 under Module
III-B.7 of the HSWA Permit.

(URS. 2007b)

15
Geology and Hydrogeology
A subsurface geologic assessment is provided below based on material descriptions recorded
in borehole logs including 33 soil borings, piezometers, and wells installed during the
LNAPL investigation and included in the RFI Report, 52 soil borings installed during the
CMS PDI and 3 soil borings installed during this ISCO pilot test in the SWMU 43 area.

SWMU 43 subsurface soils consist of topsoil and/or reinforced concrete overlying fill and
native soils. The fill thickness ranges between approximately 10 and 22.5 feet and consists
of sand, clay, and gravel. Catalyst beads were frequently observed within the fill material
and debris and asphalt fragments were observed in small proportions. Native soil underlying
fill consists of peat or clay with natural organic matter. The shallow groundwater in SWMU
43 is encountered in the unconfined fill layer. The groundwater level has been observed
between one feet bgs in S2581 and 15.5 feet bgs in S2245. In addition, the groundwater level
has been observed to fluctuate between one and 10 feet bgs in SWMU 43 monitoring wells
and piezometers (Parsons. 2009).

Woodbridge Creek, the nearest surface water body, is approximately 500 feet downgradient
of SWMU 43. However, a sheet pile wall installed around the eastern downgradient portions
of SWMU 43 impedes the flow of groundwater in the direction of Woodbridge Creek.
Groundwater flow patterns since the installation of the sheet pile wall appear to be mounding
at the sheet pile wall, resulting in a localized southwesterly flow direction (SAIC. 2003).

Nature and extent of contamination
The soil contamination found at SWMU 43 prior to this ISCO pilot test, based on the latest
environmental investigation report, the CMS PDI, is summarized below. The 75 soil samples
collected during the CMS PDI were analyzed in the following manner: 1) 74 samples were
analyzed for VOCs and TCLP VOCs, 2) 74 samples were analyzed for SVOCs and TCLP
SVOCs, 3) 72 samples were analyzed for metals and TCLP metals, and 5) two samples were
analyzed only for total lead and TCLP lead. Additionally, Figure 5 ISCO Pilot Test
Location Map depicts the SWMU 43 summary of PCOCs distribution in soil and shallow
groundwater, which was also shown in Figure 25 of the CMS PDI.

Soil VOCs results included the results from benzene, toluene, ethylbenzene, and xylenes
(BTEX) and TCLP VOCs analyses, which were compared to their USEPA F037, F038
K051, and K052 Non-Wastewater LDR Standard and USEPA D005-D043 TCLP
Standard (40 CFR 268.40), respectively. 24 samples had exceedences of one or more
BTEX constituent. Benzene, toluene, ethylbenzene, and xylenes exceedences ranged
from 10 to 82, 15 to 170, 11 to 200, and 34 to 1,200 mg/Kg, respectively. Nine samples
in SWMU 43 had benzene exceedences. TCLP benzene was the only TCLP VOC found

16
to be in exceedence of its USEPA TCLP Standards. Two samples had TCLP benzene
exceedences of 0.88 and 0.57 mg/L.

Benzene modeling results showed three areas of benzene concentrations between 13-100
mg/Kg including soil sample locations S2249, S2246 and S2241 (see Figure 5). The
estimated area and volume of benzene contaminated soil with concentrations greater than
13 mg/Kg in SWMU 43 are 772 square yards and 1,081 cubic yards, respectively. In
addition, a TCLP benzene contour of 0.5 mg/L was prepared around soil samples S2249
and S2087, which had TCLP concentrations of 0.88 and 0.57 mg/L, respectively. The
estimated area and volume of TCLP benzene contaminated soil with concentrations
greater than 0.5 mg/L in SWMU 43 are 47 square yards and 36 cubic yards, respectively.
Soil SVOCs results included the results from SVOCs and TCLP SVOCs analyses which
were compared to their USEPA F037, F038, K051, and K052 Non-Wastewater LDR
Standard and USEPA D005-D043 TCLP Standards (40 CFR 268.40), respectively.
SVOC exceedences were detected in 49 of the 74 soil samples analyzed for SVOCs. The
SVOC exceedences included acenapthene, anthracene, benzo(a)anthracene,
benzo(a)pyrene, chrysene, naphthalene, phenanthrene, pyrene, o-Cresol, and m&p-
Cresol. Naphthalene and phenanthrene were detected at higher concentrations compared
to the other SVOCs. The highest concentration of naphthalene and phenanthrene was
detected in soil samples S2256 and S2246 at concentrations of 270 and 220 mg/Kg,
respectively. Additionally, benzo(a)pyrene had exceedences above its USEPA F037-
F038 and K048-K052 Non-Wastewater Standard of 3.4 mg/Kg in 27 soil samples, and
above its NJDEP NRDCSCC of 0.66 mg/Kg in 45 soil samples in concentrations between
0.82J and 61 mg/Kg. Out of these 45 soil samples, 15 soil samples had benzo(a)pyrene
exceedences greater than 10 mg/Kg, the site-specific soil cleanup recommended action
level for benzo(a)pyrene. The results showed no exceedences of TCLP SVOCs.
Benzo(a)pyrene modeling results showed an estimated area and volume of
benzo(a)pyrene contaminated soils with concentrations above its site-specific soil
cleanup recommended action level of 10 mg/Kg in SWMU 43 of 2,579 square yards and
3,869 cubic yards, respectively, based on the average thickness of benzo(a)pyrene
exceedences of 1.5 yards estimated for the Main Yard. The major portion of
benzo(a)pyrene exceedences is shown in the northwestern portion of SWMU 43 (see
Figure 5).
Soil metals results included the results from metals and TCLP metals analyses, which
were compared to their NJDEP NRDCSCC and USEPA D005-D043 TCLP Standards
(40 CFR 268.40), respectively. Metal exceedences were detected in eight out of the 72
soil samples analyzed for metals, as well as two soil samples analyzed only for total lead

17
in SWMU 43. Total lead was the only metal found to be in exceedence of its NJDEP
Non-Residential Direct Contact Soil Cleanup Standard (NRDCSCS) at concentrations
between 843 and 3,010 mg/Kg. The highest concentration of total lead was detected in
soil sample S2466 located in the southeast portion of SWMU 43. The one TCLP lead
exceedence (70.1 mg/L) was found in soil sample S2258 located in the central portion of
SWMU 43, which had a total lead concentration of 2,060 mg/Kg.
Lead modeling results showed an estimated area and volume of total lead contaminated
soil with concentrations greater than 800 mg/Kg in SWMU 43 of 699 square yards and
699 cubic yards, respectively, based on the average thickness of lead exceedences of one
yard estimated for the Main Yard. Contours delineating the lead contaminated area
included soil samples S2256, S2240, S2258, S2249, S2246, S2250, S2257 and S2466
(see Figure 5). In addition, TCLP lead contours of 5 and 50 mg/L were prepared around
soil sample S2258. The estimated area and volume of TCLP lead contaminated soil with
concentrations greater than 5 mg/L in SWMU 43 are 127 square yards and 63 cubic
yards, respectively, based on the average thickness of TCLP lead exceedences of 0.5 yard
estimated for the Main Yard.
The shallow groundwater contamination at SWMU 43 is based on VOCs, SVOCs and metals
analytical results, which were compared to their evaluation criteria. Historically, SWMU 43
groundwater samples have been collected from monitoring wells MW-0029 in October,
1997, MW-0057 and MW-0065 between 2002 and 2008, MW-0060 between 2006 and 2008,
and MW-0061 and MW-0062 in June, 2008.

In general, benzene is the only VOC detected above its GWQS in SWMU 43. Historical
benzene data indicates undetected concentrations at MW-0057; however, MW-0060 and
MW-0065 had benzene concentrations ranging from 31 to 69 ug/L, and from non-detect to
18 ug/L, respectively. Benzene concentration in MW-0061 and MW-0062 were 42 and 370
ug/L, respectively. SVOCs data collected from MW-0061, and MW-0062 indicated
exceedences of 11 SVOCs including benzo(a)anthracene, benzo(a)pyrene,
benzo(b)fluoranthene, benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, bis(2-
ethylhexyl)phthalate, indeno(1,2,3-cd)pyrene, 2-methylnaphthalene, naphthalene, and
phenanthrene. Metals data collected from MW-0029, MW-0057, and MW-0060 indicate
exceedences of 6 metals including aluminum, arsenic, barium, cadmium, manganese and
sodium.

LNAPL contamination at SWMU 43 covers an area of approximately 73,800 square feet.
LNAPL within SWMU 43 is encountered above and below the water table. Based on the
findings of the 2008 Stabilization Measures Status Report, LNAPL thicknesses ranged
between a non-measurable coating to 0.9 feet during 2008. Based on laboratory analyses, the

18
LNAPL at SWMU 43 consists of a mixture of crude oil, gasoline, and diesel with a specific
gravity of 0.904 and viscosity of 21.7 centistokes at 10C.


19
3.0 SUMMARY OF ISCO BENCH TEST

ISCO Bench Test Scope of Work
URS conducted an ISCO bench test in March, 2008 in order to evaluate the applicability of
ISCO to remediate the organic contamination in the soil and groundwater at the Site. Two
soil samples (Soils 1 and 2) were collected from the Site for this bench test. Soil 1 was
collected in the vicinity of soil boring location S2249 in SWMU 43 between the concrete pad
and the surge pond, the location with the highest benzene concentration in SWMU 43. Soil 2
was collected in the vicinity of soil boring location S1016 in SWMU 18 in the Main Yard
between tanks 300, 301, 326, and 327, the location with the highest benzene concentration at
the refinery. These soils were collected in appropriate sampling containers, and shipped
under ice in a cooler to Spectrum Analytical, Inc., located in Agawam, MA, to conduct the
ISCO bench test. The primary goal of the ISCO bench test was to evaluate the following
ISCO reagents to determine the most effective reagent for degrading the organic
contamination in the Site soil and groundwater: 1) Fentons Reagent (FR), 2) catalyzed
sodium persulfate, and 3) RegenOx.

ISCO Jar Test Results
Tables 3.1 and 3.2 shown below summarize the results of the ISCO jar test results for the two
soil samples tested.

The jar test results for Soil 1 show that the FR oxidant represented by the 15% and 25%
hydrogen peroxide columns performed the best in reducing the levels of benzene and total
VOCs. The removal efficiency for benzene was 98% with both 15 and 25% hydrogen
peroxide catalyzed with ferrous iron (FR). The removal efficiency for benzene ranged from
57 to 83% with activated persulfate, and ranged from 46 to 76% with Regen-Ox. The
removal efficiency for total VOCs ranged from 87 to 88% with FR, 41 to 66% with activated
persulfate, and 37 to 56% with Regen-Ox.

The jar test results for Soil 1 also show that FR performed the best in reducing the levels of
SVOCs including benzo(a)pyrene. The removal efficiency for benzo(a)pyrene was 53% and
44% with 15 and 25% FR, respectively. The removal efficiency for benzo(a)pyrene for
activated persulfate and Regen-Ox could not be calculated as the pre-treatment soil
concentration was less then the post-treatment concentrations for these oxidants. The
removal efficiency for SVOCs was 92 and 91% with 15 and 25% FR, respectively. The
removal efficiency for SVOCs ranged from 86 to 88% with activated persulfate, and ranged
from 88 to 90% with Regen-Ox.


20
The estimated soil oxidant demand (SOD) was 781 g/kg with 15% FR and 1,303 g/kg with
25% FR. The estimated SOD was 85.3 g/kg and 162.5 g/kg with 20 and 40 g/L activated
persulfate, respectively. The estimated SOD was 92.5 g/kg and 281 g/kg with 18 and 54 g/L
Regen-Ox, respectively. While FR had the highest SOD, it also had the highest removal
efficiency.

