EPA CONTRACT NO. 68-W9-0036 EPA Project Officer: Nancy ...

101
J.7,t SDMS DocID 459000 EPA CONTRACT NO. 68-W9-0036 EPA WORK ASSIGNMENT NO 10-1L19 EPA Project Officer: Nancy Barmakian EPA Remedial Project Msinager: Christian Rascher FINAL WORK PLAN FOR SUPPLEMENTAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY PINE STREET CANAL SITE BURLINGTON, VERMONT AUGUST 1990 Prepared by METCALF & EDDY, INC. M&E Project Manager: Martha L. Zirbel

Transcript of EPA CONTRACT NO. 68-W9-0036 EPA Project Officer: Nancy ...

J .7 , t

SDMS DocID 4 5 9 0 0 0

EPA CONTRACT NO. 68-W9-0036

EPA WORK ASSIGNMENT NO 10-1L19

EPA Project Officer: Nancy Barmakian

EPA Remedial Project Msinager: Christian Rascher

FINAL WORK PLAN

FOR

SUPPLEMENTAL

REMEDIAL INVESTIGATION/FEASIBILITY STUDY

PINE STREET CANAL SITE

BURLINGTON, VERMONT

AUGUST 1990

Prepared by

METCALF & EDDY, INC.

M&E Project Manager: Martha L. Zirbel

IP TABLE OF CONTENTS

1.0 SITE SUMMARY 1-1

•" 2.0 OBJECTIVES/DQOs 2-1

3.0 TECHNICAL APPROACH 3-1

3.1 PROJECT PLANNING (TASK 1) 3-1

3.1.1 Kick-off Meeting 3-2 • 3.1.2 Work Plan 3-2

3.1.3 Field Analysis for Total Coal Tar 3-2 3.1.4 Laboratory Analysis of Fuel Oil Components

m versus Coal Tar Derived PAHs 3-3 3.1.5 Laboratory Analysis of Total, Individual,

and Carcinogenic PAHs 3-3 3.1.6 SAS Client Request Forms 3-3 3.1.7 Investigation Waste Minimization Plan 3-4 3.1.8 Remedial Investigation and Risk Assessment

Reports by PEER Consultants 3-4 • 3.1.9 Site Investigation Reports by the PRPs 3-5

3.1.10 Resampling of Wells for Groundwater Analysis 3-5 3.1.11 Quality Assurance Project Plan 3-5

^ 3.1.12 Field Sampling Plan 3-5 3.1.13 Health and Safety Plan 3-5 3.1.14 Sampling "Endpoint" Criteria 3-6 3.1.15 Analytical Data Generated by PEER Consultants 3-6

- 3.1.16 Hydrogeologic Review 3-6

3.2 COMMUNITY RELATIONS (TASK 2) 3-7

3.3 FIELD ACTIVITIES (TASK 3) 3-7

3.3.1 Description of Analytical Requirements 3-7 •• 3.3.2 Field Mobilization 3-9

3.3.3 Soil Boring/Sampling at the Coal Gasification Plant Area 3-13

• 3.3.4 Soil Boring/Sampling of the Tank Farm and Burlington Street Department Areas 3-17

3.3.5 Soil Boring/Sampling of the Perimeter Areas 3-18 _ 3.3.6 Surface Sediment Sampling in Lake Champlain 3-20

3.3-7 Monitoring Well/Sampling at the Pine Street Canal Site 3-22

3.3.8 Groundwater Resampling of Existing Wells 3-25 • 3.3.9 Resampling Locations 3-25

3.3.10 Investigation Waste Disposal 3-27 3.3.11 Contingency Plan 3-27

p 3.3.12 Surveying 3-27 3.3.13 Hydrogeologic Assessment 3-28

il

TABLE OF CONTENTS (Continued)

3.4 SAMPLE ANALYSIS/VALIDATION (TASK 4) 3-31

3.5 DATA EVALUATION (TASK 5) 3-32

3.5.1 Data Reduction and Evaluation 3-32

3.5.2 Evaluation of Previous Data 3-34

3.5.3 Data Reporting 3-34

3.6 RISK ASSESSMENT REVISION (TASK 6) 3-34

3.6.1 Public Health Baseline Assessment 3-35

3.6.2 Ecological Baseline Assessment 3-38

3.7 TREATABILITY STUDY/PILOT TESTING (TASK 7) 3-40

3.8 REMEDIAL INVESTIGATION REPORTS (TASK 8) 3-40

3.9 REMEDIAL ALTERNATIVES SCREENING (TASK 9) 3-41

3.9.1 Development of Remedial Action Objectives 3-42

3.9.2 Development of General Response Actions 3-43 3.9.3 Performance of Institutional Screening 3-44 3.9.4 Estimation of Volumes or Areas of Media Which

Might Require General Response Actions 3-45 3.9.5 Identification and Screening of Applicable

Remedial Technologies 3-46 3.9.6 Evaluation of Process Options 3-48 3.9.7 Development of Remedial Alternatives 3-49 3.9.8 Screening of Remedial Alternatives 3-50 3.9.9 Preparing a Technical Memorandum 3-53

3.10 REMEDIAL ALTERNATIVES EVALUATION (TASK 10) 3-53 3.10.1 Detailed Technical Evaluation 3-54 3.10.2 Detailed Public Health Evaluation 3-55 3.10.3 Detailed Environmental Evaluation 3-56 3.10.4 Detailed Institutional Requirements Evaluation 3-56 3.10.5 Detailed Cost Evaluation 3-57 3.10.6 Preparing a Technical Memorandum 3-58

3.11 FEASIBILITY STUDY REPORTS (TASK 11) 3-58

3.12 POST RI/FS SUPPORT (TASK 12) 3-58

3.12.1 Support Preparation of the ROD 3-59

3.12.2 Preparing a Responsiveness Summary 3-59 3.12.3 Publishing Public Notices 3-59 3.12.4 Other Tasks as Required 3-59

11

TABLE OF CONTENTS (Continued)

3.13 ENFORCEMENT SUPPORT (TASK 13) 3-60

3.14 MISCELLANEOUS SUPPORT (TASK 14) 3-60

3.15 EXPEDITED RESPONSE ACTIONS (ERA) PLANNING (TASK 15) 3-60

3.16 ADMINISTRATIVE RECORD (TASK 16) 3-61

4.0 DOCUMENT PRODUCTION AND DISTRIBUTION 4-1

5.0 WORK SCHEDULE 5-1

6.0 STAFFING AND ESTIMATED LABOR 6-1

7.0 CASH FLOW SCHEDULE 7-1

8.0 SUBCONTRACTING PLAN 8-1

9.0 FIELD EQUIPMENT 9-1

10.0 REFERENCES 10-1

111

TABLES

Table 1-1.

Table 1-2,

Table 1-3.

Table 3-1.

Table 3-2.

Table 3-3.

Table 3-4.

Table 6-1.

Figure 1-1.

Figure 1-2.

Figure 1-3.

Figure 1-4.

Figure 1-5.

Figure 1-6,

Figure 1-7.

Figure 3-1.

Figure 3-2.

Figure 3-3.

Figure 3-4.

Figure 3-5.

Figure 3-6.

Figure 5-1.

Figure 5-2.

Figure 7-1.

Owners and Land Uses at Pine Street Canal Site 1-6

Boring Information 1-15

Monitoring Well Information 1-16

Soil/Sediment Analysis Summary 3-10

Water Analysis Summary 3-11

Summary of Proposed SoilBorings and Monitoring Well Installation Specifications 3-16

Preliminary Remedial Technologies 3-47

Estimated Labor, Pine Street Canal Site RI/FS 6-2

FIGURES

Pine Street Canal Site, Burlington, Vermont 1-2

Pine Street Canal Site Location Map 1-3

Pine Street Canal Site Topographical Map 1-4

Pine Street Canal Site Current Property Divisions 1-5

Southern Connector Approximate Alignment 1-10

Surface Water Sampling Locations 1-13

On-site Monitoring Well Locations 1-14

Proposed Soil Boring and Well Locations for Coal

Gasification Plant Area 3-15

Proposed Soil Boring Locations for Tank Farm and Burlington Street Department Areas 3-19

Proposed Soil Boring and Well Locations in Perimeter

Areas 3-21

Proposed Sediment Sampling Locations 3-23

Proposed Existing Well Resampling Locations 3-26

Remedial Alternatives Screening Criteria 3-51

Overall Work Schedule 5-2

Field Schedule 5-3

Cash Flow Schedule 7-2

IV

10

SECTION ONE

SITE SUMMARY

mi

The Pine Street Canal Superfund site is located on the eastern shore of Lake

Champlain in Burlington, Vermont. The site occupies approximately 80 acres

•• and is situated in an industrial area located approximately one-half mile

south of the center of Burlington (Figure 1-1). The site includes an

ai abandoned barge canal, a turning basin, an adjacent filled wetlands, and a

topographically low area south of the basin and east of the canal

(Figure 1-2). A topographic map is found in Figure 1-3. A detailed

description of the site, the site history, and the environmental setting can

be found in the Draft Remedial Inves t i ga t i on Report for Pine S t r e e t Canal

•• S i t e , Burl ington, Vermont (PEER, May 1990).

m The primary environmental concern posed by the site is the past operation of a

coal gasification plant near the southern end of the canal. Coal tar residues

from this plant were allegedly disposed of on the site and have been detected

in the groundwater, the canal sediments, and the soils throughout the site.

In November 1981, the site was placed on the national priorities list (NPL)

% ^ with a score of 34.64.

•» POTENTIALLY RESPONSIBLE PARTIES

A total of 17 potentially responsible parties (PRPs) have been named by the

U.S. Environmental Protection Agency (EPA). They include the site property

owners, the City of Burlington, present and former facility owners, and the

Vermont Railway.

• CURRENT SITE USE

• The current property divisions of the Pine Street Canal site are shown in

Figure 1-4. The corresponding property owners and land uses are listed in

m Table 1-1.

1-1

\ ^ ^

SOURCE: PEER CONSULTANTS. MAY 1990

nCURE 1-1. PINE STREET CANAL SITE, BURLINGTON VERMONT

M E T C A L r a c o o V

i I I i I ! i 2 S I 8 5 5 8 8 § § § § § S S § § § § § § S § S § § S MLMMMtmcrr m -3>00 I I I I I I I I I I I I I I I I

SCALE (FEET) D 100 300 300 400 fTWCTO0T, ex, njLhL^ g

IZZi LAKE CHAMPLAIN

LOcusTSTivrr

tr.XHNSaURT TMJCNNQ

SOURCE: PEER CONSULTANTS. MAY 1990

4 * 0 0

-1+00

O-fOO

1+00

2+00

3+00

4+00

S+00

• +00

7+00

a+00

t+00

10+00

11+00

12+00

13+00

14+00

15+00

K+00

17+00

1«+00

19+00

20+00

21+00

22+00

23+00

24+00

23+00

20+00

27+00

20+00

29+00

30+00

31+00

nCURE 1-2. PINE STREET CANAL SITE LOCATION MAP

I n c A L F » f OD V

ff •

SOURCE: PEER CONSULTANTS. MAY 1990

FIGURE 1-3. PINE STREET CANAL SITE TOPOGRAPHIC MAP

I I I B i ! l § 8 § s § § § 8 § § 1§ § § § § § § § § § § § § § § § § mjaum mcET

#

SCALE (FEET) i n LOT339 100 200 300 400 a : I

nacn »im»TotPT.

^ ^ LOT345

i LOT377 ^ MAraUaTWET

LAKE CHAMPLAIN

AREA 12-92

AREA 12-83

AREA 12-68 HOWAflO STREET

AREA 12-70­

LOT 501 -

Loc ta r S7TCET

LAKE SlOe AVE

-3+00

•2+00

•1+00

0+00

1+00

2+00

3+00

4+00

3+00

«+00

7+00

(+00

•+00

10+00

11+00

12+00

13+00

14+00

15+00

16+00

17+00

ia+oo

19+00

20+00

21+00

22+00

23+00

24+00

25+00

26+00

27+00

26+00

29+00

30+00

31+00

SOURCE: PEER CONSULTANTS. MAY 1990

FIGURE 1-4. PINE STREET CANAL SITE CURRENT PROPERTY DIVISIONS

lETCAL, « e o o r

TABLE 1-1 OWNERS AND LAND USES AT PINE STREET CANAL SITE

(PEER CONSULTANTS, MAY 1990)

Lot/Area Nunber

Lot 339

Lot 345

Lot 377

Lot 405

Lot 431

Lot 453

Area 12-69

Area 12-80

Owner

City of Burlington

City of Burlington

Citizens Oil Co.

Louis Farrell

Maltex Partnership

Pine Street Association

Pine Street Association

Maltex Partnership

Land Use

Burlington Street Dept. Offices and work storage areas.

Former fuel storage area. Tanks not used but still in place. Berms around tanks.

Active business.

Former PEPSI Bottling Co. Variously used for storage or retail business.

Office building used by several small businesses, health club and restaurant.

Empty field, no buildings, mostly tall grasses, some trees.

Same as Lot 453.

Location of former coal gasification plant; no buildings currently on site.

I ETC A LF a E O O V

TABLE 1-1 (CONT.) OWNERS AND LAND USES AT PINE STREET CANAL SITE

(PEER CONSULTANTS, MAY 1990)

Lot/Area Nvunber Owner Land Use

Lot 501 VT Gas Systems Gas transmission substation, fenced.

Lot 585 City of Burlington Burlington Electric Department offices.

Lot 609 City of Burlington Burlington Electric

Lot 645 St. Johnsbury

Department parking and work building. St. Johnsbury

Trucking operates a trucking terminal on the south half of the lot. The north half of the lot is densely covered by construction rubble and trees. A drainage area that connects to the canal is in the northwest comer of the lot.

Area 12-73 and Area 12-71

State of Vermont Lots purchased by VT AOT in anticipation of highway construction. Currently wooded fields bordering canal. Maltex Pond and southern barge slip are located in these areas.

• ETC AUF » t O O Y

TABLE 1-1 (CONT.) OWNERS AND LAND USES AT PINE STREET CANAL SITE

Lot/Area Nunber

Area 12-79 and Area 12-81

Area 12-82 and Lot 128

Area 12-92

Area 12-83

Area 12-68 and Area 12-70

Unmarked lot on southwest corner of site

(PEER CONSULTANTS, MAY 1990)

Owner

Blodgett Co.

General Electric Company

VT Railway

Davis Development

BCV Associates

Blodgett Co.

Land Use

Termination of canal and wetlands area.

Active business.

Empty area between canal and train embankment.

Swampy area usually flooded by canal.

Swampy area usually flooded by canal, wetlands.

Active business

• ETCALF a E DO Y

The State of Vermont Agency of Transportation (VTAOT) has proposed plans to

construct the Interstate highway 1-189 Southern Connector (Champlain Park Way)

in the vicinity of the site. The original alignment was proposed through the

center of the site (VTAOT, April, 1990). The most recent plan (VTAOT,

April 1990) routes the highway detour over the eastern part of the site

(Figure 1-5). The VTAOT is required to start the construction process by

September 30, 1991, the end of the federal fiscal year 1991.

SITE GEOLOGY/HYDROGEOLOGY

The geology of the Pine Street Canal site consists of glacial and post-glacial

sediments overlying the Lower Cambrian-aged Monkton Quartzite (Doll, 1961).

The depth to bedrock varied from 68 to 170 feet in four monitoring wells

installed by PEER Consultants (PEER, May 1990) and suggests that a bedrock

valley or channel exists across the site oriented in a northwest-southeast

direction.

Unconsolidated sediments at the Pine Street Canal site consists of the

following (Doll, 1961):

Gravel/glacial till - Gravel clasts up to 1,5" diameter, generally in a clay or silty sand matrix.thick.

This unit is 1-2 feet

Lower silt/clay ­ Clayey silts to silty clays with clay content increasing with depth. Reaches a maximum thickness of 136 feet at the site

Sand ­ Thin sand unit observed to overlie the silt/clay in the northern portion of the site. The sand interpreted as fill, a submerged beach/localized channel deposit, or the southern edge of the Winooski Delta.

Peat ­ Large peat deposit appears to be a natural geologic formation which is nearly 100 percent organic. Peat is dark brown and fibrous and consists of decaying organic matter, small tree stumps, and branches. Peat reaches a maximum thickness of 12 feet at the site.

1-9

I I I I I ! I S § § 8 S § 8 8 § § OLautwtmtfT

# S S S S S S S S S S S S S S S S S I I I I I I I I I I I I 1.1 I I I

SCALE (FEET)

100 200 300 400

LAKE CHAMPLAIN

BASE MAP SOURCE: PEER CONSULTANTS. MAY 1990

FIGURE 1-5. SOUTHERN CONNECTOR DETOUR APPROXIMATE ALIGNMENT

M F T C A L F a F O O Y

Fill - Most of the site has been filled to some extent; fill (where present) extends down to the peat. Fill consists of three types of materials: clay/silt which resembles the lower clay/silt below the peat, sawdust or woodchips which resemble the peat, and a mixture of assorted debris including tires, bricks, gravel, pipes, and concrete (PEER, May 1990).

