What: Public meeting to share information and accept comments on EPA’s Interim Remedial Action Plan
When: Tuesday, October 13, 6:00PM
Where: TC Roberson High School Auditorium, 250 Overlook Road, Asheville
You can also submit written comments through Friday, October 30 to Craig Zeller, EPA Remedial Project Manager, at email@example.com or US EPA Region 4, Superfund Division – 11th Floor, 61 Forsyth Street, SW, Atlanta, GA 30303.
Questions for EPA: Contact Angela Miller, EPA Community Involvement Coordinator, firstname.lastname@example.org or (678) 575-8132.
Statement: POWER Supports Proposed Interim Remedial Action at CTS Superfund Site – Pushes for Increasing Treatment Area as EPA Tells CTS would get Better Results
The U.S. Environmental Protection Agency announced last week that it plans to approve an Interim Remedial Action to begin cleaning up the residual hazardous waste still saturating the ground at the CTS Superfund Site, which causes widespread ground water contamination at off-site private properties to the east and west of the old plant site.
CTS contractor AMEC Foster Wheeler proposes to treat approximately one acre of soil near the old building slab, where the light, non-aqueous phase liquid (LNAPL) contamination is concentrated (called the LNAPL Source Area).
EPA wants CTS to expand the treatment area, however, to include about one additional acre to the north, where extremely high levels of TCE exist also in soil, ground water, and weathered bedrock. TCE has been found in ground water there at up to 62,100 parts per billion (more than 12,000 times the maximum allowable level!), so it is a major source of contamination that continues to flow off-site.
A process called Electrical Resistance Heating (ERH) is proposed for the Interim Action
- Electrodes driven into the ground conduct electric current into the subsurface
- Ground heats up, and actually boils ground water
- Hazardous chemicals including the primary site contaminant, trichloroethylene (TCE), and petroleum compounds are vaporized by the boiling
- Vapors are collected by vacuum extraction wells so they can be treated
- Any liquid LNAPL collected in vapor wells is collected and disposed off-site
- Treatment would be completed in less than one year (after design)
AMEC studied various alternatives of remedial action earlier this year, but determined that none of the other methods would be as effective or quick, compared to ERH
- LNAPL was not mobile enough to pump efficiently; residual LNAPL would remain.
- Collection of liquid and vapor phase TCE using multi-phase extraction (MPE) would take up to ten years.
- Washing LNAPL from soil by injecting chemical solution to flush it toward collection wells also inefficient; not all LNAPL removed and two years needed.
- Injecting chemicals into the ground to destroy the TCE would require multiple injections to reach all LNAPL; would take three years.
POWER Action Group believes that ERH should be used, but that EPA should force CTS to increase the treatment area to include the additional part of the site to the north where so much TCE remains in the ground water. Otherwise, a major source of ground water contamination will still be there after AMEC treats its one-acre LNAPL Source Area, and off-site contamination may not be reduced much, if at all. If you agree, tell EPA to make CTS clean up the additional area NOW, as part of the Interim Remedial Action, to better protect off-site ground water.
Interim Remedial Action Plan (PDF)
Our suggestions for what to include in your comments (PDF)