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WORK PLAN FOP. THEPHASE III REMEDIAL INVESTIGATION

AND FEASIBILITY STUDY

G&H INDUSTRIAL FILL SITEShelby Township, Michigan

WA 12-5L70.0Contract No. 68-W8-0040

November 18, 1988

CKMHILL

EngineersPlannersEconomistsScientists

EPA Region 5 Records Ctr.

WORK PLAN FOR THEPHASE III REMEDIAL INVESTIGATION

AND FEASIBILITY STUDY

G&H INDUSTRIAL FILL SITEShelby Township, Michigan

WA 12-5L70.0Contract No. 68-W8-0040

November 18, 1988

GLT661/39

CONTENTS

Section

Introduction 1-1Goals of the RI/FS 1-1Site Background i-i

Location 1-1Topography/Surface Drainage 1-2Geology 1-2Hydrogeology 1-3

Site History 1-3Contaminant Sources and Migration 1-5

Contaminant Source Areas 1-5Contaminant Migration 1-6

Preliminary Risk Assessment 1-7

Project Planning and Community Relations 2-1Task PP—Planning Activities 2-1

Subtask PP.PM—Project Management 2-1Subtask PP.QC—Quality Control 2-1Subtask PP.WP--RI/FS Work Plan 2-1Subtask PP.QS—Site Planning 2-1Subtask PP.AP—Scoping ofResponse Actions 2-2

Task CR—Community Relations Activities 2-3Subtask CR.CP—Community RelationsPlanning 2-3

Subtask CR.CR—Community RelationsImplementation 2-3

Subtask CR.CS—Community RelationsTechnical Support 2-3

Phase III RI and FS Work Plan 3-1Phase III RI Data Quality Objectives 3-1Task FI—Phase III RI Field Activities 3-3

Subtask FI.PM—Project Management 3-3Subtask FI.QC—Quality Control 3-3Subtask FI.FK—Fieldwork Support 3-3Subtask FI.FM—Surveying and Mapping 3-4Subtask FI.FF—RI-Derived WasteDisposal 3-4

Subtask FI.FC—Field ScreeningLaboratory 3-5

Subtask FI.SM—Sample Management 3-5Subtask FI.FS—Soil Boring and

Sampling 3-5Subtask FI.FI—Monitoring WellInstallation 3-8

Subtask FI.FQ—GroundwaterSampling and Hydraulic Testing 3-10

LIST OF ACRONYMS

ARAR Applicable or Relevant and AppropriateRequirements

3NA Base, Neutral, and Acid

BOD Biochemical Oxygen Demand

CERCLA Comprehensive Environmental Response, Compensationand Liability Act of 1980 (Superfund)

CLP Contract Laboratory Program

COD Chemical Oxygen Demand

CRL Central Regional Laboratory

CSL Close Support Laboratory

MDNR Michigan Department of Natural Resources

HRS Hazard Ranking System

NPL National Priorities List of UncontrolledHazardous Waste Sites

OVA Organic Vapor Analyzer

PCB Polychlorinated Biphenyl

PCE Perchloroethylene or Tetrachloroethene

PRP Potentially Responsible Party

PVC Polyvinyl Chloride

QA/QC Quality Assurance/Quality Control

QAPP Quality Assurance Project Plan

RCRA Resource Conservation and Recovery Act

RD Remedial Design

REM IV U.S. EPA Zone II Contract for Remedial Planning ofUncontrolled Hazardous Waste Sites

IV

LIST OF ACRONYMS (Continued)

RI/FS Remedial Investigation/Feasibility Study

RPM Remedial Project Manager

ROD Record of Decision

SARA Superfund Amendments and Reauthorization Actof 1986

SOP Standard Operating Procedure

SOW Statement of Work

TCL Target Compound List

TOC Total Organic Carbon

U.S. EPA United States Environmental Protection Agency

USCS Unified Soil Classification System

VOC Volatile Organic Compound

GLT661/40

Section 1INTRODUCTION

This work plan defines the scope of activities for accomplish-ing work assignment 12-5L70.0, which, authorizes CH2M HILL toperform the Remedial Investigation and Feasibility Study(RI/FS) for the G&H Landfill facility in Macomb County,Michigan. The work plan for the Phase III RI incorporatesrecommendations from the Interim RI Report (July 8, 1987),review comments from representatives of the potentiallyresponsible parties (PRPs), and review comments from theMichigan Department of Natural Resources (MDNR).

Two phases of the Remedial Investigation have been completedto date (Phase I: 1983-85; Phase II: 1985-86). The dataobtained during both of those phases were presented and ana-lyzed in the Interim RI Report. Phase I activities weredirected toward identifying releases from the G&H site intothe surrounding environment. Phase II activities were con-ducted to locate and characterize source areas and werebased in part on Phase I results. The Interim RI Reportdocuments the current understanding of conditions at thesite and lists gaps in the existing data where more informa-tion is needed to quantify potential health risks caused bythe site.

GOALS OF THE RI/FS

The overall goals of the RI/FS are:

o To complete a field program for collecting addi-tional data to quantify public health risks asso-ciated with contaminants at the G&H site

o To develop and evaluate remedial alternatives forthe G&H site

The planned work is directed toward gathering the informationnecessary to identify remedial alternatives that evaluate per-manent remedies and remedies that use treatment technologies.There is a preference for selecting such remedies in Sec-tion 121(b) of CERCLA as amended by SARA.

SITE BACKGROUND

LOCATION

The G&H Landfill site is in Shelby Township, Macomb County,Michigan, and situated on approximately 100 acres (Fig-ure 1-1). The landfill encompasses three distinct fillareas (see Figure 1-2):

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o Original Disposal Areao Phase II Landfillo Phase III Landfill

"he original disposal area may be further divided to containthe following features:

o Oil Pond No. 1

o Oil Pond No. 2

o Fish Pond

o Suspected Co-disposal Area (solvents and refusedisposed of simultaneously)

TOPOGRAPHY/SURFACE DRAINAGE

The local topography is relatively flat to gently rollingterrain that slopes to the southeast. In the site area,topographic depressions resulting from previous sand andgravel operations form many small ponds. Within the G&Hsite boundaries, the surface is characterized by a hummockyterrain over the landfill areas with steep sideslopes. TheClinton River, which flows southeastward and meanders fromimmediately west of the site to approximately 1/2 mile southof the site, is the ultimate receptor of site surface drain-age (Figure 1-2). The Clinton River Valley is approximately1/2 mile wide and is 30 to 50 feet below the surrounding landelevations. Within the site boundaries, several small areasof closed drainage may act as groundwater recharge areas.

GEOLOGY

The G&H site is underlain by unconsolidated soil units overa sandstone bedrock unit (Berea sandstone). Figure 1-3 is ageologic cross section of the site area. The soil units are,from ground surface to bedrock:

o Upper sand unito Upper till unito Middle sand unito Lower till unit

The upper sand unit varies in depth from 10 to 50 feet. Itis characterized by a coarse sand/dense fine sand interfaceoccurring at depths ranging from about 20 feet in the north-ern and central portion of the site to 5 feet in the south-ern portion.

The upper till unit is composed of fine-grained, well-consoli-dated silts and clays with thin, discontinuous sand and gravelseams. These materials are collectively grouped as "till"

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OIL RECEIVING

G and H INDUSTRIAL FILL COMPANY

/CITY OF/ PIPE LINE ANDT SEWER EASEMENT

APPROXIMATESITEBOUNDARY

600

300SCALE IN FEET

900

LEGEND__— _ APPROXIMATE LIMITS OF« I LANDFILL AREAS

Note: Location of all structures and sitefeatures are approximate.

FIGURE 1-1SITE LOCATIONG & H WORKPLAN

*3n/£^->Brmm^

—. »-» SITE PROPERTY BOUNOAH .

BURIED POND AND OTHER—,—• -»" SUSPECTED CONTAMINANT' V SOURCE AREAS

LEACHATESEEP AREAOF PHASE Ml LANDFILL

OIL SEEP AREA

0 300

SCALE IN FEfT

CONTOUR INTERVAL- 1 FOOT

FIGURE 1-2WASTE DISPOSAL ARE.G & H WORKPLAN

— z

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oo

u00IO

\ \"• \ 1

^ \ 11 1

h-tnoZ

V)

I r ' i i r o o o o 1 1 ' 1 ' 1

JlLMML

678

LEGEND

MONITORING WELL

WATER TABLE CONTOUR(DASHED WHERE INFERREDCONTOUR INTERVAL IS 2 FT)

••« GROUNDWATER ELEVATION

« UPPER SAND PIEZOMETER

GELOGIC CROSS SECTIONLOCATION

0 500

SCALE IN FEET

FIGURE 1-4WATER TABLE HYDRAULIC HEADCONTOURS (1/6/87)G & H LANDFILL WORKPLAN

for purposes of the RI, regardless of origin. The upper tillvaries in thickness from 30 to 50 feet under the northern por-tion of the site to 80 to 120 feet under the southeastern ror-tion. The till surface slopes gently to the southeast, exceptnear the Clinton River where it slopes steeply toward the river

The middle sand unit is a discontinuous, fine, dense sand thatappears to extend under most of the site area. In the north-west corner of the site, it is 10 feet thick and underlainbv a lower till to an unknown depth. The offsite verticalextent of the middle sand unit is unknown and appears to hecompletely missing south of the site near the Clinton River.In the southeast, the sandstone bedrock directly underliesthe upper till unit at a depth of about 150 feet.

HYDROGEOLOGY

The G&H site is underlain by two aquifers that are hydrau-lically separated by the upper till unit. Depth to ground-water is generally 25 feet or less within the site area.Groundwater flow in the upper aquifer (upper sand unit) isgenerally from the northeast toward the topographically lowelevations in the west and south (see Figure 1-4). The mid-dle sand unit and sandstone bedrock appear to act as a sin-gle lower hydrostratigraphic unit below the upper till, withgroundwater flow trending toward the south.