There are four water bearing zones present at the Pine Street Canal Site. The

zones are only semi-confined, and can presumably leak into those zones located

directly above or below. The full extent to which the water-bearing zones at

the site are interconnected has not yet fully been determined. Until that

determination has been made,, the hydrogeologic system at the site will be

treated as a single aquifer. The surficial zone consists of the peat unit and

overlying fill material. Stratigraphically below the surficial zone at the

southern half of the site is the lower silt/clay zone, while to the north a

sand unit exists between the surficial and lower silt/clay zones. Below the

lower silt/clay zone is the bedrock zone.

The water level in the surficial zone is three or four feet below the ground

surface at the site. The water level in this zone decreases toward the west; \ ^ ^ ^ this gradient indicates that flow in the surficial zone trends towards the

west, with potentiometric surfaces approximating the outline of Lake

Champlain.

The potentiometric surface of the lower silt/clay zone trends towards the

west-northwest and does not mirror the lake shoreline, indicating that the

lake has less of an immediate impact upon this zone than it does on the

surficial zone (PEER, 1990). Insufficient data is available at this time to

determine horizontal hydraulic gradients in the sand zone or the bedrock.

PAST INVESTIGATION RESULTS

Several PRPs and other entities have completed hazardous waste investigations

over all or parts of the site. These include:

1-11

EPA (PEER, 1988, 1990; Ecology and Environment, 1982a, 1982b; Versar, 1988a, 1988b)

VTAOT (Perkins-Jordan, 1982, 1983, 1984a, 1984b, 1986; Aquatec, 1989)

• Blodgett Oven Company (Aquatec, 1989)

Ultramar (ERM - Northeast, 1986)

General Electric (Wehran, 1989)

The preliminary draft remedial investigation/feasibility study (RI/FS)

conducted for the U.S. EPA by PEER Consultants (PEER, May 1990) included air,

surface water, sediment, surface and subsurface soils, and groundwater

sampling. Surface water sampling locations are shown in Figures 1-6 and soil

boring and monitoring well sampling locations are shown in Figure 1-7. Tables

1-2 and 1-3 list the borings and monitoring wells installed during the

RI/FS. A detailed description of the RI, including sampling and analysis

protocols and results are discussed in the Draft RI Report (PEER, May 1990).

The Draft PEER RI Report concluded:

"The major sources of both organic and inorganic contamination at the

Pine Street Canal Site are process residues from operation of the

manufactured coal gasification plant. Volatile organics (benzene,

toluene, ethylbenzene, xylenes), semivolatiles (mostly 2-6 ring PAHs),

inorganics (metals and cyanide) associated with process wastes from coal

gasification plant manufacture are found at various concentrations in

different media over most of the site.

The major area of subsurface soil and groundwater contamination covers

approximately 38 acres of the 80 acre site. Groundwater, surface water,

soils, sediment and air all exhibit some degree of contamination. The

contamination appears to have resulted from common, historical practices

of disposing of process wastes on-site and in the back-waters of the

wetlands and from day to day operations of the coal gasification

manufacturing plant (i.e., leaks, inefficient equipment, improper

maintenance)."

1-12

' l u^ i i i ^^F

8 S | 8 8 § | § g g s § § 8 8 § 8 IQLtUPm 9TFCET S S S S S S S S S S S S S S S S S

I I I I I I I I I I

SOURCE: PEER CONSULTANTS. MAY 1990

nCURE 1-6. SURFACE WATER SAMPLING LOCATIONS

M C T C A L F ft E OO Y

1 1 1 1 1 1 1 8 8 8 8 8 8 8 8 8 8 raiBUdN STKET S S S S S S S S S S S S S S S S S

d i I I I I I Im SCALE (FEET)

100 200 300 400

• MONITORING WELLS (INSTALLED BY PEER)

• BORINGS (INSTALLED BY PEER)

A PREVIOUS INVESTIGATION WELLS

LAKE CHAMPLAIN

SOURCE: PEER CONSULTANTS. MAY 1990

FIGURE 1-7. ON SITE MONITORING WELL LOCATIONS

4 C T C A L F A E OO Y

BORING LOCATION

BO BO BO BO BO BO BO BO BO BO BO BO BO BO BO BO BO

1 2 3 4 5 6 7 8 9 1 0 1 1 12A 12B 13 14 15 16

\ i ^ ^ BBOO 1177BO BO BO BO BO

MW MW MW MW MW HW MW MW MW MW

19 20 2 1 22 23

1 2 3 4 5 7 8 9 10 1 1

TABLE 1-2 BORING INFORMATION

(PEER CONSULTANTS, MAY 1990)

TOTAL DEPTH (FT) SAMPLE INTERVALS (FT)

15 3 - 5 , 5 - 1 0 , 1 0 - 1 5 5 4 - 5 , 9 - 1 6 , 1 6 - 1 8

28 2 - 3 , 5 - 7 , 1 2 - 1 4 , 2 4 - 2 5 25 1 - 5 , 5 - 1 0 , 2 0 - 2 5 2 1 4 - 5 , 1 6 - 1 8 , 1 8 - 2 0 30 1 0 - 1 5 , 1 5 - 2 0 , 2 5 - 3 0 27 0 - 2 , 1 0 - 1 2 , 2 5 - 2 7 26 8 - 1 0 , 1 0 - 1 1 , 1 2 - 1 3 30 1 5 - 2 0 , 2 5 - 3 0 29 3 - 4 , 9 - 1 0 , 2 2 - 2 4 , 2 7 - 2 8 23 5 - 7 , 1 6 - 1 8 , 1 9 - 2 1 18 6 - 8 , 1 1 - 1 3 30 7 - 8 , 1 7 - 1 8 30 2 - 4 , 1 4 - 1 6 , 2 0 - 2 2 27 4*. 8-10. 25* 27 0 - 5 , 1 7 - 1 9 , 2 3 - 2 5 27 1 3 - 1 5 , 1 7 - 1 9 , 2 7 - 2 9 27 0 - 5 , 1 1 - 1 3 , 1 3 - 1 5 , 1 5 - 1 7 , 17 20 7 - 1 2 , 1 5 - 1 6 , 20 30 7 - 8 , 1 6 - 1 8 , 2 7 - 3 0 30 7 - 8 , 1 4 - 1 8 , 2 1 - 3 0 20 1 3 - 1 6 , 1 9 - 2 0 30 0 - 5 , 1 0 - 1 5 , 2 5 - 2 7 . 5

50 5 - 7 , 38-40 32 5 - 7 , 1 2 - 1 3 , 1 3 - 1 4 , 2 7 - 2 9 66 1 0 - 1 2 , 1 $ - 1 7 , 6 4 - 6 6 154 4 - 6 , 2 8 - 3 0 , 1 4 5 - 1 4 7 3 4 . 5 1 0 - 1 5 , 1 5 - 2 0 , 3 0 - 3 5 90 0 - 2 , 1 0 - 1 7 , 2 0 - 2 2 , 7 0 - 9 0 150 5 - 7 , 1 0 - 1 2 , 1 5 - 1 7 , 3 0 - 3 2 192 3 . 5 - 5 , 1 4 - 1 6 , 4 0 - 4 2 24 0 - 2 , 1 0 - 1 2 128 1 0 - 1 2 , 1 9 - 2 0 , 2 5 - 2 7 , 1 3 0 - 1 3 2

* INTERVALS NOT REPORTED

I t T C A L F ft E OO Y

TABLE 1-3 BORING INFORMATION

(PEER CONSULTANTS, MAY 1990)

\ i ^ ^ - ^ ^ ^

WELL «

MW IA MW IB

MW 2A MW 2B

MW 3A MW 3B MW 3C

MW 4A MW 4B

MW 5A MW 5B

MW 7A MW 7B MW 7C MW 7D

MW 8A

MW 9A MW 9B MW 9C

MW lOA MW IOB

MW llA MW IIB MW lie MW llD

TOTAL DEPTH (FT.)

11.0 51.0

14.5 33.0

12.0 39.0 67.0

37.0 167.0

15.0 35.0

9.0 15.0 24.5 92.0

150.0

15.0 35.0

192.0

15.0 25.0

10.0 21.0 36.0

139.0

SCREENED TOP (FT.)

5.0 35.0

9.5 22.0

7.0 28.0 56.0

25.0 144.0

10.0 25.0

4.0 10.0 17.5 70.0

140.0

9.5 18.0

182.0

4.0 19,0

6.0 10.0 30.0

118.0

INTERVAL . BOTTOM (FT.)

10.0 50.0

14.5 32.0

12.0 38.0 66.0

35.0 154.0

14.5 34.5

8.0 15.0 24.5 90.0

150.0

14.5 28.0

192.0

14.0 24.0

10.0 20.0 35.0

128.0

Fill Lower

Fill, Lower

Peat Lower Tower

Lower Till

Fill Lower

Fill Peat Sand Lower

Fill, Lower

Fill Peat Lower Lower

SCREENED LITHOLOGY

Bedrock

Fill Sand (Gravel) Bedrock

Peat Silt/Clay

Silt/Clay Silt/Clay

Silt/Clay

Peat Silt/Clay

Silt/Clay Silt/Clay, Till

Silt/Clay

Silt/Clay

Silt/Clay

l E T C A L F ft E O O Y

m Surficial (0-3 feet) and deep (3-6 feet) canal sediment samples were found to

be contaminated with total polynuclear aromatic hydrocarbons (PAHs) and

'•" benzene, toluene,

ethylbenzene, and xylene (BTEX) throughout the length of the canal.

Concentrations in the canal sediments exceeded 100,000 ppb (100 ppm) total

PAHs and were determined to be highest in the deeper sediments.

* Contamination of surface soil with total PAHs appears to be widespread

throughout the site. The concentration of total PAHs exceeds 1000 ppb (1 ppm)

^ over much of the site.

Contamination of the subsurface soil is greatest in the fill and the

underlying peat layers. The area and concentration of contamination appears

to decrease with depth in the silt/clay strata below the peat.

Groundwater samples were found to be contaminated with PAHs and BTEX. The

mm major area of groundwater contamination is approximately bounded by Pine

Street to the east, the Burlington Electric Department access road and General

Electric to the south, the western edge of the Canal to the west, and the

\ ^ ^ filled-in barge slip (north of the coal gasification plant) to the north.

Groundwater contamination is also found within the canal area as far north as

Maltex Pond.

•» Total cyanide was detected in subsurface soil samples collected between the

former coal gasification plant and the canal.

1-17

m SECTION TWO

OBJECTIVES

The work objectives for this assignment are to fill data gaps and perform

tasks to complete the Pine Street RI/FS and to provide post RI/FS,

enforcement, and miscellaneous support to the EPA, as described below. At

present, the RI/FS tasks that are being or have been completed by PEER

• Consultants are as described in the Work Plan (PEER, March 1989) and the Draft

Amendment for Work Plan Volume I (PEER, October 1989). The EPA has assigned

= additional planning, sampling, and analytical tasks to M&E, as well as the

tasks of updating and preparing the RI report. Risk Assessment, and

Feasibility Study. M4E will incorporate previous study data in the

supplemental RI/FS. Incorporation of previous studies reduces the amount of

field work and sample analysis required and thus reduces the level of effort

•• from that of a full RI/FS.

^ To date, EPA has issued four work assignments to the current contractor.

These include:

\ ^ ^ . Biological Assessment (WA #3-1L19) - Planning, literature review on ecosystem and contaminants, assessment of existing ecological conditions and contaminant effects, and ecological risk assessment.

RI/FS Support (WA #5-lL19) - Planning, Community Relations, Data Validation, Post RI/FS support, Miscellaneous Support, Enforcement

lir Support, and Administrative Record.

Supplemental RI/FS (WA #10-1L19) - Includes the effort described in _ this work plan.

Treatability Study (WA //13-1L19) - Planning for and conducting the Treatability Study.

Each work assignment is funded separately; however, the final RI and FS

• reports of the Supplemental RI/FS will incorporate information and include

final deliverables for the other Pine Street work assignments.

2-1

m DATA GAPS

**^ The RI and RA completed by PEER Consultants (PEER, May 1990) identified

several data gaps which this Supplemental RI/FS Work Plan will address:

1. Definition of the areal extent of contamination due to the coal gasification plant site is incomplete:

^ • Extent of soil and groundwater contamination east of the coal gasification plant site is unknown since samples were not collected east of Pine Street and sample data collected just

as west of Pine Street were contaminated with PAHs.

Extent of groundwater contamination in the vertical direction is poorly defined.

w • PAH contamination detected at the Tank Farm and Burlington

Street Department Areas may be due to fuel oil spills rather im than coal gasification plant residues.

• Extent of soil and groundwater with coal tar product contamination between the west side of the canal and the

"* railroad is unknown.

• Vertical extent of contamination with coal tar product in the H\ i i ^ ^ highly contaminated central portion of the site is not clearly

known, since few samples were obtained from below the peat layer. This information is also necessary to estimate the rate

^ of vertical migration of the product.

• Vertical and horizontal extent of free cyanide contamination is not completely known. Total cyanide was analyzed in the

•* previous investigation and was found to be associated with woodchip and coal tar waste west of the coal gasification plant. Free cyanide is more relevant to the risk assessment

IP than total cyanide, since it represents the cyanide which is already dissociated from any metallocyanide complexes and is available to hydrolyze with water to form the toxic HCN molecule,

m 2, Some data may be used for enforcement and risk assessment; however,

non-valid data may not be usable for these purposes. The lack of If valid data includes:

• Due to the extremely wide range of concentrations of analytes ^ encountered.and the complex coal tar matrix, many analytical * results were rejected, estimated, or found to be below the

detection limits during sample data validation.

2-2

• Levels of carcinogenic PAHs (cPAHs), including Chrysene, Benzo(a)anthracene, Benzo(a)pyrene, Benzo(b)flouranthene, Benzo(k)flouranthene, Dibenzo(a,h)anthracene, and indeno (1,2,3-cd)pyrene (which are used to determine risk and cleanup levels) were often flagged as estimated or below detection limits. Since data below detection limits was assumed to be non-detected in the risk assessment analysis, average contaminant levels may be biased, depending on how non-detects are used to calculate average concentrations.

• Some holding time violations resulted in rejected or estimated data.

3. The latest Southern Connector alignment is expected to be located in areas determined to contain relatively low contamination levels. The data collection and feasibility study process should, to the extent that additional costs are not encountered, consider and be compatible with the highway construction plans.

4. Currently, it is very difficult to distinguish PAH and BTEX contamination due to the coal gasification plant from that due to fuel oil spills from the Ultramar site, street runoff, or other sources.

5. There are currently no criteria defining what levels and type of contaminants indicate site-related contamination. Criteria are needed to determine an "end point" to delineate the site boundary, a boundary beyond which any detected contamination is no longer considered to be site-related. Delineation is complicated by the

\ m y fact that the coal tar contamination due to the coal gasification plant contains some of the same chemical components as commonly used

m» solvents, fuels, and road paving materials known to have been used in the site vicinity, a historically industrial area.

6. The risk assessment may need revision to follow EPA Region 1 guidelines, based on EPA review comments to date. In addition, the remedial investigation, feasibility study, and risk assessment should be updated to incorporate new data, and data from ail

• existing studies.

7. The effects of industrial water supply wells are unknown.

#

To address and clarify the data gaps noted above, M4E will conduct the

^ following tasks in order to prepare a supplemental RI/FS:

^ • Project Planning (Task 1)

Field Activities (Task 3)

• Sample Analysis/Validation (Task 4) m

^ 2-3

% ^ /

Data Evaluation (Task 5)

Risk Assessment Revision (Task 6)

RI Reports (Task 8)

Remedial Alternatives Screening (Task 9)

Remedial Alternatives Evaluation (Task 10)

Feasibility Study Reports (Task 11)

Tasks to provide the EPA with technical support, as necessary, include:

Post RI/FS Support (Task 12)

Enforcement Support (Task 13)

• Miscellaneous Support (Task 14)

Administrative Record (Task 16)

If during the performance of this work, the M&E objectives and/or tasks

require modification, as requested by the EPA, a separate work plan amendment

wtll be prepared.

DATA QUALITY OBJECTIVES

Data quality objectives (DQOs) are established to ensure that sufficient data

is collected and that the data is of adequate quality for their intended

uses. For the work objectives to be completed as part of the Supplemental

RI/FS at Pine Street Canal, the primary DQOs include:

1. Delineating the extent of site contamination. Sufficient samples will be collected to produce data that will delineate the areal and vertical extent of contamination and to fill in data gaps existing in current site investigation reports. An interim "end point" soil concentration or criteria will be developed to delineate the site boundary and distinguish between site related and non-site related contamination, based on site contamination information and clean-up levels used at other superfund sites. The sampling and analysis procedures will be such as to ensure: (a) the field generated data is adequate to accurately quantify the contaminant concentrations as being within the "end point" soil criteria, (b) valid sample data is present for each property contained within the site, and (c) the data generated is defensible in court.

2-4

2. Determining the extent of coal tar versus fuel oil contamination. The sampling and analytical procedures will produce data to delineate the nature and extent of contamination due to the coal gasification plant coal tar residue versus that resulting from fuel oil spills onsite.

3. Distinguishing between total PAHS and carcinogenic PAHs (cPAHs). It is expected that a correlation exists between the total concentration of cPAHs and the total PAH concentration in samples from the site. Sufficient samples of water, soil, and sediment will be collected and analyzed to produce data that will determine such a correlation. The mathematical correlation will be used to extrapolate the concentration of cPAHS at various locations on the site using data from previous studies to provide information pertinent to revising the existing risk assessment.

