Whirlpool Corp. submitted information Tuesday (May 20) to the Arkansas Department of Environmental Quality outlining further chemical treatments as part of its remediation plan for the trichloroethylene (TCE) plume in south Fort Smith.
As reported earlier in May, ENVIRON — the environmental consulting group hired by Whirlpool to address the contamination issues — had identified "an area of highly impacted soils to as deep as 25' – 30' have been located at the northwest corner of the Whirlpool building … " and also believed "a large quantity of contaminant mass (is) moving to the South."
The new findings indicate that Whirlpool knew TCE contamination was worse than previously stated and a different set of action would be necessary to treat the contamination site — including possible removal of contaminated soils
In a telephone call with ADEQ in April, Project Manager Mike Ellis of ENVIRON told the agency removal of the soil was the best method to deal with contamination, going on to say that the process would require boring into the ground with the focus shifting from chemical oxidation treatments approved in the company's remediation plan to "source removal."
But in a letter from Ellis to the ADEQ dated Tuesday, ENVIRON's project manager lays out a very specific plan for chemical oxidation treatments, the second such treatment since work began on the company's remediation plan in December, though the first chemical oxidation treatment did not take place until March of this year.
Ellis said the second treatment would take place May 27 at the site of the shuttered Whirlpool plant, mentioning nothing specific about possible soil removal, only vaguely referring to recent discussions with the agency.
"A part of the adaptive remedy approach, the plan for this second injection event incorporates information obtained during the first ISCO injection event in March of 2014, as well as the bench scale and tracer testing completed earlier this year. This round of ISCO treatment will be completed along with other additional actions to address concentrations of TCE discovered in a specific area of soil on the Whirlpool property, as discussed during recent weeks with ADEQ."
The letter states that injections will take place at the four different sites, with more than 27,000 gallons of a variety of chemicals — sodium persulfate (BASP) and Modified Fenton's reagent (hydrogen peroxide and chelated iron) activated sodium persulfate (MASP) — injected into the pollution plume.
The area where the increased levels of TCE were found, known as Area 1, will receive special attention in the next round of chemical oxidation treatments, Ellis said.
"Approximately 3,000 gallons of oxidant will be injected into ten temporary points within Area 1," he wrote. "It should be noted that discussions regarding additional remedial effort in Area 1 will be submitted under separate cover to ADEQ by May 27, 2014."
It was in that area where Ellis previously told the ADEQ contamination was worse than previously disclosed, leading to a memo in which the ADEQ said: "MIP data is presented in real time. Whirlpool certainly knew that this area was impacted prior to submitting the final Remedial Plan at the end of February."
Asked to comment Wednesday (May 21) about the document showing Whirlpool would be moving forward with chemical oxidation treatments, ADEQ's Public Outreach and Assistance Division Chief Katherine Benenati said the document was "only (a) change to the work plan that has been submitted to us."
Should Whirlpool move to change direction and officially propose methods such as soil removal as a treatment option, amendments to the Remedial Action Decision Document (RADD) approved in February would have to be submitted.
"There have been no approved amendments to the RADD as of this date," she said. "If there are actual amendments to the RADD we will hold a 30-day public comment period."
Even though the April memo from ADEQ alleged that Whirlpool and ENVIRON knew the contamination was worse than previously stated, Benenati said the agency had "no knowledge at this time that Whirlpool knew in advance of the remediation plan of this area of contamination."
Link here for a PDF of the May 20 letter from Environ to the ADEQ.