Table 3.1
ISCO Jar Test Results Soil 1
Chevron Soil ID S2249RG2

Constituent
Concentration in Soil (mg/kg)
Pre-
Treatment
Sample
Result
Oxidant Tested and Post-Treatment Sample Results
Fentons
Reagent
with
15%
Hydrogen
Peroxide
Fentons
Reagent
with
25%
Hydrogen
Peroxide
20 g/L
Activated
Persulfate
40 g/L
Activated
Persulfate
18 g/L
Regen-
OX
54 g/L
Regen-
OX
Benzene 231.5 4.8 5.75 100.55 39.45 123.95 55.30
Total VOCs 831.9 104.2 103.53 487.95 278.80 521.71 369.47
Benzo(a)pyrene 4.0 1.9 2.25 5.30 5.66 17.60 18.55
Total SVOCs 903.5 74.9 83.46 112.58 123.50 88.54 105.50

Constituent
Oxidant Tested and Removal Efficiency (% Concentration Reduction)
Fentons
Reagent
with
15%
Hydrogen
Peroxide
Fentons
Reagent
with
25%
Hydrogen
Peroxide
20 g/L
Activated
Persulfate
40 g/L
Activated
Persulfate
18 g/L
Regen-OX
54 g/L
Regen-OX
Benzene 98 98 57 83 46 76
Total VOCs 87 88 41 66 37 56
Benzo(a)pyrene 53 44 -32.5 -41.5 -340 -364
Total SVOCs 92 91 88 86 90 88
Notes:
1. Benzo(a)pyrene (BAP) concentrations increased in the post-treatment sample results for
the activated persulfate and Regen-Ox jar test results due to a breakdown of the soil
matrix allowing additional BAP to be extracted from the matrix in comparison with the
pre-treatment sample and/or the heterogeneic variability in the soil. Neither of these
oxidants were selected for use in the ISCO pilot test.


21
Table 3.2
ISCO Jar Test Results Soil 2
Chevron Soil ID S1016RC1

Target
Constituent
Concentration in Soil (mg/kg)
Pre-
Treatment
Sample
Result
Oxidant Tested and Post-Treatment Sample Results
Fentons
Reagent
with
15%
Hydrogen
Peroxide
Fentons
Reagent
with
25%
Hydrogen
Peroxide
20 g/L
Activated
Persulfate
40 g/L
Activated
Persulfate
18 g/L
Regen-OX
54 g/L
Regen-OX
Benzene 3.78 0.26 0.28 1.45 1.24 0.67 0.90
Total VOCs 143.40 33.55 39.25 140.75 74.54 100.18 117.46
Benzo(a)pyrene 1.20 U 0.20 0.13 13.45 13.45 0.46 0.41
Total SVOCs 41.00 16.07 8.61 22.27 22.28 23.79 24.13

Target
Constituent
Oxidant Tested and Removal Efficiency (% Concentration Reduction)
Fentons
Reagent
with
15%
Hydrogen
Peroxide
Fentons
Reagent
with
25%
Hydrogen
Peroxide
20 g/L
Activated
Persulfate
40 g/L
Activated
Persulfate
18 g/L
Regen-OX
54 g/L
Regen-OX
Benzene 93 93 62 67 82 76
Total VOCs 77 73 2 48 30 18
Benzo(a)pyrene NA NA NA NA NA NA
Total SVOCs 61 79 46 46 42 41
Notes:
1. NA = Not Applicable. The BAP pre-treatment sample result was undetected and, as a
result, associated % concentration reductions could not be calculated.
The jar test results for Soil 2 show that FR performed the best in reducing the levels of
benzene and total VOCs. The removal efficiency for benzene was 93% with both 15 and
25% FR. The removal efficiency for benzene ranged from 62 to 67% with activated
persulfate, and ranged from 76 to 82% with Regen-Ox. The removal efficiency for total
VOCs ranged from 77 to 73% with FR, 2 to 48% with activated persulfate, and 18 to 30%
with Regen-Ox.

The jar test results for Soil 2 also show that FR performed the best in reducing the levels of
SVOCs. The removal efficiency for SVOCs was 61 and 79% with 15 and 25% FR,
respectively. The removal efficiency for SVOCs was 46% with activated persulfate, and
ranged from 41 to 42% with Regen-Ox. Benzo(a)pyrene was not detected above the method
detection limit of 1,200 ug/kg in the pre-treatment soil sample. Consequently, the removal

22
efficiency of benzo(a)pyrene could not be calculated. However, post-treatment results show
that both FR and Regen-Ox were able to reduce the benzo(a)pyrene concentrations below
500 ug/kg.

The estimated SOD was 778 g/kg with 15% FR and 1,298 g/kg with 25% CFR. The
estimated SOD was 85.3 g/kg and 162.5 g/kg with 20 and 40 g/L activated persulfate,
respectively. The estimated SOD was 92.5 g/kg and 281 g/kg with 18 and 54 g/L Regen-Ox,
respectively. While FR had the highest SOD, it also had the highest removal efficiency.

In summary, the ISCO jar tests with both soil samples show that ISCO using FR is the most
effective oxidant for reducing the concentrations and mass of VOCs and SVOCs in the
shortest timeframe at the Site. The oxidant demand for FR is high due to its high reactivity
with other interfering oxidizable materials in the soil fill material.

ISCO Soil Column Test Results
The ISCO jar tests confirmed that FR was the best oxidant in terms of its removal efficiency.
Consequently, it was selected as the oxidant to use in the soil column test. Table 3.3 below
summarizes the soil column test aqueous effluent results.

Total VOCs in the column effluent at Day 7, Day 14 and Day 21 were measured at 178.4,
294.4 and 192.5 ug/L, respectively. The total VOCs is the sum of VOCs detected minus
acetone and 2-butanone. These compounds are degradation products of natural organic
matter such as peat. Benzene was detected at a concentration of 33 ug/L on Day 7, 43 ug/L
on Day 14, and 26 ug/L on Day 21. Total SVOCs were detected at 400.4, 1,366, and 553
ug/L on Day 7, Day 14, and Day 21, respectively.

The residual peroxide concentration in the effluent increased from 0.658 g/L on Day 7 to
1.31 g/L on Day 21, indicating that the demand for oxidant was diminishing over time as the
contaminants were being oxidized.

23
Table 3.3
ISCO Soil Column Test Aqueous Results Soil 2
Constituent
Concentration in Aqueous Column Effluent (ug/L)
Day 7 Day 14 Day 21
VOCs (ug/L)
Acetone 6,000 8,600 9,300
Benzene 33 J 43 26 J
2-Butanone 340 470 570
Ethylbenzene <3.3 22 16 J
Methylene chloride 12 J <4.4 12
Toluene <7.1 13 <7.1
1,2,4-Trimethylbenzene 26 J 40 30 J
1,3,5-Trimethylbenzene 10 J 15 10 J
m,p-Xylene 65 120 83
o-Xylene 22 J 37 27 J
SVOCs (ug/L)
Acenaphthene <6.6 74 J 33 J
Anthracene <7.5 100 J 41 J
Benzo(a)anthracene <7.4 32 J <25
Benzo(a)pyrene <7.8 30 J <26
Benzo(b)fluoranthene <12 29 J <40
Benzo(k)fluoranthene <8.8 17 J <29
Bis(2-ethylhexyl)phthalate <20 <36 51 J
Chrysene <8.8 94 J 47 J
Dibenzofuran <5.8 <10 28 J
2,4-Dimethylphenol 290 130 J <80
Fluoranthene <8.0 130 J 59 J
Fluorene <6.7 71 J 36 J
1-Methylnaphthalene <6.3 120 J 54 J
2-Methylnaphthalene <6.6 50 J <22
4-Methylphenol <8.8 19 J <29
Phenanthrene <8.0 370 150 J
Pyrene <7.1 100 J 54 J
Wet Chemistry Parameters
Dissolved oxygen, mg/L 6.77 8.20 12.7
pH 3.99 3.03 2.40
ORP, mV 483.8 585.9 632.4
Conductivity, mS/cm 2.84 4.48 6.11
Peroxide, g/L 0.658 1.01 1.31
Notes:
1. ORP = oxidation reduction potential
2. J = indicates that the detected concentration is below the practical quantitation limit
(PQL) of the analytical method

Following the completion of the ISCO soil column test on Day 22, a soil sample was
collected for analysis and comparison with the pre-treatment soil sampling results. The post
ISCO soil column test soil sampling results for VOCs are presented in Table 5.4 below.

24
Table 3.4
ISCO Soil Column Test Soil Results Soil 2
Constituent Concentration in Soil (mg/kg)
VOCs
Pre-Treatment Samples
Day 22
Post-Treatment
Sample from
Column S1016RC1
S1016RC1
(duplicate)
Acetone <14.90 <14.80 11.00
Benzene 4.77 2.78 3.00
n-Butylbenzene 5.84 0.91 0.68
sec-Butylbenzene 2.33 0.20 0.094
Ethylbenzene 3.46 1.65 2.50
Isopropylbenzene 6.01 1.11 0.67
4-Isopropyltoluene 3.14 0.20 0.066
Naphthalene 8.01 7.74 1.20
n-Propylbenzene 12.80 2.30 0.87
Toluene 1.58 <0.27 1.50
1,2,4-Trimethylbenzene 72.10 29.60 6.50
1,3,5-Trimethylbenzene 35.80 9.39 2.00
m,p-Xylene 46.80 22.10 11.00
o-Xylene 2.92 2.69 2.60
Total VOCs 205.56 80.67 32.68
Average VOCs 143.12 32.68
Average Benzene 3.78 3.00
%Reduction VOCs 77
% Reduction Benzene 21

The results of the ISCO soil column test indicate that there was a 77% reduction in total
VOCs and a 21% reduction in benzene concentrations. The reduction in benzene is low
compared to that observed in the jar test (93%) with FR for Soil 2.

The SVOC data for the ISCO soil column test were inconclusive in determining the mass
removal of SVOCs due to method detection limit problems, with the exception of 1-
methylnaphthalene and 2-methylnaphthalene. The concentrations of 1-methylnaphthalene
and 2-methylnaphthalene in the soil column were decreased by 57 % and 79 % respectively
when compared to the pre-treatment concentrations found in the soil.


25
4.0 OBJECTIVES AND SCOPE OF ISCO PILOT TEST

In order to further evaluate the effectiveness of ISCO in treating the organic contaminated
soil and groundwater at the Site, a pilot test was performed from September 17th through
October 2nd in SWMU 43 in the vicinity of soil sample location S2249, the area with the
best ISCO bench test results, as well as the only area in SWMU 43 with a benzene
concentration exceedence of both its NJDEP NRDCSCC, as well as its USEPA TCLP
Characteristic Hazardous Waste Regulatory Level.

The principal objective of the ISCO pilot test was to confirm the effectiveness of ISCO in
treating the organic contaminated soil and groundwater at the Site. The specific objectives of
the pilot test were as follows: 1) to confirm the effectiveness of ISCO in treating benzene in
soil at concentrations above 13 mg/Kg and in groundwater at concentrations above 100
mg/L, TCLP benzene at concentrations above 0.5 mg/L, and benzo(a)pyrene in soil at
concentrations above 10 mg/Kg, and 2) to obtain engineering data to support the design of a
full scale ISCO remediation system including the injection flow rates of the reagents, the
injection pressures, the radius of influence around the injection points, and the duration of
treatment.

The duration of the pilot test was two weeks (10 days). Based on the results of the bench
test, Fentons Reagent (FR) was the selected oxidant for the pilot test.

The scope of work for the ISCO pilot test consisted of the following activities: 1) pre-pilot
test sampling, 2) installation of injection points and a piezometer, 3) mobilization, 4)
injection of ISCO chemicals, 5) post-pilot test sampling, and 6) preparation of an ISCO Pilot
Test Report.


26
5.0 ISCO TREATMENT SYSTEM DESCRIPTION

5.1 Technology Overview

ISCO involves the injection of a chemical oxidant, such as ozone, hydrogen peroxide,
potassium or sodium permanganate, or sodium persulfate into the subsurface soil and/or
groundwater through injection wells or points to treat both organic contaminated soil and
groundwater. ISCO chemical reactions produce carbon dioxide, water and minerals
depending on the type of oxidant and associated chemicals used, as well as the type of
contaminants being degraded. Catalysts and acids are sometimes used to enhance the rate of
the ISCO reactions, as well as increase the oxidation reduction potential (ORP).

A general introductory discussion of the chemical oxidation process for the ISCO technology
evaluated during this pilot test is provided below.