4. Determining the nature and extent of cyanide contamination. From previous site investigation, (total) cyanide contamination was found to be associated with the marsh area west of the old coal gasification plant. Sufficient samples will be collected and analyzed from this area to produce data to determine the extent of both free and total cyanide and to estimate the volumes of free and total cyanide on the oxide coated woodchips contained in the area. The levels of free cyanide present will be incorporated into the risk assessment; free cyanide is more readily available to hydrolyze with water to form the toxic HCN molecule and thereby represents more of a health risk than metallocyanide complexes.

5. Confirming validity of existing site data. Due to the types and wide range of concentrations of various analytes encountered, much of the analytical data generated during previous site investigations was qualified as estimated during the data validation process. This data will be reviewed to confirm or deny its usability. Following the review, additional sampling and analysis may be proposed to ensure that valid and court-defensible data exists for each property contained within the site,

6. Updating and revising as necessary the remedial investigation, feasibility study, and risk assessment reports. Sampling and analysis will be conducted in order to provide additional data to revise the remedial investigation, feasibiltty study, and risk assessment reports. Data from all existing field investigations will be incorporated into these revisions.

7. Providing additional information pertinent to site remediation. The data collected from the overall site investigations will be compiled to assist in the development, screening, and evaluation of site-specific remediation options.

2-5

SECTION 3.0 TECHNICAL APPROACH

3.1 PROJECT PLANNING (TASK 1)

Project planning involves the preparation and work efforts necessary to

initiate the project following issuance of the work assignment. The planning

tasks for this project include:

Attendance at kick-off and other pertinent meetings

Preparation of Work Plan - draft and final

Development and/or modification of field analysis method to analyze total coal tar

Development and/or modification of laboratory method to analyze fuel oil components and distinguish them from coal tar derived polynuclear aromatic hydrocarbons (PAHs)

Development and/or modification of laboratory method to analyze total PAHs, individual PAHs, and carcinogenic PAHs (cPAHs)

Preparation of Specialized Analytical Services (SAS) Client Request forms for all analyses not included under the EPA Contract Laboratory Program (CLP) Routine Analytical Services (RAS) " V ^ Preparation of investigation waste minimization plan (as part of the Field Sampling Plan)

Review of draft preliminary remedial investigation and draft risk assessment reports as provided by PEER Consultants (PEER, May 1990)

Review of pertinent reports as generated by the potentially responsible parties (PRPs) including Ultramar, VTAOT, GE, and Blodgett Oven

Selection of wells to be resampled for groundwater analysis

Preparation of Quality Assurance Project Plan (QAPP) - draft and final

Preparation of Field Sampling Plan (FSP) - draft and final

Preparation of Health & Safety Plan (HSP) based on current Pine Street Canal Biological Study HSP - draft and final

3-1

4

i

• Development of sampling "endpoint" criteria necessary to categorize a sampling location as containing "site related contamination" or "non-site related contamination" based on the contaminants detected and the physical description and/or site location

• Evaluation of analytical data generated by PEER Consultants

• Hydrogeologic review of data generated by PEER Consultants as well as available literature concerning geology and hydrogeology of the site vicinity

3.1.1 Kick-Off Meeting

The Metcalf & Eddy (M&E) project team attended a kick-off meeting on

June 4, 1990 with USEPA Region I personnel to discuss the project approach and

level of effort for the Pine Street Canal work assignment and to review the

scope of work. Follow-up communications continued in order to clarify the

project scope and to provide information concerning any additional work

proposed. The results of these communications were incorporated into the

scope of the project. It is estimated that six (6) meetings of one-half day

each will be held in Boston with three members of the M&E staff.

\ ^ ^ 3.1.2 Work Plan

The development of this document, the Supplemental RI/FS Work Plan for the

field investigation, includes defining a scope of services and developing cost

estimates for each task. The draft work plan will be reviewed by EPA. The

final plan will incorporate EPA comments.

3.1.3 Field Analysis for Total Coal Tar

Field analysis techniques will be developed by a subcontracting laboratory for

the analysis of total coal tar in soil samples collected at the site. The

subcontracting laboratory will transfer the analysis technology to M&E. The

field analysis techniques will be performed on-site in a subcontracted,

staffed mobile laboratory and will be used to delineate the nature and extent

of site contamination. Results of the field analysis will be used in

determining which samples will be selected for confirmational analysis in an

off-site laboratory.

3-2

^ 3.1.4 Laboratory Analysis of Fuel Oil Components Versus Coal Tar Derived PAHs

"mi^ Analytical methods will be developed by a subcontracting laboratory in order

to determine the presence of and differentiate between fuel oil components and

coal tar derived PAHs detected in soil samples collected at the site in the

•• areas of the Tank Farm and the Burlington Street Department Areas. These

analyses will be performed in an off-site laboratory. The results of the

« analyses will be used to delineate the nature and extent of contamination on

site due to fuel oil spills versus gasification process residues. The cost

estimate does not include subcontractor costs for this task. Costs will be

included in the final work plan submittal.

* 3.1.5 Laboratory Analysis of Total, Individual, and Carcinogenic PAHs

Ol Analytical methods will be developed by a subcontracting laboratory in order

to determine the presence of and differentiate between total, individual, and

carcinogenic PAHs in soil samples collected throughout the stte. These

analyses will be performed in an off-site laboratory. The results of the

analyses will be used to provide information necessary for the risk assessment

%. .y as well as to provide information pertinent to the identification of the

individual PAHs present throughout the site. The results will also be used to « develop a mathematical model governing the relationship between total PAHs and

carcinogenic PAHs in order to estimate levels of carcinogenic PAHs in

previously collected and field testing data. The cost estimate does not

include subcontractor costs for this task. Costs will be included in the

final work plan submittal.

3.1.6 SAS Client Request Forms

A number of sample analyses required for completion of the Supplemental RI/FS

are not covered under CLP-RAS. These samples must be analyzed as part of

CLP-SAS and require the preparation and submittal of a SAS Client Request form

to initiate the analytical scheme. The analyses requiring CLP-SAS include:

3-3

Soils Lead Cyanide (free and total) Total Organic Carbon Total, Individual, and Carcinogenic PAHs Fuel Oil Components

Sediments (rapid turn around) Volatile Organics Total, Individual, and Carcinogenic PAHs

Groundwater (rapid turn around) Volatile Organics Metals (filtered and unfiltered) Cyanide (free and total) Total, Individual, and Carcinogenic PAHs (filtered and unfiltered) Water Quality Parameters

Alkalinity Biological Oxygen Demand Chemical Oxygen Demand Total Organic Carbon Chloride Nitrate-nitrite Sulfate (filtered and unfiltered) Sulfide

3.1.7 Investigation Waste Minimization Plan

An investigation waste minimization plan will be prepared and included as part

of the Field Sampling Plan (FSP). It will address pertinent issues to be

implemented in order to minimize the production of waste during the field

investigation.

3.1.8 Remedial Investigation and Risk Assessment Reports by PEER Consultants

The draft preliminary remedial investigation and risk assessment reports

provided by PEER Consultants (PEER, May 1990) will be reviewed. Information

will be extracted for use in planning, investigating, and reporting of the

Supplemental RI/FS and Risk Assessment Revision.

3-4

3.1.9 Site Investigation Reports by the PRPs

All site investigation reports generated by the PRPs (including Ultramar,

VTAOT, GE, and Blodgett Oven) will be reviewed. The information will be used

to fill-in data gaps and provide additional information to both the

Preliminary and Supplemental RI/FS Reports.

3.1.10 Resampling of Wells for Groundwater Analysis

The results of the groundwater analyses conducted as part of the Preliminary

RI/FS will be reviewed in order to select a proposed twenty of the existing

fifty-one wells for resampling and reanalysis.

3.1.11 Quality Assurance Project Plan

A Quality Assurance Project Plan (QAPP) will be written for the Supplemental

RI/FS effort following the outline detailed in the i n t e r i m G u i d e l i n e s and

Spec i f i ca t ions for Preparing Quali ty Assurance Projec t Plans , QAMS-005/aO

(EPA-600/4-83-004, February 1983). The plan will specify the sampling

locations and provide quality assurance/quality control (QA/QC) protocols

pertinent to the sampling and analysis methodologies.

3.1.12 Field Sampling Plan

A Field Sampling Plan (FSP) will be written for.the Supplemental RI/FS effort

detailing the sampling methodologies, field efforts, number of samples to be

collected, chain of custody protocol, sample packaging procedures, and the

types of sample containers and preservatives which will be used.

3.1.13 Health and Safety Plan

A Health and Safety Plan (HSP) will be written for the Supplemental RI/FS

effort addressing the eleven elements itemized in Guidance f o r Conduc t ing

Remedial I nves t i ga t i ons and F e a s i b i l i t y S tudies Under CERCLA

3-5

(EPA/540/G-89/004, October 1988). This will be based on the existing HSP

prepared for the Pine Street Canal Biological Study.

3.1.14 Sampling "Endpoint" Criteria

"Endpoint" criteria will be developed in order to specify a level of

contamination beyond which no samples need be collected and which define the

boundaries of site-related contamination for the purpose of the field

investigation. Field analysis procedures will be developed in order to

categorize a sample as containing "site related contamination" or "non-site

related contamination" based on the contaminants detected and the physical

description and/or site location. The criteria will be based on the review of

the available site data for total PAHs and BTEX and other available historical

data (e.g., 100-year flood level) and will be modified with analysis of

background soil samples. The sampling "endpoint" criteria will set a level of

total coal tar to specify the boundaries of the site contamination beyond

which no additional sampling will be required. In the area east of the coal

gasification plant, additional sampling may be required following field

analysis should the results be above the "endpoint" criteria to further

delineate the extent of contamination in this area.

3.1.15 Analytical Data Generated by PEER Consultants

The analytical data generated by PEER Consultants will be evaluated to

determine: (1) which samples that were qualified or "flagged" during the data

validation process should be resampled to obtain "unqualified" valid results,

(2) the feasibility of resampling and reanalysis of these "flagged" samples,

and (3) whether valid data exists for each property on site. A technical memo

will be prepared recommending resampling and reanalysis.

3.1.16 Hydrogeologic Review

Prior to the initiation of field work, a hydrogeologic review will be

conducted to obtain information that will be pertinent to the progress of the

field effort. The hydrogeologic review will include an examination of the

3-6

results of the preliminary remedial investigation conducted by PEER

Consultants (Peer, May 1990), as well as available up-to-date literature

concerning the geology and hydrogeology of the site vicinity.

The hydrogeologic review will also include a survey of flood insurance maps,

recorded flood elevation data, historical photos, and possible interviews of

persons referred to M&E by EPA. This information will be used to generate a

site map showing the maximum extent of flooding which will aid in the siting

of soil boring locations. It is estimated that a maximum of three maps will

be generated.

3.2 COMMUNITY RELATIONS (TASK 2)

No activities under this work assignment.

3.3 FIELD ACTIVITIES (TASK 3)

3.3.1 Description of Analytical Requirements

Chemical analysis will be performed as part of this RI/FS in order to:

• Collect data to supplement the work performed by PEER Consultants to further evaluate the nature and extent of contamination

• Further delineate the contamination boundaries caused by the coal gasification process and oil spills

• Reanalyze soils and focus on the detection of carcinogenic PAHs (cPAHs) to support the risk assessment

• Identify the presence and any areal distribution of cyanide on site

• Determine the volume of contaminated soils requiring cleanup

The analyses will be comprised of both off-site laboratory determinations and

field determinations in an on-site mobile laboratory to support the sample

analysis as listed below.

3-7

In Off-Site Laboratory:

• Soils from the Coal Gasification Plant Area: volatile organics; total, individual, and carcinogenic PAHs; lead; total organic carbon (TOC); total and free cyanide

• Soils from the Tank Farm and Burlington Street Department Areas: volatile organics; total, individual, and carcinogenic PAHs; fuel oil components

• Soils from the site perimeter (including sediments from Lake Champlain): volatile organics; total, individual, and carcinogenic PAHs

• Groundwater: volatile organics; total, individual, and carcinogenic PAHs (filtered and unfiltered); metals (filtered and unfiltered); total and free cyanide; alkalinity, biological oxygen demand (BOD), chemical oxygen demand (COD), TOC, chloride, nitrate-nitrite, sulfate (filtered and unfiltered), and sulfide

• Additional nineteen perimeter soils and one sediment (representing a range of coal tar contamination as determined by field einalyses): volatile organics; total, individual, and carcinogenic PAHs

In On-Site Mobile Laboratory:

• Soils from all collection areas of the site excluding the Tank Farm and Burlington Street Department Areas: total coal tar

The off-site laboratory analyses, performed by laboratories approved and

coordinated through the EPA Contract Laboratory Program (CLP), will include

both standardized or routine analytical services (RAS) and specialized

analytical services (SAS). The initiation and coordination of analytical

requests will be performed by contacting the EPA Region I CLP Sample

Management Office (SMO) by telephone and providing a complete description of

the analytical requirements. For SAS, a completed SAS Client Request will be

submitted to the Region I QA office for EPA approval. The QA office will

submit the approved SAS Client Request to the Region I RSCC who will in turn

submit tt to the SMO. The SAS Client Request serves as a written record to

clarify and confirm the analytical requirements, identify the analytical

method, and provide a description of the criteria to be applied by the

laboratory to ensure analytical quality control and sample integrity. RAS is

3-8

B required for all volatile organics and metal analyses. SAS is required for

all the remaining laboratory analyses required but not performed through the

•••• RAS system.

The off-site laboratory analyses being developed (including total, individual,

* and carcinogenic PAHs and fuel oil components) will be performed by the

subcontracting laboratory developing the methods. Coordination of the

• analysis requested will be made directly with the subcontracting laboratory.

- The field analyses to be performed in an on-site mobile laboratory will

include the analysis of all soil boring samples, except those collected tn the

Tank Farm and Burlington Street Department Areas, for total coal tar. The

procedures for these analyses are being developed. Additional screening to be

performed at the point of sample collection includes soil analysis for

• volatile organics using a Photovac and PAHs using thin layer chromatography

and groundwater analysis for pH, specific conductance, and temperature as

I outlined in the Metcalf & Eddy, "Standard Operating Procedure (SOP),

Section 7.0: Sampling."

Inj^^ A list of analytical requirements for this field effort is included in

Tables 3-1 and 3-2 for soil/sediment samples and water, respectively. The

cost estimate for Task 3 includes staffing and subcontractor requirements;

however, subcontracting costs for the mobile lab and for the subcontracted SAS

I analysis is not included. These costs will be included in the cost estimate

submitted with the final work plan submittal.

I 3-3.2 Field Mobilization

I

Field mobilization includes all the planning and procurements activities

required prior to the start of field work in order to ensure an effective and

» efficient field investigation. The activities include the following:

I • Procurement/mobilization of drilling subcontractors

• Mobilization of equipment and supplies for sample collection and personnel protection

,rf 3-9

i TAULK 3 - 1 . SOIL/SKUIMENT ANALYSIS SUMMAJtY

M a t r i x / A n a l y s i s A n a l y t i c a l >fethod(^)

Shore l i n e

Clas P l a n tPea t and S l l t / a a y

Area

Ueep

h j v l r o a m e n t a l Samples

blast of Gas

P l a n t

P e r i m e t e r Areas Tank Farm and B u r l . S t . Uept .

Below KK Bern.

S t . J and B u r l . K l e c t . Add ' l S u b t o t a l

W e l d 4A/gC F i e l d t q u l p Uupl. Blanks

Samples T r i p

Blanks^^^ T o t a lS o i l

Sample^. Water^­3)

S o i l s :

L a b o r a t o r y T e s t s

V o l a t i l e Organ ic s CLP-RAS 11 10 5 70 5 7 19 127 13 13 14 140 27

T o t a l . I n d i v i ­d u a l , and Car ­c i n o g e n i c PAHs

TBO 11 10 5 70 5 7 19 127 13 13 140 13

Lead CLP-SAS l i 10 21 24

Cyanide

t o t a l f r e e

CLP-SAS CLP-SAS

31 31

10 10

41 41

45 45

T o t a l O r g a n i c Carbon (TOC)

CLP-SAS 11 10 21

F u e l O i l Components TBU 70 70 77

F i e l d T e s t s

T o t a l C o a l Ta r TBU 55 50 25 25 35 190 10 200

S e d i a e D t a :

V o l a t i l e O r g a n i c s CLP-SAS 10

T o t a l , I n d i v i ­

d u a l , and Car ­c i n o g e n i c PAHs

TBO 10

(1) CLP Mathods ­ KAS U . S . KPA C o n t r a c tU.S . tPA C o n t r a c t

Labora to ry Labora to ry

Program, Program,

S t a t emen t S ta tement

of of

Work '.Jork

for fo r

O r g a n i c s A n a l y s i s , M u l t i - M e d l a / M u l t l - C o n c e n t r a C i o n , Feb rua ry l^HH. L i o r g a n l c s A n a l y s i s , M u l t i - r ^ d l a / M u l t i - C o n c e n t r a t i o n , J u l y 19a«.

TBU ­ To be d e v e l o p e d .

N o t e : A l l a n a l y s e s l i s t e d a s C L P - S A S r e q u i r e p r e p a r a t i o n and s u b m i t t a l of a SAS C l i e n t Kequest form.

