'FINAL REMEDIAL INVESTIGATION/FEASIBILITY STUDY WORK …

/

3 4 . 001

SITE-

Response Action Contract OTHER:

For Remedial, Enforcement Oversight, and Non-timeCritical Removal Activities at Sites of Release or

Threatened Release of Hazardous SubstancesIn EPA Region 8

U.S. EPA Contract No. 68-W5-0022

FinalRemedial Investigation/Feasibility Study Work Plan

Picayune Wood Treating SitePicayune, Mississippi

Work Assignment No.: 124-RICO-A4W2

Prepared By:

Reviewed By:

Approved By:

Timothy R. TurnerProject Engineer

Mike Profit

Date:

Date:

Gary P. demons, Ph.D.Region 4 RAC Program Manager

10457910

3 4 U02Contents

Figures ivTables vAcronyms and Abbreviations vi

Section 1 Introduction 1-1

Section 2 Site Description and Operational History 2-1

2.1 Site Description 2-12.2 Operational History 2-12.3 Wood Treating Process 2-52.4 Site Geology and Hydrogeology 2-7

2.4.1 Regional Geology 2-72.4.2 Site Geology and Topography 2-72.4.3 Regional Hydrogeology 2-82.4.4 Site Hydrogeology 2-9

2.5 Previous Investigations 2-92.6 EPA Remedial Actions 2-25

Section 3 Scope of Work 3-13.1 Task 1 — Project Planning and Support 3-1

3.1.1 Subtask 1.1-Project Planning •„ 3-23.1.2 Subtask 1.2-Preparation of Site-Specific Plans 3-43.1.3 Subtask 1.3-Project Management 3-43.1.4 Subtask 1.4—Subcontract Procurement/Support Activities 3-63.1.5 Subtask 1.5-External Audit or Review 3-73.1.6 Subtask 1.6-Quality Assurance 3-73.1.7 Subtask 1.7-Pollution Liability Insurance 3-93.1.8 Subtask 1.8-Conflict of Interest 3-9

3.2 Task 2—Community Relations 3-93.2.1 Subtask 2.1-Prepare a Community Relations Plan-N/A 3-93.2.2 Subtask 2.2-Prepare Fact Sheets-N/A 3-93.2.3 Subtask 2.3 - Public Hearing, Meeting, and Availability

Support-N/A 3-93.2.4 Subtask 2.4 — Maintain Information Repository and

Mailing Lists-N/A 3-93.2.5 Subtask 2.5-Proposed Plan Support 3-93.2.6 Subtask 2.6 —Responsiveness Summary Support 3-9

3.3 Task 3-Data Acquisition 3-93.3.1 Subtask 3.1-Mobilization and Demobilization 3-103.3.2 Subtask 3.2-Field Investigation 3-10

3.4 Task 4-Sample Analysis 3-16

COMWP-V1_!

34 ... u u 3Contents

Picayune Wood Treating, Inc. Site Final RI/FS Work Plan

3.4.1 Subtask 4.1 —Screening-Type Laboratory SampleAnalysis-N/A 3-16

3.4.2 Subtask 4.2-CLP-Type Laboratory Sample Analysis 3-163.5 Task 5-Analytical Support and Data Validation 3-17

3.5.1 Subtask 5.1 —Prepare and Ship Environmental Samples 3-173.5.2 Subtask 5.2 — Coordinate With Appropriate Sample

Management Personnel 3-173.5.3 Subtask 5.3 — Implement EPA-Approved Laboratory QA

Program-N/A 3-173.5.4 Subtask 5.4 —Provide Sample Management 3-173.5.5 Subtask 5.5-Validate Data 3-17

3.6 Task 6-Data Evaluation 3-173.6.1 Subtask 6.1 -Data Usability Evaluation and Field QA/QC 3-173.6.2 Subtask 6.2-Data Reduction, Tabulation, and Evaluation 3-173.6.3 Subtask 6.3-Web CIS 3-183.6.4 Subtask 6.4-Develop Data Evaluation Report 3-19

3.7 Task 7-Assessment of Risk 3-193.7.1 Subtask 7.1 -Human Health Assessment 3-203.7.2 Subtask 7.2-Ecological Risk Assessment 3-233.7.3 Refinement of BERA COPCs 3-26

3.8 Task 8-Treatability Study and Pilot Testing-N/A 3-263.9 Task 9 —Remedial Investigation Report ; 3-26

3.9.1 Draft RI Report 3-263.9.2 Final RI Report 3-26

3.10 Task 10-Remedial Alternatives Screening 3-273.10.1 Subtask 10.1 - Remedial Alternatives Objectives

Establishment 3-273.10.2 Subtask 10.2 —Technology Identification and Screening 3-283.10.3 Subtask 10.3 — Alternatives Configuration and Screening 3-28

3.11 Task 11—Remedial Alternatives Evaluation 3-283.12 Task 12-Feasibility Study Report 3-293.13 Task 13-Post-Remedial Investigation/Feasibility Study Support 3-30

3.13.1 Subtask 13.1 — Attend Public Meetings, Briefings, andTechnical Meetings With PRPs; Prepare Presentation Materials 3-30

3.13.2 Subtask 13.2-Provide Technical Assistance-Responsiveness Summary 3-31

3.13.3 Subtask 13.3 — Provide Technical Assistance — ProposedPlan and ROD 3-31

3.14 Task 14-Negotiation Support-N/A 3-313.15 Task 15 - Administrative Record-N/A 3-313.16 Task 16-Work Assignment Closeout 3-31

COMWP-V1_12J Draft/0826

- u 0 4Contents

Picayune Wood Treating, Inc. Site Final RI/FS Work Plan

Section 4 Period of Performance and Schedules .................................................................... 4-14.1 Work Assignment Period of Performance ............................................................ 4-14.2 Schedule of Deliverables/ Milestones ................................................................... 4-1

Section 5 Project Personnel and Responsibilities .................................................................. 5-1

Section 6 References .................................. . ...................................................................................... 6-1

COMWP-V1_12« OraWOBZB

Figures

COM

3 4 0005

2-1 Site Location Map 2-22-2 Site Layout Map 2-32-3 Monitoring Well Location Map 2-102-4 Extent of Soluble Plume - 1987 (as mapped by H. M. Rollins Company) 2-112-5 Extent of Naphthalene Plume - 1994 (as mapped by Pine Belt

Environmental, Inc.) 2-132-6 Extent of Naphthalene Plume - 1994 (as mapped by Pine Belt

Environmental, Inc.) 2-142-7 Extent of Naphthalene Plume - January 2003 2-203-1 Proposed Soil Sampling Grid 3-113-2 Proposed Sediment Sampling Locations 3-123-3 Proposed DPT Groundwater Sampling Locations and Temporary

Monitoring Well Locations 3-14

IV

WP-V1.124 Draft/0826

3 4 u 0 0 6

Tables

2-1 Groundwater Metal Analytical Results - January 2003 2-152-2 Groundwater Extractable Analytical Results - January 2003 2-162-3 Groundwater Volatile Organic Analytical Results - January 2003 2-184-1 Schedule for CDM Federal Deliverables/Milestones 4-15-1 CDM Federal Project Team Personnel and Responsibilities 5-1

CDMWP-V1_124 Drsn/0826

Acronyms and Abbreviations3 4 0007

AOCARARARCSBERAbgsBRACAPCBICDMCLPcm/secCOCCOICOPCCOPECCRPCTEDCNDPTDQODRGEISOPQAM

EPAFSFSPGWQAPHASPHEASTHHBRAHIHQHSWAIDWIEUBK ModelIMRPIRISITLOEMCL

area of concernapplicable or relevant and appropriate requirementAlternative Remedial Contract Strategybaseline ecological risk assessmentbelow ground surfaceBaseline Risk AssessmentCorrective Action PlanConfidential Business InformationCDM Federal Programs CorporationContract Laboratory Programcentimeters per secondchemical of concernConflict of Interestchemical of potential concerncontaminant of potential ecological concernCommunity Relations PlanCentral Tendency Exposuredocument control numberDirect Push Technologydata quality objectivedigital raster graphic 'Environmental Investigations Standard Operating Proceduresand Quality Assurance ManualU.S. Environmental Protection AgencyFeasibility StudyField Sampling PlanGroundwater Quality Assessment PlanHealth and Safety PlanHealth Effects Assessment Summary TablesHuman Health Baseline Risk Assessmenthazard indexhazard quotientHazardous and Solid Waste Amendmentinvestigation-derived wasteIntegrated Exposure Uptake Biokinetic ModelInterim Measures Remediation PlanIntegrated Risk Information SystemIT Corporationlevel of effortmaximum contaminant levelmicrograms per liter

CDM VI

1_124 DraM)B20

3 4 o U 0 8Acronyms and Abbreviations

Picayune Wood Treating, Inc. Site Draft RI/FS Work Plan

MDEQMDNRmg/kgNAPLNCPNGVDNOAELODBCOSWERPAHPCPPLI premiumPOTWPRGPWTSQAQAPPQCQMPRAGRAGSRCRARFARFIRGORIRMERODRPMSAPSERASESDSISMPSOPSOWSVOCSWMUTALTOGTOHTRV

Mississippi Department of Environmental QualityMississippi Department of Natural Resourcemilligrams per kilogramnonaqueous phase liquidNational Contingency PlanNational Geodetic Vertical Datumno-observed-adverse-effect-levelOpen Database ConnectivityOffice of Solid Waste and Emergency Responsepolycyclic aromatic hydrocarbonpentachlorophenolpollution liability insurance premiumpublicly-owned treatment workPreliminary Remediation GoalPicayune Wood Treating, Inc. Sitequality assuranceQuality Assurance Project Planquality controlQuality Management PlanRemedial Action ContractRisk Assessment Guidance for SuperfundResource Conservation and Recovery Act ;

RCRA facility assessmentRCRA facility investigationRemedial Goal OptionRemedial Investigationreasonable maximum exposureRecord of DecisionRemedial Project ManagerSampling and Analysis Planscreening-level ecological risk assessmentScience and Ecosystem Support DivisionSite InspectionSite Management PlanStandard Operating ProcedureStatement of Worksemi-volatile organic compoundsolid waste management unitTarget Analyte ListTotal Organic CarbonTotal Organic Halogentoxicity reference value

COM VII

WP-V1 124 Dmfl/0826

3 4 U G 0 9Acronyms and Abbreviations

Picayune Wood Treating, Inc. Site Draft RI/FS Work Plan

UCL upper confidence limitUSAGE U.S. Army Corps of EngineersVOC volatile organic compoundWA Work AssignmentWAF Work Assignment FormWeb GIS Web-Enabled Geographic Information SystemWTI Wood Treating, Inc.

COM VIII

3 4 ,;010

Section 1IntroductionThe objective of this work assignment is to conduct a Remedial Investigation/Feasibility Study (RI/FS) for the Picayune Wood Treating, Inc. Site (PWTS) located inPicayune, Pearl County, Mississippi. This work plan describes the scope of work,identifies key personnel, and presents the associated level of effort, costs, andschedule for performing these tasks. The work will be conducted under Contract No.68-W5-0022 and work assignment number 124-RICO-A4W2 issued to CDM FederalPrograms Corporation (CDM) on September 13, 2002 (EPA 2002). The U.S.Environmental Protection Agency (EPA) has defined the tasks that CDM will performunder this work assignment.

• Task 1 — Project Planning and Support

• Task 2—Community Relations

• Task 3 — Data Acquisition

• Task 4—Sample Analysis

• Task 5 — Analytical Support and Data Validation

• Task 6—Data Evaluation

• Task 7—Risk Assessment

• Task 9—Remedial Investigation Report

• Task 10 — Remedial Alternatives Screening

• Task 11 — Remedial Alternatives Evaluation

• Task 12 - Feasibility Study Report

• Task 13—Post-Feasibility Study Support

• Task 16—Work Assignment Closeout

Tasks 8,14, and 15 were listed as part of EPA's breakdown structure but were deemednot appropriate to this work assignment by EPA. A few other subtasks are includedto address contractual requirements. They are 1.5 —External Audit or Review, 1.6 —Quality Assurance, 1.7—Pollution Liability Insurance, and 1.8 — Conflict of Interest(COI). One revision of this Work Plan (Draft to Final) has been costed under theProject Planning and Support Task (Task 1) of the Work Assignment (WA). Any

CDM 1-1WP-V1 124 Drafl/0826

3 4 oU11Section 1

Introduction

additional revisions to the Final Work Plan will require a Work Assignment Form(WAF) from EPA. Revision to scope and/or costs will be based on discussions withEPA and its vision of CDM support required for the work assignment throughOctober 31, 2004.

CDM 1-2WPM/1_124 Draft/0826

3 4 - 0 0 1 2Section 2Site Description and Operational History

2.1 Site DescriptionThe PWTS is a 30-acre site located at 403 Davis Street in the city of Picayune, PearlRiver County, Mississippi. The site is located near the center of Section 15,Township 16 South, Range 17 West at longitude 89° 41' 30 " and latitude 30° 31' 30".Figure 2-1 shows the location of the PWTS. The plant is located within an industrialcomplex that once included a sawmill, veneer mill, a wooden box factory, and a tungoil extraction facility. Abandoned buildings and concrete foundations of these formerfacilities are located near the northern and southern property lines. The only industrypresently operating at the industrial complex is a paint blending company located tothe north of the site.

Figure 2-2 shows the layout of the site when it was operational. The main processarea is located near the eastern portion of the site. The main process area includes thecreosote, pentachlorophenol (PCP), and diesel storage tank area, oil/water separatortanks, the treatment vessels, and the treatment building. The closed cooling waterimpoundment and the biological treatment storage tanks are located to the north ofthe main process area. The wastewater treatment plant is located to the south of themain process area. The central portion of the site is the product storage area. Theclosed trench impoundments are located in the western portion of the site.

2.2 Operational HistoryThe facility utilized a pressurized wood treating process to produce wood products(primarily utility poles and foundation piling). The wood preserving plant wasconstructed in 1945-1946 by Crosby Forest Products, Inc. Crosby Wood Preserving,Inc. purchased the plant and other manufacturing operations in 1963. Wood Treating,Inc. (WTI) purchased the wood preserving facility and approximately 30 acres of landin 1973 and operated the plant until it was closed in 1999.

WTI closed two hazardous waste management units that were former surfaceimpoundments utilized to manage the waste (process waste water and/or sludge)generated during the treatment operations. The first impoundment area is the formercondenser cooling water pond, which is located in the eastern portion of the site. Thecooling water pond is believed to have been constructed when the facility beganoperations in 1946. The former cooling pond reportedly covered an area ofapproximately 5,000 square feet and had a maximum depth of about 8 feet. Thesecond impoundment area is the former trench impoundments. The trenchimpoundments are located in the western portion of the site and were constructedbetween 1975 and 1980. The former trench impoundments consisted of three trenchesthat reportedly were 400 feet long, 25 feet wide, and 7 feet deep.

2-1wp-vi_i24

J013

PEARL RIVER COUNTY

,:--lI Hickory 1

FORRESTCOUNTY

HANCOCKCOUNTY

PICAYUNE WOODTREATING, INC. 1'ndus^'

SITE

ST. TAMMANYCOUNTY

NOT TO SCALE

Figure 2-1Site Location Map

Picayune Wood Treating, Inc.Picayune, Mississippi

Source Mississippi Automated Resource Information System, aerial (March 2001) and bpographic atntues (2002)l fnm: Dunaway F H survey. Decen«er22,1994.

Scale in FeetWest Mississippi Stale Plane. NAD S3

Figure 2-2Site Layout


4 J014

COM

Section 2Site Description and Operational History

3 4 ,,015The cooling water pond and the trench impoundments were closed under theResource Conservation and Recovery Act (RCRA) and a Hazardous WastePost-Closure Permit was issued in August 1989. The impoundments were closed byremoving all pumpable sludges, solidification of the remaining sludges, and cappingthe impoundments with a "very impermeable" cap (Rollins 1987). The volume withinthe closed cooling water pond is estimated to be 30,000 cubic feet. The closed trenchimpoundments cover an area of about 27,000 square feet and contain an estimatedtotal volume of 93,160 cubic feet.

Groundwater contamination was discovered beneath the two closed impoundmentsin 1985. Subsequently, a groundwater quality assessment plan consisting of 37 soilborings and 29 monitoring wells was implemented. A Corrective Action Plan (CAP)was implemented for remediation of the groundwater contamination. In October1991, WTI installed six recovery wells as part of a groundwater pump and treatsystem. WTI operated the corrective action system to recover nonaqueous phaseliquids (NAPL) and contaminated groundwater.

The Mississippi Department of Natural Resource (MDNR) and the MississippiDepartment of Environmental Quality (MDEQ) inspected the PWTS several timesbetween 1981 and 1998. Deficiencies and RCRA violations noted during theinspections included: failure to control entry into the surface impoundments andtrenches; old sand filter bed not in compliance with RCRA; incomplete closure plansfor hazardous waste disposal units; failure to properly locate and sample monitoringwells; failure to properly inspect impoundments for leaks, deterioration, or failure;failure to maintain operating records; failure to operate groundwater pumpingsystems for recovery and treatment of contaminated groundwater; and failure toinstall a drip pad in the process area.

In April 1988, EPA issued a RCRA Facility Assessment (RFA) report that identified 10solid waste management units (SWMUs) and one area of concern (AOC). EPA issueda Hazardous and Solid Waste Amendments (HSWA) permit to WTI on September 22,1989. On June 10,1994, WTI submitted final amendments to the RCRA FacilityInvestigation (RFI) Plan and EPA approved the plan on July 12,1994. On January 9,1995, WTI issued the Draft RCRA Facility Investigation Report.