A groundwater mound in the upper sand unit may exist in theeastern portion of the original disposal area (based on waterlevels measured in one well). The mound may result fromgroundwater recharge from a locally closed surface waterdrainage basin.

SITE HISTORY

The G&H Landfill began operating in 1955 as a waste oil recov-ery facility. Oil Pond No. 2 received waste oil transportedby rail; Oil Pond No. 1 received both waste oil hauled bytruck and floating oil products pumped from Oil Pond No. 2.Michigan Department of Natural Resources files dating from1966 indicate that an estimated 650,000 gallons of oil permonth were accepted at the site, although the period overwhich the site accepted oil at that rate is unknown. Indus-trial personnel (General Oil Company) familiar with siteoperations estimated that one-half of the waste oil receivedwas eventually reclaimed.

In 1964, complaints by local residents of "sewage odors"prompted investigations by the Macomb County Health Board(MCHB) and the Michigan Water Resources Commission (MWRC).Although no new sewage discharge was found, "obnoxious odors"were noted from seeps south of the site where seepage wasobserved to eventually flow into the Clinton River.

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In 1965, an MWRC report documented that the site was receiv-ing solvents, paint residues, paint thinners and lacquers,paints, varnishes, and industrial process sludges. A subse-quent MWRC investigation concluded that the liquid disposaloperations were responsible for groundwater contamination.A Consent Order issued in May 1966 by the Macomb County Cir-cuit Court prohibited the disposal of paints, paint thinnersor lacquers, and varnishes at the site. Oil reclamationactivities were excluded from the Consent Order since adirect connection between the groundwater contaminationoccurrence and the oil facility had not been made.

In May 1966, the G&H site was used as the "Shelby TownshipDump," where "large volumes" of municipal refuse werereceived daily (MWRC Report, 1966) . MDNR files report thatliquid industrial wastes (excluding oil) and refuse weredisposed of simultaneously at the site during that time andthat fires also occurred onsite. The maximum estimatedextent of the co-disposal area is shown in Figure 1-2.

In March 1967, an MWRC report on additional field investiga-tions concluded that oil reclamation activities were a ground-water contaminant source. On the basis of that report, theMacomb County Circuit Court issued a Consent Order that bannedthe disposal of liquid industrial wastes, muds, and sludges.No subsequent disposal of any liquid industrial waste at theG&H landfill has been recorded since October 1967.

After the ban on liquid industrial waste disposal, the G&HLandfill facility continued to operate as a municipal refusedisposal site under a permit issued by the State of Michigan.By 1970, the original disposal area was covered with munici-pal refuse to depths of up to 20 feet. At that time, thePhase II Landfill was also nearly filled. The Phase IIILandfill was completed in 1973, and the G&H Landfill sitewas closed.

The site was placed on the National Priority List followinginspection and ranking by a U.S. EPA Field InvestigationTeam (FIT). The results of the two phases of Remedial Inves-tigation completed to date are documented in the Interim RIReport.

In an effort to contain the oil seepage, the EPA and MDNRimplemented emergency measures along the oil seepage area inthe southern portion of the site, including:

o A fence constructed around the perimeter of theoil seep area in 1982

o A soil berm constructed to contain oil seeps in1983

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o A steel curtain wall situated south of the seepsto inhibit migration of floating oil in 1986

o A single 2-hp jet aerator installed in the last,most terminal pond in the seep area in July 1987(the pond bottom was lined with a geotextile linertopped with 2 feet of gravel to prevent resuspen-sion of existing pond sediments)

CONTAMINANT SOURCES AND MIGRATION

The G&H Landfill site has a variety of organic contaminantsthat appear on the U.S. EPA Target Compound List (TCL),including volatile organic compounds (VOCs), base neutraland acid (BNA) extractables, and polychlorinated biphenyls(PCBs). The most commonly identified VOCs include benzene,ethylbenzene, xylene, and toluene compounds that are typi-cally the more water soluble components of gasoline andother petroleum products. The most frequently detected BNAextractable compounds are polycyclic aromatic hydrocarbons(PAHs), compounds often associated with petroleum-based pro-ducts and byproducts including fuel oils, waste oils, andcoal tar.

CONTAMINANT SOURCE AREAS

Contaminant sources within the G&H site are shown in Fig-ure 1-5 and listed below:

o Oil Pond No. 1 contains residual oil sludge andmaterials along the bottom and sidewalls of theremaining pond structure. There is oil-saturatedrefuse in and hydraulically downgradient of thepond. VOCs, BNAs, and PCBs have been detected insoil and refuse in and near the oil pond, withconcentrations tending to decrease with increasingdistance hydraulically downgradient to the south.

o Areas of Oil Pond No. 2 contain oil-saturatedrefuse with VOCs, BNAs, and PCBs.

o Drums are buried near the southeast end of OilPond No. 1, south of Oil Pond No. 1, and north ofthe railroad tracks. An area just north of thetracks, near the southeast corner of the site in asuspected drum disposal area, has the highestrecorded VOC levels among test pits at the site.

o The Solvent Co-Disposal Area contains oily refuse,but no TCL compounds have been detected in soil orrefuse there. However, TCL compounds may not befully represented in the sample analyses becauseof the possibility of chemical masking. Chemical

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masking often occurs in samples that contain highconcentrations of one or more solvents or in sam-ples in an oily matrix. The oil or solvent canmask the presence of other compounds. Therefore,undetected compounds may actually be present.

o PCBs have been detected in surface soils through-out the original disposal area in a generally ran-dom spatial distribution. PCBs have also beendetected in the surface soil of the Phase II land-fill.

o Methane has been detected by gas monitoring probesat concentrations above the lower explosive limitalong the northern border of the site. Methanelevels exceeding the limit were commonplace whendrilling through refuse in the original disposalarea.

CONTAMINANT MIGRATION

Known contaminant migration from source areas and releasesto the surrounding environment are illustrated in Figure 1-5and listed below:

o An immiscible oil plume in the eastern portion ofthe original disposal area is discharging in theform of an oil seep south of the railroad tracks.The source of the plume has been presumed to beassociated with Oil Pond No. 1. However, the fol-lowing details determined during earlier investi-gation phases suggest the plume may be caused byanother as yet unidentified oil source: 1) Theoil present between Oil Pond No. 1 and the oilseeps is discontinuous; 2) The oil seeps werefound at an elevation higher than that of OilPond 1, suggesting a hydraulic barrier to seepingat that location; 3) Flow velocities from Oil PondNo. 1 to the oil seep area do not adequatelyindicate Oil Pond No. 1 as the source of the seeps;4) The chemical "fingerprinting" of oil in the seeparea does not match with the oil in Oil Pond No. 2.It appears that the coarse sand/fine sand interfacein the upper aquifer acts as a pathway for the heavyoily materials, resulting in lateral migration ofthe oil phase through the coarse sand.

o The oil plume acts as a source of dissolved ground-water contaminants (e.g., VOCs). It appears thatsite-related contaminants have not penetrated thetill layer into the lower aquifer.

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o Surface water and sediments in the wetlands southof the site are contaminated by various compoundsassociated, with the discharging oil plume. Dis-solved VOCs have been detected in surface water,with concentrations decreasing with increased dis-tance downstream from the oil seep. Sedimentscontain PCBs and BNAs.

o Leachate seeps in the southwestern portion of thePhase III landfill contain VOCs and BNAs.

o Methane and possibly other gases are migratingnorthward away from the site.

o Residential wells located east of the site indica-ted low concentrations of VOCs; however, the ori-gin of the VOCs cannot be directly related to thesite on the basis of existing RI data.

PRELIMINARY RISK ASSESSMENT

A preliminary and qualitative analysis of potential risksfrom the G&H Landfill and associated areas is contained inChapter 8 of the Interim RI Report. This section summarizesthat information and discusses specific issues that shouldbe clarified, including associated data needs, before aquantitative endangerment assessment is performed in thePhase III RI.

Results from previous sampling of groundwater in residentialand industrial wells near the site indicate low concentra-tions of several chlorinated VOCs. The origin could not beattributed to the site because of the lack of groundwatermonitoring wells on the eastern side of the site that wouldintercept eastern flow offsite. In addition, several com-mercial industries in the area may be the sources of VOCcontamination. Those potential sources of contaminationwill be surveyed and wells will be installed along the east-ern end of the site to investigate potential contaminantmigration pathways from the site.

If available, information on residential well depths, con-struction details, and contaminant concentrations will becollected and addressed in the Phase III RI to prepare aquantitative and representative endangerment assessment ofthe ingestion of offsite residential or industrial wellwater.

The preliminary risk assessment also identified airbornetransport of contaminated particulates as a potential humanexposure pathway. To quantitatively assess risks from theinhalation of airborne, contaminant-laden particulates, dis-persion calculations will be made to estimate generation of

1-7

particulates from the site by wind and other kinds of ero-sion. Information on soil particle size and contaminantconcentrations and predominant wind directions and speedsshould be obtained.

The third general pathway identified was direct contact.This could arise if trespassing occurred and during anyonsite remedial activity, particularly activities that woulddisturb the soils. The most likely routes of exposure wouldbe dermal contact with and incidental ingestion of soil. Toquantitatively assess those routes, additional surface soilcontaminant information will be collected.

Consumption of fish and small game containing contaminantsis another exposure pathway that will be quantitativelyevaluated as part of the endangerment assessment using dataalre; :v generated from studies performed by the MDNR andU.S. "A. Estimates relating to the extent of the humanpopu -ion that could be exposed will be obtained from localfish \r.d game agencies.

Finally, established procedures for quantitatively address-ing risks to either the aquatic or terrestrial populationswill be limited to comparing surface water contaminant con-centrations to federal and state ambient water quality cri-teria for the protection of fresh water aquatic life. Tosupplement the evaluation of risks to the environment, asite walkover noting particular ecological features of thesite is planned. Also any available state or local informa-tion on sensitive populations will be gathered.