(2)(3 )

Une t r i p b l ank s e n t p e r sample s h i p m e n t . Water samples a s s o c i a t e d w i t h f i e l d QA/yC d u r i n g c o l l e c t i o n and t r a n s p o r t a t i o n of s o l l / s e d l r a e n t s a m p l e s .

( 1.

TAULE 3 - 2 . UATKR ANALYSIS SUMMARY

rtjtrix/Ana l y s i s A n a l y t i c a l f b t h o d ' II

BedrockVtells

En v i r o n m e n t a lWells Wel ls

E a s t of Below E x i s t i n g Gas

VJellB P l a n t

Samples

R a i l r o a d Berm

F i e l d (jA/ijC Samples

S u b t o t a l F i e l d

D u p l i c a t e s Equipment

Blanks Blank s'-'^' T o t a l Samples

G r o u o t b a t e r :

L a b o r a t o r y I jes t s

V o l a t i l e O r g a n i c s CLP-SAS 20 2b 40

T o t a l , I n d i v i d u a l , and C a r c i n o g e n i c PAHs

f l l t e r e d ^ ^ ^ u n f i l t e r e d

TBD TBU

20

20 26

26 32

32

M e t a l s

f l l t e red^-^^ u n f i l t e r e d

CLP-SAS

CLP-5AS

2

2 20 20

2

2 2 2

2b

26 3 3

32 32

Cyanide

t o t a l f r e e

CLP-SAS CLP-SAS

2 2

20 20

2 2

2 2

26 26

3 3

32 32

W a t e r ( A i a l l t y P a r a m e t e r s

A l k a l i n i t y CLP-SAS 2 20 2 2 26 3

B i o l o g i c a lBOUj

Oxygen Demand, CLP-SAS 26 32

ChemicalCUU

Oxygen Uemand, CLP-SAS 20 26 32

T o t a l O r g a n i cTOC

Carbon, CLP-SAS 20 26 32

C i a o r i d e CLP-SAS 20 26 32

N i t r a t e - n i t r i t e CLP-SAS 20 26 32

S u l f a t e

f lltered^^^ unfiltered

CLP-SAS CLP-SAS

2 2

20 20

2

2

2

2 2b 26

3

3

32

32

Sulfide CLP-SAS 2 20 2 2 26 3 32

I V

^ V TABLB 3-2 (Continued). WATKR ANALYSIS SUMMARY

^ t a t r i x / M a l y s l sA n a l y t i c a l

l ^ t h o d ' ' ^ Bedrock

Wells

Environmental Samples Wells Wells

E a s t of Below E x i s t i n g Gas R a i l r o a d

Wells P l a n t Berm

F i e l d tjA/ljC Samples F i e l d

S u b t o t a l U i p l l c a t e s Equipment

Blanks T r i p

Blanks^'^^ T o t a l

Samples

F i e l d T e s t s

pH E150.E150.11 22 2200 22 22 2266 33 3 32

S p e c i f i cc o n d u c t a n c e

E120.E120.11 22 2200 22 22 2266 33 3 32

T e m p e r a t u r e E170.1 2 20 2 2 26 3 3 i i

( 1 ) CLP Methods KAS U . S . EPA C o n t a c tU.S . EPA Contac t

L a b o r a t o r y L a b o r a t o r y

Program, Program,

S t a t e m e n t S ta tement

of of

Work Wark

f o r f o r

O r g a n i c s A n a l y s i s , M u l t i - M e d i a / M u l t i - C o n c e n t r a t i o n , Feb rua ry 19BB. I n o r g a n i c s A n a l y s i s , M u l t i - M e d i a / M u l t i - C o n c e n t r a t i o n , J u l y 1988.

E l 0 0 - 4 0 0 Methods

Methods f o r Chemical A n a l y s i s of Water and Was t e s , EPA 60U/4-79-U.LU, March, 19B3.

TBU ­ To be d e v e l o p e d .

Note : A l l a n a l y s i s l i s t e d a s CLP-SAS r e q u i r e p r e p a r a t i o n and s u b m i t t a l of a SAS C l i e n t Reques t form.

(2 ) One t r i p b lank s e n t p e r sample s h i p m e n t .

(3 ) Sample f i l t r a t i o n per formed I n tlie f i e l d .

• Procurement/mobilization of sample collection bottles

• Purchase of the needed: General sampling supplies Decontamination expendables Sampling expendables

• Development of sample identification system, preprinting of sample bottle labels, and preparation of necessary documentation scheme as required by EPA CLP

• Collection of site samples to be used in method development

The cost estimate for this task includes both the hours needed to complete the

above activities as well as the costing for drilling, and labor for sample

collection bottle procurement, and procurement of general supplies and

expendables as well as site samples (one each of peat, sediment, water, and

coal tar) to be used by the subcontract laboratory for method development.

For costing purposes, all drilling and sample collection activities are

assumed to be performed in 100? Level C personal protection equipment.

3.3.3 Soil Boring/Sampling at the Coal Gasification Plant Area

Soil sampling will be conducted during soil boring operations tn accordance

with the Metcalf & Eddy "SOP, Section 7.0: Sampling" using a continuous split

spoon sampler. The contents of the split spoon sampler wtll be logged every

2-foot interval. A visual and geologic description will be provided, and all

the samples will be field screened for volatile organics with a Photovac

photoionization detector.

A split spoon soil sample will be collected for field analysis at the surface

and within every 5-foot interval, where visual observations indicate the

potential for the highest contamination. These samples will be field analyzed

for PAHs using thin layer chromatography (TLC) and for total coal tar in an

on-site mobile laboratory in order to delineate the vertical extent of coal

tar contamination. One of every five of these field analyzed samples will be

selected on a non-biased basis and submitted for off-site laboratory analysts

3-13

in order to confirm the field analysis results and to provide other pertinent

site contamination information. The sample analyses include: volatile

organics; total, individual, and carcinogenic PAHs; lead; total and free

cyanide; and TOC. The analysis summary is provided in Table 3-1.

Table 3-3 summarizes soil boring and monitoring well installation

specifications.

3.3.3.1 Borings in Peat and Silt/Clay. Five soil borings (BO-24, BO-25,

BO-26, BO-27, and BO-28) will be advanced in the most heavily contaminated

areas of the site including the south end of the canal, the filled-in barge

slip, and the marsh area west of the coal gasification plant as shown in

Figure 3-1. The borings will be drilled to a minimum of 20 feet below the

interface between the peat and the silt/clay strata (assume 50-foot depth for

cost estimating) tn order to determine the extent of contamination below the

peat strata. In addition to the analyses mentioned above, all samples

collected in the fill and peat layers (approximate depth of 20 feet) will be

analyzed for total and free cyanide so that both the source of the cyanide

(believed to be oxide coated wood chips) and its potential migration pathway

can be investigated in order to estimate the volumes of free and total cyanide ^ \ t m ^ ^

present.

3.3.3.2 Deep Soil Borings. Two soil borings (MW-12 and MW-13) will be

advanced to bedrock in the most heavily contciminated areas of the site, as

shown in Figure 3-1. The soil borings will be advanced using 4 1/4-inch ID

hollow stem augers or by spinning 4-inch ID casing through the overburden.

Soil samples will be collected using a 3-inch ID split spoon sampler.

Soil samples will be collected starting at the depth of the deepest soil

sample collected by PEER Consultants (assume 40-foot depth for cost

estimating) and continuing to the point of split spoon refusal signifying

gravel or bedrock (assume 160-foot depth for cost estimating) to determine the

3-14

1 1 1 1 1 1 1 8 8 8 8 8 8 8 8 1 8 S S S S S S S S S S S S S S S S S m I I I I t I I I I I I I I I I I I

SCALE (FEET)

100 200 300 400

C T D

'cfl

LAKE CHAMPLAIN

Proposed Peat and .TO Silt/Clay Borings

Proposed Deep Wells I :

BASE MAP SOURCE: PEER CONSULTANTS, MAY 1990

O L t u m t r n t t r

•3-fOO

4 - M M

-1-f«0

O'MM

l-fOO

2 * 0 0

S-t-OO

M W L f t m e n " 44-00

S-fOO

• •MM

r-fOO

• 4-00

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10+00 H O ¥ I A M > S n £ t T

11-4-00

12-^00

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U * O 0

IS-HX)

16-^00

17-M»

U-t-OO

IS-t-00

20-«>00

21-^00

22-t OO

23-t-OO

24.«>00

23-^OO

26-MX)

27.fO0

U * O 0

2>-M>0

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31-t OO

nCURE 3-1. PROPOSED SOIL BORING AND WELL LOCATIONS FOR GASIFICATION PLANT AREA, PINE STREET CANAL SITE

M E T C A L F ft E O O Y

TABLE 3-3. SUMMARY OF PROPOSED SOIL BORING AND MONITORING WELL INSTALLATION SPECIFICATIONS

Target Pro: jected Boring/Well No. Location Formation Depth (ft)

BO-24 Coal Gas. Plant Peat and S: Lit/Clay 50 BO-25 Coal Gas. Plant Peat and S: Lit/Clay 50 BO-26 Coal Gas. Plant Peat and S: Lit/Clay 50 BO-27 Coal Gas . Plant Peat and S; Lit/Clay 50 BO-28 Coal Gas. Plant Peat and S; Lit/Clay 50 BO-32* Tank Farm Fill 20 BO-33 Tank Farm Fill 20 BO-34 Filled Barge Slip Fill 20 BO-35 Tank Farm Fill 20 BO-36 Filled Barge Slip Fill 20 BO-37 Tank Farm Fill 20 BO-38 Burl. St. Dept. Fill 20 BO-39 Burl. St. Dept. Fill 20 80-40 Burl. St. Dept. Fill 20 BO-41 Burl. St. Dept. Fill 20 BO-42 N. of Tank Farm Fill 20 BO-43 N. of tank Farm Fill 20 BO-44 N. of Tank Farm Fill 20 BO-45 N. of Tank Farm Fill 20 BO-46 Perimeter-east Fill 20 80-47 Perimeter-east Fill 20 BO-48 Perimeter-east Fill 20 BO-49 Perimeter-west Fill 30 BO-50 Perimeter-west Fill 30 BO-51 Perimeter-west Fill 30 BO-52 Burl. Electric Fill 20 BO-53 St, Johns Truck Fill 20 BO-54 St. Johns Truck Fill 20 BO-55 Burl. Electric Fill 20 MW-12 Coal Gas. Plant Bedrock 160 MW-13 Coal Gas. Plant Bedrock 160 MW-14 Perimeter-east Fill 20 MW-15 Perimeter-east Fill 20 MW-16 Perimeter-west Fill 30 MW-17 Perimeter-west Fill 30

Borings 80-29, 30, and 31 were proposed in the draft work plan and were

subsequently deleted in the final work plan.

3-16

• presence of any downward migration of contaminants. No samples collected

above a 40-foot depth will be field screened, field analyzed, or laboratory

^ '"" analyzed.

3.3.4 Soil Boring/Sampling at Tank Farm and Burlington Street Department • Areas

gi Soil sampling will be conducted during soil boring operations in accordance

with the Metcalf & Eddy, "SOP, Section 7.0: Sampling" using a continuous

split spoon sampler. The contents of the split spoon sampler will be logged

every 2-foot interval. A visual and geologic description will be provided,

and all the samples wtll be field screened for volatile organics with a •f

Photovac photoionization detector. A split spoon soil sample wtll be

collected at the surface and within every 5-foot interval, where visual

•!» observations indicate the potential for the highest contamination. No field

analysis for PAHs or coal tar wtll be conducted since the anticipated presence

of fuel oil in the area will interfere with these analyses and prevent field

determination of the vertical extent of any coal tar contamination present.

Every 5-foot interval sample collected will be submitted for off-site

\ i , „ ^ laboratory analysis in order to determine the presence of fuel oil components

as well as coal tar derived contaminants in these areas. The sample analyses

•* include: volatile organics; total, individual, and carcinogenic PAHs; and

fuel oil components. The analysis summary ts provided in Table 3-1.

The purpose of sampling in the Tank Farm and Burlington Street Department is

to determine the northern and northeastern extent of coal tar contamination.

Previous investigation data indicates widespread, shallow soil contamination

with PAHs in this area. This contamination may be the result of alleged fuel

* oil spills rather than coal gasification plant products. Therefore, soil

boring and sampling will be performed throughout the tank farm and Burlington

% Street Department areas. Since field analysis will not be performed on these

samples, immediate determination of the extent of contamination wtll not be

m possible and there will be no criteria for terminating sampling to the

north. Therefore, a round of four soil borings wtll be sampled north of the

expected boundary of contamination to confirm or rule out the presence of coaJ

tar contamination on properties north of the Tank Farm area.

_ y 3-17

^ The borings will be advanced in the locations as shown in Figure 3-2. Six

soil borings (BO-32, BO-33, BO-34, BO-35, BO-36 and BO-37) will be advanced at

" the Tank Farm Area. Two of the borings (BO-34 and BO-36) will be located in

the filled-in barge slip. Four soil borings (BO-42, BO-43, BO-44 and BO-45

will be advanced north of the Tank Farm and Burlington Street Department

*• Areas. Four soil borings (BO-38, BO-39, BO-40, and BO-41) will be advanced at

the Burlington Street Department Area. All borings will be advanced to a

1^ minimum depth of 10 feet (assume 20-foot depth for cost estimating).

I 3.3.5 Soil Boring/Sampling of the Perimeter Areas

Soil sampling will be conducted during soil boring operations in accordance

with the Metcalf & Eddy, "SOP, Section 7.0: Sampling" using a continuous

split spoon sampler. The contents of the split spoon will be logged every

V 2-foot interval. A visual and geologic description will be provided, and all

the samples will be field screened for volatile organics with a Photovac

^ photoionization detector. A split spoon soil sample will be collected at the

surface and within every 5-foot interval, where visual observations indicate

the potential for highest contamination. These samples will be field analyzed

\ ^ ^ for PAHs using TLC and for total coal tar tn an on-site mobile laboratory in

order to delineate the vertical and horizontal extent of coal tar

*'' contamination east, west, and south of the coal gasification plant. One of

every five of these field analyzed samples will be selected on a non-biased

jg basis and submitted for off-site laboratory analysis in order to confirm the

field analysis results. An additional 20 samples (including one sediment

sample from the Lake Champlain shoreline) will be selected on a biased basis

represented a range of total coal tar content as determined during field

analysis; these samples will be used to fill tn any data gaps in the

^ preliminary RI data (PEER, May 1990) and ensure that valid data will exist for

each property at the Pine Street Canal site. The sample analyses include:

tk volatile organics and total, individual, and carcinogenic PAHs. The analysis

summary is provided in Table 3-1.

ft 3.3.5.1 Borings East of the Coal Gasification Plant, The purpose of sampling

east of the coal gasification plant site is to provide data to determine the

m eastern extent of coal tar contamination, since previous investigation results

J 3-18

S S 8 8 8 | § g s i s § | g g 8 § nMmNtTMtr s s s s 8 5 s s i s S i S S S S 8

I I I I I I ^ ^ ' ^ ^ r I 80-44 I BO-43 I BO-42 .a*eo # 8*0-37 • , ^BO-41^ B6-40 •2-fOO

SCALE (FEET) , ^ 0 . BO-36A D^BO-39,A b'o-38 •1-MM 100 200 300 400

O-fOO

1-»«0 O °BO-33 Q 2-fOO A A BO-32 )<«-00 CD °d:|]-—0 4.M)0

LAKE CHAMPLAIN 9 - H »

• • H »

7. t«> A Proposed Soil Borings t-fOO

•-fOO

Filled in Barge Slip lO-t-OO

11-fOO

12-fOO

n-foo

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24-t-OO

2S<f00

3a*00

27-fOO

2S-«>00

29-fOO

30-t-OO

31-fOO

BASE MAP SOURCE: PEER CONSULTANTS. MAY 1990

FIGURE 3-2. PROPOSED SOIL BORING LOCATIONS FOR TANK FARM AND BURLINGTON STREET DEPARTMENT AREAS, PINE STREET CANAL SITE

I E T C A L F a E OO Y

9

g indicate soil contamination extending from the surface to the peat in one

boring east of the gas plant area. A minimum of five soil borings (BO-46, BO­

**i« 47, BO-48, MW-14, and MW-15) will be advanced east of the coal gasification

plant near Pine Street. The borings will be placed starting in a known area

of contamination (MW-14), and north and south of the area (BO-46, BO-47).

^ Field analysis will be used to verify the presence or absence of coal tar.

The borings will be drilled to a depth of 20 feet. Subsequent borir^

m locations (BO-48 and MW-15) will be determined based on the results of field

analysis. Placement of all borings will be discussed with the RPM prior to

each installation. The tentative locations of the borings and wells are shown

in Figure 3-3.

3.3.5.2 Borings Below the Railroad Berm on West Side of Canal. Five soil

borings (BO-49, BO-50, BO-51, MW-16, and MW-17) will be advanced below the

m railroad berm along the west side of the canal and east of the railroad tracks

taking measures to minimize any effects to the wetlands. The borings will be

^ drilled to a minimum depth of 10 feet (assume 30-foot depth for cost

estimating) and the locations staggered as much as possible between the canal

and the railroad berm. A tripod mounted Acker portable drill rig will be used

y^i^y if the soils in the area are determined to be unable to support heavy drilling

equipment. The locations of these borings are shown on Figure 3-3.

