fat* fit.

-WestinghOUSe ,''' July 24, 1997 n standee/EleCtrlC Corporation Pittsburgh Pennsylvania 15222-1364

Mr. Charles TordellaPennsylvania Department of Environmental Protection >Northwest Regional Office230 Chestnut Street ,Meadvijle, PA 16335 '

RE: REVISED PILOT PROGRAM WORK PLANBUILDING INTERIOR DECONTAMINATION .SHARON TRANSFORMER PLANT - SHARON, PENNSYLVANIA

Dear Mr. Tordella . ,

Westinghouse Electric Corporation (Westinghouse) has revised the Pilot Program WorkPlan in accordance with your letter dated July 7,1997. Enclosed are three copies.Westinghouse is proceeding with implementation of the work scope described in thisdocument. For scheduling purposes we have assumed July 28,1997 as the start date.

To assist in your review of the document we have briefly summarized our responses to ~/your comments. We have discussed several comments with you previously.

Comment 1: Section 2.2/Site Description (and remainder of the Work Plan)The Oil House is listed in the building description but is not discussed further in the PilotProgram Work Plan or identified in the Figures. The walls of the Oil House building areheavily stained with oil indicating the potential for high PCB contamination and it shouldbe included in the Pilot Study Area. Also, the tank removal area and the transformertesting pit area should be identified in the Figures and should be included in the PilotStudy.

RESPONSE: Demolition (rather than cleaning/reuse) of the Oil House and thetanks is anticipated by Westinghouse. These will be excluded from the pilot

; program. The transformer testing pit has been previously cleaned on two . 'occasions and previous test results on water in this pit show no presence ofpolychlorinated biphenyls (PCBs). Therefore, this area is not included in the pilotprogram. However, characterization may be necessary prior to future use of thearea. The transformer testing area has been identified on Figure 2.

;1R30320'2

Mr. Charles TordellaJuly 24, 1997

Comment 2: Section 2.4.2/TablesEPA also collected wipe/sweep samples for dioxin analysis and collected a water samplein the testing pit. Please provide this information in the text and in the tables. It wouldbe helpful to explain why Westinghouse is'not sampling for dioxins/rurans for the PilotStudy. '

RESPONSE: The water sample collected by U.S. Environmental ProtectionAgency (USEPA) is not associated with pilot program activities. Although thewater in the H-80 area will be addressed prior to reuse of this portion of thebuilding, it is not considered to be related to the cleaning of surfaces. Existingdioxins/furans wipe sample results have been added to the plan as backgroundinformation. ' " - , , '

Based upon the remedial investigation (RJ) data dioxins/rurans are not consideredto be risk drivers and are not constituents of interest. Also, it is expected that thesame cleaning techniques that are effective for PCBs will also be effective fordioxins/furans if they are present; this is based upon the similar physicalproperties of these compounds. . ' •> »

Comments: Section2.4/LastParagraphPlease correct the highest lead level in sweep samples to be 11,400 mg/kg.

RESPONSE: This modification has been made. ,

Comment 4: Section 3.2/Historical PCB Use AreasAny areas of Building I used for manufacturing operations should be included in thebaseline characterization at a minimum.

RESPONSE: Building I will be included in the baseline characterization.

Comment 5; Sections 3.8,3.9 and 3.10/Overhead Structures, Exhaust Fans andLight Fixtures ,Although dust or residue would be anticipated on overhead structures, fans, or lightfixtures, representatives of each should be selected for sampling regardless of staining,dust, or residues. These representative overhead structures, exhaust fans and light. fixtures should be selected in an area of high chemical (PCB) use.

RESPONSE: It is Westinghouse's intent to sample representative structures,including those in the high usage areas. The pilot program areas will be identifiedand submitted to Pennsylvania Department of Environmental Protection (PADEP)as described in Section 4.11.

,1R303203

Mr. Charles Tordella vJuly 24,1997Page!

Comment 6: Section, 3.1 ISubfloor Items (Commentary)It may be that utility trenches captured spilled PCB oils and should be inspected carefullyin the baseline characterization. Any special techniques necessary for cleanup of theseareas (especially considering that utility lines are present) should be considered for the ,Pilot Study. "

RESPONSE: Representative subfloors will be selected to undergo pilot techniques.It is envisioned that several techniques will be evaluated on the subfloor structuresduring the pilot program.

Comment 7: Section 4.3/Technologies Evaluation for PSPAlthough it is technically not a surface cleaning technique, removal and disposal shouldbe given serious consideration in the Pilot Study Program for certain highly contaminatedareas (e.g. oil soaked wood flooring). Please revise the text accordingly.

RESPONSE: It is recognized mat removal of certain structures (i.e., wood floors)may be more advantageous than cleaning. Section 4.3 was revised to includeremoval as, a possible technology.

Comment 8: Section 4.6/Sampling and Analysis PlanPlease revise the Sampling and Analysis Plan to include real-time air sampling within thebuilding.

' • ' • - - ' ' • • ' . • : : • ' . ' - - ' ' . - .RESPONSE: Air sampling for remediation worker protection will be in the health -and safety plans as described in Section 4.9. >

Comment 9: Sections 4.6.6 and 4.6.7/Analytical Program and Data QualityAssurance , ,Please clarify whether additional documentation for these sections will be submitted with.the addendum to the Work Plan for review and comment. Also, please clarify whetherthese portions of the Work Plan will address the Pilot Study area only or the entire vbuilding cleanup. If previous submittals under the RI/FS are being utilized for samplingmethodology and data quality assurance, please reference them accordingly.

RESPONSE; In response to Comment 12, the contents of the addendum will beincorporated into the baseline characterization document. As part of the PilotProgram Work Plan, these sections only address the pilot program. The revisedwork plan refers to the applicable portions of the Remedial Investigation QualityAssurance Project Plan. • .

L57/UI

Mr. Charles TordellaJuly 24, 1997

Comment 10: Section 4.7/Cleanup Criteria DevelopmentI J The October 1996 Baseline Risk Assessment for the Middle Sector Building should be~"\ utilized in the development of cleanup criteria. The text should be revised to reflect this.

• / . ' . ' .RESPONSE: The relevant portions of the risk assessment developed by USEPAalong with published data from the organizations listed in Section 4.7 will be

' reviewed as background information. The text was revised to reflect this *comment.

Comment 11: Section 4.8/Future Development Evaluation (Commentary)The development plan produced by the Shenango Valley Redevelopment Corporationmay be useful for this evaluation. As indicated by the extent of floor replacement doneby Winner Steel in the A/B Building, an analysis of floor integrity is critical. *

RESPONSE: The SVRC development plan will be utilized as a reference. Floorintegrity will be qualitatively reviewed but is beyond the scope of the pilotprogram. , , .' < • ' ' • • • • ' , - 'Comment 12: Section4.il/Reporting

The first sentence is contusing. Please revise,

The summary of the baseline characterization findings should precede, or be submittedI J together with the addendum for sampling frequency and anticipated locations so that the*r Agencies can properly evaluate the sampling addendum. "

In addition to the techniques and areas selected for the pilot study, the addendum should, include the HSP and MHP specific to each technology. Please revise the text ^

accordingly. ( .

: >. RESPONSE: The first sentence has been revised. The plan has also been revisedto include the sampling frequency and locations in the baseline characterizationfindings submittal. The HSP and a general description of the techniques to be

- used will be developed by the selected contractors (Section 4.4) after the baseline• . characterization is completed.