On November 11,1996, the facility submitted the final Phase 1 RFI. On April 1,1997,the facility submitted an Interim Measures Remediation Plan (IMRP) to address theconcerns raised by EPA during the RFI. WTI proposed reclamation of useable fluidsand sludge from the wood process, and on-site bioremediation of the contaminatedsoils. EPA approved the IMRP on July 29,1997; however, in December 1997, WTIrequested a postponement of the remedial activities due to litigation with theprevious owner and operator. In January 1998, EPA notified WTI thatimplementation of the Phase II RFI work plan should begin within 30 days; however,on February 25,1998 WTI requested a postponement of the Phase II RFI until asettlement could be reached between the current and former owners. A second

2-4

WP-V1 124 Draft/0826


3 4lawsuit was filed by the insurers of the facility to contest the insurance coverage. Thefacility ceased operations in 1999.

2.3 Wood Treating ProcessPrior to 1982, the chemicals used in the wood treatment process were coal tar creosoteand PCP in a petroleum carrier. After 1982, only creosote was used. The followingdescription of wood treating operations was obtained from the Groundwater QualityAssessment (Rollins 1987).

The wood preserving process requires a conditioning cycle followed by the impregnation cycle.The conditioning cycle removes sufficient natural moisture and saps to allow injection of therequired quantity of preservative chemical. This plant has used a steam/vacuum conditioningcycle. In this cycle, the wood to be preserved is placed in the pressure impregnation retort andis heated to 245° F by saturated steam far a period of 10-16 hours. Condensate, contaminatedwith residual preservative from the retort and sap extractives from the wood, is continuouslybled from the retort.

At the end of the steaming period, the retort is vented to the atmosphere and a vacuum of 23inches mercury minimum, is applied as rapidly as possible for a period of 2-3 hours. Prior to1985, a direct contact barometric condenser ivas used to condense any condensable vaporsremoved during this time. The cooling water for the condenser was stored in an unlinedcooling water surface impoundment constructed in 1946. The cooling water collected allcondensable organic vapors which left the retort during the vacuum phase. In 1985, processequipment was changed to replace the barometric condenser with a surface condenser. Thelarge volume of direct contact cooling water was replaced by a small volume of non-contactcooling water in a tank and a cooling tower. The condensable vapors are now collected in acondensate tank and pumped to the wastewater treatment system.

After completion of this conditioning cycle, the retort isfilkd with preservative and the woodis impregnated by raising preservative pressures to 150-200 psig. The wood is removed fromthe retort and the cycle begins again.

The wastewater stream from the steaming cycle and the condenser cooling water arecontaminated process wastewaters. Sludge generated from the treatment of processivastewaters is defined as hazardous waste by 40 CFR 261.32 as K001: "Bottom sedimentsludge from the treatment of wastewater from wood preserving processes that use creosoteand/or pentachlorophenol. "

This plant has tivo areas which were used to manage process ivastewater and/or sludge fromthe treatment of these waters. The recycled cooling water was stored in an unlined surfaceimpoundment. This impoundment was not designed or operated as a "wastewater treatment"unit. Some sludges did accumulate in the bottom oftiie impoundment. The State ofMississippi has ruled that this impoundment contained K001.

COM 2-5

WP-V1_124 DraTV0826


3 4 .,017Since the early 1970's, the steaming condensate process wastewater stream has been treated bygravity oil/water separation followed by chemical flocculation and sedimentation. Theflocculated wastewater has been discharged to the City of Picayune sanitary sewer system. In1975, the northern most "trench impoundment" was dug. The flocculation sludge from tiiewastewater treatment system, along with some creosote tank bottoms from the woodpreserving operations, were placed in this impoundment. Subsequently, betiveen 1975 and1980, tiuo additional trench impoundments were dug. They were also used for tliestorage/disposal of the same wastes. No wastes were added to these impoundments after 1980.

Changes were made in 1980 which allow recycling of the flocculation sludge to the creosotepreservative system. Process equipment changes were completed in 1985 to allow removal ofthe barometric condenser which eliminated the need for the cooling water impoundment.

All impoundments at the site were closed by removal of all pumpable sludges, solidification ofthe remaining sludges, and placement of a very impermeable cap over the impoundment sitesin accordance an approved closure plan.

Waste Generation

The treatment cycle generated a wastewater stream from the steaming cycle andcondensed vapors that are contaminated with creosote. The wastewater stream wastreated on-site in the facility's wastewater treatment plant. Other waste streamsources include drips, spills, and other loses of preservative, and spent preservativethat was no longer suitable for use in the treatment process. The operations producedthe following listed hazardous waste as defined by RCRA Part 26l of 40 CFR:

• K001 — Bottom sediment sludge from the treatment of wastewater from woodpreserving processes that use creosote and/or PCP,

• U051 — Commercial chemical products, manufacturing chemical intermediates, oroff-specification commercial chemical products containing creosote),

• F032—Wastewater (except those that have not come into contact with processcontaminants), process residuals, preservative drippage, and spent formulationsfrom wood preserving processes generated at plants that currently use or havepreviously used chlorophenolic formulations, and

• F034 — Wastewater (except those that have not come into contact with processcontaminants), process residuals, preservative drippage, and spent formulationsfrom wood preserving processes generated at plants that currently use or havepreviously used creosote formulations.

2-6



3 4 ,;0182.4 Site Geology and Hydrogeology2.4.1 Regional GeologyThe site is located in the Pine Meadows Belt of the East Gulf Coastal PlainPhysiographic Province. The Pine Meadows Belt consists of Pleistocene Terracesfeaturing low, seaward facing scarps and shallow swales bordered by slightly higherground having the appearance of natural levees. Surface deposits in this belt aredescribed as loam, sand, gravel, and clay.

Geologic formations of concern are the Pamlico Sand of Pleistocene age, which ismapped as a surface outcrop in the immediate vicinity of the site; the underlyingCitronelle Formation and/or reworked Citronelle terrace material of Pliocene orPleistocene age and the Graham Ferry formation of Pliocene age. The Pamlico Sand isreported to vary in thickness from 1 to 75 feet and is composed of gray and tan sandwith occasional lagoonal deposits of clay and silt. The Citronelle formation isreported to consist of red sands, gravels, and gravel-sand-clay mixture with some thinclay strata. The thickness ranges from a thin mantle to approximately 160 feet thick.The Graham Ferry formation is identified as a series of deltaic deposits between thePleistocene Citronelle and the Miocene Pascagoula. Being deltaic, it contains bothmarine and continental deposits and ranges in thickness from approximately 100 to1,000 feet. It includes silty clay, shale, silty sand, clean sand, and gravelly sand. ThePascagoula formation, which underlies the Graham Ferry formation, is similar inlithology and the two formations are sometimes mapped as a common unit. Massiveclay beds of very low permeability are common to both units.

2.4.2 Site Geology and TopographyMaximum relief within the entire site area is less than 7 feet with an average elevationof 59 feet National Geodetic Vertical Datum (NGVD). Site runoff is collected insurface ditches and is eventually discharged into Mill Creek, a small tributary to thePearl River at a point approximately one-half mile southwest of the site. The PearlRiver is located approximately 3 miles to the southwest of the site.

The near surface geologic profile is relatively consistent throughout the site andconsists of three distinct horizons. The first extends from the surface to depthsranging from 10.5 to 51 feet and averages 37.2 feet in thickness. This upper layerconsists primarily of fine-grained soils (silts and clays) with seams/layers of fine sandand fine silty sand. This material is tentatively identified as a lagoonal deposit withinthe Pamlico Sand but may also be recent alluvium.

The next layer, which ranges in thickness from approximately 20 to 64 feet, isidentified as the Citronelle formation of Pleistocene age. The unit is composedentirely of granular sediments from fine to medium quartz sands to coarse gravellysands and is the uppermost aquifer at the site.

2-7

WP-V1 124Dr3fV0826


3 4 -019Underlying the Citronelle formation at depths ranging from 69 to 75 feet is acontinuous, massive bed of homogeneous, high plasticity clay with a measuredpermeability of 2.12 x 1O9 centimeters per second (cm/sec). This is assumed to be thetop of the Graham Ferry formation of Pliocene age. H. M. Rollins Company, Inc.drilled up to 20 feet into this layer with no change in lithology. Logs of deep-waterwells located within the immediate vicinity of the site show that the clay layer has athickness of 100 to 300 feet.

2.4.3 Regional Hydrogeology

Southern Mississippi has extensive groundwater resources in the Citronelle aquiferand the Miocene aquifer system. The aquifer system that underlies the Citronelleaquifer in the general vicinity of the site is generally referred to as the "Mioceneaquifers."

The Citronelle occurs at a higher elevation in a band across south Mississippi and isoften the local water table. The Citronelle aquifer has an average thickness of 45 feetand an average conductivity of 150 feet/day. The quality of the groundwater isgenerally good, with soft to moderate hardness and a low mineral content; however,the water characteristically has a low pH. The Citronelle aquifer is considered to bean important source of domestic and light industrial water in those areas where itexists in sufficient thickness. A massive continuous clay member of the Graham Ferryformation separates the Miocene aquifers from the overlying Citronelle aquifer.

The Miocene aquifer system is the most widely used aquifer in south Mississippi andsupplies the City of Picayune. The City of Picayune maintains five municipal waterwells that serve approximately 10,683 persons (EPA 2001a). The City of Picayunedrinking water wells are completed at depths of 1,042 feet or greater. The four nearestwells are City of Picayune Wells 1, City of Picayune Well 2, City of Picayune Well 3,which are located within 0.25 to 0.5 mile east of the site. City of Picayune Well 4 islocated 1.75 miles northeast of the site and City of Picayune Well 5 is located 0.6 milesouth of the facility. In addition to the City of Picayune's municipal water wells,Dixie Utilities and the Nicholson Water & Sewer Association provide potable water tothe community. These two utilities have a total of four wells located within 2 to3 miles of the site and completed at depths ranging from 365 to 490 feet.

The 2001 Preliminary Assessment/Site Inspection Report (EPA 2001a) estimated that1,776 persons obtain potable water from private wells located within a 4-mile radiusof the site. Data compiled by the U.S. Geological Survey show that of the 285 wellslocated within a 4-mile radius of the site, only six are producing from the Citronelleaquifer. A public ordinance prohibits the existence of private drinking water wellswithin a 3-mile radius of the site.

COMWP-V1 124 Draft/0826

2-8


3 4 ,0202.4.4 Site HydrogeologyThe uppermost aquifer at this site is the Citronelle aquifer. Groundwater flow withinthis aquifer is toward the west with a gradient of approximately 0.001 feet/feet. Thehydraulic conductivity is approximately 200 feet/day (Pine Belt Environmental, Inc.1996). Pine Belt Environmental, Inc. calculated an average linear groundwater flowrate of 0.7 foot/day, assuming a porosity of 30 percent. There is also a slightdownward vertical groundwater flow component within this aquifer.

A massive clay member of the Graham Ferry formation separates the Citronelleaquifer from the underlying Miocene aquifers. The presence of the Graham FerryFormation was confirmed in 11 borings across the site during the 1986-1987 siteinvestigations. H. M. Rollins Company, Inc. tested samples of the clay from theGraham Ferry Formation and determined that the permeability of the soil is2.12 xlO-9 cm/sec.

2.5 Previous InvestigationsGroundwater

WTI installed the initial groundwater monitoring system (MW-1 through MW-4) inNovember 1982. MDNR requested that a fifth well (MW-5) be installed between wellsMW-3 and MW-4. The first semi-annual sampling of wells MW-1 through MW-5indicated a "statistically significant" increase in Total Organic Carbon (TOC) andTotal Organic Halogen (TOH) in wells MW-4 and MW-5 (Rollins 1987). This increasewas confirmed by replicate analyses and MDNR was notified on July 16,1985. AGroundwater Quality Assessment Plan (GWQAP) was submitted to MDNR onJuly 30,1985 and approved on September 16,1985.

WTI installed four additional monitoring wells (MW-6, MW-7, MW-8, and MW-9)down gradient of the closed cooling pond during August of 1985. The analyticalresults of groundwater from wells MW-1 through MW-9 during August 1985 showedgroundwater contamination down gradient of the closed cooling pond and the closedtrench impoundments. As part of the GWQAP, 21 additional monitoring wells(MW-10 through MW-20, MW-21S, MW-21D, and MW-22 through MW-29) wereinstalled between January 1986 and February 1987. Figure 2-3 shows the locations ofthe 30 monitoring wells. Analytical groundwater data collected from the monitoringwell network confirmed the presence of site related contaminants in the groundwater.Figure 2-4 shows the estimated extent of the soluble plume as mapped byH. M. Rollins Company in 1987.

In January 1992, WTI began the groundwater extraction/treatment system at the site.The groundwater monitoring system consisted of 30 wells divided into ComplianceMonitoring Wells (sampled quarterly), Corrective Action Effectiveness MonitoringWells (sampled semi-annually), and Boundary Monitoring Wells (sampled semi-

CDM 2-9WP-V1_I2

MW-22»>

MW-25

*/ fviV

* MW-23

Biological-, Treatment

j ^NJankAme

X 'NM

Closed CoolingWater Pond

MW-13

•

Closed Trench Impoundments

T4 MVM *MW'5

MW-10 I MW-3*~** MW-11

RW-2iO

* MW-16MW-17

South Side UpperElementary School

<§ MW-21SSD

Product Storage Area

MW-15*

6RVW

Ricnard Street

Copper ChromiumArsenal* Facility

/

4Legend

$ Existing Monitoring Well Location

V Well Screen Depth 30-40 Feet

4r Well Screen Depth 40-50 Feet

9 Well Screen Depm 60-65 Feet

Destroyed Monitoring Well Location

O Existing Recovery Well Location

— Site Boundary

Dilch

Railroad

OrvSite Gravel Road

Pond

i Culvert

Source Mississippi Automated Resource Information System, topographic attributes. 2002Adapted ten. Dunawar. F.H.. survey. December 22, 1994

Scale in FeetWest Mississippi State Plane, NAD 63

Figure 2-3Monitoring Well Location MapPicayune Wood Treating, Inc.

Picayune, Mississippi

3 4 .021

RW-1 «MW-24

Estimated Extentof Soluble

Closed Trench Impoundment! » MW21SiO

Product Storage Ant

Copper ChromiurrArsenate Facility

South Side UpperElementary Schoo

Monitonng Wan LocatorO Recovery Wall Location

CO Naphthalene PlumeSin Boundary

— - DitchSteamRailroad

On-Site Grauel RoadPond

:=: Culvert

Source: Mississippi Automated Resource Information System, topographic attributes (2002).AOi/Mdtrom:(1) Dunanoy, F.H.. survey, December 22.1994.(2) H. M. Rollins Company, Qraundwater Plumes Map. 1987. 0 100 200

Scale In FeetWest Mississippi State Plane. NAD 83

Figure 2-4Extent of the Soluble Plume - 1987


3 4 ,.022

CDM


3 4 J023annually). The post-closure ground water monitoring report dated October 21,1996reported that approximately 144 million gallons of contaminated groundwater hadbeen recovered, treated, and discharged to the City of Picayune municipal watertreatment system. Approximately 2,925 gallons of creosote oil had been returned tothe wood treating process. The extraction/treatment system was apparentlysuccessful in reducing the Closed Cooling Water Pond groundwater plume.Figures 2-5 and 2-6 show the extent of the naphthalene plume as mapped by Pine BeltEnvironmental, Inc. based on the 1994 and 1996 data, respectively.

In January 2003, EPA contracted CDM to collect groundwater samples from theexisting wells at the site. The plan was to sample all of the 30 monitoring wellsinstalled by WTI. During the site reconnaissance phase, the field crew discovered thatsix of the 30 monitoring wells (MW-1, MW-16, MW-23, MW-24, MW-27, and MW-29)had been destroyed. In addition, the owner of the property located to the west of thesite, where wells MW-13 and MW-14 are located, would not allow access on theproperty, so samples could not be collected from these two wells. The sampling crewcollected groundwater samples from the 22 remaining monitoring wells. Freeproduct was found in wells MW-6 and MW-8; therefore, the groundwater samplescollected from these two wells were not sent to the Contract Laboratory Program(CLP) laboratory. The groundwater samples from the 20 monitoring wells sampledwere sent to a CLP laboratory for semi-volatile organic compound (SVOC) andvolatile organic compound (VOC) analysis. The groundwater collected from wellsMW-3, MW-7, MW-9, MW-15, MW-19, MW-22, and MW-28 was also analyzed forTarget Analyte List (TAL) metals at a CLP laboratory. The analytical results aregenerally similar to the historic groundwater data except at well MW-18, whichshows significant naphthalene contamination [2,200 micrograms per liter (ng/L)]migrating off-site southward from the closed trench impoundments. Tables 2-1through 2-3 present the groundwater analytical data collected during the January2003 investigation. Figure 2-7 shows the extent of the extent of the naphthaleneplume based on the January 2003 data.

Soil/Sediment/Surf ace Water

As part of the RCRA Facility Investigation Report (Pine Belt Environmental, Inc.1995), Pine Belt Environmental, Inc. collected several soil samples from six of theidentified SWMUs, the one identified AOC, and the background area. Theinvestigation findings are presented below:

SWMU No. 1 - Treated Wood Storage Area

SWMU No. 1 is the treated product storage area that was used as temporary storageof treated wood until it was shipped to the customer. Two areas had been used sincethe plant began operations in 1946. Treated wood was placed directly on the groundin the storage areas without protection from the elements or secondary containment.The storage areas were referred to as the western storage area and the eastern storagearea due to their relative location with respect to the Davis Street extension, which

2-12

WP-V1.124 Draft/0826

Cbeed Trench ImpoundmentsMW-21S4D*


»MV\M2 i V .