3.3.5.3 Borings in St. Johnsbury Trucking and Burlington Electric Areas South

^ of Coal Gasification Plant. Four borings (BO-52, BO-53, BO-54, and BO-55)

will be advanced in the St. Johnsbury Trucking and Burlington Electric Areas

south of the coal gasification plant within the planned highway detour area.

The borings will be drilled to an approximate depth of 20 feet. The location

of these borings are shown on Figure 3-3.

m 3.3.6 Surface Sediment Sampling in Lake Champlain

m Eight surface sediment samples will be collected, two samples from the canal

^ outlet and six from along the Lake Champlain shoreline adjacent to the site,

alternating between approximately 50 and 150 feet from the shoreline and

spaced at approximately 400-feet intervals. The samples will be collected

^' 3-20

i l l i i l i 8 8 8 8 8 8 8 8 § 8 S S S S S S S S S S S S S S S S S KLtuHMSTnter

BASE MAP SOURCE: PEER CONSULTANT. 1990

FIGURE 3-3. PROPOSED SOIL BORING AND WELL LOCATIONS IN PERIMETER AREAS, PINE STREET CANAL SITE

( E T C A L F ft E O O Y

starting 800 feet north of the canal outlet and proceeding in a southerly

direction. The samples will be collected using a Ponar Sampler and submitted

for analysis of: volatile organics and total, individual, and carcinogenic

PAHs. The sampling locations are shown in Figure 3-4. The analysis summary

is shown in Table 3-1.

3.3.7 Monitoring Well/Sampling at the Pine Street Canal Site

Monitoring wells will be installed at the Pine Street Canal site tn order to

sample the groundwater for chemical analysis of: volatile organics; total,

individual, and carcinogenic PAHs (filtered and unfiltered), metals (filtered

and unfiltered), and water quality parameters including alkalinity, BOD, COD,

TOC, chloride, nitrate-nitrite, sulfate (filtered and unfiltered), and

sulfide. The purpose is to collect data indicative of the migration of site

contamination into the groundwater and to provide data essential to the

evaluation and planning of groundwater remediation alternatives. The analysis

summary is presented in Table 3-2.

In addition, one round of water level measurements wtll be conducted tn all 51

existing wells and in the six newly installed wells within 24 hours of each

other in order-to collect information needed to determine the groundwater flow

direction.

Groundwater sampling will be conducted a minimum of two weeks following well

development in accordance with Metcalf & Eddy, "SOP, Section 7.0: Sampling."

For costing purposes, it is assumed that one water sample wtll be collected

from each of the new wells.

3.3.7.1 Deep Wells. Two deep monitoring wells (MW-12 and MW-13) will be

installed in the two deep soil boring locations advanced to bedrock in the

most heavily contaminated areas of the site, as described in Section 3.3.3.2

and shown in Figure 3-1.

3-22 jUl "*

M

l l ! i i l l 8 8 § 8 S 8 8 8 8 8 lOLKMMfTIIGfr S S S S S S S S S S S S S S S S S

^ l l l i l l l l i i l l l l l i .a-foo # SD-037 V d 4 * 0 0

SCALE (FEET) -1-fOO

100 200 300 400 OCPT. I O-fOO nB.m.*' 1-fOO D& " ^ 2-fOO

SD-035 3-t-OO

30-033 A SD-036 1 CD °<£l 4-fOO M M a L r s T n o r —

LAKE CHAMPLAIN IVMWMIMIM S-I-OO KMMER

«-»>00 oa i 7-M)0 SD-032 A •-•-00

• > 0 0

10-fOO WOWM<0«TWEtT

SD-031 • 11-^00

12-fOO

13-fOO

SO-030 14-4^0

15-1-00

K-i-OO

• Proposed 17-fOO K Sediment IS-fOO Samples 19-t-OO

20-t'OO

21-4-00

22-^00

23-t-OO

24-fOO

lOccsrsTneET 23-fOO

26-^00

27-fOO

2a-^oo •T.jo»«4saunY • m u c M N o — f 29-M)0

30-fOO

31-fOO

BASE MAP SOURCE: PEER CONSULTANTS. MAY 1990

nGURE 3-4. PROPOSED SEDIMENT SAMPLING LOCATIONS, PINE STREET CANAL SITE

m l E T C A L F a E O O Y

The two deep soil borings will be used to determine the depth to bedrock.

Bedrock will not be cored; refusal will be taken to indicate the bedrock

surface or the till horizon overlying bedrock which ranges from 4-10 feet

thick at the site according to well logs from the PEER Draft RI report

(1990). The deep wells will also be used to determine if there is any

downward migration of site contamination into the lower part of the silt/clay

formation and to evaluate vertical gradients between the lower part of the

silt/clay formation and the overlying units.

The deep wells will be installed adjacent to and following advancement of the

deep soil borings. Samples taken during advancement of the deep borings wtll

provide visual evidence of the vertical extent of contamination tn the

borehole. The deep monitoring wells will be installed in such a way as to

prevent downward vertical migration of contaminants via the borehole. A steel

casing will be grouted in place to seal off the silt/clay unit from the

overlying peat. If samples from the deep borings indicate that the upper part

of the silt/clay formation is contaminated, then another steel casing will be

telescoped into the hole and grouted into place to provide a seal between the

upper and lower parts of the silt/clay formation.

Deep wells will first be drilled using 6i inch ID hollow stem augers to 2 feet

below the contact between the peat and the silt/clay. The augers will be

withdrawn and an 8-inch flush jointed steel casing wtll be lowered into the

hole. The casing will be lifted 2 feet while approximately 10 feet of grout

is tremied into the hole and then the casing will be lowered back down. After

the grout has been allowed to set (12 hours) the hole will be continued.

If the upper silt/clay ts contaminated a 6-tnch casing will be spun down to a

depth 2 feet below the depth of the deepest contamination. The casing wtll be

withdrawn and a 5-inch flush-Jointed casing will be lowered tn to the hole.

The casing will be lifted 2 feet as approximately 10 feet of grout is tremied

into the hole and then the casing will be lowered back down into the hole. A

4-inch casing will then be spun down to the top of the bedrock surface.

3-24

0

• If the upper silt/clay is not contaminated a 5-inch casing will be spun down

to the bedrock surface.

A 10-foot long, 2-inch diameter slotted (0.010) PVC well screen and riser will

be installed in the borehole. Sand will be added to 2 feet above the screen,

** and a 2-foot bentonite seal will be installed. All annuluses within the

borehole will then be grouted to the surface, and a locking steel protective

• cap will be installed on the 8-inch steel casing.

3.3.7.2 Wells East of the Coal Gasification Plant. Wells (MW-14 and MW-15)

will be installed in the peat strata tn a minimum of two of the borings

advanced east of the coal gasification plant near Pine Street (as described in

Section 3.3.5.1), as shown in Figure 3-3, to determine any lateral migration

of site contamination into the groundwater in this area. Overburden

• monitoring wells will be installed in accordance with the M&E SOP.

m 3.3.7.3 Wells Below the Railroad Berm on West Side of Canal. Wells (MW-16

and MW-17) will be installed in two of the soil borings advanced below the

railroad berm along the west side of the canal and east of the railroad tracks

lim^ (as described in Section 3.3.5.2), as shown in Figure 3-3, to determine any

lateral migration of site contamination into the groundwater in this area.

m 3.3.8 Groundwater Resampling of Existing Wells

Groundwater samples will be collected from 20 of the existing 51 wells, as

^ shown in Figure 3-5, to confirm the previous analytical data, delineate

groundwater contamination, and provide additional information on the

groundwater quality for the Feasibiltty Study.

3.3.9 Resampling Locations •

Various locations from around the site will be resampled, as deemed

H necessary. Resampling, sample analysis, and data validation will be performed

in areas and for analytical parameters where previous data are limited due to

data validation qualifiers or in the case that valid analytical data was not

collected for each property division.

^ 3-25

| 8 § i i i i g § g § § § g g 8 g nLaufMSTKCT S S S S S S S S S S S S S S S S S

I I I I I I I I I I I I I I I I I

Legend

cmzENs • Monitoring Wells "OIL CO. S S ^ -t] (Installed By PEER)

MAMUSTftEET gao-i i

• Borings nnNMosAsiN (Installed By PEER) "1 oa

^ Previous Investigation Wells

O Proposed Resampling Location

Lake Champlain

FORMER COAL

OASnCATtON PIANT

ELECTFtC OEPT.

LOCUST SmCET

MweiM

BASE MAP SOURCE: PEER CONSULTANTS, 1990 m

•3-fOO

•2<fOO

•1-400

04-00

1-400

2-400

3-400

4-400

S-4-00

6-4 00

7-400

• -400

9-400

104^00

114-00

124^00

134-00

14400

1$400

16400

17400

16400

19400

20400

21400

22400

23400

24 400

23400

26400

27400

26400

29400

30400

31400

SCALE (FEET)

100 200 300 400

nGURE 3-5. PROPOSED EXISTING WELL RESAMPLING LOCATIONS, PINE STREET CANAL SITE

I f T C A L r R t O O Y

3.3.10 Investigation Waste Disposal

Wastes generated during the field investigation shall include soil cuttings,

well development water, well sampling purge water and used personnel

protective equipment. These wastes will be placed in new, steel 55-gallon

drums, labeled and stored tn a secured area on the site. In addition,

previous investigation waste is being stored at the stte. This waste will be

overpacked (funded in Task 15). All waste drums will be transported to and

disposed of in a licensed RCRA facility by a licensed subcontractor procured

by Metcalf & Eddy. M&E estimates that a maximum of 120 drums will be

generated during the investigation, and that a total of 450 drums will be

disposed of.

3.3-11 Contingency Plan

Contingency plans for additional sampling will be made if "hot spots" are

discovered during the field activities or if samples collected from the site

periphery, anticipated to be clean, are found to be contaminated with coal

gasification wastes. Should remobilization be necessary, sampling may not

occur within the existing sampling schedule. The estimated contingency may be

more than four days for both the field sampling crew and the drilling

subcontractor. The cost estimate includes four extra days of boring and

groundwater sampling, although the contingency is not included in the

schedule.

3.3.12 Surveying

All newly installed monitoring wells, soil boring locations, surface water

elevation monitoring stations, and, where possible, surface water and sediment

sampling locations will be surveyed to the nearest 0.01 foot. Horizontal and

vertical coordinates will be established for each location using the Vermont

state coordinate system and the National Geodetic Vertical Datum (NGVD) of

1929. All surveying will be tied to surveying monuments established by PEER

Consultants (PEER, May 1990). Surveying will be conducted to locate soil

boring locations prior to field work and after completion of the field

investigations.

3-27

3.3.13 Hydrogeologic Assessment

As part of the field investigation, data will be collected for a hydrogeologic

assessment which will entail the determination of:

• Complete hydraulic characteristics (e.g., transmissivity, hydraulic gradients, and potentiometric surface) of the stte groundwater tn each aquifer zone

• The relationship between groundwater and surface water at the site

• The hydrologic relationship between Pine Street Canal and Lake Champlain

• The influence of subsurface manmade features in the site area

• The extent of the immiscible phase of non-aqueous phase liquid (NAPL) in groundwater at the site

The elements of the hydrogeologic assessment are discussed below.

3.3.13.1 Aquifer Testing. Slug tests will be conducted on newly installed

overburden to determine the hydraulic conductivity in all aquifer zones.

Slug tests will be conducted after sampling is completed to avoid the

possibility of sample contamination by slug test equipment. Slug test

equipment will be decontaminated between wells.

To determine the in-situ hydraulic conductivity, a slug test wtll be performed

on each well. The following protocol will be used:

• The static water level will be measured

• A slug of known volume wtll be instantaneously introduced into each well

• Using an in-situ data logger and downhole pressure transducer, the recovery of the water level in each well will be measured and recorded with time until the water level reaches the previous static level

3-28

JP • The slug will be instantaneously removed and the recovery of the well recorded as above

i i)/ • If the water table ts below the top of the screen only slug removal •* will be performed

• The slug tests will be duplicated tf necessary

The data will then be plotted on semi-logarithmic paper and analyzed using

« either the Hvorslev (1951) method or the Bouwer and Rice (1976) method.

^ 3.3.13.2 Groundwater Mecisurements. Static water level measurements will be

made in all on-site monitoring wells during a single 24-hour period;

groundwater elevations and hydraulic gradients will be determined. A set of

groundwater elevation measurements will be obtained at the completion of the

sampling episode and during the high flow and low flow events in which the

• flow through the canal is being measured.

Measurements to determine the extent of the immiscible phase of NAPL in

groundwater will be made coincidently with the groundwater elevation

measurements using an oil-water interface probe. From these measurements, the a.

^1.^^^ volume of NAPL, as well as its horizontal and vertical extent, in groundwater,

will be determined.

3.3.13.3 Surface Water Measurements. A maximum of four surface water

p monitoring stations will be installed in the canal. These stations will be

located based on site conditions and will be used to monitor changes in

_ surface water elevations so that the groundwater/surface water relationship

can be evaluated.

3.3.13.4 Determination of Discharge through the Canal. The hydrologic

relationship of Pine Street Canal to Lake Champlain has not yet been fully

• determined and will be essential in predicting contaminant transport via

surface water at the site. Measurements will be made to determine if surface

water flow ts into and/or out of the canal, and whether the canal and the

drainage ditches are a sourde of water to the lake.

3-29

^ Discharge measurements will be made at the railroad bridge where the canal

enters Lake Champlain and the bridge by the north entrance to the General

tm^ Electric (GE) plant. A minimum of 5 measurements will be made, three during a

single high flow event and two others (on separate days) during low flow

events. An additional three measurements will be taken at a flood stage event

^ during the spring thaw, which is a time when surface water gradients may be

reversed. Velocity measurements will be made using a Pygmy current meter.

Because stream velocities will vary through a cross-sectional area of the

canal, the measurements of discharge will require the determination of

sufficient point velocities to permit the calculation of an average velocity

for the canal at both measuring locations. At each location the canal will be

divided into vertical sections such that no section is more than approximately

\0% of the total flow. Velocity measurements will be made at two-tenths and

• eight-tenths of the depth below the surface and averaged together to obtain

the mean velocity in each vertical section.

The sum of the mean velocities from each vertical section will yield the

average velocity at that measuring point in the canal; the average velocity

\i^^ multiplied by the cross-sectional area will give the total discharge.

3.3.13.5 Influence of Subsurface Manmade Features on Site Groundwater.

Manmade subsurface features that may affect groundwater flow patterns at the

Ml Pine Street Canal site will be identified and evaluated for their potential

influence. Features such as industrial supply wells, sewer lines, storm

drains, and sump pumps within a one-half mile radius of the Pine Street Canal

site will be located by compiling an inventory of industrial companies tn the

area. According to the Draft Remedial Investigation report (PEER, May 1990), m

industrial production wells completed tn the bedrock aquifer are operated by

GE, Whiting, and Blodgett; and there are several storm/sewer outfalls within

• the site area. The inventory will be based on review of information and

interviews, if necessary, and wtll request the following information, tf

m available:

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• Industrial supply wells

Location and elevation Date of installation Name of drilling company that installed the well Copies of well logs Depth and diameter Well construction materials Type, size and depth of pump Pumping rates and pumping schedules Use of water

• Sewer lines and storm drains

Locations and elevations

• Sump pumps

Location

Depth Pumping rates and pumping schedules

Information concerning industrial supply wells and sump pumps will be compiled

to identify peak, regular, and slow pumping periods, as well as periods of no

pumpage. Groundwater elevations will be continuously recorded in monitoring

wells nearest the industrial supply wells to determine the maximum influence. ^ u ^ ^ ^ ^ v

The locations and elevations of existing storm drains, sewer lines and sump

pumps will be compared to groundwater elevations and groundwater contour maps

to determine whether or not groundwater at the stte ts influenced by these

features.

3.4 SAMPLE ANALYSIS/VALIDATION (TASK 4)

Metcalf & Eddy's subcontractor will validate pertinent analytical data

acquired from the samples collected at the Pine Street Canal stte. Samples

submitted and analyzed through the EPA CLP and Region I SMO will be validated

as described in this section. Data from samples analyzed or screened tn the

field will not be validated.

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Samples collected by Metcalf & Eddy and analyzed through the CLP system for

RAS will be validated following the EPA Region I Functional Guidel ines for

E v a l u a t i n g O r g a n i c s Ana lyses (EPA Region I, November 1988) and the EPA

Region I Functional Guidelines for Evaluat ing Inorganics Analyses (EPA

Region I, July 1988). The validation guidelines specify the required

deliverables to be generated for all RAS sample packages including a memo

report, a summary Table of flagged data, and a subscribed number of

worksheets. Any data generated through the CLP for SAS will require a

modification of the required sample package deliverables depending on the

special analysis performed. Data validation performed on the groundwater

samples analyzed for water quality parameters will be limited to the review of

field and laboratory quality assurance/quality control parameters (QA/QC).

The data validation deliverables will be distributed as required by the EPA

Region I Functional Guidelines.

