Report: Final Work Plan, Volume I, Vega Baja Solid Waste ...

I SDMS Document

107291

RESPONSE ACTION CONTRACT FOR REMEDIAL RESPONSE ENFORCEMENT OVERSIGHT

CRITICAL REMOVAL ACTIVniES AT SITES OF RELEASE OR THREATENED RELEASE OF HAZARDOUS SUBSTANCES

IN EPA REGION n

VEGA BAJA SOLID WASTE DISPOSAL SITE REMEDIAL INVESTIGATIONFEASIBILITY STUDY

OPERABLE UNIT 2 - SOILS INVESTIGATION VEGA BAJA PUERTO RICO

Work Assignment No 048-RICO-02HJ

FINAL WORK PLAN VOLUME I

US EPA CONTRACT NO 68-W-98-210 Document Control No 3220-048-PP-WKPN-03247

June 282002

Prepared by M i - ^ ^ ^ lAM^^yHj^ Date u l 2 ^ l o i l Michael Valentino Site Manager

Reviewed by bullbull-S^ ^ JXik-r- Date Gl ^Sd ^ Jeanne Litwm REM RAC n Technical Operations Manager

Approved by K^^^-MîSy^ Date ^ ^ ^ ^ ^ w Robert D Goltz PE S

en RAC n Program Manager bullgtbull N3

finaiwplti048wpd - 62702

I I I

bull i 125 Maiden LaneSth Roor New York New York 10038 tel 212 785-9123 fax 212 785-6114

June 28 2002

Ms Helen Eng Project Officer US Environmental Protection Agency 290 Broadway - 18 Floor New York NY 10007-1866

Mr Ramon Torres Remedial Project Manager US Environmental Protection Agency Caribbean Enviroimiental Protection Division Gentro Europa Building Suite 417 1492 Ponce de Leon Avenue Stop 22 Santurce Puerto Rico 00907-4127

PROJECT RAC n Contract No 68-W-98-210 Woric Assignment No 048-RICO-02HJ

DOC CONTROL NO 3220-048-PP-WKPN-03247

SUBJECT Final Work Plan Volume I Vega Baja Solid Waste Disposal Site Remedial InvestigationFeasibility Study Operable Unit 2 - Soils Investigation Vega Baja Puerto Rico

Dear Ms Eng and Mr Torres

CDM Federal Programs Corporation (CDM) on behalf of our entire RAC II Team is pleased to submit this Final WbrkPlan Volimie I for the Remedial InvestigationFeasibility Study Operable Unit2 - Soils Investigationat the Vega Baja Soiid Waste Disposal Site in Vega Baja Puerto Rico This Final WorkPlan reflects EPA comments dated May 32002

If you have any questions regarding this work plan please contact me at your earliest convenience at (212) 785-9123

Very truly yours

CDMFEDERAL PROGRAMS CORPORATION

Robert D Goltz PI RAC n Program Manager

RDGmd Enclosure

cc D Buder EPA Region II J Litwin CDM B Irons CDM L Villatora EPA

M Valentino CDM N Rodriguez CDM RAC n Document Control

3 0 0 6 4 3

tinalwDltr048wnd - 62802

Vega Baja Solid Waste Disposal Site Remedial InvestigationFeasibility Study Operable Unit 2 - Soils

Final Work Plan - Volume I Vega Baja Puerto Rico

TABLE OF CONTENTS Section Page

LO INTRODUCTION 1-1 11 Overview ofthe Problem 1-1 12 Approach to the Development ofthe Work Plan 1-2 13 Work Plan Content 1-3

20 SITE BACKGROUND AND SETTING 2-1 21 Site Location and Description 2-1 22 Site History and Previous Investigations 2-1 23 Current Conditions 2-6

30 INTTL^L SITE EVALUATION 3-1 31 Review of Existing Data 3-1

311 Topography 3-1 312 Geology 3-1 3121 Regional Geology 3-1

3122 Local Geology 3-2 313 Hydrogeology 3-2

3131 Regional Hydrogeology 3-2 3132 Local Hydrogeology 3-4 3714 Drainage and Surface Water 3-4 315 Climate 3-5 316 Population and Land Use 3-5

32 Summary of Identified Contamination at the Site 3-5 321 Sources and Distribution of Contamination 3-6 322 Chemical Characteristics of Soil 3-6

3221 EQB and EPA Investigations 3-6 3222 EPA Removal Action 3-6

323 Chemical Characteristics of Groundwater 3-9 324 Cheinical Characteristics of Surface Water and Sediment 3-9 325 Site Conceptual Model 3-9

3251 Physical Setting with Respect to Soil Contamination 3-9 3252 ExpectedFateandTransport of Site Contaminants in

Relation to Residential Exposure 3-10 33 Preliminary Identification of AppUcable or Relevant and Appropriate

-i-300644




Requirements (ARARs) 3-10 331 Definition of ARARs 3-10 332 Consideration of ARARs During the RIFS 3-12 333 Preliminary Identification of Potential ARARs for the Vega Baja Site 3-13

3331Chemical-specific Potential ARARs 3-14 3332 Action-specific Potential ARARs 3-14 3333 Location-specific Potential ARARs 3-15

34 Preliminary Human Health Risk Assessment 3-16 341 Chemicals of Potential Concern 3-16 342 Potential Source Areas and Exposure Pathways 3-16

^ 3421 Surface Soil Pathways 3-17 3422 Subsurface Soil Pathways 3-17

343 Summary of Additional Data Needs 3-18 35 Preliminary Identification of Remedial Action Alternatives 3-18

40 WORK PLAN RATIONALE 4-1 41 Data Quality Objectives 4-1 42 Work Plan Approach 4-1

50 TASK PLANS 5-1 51 Task 1 - Project Planning and Support 5-1

511 Project Administration 5-1 512 Attend Scoping Meeting 5-2 513 Conduct Site Visit 5-2 514 Develop Draft Work Plan and Associated Cost Estimate 5-2 515 Negotiate and Revise Draft Work Planûdget 5-3 516 Evaluate Existing Data and Documents 5-3 517 Quality Assurance Project Plan 5-3

5171 Quality Assurance Project Plan Addendum 5-3 5172 Other Quality AssuranceQuality Control Activities 5-4

518 Health and Safety Plan Addendum 5-4 519 Non-RAS Analyses (Optional) 5-4 5110 Meetings 5-5 5111 Subcontract Procurement 5-6 5112 Perform Subcontract Management 5-6

bull 3 0 0 6 4 5




5113 Pathway Analysis Report 5-6 52 Task 2 - Commxmity Relations 5-7

521 Community Interviews 5-7 522 Community Relations Plan 5-7 523 PubUc Meeting Support 5-7 524 Fact Sheet Preparation 5-8 525 Proposed Plan Support 5-8 526 Public Notices 5-8 527 Information Repositories 5-8 528 Site Mailing List 5-9 529 Responsiveness Summary Support 5-9

53 Task 3 - Field hivestigation 5-9 531 Site Reconnaissance 5-9 532 Mobilization and Demobilization 5-9 533 Environmental Sampling 5-10

5331 Site Visits 5-11 5333 Residential Dust Sampling 5-13 5334 Residential Tap Water Sampling 5-13

534 Soil Boring Drilling and Testing 5-13 5341 Optional Soil Boring Program 5-13

535 Disposal of Field Generated Waste 5-14 54 Task 4 - Sample Analysis 5-14

541 Innovative MethodsField Screening Sample Analysis 5-14 542 Analytical Services Provided via CLP DESA or EPA-ERT 5-14 543 Subcontractor Laboratory for Non-RAS Analyses 5-15

55 Task 5 - Analytical Support and Data Vahdation 5-15 551 Collect Prepare and Ship Samples 5-15 552 Sample Management 5-15 553 Data Validation 5-15

56 Task 6 - Data Evaluation 5-16 561 Data Usability Evaluation 5-16 562 Data Reduction Tabulation and Evaluation 5-16 563 Modeling 5-18 564 Technical Memorandum 5-18

57 Task 7 - Assessment of Risk 5-18

-iii-300646

i il Vega Baja Solid Waste Disposal Site

Remedial InvestigationTeasibility Study Operable Unit 2 - Soils Final Work Plan - Volume I

Vega Baja Puerto Rico

fl TABLE OF CONTENTS

r Section Page J

571 Baseline Risk Assessment (Human Health) 5-19 ri 5711 Draft Human Health Risk Assessment Report 5-20 I [ 5712 Final Human Health Risk Assessment Report 5-25

58 Task 8 - Treatability Stiidy and Pilot Testing 5-25 j] 581 Literatiire Search 5-26 II 582 Treatability Stiidy Work Plan Addendum (Optional) 5-26

