MARYLAND DEPARTMENT OF THE ENVIRONMENT AND MAYOR AND COUNCIL
TO DISCUSS PROPOSED OIL REMEDIATION AT SHORE REGIONAL HEALTH
JULY 14, 2015
Mayor Cerino called the public meeting to order at 6:03 p.m. In attendance were Council members Liz Gross, Linda C. Kuiper, Samuel T. Shoge and Mauritz Stetson, W. S. Ingersoll, Town Manager, Robert Sipes, Utilities Manager, Jennifer Mulligan, Town Clerk and guests.
Mayor Cerino said that this meeting had to do with a heating oil spill from an underground storage tank on the Hospital property at 200 Brown Street, which dated back to 1986 or 1987. It was initially thought to be a relatively small leak, but upon further investigation, up to 100,000 gallons of heating oil was mistakenly put into the groundwater system. Once this was discovered, the Hospital installed a pump and treat system which captured free product and it also created an area of hydrological control preventing contaminants within the ground from escaping and migrating towards the Town’s shallow water wellheads, which were about 1,000 feet down gradient from the spill.
Mayor Cerino stated that each year the pump and treat system is capturing less free product from the spill, so the question is how to remove the oil left in the ground. He said that IveySol© was introduced by the Hospital with a request for a pilot study to see if it would free up remaining product in the soils and pumped out of the ground. Mayor Cerino stated that the Town did have concerns about this proposal but the study was done and MDE saw promising results. The Hospital has presented MDE with a full proposal to move forward using IveySol© to capture the remaining contaminants.
Mayor Cerino stated that he asked MDE to come speak to him and they scheduled a public meeting regarding the proposed plan of action. He said that the Council and Town employees would be given time to ask questions after the presentation and then the floor would be open to the public.
Mayor Cerino introduced Mr. Horacio Tablada, Deputy Secretary of MDE and Chris Ralston, Program Manager Oil Control Program at MDE. Mr. Tablada stated that additional members of the MDE team present were Hilary Miller, Acting Managing Director of MDE, John Grace, MDE Oil Control Program and Jay Albertson, MDE Communications.
Mr. Tablada stated that MDE’s concern was the protection of public health and the environment and to insure that the citizens of Chestertown have clean water to drink, while at the same time insuring that there is no contamination in the ground. He said that this is routine for MDE, but understood it was not routine for the residents of Chestertown. Mr. Tablada stated that the water in Chestertown was safe to drink and that the water was tested many times throughout the year. Mr. Tablada stated that MDE wanted to get the remaining oil out of the ground at the Hospital site while making sure that no oil reached the Town wells.
Mr. Tablada stated that the remediation plan presented by the Hospital was going to be approved by MDE, with modifications, noting that he believed this plan would achieve the goal of insuring that the petroleum is mostly remediated with nothing moving down to affect Well #8. He said that this plan will give the Town greater protection in the long run. The pump and treat system in operation was not sustainable and has run its course.
Mr. Tablada stated that MDE’s mission was to protect public health and the environment, including drinking water supplies. He said that MDE works with the responsible party, which in this case was the Hospital. He said that they have paid for everything to remediate the site with MDE overseeing and approving their plans. He said it was the Hospital’s responsibility to implement the plans as approved by MDE.
Mr. Ralston stated that he has a staff of fifteen (15) that oversee cleanups similar to the Hospital site throughout the State of Maryland. He said that MDE coordinates with the Water Supply Program and other appropriate offices within MDE as needed for each case.
Mr. Ralston stated that the case was opened with MDE in 1987 when it was disclosed that there had been some test failures from USTs (Underground Storage Tanks) at the Hospital site. Through the course of testing there was never a real determination made as to how much was actually released only minor estimates of less than 10,000 gallons or upwards of 20,000 gallons. He said that those numbers were incorrect as over 83,000 gallons have been recovered to date. Mr. Ralston stated that there was no way to know for certain just how much oil was released, noting that was common when dealing with spills.
Mr. Ralston stated that the best way to determine how much spill is present was by site assessment and site characterization through monitoring wells and said that the models can also show how the footprint of petroleum is being reduced in the subsurface. On average, the pump and treat has pulled anywhere from 40,000,000 gallons of groundwater per year (some lower in previous years) with a dissolved fraction of product rather than free product (oil that can be seen sitting above the water in a well). Mr. Ralston stated that there was also bio-degradation occurring in the sub-surface that did a considerable amount of work in controlling contaminants, both in dissolve phase and free phase product.
Mr. Ralston began a PowerPoint presentation which he said would be available on line at www.mde.state.md.us/programs/land/oilcontrol/remediationsites/pages/program for the public to download on Wednesday, July 15, 2015.