Copper ChromiumAmenate Facility

South Side UpperElementary School

• Monitoring Well Locationo Recovery Well Location

Naphthalene PlumeSite Boundary

' ™~ DitchStreamRailroadOn-Srte Gravel RoadPond

— Culvert

Source. Mississippi Automated Resource mftxmation System, topographic attributes (2002).Adapted from(1) Ounaway, F.H.. survey. December22.1994.(2) Pine Bell Environmental, Inc. Groundvwner Naphthalene Map. 1994. 0 100 200

Scale in Feetwest Mississippi Slate Plane. NAD 83

Figure 2-5Extent of the Naphthalene Plume -1994


3 4 -'024

Closed Trench Impoundments


Copper ChromiuiTArserwte Fadlily

South Side Upper\ .' EMworySct

* Monitoring Wall Loader0 Recovery Well location

CO Naphthalene Plume—~ Site Boundary

DitchStreamRailroadOrvSIU Gravel RoadPond

=; Culvert

Source: Mississippi Automated Resource Information System, topographic attributes (2002).Adspied fnfft:(1) Dunaway, F.H.. survey, December 22, 1994(2) Pine Belt Environmental, Inc., Grounitwater Naphthalene Map, 1996 400

Scale in FeetWest Mississippi State Plane, NAD 83

Figure 2-6Extent of the Naphthalene Plume - 1996


3 4 .025

3 4 , 026Table 2-1 Groundwater Metal Analytical Results - January 2003

Analyte

AluminumAntimonyArsenicBariumBerylliumCadmiumCalciumChromiumCobaltCopperIronLeadMagnesiumManganeseMolybdenumNickelPotassiumSeleniumSilverSodiumStrontiumThalliumTinTitaniumTotal MercuryVanadiumYttriumZinc

MW-03

(ug/L)200 U1.0 U2.6511.5U

0.572.82.5 U1210 U

9.91.0U1.9505.0 U7.74.0 U2.0 U10 U14271.0 U10 U

5.0 U0.20 U2.5 U1.5U31'

MW-07

(ug/L)200 U1.0 U

23.0861.5 U

0.50 U5.72.5 U

811

20.01.0 U2.7705.0 U6.14.0 U2.0 U10 U14441.0 U10 U

5.0 U0.20 U2.5 U1.5 U14

MW-09

(ug/L)4401.0 U

13.01901.5 U

0.50 U16.02.5 U2010 U

7.81.0 U5.8

3405.0 U

13.08.72.0 U10 U15

1401.0 U10 U

5.0 U0.20 U2.5 U

25.036

MW-15

(ug/L)200 U1.0 U

23.0 A32 A1.5 U

0.50 U33.0 A2.5 U11 A10 U

19.0 A1.0 U4.1 A360 A5.0 U7.1 A4.0 U2.0 U10 U9 A

200 A1.0 U10 U

5.0 U0.20 U17.0 A

1.5 U21 A

MW-19

(ug/L)4401.0 U

15.01201.5 U

0.50 U7.82.5 U

3 D10 U

5.41.0 U2.6200.5.0U5.0 U

14.02.0 U10 U43791.0 U10 U

5.0 U0.20 U2.5 U1.5 U

5 U

MW-22

(ug/L)200 U1.0 U1.0 U

1601.5U

0.50 U14.02.5 U1510 U

0.11.0 U6.92605.0 U5.0 U5.42.0 U10 U20

1001.0 U10 U

5.0 U0.20 U2.5 U2.0

6

MW-28

(ug/L)200 U1.0 U1.5351.5 U

0.50 U0.52.5 U2410 U

4.11.0 U0.41205.0 U5.0 U4.0 U2.0 U10 U77

1.0 U10 U

5.0 U0.20 U2.5 U1.5 U

5 U

Note:U = Constituent analyzed for but not detectedJ = Estimated valueA = Averaged value 2-15

3 4Table 2-2 Groundwater Extractable Analytical Results - January 2003

J027Analyte

(3-and/or 4-)Me(hylphenol1,1-Biphenyl1 ,2.4-Trichlorobenzene2.3,4 ,6-Tetrachlorophenol2,4.5-Trichlorophenol2.4,6-Trichlorophenol2,4-Oichlorophenol2,4-Oimethylphenol2,4-Oinitrophenol2.4-Dinitrotoluena2.6-Dinitrotoluene2-Chloronaphthalene2-Chlorophenol2-Methyl-4,6-Dinitrophenol2-Methylnaphthalene2-Methylphenol2-Nitroaniline2-Nitrophenol3,3'-Dichlorobenzidine3-Nitroaniline4-Bromophenyl Phenyl Ether4-Chldro-3-Methylphenol4-Cnloroaniline4-Chlorophenyl Phenyl Ether4-Nitraaniline4-NitrophenolAcenaphtheneAcenaphthyleneAcetophenoneAnthraceneAtrazineBenzaldehydeBenzo(a)AnthraceneBenzo(b)FluorantheneBenzo(ghi)PeryleneBenzo(k)FluorantheneBenzo-a-PyreneBenzyl Butyl Phthalatebis(2-Chloroethoxy)Methanebis(2-Chloroethyl) Etherbis(2-Chloroisopropyl) Etherbis(2-Ethylhexyl) PhthalateCaprolactamCarbazoleChryseneDibenzo(a.h)AnthracenaDibenzofuranOiethyl PhthalateDimethyl PhthalateDI-n-ButylphthalateDi-n-OctylphlhalateFluorantheneFluoreneHexachlorobenzene (HCB)HexachlorobutadieneHexachlorocydopentadiene (HCCP)HexachloroethaneIndeno (1.2.3-cd) PyreneIsophoroneNaphthaleneNitrobenzenen-N itrosodi-n-Propylaminen-Nltrosodiphenylamine/OiphenylaminePentachlorophenolPhenanthrenaPhenolPyrene

MW-02

(ug/L)10 u10 U10 U10 U10 u10 U10 U10 U20 U10 U10 U10 u10 U20 U10 U10 U10 U10 u10 u10 U10 u10 u10 U10 U10 U20 U10 U10 U10 U10 U10 U10 U10 U10 U.10 U10 U10 U10 u10 U10 u10 u10 u

1.2 J10 U0 U

10 u10 U10 U10 U10 U10 u10 U10 U10 U10 u10 U10 U10 U10 U

3.3 J10 U10 U10 U20 U10 u10 u10 U

MW-03

(ug/L)10 u7210 U2 J

10 U10 U10 U10 U20 U10 U10 U10 U10 U20 U

400

10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U20 U

29017

10 U1910 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U

10.0 U350

10 U10 U

160

10 U10 U10 U10 U16

140

10 U10 U10 U10 U10 U10 U

3400.010 U10 U10 U13 J

15010 U13

MW-04

(ug/L)10 U10 U10 u10 u10 U10 U10 U10 U20 U10 u10 U10 U10 u20 U10 U10 U10 u10 u10 u10 u10 u10 u10 U10 U10 U20 U10 U10 U10 U10 U10 u10 U10 U10 U10 U10 U10 U10 U10 u10 u10 u10 u

7.2 J10 U10 u10 u10 u10 U10 U10 U10 U10 U10 U10 U10 U10 U10 u10 U10 u

10.0 u10 U10 U10 U20 U10 U10 U10 u

MW-4Dup

(ug/L)10 U10 U10 U10 U10 U10 U10 U10 U20 U10 u10 U10 U10 U20 U10 U10 U10 u10 u10 u10 u10 U10 u10 U10 U10 u10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U

7.3 J10 u10 u10 u10 u10 U10 U10 U10 U10 U10 U10 u10 U10 U10 U10 u10 U

10.0 U10 U10 U10 U20 U10 U10 U10 U

MW-05

(ug/L)1600130

10 U130

10 U10 U10 U

220020 U10 U10 U10 U10 U20 U

360800

10 u10 U10 u10 u10 U10 U10 U10 u

22020 U

490

40

10 U10 U10 U10 U10 u10 U10 U10 u10 u10 U10 U10 u10 u10 u

10.0 u1900

10 u10 u

300

10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 u10 U

4200.010 U10 U10 U

840310

430

10 U

MW-07

(ug/L)7800220

10 u45 J31 J10 U10 u

650020 U10 U10 U10 U10 U20 U

660

370010 U10 U10 U10 U10 U10 U10 u10 u10 U20 U

12001110 U7010 U10 U39

9 J2 U

1710 J10 U10 u10 u10 u10 U

10.0 u1500

3810 u

570

10 U10 U10 U10 U

310

480

10 U10 U10 U10 U2 J

10 U13000.0

10 U10 U10 U

610 J11003800

220

MW-09

(ug/L)1000

2510 u32 J40

10 U10 u

55020 U10 U10 U10 U10 u20 U

660600

10 U10 U10 u10 u10 U10 U10 U10 U10 U20 U

4905610 U6210 U10 U1 J

10 U10 U10 U10 U10 U10 U10 U10 U10 U

10.0 U520

1 J10 U

460

10 U10 U10 U10 U30

340

10 U10 U10 U10 u10 U10 U

11000.010 U10 U10 U38

370

340

21

MW-10

(ug/L)10 U93

10 U36

10 U10 U10 U

230

20 U10 U10 U10 U10 U20 U

630

110

10 U10 U10 U10 U10 U10 U10 u10 U10 U20 U

450

19

10 u10 u10 U10 U10 u10 U10 U10 u10 U10 U10 U10 U10 u10 U

10.0 U310

10 u10 U

19010 U10 U10 U10 U10 U

220

10 u10 U10 U10 U10 U10 U

3900.010 U10 U10 U

320360

2410 u

MW-11

(ug/L)10 u5 J

10 U10 U10 U10 U10 U1120 U10 U10 U10 U10 u20 U28

10 u10 u

• 10 U10 u10 U10 U10 u10 U10 u10 U20 U1310 U10 U10 U10 U10 U10 U10 U10 U10 U

.10 U10 U10 U10 u10 U10 U

10.0 U4010 u10 U14

10 U10 U10 u10 u10 U12

10 U10 U10 U10 u10 U10 U

200.010 u10 U10 U20 U9 J

10 U10 U

MW-12

(ug/L)10 U9 J

10 U10 U10 U10 U10 u10 u20 U10 u10 U10 U10 u20 U5 J

10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U20 U2610 U10 u2 J

10 U10 U10 u10 U10 U10 u10 U10 U10 U10 u10 U10 U

10.0 U6 J

10 U10 U30

10 U10 U10 u10 u2 J

2210 U10 U10 U10 U10 U10 U

25.010 U10 U10 U20 U2810 U2 J

MW-15

(ug/L)38

150

10 U220

5 J10 U10 u6020 U10 U10 U10 U10 U20 U

13002010 U10 U10 u10 U10 U10 U10 U10 u10 U20 U

660

22

37

40

10 U10 U8 J3 J

10 U4 J3 J

10 u10 U10 U10 U10 U

10.0 U1400

9 _ I10 U

36010 U10 U10 U10 u74

330

10

10 u10 U10 U10 U10 u

5200.0 U1010 U10 U

1700 U390

8

61 J


3 4 j028Table 2-2 Groundwater Extractable Analytical Results - January 2003

1 Analyte

(3-and/or 4-)Methylphenol1.1-Biphenyl1 .2.4-Trichlorobenzene2,3.4,6-Tetrachlorophenol2,4.5-Trichlorophenol2.4.6-Trichlorophenol2.4-Dichlorophenol2,4-Oimethylphenol2.4-Oinitrophenol2.4-Dinitrotoluene2,6-Oinilrotoluene2-Chloronaphlhalene2-Chlorophenol2-Methyl-4.6-Oinitrophenol2-Methylnaphthalene2-Methylphenol2-Nitroaniline2-Nitrophenol3.3'-Oichlorobenzidine3-Nitroanilina4-Bromophenyl Phenyl Ether4-Chloro-3-Methylphenol4-Chloroaniline4-Chlorophenyl Phenyl Ether4-Nitroaniline4-NitrophenolAcenaphtheneAcenaphthyleneAcetophenoneAnthraceneAtrazineBenzaldehydeBenzo(aJAnthraceneBenzo(b)FluorantheneBenzo(ghi)PeryleneBenzo(k)FluorantheneBenzo-a-PyreneBenzyl Butyl Phthalate .bis(2-Chloroethoxy)Methanebis(2-Chloroethyl) Etherbis(2-Chloroisopropyl) Etherbis(2-Ethy1hexyl) PhthalateCaprolactamCarbazoleChryseneDibenzo(a,h)AnlhracenaDibenzofuranDielhyl PhthalateDimethyl PhthalateDi-n-ButylphthalateOi-n-Octytphthalale:luorantheneFluoreneHexachlorobenzene (HCB)HexachlorobutadieneHexachlorocyclopentadiene (HCCP)HexachloroethaneIndeno (1,2,3-cd) PyreneIsophoroneNaphthaleneNitrobenzenen-Nitrosodi-n-Propylaminen-Nitrosodiphenylamine/OiphenylaminePentachlorophenolPhenanthrenaPhenolPyrene

MW-17

(ug/L)10 U10 U10 U10 U10 U10 u10 U10 U10 U10 U10 u10 U10 U20 U10 U10 U10 U10 u10 U10 U10 U10 U10 u10 U10 u20 U10 U10 u10 U10 U10 U10 u10 u10 u10 u10 U10 U10 U10 U10 U10 U10 U

4.4 J10 U10 u10 U10 U10 U10 u10 U10 U10 U10 u10 U10 U10 u10 U10 u10 U

10.0 U10 U10 U10 U20 U10 U10 U10 U

MW-18

(ug/L)10 U6610 U9 J

10 U10 U10 U10 U20 U10 U10 u10 U10 u20 U

340

10 u10 u10 U10 U10 U10 U10 U10 u10 U10 U20 U

260

27

10 U1010 U10 U10 U10 U10 u10 U10 U10 U10 U10 U10 U10 U

10.0 U320

10 u10 U

14010 U10 U10 U10 U3 J

110

10 U10 U10 U10 U10 U10 U

2200.010 U10 U10 U4 J

8710 U10 U

MW-19

(ug/L)26

65

10 U31

14

10 U10 U7020 U10 U10 U10 U10 U20 U

3601010 U10 U10 U10 U10 U10 u10 U10 U10 U20 U

190

15

19

10 u10 U10 U10 U10 U10 U10 U10 u10 U10 u10 U10 U10 U

10.0 U520

10 U10 U

11010 U10 u10 u10 U1170

10 u10 U10 u10 U10 U10 U

7500.010 U10 U10 U58

12010 U8 J

MW-21S

(ug/L)10 U9 J

10 U177 J

10 U10 U3 J

20 U10 U10 U10 U10 u20 U43

10 U10 u10 U10 U10 u10 U10 u10 U10 U10 u20832 J

10 U3 J

10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U

10.0 u130

10 U10 U5510 U10 U10 U10 U2 J

3510 U10 U10 U10 U10 U10 U

340.010 U10 U10 U542010 .U2 J

MW-21D

(U9/L)10 U10 U10 U10 U10 U10 u1 J

10 U20 U10 U10 U10 U10 U20 U10 U10 U10 U10 u10 U10 U10 U10 U10 U10 U10 U20 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 u10 U10 U10 U10 U10 U

2.6 J2 J

10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U

10.010 U10 U10 U20 U10 U10 U10 U

MW-22

(ug/L)10 U10 U10 u10 U10 U10 u10 U10 U20 U10 U10 u10 U10 U20 U10 U10 U10 u10 u10 U10 U10 U10 U10 u10 U10 U20 U10 U10 u10 u10 U10 U10 U10 U10 U10 U10 u10 U10 u10 u10 u10 u10 u

3.5 J10 U10 U10 U10 U10 U10 U10 U10 U10 U10 u10 u10 U10 u10 U10 U10 U

10.0 U10 U10 U10 U20 U10 U10 U10 U

MW-23

(ug/L)85

60

10 U30

14

10 U10 u7320 U10 U10 U10 U10 U20 U

6408610 U10 U10 U10 u10 u10 u10 U10 U10 u20 U

260

19

10 U7 J

10 U10 U10 u10 U10 u10 U10 U10 U10 U10 U10 U10 U

10.0 u710

10 U10 U

12010 U10 U10 U10 U10 U95

10 u10 U10 U10 u10 u10 U

9100.010 U10 U10 U264610 U10 U

MW-25

(ug/L)10 U10 U10 U10 U10 U10 U10 U10 U20 U10 U10 U10 U10 U20 U10 u10 U10 u10 U10 U10 u10 U10 U10 U10 U10 U20 U10 U10 U10 U10 U10 U10 u10 u10 u10 u10 U10 u10 U10 U10 U10 U10 U

12.010 U10 u10 U10 U10 U10 U10 U10 U10 U10 U10 u10 U10 U10 U10 U10 U

10.0 U10 u10 U10 U20 U10 U10 U10 U

MW-26

(ug/L)10 U10 U10 U10 u10 u10 U10 U10 U20 U10 u10 u10 U10 U20 U10 U10 U10 U10 U10 U10 U10 u10 U10 u10 U10 U20 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 u10 U10 U10 U10 U10 u10 u

2.1 J10 u10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 U10 u10 U10 U

10.0 U10 U10 U10 U20 U10 u10 U10 U

MW-28

(ug'L)10 U10 U10 u10 u10 U10 U10 U10 U20 U10 U10 U10 U10 U20 U10 U10 u10 U

10 u10 U10 U10 U10 U10 U10 U10 U20 U10 U10 U10 U10 u10 U10 U10 u10 U10 U10 U10 U10 U10 U10 U10 U10 U

4.1 J10 u10 U10 u10 U10 U10 U10 U10 U10 U10 u10 U10 U10 u10 U10 U10 U

10.0 U10 U10 U10 U20 U10 U10 U10 U


3 4 J029Table 2-3 Groundwater Volatile Organic Analytical Results - January 2003

Analyte

(m- and/or p-)Xylene1 .1 .1 ,2-Tetrachloroethane1.1,1-Trichloroethane1,1.2.2-Tatrachloroethane.1.2-Trichloro-1.2,2-Trifluoroethane (Freon 113),1.2-Trichloroethane,1-Dichloroe thane,1-Dichlonoethene(1.1-Dichloroethylene),1-Dichloropropene