5.1.1 FR ISCO Chemistry

FR is a method of generating hydroxyl radicals, which are more powerful oxidants than
ozone, hydrogen peroxide or any other commercially available oxidant. In traditional FR
applications, hydrogen peroxide catalytically reacts with iron to form hydroxyl radicals. The
generation of hydroxyl radicals is highly dependent on the pH of the system and the
availability of iron catalysts. Some literature suggests more optimal results with FR at low
pH (2 to 4 pH units) and relatively high dissolved iron concentrations (greater than 200
milligrams per liter [mg/L]). Since optimal conditions for traditional FR are not often
realized in the field, some practitioners and vendors claim that the addition of acidified iron
salts (typically sulfuric acid and iron sulfate) and chelating agents (typically proprietary
mixtures of ethylenediamine tetra-acetic acid [EDTA] and/or citrate) allow oxidants to be
delivered farther away from the injection point prior to breakdown. When these substances
are added, the solution is referred to as Modified FR.

The amount of FR required to oxidize organic contaminants will depend on the nature and
concentration of the contamination, as well as the amount of natural organic content and
other interferences within the contaminated soil and/or groundwater to be treated, scavaging
reactions, iron catalysts concentration and pH of the fluid within the treatment zone. The
amount of FR required will also depend on the ability of the delivery system to distribute the
oxidant throughout the contaminated media, because the FR oxidants tend to be short-lived in
the subsurface environment.


27
Balanced chemical equations for oxidation of representative gasoline range, diesel range, and
residual range aliphatic petroleum hydrocarbons are as follows:

C
12
H
26
+ 37 H
2
O
2
===> 12 CO
2
+ 50 H
2
O

C
24
H
50
+ 73 H
2
O
2
===> 24 CO
2
+ 98 H
2
O

C
36
H
74
+ 109 H
2
O
2
===> 36 CO
2
+ 146 H
2
O

Based on this stoichiometry, approximately 7.3 pounds of pure hydrogen peroxide would be
required to convert 1 pound of petroleum hydrocarbons to carbon dioxide and water. On a
molecular basis, however, it would require more moles of peroxide to destroy one mole of a
heavier-end hydrocarbon than a lighter end hydrocarbon. For example, from the above
stoichiometry, 109 moles of peroxide would be needed to destroy 1 mole of a 36-carbon
aliphatic hydrocarbon, whereas it would require 37 moles of peroxide for a 12 carbon
aliphatic hydrocarbon. This suggests that lighter-end hydrocarbons such as benzene may be
easier to treat than diesel range organics (DRO) or residual range petroleum hydrocarbons.
The actual amount of hydrogen peroxide required for a successful ISCO application has been
found to vary between 2 and 20 times that of the amount of the hydrogen peroxide necessary
stoichiometrically (Mahmoud, et al. 2003).

5.1.2 ISCO Pilot Test Equipment

The ISCO pilot test system consisted of several components, including the ISCO chemicals
mixing system and the injection system. A process flow diagram of the pilot test system is
shown on Figure 4.

Mixing System
The mixing system consisted of a 500 gallon pump-driven mixing tank. The ISCO solutions
including a ferrous sulfate solution and a hydrogen peroxide and phosphoric acid mixture
were recirculated through the bottom of the mixing tank creating a circulating motion, which
resulted in homogenization of the solutions.

Injection System
The injection system consisted of injection pumps, the injection manifold, a flowmeter, high
pressure chemical hoses, and packer type inserts for the injection points. The injection
pumps (in-use and back-up) were rated at 25 gallons per minute (gpm), and were air
operated, double diaphragm chemical pumps. An electromagnetic flowmeter was used to
measure and record the injected volumes. The pumps and injection manifold were connected

28
with 1 diameter high pressure chemical hoses. The injection manifold was fabricated of
diameter stainless steel and contains the following components: 1) a 0-50 psi pressure gauge,
2) a temperature sensor, 3) a check valve to prevent backflow in case of back pressure from
the injection points, and 4) a flow control valve. The chemical hoses were attached to the
injection points with packer type inserts and 1 steel nipples fitted with dry-break cam lock
quick-connect fittings. The mixing tank, injection pumps, and metering devices were staged
on 220 gallon capacity spill containment skids. The compressed air supply for the pumps
was provided by a diesel powered 160 cubic feet per minute (cfm) compressor.

Decontamination System
The decontamination system includes an emergency safety shower and eye wash, along with
a boot and hand wash, located near the injection pumps skid. Wash water was collected in
storage drums and properly treated and discharged to the on-Site effluent treatment plant..

Miscellaneous Components
Electric power for the ISCO chemical pumps and work lights was supplied by a gasoline-
powered 8,000 watt generator. A 5,000 lb capacity, off road, diesel powered fork lift was
used to off load the ISCO chemicals and move them to the chemical storage and mixing areas
on-site, as needed. On demand water for the mixing and decontamination systems was
supplied from a hydrant located close to the pilot test treatment area.


29
6.0 ISCO PILOT TEST PROCEDURES

6.1 ISCO Pilot Test Summary

The ISCO pilot test was conducted over a 10 day period from September 17
th
to October 2
nd
,
2008. Prior to the start of the test, a pre-treatment sampling event was conducted on June
19
th
and 23
rd
, 2008, in order to obtain baseline soil and groundwater samples. Three soil
borings were advanced by East Coast Drilling, Inc. (ECDI) using a truck mounted Geoprobe
rig under the supervision of a URS geologist. Two boring locations were completed as
injection point (IP) 1 (monitoring well (MW) 278) and piezometer (PZ) 0018. One soil
sample was collected from each of these borings. Additionally, groundwater samples were
collected from monitoring wells MW-0061 and MW-0062. The soil and groundwater sample
locations were selected based on their proximity to the ISCO bench test location, soil sample
S2249, the SWMU 43 location with the highest total and TCLP benzene concentrations in
the soil.

During the course of the ISCO pilot test, the following chemicals and corresponding
quantities were injected into the SWMU 43 area soil and groundwater: 1) 550 pounds of
ferrous sulfate heptahydrate as an aqueous solution, 2) 2,990 gallons of 25% hydrogen
peroxide solution, and 3) 1,280 gallons of 75% phosphoric acid solution. A number of soil
vapor and groundwater quality parameters were measured during the injection activities to
monitor the progress of the ISCO reactions and ensure safe conditions were being
maintained.

Following injection activities, two post-treatment sampling events were conducted to
demonstrate the effectiveness of the ISCO pilot test and determine its radius of influence in
the SWMU 43 area soil and groundwater. The first post-treatment sampling event was
conducted on October 15, 2008, approximately two weeks following the completion of
injection activities. Five soil borings were advanced by ECDI in a similar fashion as the pre-
treatment sampling event. One soil sample was collected from each of these borings.
Additionally, groundwater sample were collected from monitoring wells MW-0061 through
MW-0063.

The second post-treatment sampling event was conducted on March 18-19, 24-25, and April
1, 2009, approximately five months following the first post-treatment sampling event. Ten
soil borings were advanced by ECDI in a similar manner as the pre-treatment sampling
event. One soil sample was collected from each of these borings. Additionally, groundwater
samples were collected from monitoring wells MW-0060 though MW-0062, and MW-0065.


30
All of the pre- and post-treatment ISCO pilot test soil and groundwater sampling locations
are shown in Figure 5, SWMU 43 ISCO Pilot Test Location Map, in Appendix B. Further,
pictures of the SWMU 43 ISCO pilot test area, as well as injection activities, are included in
Appendix B.

A more detailed description of the ISCO pilot test procedures is provided below.

6.2 Pre-Treatment Soil and Groundwater Sampling Event

The pre-treatment soil and groundwater sampling event consisted of sampling and analysis of
the soil and groundwater in the SWMU 43 ISCO pilot test area to establish baseline
conditions. The pre-treatment sample locations included the new ISCO pilot test locations
S2581, S2582, and S2583. Locations S2582 and S2583 were completed as IP-1 (MW-278)
and PZ-0018, respectively. The soil boring and well logs for the ISCO pilot test pre-
treatment soil sample locations are included in Appendix A1.

In addition to the data collected from the ISCO pilot test sample locations, CMS data
collected from sample locations within the SWMU 43 ISCO pilot test area was included in
the baseline soil characterization (pre-treatment data) for comparison with the post-treatment
sampling results.

Soil Sampling
During the CMS and ISCO pilot test sampling events, soil samples were collected with
directpush drilling methods using track-mounted or truck-mounted Geoprobe equipment.
Soil samples were collected using a Geoprobe Macro-Core Soil Sampler. The Macro-
Core Soil Samplers used were approximately 2 in diameter and 48 long. The Macro-
Core samplers were lined with a dedicated pre-cleaned clear acetate liner, which enables
removal of the undisturbed soil from the sampler, and helps to insure sample integrity.
Continuous soil sampling was conducted from the ground surface to depths up to 13 bgs.
The borings were terminated when either the screening tool (photoionization detector (PID)
for VOCs) showed low or non-detect readings indicating that VOC contamination in the
boring had been vertically delineated, or the organic clay/peat layer was encountered.

Upon retrieval of the soil cores from various depth intervals, the following procedure was
used to collect the soil samples:

1. The Macro-Core Sampler and liner were removed from the rod string and placed on
plastic sheeting.

31

2. The liner was removed from the sampler and sliced opened. The length of the soil
core was screened with a PID and observed for staining/odors. PID readings were
taken at 6-inch intervals by breaking the soil core with a spatula. Observations (soil
type, color, odor, staining, moisture etc.), screening values (PID), and soil properties
using the Unified Soil Classification System (USCS) were recorded on a boring log.
The acetate liner and the soil core were kept in a cool and shady place until the
laboratory sample was collected for that location.

3. Based on the screening information, samples were collected for the required
parameters. For example, an analytical sample was collected for VOCs, SVOCs and
TCLP benzene from the 6-inch interval exhibiting the highest PID reading.

4. A soil sample was first collected for VOCs, followed by TCLP benzene and SVOCs
from that interval. If the soil sample volume was insufficient to allow for the required
analyses, the sample for the remaining analyses was collected from the next highest
reading screened interval provided that the next highest reading screened interval was
in the same order of magnitude range as the highest reading. If not, then the sample
was collected from a new boring placed adjacent to the previous boring, and from the
same depth interval.

5. If all of the PID readings were non-detect, then the sample was collected from the 6-
inch interval immediately above the soil/groundwater interface.

6. Soil samples for VOCs analysis were collected in 40 mL laboratory-supplied glass
vials containing 25 mL of methanol and NJDEP surrogates. Soil samples collected
for TCLP-benzene and SVOC analyses were collected in 16 oz sample jars.

7. Samples marked for VOCs analysis were analyzed by USEPA Method 8260B.
Samples marked for SVOCs (base neutrals only) analysis were analyzed by USEPA
Method 8270C. Samples marked for TCLP benzene analysis were leached by
USEPA Method 1311, followed by analysis for benzene using USEPA Method
8260B.

The remaining soil cuttings were placed into a 55 gallon drum(s) and properly disposed off-
site. Soil sample jars were placed in coolers preserved with ice to a temperature of 4C and
shipped under proper chain-of-custody documentation to Lancaster Laboratories for analysis.


32

Groundwater Sampling
The pre-treatment groundwater samples were collected at wells MW-0061 and MW-0062
using the sampling method described below:

1. A peristaltic pump with disposable tubing was used to purge approximately three
volumes of groundwater in each well.

2. After purging, a dedicated pre-cleaned, 1.5 diameter, 4 long, bottom fill, Teflon or
PVC bailer was lowered to the appropriate sampling interval to collect a groundwater
sample for analysis.

3. The bailer was retrieved and the sample placed into three 40 mL laboratory-supplied,
HCL preserved, glass vials for VOCs analysis, and in one 500 mL amber glass bottle
for SVOCs analysis.

Groundwater sample bottles were placed in coolers preserved with ice to a temperature of
4C and shipped under proper chain-of-custody documentation to Lancaster Laboratories for
analysis.

The groundwater sampling logs for each pre- and post-treatment sampling event are given in
Appendix A5.

6.3 Injection Points and Piezometer Installation

A total of four injection points (IPs) and one piezometer were installed for the ISCO pilot
test. IP-1/MW-278 was installed on June 19, 2008; and consisted of a 4" diameter stainless
steel casing with a 5' long stainless steel screen (0.010" slot size) installed from 5' - 10' bgs,
capped on the bottom with a stainless steel cap, and finished on the top with a 3' stick up
containing a NPT threaded male end. A locking steel outer casing was placed around the
stick up such that the top of the outer casing was approximately 3" above the top of the well
casing.