Mr. Ralston stated that the spill site was roughly 1,000 to 1,200 feet up gradient from the Town’s wellheads. He explained the site location in detail and showed where the USTs were located at the time of the spill. The USTs were no longer on site, but at the time of the spill there was a 10,000 gallon heating oil storage tank (primary source), a 1,000 gallon heating oil tank and a 550 gallon gasoline tank. He said that 99% of the spill recovered has been from heating oil. He showed where the boilers being fed by the heating oil were located and where the lines ran to the USTs, noting that the lines were likely corroded and deteriorated in the subsurface causing the spill.
Mr. Ralston stated that the bulk of the primary contaminants were confined to one area above Brown Street. He said that monitoring well #20 has shown levels of free phase product. He said that most of the lower wells have shown no detects, noting that MDE tested for naphthalene, TPHDRO (Total Petroleum Hydro Carbons in Diesel Range Organics), diesel and heating oil, VOCs (Volatile Organic Chemicals, which were more related to gasoline and kerosene). The primary things that MDE looked for were Benzene, Toluene, Ethyl Benzene and Xylenes.
Mr. Ralston stated that the red lines on the PowerPoint indicated cross-sections that lined up with the direction of the plume and groundwater flow. He said that cross section “A” is from the original USTs over the tops of the grades of the soil and a blue line showed the uppermost high water elevation. A green line showed the lower water table elevation. He said that this showed naturally occurring and pumping fluctuation of ground water based on a 2 year period. There was a pink “smear zone” based on water table fluctuations where residual product was expected in the soil and would be the area targeted with surfactant injections. Mr. Ralston stated that the wells were completed at a level 10 to 20 feet below the existing water table when they were installed. Mr. Ralston stated that the horizontal distance was 660 feet and the vertical went from 56 feet above mean sea level down to -20 feet. The groundwater was approximately 40 feet below grade but varied throughout the site.
Mr. Ralston stated that the groundwater contours flowed from the highest elevation to the lowest elevation and at this site flows perpendicular to the lines on the mapping to the cone of depression that was created by the pump and treat system’s active wells. The red dots on the mapping indicated areas where there was measurable free product (oil) sitting on top of water within the monitoring wells. He said LPH (Liquid Phase Hydrocarbons) was oil that would sit on water. It could be measured within a well and moved with the groundwater flow.
Mr. Ralston stated that all of the free phase LPH measured in the wells has been largely recovered by the pump and treat system over a 24 year period (1991 to 2012). The pump and treat system was on and was recovering very little, if any, free base product. It was mostly dissolved phase concentration that was showing up.
Mr. Ralston stated that the area showed in red was where MDE expected to see residual product. He said that they need to remove to the greatest extent possible the product out of the subsurface. The less source area there was in the ground, the less dissolved phase concentrations there would be to migrate down grade.
Mr. Ralston stated that the pilot test last summer included 4 monitoring wells that were used to inject surfactant (3 injections over a 2½ week period) and then 3 to 5 times the amount of surfactant injected into the wells and extracted by pumps in those same wells. The pump and treat system remained on through the entire pilot test as it helped to keep hydraulic control within the area. The surfactant was observed in the treatment system, which showed it was able to move through the subsurface despite the fact it was only injected in 4 wells. It also showed that the pump and treat system was able to extract what was not recovered during the pull events as part of the procedure. There was no indication that surfactants moved down gradient beyond the recovery zone. Mr. Ralston stated that the findings were promising that the large scale surfactant infusion could be done in a safe manner.
Mr. Ralston stated that during the pilot study there were increases in PHCs being recovered, which was expected. He said that the surfactants work by grabbing onto the oil and releasing it into water. He said that the surfactants help dissolve product that can’t otherwise move into the water and then pumps are used to extract it out of the ground.
Mr. Ralston stated that the current proposal was explained to the Mayor and Council in a letter dated July 9, 2015 and would be available on the MDE website on Tuesday, July 15, 2015. He said that the pump and treat system would remain on for the duration of the plan, which was one of the largest changes to the original plan proposal. There would be 275 gallons of potable water and a very dilute surfactant concentration .011% (what was needed to get achievable results). The surfactant would sit in the water for 2 days (48 hours). This allowed time for the water to soak and interact with the residual product in place. Then there would be 3 to 5 times as much liquid pumped out of each well than was injected 2 days prior and would help to extract what was injected into the well as well as anything else that was in the surrounding formation. Mr. Ralston stated that there would be some amount of influence into the subsurface outside of the radius of the well and when pumping it will affect more area than happened with the first injection, although how far out depended on many factors and would vary between 15 and 25 feet.
Mr. Ralston stated that there would be 4 priority zones throughout the process and IveySol© would be injected and extracted in each zone running for 24 to 48 hour turn-around time and lab analysis, which would show if there was still petroleum to recover. If there was petroleum to be recovered, there would be another treatment of that well. It could take several treatments to clear each area of the site. He said that the Hospital was predicting anywhere from 3 to 6 months to complete and then lead into a monitoring phase.