1 ,2,3-Trichlorobenzene1 ,2.3-Trichloropropane1 ,2,4-Trichlorobenzene1 ,2,4-Trimethylbenzene1,2-Dibromo-3-Chloropropane (DBCP)1,2-Dibromoethane (EDB)1 ,2-Oichlorobenzene1 ,2-Dichloroethane1 .2-Dichloropropane1 ,3,5-Trimethytbenzene1 ,3-Dichlorobenzene1 ,3-Dichloropropane1 ,4-Dichlorobenzene2.2-OichloropropaneAcetoneBenzeneBromobenzeneBromochloromethaneBromodichloromelhaneBromofortnBromomethaneCarbon DisulfideCarbon TetrachlorideChlorobenzenaChloroethaneChloroformChloromattianecis-1 ,2-Dichloroethenacis-1 ,3-DichloropropeneCydohexaneDibromochloromethaneOibromomathaneDichlorodifluoromethaneEthyl BenzeneHexactiloro-1,3-ButadieneIsopropylbenzeneMethyl AcetateMethyl Butyl KetoneMethyl Ethyl KetoneMethyl Isobutyl KetoneMethyl T-Butyl Ether (MTBE)Methyl cydohexaneMethylene Chloriden-Butylbenzenen-Propylbenzeneo-Chlorotolueneo-Xylenap-Chlorotoluenep-lsopropyltoluenesec-ButylbenzeneStyrenetert-ButylbenzeneTetiachloroethene (Tetrachloroetrtylene)Toluenetrans-1 ,2-Dichloroethenetrans- 1 ,3-DichloropropeneTrichloroethene (Trichloroethylene)Trichlorofluoromelhane (Freon 11)Vinyl Chloride

MW-02

(ug/L)1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 u1.0 u1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 u1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U25 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u2.5 U1.0 U1.0 U1.0 U1.41.0 U1.0 U1.0 u1.0 u1.0 U1.0 U1.0 U1.0 u

"1.0 U1.0 U1.0 U2.5 U12 U3 U

1.0 U1.0 U1.0 U1.0 U1.0 u1.0 u1.0 u1.0 U1.0 u1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U

MW-03

(ug/L)50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U1200 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U

120.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U5V r- u

250.0 U120.0 U

620 U120 U

50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U

MW-04

(ug/L)1.0 u1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 u1.0 U25 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U2.5 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 u1.0 U1.0 U1.0 U1.0 U

. 1.0 U1.0 U2.5 U12 U3 U


MW-tDup

(ug/L)1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 Ui.o u1.0 U1.0 U1.0 U1.0 U1.0 u25 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U2.5 U1.0 U1.0 u1.0 u1.0 u1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U5.0 U2.5 U12 U3 U

1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U

MW-05

(ug/L)98.0 J

100.0 U100.0 U100.0 U100.0 u100.0 U100.0 u100.0 U100.0 u100.0 u100.0 u100.0 U70.0 J

100.0 u100.0 u100.0 U100.0 U100.0 U100.0 U100.0 U100.0 u100.0 u100.0 U2500 U100.0 U100.0 U100.0 u100 o u100.0 U100.0 U250.0 U100.0 U100.0 u100.0 U100.0 u100.0 u100.0 u100.0 u100.0 u100.0 u100.0 u100.0 U100.0 u100.0 U100.0 U500.0 U250.0 U1200 U250 U

100.0 U100.0 U100.0 u100.0 U100.0 U100.0 U52.0 J

100.0 utoo.o u100.0 U100.0 U100.0 U100.0 U58.0 J

100.0 U100.0 u100.0 U100.0 U100.0 U

MW-07

(ug/L)120.0100.0 U100.0 U100.0 U100.0 U100.0 u100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U51.0 J

100.0 u100.0 U100.0 U100.0 u100.0 U100.0 U100.0 U100.0 u100.0 u100.0 u2500 U340.0100.0 U100.0 u100.0 u100.0 U100.0 U250.0 U100.0 U100.0 u100.0 u100.0 U100.0 U100.0 U100.0 u100.0 u100.0 u100.0 U100.0 u100.0 U100.0 u100.0 U500.0 U250.0 U1200 U250 U

100.0 U100.0 U100.0 u100.0 U100.0 u100.0 u53.0 J

100.0 u100.0 u100.0 u100.0 u100.0 U100.0 U210.0100.0 U100.0 U100.0 U100.0 U100.0 U

MW-09

(ug/L)86.0 J

100.0 u100.0 u100.0 u100.0 u100.0 u100.0 u100.0 u100.0 U100.0 U100.0 U100.0 u63.0 J

100.0 u100.0 u100.0 u100.0 u100.0 U100.0 u100.0 U100.0 u100.0 U100.0 U2500 U100.0 u100.0 u100.0 u100.0 u100.0 u100.0 u250.0 U100.0 U100.0 u100.0 U100.0 u100.0 U100.0 U100.0 u100.0 u100.0 U100.0 u100.0 U100.0 U100.0 u100.0 U500.0 U250.0 U1200 U250 U

100.0 U100.0 U100.0 U100.0 U100.0 u100.0 u100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U72.0 J

100.0 U100.0 U100.0 U100.0 U100.0 U

MW-10

(ug/L)100.0 u100.0 u100.0 U100.0 U100.0 U100.0 U100.0 u100.0 U100.0 u100.0 u100.0 u100.0 u100.0 U100.0 u100.0 U100.0 u100.0 U100.0 U100.0 u100.0 u100.0 u100.0 u100.0 u2500 U100.0 u100.0 u100.0 U100.0 U100.0 U100.0 U250.0 U100.0 U100.0 U100.0 U100.0 U100.0 U.100.0 U100.0 u100.0 U100.0 u100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U250.0 U1200 U250 U

100.0 U100.0 U100.0 u100.0 u100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U100.0 u100.0 u100.0 u100.0 U100.0 U

MW-11


12.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U

12.0 U62 U12 U

5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 Us.o u5.0 Us.o u5.0 U5.0 U5.0 Us.o u5.0 U

MW-12

(ug/L)1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U0.5 J1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U

.1.0 U1.0 U1.0 U25 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U2.5 U1.0 U1.0 u1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U5.0 U2.5 U12 U3 U

1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U

• 1.0 U1.0 U1.0 U1.0 U1.0 u1.0 u1.0 U1.0 U1.0 U1.0 U

MW-15

(ug/L)80.0 J

100.0 u100.0 u100.0 U100.0 U100.0 u100.0 U100.0 U100.0 u100.0 u100.0 U100.0 U

58.0 J100.0 U100.0 U100.0 u100.0 u100.0 U100.0 U100.0 U100.0 U100.0 U100.0 u2500 U100.0 U100.0 U100.0 u100.0 U100.0 U100.0 U250.0 U100.0 U100.0 U100.0 U100.0 u100.0 u100.0 U100.0 U100.0 u100.0 U100.0 u100.0 u100.0 U100.0 U100.0 U500.0 U250.0 U1200 U250 U

100.0 u100.0 U100.0 U100.0 u100.0 U100.0 U100.0 U100.0 u100.0 u100.0 u100.0 U100.0 U100.0 U56.0 J

100.0 U100.0 u100.0 U100.0 U100.0 U


3 4 .030Table 2-3 Groundwater Volatile Organic Analytical Results - January 2003

Analyte

(m- and/or p-)Xylene1 .1 .1 ,2-Tetrachloroethane1 ,1 ,1-Trichloroethane1 .1 ,2.2-Tetrachloroethartel,1.2-Trichloro-1,2.2-Trifluoroethane (Freon 113)1,1.2-Trichloro ethane1.1-Dichloroethane1,1-Dichloroethene(1,1-Dichloroelhylene)1,1-Dichloropropene1 ,2.3-Trichlorobenzene1 ,2.3-Trichloropropane1 ,2.4-Trichlorobenzene1 ,2,4-Trimelhylbenzene1 ,2-Dibromo-3-Chloropropane (DBCP)1.2-Oibromoethane (EDB)1.2-Dichlorobenzene1 ,2-Dichloroethane1 ,2-Dichloroprapane1 ,3,5-Trimethylbenzene1 ,3-Dichlorobenzene1 .3-Oichloropropane1 ,4-Dichlorobenzene2,2-DichloropropaneAcetoneBenzeneBromobenzeneBromochloromethaneBromodichloromethaneBromofomiBromomethaneCarbon DisulfideCarbon TetrachlorideChlorobenzeneChloroethaneChloroformChloromethanecis-1 ,2-Dichloroethenecis-1 ,3-OlchloropropeneCyclohexaneDibromochloromethaneDibromomethaneDichlorodifluoromettianeEthyl BenzeneHexachloro-1 ,3-ButadieneIsopropylbenzeneMethyl AcetateMethyl Butyl KetoneMethyl Ethyl KetoneMethyl Isoburyt KetoneMethyl T-Butyl Ether (MTBE)MethytcyclohexaneMethylene Chloriden-Butylbenzenen-Propylbenzeneo-Chlorotolueneo-Xylenep-Chlorotoluenep-lsopropyltoluenesec-ButylbenzeneStyrenetert-Buryl benzeneTetrachloroelhene(Tetrachloroethylene)Toluenetrans-1 ,2-Dichloroethenetrans- 1 ,3-DichloropropeneTrichloroethene (Trichloroethylene)Trichlorofluoromethane (Freon 11)Vinyl Chloride

MW-17(ug/L)

1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U

.1.0 U1.0 U1.0 u1.0 u1.0 U1.0 U25 U1.0 u1.0 u1.0 U1.0 U1.0 U1.0 U2.5 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U2.5 U12 U3 U

1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U

MW-18


120.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U50.0 U

250.0 U120.0 U

620 U120 U


MW-19

(ug/L)83.0 J

100.0 U100.0 U100.0 u100.0 u100.0 U100.0 U100.0 u100.0 u100.0 U100.0 u100.0 u100.0 u100.0 U100.0 u100.0 u100.0 u100.0 u100.0 U100.0 u100.0 U100.0 U100.0 u2500 U100.0 u100.0 U100.0 u100.0 U100.0 U100.0 U250.0 U100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U100.0 u100.0 u100.0 u100.0 U100.0 U1000 U10.M U500.0 U250.0 U1200 U250 U

100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U100.0 u100.0 U100.0 u100.0 U100.0 U100.0 u68.0 J

100.0 U100.0 U100.0 U100.0 U100.0 U

MW-21S

(ug/L)3.6 J5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U4.0 J5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U120 U3.2 J5.0 U5.0 U5.0 U5.0 U5.0 U

12.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U

12.0 U62 U12 U

5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U3.0 J5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U5.0 U

MW-21D

(ug/H1.0 U1.0 u1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U25 U1.0 U1.0 u1.0 u1.0 u1.0 u1.0 u2.5 U1.0 u1.0 u1.0 u1.21.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 Ui.o u1.0 U5.0 U2.5 U12 U3 U

1.0 u1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U

MW-22

(ug/L)1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 Ui.o u1.0 u1.0 U1.0 u1.0 U1.0 U1.0 U25 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U25 U1.0 U1.0 U1.0 U1.0 u1.0 u.0 u.0 U.0 U.0 U.0 U

1.0 U1.0 u1.0 U1.0 U1.0 U2.5 U12 U3 U

1.0 U1.0 Ui.o u1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U

MW-23

(ug/L)77.0 J

100.0 u100.0 U100.0 u100.0 u100.0 U100.0 u100.0 u100.0 u100.0 U100.0 u100.0 U100.0 U100.0 u100.0 U100.0 U100.0 U100.0 U100.0 U100.0 u100.0 U100.0 U100.0 U2500 U100.0 U100.0 U100.0 u100.0 u100.0 u100.0 U250.0 U100.0 u100.0 u100.0 u100.0 U100.0 U100.0 U100.0 u100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U100.0 u500.0 U250.0 U1200 U250 U

100.0 u100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U100.0 U100.0 u100.0 U100.0 U100.0 U56.0 J

100.0 U100.0 U100.0 u100.0 u100.0 U

MW-25

(ug/L)1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U25 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U2.5 U1.0 U1.0 u1.0 U1.0 U1.0 U

. 1.0 u' 1.0 u

10 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U5.0 U2.5 U12 U3 U


MW-26

(ug/L)1.0 U1.0 u1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0'U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 u1.0 u25 U1.0 U1.0 u1.0 u1.0 U1.0 U1.0 U2.5 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U2.5 U12 U3 U

1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 u1.0 U

MW-28

(ug/L)1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U2.4 A2.8 A1.0 U1.0 U1.0 u1.0 u

' 1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 u25 U1.0 u1.0 U1.0 u1.0 u1.0 u1.0 U2.5 U1.0 u1.0 u1.0 U1.0 U1.0 Ui.o u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U2.5 U12 U3 U

1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 u1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U1.0 U


Sown.- Mississippi Automated Resource Information System, topographic attributes (2002).

Adapted torn(1) Dunaway, F.H., survey, December!:. 1994. 0 100 200

Scale in FestWest Mississippi State Plane, NAD 83

Figure 2-7Extent of the Naphthalene Plume - January 2003


3 4 031


3 4 032bisects the site. The western storage area is approximately 5 acres and the easternstorage area is approximately 1 acre.

A central east-west access road bisects the western storage area. Treated wood wasstacked on both sides of this road. Surface water in the western area tends to flownorth and south away from the access road to east-west ditches/swales, which directsthe flow of surface water to the west towards the Davis Street extension. A north-south aligned ditch along the western side of the Davis Street extension then directsthe water southward. Localized ponding of surface water occurred in the storageareas during rainfall events.

The soils in SWMU No. 1 were explored using a hand auger to core to 5 feet belowground surface (bgs) at a total of 28 grid cells. Two samples, one from 0-1 feet andone from 4-5 feet, from seven of the most visually contaminated borings weresubmitted for chemical analysis. The samplers noted that recent fill soil had beenplaced in the area.

One sediment sample was collected within the drainage ditch on the western side ofthe Davis Street extension approximately 2 feet north of the southernmost culvert.The sample was collected from a depth of 0-6 inches below the ground surface. Atthe time of the sampling, creosote treated poles were stored adjacent to and extendingover the ditch sampling area. Some accumulation of "drippings" was noted by thesamplers in the ditch bank areas but none was visible within the ditch.

Three surface water samples were collected within the SWMU No. 1 drainage wayswithin 30 minutes of a rain event. One sample was collected on the south side of thesouthern-most drainage ditch on the western side of the Davis Street extension, justsouth of the southernmost culvert. A second sample was collected in the same ditch,near the location where the northern east-west running portion of the ditch on thenorth side of SWMU No. 1 intersects the Davis Street extension ditch. The thirdsample was collected within the swale located on the south side of SWMU No. 1.

Low levels of wood treating constituents were detected in the soils. PCP was the onlyphenolic compound detected in the soils and PCP concentrations ranged from<0.33 milligrams per kilogram (mg/kg) to 2.68 mg/kg. Low levels (i.e., less than 10mg/kg) of polycyclic aromatic hydrocarbons (PAHs) including benzo(a)pyrene andindeno(l,2,3-c,d)pyrene were also detected in several of the surface soil samples. Onesurface soil sample (1N13), located in the northern portion of the eastern storage area,had PAH concentrations approximately two orders of magnitude higher than theother soil samples. In general, PCP and PAHs were detected only in the surface (0-1 foot) soils.

The sediment sample had a total PAH concentration of 178.7 mg/kg. Analysis of thesurface water in the western Davis Street extension ditch also indicated the presence

COM 221

WP-V1J24 Draft/0828


3 4 ,;033of wood treating constituents, with PCP concentrations ranging from 0.033 mg/L(north end of ditch) to 0.16 mg/L (south end of ditch near the southern property line).

SWMIT No. 5 - Pressure Treatment Process Area

The pressure treatment process area consisted of three horizontal steel cylinders(retorts) each approximately 120 feet long and 8 feet in diameter. The three retortswere parallel to each other and were separated by approximately 10 feet. The retortswere used to condition the wood and impregnate the wood with creosotepreservative. Each retort had a sump at both ends, which collected the residual oiland water from the process when the doors to the retorts were opened. Extensive soilstaining was observed during the RFA.

The soils in SWMU No. 5 were explored by coring 24 hand auger borings to a depthof 5 feet bgs. Two soil samples (0-1 foot interval and 4-5 foot interval) from each ofthe four most visually contaminated soil cores were submitted for chemical analysis.

Extensive surficial and shallow subsurface contamination was found beneath andbetween the retorts. Pine Belt Environmental, Inc. estimated that the area contained220 cubic yards of sludge overlying a coarse grained fill. The fill in the immediateprocess area was saturated with wood treating oil. Each of the concrete lined sumpshad about 1 foot of sludge in them. The large sump in the treating building had 5 feetof sludge in it: The analytical results indicated significant concentrations of PAHs,and phenolics were also present in this area. Most of the data indicate that PAHcontamination is significantly greater than the PCP concentrations; suggestingcreosote constituents to be the source. Elevated concentrations were also detected atthe 4-5 foot depth indicating a downward migration of the contamination.

No. 6 - Storage Tank/Work Tank Area

The storage tank/ work tank area is located north of, and adjacent to, the retorts. Thearea is surrounded by a wooden levee and contained six vertical above groundstorage tanks of various capacities and four horizontal above ground storage tanks.Many of the tanks were used for storage and water treatment operations when PCPwas used at the facility. One of the large tanks was used for creosote and one open-topped tank was used to evaporate treated wastewater. Extensive visualcontamination, in the form of spilled or leaked creosote around the tanks, stainedsoils, and an organic sheen on ponded storm water in the area, was noted during theRFA.

