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Whirlpool Corporation Public Meeting and Public Hearing Remedial Action Decision Document (RADD)

Whirlpool Corporation Public Meeting and Public Hearing Remedial Action Decision Document (RADD). November 12, 2013. Intent of the RADD. ADEQ’s Decision Regarding the Nature and Extent of the Release Implement corrective action in response to the release of hazardous constituents

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Whirlpool Corporation Public Meeting and Public Hearing Remedial Action Decision Document (RADD)

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  1. Whirlpool Corporation Public Meeting and Public Hearing Remedial Action Decision Document (RADD) November 12, 2013

  2. Intent of the RADD • ADEQ’s Decision Regarding the Nature and Extent of the Release • Implement corrective action in response to the release of hazardous constituents • Protect public health and the environment

  3. Whirlpool Plant

  4. Introduction • Former Whirlpool facility is located at 6400 Jenny Lind Road , Fort Smith, Arkansas • Facility is approximately 153 acres • Whirlpool entered a Letter of Agreement (LOA) with ADEQ to investigate and remediate impacted groundwater at the northern portion of the facility • RADD describes the possible remedies and ADEQ’s decision for the chosen remedial actions

  5. Trichloroethene (TCE) • Toxic • Carcinogen • Volatile Organic Compound • Exists in soils and groundwater on the former Whirlpool facility • Exists off-site in groundwater north of the former Whirlpool facility

  6. Site Background • Former Whirlpool facility manufactured side-by-side household refrigerators and trash compactors • The presence of TCE in soil and groundwater was discovered in the late 1980’s • The facility volunteered to conduct corrective action through EPA CAS program

  7. Field Investigation Results • On-Site Impact: Source area is located on-site west of the former degreaser building where elevated concentrations of TCE were detected in soil and groundwater • Off-Site Impact: Groundwater with detected concentrations of TCE extends into the residential neighborhood north of the site

  8. Groundwater Plume

  9. Groundwater Plume • Groundwater plume at the site is under control • Historical data at the facility indicates the plume boundary has not shifted substantially during the past eight (8) years

  10. Groundwater Systems Made up of: • Aquifer • a geological formation, group of formations, or portion of a formation capable of yielding significant quantities of groundwater to wells or springs • Usually composed of silt, sand and gravel • Aquitard • a geologic unit which prevents movement of significant quantities of water under ordinary hydraulic pressure • Usually composed of silty clays and clays

  11. Types of Aquifers • Unconfined • the water table forms the upper boundary with an aquitard below • typically occur near the land surface • Confined • the aquifer is confined between two aquitards • typically occur at a greater depth below land surface

  12. Unconfined vs. Confined Aquifer Example Aquitard

  13. Groundwater At Whirlpool Site • Confined Aquifer • Because confined aquifers typically are under higher hydraulic pressure than unconfined aquifers, water levels in wells are at a higher elevation (shallower) than the elevation of the aquifer itself. Although water levels are reported near the land surface in some monitoring wells, true depth to groundwater is at the depth of the top of the confined aquifer (deeper), not at the depth to groundwater in the monitoring wells.

  14. Geologic Cross Section Aquifer Aquitard Aquifer From Aquitard

  15. Remedial Approach • Impacted soil (on-site) • Impacted groundwater (on-site and off-site)

  16. Soil Remediation • Impacted soil will be covered with asphalt and an impermeable coating • Soil cover will be designed to prevent water from migrating though the contaminated soil during rain events • Soil gas monitoring program will be implemented • Soil gas data will be obtained to confirm vapor intrusion continues to be an incomplete pathway

  17. Existing and proposed soil gas monitoring locations Current soil gas monitoring locations Proposed soil gas monitoring locations

  18. Groundwater Remediation • Groundwater with elevated TCE concentrations, both on-site and off-site, will be treated in three (3) areas • Area #1 (on-site source area), • Area #2 (north of Ingersoll Avenue), and • Area #3 (near IW-77) • In-situ chemical treatment of groundwater will be conducted in these areas • In-situ chemical treatment will be completed using GeoProbe temporary points • In addition, monitoring of groundwater will be conducted for on-site and of-site plume

  19. Source area (Area #1) with existing and proposed monitoring wells Area 1

  20. Whirlpool Plant

  21. Secondary areas of elevated TCE concentrations (Areas #2 and #3) Area 3 Area 2

  22. Whirlpool Plant

  23. In-Situ Chemical Oxidation (ISCO) • ISCO is conducted by introducing an oxidizing agent • ISCO decomposes and ultimately destroys COCs in the groundwater • Successful treatment requires the contact between COCs and the chemical agent • Hydrogeological conditions are important for ISCO to be successful http://www.arstechnologies.com/images/chemox_1.jpg http://www.fsengrs.com/sitebuildercontent/sitebuilderpictures/7-1225p404.jpg

  24. Types of ISCO • In-Situ Permanganate Oxidation • Utilizes either Potassium Permanganate (KMnO4) or Sodium Permanganate (NaMnO4) to oxidize environmental contaminants • In-Situ Fenton Oxidation • Utilizes hydrogen peroxide (H2O2) and ferrous iron (Fe(II)) to oxidize environmental contaminants • In-Situ Ozone Oxidation • Utilizes a mixture of ozone (O3) and air injected directly into the unsaturated and/or saturated zones to oxidize environmental contaminants • In-Situ Persulfate Oxidation • Utilizes sodium persulfate (Na2S2O8) to oxidize environmental contaminants.

  25. Examples of ISCO used in Arkansas

  26. Institutional Controls • Institutional control for the soil will be implemented to prevent future excavation of the on-site impacted soil • An on-site deed notification will be filed with the appropriate land records office to identify the kinds of contaminants present and describe the activities that are not allowed to be conducted at the facility

  27. Effectiveness Monitoring Program • Submission of Quarterly Progress Reports which includes: • Submission of Soil Gas Monitoring Report • Submission of Groundwater Monitoring Reports • Submission of an Annual Progress Report to the Fort Smith City Board of Directors, ADEQ, and the citizens residing north of Whirlpool • Whirlpool is required to submit a technical review of all remediation TWO years after initiation. • If the remedy is not effective, an additional remedial alternative must be proposed

  28. Public Notice • Public Notice and other related actions for this remedial decision will follow the procedures outlined in the RADD • The comment period applicable to the proposed RADD is scheduled to end on November 18, 2013 • Comments submitted by the mail must be post marked by November 18, 2013

  29. QUESTIONS? Please Note: ADEQ will officially accept verbal comments during the Public Hearing.

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