Mr. Ralston stated that the priority zones were as follows on the map:
1) Red Circles – the greatest concentrations of petroleum contaminants were in this area and this would be the primary focus;
2) Blue Circles – smaller wells that did not have as much influence into the subsurface;
3) Orange Wells – treated last (including monitoring well #20);
4) Green Locations – nothing will occur on these wells as they were outside of hydraulic control and the cone of depression.
Mr. Ralston stated that MDE did not have the comfort level to allow for treatments in the green locations. He said that concentrations were very low to non-detect in those wells and there was no need for remediation in those locations at this point in time. The green locations would be used purely for monitoring well locations.
Mr. Ralston stated that monthly gauging of all recovery monitoring wells would take place. The monitoring will look for any free phase product that appeared during the course of the treatments. Quarterly samplings would take place for all groundwater wells for TPHDRO, VOCs and surfactants and 11 of the wells would be sampled monthly for TPHDRO, which would provide a good indication of the gross contamination of the subsurface. The monthly lab and field data would be submitted to MDE and the Town for review.
Mr. Ralston stated that post-remedial monitoring would require the pump and treat system remain running until there were no surfactants detected in any of the monitoring wells, which took about 2 months during the pilot study. After consideration of all analytical data and gauging results a trial shut-down of the pump and treat system will be entertained by MDE. The system will remain in place and if any levels began to show in tests, the pump and treat will be turned back on for further review. He said if the system is shut off there will be an extended review period of at least 1 year, perhaps longer, depending on results of the data.
Mr. Ralston stated that key points of this discussion were that the pump and treat system was not a long term solution, but a short term goal. Hydraulic controls will be in place during the IveySol© injection but at some point they had to get to a point where the pump and treat system was no longer required.
Mr. Ralston stated that the plan, as MDE was prepared to approve, would lead to a significant amount of product removed that the pump and treat system cannot deal with at this time, enhancing the natural bio-degradation that was already occurring. He said that the net benefit will reduce the long-term risk to the Town’s wells. Once completed, there will be a minimum observation time of over a year before any case closure decisions were made.
Mr. Ralston stated that if the data indicated that more remediation was warranted the case would be moved in that direction. He said that the Hospital has come forward with plans on how to deal with remediation and they would continue to do so if the data showed it was required. Mr. Ralston stated that MDE was committed to communication with the Town. He said that all the slides shown this evening would be online on Tuesday, July 15th.
Mr. Stetson stated that much of the skepticism from the Town Council was that nobody knew that the pump and treat system was turned off until well after it had happened and asked why the Town was not notified. Mr. Ralston stated that for the past couple years MDE has notified the Town of all activity at the Hospital site. Mr. Sipes stated that remediation activities began in 2009 and the Town was not notified of anything until they found out about the shutdown and contacted the Hospital and MDE directly. Mr. Tablada stated that there were missed opportunities in the past to communicate with the Town and it was high priority for MDE, noting that this meeting was not required but the Mayor requested it. Mr. Tablada stated that legislation was introduced in 2004 which indicated that MDE was required to notify anyone within a quarter-mile radius of any contamination, but this spill occurred well before then, adding that he understood the Town was the recipient of the consequences if something was not properly handled at the Hospital site.
Ms. Gross stated that the Town had limited resources and said that none of the maps shown on the PowerPoint showed Well #8, which was one of the most productive wells that the Town ever had and has been lost as a result of this spill. She said there has been no compensation Well #8 or the expenses of over $30,000.00 spent on legal fees and extra testing, noting that there would be more expenses to come.
Ms. Gross stated that in MDE’s letter of July 9th to the Town makes a statement that “free phase petroleum typically reaches the maximum extent of migration through the period of approximately 2 to 5 years” and asked how that changed when a surfactant was added to the mix, or if the extent of migration then expands and/or accelerates. Mr. Ralston stated that surfactants liberate residual oil in the soil for extraction. Hydraulic control was key in introducing a surfactant and why the proposed method was to inject and extract while the pump and treat system was running.
Ms. Gross stated that a major concern for the Town was for the future if the case is closed. She asked what assurances would be in place if there was a future problem with the Town wells due to this spill. Mr. Tablada stated that the responsible party is never “off the hook” and a case can be reopened at any time, adding that MDE should consider a long-term sentinel well program and wellhead protections related to the Town wells.
Mr. Tablada stated that when MDE uses the term “close the case” it means no further action is required as far as remediation activity, but there was always a year or more of monitoring, sometimes as many as 5 years.