GLT661/35

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Section 2PROJECT PLANNING AND COMMUNITY RELATIONS

TASK PP—PLANNING ACTIVITIES

^ask PP includes developing the work plan; obtaining appro-vals for the work plan, budget, and schedule; project man-agement and agency coordination; and preparing the QualityAssurance Project Plan (QAPP), Site Safety Plan (SSP), andField Sampling Plan (FSP) for the proposed Phase III RIfield efforts. A quality control effort is also planned forCH2M HILL review of deliverables.

SUBTASK PP.PM—PROJECT MANAGEMENT

Subtask PP.PM consists of the day-to-day management of Task PPIt includes coordinating the team effort, scheduling and bud-geting, staffing, and agency communication through the sub-tasks described under Task PP. The cost estimate includespreparing monthly reports to keep the RPM informed of thetechnical, financial, and schedule status of the project.

SUBTASK PP.QC—QUALITY CONTROL

Subtask PP.QC provides for the formal internal review of alldeliverables in Task PP, draft or final, before they are sub-mitted to the agency. The work plan (including budget andschedule), QAPP, SSP, and FSP will each be reviewed at thedraft and final stages of production.

SUBTASK PP.WP—RI/FS WORK PLAN

Subtask PP.WP includes preparing the work plan, budgets, andschedules for implementing the proposed Phase III RI and FStasks listed Section 3. One draft version of that work planhas been budgeted. The work consists of preparing one draftwork plan for agency review, addressing and incorporatingagency review comments, and submitting a final work plan.It is assumed that the second version of the work plan willbe approved as final. Five copies of the draft and finalwork plans will be submitted to the EPA, Region V.

SUBTASK PP.QS--SITE PLANNING

Subtask PP.QS includes preparing a QAPP, SSP, and FSP forthe proposed fieldwork. The QAPP will be prepared and sub-mitted for agency review. Analytical testing will be per-formed through the Contract Laboratory Program (CLP). Anonsite field screening laboratory will be used for fieldscreening of samples. Two agency drafts will be submittedfor review and a final QAPP submitted for approval. Three

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copies of each draft and the final QAPP will be submitted tothe RPM and the MDNR.

An SSP for the proposed fieldwork will be developed based onthe previous SSP to specify field monitoring to be performedand protective gear to be used. A final copy will be pro-vided to the agency for information purposes only.

The FSP will document proposed sampling locations, procedures,and equipment for sampling and testing.

The cost estimate for this subtask assumes that the draftQAPP, dated April 6, 1988, can be revised. The estimatealso assumes that the first revised draft of the QAPP willbe approved as the final.

SUBTASK PP.AP—SCOPING OF RESPONSE ACTIONS

The existing data base will be evaluated to determine thecompleteness of site data for:

o Estimating the nature and extent of contaminationbased on information presented in the Interim RIReport

o Supporting the detailed analysis of alternativesin the FS

These goals will be achieved by identifying operable unitsand developing and screening preliminary remedial alterna-tives for the site. To the extent possible, the areal andvolumetric extent of site operable units and the degree ofcontamination will be defined. Remedial action goals foroperable units will be developed on the basis of risks posedto public health and the environment, as well as on statutoryrequirements (i.e., preference for permanence and attainmentof ARARs).

Potential treatment technologies and associated containmentor disposal requirements will be identified for individualoperable units. Technologies will be screened for suitabil-ity as part of the remedial alternatives. Technologies orcontainment and disposal combinations passing initial screen-ing will be assembled into preliminary remedial alternatives.

The results of this assessment will be used by the U.S. EPAto identify additional data needed to select a well-substan-tiated remedy. They will also be used to refine fieldinvestigation activities.

The cost estimate for this subtask includes preparing a draftpreliminary alternative array memorandum for review by the

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U.S. EPA and MDNR and a meeting with both agencies to discussthe memorandum.

TASK CR—COMMUNITY RELATIONS ACTIVITIES

SUBTASK CR.CP—COMMUNITY RELATIONS PLANNING

A community relations plan will be prepared addressing activ-ities the U.S. EPA will conduct with residents and governmentofficials involved with the G&H Landfill site. The plan willcontain the following sections:

o Site descriptiono History of the siteo Community issueso Objectives of the Community Relations Plano Community relations activitieso Timing of community relations activities through

ROD

Information presented in the plan will be developed from pre-vious work conducted at the site and interviews conducted withfederal, state, and local officials and residents as appro-priate.

SUBTASK CR.CR—COMMUNITY RELATIONS IMPLEMENTATION

The community relations implementation strategy will consistof several tasks concluding with the ROD. The specific taskswill include: 1) project updates, 2) RI summary fact sheet,3) FS summary fact sheet, 4) ROD fact sheet, and 5) publicmeeting support.

Public meeting support will include public notices, meetinggraphics and displays, and court recording. The project com-munity relations staff will assist the presentation team withmeeting strategy, scripts, and rehearsals. Project updateswill provide information regarding project status. One isplanned for late fall of 1988 at the beginning of the thirdphase of field investigation, and another is planned forlate fall 1989, approximately 4 months before the deliveryof the RI summary. The summary fact sheets for both the RIand FS will be 4- to 8-page typeset booklets that summarizethe findings of both studies. The final fact sheet will beprepared in connection with the ROD to explain the remedialalternative selected.

SUBTASK CR.CS—COMMUNITY RELATIONS TECHNICAL SUPPORT

The technical support task will include provisions for thetime and effort expended by CH2M HILL technical staff on thecommunity relations program. This includes preparation,rehearsal, and attendance of public meetings by the Site

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Manager and other project technical staff members as well asassistance in preparing fact sheets. The cost estimateassumes two people will attend two public meetings.

GLT661/36

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Section 3PHASE III RI AND FS WORK PLAN

This RI/FS work plan presents the approach that will be takento collect the data identified in Section 1. These data willbe used to perform a quantitative risk assessment and completethe feasibility study.

PHASE III RI DATA QUALITY OBJECTIVES

The first two phases of RI work confirmed the existence ofcontaminant sources, identified the major contaminants of con-cern, more clearly defined the site geology and hydrogeology,and identified the major pathways of contaminant migration.The Interim RI Report identified areas where additional infor-mation is needed. The goals of the Phase III RI are to col-lect information for:

o Identifying and characterizing areas in the land-fill (quantity and quality) so that treatment tech-nologies for the landfill wastes can be determined

o Collecting data to support and complete a quanti-tative risk assessment of the site

o Estimating the size and characteristics of contam-inant source areas to evaluate present and poten-tial future releases and for selecting and evalu-ating remedial alternatives that will contain,remove, treat, or destroy contaminant sources

o Improving understanding of site hydrogeology toevaluate potential contaminant pathways to selectremedial alternatives to control, contain, orremove groundwater contaminants

To meet these objectives, tasks were developed for thePhase III RI based on the data needs identified in theInterim RI Report. The following tasks were identified forthe Phase III RI:

o Estimate the areal extent of PCB contamination insurface soil covering the landfill and evaluatethe physical properties of the PCB-contaminatedsoil for possible transport by wind

o Explore possible subsurface landfill gas migrationto the east from the site and analyze gas for VOCsthat may present a health hazard to residents liv-ing near the site

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o Analyze ambient air on and near the site for methaneand VOCs escaping through the landfill cover thatmay present a health hazard to site visitors andnearby residents

o Estimate the extent and volume of contaminant sourceareas within the original disposal area

o Explore possible contaminant migration to the Clin-ton River from leachate seeps from the Phase IIIlandfill area

o Explore the presence and extent of the groundwatermound in the Original Disposal Area

o Explore the lateral extent of sediment contamina-tion in ditches along Ryan Road south of the site

o Determine the vertical and lateral extent of theoil plume along the railroad right-of-way to thesoutheast of the original disposal area

o Explore the water and sewer right-of-way as a poten-tial contaminant migration pathway along the pipe-lines

o Explore the potential groundwater contaminant path-way from the original disposal area to the east ofthe site in the industrial and residential areaalong Ryan Road

o Explore possible contaminant migration in ground-water through the Phase II landfill area

o Determine the water table elevation in the Phase IIand III landfill areas

o Determine the lateral and vertical extent of con-tamination in groundwater south of the site

o Analyze groundwater, surface water, and leachatefor organic and inorganic constituents and conven-tional pollutants to support a quantitative riskassessment and also for treatment oarameters tosupport the FS

o Collect additional hydraulic conductivity data inthe upper sand aquifer and the till unit

o Explore the coarse sand/fine sand interface in theupper aquifer as a potential pathway of oil andgroundwater contaminant migration throughout thesite area

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TASK FI—PHASE III RI FIELD ACTIVITIES

The following subtasks were developed to present methods toobtain data that meet the stated Phase III RI objectives.Secondary objectives are included in the individual subtaskdescriptions.

SUBTASK FI.PM—PROJECT MANAGEMENT

Project management activities will be handled throughCH2M HILL's office in Milwaukee, Wisconsin. Contact will bemaintained with the U.S. EPA Remedial Project Manaaer (RPM)during all phases of the project.

Project management during field activities will include pre-paring monthly reports to keep the RPM informed of the tech-nical, financial, and schedule status of the project. Otherresponsibilities include monitoring budgets and schedules;selecting, coordinating, and scheduling staff and subcon-tractors for task assignments; and maintaining project qual-ity control and assurance programs.

The cost estimate for this subtask assumes that Phase III RIproject management activities will occur over a 1-year period,The cost estimate also includes monthly review meetings atthe EPA's Region V office in Chicago.

SUBTASK FI.QC—QUALITY CONTROL

Periodic review of planning activities, project deliverables,and site inspection during the field activities will be con-ducted by a review team throughout the RI. The team willconsist of three or four professionals from appropriate dis-ciplines with experience related to the problems and inves-tigations at the site. They will review deliverables (tech-nical memorandums) to the U.S. EPA and act as projectadvisors throughout the project.