The soils in SWMU No. 6 were explored by coring six hand auger borings to a depthof 5 feet bgs. From each core, the samples collected from 0-1 foot and 4-5 footintervals were submitted for chemical analysis.

The surface soil in SWMU No. 6 was heavily contaminated with PAH constituentsrepresentative of creosote. Pine Belt Environmental, Inc. estimated that the areacontained 356 cubic yards of sludge in this area. The soil also contains PCP but at

COMWP.V1 l24Drafl/Oa2B

2-22

CDM


3 4 .1034lower concentrations than the PAHs suggesting that creosote is the source. Elevatedconcentrations of wood treating constituents were generally also found at the 4-5 footdepth.

SWMU No. 8 - Sand Filter Bed Unit

The sand filter bed unit was reportedly used for three weeks in 1972 to separate anddry sludge from the wastewater treatment plant process. Discharge from the unit waspiped to the sanitary sewer. The unit failed to dry the sludge and the operation wasterminated. The RFA indicated that sludges remained on the surface of the unit fortwo years, allowing leachate to seep into the underlying soils.

The exact location of the former sand filter bed was not obvious during the RCRAfacility investigation; however, the sampling crew noted what appeared to be a driedlayer of sludge cake in the north-south ditch that flows through SWMU No. 8.

The soils in SWMU No. 8 were explored by coring four hand auger borings to a depthof 5 feet bgs. The four samples collected from the 0-1 foot interval were compositedinto one sample and the four samples collected from the 4-5 foot interval werecomposited into a second sample. The composited samples were submitted forchemical analysis.

Three sediment samples were collected from the north-south ditch that runs throughthis SWMU. The samples were collected from a depth of 0-6 inches below the groundsurface. The first sample (8-SS1) sample was collected at the northernmost portion ofthe north-south running ditch near the junction of the ditch with the east-westrunning ditch located just north of SWMU No. 1. The second sample (8-SS2) wascollected near the southern property line. The third sample (8-SS3) was collectedapproximately 100 feet south of sample 8-SS2. All of the sediment samples exhibitedcreosote odors and samples 8-SS1 and 8-SS2 were visibly stained.

The composited surface (0-1 foot) sample had a PCP concentration of 520 mg/kg anda total PAH concentration of 3,411 mg/kg. The composited subsurface (4-5 foot)sample had a PCP concentration of 39 mg/kg and a total PAH concentration of320.6 mg/kg.

SWMU No. 9 - "Old Pit" (Old Flocculation Tank)

The RFA designated SWMU No. 9 as the "old pit"; however, WTI was unaware of anypits in the area described. Pine Belt Environmental, Inc. concluded that the "old pit"referred to in the RFA was the old flocculation tank area. The area consisted of threeabove ground reinforced concrete tanks. All of the tanks have concrete bottoms andare open at the top. SWMU No. 9 was located in the water treatment area and wassurrounded by a cinder block wall approximately 2 feet high. Releases were notobserved from this unit during the RFA; however, the potential for a release wasconsidered high.

2-23


3 4 ,U35The soils in SWMU No. 9 were explored by coring four hand auger borings to a depthof 5 feet bgs. The most visibly contaminated soil samples collected from the 0-1 footinterval and the 4-5 foot interval were submitted for chemical analysis. In addition,sludge samples were collected from each of the three tanks.

The 0-1 foot surface soil sample had a total PAH concentration of 1,693 mg/kg andthe 4-5 foot soil sample had a total PAH concentration of 5.69 mg/kg. PCP was notdetecte'd in either soil sample. The sludge in the tanks was contaminated with PAHconstituents with the northernmost tank (Tank #1) having the highest concentrations(43,189 mg/kg phenanthrene and others) and the southernmost tank (Tank #2)having the lowest concentrations (680 mg/kg total PAH).

SWMU No. 10- Cooling Pond Ditch

The cooling pond ditch is located northeast of, and adjacent to, the closed coolingpond. The ditch was not observed during the visual inspection of the RFA due todense vegetation in that area. The cooling pond ditch was included as a SWMU basedon file information regarding discharges to this ditch in 1977. These dischargesceased when the facility began discharging the wastewater to the local publicly-owned treatment works (POTW). The cooling pond ditch transports rainwater fromthe area of the Closed Cooling Pond as well as other areas of the plant.

The soils in SWMU No. 10 were explored by collecting six soil samples to a depth of1 foot bgs. Two of the samples were collected from one ditch bank, two werecollected from the other ditch bank, and two were collected from the center of theditch. The two soil samples collected from each area were composited and submittedfor chemical analysis. Five sediment samples were also collected within the ditch andsubmitted for chemical analysis.

Visual evidence of what appeared to be creosote contaminants was observed in theditch water, side slopes, and bottom particularly in the area of the ditch immediatelynorth of the Closed Cooling Pond. The visually contaminated soil extended to adepth of 0.5 to 1 foot bgs. There also appeared to be oil seeping out of the south ditchbank (north side of the Closed Cooling Pond) in this area. Analytical results indicatepredominantly PAH contamination at total concentrations of 1,200 mg/kg or less.The soil/sediment samples were also analyzed for metals. The arsenic concentrations,which ranged from 16 to 255 mg/kg, are noteworthy. Background arsenicconcentrations ranged from 5.6 to 12 mg/kg.

AOC "A" - Boiler Tank Slowdown Area

Pine Belt Environmental, Inc. investigated three areas adjacent to the current boilerand two older boiler systems. The bark-fired wood waste boiler was installed in 1981.WTI also periodically used a gas-fired boiler. There was not an indication of a releasein this area but an investigation was requested because of the unknown compositionof the boiler water.

COM 224

WP-V1J24 Oratl/0826


3 4 036The soils in AOC "A" were explored by collecting three surface soil samples (0-1 feetbgs) from three areas likely to have received boiler water blowdown. The threesamples were submitted for chemical analysis. The analytical results do not indicateany significant anomalies compared to the background results.

Background Samples

Three background samples were collected: one from the southeastern portion of thesite, one near monitoring well MW-1 (north site area), and one near monitoring wellMW-3 (western most portion of the site).

2.6 EPA Remedial ActionsOn October 19,1999, EPA conducted a reconnaissance and sampling investigation toevaluate and characterize the risks posed by the facility. The EPA inspectors observedthat the site was not completely fenced and contained several areas of concern.Trespassers, primarily school children on their way to and from school, wereobserved on the site. The interior surfaces of the operations building were thicklycoated with creosote, and contained 2 to 3 feet of standing water mixed with creosote.Areas throughout the site contained stained soils and puddles of sludge. Wasteproduct was observed around the biostorage tanks, central processing area, on-sitedrainage ditches, and off site in Mill Creek. Several of the on-site tanks were leakingcreosote and liquid waste product.

During the October 1999 emergency response action, product was removed from alltanks, vats, and ditches where waste product leaked or had the potential to leak. TheEPA removed approximately 53,000 gallons of liquid waste from the site. Atemporary containment berm was also constructed around the central processingunit.

In December 1999, the IT Corporation (IT) conducted a removal action at the PWTS.During this removal action, approximately 44,449 gallons of non-hazardous waterwas transported off of the site. In May 2000, IT returned to the site and constructed awater treatment system and began to treat water in June 2000. A total of387,400 gallons of water were treated on-site. In addition, small drums and containersfound on the facility property were inventoried and grouped by means of hazardcategorization, while the larger tanks were demolished and recycled. The remainingsludges on-site in the vicinities of the tanks were stabilized using fly ash. After thesludges were stabilized, all of the containers and treated materials were stagedtogether and covered with a polyethylene liner. Approximately 175 cubic yards ofasbestos was also removed from some of the tanks and pressure vessels, and disposedof in the Central Landfill in McNeil, Mississippi.

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Sections 3 4

Scope of WorkThe primary objectives of this project are to conduct a remedial investigation, performa Baseline Risk Assessment (BRA) using data obtained from the RI, and torecommend a remedial action plan for the site in an FS. The specific tasks include thefollowing:

• Conduct an RI to determine the nature and extent of contamination.

• Assess risks to human health and the environment in a BRA.

• Determine remediation goal options for chemicals of concern (COCs).

• Assemble the technologies into remedial action alternatives and screen thealternatives to identify those that appear to be most promising with respect toeffectiveness, implementability, and cost.

• Evaluate the screened remedial action alternatives in a manner that is consistentwith the National Contingency Plan (NCP) and other regulatory requirements.

• Recommend a remedial action plan that is technically and environmentally sound,and cost-effective.

Each task is described in more detail in the subsequent sections. ;

3.1 Task 1 — Project Planning and SupportThis task includes work efforts related to work assignment scoping, work plandevelopment and negotiations, project management, and quality assurance (QA). TheCOI Certification has already been provided to EPA. This task does not include anyfunctions that are related to overall Remedial Action Contract (RAC) programmanagement. Tasks required under Subtask 1.1 Project Planning are:

• 1.1.1 — Attend Scoping Meeting

• 1.1.2-Conduct Site Visit

• 1.1.3 —Evaluate Existing Information

• 1.1.4 —Develop Project Goals and Objectives

• 1.1.5-Develop Work Plan

Tasks required under Subtask 1.2, Preparation of Site-Specific Plans, are:

• 1.2.1 - Develop Site Management Plan (SMP)

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Section 3Scope of Work

3 4 -1038• 1.2.1.1 -Health and Safety Plan (HASP)

Subtasks 1.2.2, Develop Pollution Control and Mitigation Plan, and 1.2.3, DevelopRisk Assessment Plan, are not required.

Tasks required under Subtask 1.3, Project Management, are:

• 1.3.1 — Prepare Periodic Status Reports

• 1.3.2—Meeting Participation and Routine Communication

• 1.3.3 —Maintain Cost/Schedule Control System

• 1.3.6 —Manage, Track, and Report Equipment Status

• 1.3.7-ProjectCloseout

Subtasks 1.3.4, Perform Value Engineering, and 1.3.5, Perform Engineering NetworkAnalysis, are not required.

Tasks required under Subtask 1.4, Subcontract Procurement and Support Activities,are:

• 1.4.1 — Identification and Procurement of Subcontractors

• 1.4.2—Establish and Carry Out a QA Program for Subcontractors

• 1.4.3 — Perform Subcontract Management

A few other subtasks are included to address contractual requirements. They are:

• 1.5 — External Audit or Review

• 1.6 — Quality Assurance

• 1.7 — Pollution Liability Insurance

• 1.8 - Conflict of Interest

CDM assumes that only these activities will be performed under this task. The workto be performed is described more completely in the following paragraphs.

3.1.1 Subtask 1.1 - Project Planning

CDM prepared this work plan to describe the work effort required to complete theassignment. The work plan defines the scope of work, identifies key personnel, andpresents the level of effort, costs, and schedule associated with the work assignment.

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CDM


3 4 n039This work plan is a revision of the draft work plan that addresses EPA's commentstransmitted to CDM in a teleconference held on October 9, 2003.

This work plan is a product of other preliminary steps including a scoping meetingbetween EPA and CDM to discuss the goals of the assignment, a site visit with theEPA Remedial Project Manager (RPM) and the CDM Project Manager, and a reviewof background material from EPA files.

3.1.1.1 Attend Scoping Meeting

CDM reviewed the statement of work and attended a scoping meeting with EPA todiscuss the work assignment for the purposes of developing this work plan.

3.1.1.2 Conduct Site Visit

The CDM Project Manager conducted a site visit with the EPA RPM on October 24-25, 2002. The purpose of the site visit was to develop a conceptual understanding ofthe site. CDM prepared a letter report that documented the observations of the site,all decisions made during the visit, and any action items assigned.

3.1.1.3 Evaluate Existing Information

CDM collected and reviewed all available studies of the site. These studies includedSite Investigations, Preliminary Assessment Reports, Site Inspection (SI) Reports,Hazardous Ranking System Scoring Package, and other data and documents asdirected by EPA.

3.1.1.4 Develop Project Goals and Objectives

CDM will prepare the data needs and the data quality objectives (DQOs) foranalytical sampling to be performed during the RI/FS. The goals and objectives willbe used to define the analytical methods and protocols, decontamination procedures,and EPA reporting levels required.

3.1.1.5 Develop Work Plan

3.1.1.5.1 Draft Work Plan

CDM submitted a draft work plan in two volumes. Volume I (Technical), contained adiscussion on how CDM proposed to perform the tasks assigned, planningassumptions, staff assigned with their responsibilities by task, time lines, anddeliverables. Volume II (Cost Estimate) presented the associated cost schedulesincluding subcontractors, travel, other direct costs, and other supporting detailssufficient for EPA to evaluate the cost proposal for the project. The draft work planreceived technical, financial, and QA reviews prior to EPA submittal.

3.1.1.5.2 Final Work Plan

After review of the draft work plan, EPA provided its comments via teleconference onOctober 9, 2003. This final work plan incorporates a revision in scope as discussed in

3-3

WP-V1 124 Draft/Due


3 4 J040the teleconference and in subsequent discussions with the EPA RPM. Significantscope reductions include: reduction in the number of DPT points from 40 to 9;elimination of permanent monitoring wells; elimination of sediment samples in theon-site ditches; significant reduction in community relations support; and significantreduction in ecological risk assessment support. Scope increases reflected in this workplan include: seven, 2-well clusters of temporary monitoring wells; collection of fivesediment samples from a ditch that drains the Kenson Wood facility; and additionalproposed plan and ROD support. The scope revisions are presented in this section ofthe work plan. The Volume II—Cost Estimate, associated with this Volume I—Technical Approach, presents the revised cost estimate corresponding to the changedscope.

3.1.2 Subtask 1.2—Preparation of Site-Specific PlansHealth and Safety Plan

CDM will update the site-specific HASP to protect personnel during the fieldinvestigation. The HASP was developed in accordance with the CDM CorporateHASP and all applicable regulatory requirements contained in 29 CFR 1910.120 (1) (2)Occupational, Health, and Safety Administration, Hazardous Waste Operations andEmergency Response, Interim Rule, December 19,1986; EPA Orders 1440.2 and1440.3; and U.S. EPA Interim Standard Operating Procedures. The HASP provideshealth and safety requirements for all CDM personnel working at the site for eachtask identified in the Work Plan. The HASP describes personnel monitoring anddecontamination procedures in detail, and also addresses health afid safety trainingprocedures and requirements for all on-site personnel. The plan also identifiesproblems or hazards that may be encountered and how these are to be addressed.Standard operating procedures for ensuring worker safety are referenced and notduplicated in the HASP.

Sampling and Analysis Plan

CDM will update the Sampling and Analysis Plan (SAP) prepared for the January2003 groundwater sampling event. The SAP will include the Quality AssuranceProject Plan (QAPP) and Field Sampling Plan (FSP). The QAPP will describe theproject objectives and organization, functional activities, and QA/quality control (QC)protocols that will be used to achieve the desired DQOs. The FSP will define thesampling and data collection methods that will be used for the project.

3.1.3 Subtask 1.3 —Project ManagementThis activity will include the normal functions of site-specific administration andproject management for the duration of the assignment. This does not include anyfunctions that are related to overall RAC program management. Work to beperformed under this activity is described below.

CDM 34WP-V1J24 Draft/oa26


3 4 10413.1.3.1 Prepare Periodic Status Reports

Monthly project status reports and invoices will be prepared summarizing projecttechnical and financial status. These reports will include progress made, problemsresolved, anticipated problem areas and recommended solutions, upcoming activitiesand events, key personnel changes, subcontracting, travel, schedule performance, andfinancial status information.

3.1.3.2 Meeting Participation and Routine Communication

CDM will attend meetings with EPA on an as-needed basis. Additionally, the projectmanager will maintain regular communications with the EPA RPM via telephone,e-mail, or fax.

3.1.3.3 Additional Project Management Tasks

CDM will perform the following additional tasks:

• Establish and maintain work assignment files. All correspondence and otherdocumentation included in the project file will be assigned a unique documentcontrol number (DCN) under CDM's document control system. This system,administered by the CDM clerical and contracting staff, allows documents to beefficiently tracked and retrieved.

• Perform contract administration functions associated with this work assignment.This includes activities such as preparing invoices, making payments, preparingfinancial reports, and other tasks related to the project.

• Provide monthly reports and invoices. Monthly project status reports andinvoices will be prepared summarizing project technical and financial status.These reports will include progress made, problems resolved, anticipated problemareas and recommended solutions, upcoming activities and events, key personnelchanges, subcontracting, travel, schedule performance, and financial statusinformation.

• Monitor costs and performance. The function of monitoring project costs andperformance is mainly the responsibility of the CDM Project Manager. Thisinvolves reviewing the weekly labor charges, approving expenditures, andtracking the budget. CDM will notify EPA when 75 and 95 percent of theapproved work assignment budget has been expended.

• Coordinate staffing and other support activities to perform work assignment tasksin accordance with the Statement of Work (SOW), including team subcontractorsand other subcontractors.

• Attend necessary work assignment-specific meetings.

CDM 35WP-V1J24 Dran/0826


3 4 H 0 4 2• At the end of each six-month performance evaluation period, provide input to

EPA on CDM performance.

3.1.4 Subtask 1.4—Subcontract Procurement/Support Activities3.1.4.1 Identification and Procurement of Subcontractors

DPT Subcontractor

CDM will identify and procure a subcontractor to use Direct Push Technology (DPT)to collect groundwater samples, install temporary monitoring wells, and collectsubsurface soil samples. The work will be performed in accordance with EPA Scienceand Ecosystem Support Division (SESD) Standard Operating Procedures (SOPs). Thedrilling subcontractor will be responsible for the following:

• Collect Direct Push Technology (DPT) soil samples to a depth of 4 feet at 30sampling stations.

• Collect DPT continuous soil cores to a depth of 70 feet at seven locations.

• Collect DPT groundwater samples at nine sampling stations.

• Install 14 temporary monitoring wells, seven to a depth of about 40 feet and sevento a depth,of about 70 feet.