Westinghouse acknowledges the PADEP on-site notification request. Our consultantsand contractors will endeavor to give two weeks notice whenever possible. However,given the schedule and Westinghouse's commitment to return these buildings to theeconomic benefit of the Sharon community in a timely manner, we cannot guarantee twqweeks notice in all instances. - ' ' . '

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Mi*. Charles Tordella .July 24, 1997 >Page 5 • ' - . . - . . . • ' - . ; ' _ .

The on-site baseline characterization activities are scheduled to begin August 11,1997.We currently anticipate part-time,-0n-site activities through the end of August.

• ' • • '• •Please contact Mr. Kenneth Bird of Cummings/Riter Consultants, Inc. (412/373-5240) or

myself with any questions. _

Respectfully submitted,Westinghouse Electric Corporation

Gordon T. TaylorPrincipal EngineerEnvironmental RemediationLaw & Environmental Affairs

EnclosuresGTT/KJB/dmw

pc: Mr. Vie Janosik -USEPA (five copies)Mr. Kenneth Bird - Cummings/Riter (w/o enclosures)

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unUMMINGS

CONSULTANTS, INC.

PILOT PROGRAM WORK PLANINTERIOR CLEANUP - MIDDLE SECTOR BUILDINGS

SHARON, PENNSYLVANIA FACILITY

PREPARED FOR:WESTINGHOUSE ELECTRIC CORPORATION

WESTINGHOUSE BUILDING11 STANWIX STREET

PITTSBURGH, PA 15222

/.0

PROJECT No. 93111,30/01 2JULY25,1997 . ~

339 Haymaker Road -Parkway Building 'Suite 201 • Monroevffle, PA 15146(412) 373-5240 • FAX (412) 373-5242 • E-Mail: crc@nb.net ,

Regional Office • 258 Chapman Road • Suite 202 • Newark. DE19702 • (302) 731-9668 • FAX (302) 731-9609 • E-Mail: Crogmagpage.com

TABLE OF CONTENTS

. - '. '• . PAGE

LIST OF TABLES AND FIGURES.;...............'............,.........,....................,......,....f.......iii

1.0 INTRODUCTION.......,......_

2.0 BACKGROUND ....................... ...»............»......................,.................,...........32.1 GENERAL .....;.....,.........,...............;i.................................;.........................32.2 SITE DESCRIPTION ...............,...............,....».........................,.......,............32.3 WESTINGHQUSE OPERATIONS HISTORY ....................................................42.4 SUMMARY OF EXISTING DATA..................................................................6

2.4.1 Wipe Data (1985).....,..............................t...................................,62.4.2 Wipe and Sweep Data (June 1995)..,.............,.............,..-.............62.4.3 Air Samples...................................................................................7

3.0 POTENTIALLY IMPACTED SURFACES.........................,.........................!....83.1 GENERAL ..................................................................................,...............83.2 HISTORICAL PCS USAGE AREAS.............................................................3.3 ' PAINTED SURFACES ..................................................................................93.4 FLOORS...................................................................................................lo3.5 CEILINGS...........................»....»...,........................,.............................»3.6 WALLS...................!...............,............................................;.;.................!!3.7 WINDOWS.....;.......,...,.......;..............,...................;....................................! 13.8 OVERHEAD STRUCTURES ....,......................................„.....'........................ 113,9 EXHAUST FANS.................,.........;...........,*....,.....M.....................................!23.10 LIGHT FIXTIES.....,....,...........................................,.................,.3.11 SUBFLOOR ITEMS...................... ................................................................12

' ' . ( ' . . ' '4.0 PILOT PROGRAM TASKS,................................................,..............................13

4.1 TASK 1 - BASELINECHARACTER1ZATION.....................................;............134.2 TASK 2-PILOT STUDY AREA SELECTION.................................................144.3 TASKS -TECHNOLOGIES EVALUATION FOR PILOT PROGRAM .................. 15

4.3.1 Mechanical..............;......................................,..............,..........»..154.3.2 Chemical ...........................;........................................................ 174.3.3 Encapsu!ation...,...............................................»..........................174.3.4 Combination of Categories ..........................................................18

4.4 TASKA -SELECTION OF CONTRACTORS FOR PILOT PROGRAM..................! 8.

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TABLE OF CONTENTS(CONTINUED)

' . ' [ • • ' • ' - " • ' - . - ' ' " " • • • ; 'PAGE

4.5 TASK 5 -PILOT PROGRAM .....,,........,........,...................................,.......,...i84.6 TASK 6 -SAMPLING AND ANALYSIS PLAN........... .................................. ...19

4.6.2 Wipe Samples ......................,...............M......................................194.6.3 Residue................................................... ........*......... .................... 204.6.4 .Material Samples ................... ............,................,,....,.....,.........:..204.6.5 Paint Samples.................../.........................-......:.........>.....,..........204.6.6 Analytical Program .................................................................... .204.6.7 Data Quality Assurance ...............................................................21

4.7 TASK 7 -CLEANUP CRITERIA DEVELOPMENT..........................................4.8 TASK 8 -FUTURE DEVELOPMENT EVALUATION..........;..................,........4.9 TASK 9 - HEALTH AND SAFETY... ..................................................... ........234.10 TAsk 10 - MATERIAL HANDLiNG,...........,............................................,....23

4.10.1 BulkWastes.......................,.......»................................................234.10.2 Fluids ............................... ......;..............»,...,...........,....................24

4.1 1 TASK 1 1 - REPORTING .,......................,..............................,....i...............,......24

5.0 PERSONNEL ................ .,..........................;..............................»....................,...25

6.0 SCHEDULE.....,......................».....................«.............................:..»»

REFERENCES

TABLES

FIGURES ' " . : ; '1 •

APPENDIX A: MISCELLANEOUS DATA

f UMMINGS\BJTER

M-roc"" -" *

LIST OF TABLES

. TABLE NO. TITLE

1 ' PCB RESULTS - WIPE SAMPLE SUMMARY

2 PCB AND'LEAD RESULTS •> FLOOR SWEEP SAMPLES

LIST OF FIGURES

FIGURE NO. TITLE1 - ' i

1 SITE LOCATION MAP

2 BUILDING LAYOUT-MIDDLE SECTOR

3 SECTION A-A* - MIDDLE SECTOR BUILDING

4 FLOOR AND SWEEP SAMPLE LOCATIONS-JUNE 1995

UMMINGS

PILOT PROGRAM WORK PLANINTERIOR CLEANUP - MIDDLE SECTOR BUILDINGS

SHARON, PENNSYLVANIA FACILITY

1.0 INTRODUCTION

On May 9,1S>97, Westinghouse Electric Corporation (Westinghouse), Pennsylvania' Department of Environmental Protection (PADEP) and U.S. Environmental ProtectionAgency (USEPA) agreed that Westinghouse would proceed to prepare a Work Plan toperform a pilot program that would evaluate technologies and techniques for cleaningactivities to address cleanup of residual polychlorinated biphenyls (PCBs) and lead-based

; paint residues in the Middle Sector buildings'interiors at the Sharon, Pennsylvaniafacility. ,. * • . i • • . .' ( . • ' . . • •

The general objective of this pilot program is to perform the necessary activities toevaluate the effectiveness of potentially applicable cleaning technologies on various typesof interior surfaces within the Middle Sector Buildings. In addition, appropriate cleanupcriteria will be established for full-scale implementation.'The cleanup criteria will bebased on pilot program findings, a risk management assessment, and future use scenariosfor the buildings. Cleanup technologies/techniques, as used in this work plan, are definedto include various state of the practice methods, from vacuuming to encapsulation, thatcan be used to achieve cleanup criteria or eliminate potential pathways of exposure. Thefollowing specific objectives were identified for the pilot program:

•..'.. • Survey the various types of building interior surfaces and selectspecific areas for the pilot cleaning program. ., •

• • Characterize specific areas to establish baseline conditions. ,

• Identify specific cleaning technologies/techniques to compare .efficiencies on various interior surfaces in each selected study area.