The cost estimate for this task is based on the samples and analyses presented

tn Tables 3-1 and Table 3-2, For costing purposes the following assumptions

were made:

• All validation will be performed by a qualified subcontractor

No tentatively identified compound (TIC) or field generated data will be validated

• CLP RAS validation rates are contract rates

• CLP SAS validation rates are estimated; firm prices are not available

3.5 DATA EVALUATION (TASK 5)

3.5.1 Dat:a Reduction and Evaluation

Following the completion of the field activities (Task 3) and data validation

(Task 4), the information obtained during the Supplemental RI and by PEER

Consulting during the draft preliminary RI will be evaluated to characterize

the nature and extent of contamination in soil and groundwater. The

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^ % ^ i ^

hydrogeological data from the boring operations and the analytical data from

the sampling episode will be evaluated. Based on available data, the data

evaluation will include a compilation of the following:

Description of the site and environmental setting

Nature and areal extent of PAH contamination associated with the coal gasification plant, including a map and a description/ discussion of the site boundaries

Areal extent of cyanide, metal, and other non-PAH contaminants at the site including maps and analytical data

Analysis of the significance, distribution, and probable source of contaminants in the ditches and outfalls at the site

Analysis of background sample data to determine potential stte contamination attributable to the Pine Street Canal site

Evaluation of the accuracy of using site elevations to predict the distribution of coal gasification waste

Qualitative assessment of the hydraulic and physical properties of in "compressed peat" and "non-compressed peat", using available data

Assessment of the significance of and areal distribution of wood chips and sawdust at the site, using available information

Discussion of the potential and estimation of the time for BTEX and PAH to migrate to the lake or bedrock

Presentation of the following plots of the volume and area of soil to be remediated as a function of cleanup level:

Contaminated volume vs. total PAH concentration Contaminated volume vs. cPAH concentration Surface area of contaminated soil vs. total PAH concentration Surface area of contaminated soil vs. cPAH concentration and figures of the following:

Cross section showing vertical contamination Conceptual drawings indicating how various portions of the site may have become contaminated

Description of the field investigation program including soil boring and monitoring wells logs, field sampling data, development records, and hydrogeologic testing data

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• Results and significance of findings including: hydrogeologic assessment, nature and extent of contamination

• Recorranendation for any additional field investigation activities

3.5.2 Evaluation of Previous Dat:a

The previous data, as generated by PEER Consultants during the draft

preliminary RI activities, will be evaluated to determine its data validation

status.

3.5.3 Data Reporting

Following evaluation, all site data tables and maps, generated by Metcalf &

Eddy during the Supplemental RI and by PEER Consultants during the Draft

Preliminary RI, will be submitted for EPA review and comment. It ts

anticipated that one half-day meeting will be necessary to accomplish this

task.

3.6 RISK ASSESSMENT REVISION (TASK 6)

The objective of the baseline risk assessment is to provide an evaluation of

the actual or potential future threat to human health and the environment tn

the absence of any remedial action. Existing and potential public health and

environmental risks wtll be assessed based on data collected as part of the

supplemental RI/FS and on data from existing PRP reports. The M&E risk

assessor will review the risk assessment section of the Draft Preliminary

Remedial Investigation report as prepared by PEER Consultants (PEER, May

1990), and EPA review comments on this section. M&E will incorporate new

data, EPA comments, and other appropriate elements when preparing the M&E

update of this report. In addition, the risk assessor will view current

conditions by visiting the site; select the most appropriate sample data on

which to base the assessment based on data quality, timeliness, and location;

select reference values; and update toxicity profiles, ARARs, and dose-

response information if necessary. The risk assessment section of the M&E

supplemental RI/FS report, serving as an update to the PEER Consultant RI/FS

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report, will follow U.S. EPA Region I guidelines. The risk assessment wtll be

conducted as part of two tasks. In this task the baseline assessment or no­

^•(/ action evaluation is conducted as part of the RI. An evaluation of risks

associated with each of the remedial alternatives will be included as part of

FS tasks 9 and 10, where the risk assessment will be used to identify remedial

•• objectives or goals and to assess risk related to remedial alternatives.

^ The method used to evaluate baseline public health risk will follow the basic

format described in U.S. EPA guidance documents. Guidance documents will

include, but not be limited to, the Risk Assessment Guidance for Superfund

(Vol. I ) Human Health Evaluation Manual (U.S. EPA, December 1989), the

Superfund Exposure Assessment Manual (U.S. EPA, April 1988), and the Region I

Supplemental Risk Assessment Guidance for the Superfund Program Par t 1 ­

Guidance for Publ ic Health Risk Assessment (U.S. EPA, June 1989). The public

M health assessment will consist of the following parts: hazard identification,

dose-response assessment, exposure assessment, risk characterization, and a

simanary of the uncertainty and limitations of the risk assessment.

Ecological risk assessment guidance documents used, where appropriate, will

\ ^ include: Risk Assessment Guidance for Superfund (Vol. I I ) Environmental

Evaluation Manual (U.S. EPA, December 1989b), and Region I Supplemental Risk

t t Assessment Guidance for the Superfund Program ­ Pa r t 2 ­ Guidance for

E c o l o g i c a l A s s e s s m e n t s (U.S. EPA, June 1989). The ecological assessment will

gl include an evaluation of historical information, and evaluation of the

existing hazard to the environment, identification of habitat or species of

concern and a characterization of risk or threat.

m 3.6.1 Public Health Baseline Assessment

m The following six subtasks will be undertaken, if necessary, when updating the

m baseline risk assessment.

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3.6.1.1 Evaluate Historical Information. Information available for the Pine

Street Canal site will be reviewed as part of Task 5 and compiled to assess

past, present, and predict future contaminant concentrations over time. This

information will be used tn the risk assessment to evaluate the potential for

migration and exposure.

3.6.1.2 Hazard Identification. A subset of contaminants will be selected to

focus the assessment on those chemicals of greatest public health concern.

These contaminants of concern will be selected based on concentrations

detected on-site, frequency of detection, toxicity, chemical and physical

properties of the compounds, comparison to background levels, and comparison

to applicable or relevant and appropriate requirements (ARARs).

Information developed on nature and extent of contamination as part of Task 5

will be utilized to select chemicals expected to represent the largest

proportion of exposure and risk. The assessor will work closely with the

chemists to ensure the generation of mean statistics, treatment of non-detects

and trace value data, and establishment of background is conducted tn

accordance with the Region 1 guidance document and to provide data suitable

for use in the risk assessment. Both a qualitative assessment, which relies

heavily on the expertise of the risk assessor, and a quantitative assessment,

where an indicator score ts calculated, wtll be used to select the

contaminants of concern. The qualitative assessment, which wtll include

evaluation of toxicity data, evaluation of mobility, persistence tn the

environment, frequency of detection and the comparison with ARARS, will be

used as the primary method to select the compounds of concern. The indicator

score method will be used as a backup method of selection. Contaminants of

concern will be drawn from evaluation of data from all media sampled at the

site. For prevalent compounds detected at high concentrations without

toxicity data, structure activity information will be considered. A technical

memorandum presenting the selection of the subgroup of chemicals of concern

will be submitted prior to completing the risk assessment.

Toxicity profiles will be developed for the contaminants of concern. Public

health toxicity profiles will utilize U.S. EPA databases including the

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Integrated Risk Information System (IRIS), Health Effects Assessment Summary

Tables (HEAST), as well as the ATSDR Toxtcological Profiles. The full

toxicity profiles will be presented in the appendix. The information in the

toxicity profiles will be summarized in the text, and will include EPA's

provisional weight-of-evidence classification of each chemical's

carcinogenicity. Physical and chemical properties of the contaminants of

concern will be included along with the toxicity profiles. A presentation of

chemical properties will assist in identifying potential migration pathways,

and will allow the toxtcological analysis to focus on the potential exposure

routes of greatest interest.

3.6.1.3 Dose - Response Assessment. The Integrated Risk Information System

(IRIS) on-line database will be used as the primary source of dose response

data. Dose-response data will be presented in table form. Carcinogenic

weight of evidence, slope factors, chronic and subchronic noncarcinogenic

dose-response data, critical effects, and the reference and date for the

toxicity data will be tabulated. In addition, public-health-based federal and

state (ARARs) will be compiled and presented.

3.6.1.4 Exposure Assessment. The exposure assessment will include

identification of possible exposure pathways and screening of the pathways to

focus on those expected to be complete and represent the largest contribution

of the exposure and total stte risk, identification of populations at risk of

exposure, estimation of exposure point concentrations, and estimation of

exposure dose for each selected pathway. Pathways evaluated wtll include

present pathways known to exist, pathways with the potential to occur

presently, and pathways considered to have the potential to exist tn the

future. Populations at risk of exposure will be characterized as to size and

activities which may affect the likelihood of exposure. Exposure scenarios

will be developed to estimate potential doses. Exposure routes considered

will include but not be limited to exposure through ingestion of soils,

surface water, and caught fish; dermal contact with soils, sediments, surface

water, and, in connection with earth-moving, subsurface soils; inhalation of

contaminants in ambient air by workers, residents, and trespassers; and

exposure to contaminants in household water under a potential future pathway

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of use of site groundwater as a potable water supply. In each case, a range

of conditions will be used to illustrate "average case" and reasonable worst

case exposure scenarios. The Exposure F a c t o r s Handbook (U.S. EPA, May 1989)

will be used where site-specific data are not available.

3.6.1.5 Risk Characterization. The present and potential threats to human

health posed by contaminants at the site will be presented as part of the risk

characterization. Site-specific risks are evaluated by integrating

information presented tn the hazard identification, the dose response

assessment and the exposure assessment. The characterization will include a

comparison with guidelines, and an evaluation of carcinogenic and

non-carcinogenic risks for both present and potential future exposures and for

both average and reasonable worst case exposure scenarios. All contaminants

of concern will be included in the evaluation of non-carcinogenic risks. The

hazard index and incremental cancer risk will be calculated and discussed.

Obstacles to the evaluation of risk and a risk summary, as defined in the

Region 1 guidance, will be presented.

3.6.1.6 Uncertainty and Limitations of the Risk Assessment. The risk

assessment process is based on a variety of data and assumptions, each of

which carries some uncertainty. An overview of the uncertainty and

limitations inherent in the assessment is useful in order to put the

calculated risk values into perspective. The major limitations and

uncertainties associated with the different components of the risk assessment

and an indication of whether they have resulted tn an over-or under-estimation

of risk will be identified.

3.6.2 Ecological Baseline Assessment

The following subtasks are currently being conducted under a separate ARCS

work assignment 03-1L19 (WA 03-1L19). The results of these tasks will be

incorporated into the ecological risk assessment described in this work plan.

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3.6.2.1 Evaluate Historical Information. Information available for the Pine

Street Canal site has been reviewed under WA 03-1L19. This information

includes the site history, available analytical chemistry data, and existing

ecological data. Also, available information on the ecological effects of the

contaminants of concern has been reviewed and summarized. This information

will be incorporated into the ecological risk assessment.

3.6.2.2 Conduct Hazard Evaluation. Data collected as part of the field

investigations will be summarized and used to evaluate the nature and extent

of contamination as described in the work plan for WA 03-1L19. A set of

contaminants has been identified as chemicals of greatest ecological concerns

(WA 03-1L19), although there are upstream sources of canal contamination, this

study only addresses the contamination resulting from coal tar which include

polynuclear aromatic hydrocarbons (PAHs), benzene, toluene, ethylbenzene, and

xylene. New data generated as part of the public health risk assessment wtll

be reviewed to determine if additional chemicals need to be included tn the

ecological assessment. This work plan will be modified if additional

chemicals of concern need to be assessed.

To the extent possible, the effects of contamination will be assessed by

comparing conditions at the Pine Street Canal site to that of a background or

reference area. The site conditions will be evaluated versus the ecological

endpoint criteria established.

3.6.2.3 Identification of Local Habitat and Species. Site field surveys are

being conducted to characterize the ecological conditions at the site as

described in the work plan for WA 03-1L19. Observations made during surveys

will be used to document overt ecological effects, and to identify potential

pathways for ecological transfer to contaminants. Based on observation of the

vegetation and animals in the area, the ability of the area to support fish

and wildlife will be assessed. In addition, the Natural Heritage Program has

been contacted previously and wtll be recontacted as part of WA 03-1L19 to

determine whether protected species or critical habttat have been identified

in the area.

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3.6.2.4 Risk Characterization. The risk characterization will be conducted m

under EPA WA 03-1L19. The general condition of the ecological communities and

%^^ their value to the overall ecosystem will be assessed. An ecological model

•* (at the least, a descriptive model) is being developed to trace the pathway of

contamination in the ecosystem. Three issues are being addressed to meet the

m objectives of the risk assessment: 1) ecological effects of contamination on

various segments of the ecosystem on and off the site will be defined; 2)

significant environmental resources on the site be that they may be targeted

for protection or enhancement as part of remediation; and 3) the future

ecological potential of the site following remediation.

3.7 TREATABILITY STUDY/PILOT TESTING (TASK 7) - NO ACTIVITIES

m No activities will be included in this Work Plan. The Treatability

Study/Pilot Testing will be completed under a separate Work Assignment

(13-1L19).

* 3.8 REMEDIAL INVESTIGATION REPORTS (TASK 8)

\ „ ^ After Tasks 3 through 6 are complet,e, the M&E team will prepare draft and

final Remedial Investigation (RI) reports.

The RI report will include the information generated in Task 5 for the field

investigation as well as the risk assessment. It will incorporate results of

previous reports where necessary to complete the assessment of nature and

extent of contamination and risk assessment.

A total of 6 copies of the draft RI report will be submitted for EPA review

p and comment. It is anticipated that one review meeting will be held to

discuss EPA comments. The final RI report wtll incorporate these comments. A

^ total of 6 copies of the final RI report will be submitted to EPA.

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3.9 REMEDIAL ALTERNATIVES SCREENING (TASK 9)

The partial draft feasibility study (FS) entitled "Draft Preliminary Analysis

of Remedial Alternatives", prepared by PEER Consultants, includes a

preliminary remedial alternatives screening step (Task 9). ARAR

determination, numerical risk assessment results and remedial response

objective are presented in the draft study in a preliminary form, to be

updated and completed by M&E as parts of Tasks 9, 10, and 11. The revision

will incorporate all data collected as part of the supplemental RI/FS and data

from existing PRP reports. Since the PEER document is expected to provide M&E

with a great deal of information on technologies, alternatives and costs, the

scope of work to complete the remedial alternatives screening portion of the

FS, and to update information based on new data, has been limited as described

in this work plan. Should no additional technologies, process options, or

alternatives be necessary, somewhat less M&E level of effort will be needed.

The "Draft Preliminary Analysis of Remedial Alternatives" report will also be

revised to reflect any concerns or data gaps noted by the EPA.

The objectives of this task are to develop an appropriate range of remediation

options that will be analyzed more fully in the detailed remedial alternatives

evaluation task (Task 10).

The remedial alternatives development and screening task is comprised of seven

subtasks which incorporate task management and quality control activities.

These subtasks include:

Subtask 9.1 Development of remedial action objectives

Subtask 9.2 Development of general response actions

Subtask 9.3 Performance of institutional screening

Subtask 9.4 Identification of media volumes or areas which might require general response actions

Subtask 9.5 Identification and screening of applicable remedial technologies

Subtask 9.6 Evaluation of process options

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Subtask 9.7 Development of remedial alternatives

Subtask 9.8 Screening of remedial alternatives

Subtask 9.9 Preparing a technical memorandum

3.9.1 Development of Remedial Action Objectives

Remedial action objectives consist of media-specific or operable unit-specific

goals for protecting human health and the environment. The objectives will be

as specific as possible but not so specific as to unduly limit the range of

alternatives that can be developed.

Remedial action objectives aimed at protecting human health and the

environment will specify:

• The contaminant(s) of concern

• Exposure route(s) and receptor(s)

• An acceptable contaminant level or range of levels for each exposure route

'Il^j^^l/'

Remedial action objectives for protecting human receptors will express both a

target contaminant level and an exposure route, rather than contaminant levels

alone, since protectiveness may be reached by limiting exposure (through

capping, fencing, deed restrictions, etc.) rather than by reducing contaminant

concentrations.

Preliminary remediation goals wtll be established on readily available

information (e.g., reference concentrations (RfCs) derived from reference

doses (RfDs) and risk-specific doses (RSDs) or frequently used standards

(e.g., ARARs)). The final acceptable exposure levels will be determined on

the basis of the results of the baseline risk assessment and the evaluation of

the expected exposures and associated risks for each alternative. Contciminant

levels tn each media will be compared with these acceptable levels and will be

evaluated on the following factors:

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Remediation goals for all carcinogens of concern, including those with goals set at the chemical-specific^ARAR level, that provide protection within the risk range of 10" to 10"

Remediation goals set for all noncarcinogens of concern, including those with goals set at the chemical-specific ARAR level that are sufficiently protective at the site, and those with goals set at RfCs based on a hazard index of one.

Environmental effects (in addition to human health effects) that are adequately addressed

Exposure analysis conducted as part of the risk assessment that adequately addresses each significant pathway of human exposure identified in the baseline risk assessment

Remedial action objectives specifying the contaminants and media of interest,

exposure pathways, and preliminary remediation goals will be developed for the

site to permit a range of treatment and containment alternatives to be

developed.

3.9.2 Development of General Response Actions

General response actions will be developed based on the list of remedial

action objectives specific to the Pine Street Canal site. Response action

objectives will be based on the results of the risk assessment revision

(Task 6), ARARs, and data quality objectives.

General response actions will be developed for each media or operable unit

identified as contaminated. These general response actions wtll define

containment, treatment, disposal, or other actions that may be taken to

satisfy the remedial action objectives for the site. The list of general

response actions wtll be in conformance with the framework of the current

National Contingency Plan (40 CFR Part 300) and feasibility study guidance

(U.S. EPA, 1988). The EPA will be asked to review and comment on the list of

general response actions before the identification and screening of remedial

technologies is begun.