Ms. Gross stated that Mr. Ralston indicated that the Hospital would receive notice to shut down the pump and treat system when the time came and asked if the Town would also be made aware of that approval. Mr. Tablada stated that the Town would be copied on that letter.
Mr. Ralston stated that this plan would be implemented and then MDE would wait and see through monitoring if it “hit the mark” or not. If it did not, the system would be turned back on and another form of remediation would be evaluated.
Ms. Kuiper asked who would be responsible for remediation if the property changed hands. Mr. Ralston stated that the responsibility in a case such as the one in Chestertown would remain with the Hospital. Mr. Tablada explained that under the Super Fund Law, a new owner would become responsible for a hazardous waste site by acquiring the property, but under petroleum laws, the party that discharged the oil was responsible regardless of change in ownership.
Ms. Kuiper stated that Mr. Ralston stated that there was “very little or no detection past Brown Street” and asked what that meant. Mr. Ralston stated that south of Brown Street there were detections of dissolved phase petroleum. In monitoring well #20 there were detections of free phase product (oil on top of the water). So, there were detects south of Brown Street, but the majority of the detections in the wells south of Brown Street in the last 2 to 2½ years have been no or low detect levels of dissolved phase concentrations.
Ms. Kuiper asked if the State of Maryland has used IveySol© in any other cleanup efforts. Mr. Ralston stated that IveySol© has not specifically been used, but other surfactants have been used. He said surfactants perform similarly but he did not know the exact formulations.
Ms. Kuiper asked how MDE relied on the Hospital to come up with a plan, noting that she thought MDE would set the rules for the cleanup. Mr. Ralston stated that MDE sets goals for what had to be done for cleanup but it was up to the responsible party to propose a work plan to MDE. Mr. Tablada stated that typically plans are submitted and MDE’s concerns are addressed through modifications of the plans.
Mr. Stetson asked why the earth around the spill was not removed when it was discovered. Mr. Ralston stated that the school of thought on remediation over the last 25 years has changed and most UST removals are now directing the responsible party to excavate and contain a spill when possible, but that was only after the full scope of the problem was taken into consideration. He said in this case, excavation was not chosen as the best way to handle remediation.
Mr. Shoge asked if the pump and treat was the only thing that the Hospital has been doing to date or have any other techniques been implemented. Mr. Ralston stated that the pump and treat was the primary mechanism of remediation but there has been some hand-baling and wicking to pull the oil out of the different wells. He said that sometime between 2010 and 2012, a former consultant did some pilot tests with CO₂ and oxygen infusions but due to high iron content the process of adding oxygen caused the well screens to clog.
Mr. Shoge asked how the monitoring well sites were chosen. Mr. Ralston stated that MDE directed wells to be installed over time beginning in 1989 and there were different reasons for different locations of wells. He said that the initial wells were installed to try to determine how far out product had been released and then they extended out in a coarser pattern in an effort to refine the area. In 2007 there were some wells added for site characterization and to better understand the soils (2” wells).
Mr. Shoge asked about the consultants used at the Hospital. Mr. Ralston stated that responsible parties will typically hire an environmental consultant (or several) to aid in management of cleanup. The consultants would come up with a work plan that was sent to MDE for review and approval. Mr. Ralston stated that there have been transitions along the way with consultants at the Hospital but that was normal over time.
Ms. Gross said that when the pumps are eventually turned off is there was a way to predict where the oil would go as the cone of depression would also disappear. Mr. Ralston stated that the pump and treat system would not be authorized to be turned off until all the IveySol© has been extracted, which would be some time as all lab test results had to come in and be reviewed. He said it does not take long for the cone of depression to reform (hours to days) if the pumps had to be turned back on. There would also be sampling of all wells during that period.
Mr. Sipes stated that he was doing research and the site stopped producing oil in 1998. Over a 3 year period there was something in the neighborhood of 1,500 to 2,000 gallons. The wells were rehabbed and pumps were replaced at that time and the Hospital went back to recovering 1,000 gallons of oil each month. He asked if this was ever tried a second time. Mr. Ralston stated that it has not been tried recently. Mr. Sipes stated that he thought it was significant that after wells were rehabbed and the pumps were replaced the recovery numbers rose drastically.
Mr. Sipes stated that he understood the complexity of the site and that MDE shared the goals of protecting the Town’s water. He said that he had issues with transparency which MDE was well aware of. He said that the Town sent a letter in May and did not receive an answer until July 9th, and that response did not answer the questions that were raised in the May letter. Mr. Tablada stated that he held the letter back because he wanted to meet with the Mayor to see if there would be changes.
Mr. Sipes asked if part of the case closure required monitoring although no recovery was taking place. He said that if the pump and treat system was turned off monitoring should still be required. Mr. Ralston stated that there would be monitoring of the site after the pump was turned off and that he had explained that earlier in the evening.