SUBTASK FI.FK—FIELDWORK SUPPORT

Subtask FI.FK includes activities that must be completedbefore fieldwork can begin:

o Procuring subcontractors for test pit excavatingand drilling services

o Securing and shipping field equipment and healthand safety equipment/materials to the site

o Setting up an onsite field office trailer and sup-port area

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CH2M HILL will rent a mobile office trailer for use as anonsite office and for storing eauipment and supplies. Theoffice will be equipped with heat, telephone, and electric-ity. The cost estimate includes the effort to procure thetrailer and award the equipment contract. Total rental andutility charges are estimated for a 4-month period, includ-ing mobilization and demobilization. These estimated costsare included as supplies under the other direct cost (ODC)category.

The cost estimate includes construction of a 30-foot-sauarefenced storage area with a reinforced concrete pad forRl-derived waste. It also includes a 100-foot by 200-footfenced compound to protect the office trailer and fieldequipment from vandalism. The cost estimate assumes thatboth fenced areas can be constructed by a local contractor.

SUBTASK FI.FM—SURVEYING AND MAPPING

Sampling and exploration points will be located by survey.The topographic base map prepared by Abrahms Aerial SurveyCorporation for CH2M HILL in 1983 will be used for locatingpertinent features. Elevations (USCS datum) will be obtainedfor monitoring well and leachate well casings and for groundsurface at soil borings and test pit excavations. In addi-tion, an elevation marking will be placed on the ClintonRiver bridge pier of Ryan Road.

Horizontal locations will be obtained from known locationson the existing site topographic base map. Vertical eleva-tions will have an accuracy of ±0.1 foot for ground surfaceand ±0.01 foot for top of well casing groundwater measuringpoints.

The cost estimate for this subtask assumes that a two-personcrew will complete the surveying work in 10 days. The sur-vey will include all newly installed wells, staff gauges,soil borings, test pits, and other selected sampling loca-tions .

SUBTASK FI.FF—RI-DERIVED WASTE DISPOSAL

It is assumed that Rl-derived wastes can be stored in theonsite storage area. The cost estimate for Subtask FI.FMincludes removal of the current stored waste, which consistsof 20 to 30 drums and other miscellaneous debris and an addi-tional 20 drums assumed to be generated during the Phase IIIactivities. The cost estimate is based on a subcontract toremove 50 drums for RCRA disposal.

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SUBTASK FI.FC—FIELD SCREENING LABORATORY

Subtask FI.FC includes mobilization, operation, and demobili-zation of the field screening laboratory (FSL) at the G&HLandfill site. The FSL will be used for screening waste andsoil samples for target compounds using a portable gas chromato-graph unit. All analytical data will be tabulated and orga-nized for agency review in the field. The screening datawill be used to direct other field operations, includingdrilling and sampling. Samples will be selected for CLPanalysis based on screening results.

The cost estimate for this subtask includes identifying tar-get compounds, preparing the Standard Operating Procedures(SOP) document, and operating the field laboratory onsitefor a 2-month period. Two chemists will operate the labo-ratory.

SUBTASK FI.SM—SAMPLE MANAGEMENT

The objective of Subtask FI.SM is to track and manage informa-tion received from CLP analyses of samples. Laboratory spacewill be scheduled, analytical data will be tracked, and theOC comments prepared bv U.S. EPA Region V Central RegionalLaboratory will be reviewed for completeness.

The cost estimate includes preparing sample paperwork beforefield efforts and tracking sample documentation through theCLP and CSL. The labor effort is based on the number of sam-ples that will be sent to the CLP.

SUBTASK FI.FS—SOIL BORING AND SAMPLING

The work performed under Subtask FI.FS includes soil boringsand the collection of both surface and subsurface soil sam-ples for chemical and physical analyses. The cost estimateassumes that the drilling subcontract cost is included withSubtask FI.FI—Well Installation and that the work will beperformed by the same subcontractor. It also assumes that atwo-person crew (one to log the hole and one for health andsafety monitoring) will be required to observe the soil bor-ing and subsurface soil sampling work under Level C healthand safety protection for 16 10-hour days.

The surface soil sampling will be completed during the firstround of groundwater sampling. The cost estimate assumesthat surface soil sampling can be completed in 2 days duringthe first round of groundwater sampling.

Subtask FI.FS.A—Soil Boring

Approximately 65 boreholes will be drilled at 40 locations(Figure 3-1) in and surrounding the G&H Landfill site. Moni-

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toring well and soil boring details are outlined in Table 3-1.Monitoring wells (including 3 leachate collection wells) willbe installed in 44 of the boreholes, 9 boreholes will containgas probes, and 12 boreholes will be abandoned after back-filling with grout. Auger cuttings will be screened usingan OVA or HNu. Cuttings considered to be contaminated basedon the screening will be drummed in U.S. DOT 55-gallon drumsand stored onsite. The borings located in the original land-fill area and along the railroad right-of-way are assumed tobe done under Level C protection. All other borings may bedrilled under Level D protection.

All borings will be monitored using an HNu or OVA to measureorganic vapors and an HCN monitor for cyanide. If monitor-ing indicates detectable limits of cyanide, colorimetrictubes will be used to help quantify cyanide levels. In addi-tion, borings through the waste will be monitored for con-centrations of explosive gases exceeding the lower explosivelimit. In the event -hat levels exceed the limit, a head ofclean water will be maintained in the auger. Approximately100 feet of level B boring, 645 feet of Level C boring, and650 feet of Level D boring are estimated.

Whenever possible, drilling will be performed using hollow-stem augers. Borings through the refuse will be double-casedto prevent contamination of lower aquifers. Since drillingrig access to proposed leachate well locations west and south-west of the Phase III landfill is not possible, provisionsfor portable hand augers are planned. Access to other loca-tions will probably require some clearing or procurement ofeasements. The U.S. EPA will be responsible for obtainingeasements at all offsite locations. A pre-bid site meetingwill be held between the CH2M HILL Site Manager and prospec-tive drilling subcontractors to discuss accessibility.

Subtask FI.FS.B--Subsurface Soil Sampling

At each boring location, the deepest borehole will be sam-pled through its entire length. Split-spoon samples will beobtained continuously from the ground surface to the coarsesand/fine sand interface (10 to 15 feet below ground) inborings outside the refuse areas. Thereafter, split-spoonsamples will be obtained at 5-foot intervals until the tar-get depth is reached. For borings through the refuse, noattempt will be made to obtain split-spoon samples withinthe landfill waste until the borehole has advanced beyondthe depth of waste burial. Split-spoon samples will be col-lected for CLP analysis from the soil under the refuse at5-foot intervals to the target depth. Samples of waste andrefuse will be obtained from auger cuttings based on appear-ance and field screening results.

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The boreholes will be logged by a qualified hydrogeologist,geologist, or geotechnical engineer. The depth of the coarsesand/fine sand interface and the depth of buried waste is ofparticular interest. A total of 24 soil samples will beselected for grain-size analysis. This information will beused to estimate hydraulic conductivities and correlate withthe results of in situ hydraulic conductivity tests. Thesamples will be considered low contamination unless gaschromatograph screening indicates otherwise. Nine addi-tional representative soil samples will he collected, threeper each soil unit (i.e., upper sand, till, and middle sandunit as defined in Section 1) for total organic carbon (TOC)content measurements. This information will be used to esti-mate the ability of the soil to adsorb organic compounds andto approximate the retardation effect on compounds migratingin groundwater.

All soil and waste samples will be screened using a portablegas chromatograph before submittal to a CLP laboratory.Samples will be selected for CLP chemical analysis based onthe screening levels and visual observations. Samples thatappear to be source materials (e.g. oil- or grease-covered)will be given priority. A total of 43 samples selected fromthe soil borings are expected to be shipped to the CLP forthe following analyses:

o Twenty-five samples: RAS--organic parameters(VOC, BNA, pesticide/PCB); SAS—oil and grease

o Eighteen samples: RAS—organic parameters (VOC,BNA, pesticide/PCB); SAS—oil and grease, furan/dioxin

o Eight samples: SAS—BTU, percent ash, percentvolatile solids, percent fixed carbon, and percentmoisture

Subtask FI.FS.C—Surface Soil Sampling

Twelve surface soil samples will be collected for chemicaland physical analyses (Figure 3-2). Sample points will belocated on the Phase I landfill site perimeter along RyanRoad and 23 Mile Road and adjacent to the seepage area alongthe Conrail right-of-way. Four surface soil samples willalso be collected from the auto salvage area. Five addi-tional soil samples will be collected offsite to providebackground data, and five more onsite samples from the orig-inal landfill are for PCS and grain-size analyses. Thelocations for background sampling and additional samplesfrom the original landfill will be selected in the field.The 16 samples collected from the site perimeter and autosalvage yard will be submitted to the CLP for RAS pesti-cides/PCBs and metals/cyanides and SAS furan/dioxin. These

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samples will provide supplemental data for estimating thelateral extent of PCB contamination and evidence of the pos-sible existence of dioxin at the site because of past fires.

Samples from locations on the landfill cover will be submit-ted to a geotechnical laboratory for grain-size analysis andAtterberg limits. Also, the depth of soil cover will be deter-mined at each sampling location. This information will beuseful for estimating the infiltration capacity of the exist-ing soil cover and will provide an indication of the extentto which surface particulates can become airborne.

SUBTASK FI.FI—MONITORING WELL INSTALLATION

There is insufficient information on aquifer hydraulic char-acteristics and better estimates of the vertical and arealextent of the contaminant plume are needed. To provide thisinformation, it will be necessary to install, test, and sam-ple additional monitoring wells during the RI field program.

Forty-six additional monitoring wells will be installed at38 locations (Figure 3-1) at depths from 10 to 50 feet.Table 3-1 provides an explanation for each well location.Some proposed locations may change, based on the informationgained during the first round of groundwater sampling (seeSubtask FI.FQ).

During the drilling operations, flexibility will be main-tained in determining screen placement. If zones of con-tamination are observed outside the predetermined screenedinterval by either visual observation or gas chromatographscreening of soil samples, the screened interval may be mod-ified or additional wells installed. An additional five mon-itoring wells have been budgeted for this contingency. Thethree primary zones of concern are the water table level,the interface of the upper sand unit and till unit, and thetill unit.