',-i- R 3032 I!

- • .

• Perform independent cleaning techniques on a pilot basis by qualifiedvendors.

• Collect independent data on effectiveness and costs of each techniqueand interior surfaces. . ; ,

i •' ' •• Develop appropriate cleanup criteria.

* Classify waste streams for disposal.

, * Determine a cost-benefit comparison between the various surfaces andcleanup techniques.

• Prepare a summary report which documents the results of the pilot ;cleaning activities. ~

• Provide the results of this pilot program to Pennsylvania Departmentof Environmental Protection (PADEP).

The following sections describes the activities to be performed to accomplish theseobjectives. ',

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2.0 BACKGROUND

2.1 GENERAL . ,This section presents a summarized version of background information which relates tothe Middle Sector buildings' interior conditions associated with this pilot program workplan for the Westinghouse facility in Sharon, Pennsylvania. This section provides a briefdescription of the plant location, a history of Westinghouse operations, and a summary ofprevious (applicable) investigation activities. Additional details are provided in theRemedial Investigation Report (Cummings/Riter, 1996).

2.2 SITE DESCRIPTION / , • .the Westinghouse facility in Sharon, Pennsylvania is a former electrical transformermanufacturing plant. The former Sharon Transformer Plant is located along SharpsvilleA.venue in the city of Sharon, Pennsylvania, near the western border of Pennsylvania inMercer County (Figure 1). The plant site occupies nearly 58 acres and is located withinthe Shenango River Valley, The Shenango River is located 800 to 2,000 feet west of thesite. The site approaches the city of Sharpsville to the north, is bounded on the east bySharpsville Avenue, on the south by the city of Sharon, and on the west by Conrail tracksand ARMCO, Inc. (Sawhill Tubular Division) (ARMCO). The site is approximately onemile in length along a north-south axis and between 200 and 800 feet wide..

The site is divided into three areas: the South, Middle and North Sectors. This particularpilot program work plan only addresses those building structures located within theMiddle Sector of the facility. Those building structures in the North and South Sectorswere either previously demolished or sold to other parties. To differentiate the buildings,Westinghouse assigned an alpha-numeric (alpha) code to each major structure.Throughout this work plan, these buildings will be referred to by their alpha code. Theparticular buildings included in this pilot program are Buildings F, F-H, H, I, and T. Thetotal floor space of these buildings is over 702,000 square feet (ft2). The locations ofthese buildings are presented on Figures 2 and 3. > .

/ UMMINGS

*"" •-• -3' 4R3032I3

2.3 WESTINGHOUSE OPERATIONS HISTORYFor over 60 years, prior to its shutdown in January 1985, the former Sharon TransformerPlant primarily produced distribution transformers, power transformers, and relatedelectrical apparatus. Both pole-type and pad-mounted distribution transformers, and awide range of small, medium, and larger power transformers were manufactured. Inaddition, the related electrical apparatus included reactors, regulators, rectifiers, andmobile transformers. • !

Raw materials were generally received at the southern end of the plant and themanufacturing processes progressed as the product moved through the plant to the north.The bulk of the manufacturing, assembly, and testing took place in the Middle Sectorwith final packaging and shipment operations being performed in the North Sector.

The primary materials in both the transformers and the related electrical apparatus wereessentially the same. These materials included:

- " • . A , f

Silicon steel for the cores,Copper or aluminum for the coils, iPaper or varnish for insulation, - i JCarbon steel for the tanks, and , -Oil, silicone, or Inerteen® dielectric fluids for liquid-cooled designs.

However, some of the designs did not use liquid dielectric fluids. Instead, these dry-typedesigns were cooled with pressurized gas, convected air, or forced air. In addition, someof the very small transformers involved the use of molded rubber and/or other ,encapsulating solids.

Most of the liquid-cooled designs (approximately 98 percent) were filled with nbn-PCBcontaining transformer oil, which is a highly refined mineral oil. A small percentage(approximately 2 percent) of the liquid-cooled designs was filled with either a siliconefluid or Inerteen®. Inerteen® is a registered trademark of Westinghouse for a specialdielectric fluid. This fluid is nonflammable and was either undiluted PCBs or a mixture ofPCBs and trichlorobenzene. The manufacturer of Inerteen® used the trade name"Aroclor" in conjunction with a four-digit number to identify different blends of PCBcompounds. , •'..-.'-' "

. • ' • • . / " : - • • ' . • - • - . ' - • . ' - ' , ' • • • . ' . . OCUMMINOBITER

•*""- . -4- iJR 3032.1 U

The use of Inerteen® was first introduced at the former Sharon Transformer Plant in 1936.This type of Inerteen® consisted of a 60/40 mixture of Aroclor-1260 andtrichlorobenzene. The next typ of Inerteen®, introduced in January 1965, was a 70/30mixture of Aroclor-1254 and trichlorobenzene. The last type of Inerteen®, introduced inJanuary 1968, was Aroclor-1242, which was not mixed with trichlorobenzene; The plantdiscontinued all use of Inerteen® by the end of 1976. Inerteen® was not manufactured orformulated by Westinghouse; all Inerteen® formulations were purchased from themanufacturer. These fluids were typically received and stored in tanks at the former tankfarm area located in the Middle, Sector of the plant (Figure 2). :

' . • ' • ', i . . , • ' .The northern portions of both Building H and Building T, respectively, were where thetransformers and units were filled with, both oil and Inerteen*. The coil impregnation unitutilized in Building T was essentially the same as the unit used in Building H, except thatsteam was used to heat the coils rather than solvent prior to placing the transformer oilinto the units. The central portion of Building H contained a varnish dip tank and coiltreatment unit referred to as the hot-oil spray. In this process, transformer oil wasinjected into the chamber through nozzles that would disperse the oil as droplets andallow any moisture to diffuse into the air prior to contacting the transformer components.

* " < . ' * " . "Two incidents of transformer oil spillage are known to have occurred during 1963 in theMiddle Sector buildings, but the exact dates are unknown. The first incident involvedleakage from a horizontal vacuum tank in Section HT-60 (Building H). Oil spilled out ofthe tank when the vacuum was lost during a check of the oil level. The situation wasremedied by adding clamps to the tank doors for use during loss of vacuum and adding ai • * • • • . 'sight gage so that the oil level could be checked without opening the tank. The effects ofthe spill were not documented. : •

A second incident involved transformer oil spillage from the Vapotherm treatment tank inSection TM-2 (Building T). The spillage resulted from a blocked drain line which causeda false indication that the tank was empty. The problem Was corrected by backflushingthe drain line and adding an oil-level sight gage. The effects of the spillage were notdescribed.

*"'" :"'5- AR3032I5

During normal maintenance of the facility walls, floors and equipment were painted.Lead compounds were not used as a part of the manufacturing processes.

• ' . > • ' . ' , - ' • ) . - • '2.4 SLMMARY OF EXISTING DATA ,. •2.4.1 Wipe Data (1985)In 1985 wipe samples were taken from the top surfaces of machinery and equipment inthe H and T Buildings of the. Middle Sector, where usage of PCBs was reportedly thehighest (CHMR, 1987). The results showed individual PCB concentrations ranging from1.5to210microgramsper 100 square centimeters (yg/100 cm2). The majority of thisequipment has already been removed from the facility and is not included in the scope ofwork for this work plan.