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General response actions for the Pine Street Canal site may include;

No action

Containment of contaminated groundwater plume

Collection, treatment, and recharge of groundwater

Containment of source area(s)

Excavation and disposal of contaminant source area

Excavation, treatment, and disposal of contaminant source area

In-situ treatment of contaminant source area(s)

3.9.3 Performance of Institutional Screening

The institutional screening mainly identifies the technical compliance of each

potential remedial alternative with applicable federal, state, and local

laws. Consideration must also be given to procedural requirements of the

National Contingency Plan and the extent to which administrative requirements

of other laws must be addressed by the Pine Street Canal remediation.

The applicable and relevant federal regulations include: CERCLA and the NCP,

RCRA Subtitle C, Clean Air Act, Clean Water Act, Coastal Zone Management Act,

Endangered Species Act, Fish and Wildlife Coordination Act, Floodplain

Management, Protection of Wetlands, Rivers and Harbors Act, Safe Drinking

Water Act, TSCA, OSHA, the Hazardous Materials Transportation Act. Vermont

regulations which are applicable and relevant include the following:

Vermont Solid Waste Management Law. Vermont Statutes Annotated, Title 10, Conservation and Development, Chapter 159, Waste Management; Enacted by Vermont Acts of 1977 (Short Citation = 10 VSA 159)

Vermont Underground Liquid Storage Teink Law. Vermont Statutes Annotated, Title 10, Conservation and Development, Chapter 59, Underground Liquid Storage Tanks; Enacted by Acts of I988 (10 VSA 59)

Vermont Solid Waste Management Regulations and Guidelines. Rules of the Environmental Engineering Division, Agency of Environmental Conservation, Chapter 6, Solid Waste Management, effective 8/21/78; and Guidelines for Landfill Disposal of Solid Waste, effective May 1, 1978

3-44

• Vermont Hazardous Waste Management Regulations. Vermont Agency of Natural Resources, Department of Environmental Conservation Regulations on Hazardous Waste Management, Chapter 7, revised effective October 1, 1989

Vennont Underground Liquid Storage lank. Regulations. Agency of Environmental Conservation Regulations Governing Storage Tanks, adopted January 23, 1987

• Vermont Water Pollution Control Law. Vermont Statutes, Title 10, Conservation and Development, Chapter 47, Water Pollution Control, Subchapter 1, Water Pollution Control, enacted by Vermont Acts of 1961

• Vermont NPDES Permit Program Regulations. Agency of Environmental Conservation National Pollutant Discharge Elimination System Regulations

• Vermont Water Quality Standards. State of Vermont, Water Resources Board, Vermont Water Quality Standards; adopted December 13, 1984 (Chapters 1 through 4)

• Vermont Groundwater Protection Rule and Strategy. Chapter 12, .10 V.S.A., Chapter 48, adopted September 8, 1988.

The VT Department of Public Health is in the process of developing new rules

for public water supplies. Because Lake Champlain ts used as a water supply '4^^^^

and the new regulations could be applicable, M&E will contact the VT DPH to

discuss the upcoming rules.

3.9.4 Estimation of Volumes or Areas o f Media which Might Require General Response Actions

During the development of remedial alternatives, an initial determination of

the areas or volumes of each media which might require general response

actions will be made. Defining the areas or volumes of each media must take

into consideration not only the acceptable exposure levels and potential

exposure routes, but also site conditions and the nature and extent of

contamination. To account for interactions between media, response actions

for areas or volumes of media will be refined following the assembly of site-

wide alternatives.

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3.9.5 Identification and Screening of Applicable Remedial Technologies and Process Options

Remedial action technologies are treatment alternatives that may be used alone

or in combination with other technologies to eliminate or specifically reduce

the release of contaminants from a source area and/or stte. These

technologies will be used as a basis for developing remedial alternatives

specific to the Pine Street Canal site. Technology process options refers to

specific processes within a technology type, such as ion exchange and

oxidation/reduction process options within the chemical treatment technology

type. The preliminary list provided in Table 3-4 will be modified and/or

expanded to attain a general list of technology types and process options.

The technology types and process options are organized between no action,

institutional controls, migration control, and source controls.

In this task, remedial technologies will be screened on the basts of technical

implementability at Pine Street Canal retaining these technologies and options

that appear technically feasible and applicable considering site conditions,

technical requirements, and waste characteristics. Unproven technologies,

technologies lacking readily available technical and cost information, and

technologies whose use ts precluded by site or waste characteristics wtll be

eliminated. The physical nature of each contaminated media will affect the

potential selection of different remedial technologies. Proven innovative

technologies will be considered during the screening process. M&E intends to

review technologies discussed in the PEER document, and has based the cost

estimate on the assumption that: the information in the Draft Preliminary

Analysis of Remedial Alternatives will be included in the FS report with

minimal changes, and that up to five additional technologies or process

options will be discussed and up to two additional process options will be

included in the next evaluation step.

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TABLE 3-4. PRELIMINARY REMEDIAL TECHNOLOGIES

General Response Action

No Action:

Institutional Controls:

Management of GroundwaterMigration

Technology Type

• None

• Alternate Water Supply • Future Groundwater Use

Restrictions • Access Restrictions

(fencing) • Deed Restrictions • Environmental

Monitoring

Containment;

Capping

Vertical barriers

Horizontal barriers

Extraction:

On-Site Treatment:

Physical

Chemical

Biological

Off-stte Disposal:

Discharge to POTW

Discharge to surface water

Process Options

• Clay cap • Synthetic membrane

• Slurry walls • Sheet piling • Groundwater interceptor

trench

• Liners • Grout injection

• Extraction/recharge wells

Coagulation/flocculation Oil water separation Air stripping Carbon adsorption

Chemical precipitation Neutralization Oxidation/reduction

Activated sludge Fixed-film biological

treatment

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TABLE 3-4. PRELIMINARY REMEDIAL TECHNOLOGIES

General Response Action

Source Control: (Soil/Sediment Remediation)

' t a ^ ^ ^

Technology Type

Removal:

On-Site Treatment:

Iiranobilizatton

Thermal

Physical/chemical

Biological

In-situ

Off-Site Treatment

Off-Site Disposal

Process Options

• Soil excavation • Associated dewatering

• Stabilization/solidification

• Incineration • Thermal aeration/desorption

• Soil washing/solvent

extraction

• Biological treatment

• Biodegradatton

• Vitrification • Soil flushing • Soil venting • Steam stripping • Off-Site Incineration

• Hazardous waste landfill

3.9.6 Evaluation of Process Options

Technology process options will then be evaluated in greater detail and, tf

possible, one process representing each technology type will be selected.

Process options will be evaluated according to the following criteria:

effectiveness, implementability, and cost. The evaluation will focus on the

effectiveness factor. M&E will review the evaluation of process options

provided in the PEER document; the cost estimate is based on the assumption

that the majority of the information provided in the PEER document evaluation

step will be included in the final FS with minimal changes. M&E also assumes

that up to two additional process options will be included tn this evaluation

step in the final FS.

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The effectiveness evaluation will focus on: (1) the potential effectiveness

of process options in handling the estimated areas or volumes of media and

meeting the remediation goals identified in the remedial action objectives,

(2) the potential impacts to human health and the environment during the

construction and implementation phase, and (3) the reliability and proven use

of the process in respect to the contaminants and conditions at the site.

The technical implementability of various technology types and process options

will be reviewed as an initial screen to eliminate those options that are

clearly ineffective or infeasible at the site.

Economic costs will play a limited role in the screening of process options.

When reviewed, the relative capital and O&M costs will be used rather than

detailed cost estimates.

3.9.7 Development of Remedial Alternatives

Technologies and process options surviving the screening will be assembled

into remedial alternatives to be considered for overall site cleanup. Section

300.68(f) of the current National Contingency Plan (NCP, 1985) and SARA

requires that site-specific alternatives be developed addressing at least the

following five categories:

Alternatives for off-site treatment and disposal

• Alternatives that attain all applicable or relevant and appropriate federal public health or environmental standards

• Alternatives that exceed applicable or relevant and appropriate federal public health or environmental standards

• Alternatives that do not attain applicable or relevant and appropriate federal public health or environmental standards but will reduce the likelihood of present or future threats from the hazardous substances and that provide significant protection of public health and welfare and the environment (This must include an alternative that closely approaches the level of protection of the ARARs.)

• No action alternative

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Remedial alternatives for the Pine Street Canal site will be based upon a

combination of the media-specific technologies remaining following the

Subtask 9.5 evaluation and will be in accordance with the above NCP

requirements. M&E will review the PEER document and assumes that some or all

of the alternatives described will be included in the M&E report, and that up

to two additional alternatives will be developed.

3.9.8 Screening of Remedial Alternatives

The remedial alternatives identified tn each of the categories listed in

Subtask 9.7 will be screened according to the following factors (as detailed

in Figure 3-6): the effectiveness of each alternative, alternative

implementability, and cost. Nine specific criteria are identified for the

detailed evaluation, these criteria wtll be considered during the initial

screening of alternatives to ensure the direction when in the initial

screening is consistent with the direction of the detailed analysis. The

results of the treatability study will be reviewed to assist in the screening

of alternatives. The role of the criteria during remedy selection is

presented in Section 3.10.

Effectiveness is a measure of how well remedial alternatives or components of

remedial alternatives satisfy remedial response objectives. Factors to be

considered include:

Protectiveness of human health and the environment Compliance with ARARs

Contaminant-specific Action-specific Location-specific

Long term effectiveness and performance

Potential need for replacement Resulting risk to workers and community during operation O&M requirements

3-50

\

SCREENING CRITERIA

Effectivonoss

Impiamantabtlity

Cost

NINE EVALUATION CRITERIA

Overall Protection ol Human Health and Environment

Compliance with ARARS

Long-term Eftectivaness and Permanance

Reductions In Toxicity. Mobility, and Volume Through Treatment

Shorl-term Effectiveness

Implementability

Cost

State Acceptance

Community Acceptance

ROLE OF CRITEniA DURING REMEDY SELECTION

"Threshold" Factors

"Primary Balancing" Factors

"Modifying" Considerations

n C U R E 3-6. REMEDLVL ALTERNATIVES SCREENING CRITERIA

Demonstrated performance or potential performance versus lack of or no applicable field experience with similar sites or wastes

• Reduction in mobility, toxicity, or volume through treatment

Permanent and significant Use permanent solutions and alternative treatment or resource recovery technologies Irreversibility of treatment

• Short-term effectiveness

During construction During implementation

Implementability is a measure of the ease that remedial alternatives or

components can be practically applied to remediation of a site. Factors to be

considered include:

Technical feasibility

Short-term

, Ability to construct technology

Long-term

. Ease of undertaking additional remedial action, if necessary Ability to monitor and review effectiveness of temporary remedy Ability to maintain O&M requirements Length of time to achieve remediation

Administrative Feasibility

Short-term

Availability of off-site transport, storage, and disposal (TSD) services

. Availability of necessary equipment and specialists

Long term

. Ability to ensure long term TSD capacity off-site

3-52

Preliminary cost estimates will be provided at this stage of alternatives

evaluation only if varied treatment alternatives provide similar treatment

capabilities. The accuracy range of these estimates is set by SARA guidance

at -50 to +100 percent. Alternatives with similar benefits can be eliminated

on a cost basis if the cost for one of the similar alternatives exceeds the

cost for another by at least an order of magnitude.

Alternatives with proven innovative technologies will be carried through the

screening process if there is reasonable belief that they offer potential

for: (1) improved treatment performance or implementability, (2) minimization

of adverse impacts compared to other alternatives, or (3) lower costs than

demonstrated technologies.

State and community acceptance of the alternatives will be addressed during

the screening process.

M&E assumes, for cost estimating, that the information for the initial

screening in the PEER document will be reviewed by M&E, and that the

information will be included in the final report with minimal changes. M&E

will provide the information on up to two additional alternatives, necessary

to screen the alternatives.

3.9.9 Preparing a Technical Memorandimi

A technical memorandum will be prepared and submitted to the EPA discussing

the results of Subtasks 9.1 through 9.8.

3.10 REMEDIAL ALTERNATIVES EVALUATION (TASK 10)

The remedial alternative evaluation task consists of six subtasks which

incorporate task management and quality control activities. These include:

Subtask 10.1 Detailed Technical Evaluation

Subtask 10.2 Detailed Public Health Evaluation

Subtask 10.3 Detailed Environmental Evaluation

3-53

Subtask 10.4 Detailed Institutional Requirements Evaluation

Subtask 10.5 Detailed Cost Evaluation

Subtask 10.6 Preparing a Technical Memorandum

The nine evaluation criteria considered as part of the screening step and

presented in Figure 3-6 serve the basis for conducting the detailed analyses

and subsequently selecting an appropriate remedial action. It should be noted

that overall protection of human health and the environment, and compliance

with ARARs are considered the two threshold criteria in that each alternative

must meet them. The five primary criteria on which the detailed analysis is

based are: long-term effectiveness and performance; reduction of toxicity,

mobility, and volume through treatment; short-term effectiveness;

implementability; and cost. The final two criteria, state and community

acceptance, are modifying considerations to be evaluated following EPA comment

on the RI/FS report. An initial evaluation will be provided as part of the

detailed institutional requirements evaluation. Each task outlined below wtll

list the criteria being evaluated.

3.10.1 Detailed Technical Evaluation

Based on the technical screening of the alternatives described above, the

remaining remedial alternatives will be further defined tf necessary and

technically evaluated tn greater detail. Criteria evaluated will include:

Long-term effectiveness and permanence; reductions tn toxicity, mobility, and

volume through treatment; short-term effectiveness; and implementability. The

results of the treatability study will be reviewed to assist in the detailed

technical evaluation.

The technical evaluation will include the following:

• Description of the appropriate treatment, storage, and/or disposal alternatives

3-54

• Discussion of how each alternative does (or does not) comply with specific requirements of other environmental programs and a description of special design features that could be implemented to achieve compliance (When an alternative does not comply, the discussion will include how the alternative prevents or minimizes the migration of chemical constituents and the associated public health or environmental impacts.)

• Outline of the operation, maintenance, and monitoring requirements of the remedial alternative

• Identification of the potential off-site disposal facilities, if needed, to ensure compliance with applicable RCRA and other EPA environmental program requirements

• Identification of temporary storage requirements and off-site disposal needs and description of the transportation plans as appropriate

Description of whether the alternative results in permanent treatment or destruction of the chemical constituents

• Outline of the safety requirements for remedial implementation

• Description of the special engineering requirements or site preparation considerations pertinent to the remedial alternative

3.10.2 Detailed Public Health Evaluation

Work conducted under this subtask wtll assist in assessing two of the nine

evaluation criteria: overall protection of human health, and compliance with

public health ARARs. Each alternative that passes initial screening will be

assessed in terms of the extent to which tt mitigates long-term exposure and

protects public health both during and after completion of the remedial

action. The no-action assessment conducted as part of Task 6 will

characterize and describe the levels of chemical constituents on-site,

potential exposure routes, and potentially affected populations. The effect

of "no action" will be described tn terms of short-term effects, long-term

exposure to contamination, and resulting public health impacts. Each remedial

alternative will be evaluated to assess the level of exposure and the expected

reduction of exposure over time. The relative reduction in public health

impacts for each alternative will be compared to the no-action level. For

management of migration measures, the relative reduction in impact wtll be

3-55

determined by comparing residual levels of each alternative with existing

criteria, standards, o r guidelines acceptable to the EPA. For source control

measures, or when criteria, standards, or guidelines are not available, the

comparison will be based on the relative effectiveness of technologies. The

no-action alternatives will serve as the baseline for the analyses. A

qualitative assessment of risk to workers and the community during the

implementation of remedial measures will be provided.

3.10.3 Detailed Environment:al Evaluation

Work conducted under this subtask will assist in assessing two of nine

evaluation criteria: overall protection of the environment, and compliance

with environmental ARARs. The environmental assessment for each alternative

will include, as a minimum, an evaluation of both the beneficial and adverse

effects of the response and an analysis of the necessary measures required to

mitigate the adverse effects. The no-action alternative, as evaluated in

Task 6, will describe the current site situation and the anticipated

environmental conditions if no action is taken. The no-action alternative

will serve as the base line for the analysts.

3.10.4 Det^ailed Institutional Requirements Evaluation

Work conducted under this subtask will be used to assess three evaluation

criteria: compliance with ARARs, implementability, and community

acceptance. For each of the alternatives carried through the technical

screening outlined in Section 3.9, several administrative issues will be

considered. These include the likelihood of obtaining necessary

agency/governmental approvals for the given remedial alternative, the

probability of favorable community response to the alternative, and the need

for coordinating implementation of the given remedial measure with other

agencies.

3-56

3.10.5 Detailed Cost Evaluation

For those alternatives passing the screening procedures described tn

Section 3.9, cost estimates for each remedial alternative will be developed as

part of the cost evaluation criteria. The accuracy of the estimates will be

+50 to -30 percent. These estimates will incorporate the following elements:

• Capital costs

• Direct

- Labor, equipment, and materials

- Process equipment - Site development - Utilities - Disposal of wastes (including transportation)

• Indirect

- Engineering - Legal fees - Startup costs - Contingency

• Operations and maintenance costs

- Operating labor - Maintenance materials, labor, and equipment - Operating costs - Sampling and analysis - Administrative and legal costs

The sources of the individual c o s t s will be docoraented and will include vendor

quotes, discussions with contractors, cost data from the remediation of

similar sites, and data from estimating guides and EPA cost documents.