• Decontaminate the rig and downhole equipment in accordance with SESD SOPs.

• Contact the appropriate utility companies and utility clearance organizations priorto conducting the work.

Surveying Subcontractor

A surveyor will be subcontracted to determine the horizontal and vertical coordinatesof the monitoring wells and to establish the soil sampling grid.

3.1.4.2 Establish and Carry Out a QA Program for Subcontracts

CDM will implement a QA program for all subcontracts procured and managed byCDM for this project. The costs for subcontract management are accounted for underTask 3, Data Acquisition.

3.1.4.3 Perform Subcontract Management

CDM will manage all subcontracts procured by CDM for this project. This subtaskincludes preparing a scope of work for the subcontractors, providing a field managerto oversee the drilling, and treatability subcontractors, reviewing the subcontractor'sinvoices, and reporting requirements to EPA.

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\\

SectkScope of V

3 4 . :0433.1.5 Subtask 1.5 —External Audit or Review

CDM will accommodate any external audit or review mechanism that EPA mayrequire, such as Annual Allocation Reports, Financial Monitoring Reviews,preparation of annual closeout claims, and indirect rate audits/adjustments. No costsfor an external audit have been included at this time. If an external audit is required,CDM understands that EPA will fund this task at that time.

3.1.6 Subtask 1.6—Quality Assurance

All work by CDM on this work assignment will be performed in accordance with thefollowing guidance documents:

• CDM, RAC Region 8 Standard Operating Procedures, Attachment B, "QualityManagement Plan (QMP)," Document Control No. 3280-999-PP-SOPS-00086,August 23,1996.

• CDM, CDM Federal Programs Corporation Quality Assurance Manual, Section 4.0,Revision 10, February 10, 2002.

• EPA, Environmental Investigations Standard Operating Procedures and QualityAssurance Manual, Region 4, SESD, November 2001b.

• EPA, Guidance for the Data Quality Objectives Process, EPA QA/6-4/R-96/O55,August 2000. i

• EPA, Requirements for Quality Assurance Project Plans for Environmental DataOperations, EPA QA/R-5, Final, EPA/240/3-01/003, March 2001c.

The RAC 8 Atlanta Regional QA Coordinator (Tony Isolda), or an approved QA staffmember, has reviewed this work plan for QA requirements. Mr. Isolda will maintainQA oversight for the duration of the work assignment. It has been determined that aQAPP is required for this work plan. This information has also been reviewed andapproved by the Regional QA Coordinator, or an approved QA staff member.

QA review requirements in the RAC 8 QMP will be followed during this workassignment. Key components of the QA/QC program for this project are outlinedbelow. The project manager is responsible for implementing QC requirementsreferenced or defined in this work plan.

Technical Review Requirements

Technical review requirements in the RAC 8 QMP will be followed on this workassignment. Required deliverables are listed in Table 4-1.

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3 4 044Project File Maintenance and Storage

Project file maintenance, storage, and control for all tasks will be conducted at theCDM RAC Region 8 Program Management Office in Denver, Colorado. Under theRAC 8 contract, all documents associated with this work assignment will be trackedusing CDM's RAC 8 Document Control and Tracking System. The RAC 8 DocumentControl and Tracking System will be used for assigning DCNs to all documentsgenerated or received by CDM. Copies of all documents will be maintained in thecentral file located in the CDM Denver, Colorado, office by the RAC 8 SystemAdministrator. This system can be used to locate copies of documents on an as-needed basis and simplifies file inventorying during project closeout.

The project manager will maintain a working project file in the CDM Atlanta,Georgia, office throughout the project duration. During project closeout, the localproject file will be compared to the central file copy and all duplicates will bediscarded.

Additional QC Measures

No additional QC measures besides those that have been specified are anticipated.

QA Review Requirements

All CDM RAC 8 work assignment Work Plans are reviewed by the QA staff beforesubmission to EPA. Reports that present measurement data, procurement documentsand responses, and purchase requisitions for measurement and testing items also willreceive a QA review.

QA Audits

The RAC QA program includes both performance and system audits as independentchecks on the quality of data generated under this work assignment. Performanceaudits are quantitative checks most appropriate to laboratory analysis activities.System audits are qualitative reviews of project activity to check that the overallquality program is functioning and that the appropriate QC measures are beingimplemented. System audits may be conducted in the office, field, or laboratory. TheRAC 8 QMP requires the following audit frequency:

• One office system audit per year of work assignment activity, and

• Field system audits of one for every five weeks of fieldwork and laboratory work.

This work assignment is anticipated to last 24 months; therefore, two office audits arerequired. The fieldwork is expected to require eight weeks; therefore, one field auditwill be performed. The subcontractor laboratory audit will not be required becauseno subcontracted laboratory will be used. Technical and QA review requirementsstated in the QMP will be followed for this work assignment.

3-8


3 4 H 0 4 53.1.7 Subtask 1.7—Pollution Liability Insurance

Pollution liability insurance premium (PLI premium) allocable to this workassignment is included in this subtask. For purposes of estimating the PLI premium,CDM has used the most recent quote received as the basis of calculation. This quotewas received for CDM's RAC and Alternative Remedial Contract Strategy (ARCS)contracts and equated to a rate of $0.524 per $100 of revenue. CDM will update thisestimate should an updated quote be received prior to negotiations.

3.1.8 Subtask 1.8-Conflict of Interest

CDM has prepared and submitted a COI Certification indicating no conflict of interestwith regard to the work to be performed under the referenced work assignment (124-RICO-A4W2). This disclosure of conflict of interest findings is submitted consistentwith CDM's contract requirements as implemented in its COI, Confidential BusinessInformation (CBI), and Future Contracting Policies and Procedures Manual.

3.2 Task 2 —Community Relations3.2.1 Subtask 2.1 — Prepare a Community Relations Plan - N/A

3.2.2 Subtask 2.2-Prepare Fact Sheets - N/A3.2.3 Subtask 2.3-Public Hearing, Meeting, and AvailabilitySupport - N/A3.2.4 Subtask 2.4—Maintain Information Repository and MailingLists - N/A

3.2.5 Subtask 2.5—Proposed Plan Support

CDM will format, copy and prepare for distribution the Proposed Plan as directed bythe EPA RPM.

3.2.6 Subtask 2.6—Responsiveness Summary SupportCDM will assist EPA in completing the Responsiveness Summary. CDM will analyzethe comments received during the public meeting on the Proposed Plan, separatethem into two main categories (Local Community Concerns and Specific Legal andTechnical Questions) and set up the format for the document. Under this task CDMwill assist EPA in formulating the answers to Part I, Summary and Response to LocalCommunity Concerns. CDM will assist with responses to technical questions on theFS and BRA as directed by the EPA RPM.

3.3 Task 3-Data AcquisitionThe primary objective of the RI is to collect the data necessary to determine the natureand extent of contamination at the site. A field investigation of the groundwater,surface water, surface and subsurface soils, and surface and subsurface sediment will

CDM 39WP-V1_I24 Dran/0826


3 4 j Q 4 6be conducted to supplement the data collected during the previous investigations atthe site. The following sections describe in detail each of the subtasks.

3.3.1 Subtask 3.1 —Mobilization and Demobilization

3.3.1.1 Identify Field Support Equipment, Supplies, and Facilities

Field support equipment, supplies, and facilities will be identified and procured foreach field task by CDM. CDM field personnel will be responsible for inspection andacceptance of supplies and consumables to be used in the field.

3.3.1.2 Mobilization/Demobilization

Prior to the collection of any samples, a temporary decontamination pad will beconstructed. The temporary decontamination pad will be sloped to drain into arunoff collection tank for containment of contaminated wash water. The temporarydecontamination pad will be removed at the conclusion of the fieldwork.

The CDM field team will consist of a field team leader, a geologist, and one samplingtechnician. The fieldwork for the RI is expected to take about eight weeks tocomplete. The field crew will work 10 hours each day and the work schedule will be10 days on and 4 days off.

3.3.2 Subtask 3.2-Field Investigation

3.3.2.1 Perform Site Reconnaissance

Not required.

3.3.2.2 Conduct Geological Investigations (Soils and Sediments)

Surface and Subsurface Soils

Figure 3-1 shows the proposed sampling grid. Within each 150 foot by 150 footsampling area, a five-point composite surface soil sample will be collected. Thesamples will be collected from five predetermined locations within each grid from the0 to 6 inches bgs at each location. The soil samples collected from each area will becomposited using stainless steel bowls and spoons. A total of 25 composited surfacesoil samples will be collected. Discrete subsurface soil samples will be collected usinga 4-foot long DPT macro-core sampler at each corner of the sampling grid except forthe southernmost grid points (i.e., Grid Row #6). The subsurface soil samples will becollected from a depth of 42 to 48 inches bgs. A total of 30 discrete subsurface soilsamples will be collected. The surface and subsurface soil samples will be analyzedfor TAL metals and SVOCs at a CLP laboratory. Surface soil samples will be analyzedfor dioxin.

Surface Sediments

Five surface sediment samples will be collected from a ditch that drains the KensonWood facility west of the site. Figure 3-2 shows the proposed sediment sampling

CDM 3-10

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3 4 0047

11 I Closed CodingWater Pond

Proposed Surface Soil Sampling Grid

Proposed Subsurface Soil Sampling Location

Site Boundary

Ditch Pond

Railroad ^= .̂ Culvert

Stream

On-Site Gravel Road

100 200 300

Scale in FeelWast Mississippi Slat* Plane. NAD 83

Source Mississippi Automated Resource Information System,topographic attributes, Match 2002

Mapteatmm Dunaway. F H , survey, December 1994

COM

Figure 3-1Proposed Soil Sampling GridPicayune Wood Treating, Inc.

Picayune, Mississippi

3 4 ,048

Proposed Sedment Sampling Location

Ditch

Stream

Intermittent Stream

Railroad

Scal*inF**tWest Mississippi Slate Ptane. NAD 83

Source Mississippi Automated Resource Information System, aerial (March 2001)and topographic attributes(2002). Figure 3-2

Proposed Sediment Sampling LocationsPicayune Wood Treating, Inc.

Piraviinp Mississinni


3 4 < 0 4 9locations. The samples will be collected from 0 to 6 inches bgs and analyzed for TALmetals and SVOCs at a CLP laboratory.

3.3.2.3 Conduct Hydrogeological Investigations: Groundwater

3.3.2.3.1 Groundwater Investigation Objectives

The primary objectives of the ground water investigation program at the PWTS are asfollows:

(1) Define the nature and extent of groundwater contamination at the site.

(2) Develop the site hydrogeological characteristics to be used to predict the fateand transport of groundwater contaminants.

(3) Collect data for the development of the FS that will provide a detailed analysisof remedial alternatives for the PWTS.

(4) The ultimate goal of the project is to provide sufficient data to allow EPA toproduce a well-supported Record of Decision (ROD) for the PWTS.

These objectives will be fulfilled by collecting groundwater using DPT and temporarymonitoring wells. The proposed locations of the DPT groundwater sampling stationsand temporary monitoring wells are provided in Figure 3-3.

This hydrogeological investigation was planned to investigate groundwatercontamination from the water table down to and including the top of the GrahamFerry formation confining layer (estimated to be located at a depth of 69-75 feet bgs).The vertical extent of this investigation will be to the top of the Graham Ferryformation confining layer since the Citronelle aquifer is underlain by a continuous,massive bed of homogeneous, high plasticity clay with a measured permeability of2.12 x 1O9 cm/sec. Logs of deep-water wells located within the immediate vicinity ofthe site show that the clay layer has a thickness of 100 to 300 feet.

3.3.2.3.2 Groundwater Investigation

Direct-Push Groundwater Investigation

A groundwater investigation will be conducted using DPT methods to determine thenature and extent of contamination. The proposed locations of the DPT groundwatersampling points are shown in Figure 3-3.

For this investigation, CDM selected nine groundwater sampling stations tosupplement the existing groundwater monitoring network. At each station,groundwater samples will be collected from two zones within the Citronelle aquifer.One sample will be collected in the upper portion of the aquifer at a depth of 40 to45 feet bgs. The second sample will be collected at the top of the Graham Ferryformation confining layer anticipated to be located at about 70 feet bgs. The

CDMWP-V1 124 Draft/0826

3-13

Legend

Proposed DPT Sampling Location

$ Proposed Temporary Monitoring WeilCluster Location

• Existing Monitoring Welt Location

Stream

— — Site Boundary

Ditch

Railroad

On-Site Gravel Road

Pond

:=: Culvert

/

TM-3S$TM-3D

TM-4STKMD

BiologicalTreatmentTank Area

• MW-23S

MW-13S

•

Closed Trench Irnpoundrnents TM-2STM-2D

MW-21S&D

•

MW-4DO

"W-1f**MW-11D

~L.


MW-18S MW26S*

TM-1STM-1D

\ Jz

I

X . . »XMW*S

'y;>«s*v. -•' > -^.-.,-;...-., vmss .«•«.-

TM-6S^.TM-60

ClosedCooling

TM-7S*TM-7D

• MW-12

Source Mississippi Automated Resource Information System.topographic attributes, 2002.

Adaptedfrom Ounaway. P.M.. survey. December22,1994.Scale in Feet

west Mississippi Stale Plane. NAD 83

Figure 3-3Proposed DPT Groundwater Sampling Locations and Temporary Monitoring Well Locations


3 4 .,050

CDM


3 4 0051groundwater samples collected will be analyzed for SVOCs at a CLP laboratory. Thedata collected will be used to evaluate the nature and extent of groundwatercontamination.

Temporary Monitoring Well Groundwater Investigation

CDM proposes to install seven temporary monitoring well clusters (two wells percluster) using the DPT rig. The proposed locations of the temporary monitoring wellsare shown in Figure 3-3. Each two-well cluster will consist of a shallow(approximately 40 feet) well and a deep (approximately 70 feet) well. In conjunctionwith the existing monitoring well network, the temporary monitoring wells will beused measure the potentiometric groundwater elevations and to collect groundwatersamples.

After the temporary monitoring wells have been installed and developed,groundwater samples will be collected from each temporary well and each existingpermanent monitoring well. A total of 38 groundwater samples will be collected andanalyzed for SVOCs and TAL metals at a CLP laboratory.

3.3.2.4 Conduct Hydrological Investigations: Surface Water

Surface water samples will be collected, if present, at each sediment sampling location(Figure 3-2). A maximum total of five surface water samples will be collected. Thesurface water samples will be analyzed for TAL metals and SVOCs at a CLPlaboratory.

3.3.2.5 Conduct Waste Investigations —N/A

Not applicable.

3.3.2.6 Conduct Geophysical Investigations — N/A

Geophysical investigations will not be performed during the RI.

3.3.2.7 Conduct Ecological Investigations

This section summarizes the assumptions associated with conducting the ecologicalsurveys and writing the associated sections of the final report.

Wetlands Delineation

Wetlands will be delineated in the areas potentially impacted by operations at the site.The estimated boundaries of the delineation will be about 500 feet beyond the existingfacility fence line. Wetlands will be delineated in accordance with the 1987 U.S. ArmyCorps of Engineers (USACE) manual.

The wetland boundary will be determined according to the three delineationsampling criteria, soils, vegetation, and hydrology, and will be flagged usingsurveyor's tape, and surveyed for mapping by a surveyor.

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3 4 052Wildlife Observations

An informal survey of wildlife (i.e., including mammals, birds, and aquaticorganisms) will be conducted during the ecological investigation. This will includedocumentation of observed and heard species, as well as signs (i.e., tracks, nests,burrows, and scat). Both daytime and nighttime surveys will be done. The ecologistswill review species information from available technical reports prior to fieldwork.

Habitat and Community Characterization

The plant community and habitat types present in the potentially impacted areas willbe identified and indicated on a large scale map in the field. Information recorded onthe map in the field will be used to generate a habitat map for inclusion in the finalreport.

Identification of Endangered Species

A pedestrian survey will be conducted over 100 percent of the potentially impactedareas to look for the occurrence or signs of threatened and endangered species andspecies of special concern. The ecologist will review existing information prior to thefieldwork to determine which listed species could occur on-site. This information willbe used in conjunction with the habitat and community characterization to maximizethe pedestrian survey effort.

3.3.2.8 Collect Contaminated Building Samples — N/A

Contaminated building samples will not be collected during the RI.

3.3.2.9 Dispose of Investigation-Derived Waste

CDM will characterize and dispose of investigation-derived wastes in accordancewith Federal and State/Local laws and regulations. The only investigation-derivedwaste (IDW) expected to be generated during this investigation is decontaminationwash water and purge water from the monitoring well development and samplingactivities.

3.4 Task 4 — Sample Analysis3.4.1 Subtask 4.1 — Screening-Type Laboratory Sample Analysis —N/A

3.4.2 Subtask 4.2—CLP-Type Laboratory Sample AnalysisSamples will be analyzed by a CLP laboratory or EPA's laboratory in Athens,Georgia. Sample matrices and types to be collected and analyzed will be specified inthe SAP.

3-16

CDM


3 4 00533.5 Task 5 — Analytical Support and Data Validation3.5.1 Subtask 5.1 —Prepare and Ship Environmental Samples

CDM field personnel will properly collect and manage samples, and arrange forappropriate shipment to the designated laboratory. CDM will follow procedures asspecified in the EPA Region 4 Environmental Investigations Standard OperatingProcedures and Quality Assurance Manual (EISOPQAM) (November 2001b) and theCLP protocols.

3.5.2 Subtask 5.2—Coordinate With Appropriate SampleManagement Personnel

CDM will arrange shipment and delivery schedules with the appropriate samplemanagement personnel at EPA Region 4 SESD to provide any clarification on the datacollection procedures that may be required. CDM anticipates using a CLP laboratoryor the EPA Region 4 SESD laboratory.