583 Conduct Treatability Studies (Optional) 5-27 [I 584 Treatability Stiidy Report (Optional) 5-27 ^ 59 Task 9 - Remedial Investigation Report 5-27

591 Draft Remedial Investigation Report 5-28 592 Final Remedial Investigation Report 5-28

510 Task 10 - Remedial Alternatives Screening 5-28 5101 Draft Technical Memorandum 5-29

f I 5102 Final Technical Memorandum 5-30 511 Task 11- Remedial Alternatives Evaluation 5-30

P 5111 Draft Technical Memorandum 5-32 | 5112 Final Technical Memorandum 5-32

512 Task 12 - Feasibility Shidy Report 5-32 n 5121 Draft FS Report 5-32 i 5122 FinalFSReport 5-33

513 Task 13-Post RIFS Support 5-33 fi 514 Task 14 - Negotiation Support 5-33 i r 5141 AttendProvide Technical Support at Negotiation Meetings 5-33

5142 ReviewComment on PRP Documents 5-33 515 Task 15 - Administrative Record 5-33

J 516 Task 16 - Project Closeout 5-33 5161 Work Assignment Closeout Report 5-34

j 5162 Document Indexing 5-34 bull 5163 Document RetentionConversion 5-34

0

60 COSTS AND KEY ASSUMPTIONS 6-1

70 SCHEDULE 7-1

80 PROJECT MANAGEMENT APPROACH 8-1

-iv- 3 00647

n



LIST OF FIGURES (continued)

5-1 Properties for Residential Surface Soil Dust and Tap Water Sampling -Lead Analysis

5-2 TAL Metals PCB and Pesticide Samphng Blocks 5-3 Proposed Locations of Trash Mound Surface and Subsurface Soil Samples 5-4 Proposed Locations for Non-Residential Surface and Subsurface Soil Samples

7-1 Proposed Project Schedule

8-1 Project Organization

-vn-300648

10 INTRODUCTION

CDM FEDERAL PROGRAMS CORPORATION (CDM) received Work Assignment Number 048-RICO-02HJ under the RAC II program to perform a Remedial InvestigationFeasibility Study (RIFS) including a Human Health Risk Assessment (HHRA) for the United States Environmental Protection Agency Region II (EPA) at the Vega Baja Solid Waste Disposal Superfund Site (the Site) located in Vega Baja Puerto Rico The purpose ofthis work assignment is to investigate the overall nature and extent of soils contamination at the Site assess risks to human health posed by site contaminants and to develop remedial alternatives as appropriate

For presentation purposes work plan figures and tables are presented at the end of each section

11 OVERVIEW OF THE PROBLEM

The Vega Baja Solid Waste Disposal Site is a 72-acre inactive unhned uncapped sohd waste disposal facility located approximately 12 miles south of the town of Vega Baja in the rural area of Rio Abajo Ward Puerto Rico (Figure 1-1) The Site consists ofthe residential area south of Route 22 and east of Avenue Trio Vegabajeiio terminating on Calle Progreso to the east and includes the wooded area to the south (Figure 1-2) The Site operated as an open burning disposal site by the Vega Baja Municipality from approximately 1948 to 1979 During this time an estimated 1108540 cubic yards of waste including commercial industrial and domestic waste were dumped andor open-bumed During the 1970s the Puerto Rico Environmental Quality Board (EQB) conducted several inspections at the Site As a result of these inspections EQB and EPA cited the municipality for problems caused by ineffective controls of their daily operations (ie smoke bad odors)

During the 1970s individuals began constructing residential homes on and around the Site Currently there are over 213 homes located on approximately 55 acres of the Site This residential community is known as Comunidad Brisas del Rosario Trash broken glass and other debris was observed in the residential yards located on site with debris mounds greater than 10 feet thick at sorne locations Most homes have a backyard garden typically containing fruit crops root crops and legumes In addition most households rear farm animals such as chickens goats pigs and rabbits

From 1994 to 1999 EPA and EQB conducted several multi-phased investigations that documented surface and subsurface soil contamination resulting from landfilling operations at the Site The main contaminants that were determined to pose the greatest threat to residents were lead and arsenic As a result of these investigations EPA conducted a removal action in 1999 to excavate lead-contaminated soils at three properties located on the Site The Site was listed on the National Priorities List (NPL) in July 1999

bull Currently there are four garbage mounds and contaminated soil remaining in the residential portion of the Site In addition an unknown amount of contaminated soil and landfill debris may be present

1-1 300649

in the non-residential area in the southern part of the site It is unknown whether groundwater underlying the Site has been affected by contaminated soils

As part of the RIFS EPA has divided the Site into two Operable Units (OUs) OUl is an RIFS for groundwater CDM began OUl field activities in October 2001 0U2 is an RIFS for soils The purpose of the 0U2 RIFS is to gather data sufficient to characterize the extent of contamination and to characterize potential risks to human receptors

It should be noted that another NPL Superfund Site Vamp M Albaladejo Farms (VampM) is located approximately 23 mile southeast of the Site CDM on behalf of EPA conducted an RI at the VampM Site Investigation activities included the installation of monitoring wells groundwater sampling and seep sampling Information obtained during the VampM RI will be reviewed by CDM and incorporated into project planning documents where appropriate

12 APPROACH TO THE DEVELOPMENT OF THE WORK PLAN

Prior to the formulation of the scope of work that is presented in this Work Plan CDM reviewed all available information on the Site provided by the EPA Remedial Project Manager (RPM) Section 90 presents a hst of all documents reviewed and referenced in the development of this Work Plan The 0U2 RIFS will be completed in three phases an RI an HHRA and a FS

The OU2 RI will focus on collecting adequate soil data to fully characterize the nature and extent of site-related soil contamination and to identify potential areas of contamination In addition residential dust and tap water samples will be collected to obtain data for the Integrated Exposure Uptake Biokinetic Model of Lead in Children If directed by EPA CDM will also conduct a soil boring program to assess the nature and extent of subsurface soil contamination The field program activities are detailed in Section 50 Addendums to the OUl Quality Assiirance Project Plan (QAPP) and the associated Health and Safety Plan (HSP) will be submitted separately The QAPP Addendum will detail the sampling and analysis requirements for the 0U2 field investigation program CDM will prepare an RI report that will provide a complete evaluation ofthe 0U2 sampling and field investigation results

An HHRA which will evaluate risk to the public health from exposure to site contaminants will be completed for 0U2 The HHRA will be conducted according to EPAs Risk Assessment Guidance for Superfund (RAGS) (Part A 1989 and Part D 2001) or according to the most current EPA guidances and requirements The report will also include a list of indicator compoundsconstituents transport degradation and fate analysis of indicator compoundsconstituents toxicology of indicator compoundsconstituents to humans comparison of concentrations of indicator compoundsconstituents found in the soil to Applicable or Relevant and Appropriate Requirements (ARARs) and determination of risk

The FS for 0U2 will be prepared in accordance with EPA Interim Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA (EPA 1988a) or the most updated

1-2 300650

EPA FS guidance document CDM will develop and screen remedial alternatives and provide detailed analysis of selected alternatives including the No Action alternative The alternatives which will be carried through detailed screening will be evaluated against the nine evaluation criteria required by the EPA guidance documents (1) overall protection of human health and the environment (2) compliance with ARARs (3) long term effectiveness and permanence (4) reduction of toxicity mobility or volume through treatment (5) short term effectiveness (6) implementability (7) cost (8) StateCommonwealth acceptance and (9) community acceptance

13 WORK PLAN CONTENT

This Work Plan contains the following sections

Section 10 - Presents an introduction

Section 20 - Describes the Site background including the current understanding of the location history and existing condition of the Site

Section 30 - Presents the initial evaluation of existing data This section includes a description of the contaminants in the potential source areas the regional and site geology and hydrogeology the migration and exposure pathways a preliminary assessment of pubhc health and environmental impacts a preliminary identification of ARARs and remedial action objectives

Section 40 - Presents the Work Plan rationale including the data quality objectives (DQOs) for RI sampling activities and the approach for preparing the Work Plan which illustiates how the planned activities will satisfy the project goals

Section 50 - Presents a discussion of each task of the RIFS in accordance with the RAC II Statement of Work for Soil Remedial Investigation and Feasibility Study Vega Baja Sohd Waste Disposal Site and the Interim Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA (EPA 1988a)

Section 60 - Presents costs and key assumptions

Section 70 - Presents the anticipated schedule for the RIFS tasks

Section 80 - Presents project management considerations that define relationships and responsibilities for selected tasks and project management teams

Section 90 - Provides a list of references used to develop material presented in this Work Plan

Section 100 - Provides a glossary of acronyms and abbreviations used in this Work Plan

1-3 300651

i -c^^- ^ gt ^ 4g--l- M

Contour Interval = 5 meters Scale 3 Inches = 5000 feet

(adapted from USGS Manati PR 120000 Quadrangle last revised 1982)