PZ-0018 was installed on June 19, 2008; and consisted of a 1" diameter polyvinyl chloride
(PVC) casing with a 7' PVC screen (0.010" slot size) installed from 3' - 10' bgs, capped on
the bottom with a PVC cap, and finished on the top with a 3stick up. A locking inner steel
cap was placed on top of each stick up.


33
IPs 2 through 4 were installed on September 18, 2008; and consisted of a 1" diameter
stainless steel casing with a 3' long stainless steel screen (0.010" slot size) installed from 6' -
9' bgs, capped on the bottom with a stainless steel cap, and finished on the top with a stick
up. A locking inner steel cap was placed on top of each stick up.

The packing for MW-278/IP-1 and PZ-0018 consisted of #00 Morie sand, which was placed
to 6" above the top of the screens. The remaining annulus was sealed with a 95% Portland
cement/5% bentonite grout to the surface. No packing was used for IP-2 through IP-4. The
annuluses above the screens were grouted with Portland cement Type 1 to the surface. The
IPs and PZ-0018 construction logs, and certification forms As and Bs for permanent
installations IP-1 and PZ-0018 are included in Appendix A2.

6.4 Mobilization

The personnel and necessary equipment and materials for the ISCO pilot test were mobilized
to the concrete pad area of SWMU 43 at the Site, proximate to the ISCO pilot test area. The
ISCO pilot test equipment was transported by a mobile remediation trailer. The ISCO
chemicals were transported by truck, and were off-loaded using a fork lift. The hydrogen
peroxide and phosphoric acid solutions were transported in 55-gallon Department of
Transportation (DOT) approved drums, while the ferrous sulfate heptahydrate was
transported in 50-pound bags.

6.5 Site Preparation and Staging

The subsequent tasks were followed during the Site preparation and staging of the test
equipment:

1. Installation of an 8,000 watt generator and electrical connections;
2. Installation of potable water supply lines and a decontamination station; and
3. Preparation of a chemical storage area. The hydrogen peroxide and phosphoric acid
55-gallon DOT approved drums, and ferrous sulfate 50-pound bags were staged on
separate loading skids to avoid accidental chemical mixing. Additionally, each
reagent was placarded with hazardous material labels.


34
6.6 Chemical Preparation

30% Hydrogen peroxide solution, 75% phosphoric acid solution, and ferrous sulfate
heptahydrate (in granular form) were supplied by Veckridge Chemical Company, located in
Kearny, New Jersey. During the ISCO pilot test, Veckridge made chemical deliveries to the
Site to replenish the ISCO chemicals to be injected. Drums of hydrogen peroxide and
phosphoric acid were off-loaded by forklift and placed on skids in the chemical storage area,
and the empty drums were picked up and recycled.

The ISCO chemical reagents were diluted and mixed in the 500 gallon mixing tank in a two
step process as follows:

1. A catalyst solution was prepared mixing potable water and ferrous sulfate
heptahydrate. Sixty-three pounds of ferrous sulfate heptahydrate was added slowly
into the mixing tank with 300-gallons of water to prepare a 2.5% solution. The
mixture was allowed to mix for at least a half hour prior to starting the injections.

2. At least 16 hours following the injection of all of the 2.5% ferrous sulfate solution,
the peroxide/acid solution was prepared in the mix tank by transferring and diluting
hydrogen peroxide to a concentration of 25% using potable water. Phosphoric acid
was then added to the 25% hydrogen peroxide solution in 30:70 proportions of acid to
peroxide and mixed slowly.

6.7 Chemical Injection

ISCO solution injections were accomplished utilizing the 25 gpm, air operated, double
diaphragm chemical pump connected to the chemical mixing tank on the suction side and to
three of the injection points on the discharge side. The rate of injection was gradually
increased to approximately 7 gpm and the pumping pressure was generally kept below 20
pounds per square inch (psi). The injection pressure and temperature were monitored
continuously during injection activities. If the injection pressure exceeded 40 psi or the
temperature exceeded 160F, the injection would be stopped until the system became
stabilized. This did not occur during the course of the ISCO pilot test. The process data logs
summarizing the ISCO injection process data are provided in Appendix A3.

Following completion of the ISCO pilot test, IPs 2 through 4 were decommissioned and
sealed with a Portland cement/bentonite grout to the surface.


35

6.8 Field Screening

Field screening of groundwater and vapor parameters was performed at PZ-0018 and
monitoring wells MW-0061 through MW-0063 during the ISCO injection activities. The
field screening parameters measured are described below:

1. Oil/water interface parameters - including groundwater and free product LNAPL
levels, and height of water column.
2. Water quality parameters - including pH, temperature, conductivity, DO, and ORP.
3. Vapor phase parameters - including % carbon dioxide, % oxygen, % lower explosive
limit (LEL), and total VOCs.
The results of the field screening for the abovementioned parameters are summarized in the
field screening data logs shown in Appendix A4.

6.9 Post-Treatment Soil and Groundwater Sampling Events

The post-treatment soil and groundwater sampling was performed in two events. The post-
treatment soil samples were collected following the procedures described in Section 6.2. The
first post-treatment sampling event included the collection of soil samples at existing CMS
PDI locations S2087 and S2250, and ISCO pilot test locations S2581, S2582, and S2583.
The second post-treatment sampling event included the collection of soil samples at existing
CMS PDI locations S2087, S2221, S2235, S2249, S2250, S2254, and S2466, and ISCO pilot
test locations S2581 and S2583. For direct comparison to the pre-treatment sampling results,
all post-treatment soil samples were collected at the same depth as their corresponding pre-
treatment soil samples.

Post-treatment groundwater samples were collected in monitoring wells and piezometers
located in the ISCO pilot test area. The first and second post-treatment sampling event
groundwater samples were collected in wells MW-0061 through MW-0063, and wells MW-
0060 through MW-0062, and MW-0065, respectively. The groundwater post-treatment
results were compared to the most recent groundwater results obtained in each well prior to
the injection of ISCO chemicals.

The post-treatment groundwater samples were collected at wells MW-0061, MW-0062, and
MW-0063 using the same sampling method described in Section 6.2 for the pre-treatment

36
groundwater sampling event. In addition, the water quality parameters including turbidity,
temperature, specific conductance, pH, ORP, and DO were monitored during purging
activities at wells MW-0061 and MW-0062.

The groundwater samples were collected at wells MW-0060 and MW-0065 using low flow
purging and sampling methods as follows:

1. A Grundfos Rediflow pump with disposable tubing was used. The sampling pump
intake velocity was set to a flow rate that limited drawdown inside the well.

2. During well purging, water quality parameters including turbidity, temperature,
specific conductance, pH, ORP, and DO were monitored every five minutes until
their readings stabilized. Stabilization was considered to be achieved when three
consecutive readings, taken at three to five minute intervals, were within the
following limits:

turbidity (10% for values greater than 1 NTU),
DO (10%),
specific conductance (3%),
temperature (3%),
pH ( 0.1 unit),
ORP ( 10 millivolts).

3. The samples were collected in three HCL preserved, 40 mL glass vials for VOC
analysis, and in one 500 mL amber glass bottle for SVOCs analysis.

Samples marked for VOCs analysis were analyzed by USEPA Method 8260B. Samples
marked for SVOCs (base neutrals only) analysis were analyzed by USEPA Method 8270C.

Groundwater sample bottles were placed in coolers preserved with ice to a temperature of
4C and shipped under proper chain-of-custody documentation to Lancaster Laboratories for
analysis.

The groundwater sampling logs summarizing the water quality parameter results collected
during the groundwater sampling activities are included in Appendix A5.


37
7.0 RESULTS AND DISCUSSION

7.1 ISCO System Operations

The ISCO Pilot Test injections were conducted for ten days beginning on September 17,
2008 and ending on October 2, 2008. During the course of the ISCO Pilot test, the following
chemicals and corresponding quantities were injected into the SWMU 43 area soil and
groundwater: 1) 550 pounds of ferrous sulfate heptahydrate in an aqueous solution, 2) 2,990
gallons of 25% hydrogen peroxide solution, and 3) 1,280 gallons of 75% phosphoric acid
solution. The amounts of each of these chemicals injected into each IP on a daily basis are
summarized in the process data logs included in Appendix A3.

As shown in these logs, the chemical injection flow rates ranged from 1 to 15 gpm.
Additionally, injection pressures ranged from 2 to 30 psig. The total volume of chemical
solutions injected daily ranged from 140 to 1,200 gallons, with an average of 672 gallons.

7.2 Problems Encountered and Resolved

Only the following minor problems were encountered during the ISCO pilot test:

1. Short-circuiting of ferrous sulfate solution was observed approximately 8' from IP-1
after injection of 100 gallons on the first day of injection. Injection activities were
subsequently stopped. After further observation, it was determined that the short-
circuiting was caused by a test pit located near IP-1, which was excavated and back
filled approximately one year prior to commencement of injection activities. The
following day, three additional injection points were installed 15 to 25 towards the
south of IP-1. Injection activities resumed the next day, September 19, 2008, in new
injection points IP-2 through IP-4. Injection activities were reinitiated in IP-1 on the
sixth day of injection, September 25, 2008.
2. Minor short-circuiting of ferrous sulfate solution was observed during the fourth and
fifth days of injection activities in piezometer PZ-0018. Injection activities were
briefly stopped to allow the water levels in PZ-0018 to recede, prior to recommencing
them.
In summary, the problems experienced during the ISCO pilot test were relatively minor in
nature, and all were corrected within a day or less time. There were no problems
encountered related to the ISCO equipment including its O&M.

38
7.3 Field Screening Parameters Results

Field screening of groundwater and vapor parameters was performed at wells MW-0061
through MW-0063 and piezometer PZ-0018 during the ISCO injection activities. Various
oil/water interface, water quality and vapor phase parameters were recorded and are shown in
the field screening data logs provided in Appendix A4. These logs indicate that the ISCO
chemicals were injected in an average of three batches per day, during which parameter
readings were recorded at the beginning, middle, and end of each batch.

Oil/Water Interface Parameters
The oil/water interface parameters recorded during the ISCO pilot test included the
groundwater and free product LNAPL levels, and the height of the water column in each
well/piezometer. These parameters were measured using an oil/water interface probe. As
shown in the field screening data logs, free product LNAPL was found in the following
wells/piezometer during the ISCO injection activities: 1) up to 0.58 in piezometer PZ-0018,
2) up to 1.06 in well MW-0062, and 3) up to 0.64 in well MW-0063. Free product LNAPL
was not found in well MW-0061.

As shown in the logs, the height of the water column increased in all of the wells and
piezometer monitored during injection of the ferrous sulfate solution. An increase of up to 3
was observed. In the other hand, a decrease in the height of the water column was observed
in all of the wells and piezometer monitored during injection of the peroxide/acid solution.
An increase of up to 12.5 was recorded during injection activities.
Water Quality Parameters
The water quality parameters recorded during the ISCO pilot test included the pH,
temperature, conductivity, DO, and ORP. These parameters were measured using a water
quality analyzer. As shown in the field screening data logs, the level of these parameters
remained fairly steady during injection of the ferrous sulfate solution, with the exception of
the conductivity, which increased by more than approximately 200% in each of the wells
and piezometer monitored. However, during the injection of the peroxide/acid solution,
most of these parameters changed substantially in each of the wells and piezometer
monitored as a result of the ISCO reactions. To better illustrate these changes and their
relationship to time of injection for each monitoring point and distance from the injection
points, charts were prepared for those parameters exhibiting substantial changes, which are
included in Appendix A4.

A review of the pH versus distance charts during peroxide/acid solution injection activities
shows pH decreases of up to 2 to 3 pH units at distances of up to 38 from the respective
injection point, with the highest pH decreases occurring closest to the injection points. A

39
review of the pH versus time charts during these activities indicates pH decreases of up to 2.5
to 3 pH units over a six hour period of injection, with the highest pH decreases occurring at
the beginning of injection activities for the day.

A review of the DO versus distance charts during peroxide/acid solution activities shows DO
increases of up to 4 mg/L at distances of up to 52 from the respective injection point, with
no correlation between DO changes and distance from the injection points. A review of the
DO versus time charts during these activities indicates DO increases of up to 4 mg/L over a
6.5 hour period of injection, with the highest DO increases occurring at the end of injection
activities for the day.