2.4.2 Wipe and Sweep Data (June 1995)During the week of June 26/1995, the U.S. Environmental Protection Agency (USEPA)came to the site and divided the Middle Sector buildings (F, H, F-H, I, and T) into 13areas for the collection of several wipe and sweep samples from within each building.The locations of wipe and sweep samples were-biased towards "stained areas" of thefacility. The locations of these sample are presented on Figure 4. • • • ,

. , , - ' • • • • • • . • -'• . ' '•• /..The USEPA collected a total of 67 wipe samples and 13 sweep samples from a variety offloor and wall surfaces. Duplicate samples were also collected by Wcstinghouse at thesame time from adjacent locations for comparison purposes. The wipe samples wereanalyzed for PCBs and the floor sweep samples were analyzed for PCBs and lead.Westinghouse performed independent replicate analyses on 32 of the wipe samples and 6of the sweep samples. Both the USEPA and Westmghouse analytical results arepresented in Tables 1 and 2. Additional wipe sample results are in Appendix A.

The wipe sample results ranged from <1.5 fig/100 cm2 to 32,000 ug/100 cm2 PCBs; Thesweep sample results ranged from 13.5 milligrams per kilogram (mg/kg) to 19,500 mg/kgfor PCBs and from 931 mg/kg to 11,400 mg/kg for lead.

-6-

2.4.3 Air SamplesFollowing plant shutdown and during the 1986 subsurface investigation study, fiveindoor air samples were collected. The samples were collected during drilling operationsand analyzed for PCBs. PCBs were not detected in any of the five samples with detectionlimits ranging from 0.01 to 0.10 milligrams per cubic meter (mg/m3). -

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3.0 POTENTIALLY IMPACTED SURFACES

In preparation of the work plan, areas within the Middle Sector buildings have beeninitially classified by historical PCB usage and existing surface media. For theclassification of PCB usage, historical records and previous PCB sampling results wereused, Surface media, including painted surfaces, were identified based on visualobservations of the buildings. •

3.1 GENERALAS described in Section 2.0, historical operations conducted at this facility involved theuse of oils which contained varying levels of PCBs. Therefore, the potential exists thatsome of the interior building surface areas may have an accumulation of PCB residues asa result of normal process operations and material handling practices. These residuescould be present due to incidental spillage/splashes, dust, oil mists, and vapors associatedwith process operations. These potentially impacted areas could include ceilings, floors,walls, windows, structural columns, overhead structures (cranes and trusses), and exhaustfans. Some characterization activities have already been performed as discussed earlier in ; iSection 2.0, however, additional baseline information is required prior to conducting the *Pilot Study and proceeding with the interior cleaning.

In addition to the potential PCB impacts on the interior building surfaces, it is alsopossible that the paint utilized on many of the painted surfaces within the buildings mayhave contained lead. Analytical results of the floor sweeping samples collected in June- 1 • ' .1995 by the USEPA detected lead in nearly all of the samples.

" ' ' , - . - '

3.2 HISTORICAL PCB USAGE AREAS .Buildings H and T are reportedly where the highest usage of PCBs historically occurred(CHMR, 1987). Buildings H and T were both used as assembly areas for largetransformers. Both buildings had much of the same process equipment which wasprimarily located in the central and northern portions of each of the respective buildings.Building H represents approximately 1 57,500 ft2 and Building T representsapproximately 178,875 ft2.

„* , IR3U32I8

The remainder of the buildings were identified as low use areas due to the nature of thehistorical operations and processes that they contained. These remaining buildings didnot involve the extensive handling of oils containing PCBs. These particular buildingsare identified as Buildings F, F-H, and I.

Building I represents approximately 130,500 ft2 in four floors. This building served bothas office space with some manufacturing processes involving paper insulation, casehardening, and coil winding operations.

Building F represents approximately 153,200ft2. The historical operations conducted inthis building from 1924 through 1950 are unavailable. Since that time it has reportedlybeen used for a variety of component cleaning and painting purposes. However, atransformer core manufacturing area was previously located in section F-24 whichincluded an etching unit and two impregnating tanks, ' " • ' ' ' .

. . ' i * • *

Building F-H represents approximately 81,000 ft2. This building, constructed in 1953,was primarily used for storage and coil insulating processes. The operations in thisbuilding present little potential for chemical contamination.

A description pf the specific interior building surfaces with potential PCB and leadimpacts is provided in Sections3.4 through 3.11. These potentially impacted areas couldincludeceilings, floors, walls, windows, structural columns, overhead structures(cranesand trusses), and exhaust fans. Many of these components vary slightly within eachparticular building. Each surface type will be addressed in the pilot program.

33 PAINTED SURFACESGeneral maintenance and housekeeping activities while the facility was in operationprevented deterioration of painted surfaces. Since the facility ceased operations, thepainted surfaces have begun to deteriorate. Most of the interior surfaces are painted.There are no records on the paint used at the plant.

-«"» . -9- JRJ032I9

\&ITER"•**•'•

3.4 FLOORSThere are generally three types of floors consistently found throughout the Middle Sectorbuildings: concrete, brick and wood. Each building typically has a combination of eachtype in varying amounts. As part of the pilot program, the floor types and their locationswill be documented. '

The most common type of floor found in the Middle Sector buildings is concrete. Brickis the second most common type of floor and is typically found in the main traffic isles ofeach building. The amount of wood flooring found at the facility is relatively limited.The wood flooring consists of either tongue and groove style or wood block style. Thewood block style floor is primarily located in Building I and at the southern section ofBuilding H.

The majority of the brick and concrete floors are painted. Most of these painted surfaces .are generally found to be in poor condition with noticeable peeling, flaking and chipping.One section of pbncrete floor in Building F (Sections F-10 to F-35) appears to have anepoxy coating which is in good condition. The condition of the floors will be evaluatedin the pilot program (Section 4.1).. • '• • •-.-.: ..-."- •;.- •'• ' • -3.5 CEILINGSThe buildings in this facility were constructed with a range of ceiling heights (24 to 64feet). The heights for each building are shown on Figure 3. The ceiling constructionmaterials vary depending on the particular building. * '

r •

Building T has a concrete poured arch ceiling which appears to be painted. Building Happear to be a metaJ type roof with a gypsum-like board material on the underside. Asample of this material was collected and found to contain no asbestos. Certain portionsof this roof appear to be in a deteriorating condition due to roof leaks. The ceilings inBuildings F, F-H, I appear to be constructed with a combination of a variety of materialssuch a metal, wood, and gypsum ceilings.

""" -10' .1R303220

The ceiling surfaces will be inspected during the baseline characterization (Section 4.1)i j- *for significant dust accumulation which can be characterized for PCBs with wipe

sampling. ;

3.6 WALLSThe walls are constructed primarily of either masonry block or brick. The structuralcolumns are either reinforced concrete* brick, or structural steel. Nearly all of these wallsand columns are painted. The majority of the walls and columns exhibit a significantamount of peeling, flaking and chipping paint. The painted masonry block walls

, generally seem to be in very good condition with minimal deterioration of the paint.Several wipe samples have been collected from select wall surfaces throughout thebuildings, as discussed earlier in Section 2.4. Many of these wipe sample results

/ indicated the presence of PCBs. :

Buildings H and T also have corrugated metal divider walls which were used to separatethe distinct isles within each of the buildings. These metal dividers are located along thestructural column lines in the north-south axis of the buildings. Most of these metal

( surfaces were also painted, and the paint is peeling, flaking and chipping. A painted**~/ surface survey will be performed as part of the baseline characterization (Section 4.1).