CDM

Figure 1-1 SITE LOCATION MAP

Remedial InvestigationFeasibility Study Vega Baja Solid Waste Disposal Site Puerto Rico

LEGEND

SITE BOUNDARY

SUBSITE BOUNDARY

APPROX SCALE 1=20a

CDM

Figure 1-2 SITE MAP

Remedial InvestigationFeasibility Study Vega Baja Solid Waste Disposal Site


20 SITE BACKGROUND AND SETTING

21 SITE LOCATION AND DESCRIPTION

The Site is a 72-acre inactive unlined uncapped solid waste disposal facility located in the rural area of Rio Abajo Ward Puerto Rico The Site is located approximately 12 miles south ofthe town of Vega Baja and is situated on relatively flat terrain surrounded by residential areas to the north east and west and is bordered to the south by mogotes which are conical limestone hills The Rio Indio is located approximately one-quarter of a mile east of the Site A drainage ditch runs through the site and discharges to the Rio Indio floodplain The Site is currently defined as the residential area south of Route 22 east of Avenue Trio Vegabajeno and west of Calle Progreso The undeveloped wooded area to the south is also included Figures 1-1 and 1-2 show the site location and site plan respectively There are currently more than 213 dwellings located on 55 acres of the Brisas del Rosario residential area

The Rfo Abajo Head Start school and a contiguous baseball park are located 021 miles from the Site boundary According to EQB s Expanded Site Investigation (ESI) the population within a four mile radius of the Site is more than 40000 The population within a one mile radius of the Site is approximately 6871 and 2280 within a one quarter mile (EQB 1997)

22 SITE HISTORY AND PREVIOUS INVESTIGATIONS

From 1948 to 1979 the municipality of Vega Baja used the site as an unlined landfill that received conrmnercial industrial and domestic waste It is estimated that approximately 1108540 cubic yards of waste were disposed of andor burned at the Site At the time of disposed activities the site was owned by the Puerto Rico Land Authority (PRLA)

Local residents began constructing homes on portions ofthe uncapped landfill beginning in the late 1970s Currently there are over 213 homes located on approximately 55 acres ofthe Site In 1984 the PRLA transferred Ihe landfilLproperty (approximately 55 acres) to the Puerto Rico Housing Department (PRHD) The PRHD has given titles to several residents who have constructed homes on the landfill property It is unclear at this time which residents have deeds to their property All the remaining undeeded properties and the 17 undeveloped acres are owned by the PRHD

During the late 1970s EQB in response to complaints of neighboring residents conducted several inspections at the active landfill As a result of these inspections the municipality was cited by EQB and EPA for problems including smoke bad odors and presence of scavengers caused by the ineffective control of the landfills daily operations Landfill operations at the Site were discontinued when the municipality opened a new landfill at Cibuco Ward Vega Baja

Beginning in 1994 EQB and EPA conducted several investigations at the Site These are summarized below

^^ 300654

Site Inspection May 1994 In May of 1994 EQB conducted a Site Inspection (SI) at the site During the SI five surface soil samples one background soil sample five sediment samples and two groundwater samples (from one upgradient and one downgradient residential supply well) were collected (EQB 1995)

The surface soil samples were collected from the backyards of five residential properties that were located on the former landfill Analytical results indicated lead at concenttations up to 3410 parts per million (ppm) and copper concentrations up to 350 ppm in the soil samples Other inorganics detected in the samples above background levels included arsenic barium cadmium nickel iron and magnesium Organics detected above background levels included bis(2-ethyhexyl)phthalate fluoranthene pyrene and Aroclor 1260

Sediment samples were collected from two locations along the site drainage ditch and from three locations along the Rio Indio one upstream of the site one at the drainage ditchs probable point of entry and one downstream of the site Acetone 2-butanone tetrachioroethene and copper were detected at concentrations above background in the sediment samples The upstream sediment sample was used as background

Groundwater samples were collected from the upgradient Villa Pinares municipal well located 1 mile south ofthe Site and from a downgradient Vega Baja municipal well located 09 mile north ofthe site respectively Copper was detected in the downgradient well sample at 34 parts per billion (ppb) Subsequent analysis of the data by EPA determined that the detected copper concentration in the public supply well did not represent a health threat to the community

Expanded Site Inspection 1996 An ESI was conducted from June through August 1996 by EQB and Roy F Weston - Superfund Technical Assistance and Response Team (START) (Weston-START 1998) As part ofthe ESI groundwater surface water sediment and surface soil samples were collected to characterize the extent of contamination within the landfill and to determine if the site represented a potential threat to human health Data were also collected to provide information forthe Agency for_Toxic_Substances_Disease_Registry_(ATSDR)_sitebdquo health consultation

As part ofthe 1996 ESI surface soil samples were initially collected from residential properties and screened for lead with an X-Ray Fluorescence (XRF) instrument Sampling points for confirmatory laboratory analysis were determined based upon the results ofthe XRF screening activities A total of 153 soil samples were subsequently collected from locations throughout the former landfill area and submitted to EPAs Contract Laboratory Program (CLP) laboratories for Target Compound List (TCL) and Target Analyte List (TAL) analysis Copper lead cadmium nickel and several other inorganics were detected at concentiations above background Organic compounds detected above background or the Contract Required Detection Limit (CRDL) included pyrene benzo(a)pyrene fluoranthene phenanthrene methoxychlor and Aroclor 1254

2-2 300655

Six sediment and five surface water samples were collected from locations along the site drainage ditch and from upstream and downstream locations on the Rio Indio The samples were submitted to CLP laboratories for TCL and TAL analysis Analytical results indicated the presence of chromium copper lead nickel zinc and several other inorganics in the sediment samples However no organic compounds were detected in the sediment samples and no organic compounds or inorganic analytes were detected in the surface water samples

Groundwater samples were collected from two public supply wells one upgradient of the site and one downgradient No inorganic or organic analytes were detected in either of the supply wells

Based on review of the ESI soil analytical results ATSDR determined that the site could be a public health hazard since long-term exposure to the lead concentrations detected in many yards could have harmful effects on children

Limited Groundwater Study April - June 1998 From April to June 1998 Weston-START conducted a limited groundwater study at the Site The study included the installation of monitoring wells (MWOl MW02 and MW03) and sampling of the newly installed wells and neighboring public supply wells Weston-START installed three water table wells that ranged in depth from 195 feet below ground surface (bgs) to 215 feet bgs The public supply wells that were sampled included the nearby United States Geological Survey (USGS) observation well (Rosario 2) located 40 feet west of the Site and three public supply wells the upgradient Villa Pinares well and the two downgradient Vega Baja 1 and Vega Baja 3 wells The samples were submitted to an EPA CLP laboratory for TCL organic compound and TAL inorganic analyte analyses

Acetone and 111-trichloroethane were detected in the Rosario No 2 well at levels up to 54 micrograms per liter (ugl) and 61 ugl respectively Bis(2-ethylhexyl) phthalate was detected in two ofthe public supply well samples but was also noted in associated quality control blanks Estimated concentrations of heptachlor-andendrin aldehyde_were_detectedbdquoin_bothup and_ downgradient wells the highest levels were detected in the downgradient MWOl at concentrations up to 0019 ugL and 0053 ugL respectively No other TCL organic compounds were detected in the groundwater samples

Iron and manganese were detected in the samples collected from both up and downgradient wells at concentrations above their respective CLP CRDLs iron was detected at levels up to 2310 ugL and manganese was detected at levels up to 144 ugL Several other inorganics including aluminum arsenic barium copper mercury and selenium were detected at estimated concentrations in both up and downgradient wells

Soil Samphng Event April -December 1998 EPA conducted a soil sampling event at the Site from April 1998 to December 1998 A total of 3693 surface soil samples were collected and

2^ 300656

analyzed primarily for lead Section 32 presents a detailed description of sampling locations and results The sampling event was divided into three phases

bull Phase I - The sampling was conducted from April 14 to June 8 1998 This phase was focused on the entire Site as one unit The primary contaminant of concern during this phase was lead However the samples were also analyzed for the presence of other inorganic and organic compounds The sampling area consisted ofthe residential area south of Route 22 and east of Trio Vegabajeno Avenue terminating on Calle Progreso to the east and included the undeveloped wooded areas to the south Soil samples were also taken from the bottom and side walls of the drainage ditch

bull Phase n - Subsequent sampling was conducted from August 3 to December 1998 The majority of the sampling area consisted of the residential area south of Route 22 and east of Avenue Trio Vegabajeiio The sampling area terminated on Calle Progreso to the east and the undeveloped wooded area to the south No soil sampling was done in the undeveloped wooded area south of the residences