Mr. Sipes stated that when the pump and treat system was installed it was for a two-fold purpose. It was for oil recovery and to keep the contamination from moving offsite. He said that it has been stated that it was not a long-term solution but it was his opinion that it has been a working long-term solution for 25 years as contamination has not moved offsite. Mr. Sipes stated that he did not understand the urgency to move this matter along now. Mr. Sipes stated that the Hospital merged with University of Maryland in 2008 and the process of trying to close this site began almost immediately. The merger took place in 2008 and in 2009 there was a well dug to perform CO₂ and Oxygen injections. He said that the primary purpose of the pump and treat at this point should be to keep a “curtain” on the contamination so it did not move offsite.
Mr. Sipes stated that the IveySol© worked similarly to Dawn© soap, in that if a drop is put in the sink, it emulsifies what is there and removes it from dishes. He said that the same thing was being done to the soil, but when it was done to the well the area of influence confused him. He said that the Hospital wanted to put 300 gallons of IveySol© into the ground through a well screen that was 25 to 30 feet long. If 300 gallons was equal to six (6) 50-gallon drums and if they were stacked one on top of the other it was less than 20 feet high. He said that the Town was being told that the drums would spread out 25 feet in all directions but the actual area of those 300 gallons does not extend out of the wells more than 2 feet. He said taking the porosity of the soil into consideration, it would not be more than 3 feet. Mr. Sipes stated that adding water into the soil would take up more volume but the IveySol© was said to clean a 25 foot radius.
Mr. Sipes stated that the fact that the oil becomes mobile once the surfactant is added and it can be removed from the 3 foot area makes him think that this is not really site clean-up but a well clean- up. The soil around the wells is going to be clean from injection and extraction events and there won’t be oil in the monitoring wells before the soils get saturated again. The soils were going to act like a sponge and reabsorb contamination as it enters and not make it to the well to be extracted for a year, at which time MDE is out of it and the case is closed out.
Mr. Sipes stated he was concerned over the IveySol© injection in the pilot study and it was modified to lessen the Town’s concerns, but what was being discussed now was a large scale project. Mr. Sipes stated that the red dots that were shown on the map took up about 15 feet, not 3. The entire site was not going to be cleaned in this fashion only the monitoring wells.
Mr. Sipes stated that on a large scale injection and extraction of surfactant, the controls in place work for oil, but questioned if they worked for emulsified oil. He said that oil moves slowly on the ground and generally floats on top of water, but adding IveySol© changes the characteristics and it no longer floats and it does move.
Mr. Sipes stated that controlling a plume is one thing, but controlling the product once it is dissolved and free to move is a different thing. He was not confident that there was not a large level of risk associated with this plan and he was not comfortable that the oil wouldn’t become mobile and make it off site. Mr. Sipes stated that the oil did not have to move downstream or down gradient because mounding occurs when injection takes place, which not only pushes down but out. He said the contours of the site as they were shown do not mean that everything moves in one direction and if something crosses past Well #34, it can’t be pulled back on site.
Mr. Sipes stated that he thought the pump and treat acted as a curtain but it did not mean that it was 100% effective because there were detects that went away. He said those detects did not evaporate; they moved out of the wells. He said if there was detects in Well #4½ in April and it was gone in May, the contamination did not disappear, it moved. He said that the same thing is true with sheen when it shows on the surface of a monitoring well one month but it is not there the next, it did not evaporate, it moved.
Mr. Sipes stated that as far as the product not being mobile, after 3 to 5 years it may be less mobile but it was still mobile. When the system was shut down in 2012, there were detects of measurable product in monitoring wells #14 and #47. There was sheen film in 9 of the monitoring wells and all of the recovery wells. He said that liquid product did not facilitate starting the system back up and asked what levels of contamination MDE was comfortable with, but if it is the Town’s drinking water it should be zero.
Mr. Sipes stated that he did not know what the ground water clean-up standards are, other than what is supplied to the Town in quarterly monitoring reports from the Hospital, but they did not correlate. He said that when the shutdown was approved there were detects in most of the wells of a sheen or some type of product and the system was shutdown anyway. Mr. Sipes stated that measurable DRO in lab tests would shut down a public drinking water well and he could not understand why it would be acceptable for any contamination to remain.
Mr. Sipes stated that the path of the oil was not generally towards the water plant, it was directly towards the water plant. Groundwater does not move as a unit or sheet flow. There were preferential flow channels and the amount of time it would take to travel is unknown because it is not moving as a unit.