As previously stated in Subtask FI.FS.A, drilling will beperformed using hollow-stem augers whenever possible. Pro-visions will be made for other equipment, such as hand-driven well points or portable hand augers when drilling rigaccess is not possible. Under no circumstances will drill-ing methods that require the addition of bentonite mud orother drilling additives (other than water) to the boreholebe permitted.

Upon achieving the target depth, the monitoring well will beinstalled through the center of the hollow-stem auger. Allmonitoring wells will be constructed of 2-inch diameterthreaded flush-joint stainless steel having a 5-foot lengthof 0.007 or 0.0010 slot stainless-steel wound-wire screenfor wells installed in the till or a 10-foot screen length

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for leachate head wells. All joints will be wound withTeflon thread tape to provide a watertight seal.

A filter pack consisting of medium-grained sand will beplaced at least 2 feet above the top of the screen for wellsscreened in the till unit and wells in the upper sand unitwhere cave-in does not occur. If cave-in around the wellscreen occurs, the formation sand will be allowed to act asthe filter pack material. A 2-foot minimum bentonite slurryor bentonite pellet seal will be placed into the annulususing the tremie method above the top of the filter pack.Seal placement will be concurrent with auger removal. Therest of the borehole will be filled with a bentonite/cementgrout to prevent cracking and shrinkage. The well will becompleted with a locking 4-inch-diameter protective steelcasing anchored in a sloping cement collar.

Each monitoring well will be surveyed and developed uponcompletion. Surveying and mapping well locations areaddressed in Subtask FI.FM. The wells will be developedusing the double tube air lift, bailing, pumping, or othermethods. Development will continue until the water iseither free of sediment or when a constant level of tur-bidity is achieved and until the pH, temperature, and spe-cific conductance have stabilized. These data will be tab-ulated and reported. If water was added to the boreholeduring well installation, a minimum of three times the wateradded will be purged during well development. Purged waterwill be field screened using an HNu or OVA and dischargeddirectly to the ground if no readings above background arenoted. Purged water indicating HNu or OVA readings abovebackground will be contained in 55-gallon drums and trans-ported to the existing onsite drum storage area for laterdisposal by the EPA.

The cost estimate for this subtask assumes that drilling andwell installation will require a two-person crew for onedrilling rig under Level C health and safety protection for24 days and one person with another drilling rig under Level Dhealth and safety protection for 12 days. A subcontract willbe required for the drilling and well installation services.The drilling subcontractor will be paid on a unit price basisfor drilling and well installation costs. The subcontractcost estimate for this subtask also includes the subcontractdrilling costs for Subtasks FI.FS—Soil Boring and Samplingand FI.FG—Landfill Gas Emissions.

The time required to complete the drilling effort may varygreatly because of weather conditions and constraints asso-ciated with site safety and the subsurface conditions encoun-tered. Costs for observation of subcontracted drilling ser-vices will depend on production rates of the driller andcould vary greatly from the estimates.

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SUBTASK FI.FQ—GROUNDWATER SAMPLING AND HYDRAULIC TESTING

Subtask FI.FQ.A--Groundwater Sampling, Round One

Sixty-five existing monitoring wells will be sampled to sup-plement previous sampling results, including background lev-els. The information from the sample analvses will be eval-uated for indications of trends in contaminant movement.Samples will be submitted to the CLP for analysis of routineorganic and inorganic packages (RAS). The analyses will benecessary for evaluating the feasibility of source contain-ment, destruction, and groundwater extraction and treatmentalternatives. Field parameters of pH, temperature, and spe-cific conductance will be measured at the time of samplecollection. Details on sampling methods, collection ofblanks and duplicates, preservation of samples, and samplehandling and shipping will be presented in the QAPP SamplingPlan.

Concurrent with the first round of groundwater sampling andbefore the start of drilling activities, the existing wellnetwork will be evaluated. Water level and total well depthwill be measured in wells that can be opened. An inventoryof the wells needing repair or replacement will be compiledand evaluated. It may not be possible to obtain water sam-ples from some wells for these reasons:

o A well may not produce sand-free water afterrepeated attempts to redevelop it by surging andpurging, indicating a broken well screen.

o A well may not produce a sufficient quantity ofwater.

o A well may have a seized cap or plugged riser.

Should one of these or some other event prevent collectionof a groundwater sample, the occurrence will be documentedin a field logbook. Actual attempts to remedy the problemwill be described and documented in the field notebook.Following the completed sampling event, problems with theexisting well network will be studied. Actions for correct-ing inoperable wells will be proposed and the plan forinstalling new monitoring wells may be altered.

The cost estimate for the first phase of groundwater sam-pling assumes that two sampling crews will work for 12 daysin the field. The effort will also require a site safetyofficer and a paperwork coordinator. The cost estimates forthe existing well inventory are included with the costsrelated to the preliminary site visit.

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Subtask FI.FQ.B—Groundwater Sampling, Round Two

Approximately one-half of the 65 existing monitoring wellswill be sampled to supplement previous analytical results,investigate seasonal variations, and further examine trendsin contaminant migration. The 44 new monitoring wells(excluding the 3 leachate collection wells) will also besampled. Information obtained from the new monitoring wellswill be used to study the possible groundwater mound and itseffect on groundwater flow, to determine the vertical andlateral extent of the voc contamination south, east, andwest of the oil seep, and to investigate the migration ofcontaminants along utility lines. Samples will he submittedto the CLP for the same analyses outlined above for RoundOne as well as for SAS parameters of BOD? COD, TOC, TDS,chloride, total P, NH3/ N02~, NO ~, S04~ , and oil andgrease. Field parameters will also be the same as underSubtask FI.FQ.A.

The cost estimate for the second round of groundwater samplingassumes that two sampling crews will work for 16 days in thefield. The effort will also require a site safety officerand a paperwork coordinator.

Subtask FI.FQ.C—Groundwater Sampling, Round Three

Approximately 70 percent of the 44 newly installed monitor-ing wells and at least half of the previously sampled exist-ing wells will be sampled to confirm data collected from thenew wells and supplement previous data collected during RoundsOne and Two of the groundwater sampling event. All sampleswill be submitted to the CLP for routine organic and inorganicanalyses (RAS) , and 30 percent of the samples will be submit-ted for the SAS parameters listed in the second round of samp-ling. The same field parameters in Rounds One and Two willbe measured in Round Three.

The cost estimate for the third round of groundwater samplingassumes that two sampling crews will work for 9 days in thefield. The effort will also require a site safety officerand a paperwork coordinator.

Subtask FI.FQ.D—Water Level Measurementand In Situ Hydraulic Conductivity Testing

Concurrent groundwater level measurements will be conductedin all new and existing monitoring wells to develop hydrau-lic contours. River stage measurements will be made toestablish the relationship between the groundwater level andthe river stage.

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In situ hydraulic conductivity tests (slug tests) will beconducted at a minimum of 20 locations, using pressuretransducers and an electronic data logger, to acquire dataon the hydraulic characteristics of the coarse sand, thefine sand, and the silty clay (till). Grain-size distribu-tions of the soil in the screened zone at slug test loca-tions will be evaluated and compared to the estimated per-meabilities .

The cost estimates for hydraulic conductivity testing assumesa 2-person crew can complete the work in a 2-day effort.Travel expenses are included with groundwater sampling.

Subtask FI.FQ.E—Residential andIndustrial Water Well Survey

A survey of the industries along Ryan Road will be conductedto explore other possible sources of VOCs detected in resi-dential wells located east of the site. Available informa-tion on residential, commercial, and industrial well depthsand construction details will also be collected. Table 3-2shows a sample of the questionnaire that will be used duringthe survey. The survey, along with data from additionalmonitoring wells located along the eastern site boundary,will help to investigate the potential groundwater contami-nant pathway from the site.

The cost estimate for this subtask assumes that 5 industrialwells and 11 residential wells located east of the site willbe sampled for RAS organic parameters (VOC, BNA, pesticide/PCB). The cost estimate also assumes that a 2-person teamcan complete the well inventory survey in a 3-day effort.

Subtask FI.FQ.F—Groundwater Level Measurements, Long-Term

Groundwater level measurements will be conducted bimonthlyfor approximately 2 years. These measurements will be usedto document the vertical and horizontal groundwater flowdirections. Water levels will be measured using an electricwater level indicator. Bimonthly surface water level mea-surements are also planned with the groundwater measurements.Staff gauges for surface water level measurements will beinstalled in approximately the same locations as shown inFigure 3-4 under Subtask FI.FW. Staff gauges will beinstalled in four locations of the Clinton-Kalamazoo Canaland in one pond in the seepage area. Three river stagegauges will also be installed in the Clinton River. Thelocations for the river stage gauges will be selected in thefield based on the initial site visit.

The cost estimate for the water level measurement taskassumes two field crew personnel will work 3 days recordinginformation for each round of measurements.

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Table 3-2GROUNDWATER USE SURVEY

WELL INFORMATION CHECKLIST

Date: Time:Name of Contact:Address:Telenhone:Rent or Own: ... How Long:Name of Property Owner:

Do You Have a Well on Your Property?: Yes NoDiameter: Screened:Date Drilled:Driller's Name and Address:

Use:

Garden:YesYes

NoNo

Bathing:Drinking:

YesYes

NoNo

Boring Log Available: Yes NoDepth of Well:Pump in Well: Yes NoDepth of Pump:Type of Pump:Operational: Yes NoSurface Casing and Depth:

Well WaterCooking:Lawn andOther: _

Type of Plumbing:Copper/Steel/Galvanized Stee1/PVC/BlackIron/Other

Pressure Tank: Galvanized Steel or Newer ModelAny Present Problems/Complaints?:

Taste: Yes No Odor: Yes NoColor: Yes No Other:

Any Water Sampling and Analyses?: Yes NoSampled By: Date:Analyzed For:Analyzed By:

Is Well Treated in Any Manner?: Yes NoType of Treatment:Frequency:

Do You Have a Water Softener?: Yes No

General Comments:

Name of Surveyor: Project Name:Signature: Project Number:

GLT661/26

SUBTASK FI.FP—GEOPHYSICAL INVESTIGATIONS

Surface geophysical surveys will be performed to locate land-fill areas that may contain buried hazardous waste drums andto aid in selecting test pit sites. Both a magnetometer sur-vey (total field and vertical gradient) and an electromagneticsurvey are proposed to meet these objectives. While the sur-veys cannot specifically distinguish between drums and othermetal objects, they can delineate areas of buried metal masses.Subsequent investigations (such as test pits) will laterexplore the specific nature of the buried metal.