During this phase each residential lot was sampled as a discrete unit and analysis focused on soil lead content Two sampling protocols were followed In yards where elevated lead levels (400 mgkg or greater) were found during previous sampling activities biased sampling locations were collected at ground surface 10 and 20 feet bgs In yards where lead levels less than 400 mgkg were found during previous sampling activities six surface soil samples were initially collected on a regular grid where feasible However later in the sampling event soil samples were also collected at 1 foot bgs A total of 214 residential lots were sampled and 2823 soil samples were collected and analyzed

bull Phase in This phase was focused on sampling the four garbage mounds in the residential area ThesamplingwasconductedfromDecemberS to December 161998 The objective of this phase was to estimate the area of the mounds the thickness of the garbage and the level of lead-contamination within the mounds A total of 56samples were collected andbdquo analyzed using XRF methodology

Removal Action 1999 After the evaluation of data from Phases I II and HI the EPA Removal Program decided to evaluate the area where the higher lead levels were found in residential lots in order to perform an expedited action As a result of this evaluation the EPA Removal Program recommended a time-critical removal action at three properties 5571 Alturas Street 5569 Altura Street and 5460 Los Angeles Street On August 18 1999 the Director of EPA Region 2 Emergency and Remedial Response Division signed an action memorandum to conduct a Comprehensive Environmental Response Compensation and Liability Act (CERCLA) time-critical removal action The removal action which lasted from October 8 1999 to September 2001 consisted of the following tasks

2-4 300657

bull Secured access to each affected property

bull Disconnected and temporarily moved utilities which caused an obstruction

bull Documented and removed other physical obstructions such as animal pens trees shrubs and fences

bull Temporarily relocated the residents at 5460 Los Angeles Street during the demolition of their house as well as during the excavation backfill and rebuild phases

bull Completed the demolition of one residence which presented an obstruction and construction hazard to excavation activities

bull Excavated and disposed of contaminated soil at 5569 and 5571 Alturas Street

bull Conducted post excavation sampling and analysis

bull Backfilled excavated areas at 5569 and 5571 Alturas Street to an appropriate grade

bull Excavated and staged contaminated soil at 5460 Los Angeles Street

Hazard Ranking System Evaluation February 1999 Information gathered during the EQB and EPA investigations was used to perfomi the sites Hazard Ranking System (HRS) Evaluation The HRS score for the site was based largely on the potential threat of a release of hazardous substances to groundwater The soil exposure pathway also contributed to the HRS site score The soil exposure pathway evaluated the likehhood that residents and nearby populations would be exposed to contaminated soil associated with sources at the site The primary driver for the Vega Baja soil exposure pathway score was the detection of inorganics including lead and arsenic at concentrations significantly above background or health-based benchmarks in residential surface soil samples - -- _

NPL Listing Based upon the results ofthe HRS the Site was proposed for the NPL on April 22 1999 and hsted on July 22 1999

Dioxin Sampling Event June 2001 The Lockheed Martin-Response Engineering and Analytical Contract (REAC) Team collected surface soil samples in June 2001 for analysis of dioxins The sampling event was conducted to determine if dioxin is present at the Site in sufficient quantities to be considered a chemical of concern

The final report was presented to EPA in February 2002 (Lockheed Martin-REAC 2002) The report concluded that the residential and undeveloped areas do not warrant any innmediate removal or remedial action for dioxin and that dioxin will not be considered as a chemical of concern

2-5 300658

23 CURRENT CONDITIONS

Currently there are an estimated 213 homes located on 55 acres ofthe 72-acre site in the residential community known as Brisas del Rosario Four garbage mounds are still present within the residential community and an unknown amount of landfill debris may still be present south of the undeveloped area in and around the mogotes

CDM began the OUl groundwater RIFS in September 1999 Field activities started in October 2001 and are currently underway Field work consists of installation of 7 monitoring wells and a sampling program consisting of surface water sediment springseep leachate groundwater subsurface soil and soil gas sample collection CDM will conduct an ecological survey to determine wildlife occurrence and potential exposure pathways and an assessment of the hydrogeologic properties at the site under OUl

2^ 300659

acts as a confining unit to the deeper Cibao aquifer Confining layers are not known to exist within the upper aquifer in the immediate vicinity of the study area

On a regional scale groundwater in the upper aquifer flows northward towards the Atiantic Ocean The unconfined aquifer system is recharged by precipitation in the upland areas to the south which infiltrates down to the water table via surface runoff infiltiation through soils and limestones and by direct runoff into sinkholes Upper aquifer recharge may also occur via leakage from the underlying confined aquifers Groundwater in the upper aquifer discharges to the low-lying areas of the coastal plain arid Atlantic Ocean to the north expressed at the surface and along the sea floor as springs andor seeps The overall net rate of recharge to the upper aquifer is approximately 15 inches per year Given the heterogeneous nature of karst terrain the rate of recharge to the aquifer is likely to be highly variable on a local scale Published potentiometric surface maps of the Aymamon-Aguada aquifer system (as shown in Figure 3-5) suggest a general regional groundwater flow direction towards the north with localized flow directions verging to the northwest and northeast (Conde-Costas and Rodriguez-Rodriguez 1997)

Hydraulic conductivity estimates of the upper aquifer range from 500 feet per day (ftd) to more than 1500 ftd for the Aymamon Formation to approximately 90 ftd for the underlying Aguada Formation (Giusti and Bennet 1976 Torres-Gonzalez and Diaz 1985) Hydraulic conductivity is generally believed to decrease with depth and the lower part the Aymamon Formation is believed to be less permeable than the middle and upper Aymamon Formation Hydraulic gradients are steeper in the Aguada than in the Aymamon reflecting the lower transmissivity of the Aguada Formation (Torres-Gonzalez and Diaz 1985) Specific capacities of wells tapping the Aymamon range from 100 to 1000 gallons per minute per foot of drawdown (Torres-Gonzalez and Wolansky 1984)

Groundwater flow in the NLP karst occurs both as diffuse and conduit or free flow Secondary porosity (ie solution channels) can significantly affect local groundwater flow patterns Predominantly groundwater flow in such karst aquifers is along bedding planes fractures enlarged through solution or large solution channels or conduits When thepreferred flow path is along a conduit in which flow is non-laminar (ie non-darcian) this type of groundwater movement is considered conduit flow As such a karst aquifer can be very heterogeneous the direction of groundwater flow in free-flow aquifers is contiolled by the orientation of the bedding planes and fractures that determine the location of solution conduits Although all void spaces in the limestone reservoir may be saturated the vast majority of groundwater flow is accomplished through turbulent conduit flow

The regional hydraulic gradient is approximately 0045 in the outcrop areas of the less permeable lower Aymamon Formation and Aguada Formation to the south of the Site (Giusti 1978) From there the hydraulic gradient attenuates to plusmn00007 within the Aymamon Formation along the coastal plain The regional water table is nearly flat having only a small elevation above regional base level because of the rapid drainage through the vadose zone The very low regional hydraulic gradient suggests that defuse flow through solution planes and fractures is extremely slow

3-3 300660

3132 Local Hvdrogeolo^

Three monitoring wells (MWOl MW02 and MW03) were installed by Weston-START in 1998 (Weston-START 1998) to assess groundwater quality at the Site MWOl and MW02 were installed north ofthe Site in what were assumed to be downgradient locations and MW03 was installed south ofthe Site in an upgradient location Well data indicate the water table was encountered within the Aymamon Formation at a depth of 200 feet bgs The static water table was approximately 5 feet above mean sea level (amsl) Neither the underlying Aguada Limestone nor the lower confining unit of the Cibao Formation were encountered during drilling The on site surficial soils of unconsolidated clayey-sands likely retard the infiltration of surface water runoff into the aquifer Surface runoff is collected by the on site stormwater management system which discharges stormwater to the Rio Indio via a manmade ditch that crosses the southern portion of the Site

The potentiometric surface within the Sites vicinity was measured by Weston-START in order to construct a water table elevation contour map of the area and define the local groundwater flow direction (Weston-START 1998) Water level measurements were collected from the three Weston-START monitoring wells The contour map indicates a flow direction across the Site to the northwest along a relatively flat hydraulic gradient

Recharge to the water table aquifer at the Site is limited due to the thickness of clay-rich soils that overlie the limestone and due to the density of dwellings and roads which would prevent direct infiltration of precipitation The path that stormwater takes from the surface to the water table is most likely complex As has been shown at the VampM Site less than 5 miles to the south of the Site (CDM 1999) the overburden thickness and elevation of the soilbedrock interface are highly irregular As such the rate of infiltration across the Vega Baja Site is likely to be variable and not easily quantifiable