A review of the ORP versus distance charts during peroxide/acid solution injection activities
shows ORP increases of up to 7 millivolts (mV) at distances of up to 38 from the respective
injection point, with the highest ORP increases occurring closest to the injection points. A
review of the ORP versus time charts during peroxide/acid solution injection activities shows
ORP increases of up to 150 mV over a 6 hour period of injection, with no correlation
between ORP changes and time of injection for each injection point.

No correlation was observed in the field screening data logs regarding distance from
injection point and the time of injection for the water quality parameters temperature and
conductivity during peroxide/acid solution injection activities. As a result, no charts were
prepared for these parameters.

Vapor Phase Parameters
The vapor phase parameters recorded during the ISCO pilot test included the % carbon
dioxide, % oxygen, % LEL, and total VOCs. The % carbon dioxide was measured using a
landfill gas meter, while the remaining parameters were measured using a PID multi-RAE
meter. These measurements were obtained at depths of 0 to 3 below the top of the casing
of each of the monitoring points as shown in the field screening data logs.

As shown in the field screening data logs, the levels of these parameters remained fairly
steady during injection of the ferrous sulfate solution. However, during the injection of the
peroxide/acid solution, the total VOCs and % carbon dioxide changed substantially in each of
the wells and piezometer monitored as a result of the ISCO reactions. To better illustrate
these changes and their relationship to time of injection to each monitoring point and distance
from the injection points, charts were prepared for total VOCs and % carbon dioxide, which
are included in Appendix A4.


40
A review of the total VOCs versus distance during peroxide/acid solution injection activities
show total VOCs increases of up to 400 ppm at distances up to 34.5 from the respective
injection point, with the highest increases occurring closest to the injection points. A review
of the total VOCs versus time charts during these activities indicates total VOCs increases of
up to 400 ppm over a 7 hour period of injection, with the highest total VOCs increases
occurring at the beginning of the injection activities for the day.

A review of the % carbon dioxide concentration versus distance during peroxide/acid
solution injection activities show % carbon dioxide increases of up to 249,600 ppm from a
background concentration of approximately 400 ppm at distances up to 30 from the
respective injection point, with the highest increases occurring closest to the injection points.
A review of the % carbon dioxide concentration versus time charts during these activities
indicates % carbon dioxide concentration increases of up to 249,600 ppm over a 6 hour
period of injection, with no correlation between carbon dioxide concentration changes and
time of injection for each monitoring point.

No correlation was observed in the field screening data logs regarding distances from
injection point and time of injection for the vapor phase parameters % oxygen and LEL
during peroxide/acid solution injection activities. As a result, no charts were prepared for
these parameters.

Summary of Field Screening Parameter Results
Table 7.1 summarizes the maximum change in these parameters during the course of the
ISCO chemicals injection activity.

Table 7.1
Summary of Changes in Field Screening Parameters

MPs Distance
from IPs
(feet)
Height of
Water
Column
(feet)
pH DO
(mg/L)
ORP
(mV)
CO
2

(ppm)
Total
VOCs
(ppm)
PZ-0018 25.8 4 feet
(13 to 9)
3 pH units
(3.5 to 6.5)
3 mg/L
(0.5 to 3.5)
275 mV
(-125 to 150)
250K ppm
(400- 250K)
425 ppm
(0 to 425)
MW-0062 30.5 9.5 feet
(11.5 to 2)
2 pH units
(4.75 to 6.75)
4 mg/L
(1 to 5)
225 mV
(-150 to 75)
52K ppm
(400 to 52K)
23 ppm
(0 to 23)
MW-0063 52.2 12.5 feet
(12.5 to 0)
2 pH units
(5 to 7)
3.75 mg/L
(0.75 to 4.5)
220 mV
(-140 to 80)
42K ppm
(400 to 42K)
140 ppm
(0 to 140)


41
In summary, the water quality parameter field screening results demonstrate multiple lines of
evidence of ISCO reactions occurring in the subsurface groundwater within the ISCO pilot
test area.

The height of the water column decreased in all of the wells and piezometer monitored
during injection of the peroxide/acid solution. While an increase in the height of the water
column could generally be expected as a result of injection activities creating a mounding
effect, the decrease in water column height during the injection of the peroxide/acid solution
can probably be attributed to the force of the ISCO reactions pushing groundwater radially
away from the injection points, thereby creating a temporary groundwater depression in the
areas in which the ISCO reactions were taking place.

Significant increases in pH, DO, and ORP at distances of up to 52 from the respective
injection points are also indicative of oxidation in the ISCO pilot test area. The pH increased
up to 3 units during the course of the peroxide/acid solution injection activities. In agreement
with the FR ISCO reaction chemistry (see Section 5.1.1), these increases in pH are attributed
to the generation of hydroxyl radicals, the intermediate product of the FR ISCO process.
During injection activities DO increased of up to 4 mg/L. The increase in DO concentrations
are attributed to ?? The ORP conditions of the ISCO pilot test area changed from reductive
(as indicated by negative values) to oxidative (as indicated by positive values) during the
course of the peroxide/acid solution injection activities.

Finally, the vapor phase field screening results demonstrate additional lines of evidence of
ISCO reactions occurring in the subsurface soil and groundwater within the ISCO pilot test
area including significant increases in the carbon dioxide and VOC concentrations. The
concentrations of carbon dioxide, which is a final product of the ISCO reactions, showed an
increase of up to 62,400% during the course of the peroxide/acid solution injection activities.
The increase in VOC concentrations can be attributed to their volatilization resulting from
the increase of the subsurface groundwater temperature within the ISCO pilot test area
typical of the ISCO exothermic reactions.

In addition to the field screening parameters, visual evidence of ISCO reactions occurrence
was observed east and south of the injection area. Pictures 23 through 29, included in
Appendix C, show the ISCO chemicals coming out of the ground surface. Evidence of ISCO
reactions occurrence was not visualized in the north and west areas of the injection area
because they are covered by the SWMU 43 concrete pad. However, the analytical results
discussed below, demonstrated stoichiometric evidence of the ISCO reactions in the concrete
pad covered areas as well.


42

7.4 Soil Sampling Results

Pre-Treatment Sampling Results
Pre-treatment soil sampling results from samples collected in June 2008 at ISCO pilot test
soil borings S25581, S2582, and S2583 are summarized in Table 7.2. Additionally, pre-
treatment soil sampling results from samples collected during the CMS PDI from soil borings
S2087, S2221, S2235, S2249, S2250, S2254, and S2466 are also summarized in Table 7.2.

The soil sampling pre-treatment results indicate that the ISCO pilot test area soil is primarily
impacted by BTEX and SVOCs. The highest benzene concentration found was 39
milligrams per kilogram (mg/kg) in soil boring S2581, at a depth of 8.0 to 8.5 feet bgs. The
highest ethylbenzene and total xylenes concentrations were 150 and 780 mg/kg, respectively
in soil boring S2249(DUP), at a depth of 8.5 to 9.0 feet bgs. The highest toluene
concentration found was 70 mg/kg in soil boring S2254, at a depth of 8.5 to 9.0 feet bgs.
Benzene was the only VOC found at a concentration exceeding its criteria. Benzene
exceedences were found in four sample locations (S2581, S2087, S2249(DUP), and S2254).

Additionally, four SVOCs including benzo(a)anthracene, benzo(a)pyrene,
dibenz(a,h)anthracene, and naphthalene were found at concentrations exceeding their
respective criteria/standard in up to eight sample locations (S2581, S2583, S2087, S2235,
S2249, S2250, S2254, and S2466). The highest benzo(a)anthracene, benzo(a)pyrene and
naphthalene concentrations were 16, 16 and 170 mg/kg in soil boring S2249(DUP), at a
depth of 8.5 to 9.0 feet bgs. The highest dibenz(a,h)anthracene was 1.2 mg/kg, below its
PQL level, in soil boring S2581, at a depth of 8.0 to 8.5 feet bgs.

Finally, TCLP benzene concentrations were detected in seven pre-treatment samples, two of
which (sample locations S2249(DUP) and S2087) had concentrations exceeding the TCLP
benzene standard of 0.5 milligrams per liter (mg/L). The highest TCLP benzene
concentration was 0.88 mg/L in soil boring S2249 location, at a depth of 8.5 to 9.0 feet bgs.
The shaded results in Table 7.2 indicate the concentrations above the compounds NJDEP
NRDSCC, NJDEP NRDSCS, or USEPA TCLP benzene regulatory level of 0.5 mg/L.

The VOC results for one sample location (S2582) were below the respective method
detection limit (MDL) for each of these constituents, while the SVOC results for two sample
locations (S2582 and S2221) were below the respective practical quantitation limit (PQL) for
each of these constituents, and for one sample location (S2466) were below the respective
MDL for each of these constituents. The TCLP benzene results were below its PQL for three
sample locations (S2581, S2221, and S2235) and below its MDL for three sample locations
(S2582, S2583, and S2466).

43

Post-Treatment Sampling Results
Post-treatment soil sampling results from samples collected during the two post-treatment
sampling events in October 2008 and March 2009 are also summarized in Table 7.2. During
the first post-treatment sampling event in October 2008, soil samples were collected at ISCO
pilot test locations S2581, S2582, and S2583, as well as CMS PDI locations S2087 and
S2250 to demonstrate the effectiveness of the ISCO pilot test and determine its radius of
influence in the SWMU 43 ISCO pilot test area. During the second post-treatment sampling
event in March 2009, soil samples were also collected in ISCO pilot test locations S2581 and
S2583, as well as CMS PDI locations S2087, S2221, S2235, S2249, S2250, S2254, and
S2466 to further determine the radius of influence of the ISCO pilot test, which was not fully
delineated after the first post-treatment sampling event. In general, VOCs, SVOCs, and
TCLP benzene results for the ISCO pilot test location S2582 were not detected; therefore, a
sample was not collected at S2582 during the second post-treatment sampling event.

In general, soil sampling post-treatment results show significant reductions in BTEX and
SVOCs concentrations. Benzene was the only VOC found at a concentration exceeding its
criteria in only two sample locations (S2235 and S2249) in the second post-treatment
sampling event results. The highest concentration of benzene was 30 mg/kg at sample
location S2249, at a depth of 8.5 to 9.0 feet bgs. Benzene concentrations were reduced in 7
of 10 soil samples analyzed by 70.9 to 99.9% with an average of 92.2%. Additionally,
benzene concentrations increased slightly in the two sample locations (S2235 and S2249)
with benzene exceedences. Further, the benzene concentration was not detected in the pre-
and post-treatment results for sample location S2582. As a result, a benzene concentration
reduction was not applicable to these three locations. Finally, the VOC results were not
applicable for two sample locations (S2582 and S2221), which were below the respective
MDLs for each of these constituents.

Additionally, four SVOCs including benzo(a)anthracene, benzo(a)pyrene,
benzo(b)fluoranthene, and naphthalene were found at concentrations exceeding their
respective criteria/standard in up to four sample locations (S2583, S2235, S2249, and S2250)
in the second post-treatment sampling event results. The highest benzo(a)anthracene,
benzo(a)pyrene, benzo(b)fluoranthene, and naphthalene concentrations were 8.7 J, 6.6 J, 4.5
J, and 180 mg/kg, respectively, in soil boring S2249, at a depth of 8.5 to 9.0 feet bgs. All but
naphthalene were present in concentrations below their respective PQLs.
Benzo(a)anthracene concentrations were reduced in 8 of the 10 soil samples analyzed by 17.4
to 97.2%, with an average of 66.2%. Benzo(a)anthracene concentrations were not detected
in the pre- and post-treatment results for sample locations S2221 and S2466. As a result, a
concentration reduction was not applicable to these locations. Benzo(a)pyrene

44
concentrations were reduced in 7 of the 10 soil samples analyzed by 50 to 97.7%, with an
average of 71.3%. The benzo(a)pyrene concentration increased slightly in one sample
location (S2582). Further, benzo(a)pyrene was not detected in the pre- and post-treatment
results for sample locations S2221 and S2466. As a result, a concentration reduction was not
applicable to these three locations. Benzo(b)fluoranthene concentrations were reduced in
two of the three soil samples analyzed by 57.6% to 92%, with an average of 74.8%.
Benzo(b)fluoranthene was not detected in the pre-treatment result for sample location S2582.
As a result, a concentration reduction was not applicable to this location. Naphthalene
concentrations were reduced in 9 of 10 soil samples analyzed by 28.8% to 99.3%, with an
average of 71.3%. Additionally, the naphthalene concentration increased slightly in one
sample location (S2249) with a naphthalene exceedence. As a result, a concentration
reduction was not applicable to this locations. Finally, dibenz(a,h)anthracene concentrations,
which had one exceedence in the pre-treatment result for sample location S2581, were
reduced in two of the three soil samples analyzed by 62.7% to 81.3%, with an average of
72%. Dibenz(a,h)anthracene was not detected in the pre- and post-treatment results for
sample location S2582. As a result, a concentration reduction was not applicable to this
location.