The proposed surveys will be performed on a grid system cover-ing the original landfill area and in selected portions ofthe Phase II and III landfills. The electromagnetic andgradiometer data will be evaluated in conjunction with testpit data, groundwater data, and historical aerial photographspreviously developed to help define the discrete areas ofsource materials requiring eventual remediation. The geo-physical surveys will be performed by personnel fromCH2M HILL. CH2M HILL will also provide all the necessaryequipment for this activity.

Magnetometer surveys were performed at the G&H site in 1983during the Phase I RI. The Phase I data reported the pres-ence of several laterally extensive anomalous areas on thesite suggesting the occurrence of a dense concentration ofmetal, possibly a filled trench. The previous survey alsoreported that a high level of background noise exists at thesite, probably attributed to the presence of metal scatteredacross the site. The high background noise may cause erro-neous readings, but such problems can be minimized by operat-ing the magnetometer with the sensor at least 8 feet abovethe ground.

The magnetometer survey will consist of total field measure-ments and vertical magnetic gradient measurements. Verticalgradient data are capable of higher resolution than the totalfield data and will minimize some of the noise problemsencountered in the Phase I RI geophysical investigations.The total field and gradient data are collected simultaneously,

The electromagnetic conductivity surveys will be run overthe sane grids as the magnetometer surveys. A Geonics EM31ground conductivity meter will be used. The instrumentresponds to the presence of buried metal but does not havethe sensitivity of a magnetometer. Thus, a metal object thesize of a drum may produce a slight response, but a drum-filled trench will produce a distinct response. Some areasof extremely high conductivity were found by electromagneticsurveys conducted at the G&H site by the U.S. EPA in 1984and may suggest buried drums. The combination of electro-

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magnetic and magnetometer methods should suggest locationsof areas potentially containing buried drums.

A grid will be established on the site to allow accurate andsystematic sampling and to cite the positions of anomaliesin the field. A north-south baseline will be establishedacross each of the three phases of the landfill and markedin 100-foot intervals. Lines of markers (pin flags, lathe,or stakes) will be laid out in an east-west direction fromeach of the flagged locations on the baseline. Markers willbe placed at 40-foot intervals along the east-west gridlines.

Data will be collected along north-south lines at 20-footintervals. Lines will be 40 feet apart. A tape or markedrope will be stretched between corresponding marked loca-tions on adjacent east-west flagged lines. The operatorwill walk along the tape, collecting data at the marked20-foot intervals. Magnetometer data (total field and ver-tical gradient) will be stored in digital memory in themagnetometer. Data will be transferred daily to floppy diskin a format compatible with IBM PCs.

A base station for the magnetometer will be established in aconvenient location that is not influenced by nearby magneticanomalies. Because the magnetic data of primary interest isthe vertical gradient (which does not experience diurnaldrift), a minimal number of base station readings will betaken. The field team will read the base station at thebeginning of the day, at midday, and at the end of the day.The anticipated total field anomalies will be much largerthan the probable diurnal drift. A drift correction will beapplied at the discretion of the interpreter.

The electromagnetic conductivity data will be collected atthe same stations as the magnetic data. Conductivity mea-surements will be collected with the instrument orientedinline and perpendicular to the line direction (or north-south and east-west). If the ground is homogeneous, theorthogonal measurements will be identical. If buried metalis present, the readings will differ. Negative conductivityreadingf and differing orthogonal readings will be used tomap buried metal. The data may be recorded manually or auto-matically using digital recording devices.

A crew of three will be needed for the work. One personwill pull the tape ahead and keep notes, and one person isrequired to operate each instrument. Both the EM31 andmagnetometer can be operated simultaneously within a fewfeet of each other without affecting the readings. Thenotebook will be used to record the ground features that may

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affect measurements. Notes will also record physical infor-mation, such as roads and ditches, useful in the preparationof a base map.

A CH2M HILL geophysicist will interpret the data and reportthe findings in a technical memorandum. Graphical represen-tation of the data will be prepared by CH2M HILL. Raw datawill be presented in graphic form as profile plots. Allplots will be at the same scale to allow comparison of data.All sets of data (electromagnetic and magnetometer) from oneline may be presented on the same graph, or more than oneline of similar data (e.g., vertical gradient) may be pre-sented on a single graph to minimize the number of graphs.Optionally, data tables of the raw data may be included.

Three contour maps—total magnetic field, vertical magneticgradient, and electromagnetic conductivity—will be generatedat the same scale as the base map and included in the tech-nical memorandum. Negative electromagnetic values may beassigned an arbitrary value (such as -10) for plotting pur-poses.

Approximately 61 acres will be covered by the surveys. Usinga 20- by 40-foot grid, 3,300 stations will be needed to coverthe site. Assuming 400 stations can be read per day, 8 to9 days will be needed for data collection. An additional dayis required to establish the grid.

SUBTASK FI.FT—SOURCE TESTING, TEST PITS

The principal objective of the source testing program is todefine discrete areas of source materials well enough to pro-pose remedial action alternatives for the eventual cleanupof the site sources. Subtask activities include site inves-tigations for other drum burial areas and additional solventdisposal pits in the southern and central portions of thelandfill to characterize the depth and areal extent of oilcontamination in Oil Pond No. 2. To achieve this goal, aminimum of 20 test pits (Figure 3-3) will be excavated inthe suspected contaminant source areas in a 2-week period.Final test pit locations will be determined subsequent todrilling and the geophysical survey. Additional test pitsmay be excavated in the area between Oil Pond No. 1 and theSolvent Pit Area and possibly in the Phase II Landfill, iftime permits within the budgeted 2-week period. Additionaltest pit locations will be selected based on discussionswith the MDNR.

Test pit depths will be limited by the stability of subsur-face materials and the maximum depth of the excavator.Excavators typically can reach depths of at least 20 feetbelowgrade, but actual test pit depths are expected to be

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less because of soil stability limitations. For cost esti-mating purposes, the maximum depth of test pits was estimatedto be 20 feet beiowgrade. Specific excavating equipment can-not be identified until an excavating contractor has beenselected, but will probably be a track-mounted backhoe.

Each test pit will be logged and photographed to documentthe subsurface conditions encountered. No attempt will bemade to enter the pits, and samples will be collected directlyfrom the backhoe bucket. Excavated soils will be placed ona sheet of heavy plastic to prevent contamination of surfacesoils.

If intact or crushed drums are encountered, the field excava-tion crew will leave them undisturbed. Drums will not beremoved from test pits. Drummed materials will not be testedunless drums are degraded and leaking, as evidenced by thevisual presence of liquids in the test pits around the drums.If a free-floating liquid layer is found, the pit will belined with a sorbent material and closed immediately aftersamples of the liquid are collected.

Following completion of sampling and test pit logging, eachtest pit will be backfilled to grade. If a strong contami-nant profile is observed in the test pit wall, the fieldexcavation crew will backfill the test pit to roughly thesame condition it was in before excavation. Disposal of anyremaining material will be determined from HNu screening.If the excess material shows evidence of organic contamina-tion or HNu readings above background, it will be drummedand removed to the secure storage area. Otherwise, theexcavated materials will be left at the test pit locationand covered with clean clay fill obtained from an offsiteborrow area.

The qualitative data obtained from the field screening willbe used in conjunction with visual and stratigraphic infor-mation derived from test pit logging to select soil samplesfor submittal to the CLP for analyses. The chemical infor-mation obtained from the CLP analyses will be compared tothe groundwater plume data to identify groundwater contami-nant source areas. The chemical information will also char-acterirt the type and concentration of contaminants in thesource areas. This soil information is necessary to charac-terize the potential for future contaminant releases to thegroundwater and to evaluate containment, treatment, anddestruction alternatives in the FS.

A maximum of 40 test pit samples will be submitted for CLProutine organic analyses. Samples will also be analyzed forfuran/dioxin incinerator parameters and oil and grease.Samples will be considered medium concentration. Sampling

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-• A'J-l rnj'/

AREA (SOLVENTS!-i;.J.".r

APPROXIMATE LIMITS OF LANDFILL AREAS

• PROPOSED TEST PIT LOCATIONS(SUBJECT TO FIELD DECISION!

d EXISTING TEST PIT LOCATIONS (PHASE II HI)

g PROPOSED BOREHOLES AND WELLINSTALLATIONS (WILL HELP DEFINEOIL PLUME!

f~~ ' 1 OIL PONDS AND SOLVENT' • — " DISPOSAL AREA

0 300

SCALE IN FEET

CONTOUR INTERVAL - 1 FOOT

FIGURE 3-3LOCATION OF TEST PITG 4 H WORKPLAN

methods and protocol will be discussed in detail in thesampling plan.

Some or all of the soil samples may be depth interval sam-ples. Samples will be selected by depth based on visualobservations (e.g., soil staining), the concentrations ortypes of VOCs detected during the screening process, andstratigraphic relationships. The sampling team leader willdecide in the field after consultation with the projecthydrogeologist and chemist which sample will make up thedepth interval.

The cost estimate for this subtask assumes the test pit exca-vating effort will last 2 weeks in the field. A three-personfield team will be required to support the logging and samplingeffort. Level B health and safety protection will be requiredfor all personnel near the excavations. A subcontractor willbe paid on a time and materials basis to supply the excavatorand an operator trained in health and safety procedures.