Secondary porosity (ie solution channels and vugs) in limestone bedrock significantly affects groundwater flow patterns The presence of sinkholes in the Aymamon Limestone which have been identified throughout the NLP suggests that conduit flow through solution channels may be an important groundwater flow mechanism Sinkholes may be present at the Site beneath the natural soils and landfill wastes Solution channels beneath sinkholes would facilitate rapid infiltration of surface runoff through the vadose zone to the water table within the Aymamon Formation

314 DRAINAGE AND SURFACE WATER

The Vega Baja Site is located in the karst belt within the Rio Indio drainage area which is characterized by karst outcrops and closed depressions (sinkholes) Overland drainage on the Site flows into an open drainage ditch The drainage ditch which is estimated to be four to five feet in depth flows through the middle ofthe Site and collects stormwater from the surrounding landfill and residential properties The drainage ditch flows east and subsequently empties into the Rio Indio which is located 066 mile east of the Site

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

The Rio Indio is classified by EQB as a Class SC water body which means its waters are intended for use as a raw water source for water supply The Rio Indio runs south to north and ultimately converges with the Rio Cibuco The Rio Cibuco subsequently empties into the Boca del Cibuco Bay in the Atlantic Ocean Both the Rio Indio and Rio Cibuco are used locally as a recreational fishing areas A surface water intake is located on the Rio Indio 022 mile downstream from the Site drainage ditchs point of entry The water intake is operated by the Puerto Rico Aqueduct and Sewer Authority (PRASA)

CDM will obtain additional drainage and surface water quality data during the course of the field investigation and will incorporate that data into the RI report

315 CLIMATE

The climate for Vega Baja which is located in the north central area of Puerto Rico is classified as tropical marine and is moderated by the nearly constant trade winds that originate in the northeast The average temperature for the area ranges from 23degC in the winter months to 27degC in the summer Regionally annual precipitation ranges from 60 to 70 inches The average evapotranspiration for the region is 45 inches per year Therefore annual groundwater recharge for the area ranges from 15 to 25 inches The one-year 24-hour rainfall for the region is approximately 85 inches

CDM will obtain both historic and current climate data including but not limited to temperature precipitation and wind speed and direction from local meteorological stations Climatic data yill be collected during the course of the field investigation and will be incorporated in the RI report

316 POPULATION AND LAND USE

The Site is located approximately 12 miles south of the Town of Vega Baja and is surrounded by residential areas to the north east and west and is bordered to the south by mogotes The Rio Abajo Head Start School and a baseball park are located 021 mile from the Site It is estimated that 2280 people hve within a one-quarter mile radius while 6871 people live within one mile ofthe Site

Since the 1970s approximately 213 houses have been built on 55 acres of the former landfill Gardens and animal pens have been observed on many of the residential properties Avocados bananas breadfruit lemons oranges and plantains were among the edible crops observed in the residential areas The fruits vegetables and penned animals are a source of food for the residents

CDM will obtain additional up-to-date demographic data during the course ofthe investigation and will incorporate that data in the RI report

32 SUMMARY OF IDENTIFIED CONTAMINATION AT THE SITE

Since the late 1970s until 1999 EQB and more recently EPA have conducted several investigations and limited sampling of groundwater surface water sediment and surface soil to characterize the

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extent of contamination within the landfill and to determine if the site represents a potential threat to human health

321 SOURCES AND DISTRIBUTION OF CONTAMINATION

From 1948 to 1979 the Municipality of Vega Baja used the approximately 72-acre site as an unlined landfill Commercial industrial and domestic waste were dumped andor open-bumed at the Site An estimate of 1108540 cubic yards of waste were disposed andor burned at the site during the 30 years of operation These activities have resulted in the contamination of the site surface soil and sediment

Contamination from the landfill soil is considered an exposure risk at the site and will be evaluated during this RIFS Contamination from the landfill soil also may have migrated vertically down through the vadose zone until it intercepted groundwater at the water table at an estimated depth of approximately 200 feet bgs None of the available groundwater data have indicated the presence of contaminant concentrations above the Federal Drinking Water Standards however the groundwater has not yet been fully characterized CDM is conducting the OUl RIFS to investigate the groundwater at the Site

322 CHEMICAL CHARACTERISTICS OF SOIL

3221 EQB and EPA Investigations

During the SI conducted by EQB in 1994 and subsequent ESI conducted by EQB and Weston-START in 1996 both inorganic and organic contaminants were detected in surface soil samples Napthalene pyrene butyl benzyl phthalate dieldrin bis(2-ethyhexyl)phthalate and Aroclor 1254 were among the organic compounds detected at low concentrations (see Table 3-1) The following contaminants were also detected but at levels below CRDLs benzo(a)pyrene phenanthrene methoxychlor fluoranthene and Aroclor 1260 It should be noted that the locations of the highest detected organicconcentrationswere not-provided in-theSI-or-ESI-reports

Arsenic cadmium copper chromium lead and zinc were among the inorganic analytes that were detected at elevated levels in the surface soil samples collected during the SI and ESI investigations (see Table 3-2) The highest detected concentrations were generally found in areas that cortesponded to the historic landfill bum areas Analytical results indicated lead concentrations up to 3410 ppm and copper concentrations up to 350 ppm in soil samples Other inorganics detected above background levels included barium cadmium nickel iron and magnesium

3222 EPA Removal Action

As part of the Removal Action EPA conducted a soil sampling event at the Site from April 1998 to December 1998 A total of 3693 samples were collected and analyzed over this period These samples were targeted to delineate lead contamination at the Site The results were presented in a

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report titled Final Report Assessment of Soil Lead Contamination Vega Baja Landfill Site dated January 2000 (Lockheed Martin-REAC 2000) No QC evaluation was performed on the data presented in this report therefore the analytical results presented in this section are considered unvalidated

Subsequent to the completion of the lead assessment task EPA requested the Lockheed Martin-REAC Team to analyze a subset of the soil samples stored at REAC laboratories for arsenic Arsenic was found site-wide at concentrations exceeding regulatory screening criteria Arsenic ranged from 3 ppm to 140 ppm at surface soil in the residential area Even though this data does not meet all Quality AssuranceQuality Control (QAQC) standards it is considered adequate for screening purposes and can be used to develop the sampling approach for the soil RIFS investigation The sampling event was divided into three phases

Phase I The Phase I sampling area consisted of the residential area south of Route 22 and east of Trio Vegabajeno Avenue terminating on Calle Progreso to the east and included the wooded areas to the south A total of 814 soil samples were collected and analyzed for lead using XRF methodology Figure 3-6 presents the highest detections in surface soil samples (05 -1 foot bgs) and Figure 3-7 presents the highest detections in subsurface soil samples (gt 2 feet bgs) Lead concentrations across the Site ranged up to 14000 milligrams per kilogram (mgkg) or ppm The highest lead concentration found in the residential area was 2600 mgkg at 05 foot depth In the residential area lead concentration generally decreased with depth (ie at 2 ft depth the lead concentrations were below 400 mgkg) The area where the highest lead levels were found extends from the undeveloped area to the intersection of Trio Vegabajeno Avenue and Calle Alturas

Soil samples collected from the drainage ditch bottom had very low lead levels (not detectable to 42 mgkg) However samples collected from thei sides of the ditch had lead levels ranging from 220 mgkg to 1100 mgkg EPA indicated that lead levels on the drainage ditch sides are reflective of soil levels and are expected to remain constant However those on the drain bottom are expected to be renewedcontinuously with rainfall soil erosion-and deposition

Ten percent of the soil samples were sent to the REAC Laboratory in Edison New Jersey for confirmation of XRF results or for XRF analyses along with other TAL metals excluding mercury selenium and thallium (Lockheed Martin-REAC 2000) Unvalidated data shows lead concentiations up to 24000 mgkg copper concentrations up to 24000 mgkg arsenic concentrations up to 190 mgkg and chromium concentrations up to 390 mgkg Other metals detected above detection limits included antimony cadmium iron manganese nickel and zinc

The XRF confirmation samples were also analyzed for volatile organic compounds (VOCs) baseneutral acids (BNAs) and pesticidespolychlorinated biphenyls (PCBs) Trace amounts of the following VOC compounds were found toluene xylenes ethylbenzene styrene trichlorofluoromethane acetone and butanone Traces of BNAs including bis(2-ethylhexyl phthalate) butylbenzyl phthalate di-n-octylphthalate di-n-butylphthalate and diethylphthalate were

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also found in a number of samples at concentrations up to 92000 micrograms per kilogram (pgkg) However a phthalate compound was also found in the laboratory blank on May 7 1998

A total of 72 soil samples were analyzed for pesticides and PCBs Dieldrin was the pesticide detected most frequently and with the highest concentrations Dieldrin was detected in 20 samples at concentrations ranging up to 2900 pgkg Other pesticides detected include dichlorodiphenyltrichloroethene (DDT) chlordane and heptachlor epoxide Ofthe PCBs weathered Aroclor 1254 was detected in nine samples at concentrations up to 360 pgkg Aroclor 1248 was detected in two samples at a maximum concentration of 900 pgkg and Aroclor 1260 was detected in two samples at a maximum concentration of 600 pgkg The pesticidePCB detections were found in the southern section of the site and correlate with the occurrence of garbage