3.5.3 Subtask 5.3—Implement EPA-Approved Laboratory QAProgram—N/A

3.5.4 Subtask 5.4—Provide Sample Management

CDM will develop and implement a site-specific data management system thatincludes maintaining field logs, sample management and tracking procedures, anddocument control and inventory procedures for both laboratory data and fieldmeasurements to ensure that the data collected during the investigation are ofadequate quality and quantity to support the risk assessment and the FS. All samplemanagement procedures used in this investigation will be in accordance with thestandards specified in the Environmental Investigation Standard Operating Procedures andQuality Assurance Manual, EPA Region 4, November (2001b).

3.5.5 Subtask 5.5 - Validate Data

All CLP data will be validated by the EPA Region 4 SESD.

3.6 Task 6 — Data Evaluation3.6.1 Subtask 6.1-Data Usability Evaluation and Field QA/QC

CDM will review the data collected and the field QA/QC protocols to evaluate if thedata generated are appropriate for the intended use.

3.6.2 Subtask 6.2—Data Reduction, Tabulation, and Evaluation

CDM will analyze all site investigation data and present the results of the analyses inan organized and logical manner so that the relationships between site investigationresults for each medium are apparent. The data evaluated will include soilmeasurements, biological measurements, etc. The data evaluation process may

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3 4 ^ 0 5 4include tabulation, computer analysis, graphic representation, or other methods thataid in the evaluation of the data and conceptualization of the results. The results ofthis data evaluation subtask will be presented in the Data Summary Report.

3.6.3 Subtask 6.3-Web CISCDM will produce a Web-Enabled Geographic Information System (Web GIS) withthe overall objective to improve the usability of the current environmental databaseby linking it to data query/display desktop software application, and integrating itwith other applicable base maps and aerial photos. This system will include dataquery tools and the Picayune base map integration utilizing existing environmentaldata and base maps.

3.6.3.1 Basemap GIS Data Conversion

CDM will convert existing basemap coverages for Picayune to a GIS compatibleformat for use in AutoDesk MapGuide. All spatial data, including vector, tiger, andimagery will be converted to State Plane North American Datum 1983 using ESRI'sArcGIS GIS package.

Assumptions:

Spatial data files provided will be in native AutoCAD file format and will be limitedto transportation, vegetation, buildings, relevant site boundaries, and up to fourregistered orthophotos.

Spatial data for Picayune not currently available will be purchased from the spatialdata clearinghouse. Spatial data coverages will be provided in consistent projection,units, and coordinate system.

3.6.3.2 Web-Based Data and GIS System

CDM will build and maintain a web-based system with Web GIS functions only forPicayune. CDM will utilize ESRI ArcIMS software to host the Web GIS portion of thesite.

The software application will provide the ability to query the data by location, media,date and depth. Project shape files (roads, streams, sampling grids, etc.) and imagery(aerial photos, Digital Raster Graphics [DRG] Quad Maps) will be accessible forviewing. Site boundaries and sampling locations will be identified. GIS functionsincluding zoom in, zoom out, pan, and identify will be added to the site. Analyticdata will be linked to the site using Open Database Connectivity (ODBC) technologydirectly from the Microsoft Access Database. Analytical data will be accessiblethrough both a geographic selection and through interactive queries that outputregulatory criteria exceedance, detect, and raw data reports. These data reports willopen through the web browser in standard Adobe Acrobat software format. Access tothe site will be restricted through a password-protected logon.

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3 4 -,-055The software will allow all queries to be screened against Maximum ContaminantLevels (MCLs) and risk-based levels. CDM will host the web site for the system for aperiod of one year beginning on the delivery date.

Assumptions:

Analytical data will be included in the Access database and will include associatedreferential coordinates, sample attributes, and analyte names. Data that do notinclude this information will be excluded from the Web CIS Application.

Not included in this task will be adding new analytical data to the system orupgrading the system for the addition of new features not listed above.

The site will be hosted on the domain http://online.cdm.com administered by CDM'sI-Technology group located in Cambridge, Massachusetts.

• The server will be contained in a locked computer room, with strictly limited keycard access.

• The computer room will maintain an Inergen system, which suppresses firewithout damaging equipment or endangering personnel.

• The room will be serviced by an uninterruptible power supply with battery andgenerator backup to commercial power with the air handling and conditioning isseparate from the building system.

Regulatory criteria shall be readily available or provided in electronic format and willbe incorporated at a site-wide level.

Each user will be required to install a free ArcIMS Viewer for access to the site.

3.6.4 Subtask 6.4 —Develop Data Evaluation Report

The results of the data evaluation subtask will be presented in the Data EvaluationSummary report. CDM will prepare a report summarizing the information collectedduring the field investigation and ecological field survey.

3.7 Task 7—Assessment of RiskCDM will prepare a BRA to provide a quantitative and qualitative understanding ofthe actual and potential risks to human health and the environment posed by the siteif no remediation or institutional controls are applied. The BRA consists of both ahuman health assessment (Section 3.7.1) and an ecological assessment (Section 3.7.2).Together, they will be used to help determine whether additional remediation isnecessary. If it is, the BRA will yield a set of risk-based remedial action objectives,which may be used as cleanup goals.

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3 4 10563.7.1 Subtask 7.1 —Human Health Assessment

The purpose of the Human Health Baseline Risk Assessment (HHBRA) is to analyzethe potential adverse effects on humans, which may result, either now or in thefuture, from the presence of hazardous chemicals at the site or released from the site.CDM will prepare the HHBRA utilizing principal guidance documents including, butnot limited to, the documents list in the References (Section 6 of this Work Plan).Other EPA guidance, technical directives, and memos will be used and referencedwhere appropriate.

3.7.1.1 Data Collection and Evaluation

CDM will tabulate the data collected during the RI to show the frequency ofdetection, the arithmetic mean (using only samples with detected contamination"hits"), the range of detects, the range of background concentrations, and the samplecollection dates. Estimated ("J" values) will be included. Tentatively identifiedcompounds ("N" values) will be included on the list of chemicals of potential concern(COPCs) if there is reason to believe that the chemicals may be linked to past site use.

COPCs will be developed using the screening criteria as described in Risk AssessmentGuidance for Superfund (RAGS) (EPA 1989) and EPA Region 4 Guidance (EPA1998a). CDM will use the EPA Region 9 Preliminary Remediation Goals (PRGs)toxicity screening tables (most current version) for groundwater, surface water, andsediment data. For the soil data, CDM will use the EPA Region 9 PRGs. Chemicalsdetected at least once in a medium will be evaluated for that medium. Screeningcriteria include: toxicity screen using EPA Region 9 PRGs tables, background sampleconcentration comparison (inorganics only, two times the mean backgroundconcentration used as the screening criterion), and unless present at highconcentrations (per the EPA Region 4 toxicologist), essential nutrients (calcium,chloride, iodine, magnesium, phosphorus, potassium, and sodium) will not beincluded for further evaluation. The COPCs will be used in the subsequent exposureassessment, toxicity assessment, risk characterization, and development of RemedialGoal Options (RGOs).

3.7.1.2 Exposure Assessment and Documentation

CDM will identify potential exposure points and contaminant migration pathways aspart of the exposure assessment. Reasonable maximum exposures (RMEs) will bedeveloped for both current and future land-use assumptions. RMEs forenvironmental media will be calculated according to EPA Region 4 guidance usingthe lesser of the 95 percent upper confidence limit (UCL) on the arithmetic average fora log normal distribution or the maximum detected value (EPA 1992b, EPA 1997a).Where a COPC is not detected, one-half the sample quantitation limit will be used asa proxy concentration to calculate the exposure point concentration. If both the proxyconcentration and the UCL exceed the maximum detected value, the maximumdetected value will be used as the RME concentration. The Central TendencyExposure (CTE) may also need to be considered. If this is determined to be the case

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3 4 j057based on consultations with the EPA Region 4 health assessment staff, these CTEconsiderations will be included in an appendix to the BRA report.

Exposure factors will be obtained from EPA's Standard Default Exposure Factors,Office of Solid Waste and Emergency Response (OSWER) Directive 9285.6-03 (EPA1991). CDM will identify exposure pathways based on the sources, release types, andlocations of chemicals at the site; the likely environmental fates of these chemicals;and the locations and activities of the at-risk populations. Exposure pointconcentrations and routes of exposure (e.g., ingestion, inhalation, dermal contact) willbe identified for each exposure pathway and medium.

3.7.1.3 Toxicity Assessment and Documentation

CDM will produce a toxicity assessment of the COPCs using data derived from theIntegrated Risk Information System (IRIS) and Health Effects Assessment SummaryTables (HEAST) for inclusion in the baseline risk assessment report (EPA 1998b, EPA1997a). Where information is not available in IRIS or HEAST, EPA will be consultedand other reputable data sources will be searched.

The assessment will summarize the types of adverse health effects associated withchemical exposure; the relationships between the magnitude of exposure and adverseeffects; and the uncertainties concerning contaminant's toxicity (e.g., weight ofevidence for chemical's carcinogenicity). Toxicity information for each chemical willbe summarized in the BRA report with a reference to the source of information.

Carcinogenic toxicity tables will be developed containing the following informationfor each COPC: weight of evidence and for oral, inhalation, and dermal pathways,tumor site(s), unit risk values, and slope factors will be provided as appropriate.Noncarcinogenic toxicity tables will be developed containing the followinginformation for each COPC: critical effect/target organ affected and chronic referencedoses. All data provided will be properly referenced in each table.

3.7.1.4 Risk Characterization

The objective of the risk characterization is to integrate the information developed inthe exposure assessment and the toxicity assessment into an evaluation of thepotential current and future health risks associated with the COPCs at the site.Potential cancer risk will be calculated by multiplying the estimated lifetime-averageddaily intake that is calculated for a chemical through an exposure route by theexposure route-specific (oral, inhalation, or dermal) cancer slope factor. For eachscenario, the cancer risks will be added to calculate total risks for each chemical, foreach exposure route, and for all chemicals and exposure routes.

The potential for non-carcinogenic health effects will be evaluated by the calculationof hazard quotients (HQs) and hazard indices (His). An HQ is the ratio of theexposure duration-averaged estimated daily intake through a given exposure route tothe chemical and route-specific (oral, inhalation, or dermal) reference dose. HQs will

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3 4 ^ 0 5 8be totaled to calculate His for each receptor scenario. His will be calculated based onall chemicals and exposure routes.

Adverse effects from exposure to lead contaminated materials are not determined bymethodology described above; no reference dose for lead currently exists. Therefore,non-cancer effects from the potential exposure to lead contaminated soils will beevaluated for children by using the Integrated Exposure Uptake Biokinetic Model(IEUBK Model). For adults, adverse effects to lead will be evaluated by using theadult lead model presently under review (EPA 1996) and by consultation with EPARegion 4 toxicologists.

3.7.1.5 Risk-Based Remediation Goal Options

CDM will calculate RGOs for the COCs based on site-specific information. Region 4EPA defines COCs as chemicals (i.e., COPCs) that contribute to a use scenario thatexceeds a 1 x 1O1 excess cancer risk or an HI of 1 (EPA 1997b). Chemicals that exceeda state or federal applicable or relevant and appropriate requirement (ARAR) are alsoCOCs. Chemicals are not COCs if their individual contribution to a pathway is lessthan 1 x 10~5 for carcinogenic risk or less than 0.1 for non-carcinogenic risk, asestimated in the risk characterization.

The media, exposure scenarios, and exposure assumptions will be the same as thoseused in the BRA. The analysis will include exposures under both current and futureuse conditions. For carcinogens, concentrations corresponding to 1 x 10-*, 1 x 1O5, and1 x 1O6 risk levels will be presented. For non-carcinogens, concentrations thatcorrespond to HQs of 0.1,1, and 3 will be presented. Where appropriate, the risk-based remediation goals will be compared to the risks associated with ARARs at thesite.

3.7.1.6 Baseline Risk Assessment Report

Following completion of the risk assessment subtasks, CDM will prepare a BRAreport. The BRA report will document in detail the results of the baseline riskassessment and the conclusions drawn from these results. All supporting data,information, and calculations will be included in the report and all documents andpublications used in its preparation will be properly referenced. The report will bedeveloped by closely following RAGS guidance (EPA 1989) and tables presented inthe risk assessment (e.g., COPC list, exposure tables, toxicity tables, estimated cancerrisks, estimated non-cancer risks) will follow RAGS Part D guidance (EPA 1997c)where possible. CDM will deliver three copies of the draft BRA report. Within15 days after receipt and reconciliation of EPA comments on the draft BRA report,CDM will prepare and deliver three copies of the final BRA report addressing EPA'scomments.

A qualitative uncertainty analysis will be provided which presents major assumptionsand uncertainties associated with the risk assessment, including general uncertainties

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3 4 "'059associated with the risk assessment process, and site-specific uncertainties associatedwith the site. The predicted direction of each assumption or uncertainty on theevaluation of risk (i.e., overestimate, underestimate, or uncertain) will be indicated.The focus will be on those chemicals and exposure pathways that pose a potentialcancer risk of greater than 1E-06 or have a total HI greater than 1. Quantitativeestimates of uncertainty (e.g., Monte Carlo simulation) will not be performed.

3.7.2 Subtask 7.2—Ecological Risk AssessmentCurrent EPA guidance recommends an 8-step process for designing and conductingconsistent and technically defensible ecological risk assessments for the SuperfundProgram (EPA 1997c).

For this proposal, CDM has included the costs through Step 3a. At the conclusion ofStep 3a, a decision point meeting will be held to determine if further ecologicalinvestigation work is necessary to complete the baseline ecological risk assessment(BERA). An addendum to this work plan and additional budget will be required ifthe remaining steps of the BERA are necessary.

Steps 1 and 2 constitute a screening-level ecological risk assessment (SERA), whichcompares existing site data to conservative screening level values to identify thosechemicals which can confidently be eliminated from further evaluation, and those forwhich additional evaluation is warranted. Step 3 of the 8-step process is initiated asthe planning and scoping phase for implementing a BERA. Step 3 includes severalactivities, including refinement of the list of COPCs, further characterization ofecological effects, refinement of information regarding contaminant fate andtransport, complete exposure pathways, ecosystems potentially at risk, selectingassessment endpoints, and developing a conceptual model with working hypothesesor questions that the site investigation will address. The refinement of the list ofCOPCs is referred to as Step 3a, and is typically submitted to the Ecological TechnicalAssistance Group for review and comment before completing the remainder of Step 3.In Step 3a, additional types of information are considered to further refine the list ofchemicals to be carried through the BERA, so that the chemicals most likely to resultin risks to ecological receptors remain the focus of the evaluations. Step 3b is referredto as the problem formulation.

In Step 4, a SAP is developed and used to gather further data to support the BERA.The SAP contains both the DQOs and the work plan developed for the field effort.The budget for the preparation of the SAP is included in Section 3.1.2 of this workplan.

Step 5 is the field verification of the Step 4 sampling design. This consists of a sitevisit or site reconnaissance, to determine that the field activities can take place asoutlined in the Step 4 work plan and SAP.

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Step 6 of the process is the actual data collection for the BERA, which results inanother scientific/management decision point that documents the results of the fieldeffort.

Step 7 is the summary and analysis of the data, and prediction of the likelihood ofadverse effects based on the data analysis, which is presented as the RiskCharacterization. It also includes consideration of uncertainties and ecologicalsignificance of risks in view of the types and magnitude of effects, spatial andtemporal patterns, and likelihood of recovery.

Step 8 results in a scientific/management decision point discussing significant risks,recommended cleanup (if any), and future efforts.

Steps 1 through 3a are further detailed below.

3.7.2.1 Screening Level Problem Formulation

The screening level problem formulation will consist of several subsections providingbackground information necessary to complete the screening level ecological riskassessment. These sections will include the following:

• a description of the environmental setting including habitat descriptions, potentialecological receptors, sensitive ecosystems, and threatened and endangered speciesand habitat survey results;

• identification of contaminants at the site;

• identification of fate and transport mechanisms;

• a discussion of the ecotoxicity potential for the contaminants of potentialecological concern (COPEC);

• a description of the complete exposure pathways and a conceptual site model; and

• identification of assessment and measurement endpoints.

3.7.2.2 Screening-Level Ecological Effects Evaluation

The next step in the process is the screening-level ecological effects evaluation and theestablishment of contaminant exposure levels that represent conservative thresholdsfor adverse ecological values. A literature search will be conducted to identify studiesthat quantify toxicity to evaluate the likelihood of toxic effects occurring at the site.Screening ecotoxicity values will be selected that ideally represent a no-observed-adverse-effect-level (NOAEL) for reproduction in the species of concern, based onlong-term exposure to a contaminant. If this is not possible, uncertainty factors willbe incorporated into the literature-derived value in the derivation of a final toxicity

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3 4 0061reference value (TRY). This will be done in consultation with EPA Region 4lexicologists.

3.7.2.3 Screening-Level Exposure Estimates

The exposure estimate will be based on the highest detected on-site contaminantconcentration for each environment. Exposure parameters will be identified using themost conservative assumptions for area-use factors, bio-availability, life stage, bodyweight, food ingestion rate, and dietary consumption.

3.7.2.4 Screening-Level Risk Calculation

A quantitative screening-level risk value will be estimated using the exposureestimates and screening ecotoxicity values that will be developed. For the screening-level risk calculation, the HQ approach will be used. This approach compares pointestimates of screening ecotoxicity values and exposure values to derive an HQ. AnHQ value greater than 1 indicates the potential for risks to the receptor evaluated.

3.7.2.5 Uncertainty Analysis

As with human health risk assessment, there are many uncertainties associated withestimating exposure and risks to ecological organisms. The uncertainty analysis willaddress the major assumptions that affect the degree of confidence in the estimate ofrisk. Variables such as exposure locations, strength of the exposure assumptions usedin calculating doses, and the strength of the toxicological evidence supporting thetoxicity values, will be evaluated in the uncertainty analysis and their respectiveinfluence on the risk estimates will be discussed. Quantitative measures ofuncertainty (e.g., Monte Carlo analyses) will not be preformed.