SUBTASK FI.FW—SURFACE WATER, SEDIMENT, LEACHATE

Subtask FI.FW.A—Flood Plain Study

Hydraulic information for the Clinton River will be obtainedfrom the Macomb County Flood Insurance Study. This informa-tion will be used to determine if any portion of the site orany contaminant release points are in the river flood plainfor several different flood frequencies. This informationmay also be useful in determining locations for proposedcontainment structures in the feasibility study. Staffgauges will be installed on the Clinton River upstream anddownstream of the project site as part of the long-termgroundwater measurement activity (Subtask FI.FQ.F). Theywill be checked during other field activities for additionalriver stage information.

Subtask FI.FW.B—Sediment Sampling

The main objective of this task is to assess the lateralextent of the contaminant migration following the drainageditch along Ryan Road. Additional samples will be collectedin and south of the oil seep area toward the Clinton-KalamazooCanal to develop remedial alternatives in the area. At eachsampling location, one sediment sample will be collected forCLP analysis. The depth of sediments will be measured ifwater is not present. This information will be used toevaluate the need for removal and disposal of sediments andas an aid to estimate volumes.

Sediment sampling locations are shown in Figure 3-4. Sam-ples will be analyzed by the CLP for RAS organic constitu-ents and will be considered low concentration.

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Subtask FI.FW.C—Leachate and Surface Water Sampling

Six leachate samples will be collected during the two conse-cutive sampling days from the three leachate collection wellswest of the Phase III Landfill Area (Figure 3-1). They willbe collected during the second round of groundwater sampling,and the results of the chemical analyses of groundwater andleachate samples will be compared. This information mayhelp determine if a relationship exists between the contami-nant source and release point.

Six surface water samples will be collected at the threelocations shown on Figure 3-4. A shallow or near-surfacewater sample will be collected to analyze for the low den-sity constituents associated with oil in the seep areas. Awater sample will be collected near the bottom of the pondat each of the three locations to analyze for constituentsassociated with groundwater contamination in the oil seeparea. The surface water data will also be used to assessthe effectiveness of emergency response work completed in1985 and 1986.

Sampling locations are shown in Figure 3-4. Specific samplecollection methods and protocols will be detailed in thesampling plan. Samples will be submitted to the CLP for thesame parameter set performed on the groundwater samples(Subtask FI.FQ.A) and will be considered medium level con-centration.

The cost estimate for this subtask assumes that the fieldworkcan be completed with other field activities and that travelexpenses are included with other field tasks. The floodplain study, sediment sampling, and leachate sampling areassumed to require one person for 1 week in the field.

SUBTASK FI.FG—LANDFILL GAS EMISSIONS

Six offsite gas probes will be installed along the easternborder of the site near the industrial and residential area,and three offsite gas probes will be installed along thenorthern border near 23 Mile Road. The objective of thistask is to investigate the concentrations and migration pat-terns o£ the landfill gas and determine whether the soil gasis migrating to the surrounding offsite soils.

The probes will be placed to a depth of 5 feet. They willbe constructed of 1-inch PVC perforated only in the bottom3 feet. Perforations will be 1/4-inch holes spaced 2 inchesapart. The annular space between the probe and the edge ofthe borehole will be backfilled with crushed rock or peagravel. The top 2 feet of annular space will be sealed withbentonite/cement grout. Borings for the gas probes will bedrilled using hollow-stem augers. Gas probe installation

3-18

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SUSPECTED CO DISPOSALAREA (SOLVENTS)

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1983 SURFACE WATER LOCATION

1996 SURFACE WATER LOCATION

19B3 SEDIMENT LOCATION

1986 SEDIMENT LOCATION

1983 LEACHATE LOCATION

1986 LEACHATE LOCATION

PROPOSED LEACHAT6 HEAD WELLS

. APPROXIMATE LIMITS OFLANDFILL AREAS

AOit PROPOSED WATER LEVEL MEASUREMENT STATIONS

PROPOSED SEDIMENT SAMPLING LOCATION

PROPOSED SURFACE WATER ANDSEDIMENT SAMPLES LOCATION

0 300

SCALE IN FEET

CONTOUR INTERVAL - 1 FOOT

FIGURE 3-4SURFACE WATER. SEDIMENT, ANDLEACHATE SAMPLE LOCATIONSG & HWORKPLAN

will be included in the soil boring and well installationsubcontract.

No soil or waste samples will be collected during the drill-ing at gas probe locations. The gas probes will be moni-tored for methane concentrations immediately after installa-tion and later during the second round of groundwater samp-ling. Samples will be collected for methane and VOC analysisas addressed in the QAPP.

The cost estimate for this subtask assumes that one personcan complete the probe installation and sampling work duringa 1-week period. The drilling subcontract cost is includedwith well installation (Subtask FI.FI).

SUBTASK FI.FA—AMBIENT AIR SAMPLING

Two 5-day air sampling events are planned at three offsiteand two onsite locations. The three offsite positionsinclude one location upwind of the site, one location down-wind, and one location downwind near the residential area.One onsite location will be situated in the seep area down-wind between the aerated pond and the test pits; the otherwill be located downwind of the test pits. The air will besampled and analyzed for potential VOC emissions from theseep area and from the Phase I oil ponds and solvent codis-posal area. Contemporaneous with the air sampling events,particulate sampling for PCBs is planned downwind in theseep area.

The first 5-day event will be conducted to assess ambientair conditions on and around the site. The data will beused to evaluate whether current site conditions present arisk to site visitors and residents living near the site.At that time, the air quality impact from the aerationtreatment in the seep area pond will be evaluated. The sec-ond 5-day event will be conducted while the test pits areexcavated. Those data will be used to characterize theemissions that may be released as a result of the onsiteactivities and determine whether excavating the landfillcontents will present air quality risks to nearby residents.

The cost estimate for this task assumes that a 2-person crewcan conduct the air sampling activities over each of the5-day events. The cost estimate also includes a portableweather station that will be set up at the site office com-pound. It is assumed that the weather station will be rentedfrom CH2M HILL for a 3-month period to cover all samplingactivities.

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TASK DE—DATA EVALUATION ACTIVITIES

SUBTASK DE.DV—DATA VALIDATION

Analytical data received from the CLP and the soils labora-tory will be reviewed by CH2M HILL. The appropriate use ofthe analytical data for RI/FS purposes will be evaluatedbased on the CLP QA/QC comments. Limitations of theanalytical data will be presented and explained in the RIReport (Subtask RI.Rl).

The cost estimate for this subtask includes reviewing QA/QCcomments, preparing data tables, and presenting data limita-tions and qualifiers for the RI Report (Subtask RI.Rl).

SUBTASK DE.DE—DATA EVALUATION

Data from the RI field tests will be summarized and evalu-ated. A data base system will be used to compare and sortdata based on factors such as type of sample, location,parameter, and concentration. Figures and graphic presen-tations will be developed to assist in data interpretationand evaluation of the hydrogeologic system, extent of ground-water contamination, and nature and extent of contaminantsin suspected source areas.

Specific analyses and evaluations to be performed willinclude:

o Preparing groundwater contour plots for all iden-tified hydrostratigraphic units

o Computing vertical and horizontal hydraulic gradi-ents and evaluating groundwater flow direction ineach stratigraphic unit

o Generating figures showing spatial and, when appli-cable, temporal distribution of contaminants insoil and groundwater

To assist in the evaluation of the potential for airbornecontamination, air transport calculations will be conductedfrom the offsite perimeter gas probes. Meteorological infor-mation such as wind direction, wind speed, temperature, andbarometric pressure will be incorporated. If the onsitemeteorological information is not considered representative,other nearby weather data may need to be obtained.

Calculation of dispersion from a point source is a reliablemeans of predicting downwind concentrations. However, themajor limitation to this approach is that the data willrepresent only isolated point sources and not the steady,naturally occurring emissions from the site.

3-20

The labor effort estimated to complete this subtask isassumed to occur over an 8-week period. The cost estimateincludes developing figures, graphic presentations, andtables to assist in evaluating data. Additional data needswill also be identified.

TASK AR--RISK ASSESSMENTAND TASK RI—REMEDIAL INVESTIGATION REPORT

SUBTASK AR.PH—RISK ASSESSMENT

The risk assessment will provide a quantitative and qualita-tive baseline evaluation of the potential threat to the pub-lic health and environment from the areas of the landfillsite investigated as part of the RI. Using the results ofthe RI, the risk assessment will address the potential haz-ards under existing and future conditions before any correc-tive or remedial actions are implemented. This is equiva-lent to an assessment of the no-action alternative.

The assessment will indicate whether the site requires reme-diation. The results of the assessment will be used tofocus corrective measures on remediation of the problemsidentified. The assessment, which serves as link betweenthe RI and FS, lays the groundwork and establishes guide-lines to protect the public health and the environment underthe future remedy.

The risk assessment will be consistent with U.S. EPA methodsfor estimating the health risks of environmental pollutants,Office of Emergency Remedial Response (OERR) guidelines forSuperfund public health evaluations, and Office of Waste Pro-grams Enforcement (OWPE) guidelines for endangerment assess-ments .

The cost estimate for this subtask assumes that two peoplewill work about 4 weeks to complete the assessment. Therisk assessment will be incorporated as a chapter and sup-porting appendixes in the RI report (Subtask RI.Rl).

SUBTASK RI.Rl—PREPARE RI REPORT

A report summarizing RI activities will be prepared and sub-mitted to the U.S. EPA and MDNR for review and comment. Thereport will provide documentation of data obtained forPhase III RI tasks, as well as data evaluation and interpre-tation. Two drafts of the RI report are budgeted in thecost estimates. Twelve copies of each draft, consisting ofa 500-page, double-spaced, single-sided report, will be dis-tributed for agency review. The cost estimate includes an8-hour review meeting with the MDNR in Lansing. The finalreport cost estimate includes preparing and printing 50 copiesof a 400-page, single-spaced, double-sided document.