Phase II During this phase lead concentrations from XRF analysis methods at the residential area ranged from non-detect to 7100 ppm at 1 feet bgs Figure 3-8 presents the highest detections in surface soil samples ( 0 - 2 feet bgs) An extensive area in the residential development with high lead concentration was identified in the southwestern section ofthe Site Other areas with pockets of elevated lead concentration were found in the northeast section of the Site

Sixty soil samples were sent to a subcontract laboratory for lead analysis via the Toxicity Chemical Leachate Procedure (TCLP) These samples were split from the XRF samples and were selected after XRF analysis to represent a range of lead concentrations above 400 mgkg Lead TCLP concentrations ranged from not detect to 334 milligrams per liter (mgL) However the 334 mgL concentration appears to be an anomaly since the next highest TCLP number is 065 mgL The Resource Conservation and Recovery Act (RCRA) threshold limit for the characteristic of toxicity for lead is 5 mgL None of the samples analyzed surpassed the TCLP RCRA threshold limit

Phase III During the sampling of the four garbage mounds in the residential area lead was detected at concentrations up to 2900 mgkg Figure 3-9 presents the highest XRF sampling results The highest concentrations were found in garbage mound 1 where the garbage was the thickest (over 10 feet) Ten percent of the XRF cups were analyzed using the Inductively Coupled Argon Plasma (ICAP) technique for confirmation of the XRF results

Based upon the validated data from the three-phased Removal Action Investigation EPA determined that there are 5 contaminants of potential concern (COPCs) at the Site lead chromium arsenic dieldrin and PCB In addition 39 houses have been identified for further investigation for lead risk from exposure to soils

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323 CHEMICAL CHARACTERISTICS OF GROUNDWATER

The extent of site related groundwater contamination is not known at this time Groundwater is being investigated and seven new monitoring wells will be installed and sampled as part ofthe OUl RIFS for the Site

324 CHEMICAL CHARACTERISTICS OF SURFACE WATER AND SEDIMENT

The extent of surface water and sediment contamination is being investigated as part of the OUl RIFS for the Site

Arsenic chromium copper lead nickel and zinc were among the inorganics detected in the sediment samples during the SI and ESI investigations The highest concentrations of copper and nickel were detected in samples collected from the Rio Indio surface water intake area The highest chromium lead and zinc concentrations were collected from the Las Margaritas Ditch It is unclear from the ESI where the Las Margaritas Ditch is located Organic results were not provided in the investigation reports therefore they could not be tabulated for inclusion in this document

325 SITE CONCEPTUAL MODEL

The conceptual site model is a framework within which the environmental pathways of potential concern are identified and illustrated The model includes a set of hypotheses about the contaminated media and environmental pathways that are selected on the basis of existing data and site understanding The source areas are identified as those areas of waste deposition

A contaminant release mechanism is defined as a process that results in migration of a contaminant from a source area into the immediate environment Once in the environment contaminants can be tiansferred between media and transported away from the source andor site

3251 Physical Setting with Respect to Soil Contamination

The Site is part of the doline karst terrain ofthe North Coast Limestone Province The topography ofthe region is characterized by the presence of large-scale karst weathering and dissolution features including closed drainage depressions sinkholes (dolines) and rugged limestone hills (mogotes)

Figure 3-10 illustrates the current scenario and potential pathways that could be affected by release of the source material within the landfill The main exposure risk to the residents is from surface soil contaminated with metals pesticides and PCBs Potential exposure to the residents may occur by reworking the existing garbage mounds and excavating deeper soils Groundwater and surface water contamination are possible through leaching and runoff mechanisms The extent of contamination in the undeveloped area to the south has not been delineated and may pose a risk to trespassers and future users of this area Currently no institutional controls are in place to prohibit this area from being developed for residences For the most part data collected during this RI will

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be used to characterize the current nature and extent of contamination to support the human health risk assessment and the FS

3252 Expected Fate and Transport of Site Contaminants in Relation to Residential Exposure

The following are the probable release mechanisms for contaminants

bull Direct contact People directiy in contact with the surface soil material can be exposed through ingestion and dermal contact Residents and workers may also be exposed to contaminated subsurface soil if it is brought to the surface (eg if the material from the remaining mounds in the residential area are moved for landscaping additional construction or excavation during redevelopment activities in the undeveloped area)

bull Leaching Contaminants may leach from the source (landfill) into surrounding soil and groundwater

The potential ramifications resulting from the probable release mechanisms discussed above have been identified as follows

bull Contaminated offsite sediment and surface water It is possible that leachate has migrated offsite to contaminate sediment and surface water in downgradient surface water bodies (ie Rio Indio)

bull Contaminated offsite groundwater It is possible that contaminants have leached into the groundwater from contact with landfill materials and have the potential to reach Vega Baja public water supply wells

bull Contaminant tiansport pathways such as direct air transport downwind soil gas migration and biomagnification in the food chain

33 PRELIMINARY IDENTIFICATION QF APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)

This section provides a preliminary determination of the federal and Commonwealth environmental and public health requirements that are ARARs for the Vega Baja Site In addition this section presents an identification of federal and Commonwealth criteria advisories and guidance that could be used for evaluating remedial alternatives

331 DEFINITION OF ARARs

The legal requirements that are relevant to the remediation of the Vega Baja Site are identified and discussed using the framework and terminology of CERCLA as amended 42 United States Code

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(USC) Section 9601-96-75 These acts specify that Superfund remedial -actions must comply with the requirements and standards of both federal and Commonwealth environmental laws

The EPA defines applicable requirements as those cleanup standards standards of control and other substantive requirements criteria or limitations promulgated under federal environmental or state environmental or facility siting laws that specifically address a hazardous substance pollutant contaminant remedial action location or other circumstance at a CERCLA site An applicable requirement must directly and fully address the situation at the Site

The EPA defines relevant and appropriate requirements as those cleanup standards standards of control or other substantive requirements criteria or limitations promulgated under federal environmental or Commonwealth environmental or facility siting laws that while not applicable to a hazardous substance pollutant contaminant remedial action location or other circumstance at a CERCLA site address problems or situations sufficiently similar to those encountered at the CERCLA site that their use is well suited to the particular site

Actions must comply with Commonwealth ARARs that are more stringent than federal ARARs Commonwealth ARARs are also used in the absence of a federal ARAR or where a Commonwealth ARAR is broader in scope than the federal ARAR In order to quahfy as an ARAR Commonwealth requirements must be promulgated and identified in a timely manner Furthermore for a Commonwealth requirement to be a potential ARAR it must be applicable to all remedial situations described in the requirement not just CERCLA sites

ARARs are not currently available for every chemical location or action that may be encountered For example there are currenfly no ARARs which specify clean-up levels for soils When ARARs are not available remediation goals may be based upon other federal or Commonwealth criteria advisories and guidance or local ordinances In the development of remedial action alternatives the information derived from these sources is termed To Be Considered (TBCs) and the resulting requirements are referred to as TBCs EPA guidance allows clean-up goals to be based upon non-promulgated criteria and advisories such asreferenee doses when ARARs do not exist orwhen an ARAR alone would not be sufficientiy protective in the given circumstance

By contiast there are six conditions under which compliance with ARARs may be waived Remedial actions performed under Superfund authority must comply with ARARS except in the following circumstances (1) the remedial action is an interim measure or a portion of the total remedy which will attain the standard upon completion (2) compliance with the requirement could result in greater risk to human health and the environment than alternative options (3) compliance is technically impractical from an engineering perspective (4) the remedial action will attain an equivalent standard of performance (5) the requirement has been promulgated by the Commonwealth but has not been Consistentiy applied in similar circumstances or (6) the remedial action would disrupt fund balancing

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Potential A R A R S and TBCs are classified as chemical action or location specific Chemical-specific ARARs or TBCs are usually health or risk-based numerical values or methodologies which when applied to site specific conditions result in the establishment of numerical values These values establish the acceptable amount or concentration of a chemical that may be found in or discharged to the ambient environment Location-specific ARARs or TBCs generally are restrictions imposed when remedial activities are performed in an environmentally sensitive area or special location Some examples of special locations include floodplains wetlands historic places and sensitive ecosystems or habitats Action-specific ARARs or TBCs are restrictions placed on particular treatment or disposal technologies Examples of action-specific ARARs are effluent discharge limits and hazardous waste manifest requirements