3.7 WINDOWS ;There are a significant number of windows located around the perimeters of many of thebuildings. These windows will be characterized with wipe tests to determine if PCBresidues are present. These results should be compared to the site cleanup criteria andaddressed (if necessary) during the pilot program.

3.8 OVERHEAD STRUCTURESThis category basically addresses the cranes, trusses, piping, electrical lines and structural

. ' . , . , steel. These surfaces will be inspected primarily for the accumulation of dust. If present,this dust will be sampled. Wipe samples will also be collected on the various metalsurfaces to determine the extent of PCB impact (if any),, The parts of the structural steel

u; • :.•.,•:'•,':'' •..;'' •..'.'-::"./'.••"'^•''"'•'•;'"•' ;ifU0322l

fMTER

columns located between the floor elevation and ten feet will be closely inspected foroils/residues which may have resulted in incidental splashing. If staining is observed,representative locations will also be sampled during the baseline characterizationactivities. . • ^

1 . • - • '.3.9 EXHAUST FANSMost of the buildings are equipped with several exhaust fans which are located in theceilings. These fans will be inspected for the accumulation of dust/residues. If asignificant amount of dust is discovered, a representative fan will be characterized andaddressed during the pilot program. ,

3.10 LIGHT FIXTURESThe overhead lighting will be inspected for the accumulation of dust If a significantamount of dust is observed, representative light fixtures will be characterized andaddressed during the pilot program.

3.11 SUBFLOOR ITEMSThere are several items built into the floor or located below the floor level. These includerailroad tracks and utility trenches. The railroad tracks are embedded into the floor inseveral locations. These tracks were utilized to transport transformers and componentsduring the assembly and testing operations. The pilot program will evaluate approachesand techniques for addressing these areas.

Shallow utility trenches are located in several areas. The condition, sizes, locations andcontents (pipe, electric, gas, etc.) of the trenches will be noted during the baseline . • .characterization (Section 4.1). Depending on the baseline findings, the utility trenchesmay be included in the pilot program. . .

-i2- 4R.J03222

4.0 PILOT PROGRAM TASKS

The strategy of the overall pilot program relies on the identification and evaluation ofPCBs and lead paint on the interior surfaces. Although the limited sampling effortsperformed to date indicate that PCBs and lead paint are present, the extent of theirpresence must be determined.

The pilot program will consist of a series of ten tasks. The tasks are as follows:

Task 1 - Baseline Characterization,Task 2 - Pilot Study Area Selection,Task 3 - Technologies Evaluation for Pilot Program,Task 4 r Selection of Contractors for Pilot Program,Task 5 • Pilot Program,Task 6 - Sampling and Analysis Plan,Task 7 - Cleanup Criteria Development, ' .Task 8 - Future Development Evaluation,Task 9: Health and Safety, , 'Task 10-MaterialHandling,and • - - .Task 11 - Reporting,

Tasks 1 and 2 will develop the pilot program strategy, and Tasks 3 through 10 involve theimplementation of the pilot program.

' ' V ' . . - • : ' •

4.1 TASK 1 - BASELINE CHARACTERIZATIONThe initial task for the pilot program will be a detailed assessment of the interior surfaces.The assessment will evaluate existing relevant data and record surface material, surfacelocation, degree of staining, surface condition and other items applicable to the cleaningprocess. Based on the findings of the reconnaissance, several potential pilot areas will beselected for further evaluation. These areas will be sampled to document lead and PCBconcentrations. The sampling procedures are described in Section 4.6. Dust and wipe

• CUMMINGSK&ITER

*i3- AR303223 -"-

samples of exposed surfaces, including floor, ceiling, beams, pipes and wall fixtures willbe collected and analyzed for lead and PCB concentrations. The number and types ofsamples will be area-specified and determined after selection of the study areas,

The baseline characterization will include a lead paint survey to document the leadcontent in existing painted surfaces. Several methods may be used for determining the .lead content. These include XRF, chemical spot tests, and analytical tests. XRFanalyzers are portable instruments used to estimate the amount of lead in paint. Chemicalspot tests like XRF are performed on site. A scratch is made through the paint layers anda chemical solution is placed on the scratch. If the solution turns a certain color, the. ipotential presence of lead is indicated. These tests are qualitative. Analytical tests will 'be done off site by a laboratory in accordance with Section 4.6.6.

During the survey, painted surfaces, including walls, floors, ceilings, doors, windows, .equipment and other painted structures will be evaluated. Extrapolating test results tountested areas may be performed based on observations of the survey team. The results ofthe survey will be an inventory of lead concentrations and the current condition of thepainted surfaces. ; ' \ J

4.2 TASK 2 - PILOT STUDY AREA SELECTIONWestinghouse will select areas which are representative of the Middle Sector buildings toundergo cleaning during the pilot program. The selection process will be based upon thefollowing:

Existing analytical information, -Past operations, , ,Visual observations,Representative surfaces, andWipe/residue sample results.

Based upon past operational usage, previous wipe/residue samples, and generalobservations, six areas Have been selected as tentative pilot areas. Theses areas are:• . - . • - . . - • ^ , , • f

• Building T, south/central areas,• Building H, south area, ,

.. / UMMINGS

*>.».' -14' !\R3U322'li - •

• Building H, central area,,• Building F-H, north end, ' ' .; . ..

, • Building F, north end, and . ' , .• Building!-1st Floor.i • ' •.,.'"•' ' • ' •

• ; . . ,

( The selected areas will be finalized upon completion of the baseline characterization. It isenvisioned that the areas may be expanded or subdivided to allow more than one cleaningtechnology to be evaluated in an area. ', • •

4.3 TASK 3 - TECHNOLOGIES EVALUATION FOR PILOT PROGRAMSeveral cleaning techniques will be employed during the pilot program to determine theireffectiveness in reducing the PCB and lead levels at the Sharon facility. Cleaningtechniques will be evaluated for floors, ceilings, walls, and other structures in Sections3.7 through 3.11. Each of these surfaces can further be divided into smooth and roughsurfaces. Concrete, bricks and wood are examples of rough surfaces. Glass, steel, andother metals are smooth surfaces. Smooth and rough surfaces will be evaluated in thepilot program. . , • ,

1 : ' • ' " ' . ' ' • ' • , ^ • ' . ' • - . / ' • ' . - '/ , To determine the most effective way. to reduce dust and residue concentrations, several- different technologies will be evaluated. Depending on the type of the interior surface, a •

. variety of cleaning techniques will be considered for implementation of the pilotprogram. A combination of several different techniques may also be employed. Thegeneral cleaning categories to be evaluated are: ' ,

• Mechanical, . v• Chemical, and• - * Encapsulation.

Each cleaning technique will be performed In accordance with an operations plan which\vilIbeprovidedbythecontractorandreviewedbyWestinghouse.

4.3.1 MechanicalThe mechanical category includes the physical removal of dust/dirt particles from thesurfaces by common cleaning techniques. A brief listing of these general mechanicalcategories is as follows: ?

• ' • ' ' ' . ! ' ' •

I ' ' ' * , . ' ' ' '

- . ' • / UMMINGS

•*"" -15- '••;jRJ032'25l&ITER

• Vacuuming - ' ^_ yAn industrial vacuum with a high efficiency filter will remove surfaceresidue. This process minimizes dust generation,

• Scraping/WipingThis involves the physical scraping and wiping of surfaces. Wet , ' ;wiping will reduce dust levels.

• WashingThis typically involves hand washing and scrubbing techniques. Oftensurfactants/solutions are added to the wash water to aid in the removalprocess.