TCLP benzene concentrations were found at levels above its PQL in two post-treatment
samples collected in soil borings S2235 and S2249 at concentrations of 0.38 and 0.39 mg/L,
respectively, in the second post-treatment sampling event results. Therefore, none of the
post-treatment sample results exceeded the TCLP benzene regulatory level of 0.5 mg/L.
Additionally, TCLP benzene concentrations were not detected in five sample locations
(S2582, S2583, S2087, S2221, and S2254). TCLP benzene concentrations were reduced in
seven of the 10 soil samples analyzed by 38.6% to 99.1 % with an average of 69%.
Additionally, the TCLP benzene concentration increased slightly in one sample location
(S2235) and was not detected in the pre-treatment results for sample locations S2582 and
S2583. As a result, a concentration reduction was not applicable to these three locations.

Table 7.2 also shows the percentage concentration reduction of individual VOCs, SVOCs,
and TCLP benzene for detected pre-treatment concentrations for each sample location
following both post-treatment sampling events. Additionally, Table 7.2 gives the percentage
concentration reduction for total VOCs and total SVOCs analyzed in both the pre- and post-
treatment samples for each soil sample location.

Total VOCs concentrations were reduced in 7 of the 10 samples analyzed by 85.6 to 99.6%,
with an average of 94.4%. Additionally, VOC constituents were not detected in the pre-
treatment results for sample location S2582 and increased their concentration in sample

45
locations S2235 and S2249 where only BTEX constituents were analyzed. As a result, a
concentration reduction was not applicable to these locations.

49
Total SVOCs concentrations were reduced in 9 of the 10 soil samples analyzed by 5.1 to
98%, with an average of 62.8%. Additionally, SVOC constituents were, in general, not
detected in the pre- and post-treatment results in sample location S2221, and had higher
MDLs in the post-treatment results. As a result, a concentration reduction was not applicable
to this location.

ISCO Pilot Test Pre- and Post-Treatment Soil Modeling Results
Figure 6, ISCO Pilot Test Pre- and Post-Treatment Results, summarizes the pre- and post-
treatment soil and groundwater sampling results, and the percentage concentration reductions
for each sample location. Additionally, Figure 6 shows the pre- and post-treatment modeling
results using RockWorks software for PCOCs benzene and benzo(a)pyrene concentrations in
soil and groundwater. The post-treatment modeling results are based on the results from the
most recent second post-treatment sampling event. Consistent with the ISCO pilot test soil
sampling results presented in Table 7.2, significant reductions of the benzene and
benzo(a)pyrene soil exceedence areas within the ISCO pilot test area are displayed in the
figure.

Table 7.3 presents the pre- and post-treatment volumes of benzene and benzo(a)pyrene
contaminated soil, and their percentage volume reductions based on the soil modeling results
depicted in Figure 6.

Table 7.3
Volume Reduction for Soil Modeling Results

Contaminants
Pre-Treatment Post-Treatment
Percentage
Volume
Reduction
Area
(SY)
Volume
(CY)
Area
(SY)
Volume
(CY)
Benzene
> 13 mg/kg 254 356 135 189 46.9
TCLP Benzene
> 0.5 mg/L 26 20 0 0 100
Benzo(a)pyrene
> 10 mg/kg 78 117 0 0 100

Notes:
1. The average thicknesses used to calculate the volumes of contaminated soil were estimated
based on the benzene and benzo(a)pyrene cross sections shown on the figures in the CMS
PDI Results Report.
2. The benzene and benzo(a)pyrene concentrations were contoured from their applicable
regulatory standard or criteria as follows: 1) benzene in soil was contoured from 13
mg/Kg, its NJDEP NRDSCC; 2) TCLP benzene was contoured from 0.5 mg/L, its RCRA

50
Characteristic Hazardous Waste Regulatory Level; and 3) benzo(a)pyrene in soil was
contoured from 10mg/Kg, its CMS recommended action level for active remediation.

This table shows that the volume of soil contaminated with benzene concentrations above 13
mg/kg was reduced 46.9%; while the volume of soil found to be characteristically hazardous
for benzene, as determined by TCLP benzene testing, and the volume of soil contaminated
with benzo(a)pyrene concentrations above 10 mg/kg were reduced 100%.

7.5 Groundwater Sampling Results

Pre-Treatment Sampling Results
The pre-treatment groundwater sampling results for monitoring wells MW-0060, MW-0061,
MW-0062, and MW-0065 are summarized in Table 7.4. Wells MW-0060 and MW-0061 are
located north northwest of the ISCO pilot test injection area, MW-0062 is located within the
injection area, and MW-0065 is located southeast of the injection area. The water quality
parameter data recorded during the groundwater sampling activities is given in the
groundwater sampling logs included in Appendix A5.

The groundwater sampling pre-treatment results indicate that the ISCO pilot test area
groundwater is primarily impacted by BTEX and SVOCs. Benzene was the only VOC
exceeding its evaluation criteria. Benzene exceedences were found in all four pre-treatment
sample results. The benzene concentrations ranged from 10 to 370 micrograms per liter
(ug/L), with the highest concentration detected in well MW-0062.

Further, nine SVOCs including benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene,
chrysene, bis(2-ethylhexyl)phthalate, indeno(1,2,3-cd)pyrene, 2-methylnaphthalene,
naphthalene, and phenanthrene were detected in concentrations exceeding their respective
evaluation criteria in at least one pre-treatment sample. The highest concentrations for each
of these constituents were also found in well MW-0062. SVOCs were not analyzed in the
pre-treatment samples for wells MW-0060 and MW-0065.

53

Post-Treatment Sampling Results
Post-treatment groundwater sampling results from samples collected during the two post-
treatment sampling events in October 2008 and March/April 2009 are also summarized in
Table 7.4. During the first post-treatment sampling event in October 2008, groundwater
samples were collected from three monitoring wells (MW-0061, MW-0062, and MW-0063)
to demonstrate the effectiveness of the ISCO pilot test and determine its radius of influence
in the SWMU 43 ISCO pilot test area. During the second post-treatment sampling event in
March/April 2009, groundwater samples were collected from four wells (MW-0060, MW-
0061, MW-0062, and MW-0065) to further determine the radius of influence of the ISCO
pilot test, which was not fully delineated after the first post-treatment sampling event.

In general, the groundwater sampling post-treatment results show significant reductions in
BTEX and SVOCs concentrations. Benzene exceedences were found in monitoring wells
MW-0060, MW-0062, and MW-0065 in the second post-treatment sampling event results.
The highest concentration of benzene was 190 ug/L in well MW-0062. Benzene
concentrations were reduced in all four of the wells sampled in both the pre-and second post-
treatment sampling events by 48.6 to 99.3%, with an average of 70.5%.

Six SVOCs including benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, chrysene,
dibenz(a,h)anthracene, and bis(2-ethylhexyl)phthalate exceeded their respective evaluation
criteria during the second post-treatment sampling event. The highest concentrations of these
SVOCs were found in well MW-0061. SVOC concentrations were reduced in both of the
wells that were sampled in both the pre-treatment and second post-treatment sampling events
(MW-0061 and MW-0062) by the following percentages: 1) up to 99%, with an average of
72.2% for benzo(a)anthracene, 2) up to 98.8%, with an average of 56.5% for benzo(a)pyrene,
3) up to 97.8%, with an average of 48.9% for benzo(b)fluoranthene, 4) up to 97%, with an
average of 60.3% for chrysene, 5) up to 93.8%, with an average of 79.1% for bis(2-
ethylhexyl)phthalate, 6) 55%, with an average of 55% for indeno(1,2,3-cd)pyrene, 7) up to
94.3%, with an average of 63.8% for 2-methylnaphthalene, 8) 91.6%, with an average of
91.6%, for naphthalene, and 9) up to 96.6%, with an average of 68.8% for phenanthrene.

Table 7.4 also shows the percentage concentration reduction of individual VOCs and SVOCs
for detected pre-treatment concentrations for each well location following both post-
treatment sampling events. Additionally, Table 7.4 gives the percentage concentration
reduction for total VOCs and total SVOCs for each well location following both post-
treatment sampling events.


54
Total VOCs concentrations were reduced in wells MW-0060, MW-0061, and MW-0065 by
69.4%, 12.8%, and 53.8%, respectively, with an average of 45.4%, in the second post-
treatment sampling event. VOC constituents were not fully analyzed in the pre-treatment
results for well MW-0065, where only BTEX constituents were analyzed. Additionally, total
VOCs concentration slightly increased in well MW-0062. As a result, a concentration
reduction was not applicable to well MW-0062.

Total SVOCs concentrations were reduced in wells MW-0061 and MW-0062 by 52.3% and
93.8%, respectively, with an average of 73.1%. Well MW-0062 also had the highest total
SVOCs concentration in the pre-treatment sampling results (3,422 ug/L). Finally, SVOCs
concentrations were not analyzed in the pre-treatment sampling results for wells MW-0060
and MW-0065. As a result, a concentration reduction was not applicable to these locations.

ISCO Pilot Test Pre- and Post-Treatment Groundwater Modeling Results
Figure 6 summarizes the pre- and post-treatment soil and groundwater sampling results, and
the percentage concentration reductions for each sample location. Additionally, Figure 6
shows the pre- and post-treatment modeling results using RockWorks software for PCOCs
benzene and benzo(a)pyrene concentrations in soil and groundwater. Consistent with the
ISCO pilot test groundwater sampling results presented in Table 7.4, significant reductions of
the benzene exceedence areas within the ISCO pilot test area are displayed in the figure.

Table 7.5 presents the pre- and post-treatment areas and volumes of benzene contaminated
groundwater, and their percentage volume reductions based on the groundwater modeling
results depicted in Figure 6.

Table 7.5
Volume Reduction for Groundwater Modeling Results

Contaminants
Pre-Treatment Post-Treatment
Percentage
Volume
Reduction
Area
(SY)
Volume
(CY)
Area
(SY)
Volume
(CY)
Benzene
1 - 10 ug/L 2,009 6,429 3,040 9,728 -51.3
Benzene
10 - 100 ug/L 1,647 5,270 609 1,949 63.0
Benzene
100 - 1,000 ug/L 124 397 82 262 33.9


55
Notes:
1. The unconfined saturated zone thickness used to calculate the volume of groundwater to
be managed was estimated to be 9.6 feet based on the site-wide boring log observances
and cross-sections shown in the CMS PDI Work Plan figures.
2. Benzene in groundwater was contoured from 1 ug/L, its NJDEP GWQS.
3. The area used to calculate the pre- and post- treatment volumes of benzene contaminated
groundwater within the ISCO pilot test area was based on the ISCO pilot test radius of
influence (see Section 7.6 and Figure 7).
4. A negative value indicates a percentage increase (not reduction) in volume.

This table shows that the volume of groundwater contaminated with benzene concentrations
between 10 and 100 ug/L and >100 ug/L decreased 63% and 33.9%, respectively; while the
volume of groundwater contaminated with benzene concentrations between 1 and 10 ug/L
correspondingly increased.

7.6 Radius of Influence

The groundwater horizontal radius of influence around the ISCO pilot test area was
estimated by observing the percentage concentrations reductions of VOCs, SVOCs, and
benzene in the groundwater sample locations. Figure 6 and Table 7.6 show that all the well
locations that were sampled in both the pre- and second post-treatment sampling events had
concentration reductions greater than 20% of VOCs, SVOCs, and/or benzene.