332 CONSIDERATION QF ARARs DURING THE RIFS

ARARs are used to determine the necessary extent of cleanup to scope and formulate remedial action alternatives and to govern the implementation of the selected alternative The different ARAR classifications are considered at various points in a RIFS Chemical-specific ARARs are used early in the development of specific remediation goals Location-specific ARARs may be developed throughout the study Action-specific ARARs are addressed in the detailed evaluation of remedial alternatives and the selection of a preferred remedy

Specifically ARARs (ARARs here includes TBCs) will be considered during the following intervals of the RIFS process

bull Scoping of the RIFS Chemical action and location-specific ARARs will be identified on a preliminary basis

bull Site characterization and risk assessment phases of the RI Chemical and location-specific ARARs will be identified comprehensively and will be refined to determine site cleanup goals

bull Development of remedial alternatives in the FS report Action-specific ARARs will be identified for each of the proposed alternatives and will be considered along with other ARARs

bull Detailed evaluation of alternatives in the FS reports All potential ARARs identified up to this point will be examined to specifically identify a package of ARARs for each alternative Each alternative will be evaluated to determine what is required to achieve compliance with the package of ARARs

bull Selection of remedy Compliance with identified ARARs is used as a criterion for the selection of aremedial alternative If necessary the provisions forthe waiver of ARARs will be considered

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bull Remedial design All technical specifications of the remedial design and proposed construction will be evaluated to ensure compliance with action-specific ARARs

As the RIFS process continues the list of ARARs will be updated particularly as guidances are issued by state and federal agencies ARARs will be used as a guide to establish the appropriate extent of site cleanup to aid in scoping formulating and selecting proposed treatment technologies and to govern the implementation and operation of the selected remedial alternative Primary consideration should be given to remedial alternatives that attain or exceed the requirements ofthe identified ARARs Throughout the RIFS ARARs are identified and utilized by taking into account the following

bull Contaminants suspected or identified to be at the site bull Chemical analysis performed or scheduled to be performed bull Types of media (air soil ground water surface water and sediment) bull Geology and other site characteristics bull Use of site resources and media bull Potential contaminant tiansport mechanisms bull Purpose and application of potential ARARs and bull Remedial alternatives considered for site cleanup

333 PRELIMINARY IDENTIFICATION OF POTENTIAL ARARs FOR THE VEGA BAJA SITE

The National Contingency Plan (NCP) of 199040 CFR Part 300 and the Superfund Ammendments and Reauthorization Act (SARA)CERCLA Compliance Policy guidance define applicable requirements as the federal and Commonwealth requirements for hazardous substances which would be legally binding at the Site if site response were to be undertaken Relevant and appropriate requirements are defined as those federal and Commonwealth requirements that while not directly applicable apply to facilities or problems similar to those encountered at this Site In other words requirements may be-relevant and appropriate if they would be apphcable except for jurisdictional restrictions associated with the requirements With respect to the selection of remedial alternatives relevant and appropriate requirements are to be afforded the same weight and consideration as applicable requirements

The list of potential ARARsTBCs identified in this section will be reviewed throughout the RIFS process to ensure that they are still relevant to the remedial measures They will be reviewed to identify additional ARARsTBCs that may be appropriate due to additional information gained regarding the Site or new guidance issued by federal or Commonwealth agencies Brief discussions of key potential ARARsTBCs that are relevant to soil contamination are provided below

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3331 Chemical-Specific Potential ARARs

Chemical-specific ARARS which may be considered are listed below

Federal

bull National Ambient Air Quality Standards (NAAQC)(40 CFR 50)

bull RCRA Toxicity Characteristic Leaching Procedure (TCLP) and Land Ban Requirements for Landfilling (40 CFR 261)

bull Lead-Based Paint Hazards (40 CFR Part 475 Section 74565)

Commonwealth

bull Regulations for the Control of Lead-Based Paint Mitigation Activities PR EQB Chapter VH Rule 1570 Cleanhness Levels

3332 Action-Specific Potential ARARs

Action-specific ARARS which may be considered are listed below

Federal

bull RCRA Subtitle G Hazardous Waste Treatment Facility Design and Operating Standards for Treatment and Disposal Systems (ie landfill incinerators tanks containers etc) (40 CFR 264 and 265) (Minimum Technology Requirements) RCRA Subtitle C Closure and Post-Closure Standards (40 CFR 264 Subpart G) RCRA Ground Water Monitoring and Protection Standards (40 CFR 264 Subpart F) RCRA Manifesting Transport and Recordkeeping Requirements (40 CFR 262) RCRA Wastewater Treatment System Standards (40 CFR 264 Subpart X) RGRA Corrective Action (40 CFR 264101) RCRA Storage Requirements (40 CFR 264 40 CFR 265 Subparts I and J) RCRA Subtitie D Nonhazardous Waste Management Standards (40 CFR 257) Off-Site Transport of Hazardous Waste (EPA OSWER Directive 983411) RCRA Excavation and Fugitive Dust Requirements (40 CFR 264251 and 264254) RCRA Land Disposal Restrictions (40 CFR 268) (On and off-site disposal of excavated soil) Clean Water Act - NPDES Permitting Requirements for Discharge of Treatment System Effluent (40 CFR 122-125) National Emission Standards for Hazardous Air Pollutants (NESHAPs) (40 CFR 61) Department of Transportation (DOT) Rules for Hazardous Materials Transport (49 CFR 1071711-171500) Occupational Safety and Health Standards for Hazardous Responses and General Construction Activities (29 CFR 190419101926)

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bull Fish and Wildlife Coordination Act (16 UC 661 et seg) (Requires actions to protect fish or wildlife when diverting channeling or modifying a stream)

bull Federal Occupational Safety and Health Administration Standards for Hazardous Responses and General Construction Activities (29 CFR 1904 1910 1926)

bull Federal Noise Control Act (42 USC 4901 et seq)

Commonwealth

bull Puerto Rico EQB Regulation for the Control of Atmospheric Pollution 1995 bull EQB Regulation forthe Control of Hazardous and Non-Hazardous Waste 1982 as amended

198519861987 bull EQB Underground Storage Tank Contiol Regulations 1990 bull EQB Regulations for the Control of Noise Pollution

3333 Location-SpeciHc Potential ARARs

Location-specific ARARs which may be considered during the Vega Baja RIFS are listed below

Federal

Endangered Species Act of 1973 (16 USC 1531) (Generally 50 CFR Parts and 402) Executive Order on Wetlands Protection (CERCLA Wetlands Assessments) No 11990 Historic Preservation Act (16 USC 470) Section 106 et seq (36 CFR National 800) RCRA Location Requirements for 100-year Floodplains (40 CFR 26418(b)) Fish and Wildlife Coordination Act (16 USC 661 et seq) Wetlands Construction and Management Procedures (40 CFR 6 Appendix A) Farmland Protection Pohcy Act of 1981 (7 USC 4201 et seq) Executive Order 11990 (Protection of Wetlands)

When ARARs do not exist for a particular chemical or remedial activity or othercriteria advisories and Guidance (TBCs) may be useful for designing and selecting a remedial alternative The following criteria advisories and guidance were developed by EPA and other federal agencies

Federal TBCs (Action Location and Chemical-Specific)

bull Proposed Requirements for Hybrid Closures (combined waste-in-place and clean closures) (52 Federal Register 8711)

bull EPA Health Effects Assessment (HEAs) bull Toxic Substances Control Act (TSCA) Health Data bull Toxicological Profiles Agency for Toxic Substances and Disease Registry US Public

Health Service bull Cancer Assessment Group (National Academy of Science) Guidance bull Fish and Wildlife Coordination Act Advisories

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bull EPAs soil screening levels in the Soil Screening Guidance Users Manual dated April 1996

Commonwealth

bull EQB Guidelines for Environmental Impact Statements bull Puerto Rico Department of Natural and Environmental Resources Critical Element and

Endangered Species Database 1998

The presently identified potential location-specific ARARsTBCs will be reviewed throughout the investigation to identify additional ARARsTBCs that may be appropriate due to additional information gained regarding the Site

34 PRELIMINARY HUMAN HEALTH RISK ASSESSMENT

This section presents the Preliminary Human Health Risk Assessment for the Vega Baja Soils and is based on historical site information and available analytical results for surface and subsurface soil COPCs source areas and release mechanisms receptors exposure pathways and additional data needs are discussed in the following subsections

341 CHEMICALS QF POTENTIAL CONCERN

As discussed in Section 32 EPA has preliminarily identified five chemicals of potential concern associated with site soils lead arsenic chromium dieldrin and PCBs Lead concentrations in soils were particularly high ranging up to 14000 mgkg (Lockheed Martin-REAC 2000) for samples analyzed using field XRF and up to 24000 mgkg in the confirmation samples analyzed in the laboratory While contamination has also been found in groundwater surface water and sediment risks associated with contamination of those media are being evaluated in a separate RI A full screening of the soils RI data to select COPCs will be conducted as part of this HHRA using the criteria outlined in Section 57