3.7.3 Refinement of BERA COPCs

The COPCs identified in the SERA are reevaluated (Step 3a) to identify thosechemicals most likely to contribute to ecological risks, and to eliminate fromconsideration those chemicals having little or no potential to contribute to risks.Factors considered in the revaluation of COPCs included the following:

• Consideration of chemicals that are site-related.

• An evaluation of the frequency of detection for each chemical.

• A comparison to reference site concentrations.

• A review of alternative screening level values.

• Calculation of HQs.

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3 4 00623.7.3.1 Scientific/Management Decision Point

Following completion of the Steps l-3a of the ecological risk assessment process, anevaluation of the information available is required to determine if a risk managementdecision can be made regarding the potential for ecological risks. There will be threepossible decisions at this point in the process. These include the following:

• There is adequate information to conclude that ecological risks are negligible andtherefore there is no need for remediation on the basis of ecological risk;

a The information is not adequate to make a decision at this point, and theecological risk assessment process will continue to a supplemental effort to collectdata from the site; or

• The information indicates a potential for adverse ecological effects, and the riskassessment will continue to the Problem Formulation (Step 3b).

3.8 Task 8-Treatability Study and Pilot Testing -N/A3.9 Task 9 —Remedial Investigation ReportCDM will prepare the RI report that accurately establishes the site characteristics suchas media contaminated, extent of contamination, and the physical boundaries of thecontamination. CDM will obtain only the minimal amount of data necessary todetermine the key contaminants movement and the extent of contamination.

3.9.1 Draft RI ReportCDM will produce a draft RI report that will include the following sections:

• Site Background

• Site Investigation

• Site Characteristics

• Nature and Extent of Contamination

• Fate and Transport

• Summary and Conclusions

3.9.2 Final RI ReportAfter EPA review of the draft RI report, CDM will address and incorporate the EPAcomments, as appropriate, and produce the final RI report.

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3 4 -10633.10 Task 10—Remedial Alternatives ScreeningCDM will develop a range of distinct hazardous waste management alternatives thatwill remediate or control contamination at the site to protect human health and theenvironment. The potential alternatives will encompass the following:

• A range of alternatives in which treatment is used to reduce the toxicity, mobility,or volume of wastes. The range will vary in the types of treatment, the amounttreated, and the manner in which long-term residuals or untreated wastes aremanaged.

— Alternatives involving both containment and treatment components

— Alternatives involving containment with little or no treatment

— A no-action alternative

Alternatives that involve minimal efforts to reduce potential exposures (e.g., sitefencing, deed restrictions) will be presented as "limited action" alternatives.

The subtasks described below will be performed in sequential order to determine theappropriate range of alternatives for the site. The results of these subtasks will besummarized in a remedial alternatives technical memorandum to EPA. This technicalmemorandum will include an alternatives array summary that may be modified byEPA to ensure evaluation of a complete and appropriate range of viable alternativesduring the remedial alternatives evaluation phase (Task 11). The technicalmemorandum will document the methods, rationale, and results of the alternativesscreening process.

3.10.1 Subtask 10.1 —Remedial Alternatives ObjectivesEstablishmentBased on the information collected during the RI, CDM will review and, if necessary,refine the remedial action objectives. These objectives will specify the contaminantsfound and media of concern, exposure pathways and receptors, and an acceptablecontaminant level or range of levels for each exposure route (i.e., remediation goaloptions).

CDM will also develop the general response actions, defining contaminantcontainment, treatment, excavation, pumping, or other actions, singly or incombination, to satisfy the remedial action objectives. Areas and volumes of media towhich general response actions may apply will be identified, taking into account therequirements for protectiveness as identified in the remedial action objectives. Thechemical and physical characteristics of the site and the baseline risk assessment andremediation goals will also be taken into account.

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3 4 00643.10.2 Subtask 10.2—Technology Identification and ScreeningCOM will identify and evaluate those technologies applicable to each generalresponse action to eliminate those that cannot be implemented at the site. Based onthe developed general response actions, hazardous waste treatment technologies willbe identified and screened to ensure that only those technologies applicable to thecontaminants present, their physical matrix, and other site characteristics will beconsidered. This screening will be based primarily on a technology's ability toeffectively address the contaminants at the site, but will also take into account theimplementability and cost of the technology. The results of treatability studies (ifavailable) will be used to assist in the screening. Technologies that are innovative, orreduce the mobility, toxicity, or volume, or lead to a permanent remedy will beemphasized in the alternatives. CDM will select representative process options, asappropriate, to carry forward into alternative development.

3.10.3 Subtask 10.3—Alternatives Configuration and ScreeningSelected technologies and process options retained in this FS will be combined intomedia-specific or site-wide alternatives. The developed alternatives will be definedwith respect to size and configuration of the representative process options, relativetime for remediation, rates of flow or treatment, spatial requirements, distances fordisposal, required permits, imposed limitations, and other relevant factors. If manydistinct, viable options are identified, the alternatives will be screened with respect totheir effectiveness, implementability, and cost to consider only the most promisingprocess options. As appropriate, the screening will preserve the range of treatmentand containment alternatives that was initially developed. The action-specific ARARswill be updated as the remedial action alternatives are refined.

3.11 Task 11 — Remedial Alternatives EvaluationCDM will perform a detailed analysis of the alternatives that passed through thedevelopment and screening process (Tasks 10 and 11). Each alternative will beanalyzed with respect to the following nine EPA-mandated evaluation criteria:

• Overall Protection of Human Health and the Environment—addresses whether ornot a remedy provides adequate protection and describes how risks posedthrough each pathway are eliminated, reduced, or controlled through treatment,engineering controls, or institutional controls

• Compliance with ARARs — addresses whether or not a remedy will meet all of theARARs of federal and state environmental statutes and/or provide grounds forinvoking a waiver

• Long-Term Effectiveness and Permanence — refers to the ability of a remedy tomaintain reliable protection of human health and the environment over time oncecleanup goals have been met

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3 4 0065• Reduction of Toxicity, Mobility, or Volume — refers to the anticipated performance

of the treatment technologies used in a remedy

• Short-Term Effectiveness —addresses the effects on human health and theenvironment during the implementation of a remedy and until cleanup goals areachieved

• Implementability—refers to the technical and administrative feasibility of aremedy, including the availability of materials and services needed to implementa particular option

• Cost—includes estimated capital, and operation and maintenance costs, and netpresent worth costs

• State Acceptance —addresses the technical or administrative issues and concernsthe state support agency may have regarding a remedy

• Community Acceptance —addresses the issues and concerns the public may haveregarding a remedy.

The individual analyses will include a technical description of each alternative thatoutlines the waste management strategy and identifies the key ARARs associatedwith the alternative, and a discussion that profiles the performance of the alternativewith respect to each of the evaluation criteria. A table summarizing the results of theanalyses will be prepared and included in the FS report (Task 12). 'Once theindividual analyses are completed, the alternatives will be compared and contrastedto one another with respect to each of the evaluation criteria. Note that the last twocriteria (state acceptance and community acceptance) will be addressed by EPA in theROD after all comments have been received and will not be included in the FS report.

For cost estimating purposes, up to ten remedial action alternatives (not including theno action alternative) will be analyzed in detail for this task. If more than tenalternatives are included, a work assignment amendment may be required to accountfor the additional effort needed.

3.12 Task 12-Feasibility Study ReportFollowing completion of Tasks 9,10, and 11, CDM will prepare an FS report. Thereport will summarize the activities conducted during the RI, the results of theseactivities, and the conclusions that were drawn. The report will also document theremedial alternatives development and screening, and the detailed analysis ofalternatives: In addition, the results of the BRA will be summarized in this report. Allsupporting data, information, and calculations will be included in appendices to theFS report; all documents and publications used in preparing the report will beproperly referenced.

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3 4 0066CDM will prepare a draft FS report and submit three copies to EPA for review.Within 45 days after receipt and reconciliation of EPA comments on the draft FSreport, CDM will prepare and deliver three copies of the final FS report addressingEPA's comments.

3.13 Task 13 —Post-Remedial Investigation/FeasibilityStudy SupportCDM will assist EPA in performing any or all of the activities described below whichare needed in the post-FS phase of the project.

3.13.1 Subtask 13.1-Attend Public Meetings, Briefings, andTechnical Meetings With PRPs; Prepare Presentation Materials

CDM will provide administrative and logistical support to EPA in preparation for anypublic meetings, briefings, press conferences, and/or workshops. Support activitiesfor these meetings may include any of the following activities:

• Arranging the meeting location;

• Arranging meeting logistics (rental and delivery of audio-visual equipment, set-up, takedown, room fees, etc.);

• Preparing a meeting agenda, sign-in sheets, name tags, cards for participants,response cards or envelopes, and visual aids;

• Preparing and reproducing handouts;

• Coordinating a dry run of the meeting;

• Preparing and arranging for publication of a public notice to announce themeeting;

• Arranging for a court reporter to record the meeting proceedings;

• Preparing a simple sign (not requiring outside vendors) for the meeting; and

• Participating in the meeting.

CDM will assist EPA in preparing public notices for publication as advertisements inthe local newspaper to allow the general public to receive accurate and timelyinformation about site remedial activities. Upon EPA approval of each public notice,CDM will coordinate the publication of the notice in the local newspaper. At EPA'srequest, the notices will also be mailed to interested parties on the mailing list.

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3 4 00673.13.2 Subtask 13.2—Provide Technical Assistance —Responsiveness Summary

At the completion of the public comment period, COM will assist EPA in preparingthe responsiveness summary that will accompany the EPA ROD. The summary willconsist of an overview of the selected remedy for the site and/or changes in theremedy and any alternatives suggested by the public that the agency had notpreviously considered, background on community involvement, and a summary ofcomments received and EPA responses. CDM will assist EPA in formulatingresponses to comments of a technical nature, but will rely on EPA to respond to legalquestions or comments.

3.13.3 Subtask 13.3—Provide Technical Assistance—ProposedPlan and ROD

CDM will assist EPA in preparing the proposed remedial action plan. CDM technicalstaff responsible for the BRA and FS reports will assist EPA in drafting the technicalportions of the proposed plan and ROD. CDM will also prepare figures, tables, andgraphs, as necessary, assist with the community involvement information, and willformat and print copies of the proposed plan for distribution. The schedule for thecompletion of any support activities and delivery of the appropriate documents willbe established by the EPA RPM after conferring with the CDM Project Manager.

3.14 Task 14 - Negotiation Support - N/A

3.15 Task 15 - Administrative Record-N/A

3.16 Task 16—Work Assignment CloseoutProject closeout procedures will be implemented upon completion of the workassignment. Closeout of the work assignment will be divided into two majoractivities: technical/financial and work assignment files. The technical/financialactivities will include, as appropriate:

• closeout of purchase order accounts;

• property identification, inventory, and turnover;

• review and reconciliation of work assignment accounting status;

• review and reconciliation of work plan and work plan amendment approvalstatus;

• technology transfer database update;

• completion of the Work Assignment Completion Report;

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3 4 1Q68• finalization and invoicing of the award fee; and

• submission of the final invoice.

The work assignment file closeout and transfer activities will include the following:

• collection and organization of work assignment files,

• file microfiching,

• file inventory and shipping,

• quality control review, and

• file duplication and disposition.

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Section 4Period of Performance and Schedules

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4.1 Work Assignment Period of PerformanceThe period of performance for this work assignment will extend from September 13,2002, through October 31, 2004. All reporting and project closeout will be completedwithin this time frame.

4.2 Schedule of Deliverables/MilestonesTable 4-1 below shows the schedule proposed at this time for CDM deliverables.

Table 4-1Schedule for CDM Deliverables/Milestones

Task Deliverable Due Date

1.1.1 Scoping meeting

1.1.2 Site Visit Report

1.1.5.1 Draft Work Plan

1.1.5.2 Final Work Plan

1.2.1(1) Draft Health, and Safety Plan

1.2.1 (1) . Final Health and Safety Plan .

1.2.1 (2) Draft Sampling and Analysis Plan

1.2.1(2) Final Sampling and Analysis Plan

1.3.1 Monthly Progress Reports

1.3.1 Ad hoc financial information

1.3.2 Technical meetings

1.5 Audit

6.4 Data Evaluation Summary Report

7.1.1 Draft Human Health Risk AssessmentReport

7.1.2 Final Human Health Risk AssessmentReport

7.2.1 Draft Ecological Risk AssessmentReport

7.2.2 Final Ecological Risk AssessmentReport

9.1 Draft Remedial Investigation (Rl)Report

9.2 Final Rl Report

November 1,2002

November 8, 2002

August 26, 2003

October 24, 2003

30 days after work plan is approved

15 days after receipt of EPA comments

30 days after work plan is approved


20 days following the last day of each month

14 days after WAM/RPM request

As scheduled

As requested by EPA

30 days after receipt of analytical results fromlaboratory

90 days after completion of fieldinvestigations


90 days receipt of CLP laboratory data


90 days after EPA approval of the Final DataSummary Report


4-1

WP-V1 124 Oraft/0826

Section 4Period of Performance and Schedules

3 4Table 4-1 (continued)Schedule for COM Deliverables/Milestones

0070

Task Deliverable Due Date

10.1 Draft Remedial Alternatives TechnicalMemorandum

10.2 Final Remedial Alternatives TechnicalMemorandum

11.1 Remedial Alternatives Evaluation

12.1 Draft Feasibility Study Report

12.2 Final Feasibility Study Report

13.2 Responsiveness Summary Support

13.3 Draft Proposed Plan

13.3 Final Proposed Plan

13.3 Draft ROD

13.3 Final ROD

16 Work Assignment Closeout Report

45 days after Rl Report Approval


30 days after completion of RemedialAlternatives Technical Memorandum

90 days after Rl Report Approval


As directed

As directed


As directed


30 days after receipt of WAF from EPA

COMWP-V1J24 Draft/0826

4-2

c . . • - 34 0071Section 5Project Personnel and ResponsibilitiesA multi-disciplinary team has been organized to provide technical expertise toconduct the tasks identified within this work assignment. CDM personnel proposedat this time and their responsibilities involved with the project are shown onTable 5-1 below. Other personnel will be identified as required to meet project needs.

Table 5-1CDM Project Team Personnel and Responsibilities

Position Personnel Responsibilities

Region 4 Program Manager - P4 Gary demons

CFAM - P4 Richard Culver

QA Coordinator - P3 . Tony Isolda

Project Manager - P3 Mike Profit

Human Health Risk'Assessment Mike ProfitSpecialist - P3

Ecological Risk Assessment Murray WadeSpecialist - P3

Finance & Administration Staff - P2 Various

Program management for RAC inRegion 4

Contract and financial management forRAC

Region 4 RAC QA compliance

Site-specific administration and projectmanagement

Draft/Final Human Health RiskAssessment Reports

Draft/Final Ecological Risk AssessmentReports

Contract administration and financialreporting, and invoicing

A breakdown of estimated staffing levels for each task within this work assignment isincluded in Volume II.

CDM 5-1

3 4 0072Section 6References

CDM Federal Programs Corporation (CDM) 1996. RAC Region 8 Standard Operating Procedures,Attachment B, "Quality Management Plan (QMP)," Document Control No. 3280-999-PP-SOPS-00086, August 23.

CDM 2002. CDM. Federal Programs Corporation Quality Assurance Manual, Section 4.0,Revision 10, February 10.

EPA (U.S. Environmental Protection Agency). 1989. Risk Assessment Guidance for Superfund(RAGS), Volume I: Human Health Evaluation Manual (Part A). Office of Emergency andRemedial Response, Washington, D.C., EPA/540/1-89/002.

EPA 1991. "Standard Default Exposure Factors," Human Health Evaluation Manual, SupplementalGuidance, OSWER Directive 9298.6-03. March 25.

EPA 1992a. Community Relations in Superfund: A Handbook, January.

EPA 1992b. Supplemental Guidance to RAGS: Calculating the Concentration Term, May.

EPA 1996. Recommendations of the Technical Review Workgroup for Lead for an Interim Approach toAssessing Risks Associated with Adult Exposures to Lead in Soil. Technical Review Workgroupfor Lead.

EPA 1997a. Health Effects Assessment Summary Tables (HEAST) FY-1997 Update. Office of SolidWaste and Emergency Response, EPA/540/R-97-036, PB97-921199. July.

EPA 1997b. Risk Assessment Guidance for Superfund, Volume I: Human Health Evaluation Manual,(Part D, Standardized Planning, Reporting, and Review of Superfund Risk Assessments).

EPA 1997c. Ecological Risk Assessment Guidance for Superfund: Process for Designing andConducting Ecological Risk Assessments (Process Document).

EPA 2000. Guidance for the Data Quality Objectives Process, EPA QA/6-4/R-96/O55, August.

EPA 2001a. Final Preliminary Assessment/Site Inspection Report Picayune Wood Treating, Inc.,Picayune, Pearl River County, Mississippi. May 9.

EPA 2001b. Environmental Investigations Standard Operating Procedures and Quality AssuranceManual, Region 4, SESD, November.

EPA 2001c. Requirements for Quality Assurance Project Plans for Environmental Data Operations,EPA QA/R-5, Final, EPA/240/3-01/003, March.

CDMWP-V1_1240rafl/OB28

3 4 0073Section 6

References

Pine Belt Environmental, Inc. 1995. RCRA Facility Investigation Report.

Pine Belt Environmental, Inc. 1996. Semi-Annual Corrective Action Progress Report, Wood Treating,Inc., Picayune, MS. October 21.

Rollins (H.M. Rollins Company) 1987. Wood Treating, Inc. Picayune, MS., Groundwater QualityAssessment. Volume I. August 20.

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02-014/3282-12IV0325

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