The alternatives passing the final screening wtll be evaluated by a present

worth and sensitivity analysis using appropriate time factors and a discount

rate of 10 percent.

3-57

3.10.6 Preparing a Technical Memorandimi

A technical memorandum summarizing the remedial alternatives evaluation will

be prepared and submitted to the EPA for review and comment. After a meeting

is held with the EPA to resolve any comments, the Feasibility Study Report

(Task 11) will be prepared.

3.11 FEASIBILITY STUDY REPORTS (TASK 11)

The information compiled during the Remedial Alternatives Screening (Task 9)

and the Remedial Alternatives Evaluation (Task 10) will be presented to the

EPA in a Draft Feasibility Study Report. The Feasibility Report may

incorporate information compiled for FS conducted by PEER Consultants;

however, all such information would be verified. For the purposes of the cost

estimate it has been assumed:

• One source area will be identified

• A maximum of 20 preliminary remedial alternatives will be developed Sind a maximum of 6 will be evaluated in detail. Each will include source control and management of migration, as appropriate

\ ^ l ^ ^ ^

Following comments from the EPA, a final feasibility study report will be

prepared. The cost estimate is based on the assumption that all operable

units are developed and the results presented in one report.

3.12 POST RI/FS SUPPORT (TASK 12)

Post RI/FS support activities for this assignment will occur between the

completion of the FS and the completion and signing of the stte Record of

Decision (ROD). These support activities include technical support of the ROD

and community relations activities. This task ts already funded under work

assignment 5-1L19 (Pine Street RI/FS Support); however, additional funding

under this assignment (10-1L19) may be required when those funds are

expended. No additional funding is included in this cost estimate.

3-58

3.12.1 Support Preparation of the ROD

After receipt of public comment on the proposed plan, and tf requested by EPA,

M&E will assist in preparing the Record of Decision (ROD) for the site, which

documents the remedial action plan. If required by EPA, M&E will provide

technical briefings as required by EPA to present alternatives to management

review meetings. These activities have not been included in the cost

estimate.

3.12.2 Preparing a Responsiveness Sumnary

The M&E team will assist in the coordination and preparation of draft and

final responsiveness summaries. This task includes compiling and summarizing

public comments received during the FS/proposed plan public comment period and

working with the EPA and contractor technical staff to formulate responses to

these comments. A draft and final responsiveness summary will be prepared and

delivered to the EPA. These activities have not been included tn the cost

estimate.

\ ^ ^ 3.12.3 Publishing Public Notices

The M&E team wtll prepare and coordinate publication of one public notice tn a

local newspaper serving the Pine Street Canal stte community. This public

notice will announce the Record of Decision. A copy of the public notice as

it appeared in the newspaper will be submitted to the EPA for inclusion in the

Administrative Record and information repositories. These activities have not

been included tn the cost estimate.

3.12.4 Other Tasks as Required

The M&E team will conduct other tasks for the EPA as necessary. Activities

which may be requested by the EPA include:

• Preparation of predesign report

• Attendance at additional public meetings

3-59

^ • Changes to the proposed plan

Preparation of FS addendum

These activities have not been included in this cost estimate.

••

^

••

3.13 ENFORCEMENT SUPPORT (TASK 13)

Activities for this assignment will occur on an as-needed basis during the

RI/FS process and include both community relations activities and technical

support activities. This task is already funded under work assignment 5-ILI9

(Pine Street RI/FS support); however, additional funding may be required when

those funds are expended. No additional funds have been added to this

(10-1L19) cost estimate.

m 3.14 MISCELLANEOUS SUPPORT (TASK 14)

\., ,

•I

_

The M&E team will provide miscellaneous support as requested by the EPA.

Activities for the assignment will occur on an as needed basis during the

RI/FS process and may include site visits, special research, or any tasks as

specified by EPA. This task ts already funded under work assignment 5-1L19

(Pine Street RI/FS support); however, additional funding may be required when

those funds are expended. A total of 100 technical hours as well as two round

trips to Burlington, Vermont are included in the cost estimate for this work

assignment (10-1L19).

3.15 EXPEDITED RESPONSE ACTIONS (ERA) PLANNING (TASK 15)

"•

H

M&E will procure a qualified subcontractor and provide oversight to provide

three access gates to the site, overpack leaking or damaged existing drums

already on site, place drums on pallets on a prepared gravel surface, and

secure the drums with fencing and a locked gate. The scope of work for this

task is detailed in a M&E technical memorandum to EPA dated August 9, 1990.

3-60

3.16 ADMINISTRATIVE RECORD (TASK 16)

An a(iministrative record to support the Record of Decision (ROD) will be

prepared for the EPA. This task is already funded under work assignment

5-1L19, however; additional funding may be required when funds are expended.

It is estimated that approximately 10 hours/month for a period of 18 months is

required for this task.

^(^^^^

3-61

SECTI(»I FOUR

DOCUMENT PRODUCTION AND DISTRIBUTION

The M&E team will produce six (6) copies of each of the following documents as

required by the EPA in the scope of work (except where noted). Due dates for

some deliverables have not yet been determined.

Draft Supplemental RI/FS Work Plan

Final Supplemental RI/FS Work Plan

Cost Estimate

Draft Health and Safety Plan

Final Health and Safety Plan

Draft Quality Assurance Project Plan

Final Quality Assurance Project Plan

Draft Field Sampling Plan

Final Field Sampling Plan

Meeting Minutes Technical Memorandum

PEER Data Evaluation Technical Memorandum

Data Submittal

Selection of Chemicals of Concern Technical Memorandum

Draft Supplemental RI Report

Final Supplemental RI Report

Remedial Alternatives Screening Technical Memorandum

Remedial Alternative Evaluation Technical Memorandum

Draft Supplemental FS Report

Final Supplemental FS Report

(Task 1) July 16, 1990

(Task 1) September 10, 1990

(Task 1) July 16, 1990

(Task 1) August 20, 1990

(Task 1) October 1, 1990

(Task 1) August 20, 1990

(Task 1) October 1, 1990

(Task 1) August 20, 1990

(Task 1) October 1, 1990

(Task 1) As required

(Task 1) To be determined

(Task 5) To be determined

(Task 6) To be determined

(Task 8) To be determined

(Task 8) To be determined

(Task 9) To be determined

(Task 10) To be determined

(Task 11) To be determined

(Task 11) To be determined

4-1

The M&E team will also prepare monthly progress reports for the duration of

the work assignment.

M&E will furnish the following people with the specified number of documents

both in the draft and final form. All documents will be submitted with a

computer disk containing the document tn Word Perfect Version- 5.0.

Person Position Number of Copies

Mr. Joshua Nemzer Contracting Officer 1 Ms. Nancy Barmakian Project Officer 1 Mr, Christian Rascher Remedial Project Manager 4

Documents will be forwarded to the EPA contracting officer and the EPA project

officer.

y \ ^ ^ ^

4-2

gi|

0

SECTION FIVE

WORK SCHEDULE

"* The work schedule for this assignment is shown in Figure 5-1. The schedule

has been developed based on:

• The scope of work as described in Section 3 of this work plan

• • Standard laboratory turnaround times (5 weeks) for soil boring samples and accelerated turnaround times (2 weeks) for sediment and groundwater.

if • Accelerated data validation turnaround times (2 weeks) for all

samples.

•• • EPA approval of all documents within 3 weeks of submittal.

A detailed schedule for the field investigation program (Task 3) is presented

in Figure 5-2.

The schedule for completion of all tasks and subtasks ts extremely aggressive

in order to complete the draft FS on time. The schedule assumes that no

^i^^v delays will be encountered due to weather, subcontractor mobilization,

unexpected analytical problems, unexpected or changed field conditions, or

M changes in scope. M&E has used the scheduled task durations and deliverable

dates for the purpose of cost estimation. Should a different schedule or

change in the deliverable dates be required, a revision tn the level of effort

(LOE) may be necessary.

5-1

• • • I ^ / I I I I I I f i

Description

TASK 1 5/01/90 PROJECT PLANNING

TASK 2 COMMUNITY RELATIONS

TASK 3 9/25/90 FIELD INVESTIGATION

TASK 4 10/01/90 OATA VALIOATION

TASK 5 10/16/90 DATA EVALUATION

TASK 6- 1/09/91 RISK ASSESSKCNT

TASK 7 TREATABILITY STUOY

TASK B 1/09/91 DRAFT RI REPORTS

FINAL RI REPORTS

TASK 9 1/23/91 RA SCREENING

TASK 10 3 /20/91 RA EVALUATION

TASK 11 4/17/91 DRAFT FS REPORTS

FINAL FS REPORTS

TASK 12 5/15/91 POST R I / F S SUPPORT

TASK 13 6/04/90 ENFORCEMENT SUPPORT

TASK 14 B/04/90 MISCELLANEOUS SUPPORT

TASK 16 6/04/90 ADMINISTRATIVE RECOFC

PINE STREET SUPPLEMENTAL RI/FS U.S. EPA ARCS

1990 K m a K D M Caailiii E H

9/25/! >0

I I I I ' I 1

• • f t B l l i y i l l l l l f t l

SubtasKD**crlptlon

3 .1

PINE STREET SUPP. FIELDU.S. EPA ARCS

ACTIVITIES

Mobillzation/DoBobillzstlon

Subtask 3.2 D r i l l i n g

Rig 1 Deep Well. Borlngi

Rig 2 Osip well. Borings

Rig 3

Subtask

Shallow Mails, Borings

3.3

Surface Water/sediaent saspling

Subtask 3.4

Groundwater 8aa4>llno 26

Subtask 3 .5

Surveying

Subtask 3.6

Hydrogeologic ABBeaement

SECTION SIX

STAFFING AND ESTIMATED LABOR

M&E team Project Manager, Ms. Martha Zirbel (M&E), will coordinate and direct

all activities for this work assignment.

M&E's anticipated LOE is summarized in Table 6-1 for each task by the EPA

professional level.

6-1

TABLE 6-1. ESTIMATED LABOR, PINE STREET CANAL SITE RI/FS

HOURS

Prof. Prof. Prof. Prof. Tech.

Task No. Level 4 Level 3 Level 2 Level 1 Level 2 Clerical

1) Project Planning 744 285 880 550 52 252

2) No Activities

3) Field Investigation 468 1750 1610 40

4) Sample Analysis/ Validation 128 - 629 - - -

5) Data Evaluation 390 80 1140 550 106 313

6) Risk Assessment 62 116 402 248 - 48

7) No Activities

8) RI Report 105 - 520 200 56 200

9) RA Screening 82 346 494 40 90 118

10) RA Evaluation 86 541 499 0 40 100

"V / 11) FS Report 80 216 212 0 24 56

12) Post RI/FS Support

13) Enforcement Support

14) Miscellaneous Support 60 20 20 - - 10

15) ERA 46 56 - 174 - 20

16) Administrative Record 40 80 80 - - -

TOTAL .2291 1740 6626 3372 408 1117

6-2

SECTION SEVEN

CASH FLOW SCHEDULE

M&E has prepared a cash flow schedule based on schedule and budget information

included in Section 5.0 and 6.0. Cash flow estimations for all tasks have

been based on the approximate schedule anticipated by M&E. The cash flow

schedule is shown in Figure 7-1.

7-1

I I I I I I I I I I I I

— BCWS(E)

^ ^ ^ ^

SECTION EIGHT

SUBCONTRACTING PLAN

The M&E team anticipates using the following subcontractors for the Pine

Street Canal Supplemental RI/FS:

Work Item

Field Test Method Development, SAS Method Development, CLP Analysis

Data Validation: RAS SAS

Drilling

Waste Disposal

Surveying

Mobile Laboratory

Subcontractor

Enseco

Dynamac

New England Boring

To be determined

Diversified Technologies Corporation

North Haven, CT

Weston, Inc.

8-1

SECTION NINE

FIELD EQUIPMENT

The following equipment wtll be needed for the field investigation/sampling

effort:

Quantity Item

3 Conductivity Meter 3 pH Meter 3 Electronic Water Level Indicator 3 Photovac Photoionization Detectors with Calibration Gas and

Charger 3 Draeger Pumps With Tubes

Fire Extinguisher (Class A, B, C) Brainard-Kilman Positive Displacement Pump Geoguard Bladder Pump and Other Pumps, as needed Centrifugal Pump Rental Cars Fax Machine Telephone Answering Machine Field Trailer W/Telephone (in addition to mobile lab) Eckman Dredge Boat

The following equipment wtll be needed for the hydrogeologic assessment:

Quantity Item

In-situ Data Logger Equipped with Pressure Transducer Solid Slug for Performing Aquifer Testing Solinst Water Level Indicator Pygmy Current Flowmeter Oil-water Interphase Probe

3-6 Continuous Recorders for Groundwater Elevations

9-1

SECTION TEN REFERENCES

APHA-AWWA-WPCF. 1985. s tandard Methods for the Examination of Water and Wastewater, 16th Edi- ion.

Bouwer, H. and Rice, R.C. 1976. "A Slug Test for Determining Hydraulic Conductivity of Uncorfined Aquifers with Completely or Partially Penetrating Wells," water Resources Res. , Vol. 12.

Doll, CG. 1961. "Centennial Geologic Map of Vermont," Vermont Geological Survey.

Ecology and Environment, Inc., June 23, 1982. Pre l iminary S i t e Assessment and S i t e Inspec t ion for Pine S t r e e t Canal, Pine S t r e e t , Burl ington, Vermonc, Final Report. Reporc prepared for the U.S. Environmental Protection Agency.

Hvorslev, M.J. 1951. "Time Lag and Soil Permeability in Groundwater Observations," Army Corps of Engineers, Waterways Exp. s t a . Bul l . 36. Vicksburg, MI.

Metcalf & Eddy. September 1989. "Standard Operating Procedure, Section 7.0: Sampling, Revision No. 3."

PEER Consultants, P.C. Occober 13. 1989. Draft Amendment for Work Plan Volume I - Technical , For Pine S t r e e t Canal S i t e Remedial I n v e s t i g a t i o n / F e a s i b i l i t y Study, Burl ington, Vermont. Report prepared for the U.S. Environmental Prot ection Agency.

" I H ^ ^ ^ ^ '

PEER Consultants, P.C. May 1990. Draft Remedial I n v e s t i g a t i o n Report for Pine S t r e e t Canal S i t e , Burl ington, Vermont. Report prepared for the U.S. Environmental Protection Agency.

PEER Consultants, P.C. March 20, -989. work Plan Volume I - Technical . For Pine S t r e e t Canal S i t e Remedial I n v e s t i g a t i o n / F e a s i b i l i t y Study, Burl ington, Vermont. Report prepared for the U.S. Environmental Protection Agency.

State of Vermont Agency of Transportation. April 3, 1990. Proposed Urban Improvement, City of Burl ington, County of Chit tenden, Southern Connector (Champlain Park Way), Prel iminary Plans .

U.S. Environmental Protection Agency. July 1988. Contract Laborazory Program, Statement of Work for Inorganics Analysis , Mult i -Media/Mult i -Concentration .

U.S. Environmental Protection Agency. February 1988. Contract: Laboratory Program, Statement of Work for Organics Analys is , Mult i -Media/Mult i -Concentration .

10-1

m U.S. Environmental Protection Agency. May 1989. Exposure F a c t o r s Handbook. EPA/600/8-89/043.

^ ^ U.S. Environmental Protection Agency. October I988. Guidance fo r Conduct ing •* Remedial Investigations and Feasibi l i ty Studies under CERCLA.

EPA/540/G-89/004.

^g, U.S. Environmental Protect ion Agency. February 1983. i n t e r i m G u i d e l i n e s and Specifications for Preparing Quality Assurance Project Plans, QAMS-005-80, EPA-600/4-83-004.

" U.S. Environmental Protection Agency. March 1983. Methods f o r chemical Analysis of Water and Wastes, EPA-600/4-79-020.

m U.S. Environmental Protection Agency. February 1989. Region I L a b o r a t o r y Data Validation, Functional Guidelines for Evaluating Inorganics Analysis. Report prepared for the Hazardous Site Evaluation Division of the U.S. Environmental Protection Agency.

U.S. Environmental Protection Agency. November 1988. Region I L a b o r a t o r y Data Validations, Functional Guidelines for Evaluating Organics Analysis.

m Report prepared for the Hazardous Stte Evaluation Division of the U.S. Environmental Protection Agency.

U.S. Environmental Protection Agency. June 1989. Region I Supplemental Risk Assessment Guidance for the Superfund Program, Draft Final. EPA 901/5­89-001.

U.S. Environmental Protection Agency. December 1989a. Risk Assessment Guidance ^tma^ for Superfund Volume I, Human Health Evaluation Manual. EPA/540/1-89/002.

U.S. Environmental Protection Agency. December 1989b. Risk Assessment Guidance for Superfund Volume I I , Environmental Evaluation Manual. EPA/540/1-89/002.

•• U.S. Environmental Protection Agency. April 1988. Superfund Exposure Assessment Manual. EPA/540/1-58/001.

H U.S. Environmental Protection Agency. November 1986. rest Methods f o r Evaluating Solid Waste, SW-846, 3rd Edition.

10-2