• Water Blasting/Pressure WashingHigh pressure water is directed at the surface. At higher pressures,some destruction of the surface can occur. Water blasting can generatea high volume of waste water. ,

• Steam CleaningThis process physically extracts contaminants from building materials.

. Steam is applied by hand-held wands (or automated systems), and the "condensate is collected for disposal. '

• Ice and CO2 (dry ice) BlastingThis process replaces water with ice/dry ice. The waste volume fromthe blast media is much lower with ice blasting and is negligible due toevaporation in CO2 blasting.

• Grit Blasting .This method uses an abrasive material (sand, etc.) for uniform removalof surface layers. v . ,

• Bead/Shot BlastingThis method uses metal beads or shot for blasting the surface. Thebeads can be recovered and reused to minimize waste volume.

• Scabbling/ScarifyingThese physical/mechanical processes remove the surface (normallyconcrete) one layer at a time. This is a destructive process with typicalremoval rates of 1/16 inch to 1/8 inch per pass. .

/ UMMINGSitfiii

• REMOVAL• Removal and off-site disposal of certain structures (i.e., wood floors)may be performed instead of cleaning. v

It is envisioned that surficial debris will be vacuumed from the floors, walls and overheadpiping prior to implementing any other technology. Walls, pipes, and other structures . .may also be wiped. The vacuum units will be equipped with a HEPA (high efficiencypaniculate air) filter. .

4J.2 ChemicalExtraction: These processes use a series of chemical formulations to extract theconstituents of interest. These formulations typically involve acids and surfactants toprepare the surface. This is followed by a customized extraction solution. Based onmicroemulsification and ion exchange the rinse step removes the constituents of interest.

Acid Cleaning: Of the acid cleaning approaches, nitric acid is the most aggressive.Acids can be highly effective in surface cleaning and can reduce subsurfaceconcentrations for certain types of constituents. Cleaning with many acids also can createan acidic waste.- . . • • ' . . " - ' • ' • • • • • • ' , ; • • • •Strippable Coatings: Compounds that bind with constituents of interest are mixed witha polymer, applied to the .impacted surface, and subsequently removed.

Other Products: Besides acids, there are many other chemical products that are, commercially available. Most of these are based on either detergent or solvent chemistry.

4.3.3 Encapsulation ' .• • . iEncapsulation is sealing the surface with the application of a material that penetrates aporous surface and immobilizes the constituents of interest in place. The encapsulateprovides a new surface layer which reduces direct contact exposures. The encapsulantstypically include materials such as epoxy coatings, concrete, rubber, polymers, paints,•etc. . . • • ' •

/ UMMINGS

•17- ' i R303227t&ITER

4.3.4 Combination of Categories . ' ~ • 'Based upon the effectiveness of the individual technologies, Westinghouse also intends toevaluate the effectiveness of combining various technologies. It is anticipated that thecleaning of PCB and lead from an area may include a series of cleaning steps comprisingof various technologies (i.e. mechanical, chemical, encapsulation).

4.4 TASK 4-SELECTION OF CONTRACTORS FOR PILOT PROGRAMIt is anticipated that several specialists will be retained by Westinghouse to effectivelyevaluate various cleaning technologies. This process will be comprised of the followingstages: - . • . ,_

• Requests for Statements of Qualification (SOQs) will be sent toseveral vendors. This request will ask the vendors to provide variousoptions and cleaning technologies that could be effective on surfacessimilar to those found at the Sharon facility.

• After evaluation of the SOQs, a Request for .Proposal (RFP) will besent to the vendors that can provide the most potentially applicabletechniques. > - -

• After review of the proposals/bids, one or more of those vendors willbe contracted to demonstrate their applicable cleaning technology inselected areas of the facility.

* The vendors will prepare a detailed operations plan describing theiractivities. \

4.5 TASK 5 - PILOT PROGRAMPrior to implementation of any cleaning activities in each pilot area (floors, walls,structures, etc.), the loose surficial debris will be removed. These walls, floors or otherstructures will be thoroughly vacuumed to remove dust and dirt A vacuum configuredwith HEPA filters will be utilized. Prior to and following this initial step, lead/PCBconcentrations will be established for the pilot area. This vacuuming technique is alsoone of the mechanical cleaning techniques. Sample collection procedures are describedin Section 4.6.

UMMINGS

\ J -Preparation for the pilot programs will be area specific. To the extent possible, existingwalls and structures will be used in isolating areas tq reduce impacts from adjacent areas.

4.6 TASK 6-SAMPLING AND ANALYSIS PLANThe sampling and analytical program (SAP) involves three types of samples. The firsttwo types (wipe and residue samples) relate to the determination of effectiveness of thecleaning process. The final type of sample is for worker health and safety. Results fromthe three types of samples will also be used in the evaluation of worker health and safety.Sampling for disposal characterization will also be performed on the waste materialslisted in Section 4.9. ,

During the pilot program an evaluation of sample locations as they relate todocumentation of cleaning effectiveness will be performed. In some cases the prc- andpost-samples may be collected from the same location. In other areas they may becollected side-by-side or at another random location. It is envisioned that a combinationof locations will be sampled in the pilot program. Sample locations will be both randomand biased to evaluate the cleaning processes.

4.6.1 Core SamplesCore samples in select concrete floors may be utilized as either a characterization tool todetermine the penetration depth of PCBs (if any) or also to evaluate the effectiveness(depth) of various remedial technologies. Core samples will be split into depth intervals 'and analyzed for PCBs. Core samples will be collected using concrete coring equipment.Samples will be placed in wide mouth glass containers. Sample preparation (slicing ofsample into discrete intervals) will be performed by the laboratory. Each sample intervalwill be prepared .hi accordance with the analytical method. Analytical methods are listedin Section 4.6.6. As an evaluation tool, the core samples may also be collected aftercleaning to determine the actual depth of cleaning achieved.

4.6.2 Wipe SamplesWipe tests will be performed before and after cleaning techniques. Wipe samples mayalso be collected after a cleaning step is applied to evaluate effectiveness of each step. A100 squared centimeters (cm2) template will be placed on an area of the floor or othersurface. The surface will be wiped with a clean 2" x 2" gauge pad dampened with bexarie

• • ". f UMMINGSrt/in -19- '* C

(10 milliliters). The pad will be wiped in one direction (i.e., top to bottom). The wipewill then be turned over to expose a clean surface and the area will be rewiped at. 9ft'degrees to the first direction. Th« pad will be placed in a labeled glass container, .Thefrequency of the wipe samples will be determined based on the cleaning techniqueapplied. The before and after samples will not be collected in the exact same location,but will be in close proximity to each other. The before sample will document conditionsbefore and the after sample will document remediated conditions. When necessary,duplicate samples will be collected side-by-side.

4.6 3 ResidueIf discovered during the baseline characterization, residue or dust samples will becollected. A portion of a flat horizontal surface in the pilot areas will be selected. Usingbrushes the residue will be gently swept into a pile. The piled material will be placed intoa glass container for analysis. The area swept will be measured. No residue samples areanticipated after cleaning because the cleaning technique should remove surface residue.In cases where no residues remain, only wipe samples will be collected after cleaning.

4.6.4 Material Samples ,1 ' • • . .Material samples will be collected of several waste streams generated during the pilotprogram activities. Samples will also be collected for disposal characterization of •anticipated waste streams that will be encountered during facility wide cleaning.Representative samples of waste materials will be collected. Analytical parameters willinclude PCBs, lead, and other parameters required for disposal. Analytical results will bef . i • ' •used for disposal decisions.