Table 7.6
ISCO Pilot Test Percentage Concentration Reduction Results

Well
Distance to
Center of
Injection Area
(feet)
% VOC
Concentration
Reduction
(%)
% SVOC
Concentration
Reduction
(%)
% Benzene
Concentration
Reduction
(%)
MW-0060 120 26.4 NA 83.3
MW-0061 67.25 26.4 51.5 99.3
MW-0062 12.5 14.2 93.5 48.6
MW-0065 126 53.8 NA 60

Injection point IP-02 is in the approximate center of the injection area (see Figure 6). The
maximum distance from IP-02 of a well location shown to have concentration reductions
greater than 20% of VOCs, SVOCs, and/or benzene is 126 feet, or that measured from IP-02
to well MW-0065. However, benzene concentration fluctuations have been observed at this
well prior to the ISCO pilot test, and a decrease in its concentration shouldnt be attributed to

56
its oxidation during the ISCO treatment. Therefore, the following maximum distance from
IP-02 is 120 feet, or that measured to well MW-0060. Although this distance could probably
be considered a maximum groundwater horizontal radius of influence that can be estimated
from the sampling results, well locations were not sampled at distances greater than 120 feet
from the center of the injection area in the post-treatment sampling events. The groundwater
horizontal radius of influence for this ISCO pilot test is shown on Figure 7, which also
displays the post-treatment modeling results and percentage concentration reduction results
for VOCs, SVOCs, and benzene and benzo(a)pyrene (the organic PCOCs) in both soil and
groundwater.

The area of the groundwater encompassing the horizontal radius of influence shown on
Figure 7 is estimated to be 34,020 square feet based on the radius of influence of 120 feet
and the boundary of the Surge Pond sheet pile wall on the northeast side of the ISCO pilot
test area. The thickness of the groundwater in this area was estimated to be 9.6 feet based on
the boring log observances and cross sections shown in the CMS PDI Work Plan Figures.
The soil horizontal area of influence around the ISCO pilot test area was estimated by
observing the percentage concentration reductions of VOCs, SVOCs, and the organic
PCOCs in the soil sample locations. Figure 6 shows that all of the soil locations that were
sampled in both the pre- and post-treatment sampling events had concentration reductions
greater than 20% for VOCs, SVOCs, and/or organic PCOCs, except for S2582, whose pre-
treatment results were either undetected or below the PQL levels for all VOC and SVOC
constituents, as well as TCLP benzene.
Therefore, the minimum soil horizontal area of influence was estimated by drawing a
rectangle that encompasses all 10 of the soil sampling locations, which is shown on Figure 7.
This area is calculated to be approximately 10,600 square feet. The soil sampling location
furthest from IP-02, the approximate center of the injection area, is S2221, which had
concentration reductions of VOCs, benzene and TCLP benzene of 99%, 99.7%, and 77.3%
respectively. S2221 is located approximately 141 feet from IP-02. The soil horizontal area
of influence is considered a minimum because soil samples were not collected at distances
greater than 141 feet from IP-02 in the post-treatment sampling events, while S2221 had
significant reductions in VOCs, including benzene, concentrations as discussed above.
Further, the minimum soil horizontal area of influence was not extrapolated beyond the
locations of soil samples collected in the pre- and post-treatment sampling events. The
pictures included in Appendix C support the estimated soil horizontal area of influence of
141 feet. Picture 28 shows ISCO chemicals foam coming out of the soil at distance of
approximately 155 feet form IP-02, which would results in an estimated soil horizontal area
of influence of approximately 14,650 square feet.

57
The soil thickness of influence in the ISCO pilot test area was estimated based on the depths
of the post-treatment soil sample locations samples where concentration reductions greater
than 20% for VOCs, SVOCs, and/or organic PCOCs were achieved. Table 7.2 shows that
these sample depths ranged from 0.5 feet (soil sample location S2582) to 13.0 feet bgs (soil
sample locations S2221 and S2466). Based on these observations, the soil thickness of
influence for this ISCO pilot test is estimated to be 12.5 feet.

Based on these sampling results and the observations made in the soil boring logs (see
Appendix A1), the ISCO pilot test was effective in reducing concentrations of VOCs,
SVOCs, and organic PCOCs in the soil in both the vadose and saturated zones. Out of 10
soil sample locations, seven were collected in the saturated zone and three in the vadose
zone. Two of the saturated zone soil samples (S2221 and S2235) were collected from the
native stratum.


58
7.7 Petroleum Hydrocarbon Mass Reduction

The amount of petroleum hydrocarbons degraded at the Site as a result of the ISCO pilot test
was determined by calculating and comparing the mass of VOCs and SVOCs within the soil
and groundwater volumes of influence in the pre- and second post-treatment sampling
events.

The mass of petroleum hydrocarbons in the soil before and after treatment was calculated as
follows:

( ) ( ) M mg
Kg soil
L soil
C
mg
Kg soil
V L soil =

_
_ _
_
where:
M is the mass of contaminant in the soil,
is the density of the soil in the SWMU 43 ISCO pilot test area (assumed to be 110 lbs/ft
3

or 1.76 kg/L),
C is the average concentration of the contaminant in the soil, and
V is the volume of contaminated soil (10,600 ft
2
x 12.5 ft x 28.34 L/ft
3
= 2.85 x 10
6
L).

The mass of petroleum hydrocarbons present in the groundwater before and after treatment
was calculated using the following equation:

( ) ( ) M ug C
ug
L water
V L water =

_
_
where:
M is the mass of contaminant in the groundwater,
is the porosity of the soil in the SWMU 43 area (assumed to be 0.4),
C is the average concentration of the contaminant in the groundwater, and
V is the volume of contaminated groundwater (34,025 ft
2
x 9.6 ft x 28.34 L/ft
3
= 9.24 x 10
6

L).

Tables 7.7 and 7.8 summarize the pre- and post-treatment average concentrations, masses
and mass reductions for each VOC and SVOC contaminant detected in the pre-treatment
sampling results for soil and groundwater, respectively.

These tables show that the ISCO pilot test was effective at reducing the mass of both VOCs
and SVOCs in the soil and SVOCs in the groundwater within the area and radius of
influence of the test, respectively.

60
Table 7.7 demonstrates that 1,255 kg of VOCs and 693 kg of SVOCs, for a total of 1,948 kg
of regulated organic contaminants in the soil were destroyed during the test. This significant
mass reduction occurred even taking into account a substantial increase in the mass of
cyclohexane (68 kg) partial oxidation product of BTEX and PAH contaminants. This is
evidence that incomplete oxidation took place during the duration of ISCO reactions. It is
important to mention that the objective of the test, as a CM to be implemented, is not to
complete degrade regulated contaminants, nor the soil oxygen demand; but to decrease the
regulated contaminants concentration to levels below the criteria. Additionally, this
cyclohexane is far less toxic and not carcinogenic as compared to its associated reactant
BTEX and PAH contaminants, especially PCOCs benzene and benzo(a)pyrene, which are
class A and B carcinogens, respectively (USHHS. 2001). Additionally, the mass of methyl
acetate increased by only 1 kg.

The percentage mass reduction of total VOCs and total SVOCs were 34.8% and 46.5%,
respectively, and the total percentage mass reduction of VOCs and SVOCs was 38.2%.
Finally, 54.9 kg of benzene and 26.0 kg of benzo(a)pyrene, the organic PCOCs, were
destroyed in the soil for mass/concentration reductions of 57.3 and 70.1% , respectively.

Table 7.8 demonstrates that 0 kg of VOCs and 6.67 kg of SVOCs, for a total of 6.67 kg of
regulated organic contaminants in the groundwater were destroyed during the test.
Additionally, the total percentage mass reduction of SVOCs was 82%. The null mass
reduction of VOCs is probably attributed to the low concentrations and low mass of VOCs
dissolved in the groundwater within the radius of influence of the test (281 ug/L and
1.04 kg of total VOCs, respectively). Total VOCs represented approximately 13% of the
total organic regulated contaminants in the groundwater. Finally, 0.227 kg of benzene and
0.082 kg of benzo(a)pyrene were destroyed in the groundwater for mass/concentration
reductions of 54.9 and 92.2%, respectively.

Comparing Tables 7.7 and 7.8, its clear that the overwhelming bulk of VOC and SVOC
contaminants were adsorbed to the soil (99.8%). Correspondingly the overwhelming bulk of
the mass reduction occurred in the soil (99.7%).

Using the same equations to calculate the mass of petroleum hydrocarbons, as well as the
volumes from the modeling results presented in Tables 7.3 and 7.5, the masses of the
organic PCOCs benzene and benzo(a)pyrene that exceeded their criteria and action level,
which were destroyed in the soil and groundwater as a result of the ISCO pilot test, were
calculated and are presented in Table 7.9 below.


61
Table 7.9
Mass Reduction for Soil and Groundwater Modeling Results

Contaminants
Pre-Treatment
Sampling Event
Second Post-Treatment
Sampling Event
Mass
Reduction
(Kg)
Percentage
Mass
Reduction
Average
Concentration
Volume
(CY)
Mass
(Kg)
Average
Concentration
Volume
(CY)
Mass
(Kg)
Benzene
> 13 mg/kg 28.25 356 13.52 28.50 189 7.25 6.27 46.4
Benzo(a)pyrene
> 10 mg/kg 14.00 117 2.20 NA 0 0 2.20 100.0
Total Soil NA NA 15.72 NA NA 7.25 8.47 53.9
Benzene
1 - 10 ug/L 5.50 6,429 0.011 6.00 9,728 0.018 NA NA
Benzene
10 - 100 ug/L 26.00 5,270 0.042 55.00 1,949 0.033 0.009 21.8
Benzene
100 - 1,000
ug/L 370 397 0.045 190 262 0.015 0.030 66.0
Total
Groundwater NA NA 0.098 NA NA 0.066 0.032 32.5

Notes:
1. NA = Not applicable
2. Average concentrations were estimated based on the sampling results included in Tables 7.2
and 7.4, except for the average concentration for benzene within 1-10 ug/L in the pre-
treatment sampling event and benzene within 10-100 ug/L in the second post-treatment
sampling event. In these cases, benzene concentrations were not found within the above-
mentioned ranges in the samples analyzed. As a result, the average benzene concentrations
were estimated by averaging the boundary concentrations of these ranges.
3. An average bulk soil density of 1.76 grams per cubic centimeter was used to calculate the
mass of hydrocarbons. This soil density is consistent with that assumed in Table 10 of the
CMS Final Report (110 lb/ft
3
).

Table 7.9 demonstrates that 6.27 kg of benzene and 2.2 kg of benzo(a)pyrene, for a total of
8.47 kg of these organic PCOCs in exceedence of their respective criteria and action level,
were destroyed during the test. Additionally, the mass of benzene in concentrations above
its criteria was reduced by 46.4%. This percentage mass reduction is close to the overall
benzene percentage mass reduction in soil of 57.3% shown in Table 7.7. Further, the mass
of benzo(a)pyrene above its action level was reduced 100% compared to the overall
benzo(a)pyrene percentage mass reduction of 70.1% (see Table 7.7). The overall mass
reduction in soil of benzene and benzo(a)pyrene in exceedence of their respective criteria
and action level was 53.9% as given in Table 7.9, and the overall mass reduction of VOCs
and SVOCs in soil was 38.2% presented in Table 7.7.

62

Table 7.9 shows that 0.098 kg of benzene in exceedence of its GWQS was destroyed during
the test, which corresponds with a percentage mass reduction of 32.5%. This is similar to
the overall benzene percentage mass reduction in groundwater of 54.9% shown in Table 7.8.
The results also show that the FR ISCO process is more effective in reducing higher
concentrations of benzene in the groundwater. The mass of benzene in concentrations
between 10 and 100 ug/L was reduced 21.8%, while the mass of benzene in concentrations
above 100 ug/L was reduced 66.0%. This is a typical result of FR ISCO processes, which
have high reaction kinetics. As a result, there is a higher probability of the free hydroxyl
radical, the intermediate product of the FR ISCO process, making contact and reacting with
higher concentrations of contaminants, including benzene. Finally, Table 7.9 indicates that
the overwhelming bulk of mass reduction for the organic PCOCs benzene and
benzo(a)pyrene in exceedence of their respective criteria and action level occurred in the soil
(99.6%), consistent with the results above for the overall VOC and SVOC contaminants
presented in Tables 7.7 and 7.8.

LNAPL monitoring and interim remedial measures (IRMs) are currently being conducted in
the SWMU 43 area where the ISCO pilot test was performed. These IRMs include periodic
active LNAPL extraction with a mobile vacuum truck and belt skimmer systems operated
intermittently. The LNAPL product from the belt skimmer systems is collected in a drum
and periodically removed from the area and recycled off-site. Monitoring wells MW-0061,
MW-0062, and MW-0063 each have belt skimmer systems. These systems were turned off
during the ISCO pilot test to allow monitoring of the test to be conducted in each of these
wells. However, each of these systems was turned on following the completion of the test.
As a result, it is impossible to quantify and attribute the mass reduction of LNAPL in these
wells to the ISCO process or the ongoing IRMs.

