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Feasibility Study

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A Feasibility Study (FS) is an evaluation of alternative remedial options for soil and groundwater contamination. Both technical and economic feasibility shall be evaluated for each viable remedial alternative to comply with the most current applicable regulatory standards (when applicable, a combination of three or more remedial alternatives should be evaluated). Alternative cleanup standards based on natural attenuation (Appendix F) through implementation of risk-based corrective action will be considered only if a thorough feasibility study was conducted and the best available technology (BAT) was chosen and implemented. The selected BAT must have been operated for a pre-determined time period determined by the RWQCB and GPP, and the contamination must have reached asymptotic levels. Continued operation of the remedial system must be shown to only result in insignificant reduction in contaminant concentrations. The trade-off analysis of economic feasibility and added protection of human health and the environment must be presented to justify alternative cleanup standards. Regardless of the economic feasibility, however, the designated beneficial uses of any existing or potential drinking water sources must not be compromised. 1.0 Feasibility Study Workplan Within ninety (90) calendar days following GPP approval of the Final Remedial Investigation Report, a Feasibility Study Workplan must be submitted with the following information. 1.1 Site Information - Refer to PSA Report Site Information section 1.2 Maps - Refer to PSA Report Map section 1.3 Screening Criteria At least three alternatives must be evaluated (including Natural Attenuation; Appendix F) according to the following criteria: 1.3.1 Technical Feasibility 1.3.1.1 Literature search 1.3.1.2 Site geology and hydrogeology 1.3.1.3 Nature and extent of impact to all media 1.3.1.4 Quantity of groundwater and surface water requiring remediation 1.3.1.5 Quantity of contaminated soil requiring remediation 1.3.1.6 Chemical and physical characteristics of contaminants 1.3.1.7 Targeted cleanup goals 1.3.1.8 Site conditions 1.3.1.9 Current and future site use 1.3.2 Economic Feasibility 1.3.2.1 Capital cost 1.3.2.2 Operating cost, including periodic monitoring 1.3.2.3 Long term operation and maintenance cost, including periodic monitoring 1.3.2.4 Disposal cost 1.4 Treatability Study 1.4.1 Description of the testing procedures (e.g., aquifer test, soil extraction tests) 1.4.2 Treatability design parameters 1.4.3 Description of monitoring plan 2.0 Feasibility Study Report Within sixty (60) calendar days following completion of the feasibility study, a Feasibility Study Report must be submitted that includes the following information. 2.1 Site Information - Refer to PSA Report Site Information section 2.2 Maps - Refer to PSA Report Map section 2.2.2 Locations of soil borings, soil probes, and monitoring wells installed to conduct the feasibility study must be shown relative to historic site features. 2.3 Testing Procedures 2.3.1 Description of construction and destruction of testing equipment 2.3.2 Description of on-site and off-site monitoring and data collection 2.3.3 Dates and duration of tests 2.4 Treatability Study Findings 2.4.1 Radius of capture 2.4.2 Analytical results of influent and effluent 2.4.3 Preferential flow/capture of groundwater 2.4.4 Effectiveness evaluation 2.4.5 Discussion of advantages and disadvantages 2.4.6 Contaminant removal rates 2.5 Comparative Analyses 2.5.1 Relative performance result 2.5.2 Implementability 2.5.3 Cost effectiveness 2.5.4 Implementation time frame 2.5.5 Advantages and disadvantages of each remedial alternative 2.6 Risk-Based Corrective Action RBCA may be included as one of the remediation options. See the section on Evaluation of Risk. 2.7 Recommendations Recommend the best available technology based on technical feasibility, economic feasibility, water conservation, and time frame. 3.0 Alternative Cleanup Standards 3.1 Alternative cleanup standards may apply given the following conditions. 3.1.1 Best available technology has been implemented over a pre-specified period of time; the majority of the contaminant mass has been successfully removed and the contaminant concentrations have reached asymptotic levels. 3.1.2 Best available technology has been implemented to the maximum extent feasible; the residual contamination in groundwater and soil will not affect beneficial uses or pose a significant threat to the environment and human health. 3.1.3 Section I and II of the Feasibility Study have been completed and circumstances exist for the specific site such that alternative cleanup standards are appropriate. 3.2 The following supporting documentation must be provided 3.2.1 Exposure risk assessment of human health and environment (see Evaluation of Risk) 3.2.2 Toxic nature and hazardous potential of individual contaminants when any receptor is exposed to a mixture of contaminants 3.2.3 Nature and extent of residual contaminants in all media 3.2.4 Monitoring plan 3.2.5 Risk management plan for short and long term risk 3.2.6 Risk management for long term exposure