3-21

SUBTASK RI.PM—PROJECT MANAGEMENT

RI report and risk assessment project management activitieswill be handled through CH2M HILL's office in Milwaukee,Wisconsin. Contact will be maintained with the U.S. EPARemedial Project Manager (RPM) during all phases of theproject.

Project management during data evaluation, risk assessment,and RI report activities will include preparing monthlyreports to keep the RPM informed of the technical, finan-cial, and schedule status of the project. Other respon-sibilities include monitoring budgets and schedules; select-ing, coordinating, and scheduling staff task assignments;and maintaining project quality control and assurance pro-grams .

The cost estimate for this subtask assumes that project man-agement activities will occur over a 6- to 8-month period.The cost estimate also includes monthly review meetings atthe EPA's Region V office in Chicago.

SUBTASK RI.QC—QUALITY CONTROL

Periodic review of project files, project deliverables, andsite inspection during the field activities will be conductedby a review team throughout the RI. The team will consistof three or four professionals from appropriate disciplineswith experience related to the problems and investigationsat the site. They will review deliverables (RI Report) tothe U.S. EPA and act as project advisors throughout the dataevaluation and reporting activities.

TASK AS—ALTERNATIVES SCREENING AND DEVELOPMENT

SUBTASK AS.AT—TECHNOLOGY SCREENING

A list of applicable general response actions will have beenidentified for the G&H site under Subtask PP.AP—Scoping ofResponse Actions. Based on the general response actions,specific remedial technologies enabling implementation ofthe actions will be identified and screened. This initialscreening will consider two criteria pertaining to appli-cability:

o Physical site conditions that preclude the practi-cal use of a technology

o Chemical character of site contaminants that pre-clude the application of a technology

3-22

Summary lists of both applicable and inapplicable remedialtechnologies and explanations for the rejection of theinapplicable technologies will be provided.

SUBTASK AS.AD—ALTERNATIVES DEVELOPMENT

Subtask AS.AD will be performed to identify the screenedalternatives assembled from the technologies retained fromSubtask AS.AT.

According to available guidance on interpretation of SARA,selected remedies at Superfund sites must:

o Be protective of human health and the environment

o Stress permanent solutions to the maximum extentpracticable

o Attain both state and federal applicable or rele-vant and appropriate requirements (ARARs)

o Be cost-effective

Alternatives will be developed using the concept of "perma-nence" as a guide. Treatment alternatives that reduce toxi-city, mobility, or volume of contaminated media will beemphasized. A list of alternatives will be developed rang-ing from permanent, low maintenance, or management solutionsto less permanent solutions requiring more long-term manage-ment. Innovative technologies having the potential for bet-ter treatment performance, implementability, or lesseradverse effects than other available approaches will becarried through the screening process. For a large, complexsite like the G&H landfill, treatment of sources may pos-sibly be eliminated in the FS screening process.

Developed alternatives will be screened against effective-ness, implementability, and cost. Cost will be used to dis-criminate between treatment alternatives that provide simi-lar levels of protection but it will not be used as acriterion for comparing treatment to nontreatment alterna-tives.

To further evaluate the effectiveness of selected alterna-tives, bench-scale or pilot-scale tests may be conducted aspart of the RI/FS work scope. The practice is encouragedunder SARA. The costs for bench-scale or pilot-scale testsare not included in the cost estimate.

3-23

T3SK AE—ALTERNATIVES EVALUATION

SUBTASK AE.AE—ALTERNATIVES EVALUATION

The purpose of Subtask AE.AE is to analyze the alternativesthat passed through the screening process against the cri-teria of effectiveness, implementability, and cost and tocompare them to each other.

Effectiveness will be evaluated in terms of whether analternative adequately protects human health and theenvironment, whether it attains state and federal ARARs,whether it significantly and permanently reduces thetoxicity, mobility, or volume of hazardous constituents, andwhether it is technically reliable.

Implementability factors include technical feasibility andavailability of the technologies each alternative wouldemploy, the technical and institutional ability to monitor,maintain, and replace technologies over time, and the admin-istrative feasibility of implementing the alternative.

Capital cost and long-term operation and maintenance costestimates will be developed, and a present worth analysiswill be conducted. The cost estimates will be order-of-magnitude and are expected to be accurate within a range ofplus 50 and minus 30 percent.

TASK FS—FEASIBILITY STUDY REPORT ACTIVITIES

SUBTASK FS.P4—PREPARE FS REPORT

A draft FS report summarizing the results of the feasibilitystudy will be prepared. The alternative remedial actionassessment will be documented. Copies of the draft reportwill be submitted to the U.S. EPA and MDNR for review.CH2M HILL has budgeted for two draft versions and a finalversion (public comment) of the FS report. The cost assump-tions for preparing the FS report are the same as for the RIreport (Subtask RI.Rl).

A review meeting will be held between the U.S. EPA, CH2M HILL,and the MDNR to discuss the draft FS report. To prepare forthe meeting, the EPA and MDNR will provide their review com-ments on the draft FS report to CH2M HILL. The draft FSreport will be modified as directed by the EPA in prepara-tion of the public comment FS report.

SUBTASK FS.PM—PROJECT MANAGEMENT

Project management activities for the FS activities (Tasks AS,AE, and FS) will be similar to activities described in Sub-task FI.PM. The cost estimate for this subtask assumes that

3-24

project management activities for the FS will occur over a1-year period. The cost estimate also includes monthlyreview meetings at the EPA's Region V office in Chicago.

SUBTASK FS.QC—QUALITY CONTROL

The review team described under Subtask FI.QC will conductperiodic reviews of FS activity and project deliverables.The level of effort for this subtask assumes that the reviewteam will review the following deliverables:

o Alternative Array Memorandumo Draft and Final Feasibility Study Reportso Draft and Final Predesign Reports

TASK PS—POST FEASIBILITY STUDY SUPPORT

SUBTASK PS.RS--RESPONSIVENESS SUMMARY

Following the close of the FS public comment period, a Respon-siveness Summary will be prepared to address public commentsand questions concerning the RI and FS. CH2M HILL will pre-pare a draft Responsiveness Summary Memorandum and submit itto the U.S. EPA and MDNR for review. Transcripts of commentsfrom the public meeting and copies of written comments willbe attached to the memorandum.

The cost estimate for this subtask assumes that one personcan complete the memorandum in a 2-week period. An addi-tional effort may be required if a large number of publiccomments require technical evaluations.

SUBTASK PS.RD—ROD SUPPORT

After completing the FS, CH2M HILL will provide technicalsupport to the U.S. EPA in its Record of Decision (ROD) orEnforcement Decision Document (EDO). This would includeclarification of the FS, reviewing technical content of RODdocuments, and assisting U.S. EPA regional staff in prepar-ing briefing materials or visual art. Costs for additionaltechnical analyses or evaluations of alternatives have notbeen budgeted.

SUBTASK PS.R7—CONDUCT REMEDIAL PREDESIGN AND PREPARE REPORT

At the EPA's request, CH2M HILL will conduct a remedial pre-design of the selected remedial action. The objective ofthe predesign task is to describe engineering parameters andinstitutional concerns and to provide pertinent project infor-mation for transferring the project to the lead design party.

3-25

The results of the predesign effort will be presented in aformal report. The following elements will be included inthe draft predesign report:

o Site descriptiono Description of remedy and rationale for selectiono Preliminary layouts of preferred remedyo Preliminary design criteria and rationaleo Preliminary process diagramso General operation and maintenance requirementso Long-term environmental monitoring requirementso Potential desian/implementation problemso Additional engineering data requiredo Permit and regulatory requirementso Access, easements, and right-of-way requirementso Health and safety requirementso Community relations needso Implementation order-of-magnitude cost estimateo Preliminary project schedule (design, construc-

tion, permits, and access)

The draft report will be prepared and submitted to theU.S. EPA and MDNR for review. A meeting will be held todiscuss review comments to the report. The agencies willsubmit their review comments to CH2M HILL before themeeting. To promote project continuity from predesign todesign, the design agency or firm should also be present atthe meeting. The predesign report will incorporate theU.S. EPA's and MDNR's review comments. The final predesignreport will be submitted to the U.S. EPA and MDNR followingthe review meeting.

The cost estimate for this subtask assumes that only datafrom the RI/FS will be used to develop the predesign report.No new data will be collected or additional analyses per-formed. Cost estimates will be based directly on the costsdeveloped in the FS.

SUBTASK PS.PC—PROJECT CLOSEOUT

This subtask includes activities to complete or close outthe technical and financial aspects of the project. Thecost estimate for this subtask includes the followingactivities:

o Organizing file recordso Indexing files to be microfilmedo Closing out project subcontractso Completing the work assignment close out request

(WACR)

3-26

SUBTASK PS.PM—PROJECT MANAGEMENT

Project management activities for post-FS support will besimilar to activities described in Subtask FI.PM. The costestimate for this subtask assumes that project managementactivities for the FS will occur over a 6-month period. Thecost estimate also includes monthly review meetings at theEPA's Region V office in Chicago.

SUBTASK PS.QC—QUALITY CONTROL

The review team described under Subtask FS.QC will conductperiodic reviews of post-FS activity and project deliver-ables. The level of effort for this subtask assumes thatthe review team will review the following deliverables:

o Draft and Final Responsiveness Summaryo Draft and Final Predesign Reports

GLT661/37

3-27

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EXISTING MONITORING WELL LOCATION

PROPOSED MONITORING WELL LOCATION

SLUG TEST AT WELL NEST IALL WELLS!

EXISTING SOIL BORING

PROPOSED SOIL BORING

GAS PROBE (PHASE II Rl l

PROPOSED GAS PROBE

0 300

SCALE IN FEETASSUMED WIND DIRECTION

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FIGURE 3-1PROPOSED LOCATIONS OFMONITORING WELLS, SOIL BORINGS &GAS PROBES0 * H WOHKPLAN

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EXISTING MONITORING WELL

EXISTING BORINGS

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SCALE IN FEET

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FIGURE 3-2SURFACE SOIL SAMPLE LOCATIONSG&HWORKPLAN

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