Mr. Sipes stated that in 1998 when monitoring wells were added, it increased the movement of the product and recovery up to 1,000 gallons per month. He said that nobody thought product was there at that time and nobody seems to know for sure how much product is in the ground now, although estimates ranging from 5,000 gallons at the time of the original spill, to 100,000 gallons now. He said that the EPA has a paper called “Behavior of Hydro Carbons in the Sub Surface” that says with a pump and treat system 50% of product is recovered. He said it was possible that there was still 80,000 gallons of oil still in the ground.
Mr. Sipes stated that the well network provided a picture of what was in the ground but it was incomplete. He said that there were borings in the ground and an assumption was made that what was uncovered at one well stayed linear. He said if it worked that way, a detection in a monitoring well this month moving at half a foot a day should show up in the well downstream the next month, but the water is not behaving like that and it is not that predictable. Mr. Sipes stated that was the reason he asked for a site characterization model.
Mr. Sipes stated that even if he was only half right and there was only 40,000 gallons of oil in the ground, much of that would be absorbed on the soils and may never move. He said that there are pockets of contamination on this site that have not been hit with wells. Mr. Sipes stated that when the system was shut down and the Hospital thought that there was nothing to recover, 4 inches of free oil came into a monitoring well through the groundwater.
Mr. Sipes stated that he was not comfortable with the plan as proposed. Mayor Cerino asked what would lessen Mr. Sipes discomfort besides continuing for another 50 years with the pump and treat system. Mr. Sipes stated that he was already told by MDE that the pump and treat would not continue to run for 50 years, but he also told MDE that if that is what is necessary to keep Chestertown’s water supply safe and clean than the Hospital will continue to run the pump and treat system for that long.
Mr. Sipes stated that what he would be comfortable with was a full site remediation: a plan that would clean the entire site. This proposed plan is not site clean-up, it is well clean-up. He said that the monitoring wells are not the only place there is product, it is just where they test for product. Areas around and between the wells have product in the ground. This remediation plan as proposed cleans the wells and increases the likelihood of good results for a year, which was almost what happened the last time that the pump and treat was shut down.
Mayor Cerino asked what site clean-up would take place if Mr. Sipes was able to design it. Mr. Sipes stated that according to the IveySol© website, the push/pull method is recommended for localized, small spills. Site clean-up involved horizontal drilling and weeping the product into the ground to clean the soil. This method has been effective for industrial clean-up sites. Mr. Sipes said that this was not an industrial site, but it showed much more potential for cleaning the entire area. With this site clean-up method the oil could be chased and captured. Mr. Sipes stated that he was not interested in short-term success; he was concerned with long-term success and complete removal of contamination from the site.
Mr. Sipes stated that the formulas used to figure the area of liquid do not match the 25 foot radius shown on the map. He said that 300 gallons of IveySol© could not clean the 25 foot radius.
Mayor Cerino stated that if Mr. Sipes was not comfortable with the plan, than he was not comfortable with it either. He said that if IveySol© was the “silver bullet” the Hospital and MDE thought that it was, then a bond should be put in place to completely replace Chestertown’s wells as well as required infrastructure to pump that new water source to all the properties in Town should this fail. He said that someone had to take responsibility for this problem as it was not caused by the Town.
Mr. Sipes stated that it was important for everyone to remember that this site was a quarter mile from a water plant and there needs to be a large level of concern and protection for Chestertown’s natural resource. He said when there is discussion of compromising this aquifer, which has been in use for 100 years, whether intentional or not makes no difference. Once the resource is gone you can’t get it back and it needs to be protected by all parties. Wells cannot be re-drilled on site and it was a large expense to relocate the water plant and the water capacity would have to be replaced. He said that there were 2 wells on the Magothy aquifer now and they influence one another, which limited capacity.
Mr. Sipes asked if the Mycelex filter can treat the product with IveySol© in it as the hydraulic compounds will be separated. Mr. Ralston stated that MDE did investigate that the existing system could treat from a water quality and water quantity standpoint and the consultants from the Hospital verified with their engineers that the Mycelex filters would deal with the additional flow through volume of what is expected to be extracted. He said that they were adding filter products from Mycelex to better insure that there will be no problems.
Mayor Cerino asked MDE to comment on the issues that Mr. Sipes addressed. Mr. Ralston stated that Mr. Sipes was not incorrect and most of the impact would be close to the wells, which was why so many wells were targeted. Mayor Cerino stated that there were considerable areas where wells did not overlap. Mr. Tablada stated that the project would be carried out in phases, incrementally as they move and collect data, beginning with the hottest wells. He said by increasing the activity the product will be disbursed so it would move and could be captured.
Mayor Cerino asked what would happen if product escaped and was detected at the line of last defense. Mr. Sipes stated that there was a point where you could not turn back if product escaped, which was Well #34. Mr. Ralston stated that there was always opportunity to install additional recovery wells and if during the course of the project something happened mobile pumps that could be placed in monitoring wells down gradient.