• . ' " • --i . • '4.6.5 Paint SamplesThe painted surface survey (Section 4.1) will collect a limited number of paint samplesfor lead analysis. The majority of the survey will be conducted using field screeninginstruments (Section 4.1). Paint samples will be carefully collected to confirm fieldmeasurements. Paint samples will be placed in a plastic bag and labeled.

4.6.6 Analytical Program iSamples will be prepared and analyzed following USEPA methop's. For lead and PCBsUSEPA's Contract Laboratory Program (CLP) methods will be used. Lead will be

-2°- VR 303230

analyzed by the CLP inductively coupled plasma (ICP) method. Analysis for disposalcriteria will be done using the appropriate USEPA method. Health and safety relatedsamples will be analyzed in accordance with the health and safety plans (HSPs).

4.6.7 Data Quality Assurance • ;The pilot program includes a procedure which assures that precision, accuracy,completeness and representativeness of the data are known and documented. Also, theapplicable sections of the Remedial Investigation Quality Assurance Project Plan will befollowed during the pilot program. Precision and accuracy goals will be established bythe laboratory based upon analytical methods and requirements of the pilot program. Thecompleteness goal is 90 percent. The sampling and analytical methods were selected toensure the results are representative of the media.

The data quality objective levels for the pilot program are Levels II, HI and IV. Level IIpertains to field data primarily collected during the painted surface survey. Data forLevel III objectives will primarily be for health and safety and disposal purposes. Wipeand dust samples performed after completion of pilot cleaning analyzed for PCBs or leadwill be Level IV data. '

1 ( . • >Suitable calibration standards and reference materials will be used for Level II data. Therequirements for Levels III and IV data are as follows: , ',.

Case narrative,Chain-of-custody,Reporting limits, vResults, ' ,Method blank results,Laboratory control sample/blank spike,Calibration data,ICP spike (metals),Sample spike recovery (metals),Sample duplicate, , •ICP interference check sample (metals),ICP serial dilution (Level IV, metals),Raw data.

• UMMINGS.-21' AR30323J

• MS/MSD (organics).• Aroclor identification (PCBs), and . .* QC summary package (Level IV). .

, • N ' " - . - " "

Calibration frequency and data reporting will be in accordance with the analyticalmethod] Duplicate, method blanks, spiked samples, and "equipment" blank samples willbe analyzed at a one in twenty frequency. v • - - -

4.7 TASK 7-CLEANUP CRITERIA DEVELOPMENTCriteria for residual lead and PCB levels will be developed based on futurecommercial/industrial use. The criteria will be based upon published data from suchorganizations as American Conference of Governmental Industrial Hygienists, USEPA,Occupational Safety and Health Administration, Center for Disease Control and

^

American Society for Heating, Refrigeration and Air Conditioning Engineers. Therelevant portions of the risk assessment developed by USEPA will be evaluated as"background information.

Potential site-specific pathways will be considered in developing cleanup criteria.• • ' • •Potential pathways through which future occupants might be exposed include inhalation

of airborne dust and vapors, incidental ingestion and dermal contact Although PCBs arenot considered to be highly volatile, some volatilization and subsequent inhalationexposure may occur. Following cleaning of an area it is unlikely that significantquantities of dust containing PCBs or lead would remain. Under these conditions, contactwith surfaces (dermal contact and associated incidental ingestion) may be thepredominant pathways for exposure to residual concentrations of PCBs and lead.Inhalation of dust and vapors may be less significant pathways.

4.8 TASK 8-FUTURE DEVELOPMENT EVALUATION .An evaluation of the potential of the Middle Sector buildings for future development willbe performed. The Development Plan provided by the Snenango Valley RedevelopmentCorporation will be used as guidance. The evaluation will include current equipment(i.e., cranes), building configuration, utilities, structural integrity and their suitability forreuse. The findings of this evaluation will be integrated with the cleanup criteria.

/ ' / UMMINGS\&ITER

-22- ,»R.JG3232 -"•

4.9 TASK 9 - HEALTH AND SAFETYPilot program workers will be protected through implementation of HSPs. Because ofdifferent techniques, a separate HSP for each cleaning technique will be required. EachHSP will address hazard analysis, protective clothing, respirat6ry protection, airmonitoring, training and other measures covered by 29 CFR 1910.120. Engineering

I . , . > ' - ' . v ' - '

controls such as barriers and use of negative pressure will also be addressed in the HSP as-• *» • ' . .necessary. ,* li

4.10 TASK 10 - MATERIAL HANDLINGVarious waste streams will be generated during the pilot program. It is anticipated thatthis material will be representative of wastes generated during additional cleaningactivities. Proper segregation of these different waste streams will be important becauseof disposal regulations and restrictions. Anticipated wastes to be generated during thepilot program could include the following: ' • , - . •

Residues (floor sweepings); . 'Wood flooring;Abrasive media; ,Cbncrete, brick, cpncrete block; \ 'Containment polyethylene sheeting; - ' •Waste water;Tyvek and personal protective equipment (PPE);1HEPAfilters;Debris; and , ,Paint chips. ! <

4.10.1 Bulk WastesSolid bulk wastes will include, but not be limited to, floor sweepings, floor material,concrete, polyethylene, Tyvek and PPE. The bulk materials will be segregated intocommon lots (i.e., Lot 1 - concrete, Lot 2 - wood, Lot 3 - debris, etc.) in preparation forcharacterization and disposal. Although it may be feasible to dispose of the materials asan integrated lot, segregation of the materials is required prior to shipment. This methodof handling will allow the materials to be originally screened individually, prior to• i ' < • *disposal. . , . . . - '

ITER• -' AR303233'

Depending upon the transportation and disposal method the material handling procedureswill vary. If bulk material is to be disposed of in drums, the drums should be filled withbulk waste while the area is being subjected to the process. These drums must be "UN" ,,certified for hazardous waste shipments. The sealed drums will be identified, logged, andtransported to a staging area to await transportation to a disposal facility.

If bulk material is being disposed of in a rollofF, the waste material will be transferred torolloffs. The transfer of the material from the work area to the rolloffwill be done in acontrolled manner to minimize the chance of impacting other areas of the facility. Thismay include sealing the waste material in a transfer container (i.e., drum or dumpster).

4.10.2 FluidsSeveral cleaning techniques are liquid based. Fluids generated during the pilot programwill primarily be waste water associated with mechanical removal techniques or chemicalsolutions. The cleaning fluids will be contained for disposal in portable tanks, drums ortransport trailers. The container selected will be placed inside a lined containmentstructure. Fluids will be characterized and containerized separately, unless instructed todo otherwise by the disposal facility.

4.11 TASK 11-REPORTINGWestinghouse will provide two deliverables to the PADEP related to the pilot program.The first deliverable will be a summary of the baseline characterization findings,sampling locations, results, techniques and areas selected for the pilot study, arid a revisedschedule of the pilot program.

The final deliverable will be a report summarizing the findings of the pilot study; including:

Activities performed,Waste material profiles,Cleanup criteria selected, 'Future development evaluation,Evaluation of results, andFindings.

The cleanup criteria will be integrated with the findings of the future development evaluation.

5.0 PERSONNEL

The pilot program will be performed by a team of qualified individuals and companieswith relevant experience to meet the identified objectives of the pilot program. The teamconsists of the following: '' r ' . • . . - ' • ' ' .

• Project DirectorA representative from Westinghouse Environmental Affairs located inPittsburgh, Pennsylvania will lead and direct the implementation of ,this pilot program work plan.