63
8.0 CONCLUSIONS

Based on the results presented in Section 7, the ISCO pilot test was effective in achieving its
objectives including: 1) to confirm the effectiveness of ISCO in treating the organic
contaminated soil and groundwater at the Site, specifically benzene in soil at concentrations
above 13 mg/kg and groundwater at concentrations above 100 ug/L, TCLP benzene at
concentrations above 0.5 mg/L, and benzo(a)pyrene in soil at concentrations above 10
mg/kg, and 2) to obtain engineering data to support the design of a full scale ISCO
remediation system including the injection flow rates of the reagents, the injection pressures,
the radius of influence around the injection points, and the duration of treatment.

Total regulated VOCs and SVOCs masses/concentrations in soil were reduced by 34.8% and
46.5%, respectively, with a total mass/concentration reduction of VOCs and SVOCs of
38.2%. Additionally, 1,255 kg of VOCs and 693 kg of SVOCs, for a total of 1,948 kg of
regulated organic contaminants in the soil were destroyed during the test, including 54.9 kg
of benzene and 26.0 kg of benzo(a)pyrene, the organic PCOCs. Further, the
mass/concentration reductions for benzene and benzo(a)pyrene in soil were 57.3 and 70.1% ,
respectively. Also, the concentration reduction for TCLP benzene was 69%. Finally, the
average concentrations of benzene, TCLP benzene and benzo(a)pyrene in the soil within the
area of influence of the ISCO pilot test following the second post-treatment sampling event
are 6.18 mg/kg, 0.09 mg/L, and 1.63 mg/kg, respectively. Each of these concentrations are
below the criteria, regulatory level, and action level for benzene, TCLP benzene, and
benzo(a)pyrene of 13 mg/kg, 0.5 mg/L, and 10 mg/kg, respectively, as given in the CMS
Final Report (URS. 2008c).

Total regulated VOCs and SVOCs masses/concentrations in groundwater were reduced 0%
and 94.1%, respectively, with a total mass/concentration reduction of VOCs and SVOCs of
82%. Additionally, 0 kg of VOCs and 6.67 kg of SVOCs, for a total of 6.67 kg of regulated
organic contaminants in the groundwater were destroyed during the test, including 0.227 kg
of benzene and 0.082 kg of benzo(a)pyrene. Further, the mass/concentration reductions for
benzene and benzo(a)pyrene in groundwater were 54.9 and 92.2%, respectively. Finally, the
average concentration of benzene in the groundwater within the radius of influence of the test
following the second post-treatment sampling event is 50.6 ug/L, below the action level of
100 ug/L of benzene for recommending ISCO as a corrective measure for contaminated
groundwater as shown in Table 7.1 of the CMS Final Report (URS. 2008c).

(URS. 2008c)

64
Significant mass/concentration reductions of benzene and benzo(a)pyrene in exceedence of
their respective criteria and action level were also achieved. Benzene and benzo(a)pyrene
exceedences in soil were reduced by 46.4 and 100%, respectively, with a combined mass
reduction in soil of 53.9%. Additionally, 6.27 kg of benzene and 2.20 kg of benzo(a)pyrene
exceedences, for a combined mass of 8.47 kg of organic PCOCs, were destroyed during the
test. Also, benzene exceedences in groundwater were reduced by 32.5%, with a benzene
exceedence mass reduction of 0.032 kg as a result of the test. Finally, 100% of the TCLP
benzene exceedences were destroyed during the test.

The groundwater horizontal radius of influence for the ISCO pilot test is 126 feet, or the
distance from injection point IP-02, the approximate center of the injection area, and well
MW-0065, which had a benzene concentration reduction of 60%. Additionally, the
minimum soil horizontal area of influence was calculated to be approximately 10,600 square
feet, or the area inside a rectangle that encompasses all of the soil sampling locations (see
Figure 7). Each of the sampling results for these locations showed concentration reductions
greater than 20% for VOCs, SVOCs, benzene, and/or benzo(a)pyrene. In fact, the soil
sampling location furthest from IP-02, S2221, had concentration reductions of VOCs,
benzene, and TCLP benzene of 99%, 99.7%, and 77.3% respectively. S2221 is located
approximately 141 feet from IP-02. Finally, the minimum soil horizontal area of influence is
consistent with visual observations of ISCO byproducts seeping from the surface soil during
and immediately after injection activities. These byproducts seeps were photo documented
and are displayed in Appendix C.

The results of the field analytical parameters monitored during the course of injection
activities demonstrate further evidence of ISCO reactions occurring in the subsurface soil and
groundwater within the ISCO pilot test area including the following: 1) significant increases
in the soil vapor carbon dioxide and VOC concentrations, 2) significant increases in the DO
and ORP of the groundwater, and 3) a significant decrease in the pH of the groundwater.
The carbon dioxide concentrations, which are a product of the ISCO reactions, showed an
increase of up to 62,400% in the soil vapor during the course of the peroxide/acid solution
injection activities. Additionally, the ORP concentrations of the groundwater changed from
reductive (as indicated by the negative values) to oxidative (as indicated by the positive
values) during the course of the peroxide/acid solution injection activities. These changes
occurred at distances of up to 52 feet from the respective injection points. No monitoring
point (wells or piezometers) were monitored at distances greater than 52 feet from an
injection point.


65
Critical engineering data was obtained during the course of the ISCO pilot test to support the
design of a full scale ISCO remediation system including the following: 1) injection flow
rates of the ISCO reagents, 2) injection pressures, 3) the duration of treatment, and 4) the
radius of influence around the injection points.
The ISCO reagents injection flow rates ranged from 2 to 7 gpm. Additionally, injection
pressures generally ranged from 2 to 30 psig. Also, the duration of the ISCO pilot test was
10 days with an average volume of FR solutions injected per day of 672 gallons. This
volume would be expected to increase during the full scale ISCO application. Further, the
radius of influence around the injection points was discussed above. Finally, as
demonstrated above, ISCO has been shown to be an effective CM for both groundwater and
soil contaminated media, including both vadose zone and saturated zone soils. Three of the
10 soil samples collected in the pre-treatment and second post-treatment sampling events
were collected in the vadose zone (S2582, S2087, and S2221). The average concentration
reductions for VOCs, SVOCs, and TCLP benzene in the sampling results for these vadose
zone locations were 99.3%, 53.2%, and 88.2%, respectively.
In addition, ISCO would be effective in treating the characteristically hazardous benzene,
non-hazardous benzene and other organic contaminated soil in exceedence of their respective
criteria/standard, and groundwater with benzene concentrations >100 ug/L in the Main, East
,and Central Yards, as recommended in the CMS Final Report, based on their geologic
similarity with SWMU 43. As described in Section 2, the fill overlying a discontinuous peat
layer and gray clay (Clay Horizon A) contains varying amounts of sands, silts and clay, and
ranges in thickness from 3 to 15 feet, 4 to 29 feet, and 7 to 19 feet in the Main, East, and
Central Yards, respectively. The shallow groundwater in the Site is mainly encountered in
the unconfined fill layer; and groundwater levels have been observed between and feet bgs,
and feet bgs, and and feet bgs in the Main, East, and Central Yards, respectively. With the
exception of the SWMU 8 area, the results from the CMS PDI showed that the organic
contamination throughout the Refinery has been found primarily in the fill material.


66


67
9.0 REFERENCES

Driscoll, F. G. 1986. Groundwater and Wells. Reynolds Guyar Designs, Johnson Division,
Second Edition. USA; pps 67 and 1089.

Entact. 2008. Bench Scale Treatability Study Report. Prepared for Chevron Perth Amboy
Refinery. Perth Amboy, New Jersey. May.

Interstate Technology Regulatory Council (ITRC). 2005. Technical and Regulatory Guidance
for In-Situ Chemical Oxidation of Contaminated Soil and Groundwater. 2
nd
Edition. January.

Mahmoud, M., Achari, G., Xu, P., Joshi, R.C., 2003. Latest Findings in In Situ Remediation
of Hydrocarbon Impacted Soils Using Hydrogen Peroxide. Remediation Technologies
Symposium. October.

Parsons. 2005. AOC 29 5 Berth Alternatives Evaluation Report. Prepared for Chevron
Perth Amboy Refinery. Perth Amboy, New Jersey. April.

Parsons. 2006. Data Management Plan for the RCRA Facility Investigation. Prepared for
Chevron Perth Amboy Refinery. Perth Amboy, New Jersey. August.

Parsons. 2008a. 2006 Stabilization Measures Status Report. Prepared for Chevron Perth
Amboy Refinery. Perth Amboy, New Jersey. February.

Parsons. 2008b. 2007 Stabilization Measures Status Report. Prepared for Chevron Perth
Amboy Refinery. Perth Amboy, New Jersey. June.

Parsons. 2009. 2008 Stabilization Measures Status Report. Prepared for Chevron Perth
Amboy Refinery. Perth Amboy, New Jersey. June.

Science Applications International Corporation (SAIC). 2003. Full RCRA Facility
Investigation (RFI) Report. Prepared for Chevron Perth Amboy Refinery. Perth Amboy, New
Jersey. November.

SAIC. 2005. Central Yard Area of Concern (AOC) 36 Triad-Based Approach Chlorinated
Plume Investigation. Prepared for Chevron Perth Amboy Refinery. Perth Amboy, New
Jersey. August 25.

SAIC. 2007. SWMU/AOC Assessment Report AOC 37 through AOC49. Prepared for
Chevron Perth Amboy Refinery. Perth Amboy, New Jersey. February.

SAIC. 2008. Supplemental RFI Report. Prepared for Chevron Perth Amboy Refinery. Perth
Amboy, New Jersey. February.

URS Corporation. 2004. Corrective Measures Study Work Plan. Prepared for Chevron Perth
Amboy Refinery. Perth Amboy, New Jersey. July.

68

URS Corporation. 2006a. Corrective Measures Study Pre-Design Investigation Work Plan
Main Yard. Prepared for Chevron Perth Amboy Refinery. Perth Amboy, New Jersey.
October.

URS Corporation. 2006b. Corrective Measures Study Pre-Design Investigation Work Plan
East Yard. Prepared for Chevron Perth Amboy Refinery. Perth Amboy, New Jersey.
December.

URS Corporation. 2007a. Corrective Measures Study Pre-Design Investigation Work Plan
Central Yard. Prepared for Chevron Perth Amboy Refinery. Perth Amboy, New Jersey.
August.

URS Corporation. 2007b. Petition to Delist SWMU 43. Prepared for Chevron Perth Amboy
Refinery. Perth Amboy, New Jersey. April 2.

URS Corporation. 2008a. Request for Authorization of Discharge to Groundwater by Permit-
by-Rule for Proposed In-Situ Chemical Oxidation Pilot Test for Treatment of Impacted Soil
and Groundwater. Prepared for Chevron Perth Amboy Refinery. Perth Amboy, New Jersey.
July 29.

URS Corporation. 2008b. Corrective Measures Study Pre-Design Investigation Results
Report. Prepared for Chevron Perth Amboy Refinery. Perth Amboy, New Jersey. November.

URS Corporation. 2008c. Corrective Measures Study Final Report. Prepared for Chevron
Perth Amboy Refinery. Perth Amboy, New Jersey. November.

US Department of Health and Human Services (USHHS). 2001. 9
th
Report on Carcinogens.
Public Health Service. National Toxicology Program. January.

Woodward-Clyde Consultants. 1981. Phase I Report and Hydrogeological Study. Prepared
for Chevron USA, Inc., Perth Amboy, New Jersey Refinery by Woodward-Clyde
Consultants, Wayne, NJ. September.

Woodward-Clyde Consultants. 1982a. Phase II Report and Hydrogeologic Study. Prepared
for Chevron USA, Inc., Perth Amboy, New Jersey Refinery by Woodward-Clyde
Consultants, Wayne, NJ. February 25.

Woodward-Clyde Consultants. 1982b. Addendum to the Phase II Report - Hydrogeologic
Conditions and Analysis of Groundwater Quality (North Field Extension). Prepared for
Chevron USA, Inc., Perth Amboy, New Jersey Refinery by Woodward-Clyde Consultants,
Wayne, NJ. February 10.

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