Mr. Grace stated that each injection point would be dealt with separately because each well was different. Water finds the path of least resistance so the sphere of influence was unknown. He said that oil would be left in the ground, but the key question is will that oil move. Mr. Grace said that IveySol© mobilizes the oil but there has not been much discussion about the recovery out of those same wells, which was 3 to 5 times the amount that was put in. The vast majority of the IveySol© and the liberated oil will be recovered during the extraction period. However, the injection is only taking place in the areas MDE believed would be controlled by the recovery system. Mr. Grace stated that any product removed from the site would enhance biodegradation. Water will be moving and there will be small amounts of product breaking down at the same rate it is moving and at the same time monitoring will be taking place.
Mr. Ralston stated that MDE did not want to see any product moving past Campus Avenue or crossing Brown Street as the goal was to not even come close to the intake of the municipal wells.
Mr. Sipes stated that MDE referred to 3 to 5 years of recovery with the pump and treat system, but that was with static conditions. He said when hydraulic conditions on site are changed, the 3 to 5 years begins again. Mr. Ralston disagreed. Mr. Sipes stated that he believes this to be true because the Hospital shut down the system and the oil moved. Mr. Ralston stated that oil was entering into wells within the established footprint and that it was only locally mobile.
Mr. Sipes stated that the proposed plan did not call for monitoring of GROs (Gasoline Range Organics) even though they have been detected on site. Mr. Ralston stated that GROs are lighter hydrocarbons that are consistent with the VOCs being analyzed. There were 40 to 50 VOC contaminants that are run in a sample. The GRO was one number that gave a gross range of contamination and said that MDE was more interested in the individual compounds in the volatile range. The GRO did not give as much information at this site because they were dealing with heating oil which fell in the Diesel Range Organic analysis.
Mr. Sipes asked if there would be testing for individual constituents of the GRO. Mr. Ralston stated that VOCs generally fall within the GRO detection and will be monitored quarterly.
Mr. David Sobers was in the audience and asked if the State would be willing to have the Town as a signatory to a Consent Agreement. He also asked why no geophysical monitoring was applied to this site as spontaneous polarization had been used for this type of problem in the past. Mr. Tablada stated that there was not a legal mechanism in place at this time, but a consent order can be created and it has been discussed with the Hospital and the Town. Mr. Ralston stated that he was not familiar with the geophysical question raised but there were geophysical techniques that can be used to find liquid phase hydrocarbons in the subsurface, but at this point in time, MDE was comfortable with the level of site assessment that has occurred and did not see the need for anything additional.
Ms. Alice Macnow said that she has not seen an end goal or final objective to reopen Well #8 and asked if that had been given any consideration. Mr. Tablada stated that MDE recommended to close Well #8 and the Town would have to consult with MDE’s Water Supply division to see when the proper time would be to restart the well, noting that it should be done incrementally. He said a sentinel well system should be implemented before that time, along with monitoring to be sure that nothing has resurfaced for a 1 to 5 year period. Mr. Sipes stated that from his point of view the Town would probably never use that well again for anything other than monitoring for contamination.
Mr. Gibson Anthony asked if VOCs traveled differently than PHCs and would they react differently to the surfactant and/or travel differently. Mr. Ralston stated that PHCs travel by gravity and on initial release will sink and then slow down and continue to spread with groundwater flow direction. VOCs and TPHDRO move at the speed the groundwater is moving as they are in a dissolved phase, regardless of natural or pumping conditions. He said that there will not be a large change in flow to the VOCs but the surfactant will allow the residual oil to release from the soil and travel at the same speed as groundwater, which allows for more extraction with the use of surfactants.
Mr. Garrett Falcone stated that the initial presentation made sense but when Mr. Sipes spoke he did not hear anyone arguing his points. He said that MDE said that they used surfactant in other areas and asked what was currently happening at those sites. Mr. Ralston stated that surfactants generally do what has been described and allow residual oils to be collected hydraulically through pumping, achieving greater mass removal by using them. He said removing the mass might not be the end of the story and other treatments may be necessary or there could be a change to another form of remedial technology if there is an issue that remains to be resolved.
Mr. Tablada stated that Mr. Sipes was comfortable with the pilot study and the results of the pilot study. He said that this proposal was basically a blanket approval of multiple pilots, which will be the different phases of the project with the pump and treat system working at all times, based on Town’s concerns.
Mr. David Bowering stated that there was a bullet point in the presentation that the pump and treat was not a long-term solution and he asked why the Hospital did not have to provide a long-term solution given the criticality of the short-term solution. Mr. Ralston stated that the pump and treat was meant to recover bulk oil that was freely recoverable, with additional wells installed over time. He said that the pump and treat has run its course in recovering bulk oil and was now just pumping water. He said that the goal of MDE Oil Control Program was to clean the site and that is what the proposal was designed to do.