• Supervisor/CoordinatorA designated representative of the Project Director will monitor andreport on the pilot program progress. This coordinator will beresponsible for the baseline assessment, selecting pilot areas, andrecommending cleaning techniques. This representative will reportdirectly to the Project Director and will be situated in the plant officeson an as-needed basis at the discretion of the Project Director. Thisindividual will also have responsibility for independent sample

. collection and verification of cleaning activities, and supervisingpreparation of a report on the pilot cleaning program.

• Cleaning Specialists/ContractorsIt is anticipated that several vendors will be retained by Westinghousein order to effectively evaluate various cleaning technologies. Each ofthese firms will be assigned a unique area of the facility for theirspecific cleaning technique. • . . ' \

Each vendor that is selected to implement any portion of this pilotprogram, at a minimum, will provide the following qualified keyproject personnel:

, • ' - - ' . - . " - . . ' - " "- Project Manager,

•••<•- Site Supervisor, and . , ,- Health and Safety Officer.

• LaboratoryA qualified laboratory with appropriate certifications will be utilized .for sample analysis. The laboratory will be retained by Westinghouse.

UMMINGS

6.0 SCHEDULE ~>• . • . , : . \ JWestinghouse is prepared to implement the pilot program work plan upon receipt ofPADEP approval. The baseline characterization will be started within two weeks afterreceipt by PADEP of this plan (July 28,1997). The schedule is as follows:

i -• Baseline Characterization - 5 weeks,• Select Pilot Areas/Technology - 2 weeks, ' '• '• Contracting - 6 weeks,• Pilot Study - 20 weeks, and• Report Preparation - 4 weeks. ,

The pilot study includes performing the cleaning in the pilot areas, collecting and -.analyzing post cleaning samples, evaluation of the findings and determining the cleanupcriteria.

The summary of the baseline characterization findings (Section 4.11) will be submittednine weeks'after project initiation. The second report will be submitted 30 weeks afterthis submittal.

CUMMINGSOBITERAR303236 ••**

TABLES

.C'UMMINGS\BITER

rf-ban/m . ' • 'JVAR:i03237

TABLE!PCB RESULTS*"

WIPE SAMPLE SUMMARY ,FORMER SHARON TRANSFORMER FACILITY

SHARON, PENNSYLVANIA

SAMPLEID

W-1AW-1BW-1CW-1D

W-2A 'W-2BW-2CW-2D

W-3AW-3BW-3CW-3DW-3E

W-4AW-4BW-4CW-4DW-4E

W-5AW-5BW 5CW-5D

MATRIXCFCF;BWCFBWCFBWCF

CFBWEQBWCF

CWCFCFBWCF

CFBWBWCF

USEPARESULT

J4C/100 CM*

41751 J<1.59.4

<1.5632.0 J31 J

-210J2.0 J1.2J64

130 J f

9.3 J, 8.9

231251J

470<1.50.89 J26J

WESTINGHOUSERESULT

HC/100 CMJ3946NANA

NANA3.828

1301.2NA ' ,NA "NA

1.1NANANA54

isoNANA-20

• • • • • • ' iITER™" 3R3032.38

TABLE 1(CONTINUED)

SAMPLEID

W-6AW-6BW-6CW-6DW-6E

W-7AW-7BW-7C

W 8AW-8BW-8C

W-9A.W-9BW-9CW-9D

W-10AW-10B•W-10C

MATRIXCFEQBWCFCF

WBFCFCF

CFCFCF

WBFWBFCFCF

CFCFCF

USEPARESULT

HC/100 CM2

U200<1.5<1.52,26029 J

341226 ,

200 J260 J900 J

2,60085047220

7.1 J110J76J

WESTINGHOUSERESULTC/100 CM*

NA -.NA '2.2NA18

NA1015 \

NA480690

' . NA,640NA62

8.4160NA

UMMINGS;iR303239

TABLE!(CONTINUED)

' 'SAMPLEID

W-11AW-11BW-MCW-11DW-11EW-11F

W-12AW-12BW-12CW-12DW-12E.

W-13AW-13B

MATRIXCFBFCF'CFCFCF

BWCFCFCFCF

CFCF

USEPARESULT

UC/IOO CM2

8,700 J960 J37,000900,98 J20

47J260 J90 J540 J

• 430

84 J27

WESTINGHOUSERESULT

UG/100 CM2

NA1,100NA

, NA'NA12

30NA ,NANA380

<112

CF * Concrete Floor BF »Brick FloorBW = Brick Wall EQ - EquipmentWBF - Wood Brick Floor NA - Not Analyzed 'CW - Concrete Wall . " J '• Analyte present. Reported value may

not be accurate or precise.•, * . '' *

a. Results are a summation of Arochlors detected. Estimated concentrations are notincluded for Westinghouse results. Results are reported to two significant figures peranalytical method. ,

UMMINGS

TABLE 2PCB AND LEAD RESULTS'"FLOOR SWEEP SAMPLES

FORMER SHARON TRANSFORMER FACILITYSHARON, PENNSYLVANIA

SAMPLEID

Sweep 1Sweep 2Sweep3Sweep 4Sweep 5Sweep 6Sweep?SweepSSweep 9Sweep 10Sweep 1 1Sweep 12Sweep 13

AREA12345678910111213

USEPARESULTSMG/KG

PCB100 Jno16021 J61200260 J1,600 J580J1,90097J19,000250 J

Lead1.0208209,9509105021,0501,5603,4804142,80038711,4001,510

WESTINGHOUSERESULTSMG/KG

PCB42NA«>NA13.5NA188NA1,800NA' '4,030NA2,850NA

Lead1,870NANA931NA1,170NA3,620NA ...3,130NA11,500NA

AREA"",M2

23.515.512.414.28.210.48.37.63.18.32.06.78.5

a. Results are a summation of Arochlors detected. Estimated concentrations are notincluded for Westinghouse results. .PCB results for USEPA samples are reported totwo significant figures.

b. Area as measured by USEPA. ' ',c. Symbol NA indicates sample was not analyzed.

. Y UMMINGS

: 1R.10321*!

FIGURES

UMMINGS

7.5-MIN. TOPOGRAPHIC QUADRANGLE; ORANGEV1LLE. OH-PA,1961 PHOTOREVISED 1979; SHARON EAST, PA, 1958PHOTOREVISED 1981; SHARON WEST, OH-PA,! 1962PHOTOREVISED 1979; AND SHARPSVILLE, PA, 1958PHOTORE^SEO ,1981. SCALE 1:24000. PITTSBURGH. PENNSYLVANIA

4000 FT.

FIGURE 1SITE LOCATION MAP 2

FORMER TRANSFORMER FACILITY c\jSHARON, PENNSYLVANIA cr>

• PREPARED FORWESTINGHOUSE ELECTRIC CORPORATION

[UMMINGSIJZZX"CONSULTANT INC

DRAWING NUMBER93111A3

DRAWN BY: B. MAURER DATE: J-M-P4CHECKED BY W. BAUGHMAN DATE: J-/4-94

REVISION DATE DESCRIPTION APPROVED BY: P. 0'«4/W ' DATE: 3-14-94-

EP A REGION ULSUPERPUND DOCUMENT MANAGEMENT SYSTEM

DOCID#_

IMAGERY COVFRUNSCANNABLE ITEM

Contact the CERCLA Records Center to view this document

S1TENAME

OPERABLE UNIT

REPORT OR DOCUMENT2>/ -/ T Isvfesior CDATE OF DOCUMENT

DESCRIPTION OF IMAGERY

NUMBER AM> TYPE OF IMAGERY fTEM(S),

APPENDIX A-" ' ' j

MISCELLANEOUS DATA

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