Mr. Kevin Shertz stated that the criterion for shutting off the pumps was going to be based upon no surfactants in the wells and said that given the certainty that nobody can say how much oil is in the ground or how far the IveySol© will spread out from the injection points, would anyone get sick if they drank the water from the site? Mr. Ralston stated that the minimum measure was to make sure that all the surfactant is removed before there is any discussion of turning the pump and treat system off. MDE will be reviewing the analytical data of organic compounds that will be collected. If there is a continued increase in numbers the pump and treat system may not be turned off, but run for another quarter or so to see if levels stabilize. The removal of surfactants was not the only measure for turning the system off.
Mr. Sipes asked if running the pump and treat system until surfactant was not detected would be based on surface tension tests or laboratory analyses. Mr. Ralston stated that it would be based on analytical data.
Mr. David Foster stated that he thought MDE got the gist that the residents were concerned about the risks that were being taken at the Hospital site. He said that the pump and treat system may not be the “silver bullet” but it has protected Chestertown well for over 25 years. He said that he listened to what was said at the meeting but could not figure out the advantage to the residents of Chestertown to having the pump and treat system turned off. He said that it may not be drawing oil but it is keeping the cone of depression and hydraulic controls in place insuring Chestertown that the drinking wells are protected and water is safe to drink.
Mr. Tablada stated that MDE did not want to run a barrier to the oil. MDE’s objective was to remove the petroleum from the ground. He said that MDE wanted to protect Chestertown’s water and the pump and treat will continue to operate during the IveySol© injection and extraction, and until lab results indicated that petroleum was not moving. Mr. Tablada stated that the Hospital’s proposal was to remove some of the residual petroleum that is on site and when that is removed they will reassess the site. Until that point, the pump and treat system will be turned on and everything will be monitored.
Mr. Tablada stated that Well #8 has been tested for petroleum and the spill has not reached it nor has it crossed into other wells down gradient and beyond the cone of depression.
Mr. Ralph Morgan stated that a higher comfort level for the citizens of Chestertown was required. He said that open areas were located between the wells and perhaps additional wells should be added between those points. He said there was no characterization to know what the plume looked like and thought that should be better determined.
Mr. Jim Gatto stated that the Town was looking at worst case scenario and asked if there was an exit plan if this did not work. He said that the Town had to be concerned with the safety of their drinking water not the time that the State wanted to spend dealing with the spill. Mr. Tablada stated that MDE was not finished with their work until each person was satisfied that the work was done, but there had to be a plan to get to the point where the work was finished.
Mr. Gatto asked if the plume migrated towards the wells in a rapid fashion, what would MDE do to stop it. Mr. Tablada stated that was an original concern with the pilot test but the oil did not break lose. He said that this procedure, although larger in scope, would be performed as “mini” pilot tests to many of the wells, so oil running quickly anywhere was not going to happen.
Mr. Sipes stated that worst case scenario was that one of the wells was in a preferential flow pattern where IveySol© would be injected and that it would move from the site, although it was not probable. Mr. Ralston agreed, stating that they know the groundwater flow at this site and had control of the hydraulic system. If there was an indication in a down gradient well there were mobile pumps that could be used on those wells while sorting out next steps.
Ms. Margaret Lynch asked how the IveySol© would affect homes closest to the Hospital. Mr. Tablada stated that there would be no effect on the houses closest to the Hospital. The drinking water supplied by the Town was good water and this work was well below any basements in the area. Mr. Ralston stated that there was no indication that the IveySol© would get past the pump and treat system and there would be no impact to any houses by way of vapor.
Mr. Ralston stated that the next step for MDE would be to discuss anything new that is relevant to get an approval letter to the Hospital, along with possible follow-up conversation with Mayor Cerino or Mr. Sipes and the Hospital. Once the plan is approved, Mr. Dane Bauer, consultant for the Hospital, would determine how fast that the Hospital could move into the field.
Mayor Cerino stated that he would be happy to meet with MDE at any time, but he wanted to make sure that Mr. Sipes was there with him. Mr. Tablada stated that it was unfortunate the Mr. Sipes did not make the initial meeting. Mr. Sipes stated that the last meeting he was out of State for the first time in years on vacation.
Mr. Michael Forlini asked if a Consent Order would be considered early on or during the next stage. Mr. Tablada stated that he would have to direct that question to his legal staff who would contact Mr. Forlini, noting that the approval letter will go out as Mr. Ralston described whereas it took some time to prepare a Consent Order.
Mayor Cerino thanked everyone in attendance and especially the representatives from MDE for presenting the information to the residents. Mayor Cerino closed the meeting at 8:30 p.m.
Submitted by: Approved by:
Jennifer Mulligan Chris Cerino
Town Clerk Mayor