342 POTENTIAL SOURCE AREAS AND EXPOSURE PATHWAYS

As discussed in Section 32 former use of the site for waste disposal contributed to the contamination observed in soil Onsite source areas include waste that remains in the undeveloped (ie nonresidential) area and in the mounds in the residential area as well as the historic landfill bum areas

Several potential receptors are associated with the Vega Baja Site As discussed previously the 72-acre Vega Baja property currently includes a residential area (approximately 55 acres) and a heavily-vegetated undeveloped area The land surrounding the Vega Baja property is residential consisting of single and multi-family houses The site itself is zoned for residential use though the municipality has expressed interest in developing the unused portion for commercial purposes Based

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on these land uses the most likely current and future receptors for site-related contamination in the developed residential area are current and future residents and future construction workers The most likely current receptors for the undeveloped area are trespassers while the most likely future receptors for that area include residents workers and construction workers Pathways of potential concern at the site have been identified and are presented below

3421 Surface Soil Pathways

Surface soil sampling has been conducted at the site Inorganic pesticide and PCB contamination was found in the samples Surface soil sampling will be performed at the Vega Baja site during the RI both in the residential area and in the undeveloped portion of the former landfill

In the residential area current and future residents may be exposed to contaminated surface soil via ingestion and dermal contact Future construction workers may be exposed to contaminated surface soil during excavation (eg during any redevelopment activities) via ingestion and dermal contact

In the undeveloped area current trespassers may be exposed to contaminated surface soil via ingestion and dermal contact If this portion of the site is developed for commercial or residential use in the future future construction workers may be exposed to contaminated surface soil during excavation via ingestion and dermal contact Future residents or future workers (which receptor will depend on how the site is developed) may be exposed to contaminated surface soil via ingestion and dermal contact

3422 Subsurface Soil Pathways

Subsurface soil sampling has been conducted at the site Inorganic pesticide and PCB contamination was found in the samples Subsurface soil sampling will be performed at the Vega Baja site during the RI both in the garbage mounds in the residential area and in the undeveloped portion of the former landfill

In the residential area future residents may be exposed to contaminated subsurface soil if it is brought to the surface (eg if the material from the remaining mounds in the residential area are moved for landscaping or additional construction) Future construction workers may be exposed to contaminated subsurface soil during excavation via ingestion and dermal contact

If the undeveloped area is developed for commercial or residential use in the future future construction workers may be exposed to contaminated subsurface soil during excavation via ingestion and dermal contact Future residents or future workers depending on how the site is developed may be exposed to contaminated subsurface soil via ingestion and dermal contact

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343 SUMMARY OF ADDITIONAL DATA NEEDS

Previous investigations of the site have not provided sufficient environmental samphng data to characterize the potential risks to human receptors Soil contamination has been found but the extent of the contamination has not been fully determined Only a limited number of samples were analyzed for contaminants other than lead

While a significant number of samples were collected and analyzed for lead in previous investigations the data quality was not adequate for use in the risk assessment In addition lead concentrations in household dust and tap water are needed to model potential blood lead levels in children at the residences with elevated lead concentrations in soil Additional data will be collected during the RI for use in the Baseline HHRA

35 PRELIMINARY IDENTIFICATION OF REMEDIAL ACTION ALTERNATIVES

Previous investigations identified the soil at the site is contaminated by lead and potentially other contaminants However the nature and extent of contamination have not been fully characterized Preliminary remedial action objectives identified for this site based on existing information are

bull Prevent ingestion and direct contact with soil which has contaminants of potential concern concentrations greater than preliminary remediation goals (PRGs) to be determined during the Feasibility Study

bull Minimize the potential for off-site migration of contaminants of potential concern with concentrations which exceed the PRGs

bull Minimize the potential for tiansfer of contaminants to other media (eg groundwater) at concentrations in excess of applicable ARARs

o 0 3 0 0 6 7 5

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TABLE 3-1

SURFACE SOIL RESULTS ( 0-2) FROM SI AND ESI ORGANIC COMPOUNDS

VEGA BAJA SOLID WASTE DISPOSAL SITE VEGA BAJA PUERTO RICO

[ Compound

Naphthalene

Pyrene

Butyl benzyl phthiate

Di-n-butyl phthiate

Bis (2-ethylhexyl) phthalate

Dieldrin

[Aroclor-1254

Range of Detection

ND-22J

ND-22J

ND-73J

ND-28J

ND-65

ND-36

ND-15

Location of Highest Detection

ESI 1997

ESI 1997

ESI 1997

ESI 1997 1

ESI 1997

ESI 1997

ESI 1997

Notes

All units in mgkg Includes results from the EQBSTART SI and ESI reports (1995-1997) ESI - Extended Site Investigation - Includes only those detections of 1 mgkg or greater - Location of highest organic detection not provided in ESI report ND - Not Detected J - Estimated Value

3 0 0 6 7 6

TABLE 3-2

SURFACE SOIL RESULTS ( 0-2) FROM SI AND ESI INORGANIC ANALYTES


Analyte

Arsenic

Antimony

Cadmium

Chromium

Copper

Lead

Mercury

Nickel

Zinc

Range of Detection

ND-541J

ND-432J

ND-207

ND-266

ND-3600

ND-26300

ND-17

ND-287J

ND-3860


5443 Calle Roberto Clemente

527 Ave Trio Vegabajeno

5563 Calle Arturas


5782 Los Ortiz

5462 Santa Maria

5378 Santa Maria

5153 Calle Principal


Notes

All units in mgkg Includes sample results from the EQBSTART SI and ESI reports (1995-1997) ND - Not Detected J - Estimated Value

3 0 0 6 7 7

6715

1830

1800 mdash

Rlnc6n

6700 4 5 30

T 15

T eeoo

ATLANTIC OCEAN

Arecibo Barceloneta

SHJDY AREA OF MANAlt QUAORANQLE

45 6530

QUATERNARY

MIOCENE

EXPLANATION

SURFICIAL DEPOSITS ALLUVIUM MARSH SWAMP EOLIAN AND TERRACE

CAMUY FORMATION

AYMAM6NI UMESTONE

AGUADA (LOS PUERTOS) LIMESTONE

MIOCENE AND OUQOCENE

OUGOCENE

CIBAO FORMATION INCLUDING UNDIFFERENTIATED MONTEBEIXO QUEBRADA ARENAS AND RiO INDIO UMESTONE MEMBERS

MUCARABONES SAND

I I 1 I M bull 1

-w LARES LIMESTONE

SAN SEBASTIAN FORMATION

(adapted from Conde-Costas and Rodriguez 1997)

CDM

Figure 3-1 GENERALIZED GEOLOGIC MAP OF THE

NORTH COAST LIMESTONE REGION PUERTO RICO Remedial InvestigationFeasibility Study

Vega Baja Solid Waste Disposal Site Puerto Rico

8Z900e

EPOCH MONROE (1980) SEIGLIE AND MOUSSA (1980)

ROIIRIOUEZMARTINEZ (1995)

PLIOCENE QUEBRADILUS UMESTONE

UJ

LU o o

CAMUY FORMATION

AYMAMON LIMESTONE

LOS PUERTOS UMESTONE

LU z m o O CD

AYMAMON UMESTONE

EARLY AGUADA UMESTONE

CIBAO UMESTONE AYMAMON LIMESTONE AGUADA UMESTONE

LATE

o

o m a O

UPPER MEMBER

Montebello Umestone Member

Quebrada Arenas

Umestone Member and

RIo Indio Umestone Members

LARES UMESTONE

LOWER MONTEBEUO EQUIVALENTS IN TIME

LARES UMESTONE

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE

MIDDLE 1 ^

SAN SEBASTIAN


^ ^ -


Source Rodrigucz-Mutinez 1993

CDM

Figure 3-2 STRATIGRAPHIC COLUMN OF MIDDLE TERTIARY AGE

NORTH COAST LIMESTONES PUERTO RICO Remedial InvestigationFeasibility Study


ly 0

600

1000 J 35000

_ _ J 30000 25000

-L J_ J_ 20000 15000 10000

DISTANCE FROM SEA IN FEET

I 5000

EXPLANATION

^gt$^ltj LOWER ZONE OF AYKIAM6N UMESTONE

mdash mdash APPROXIMATC LOCATION OF GEOLOGIC CONTACT

I J J

O O O l 00 O


CDM

Figure 3-3 GENERALIZED HYDROGEOLOGIC CROSS SECTION

ACROSS THE MANATI QUADRANGLE PUERTO RICO Remedial InvestigationFeasibility Study


RiB Path cVBga_ba|a^gls^vBga_baja_flguâsap^

663000 662230 183000

Atlantic Ocean Pta chivato ^

Pg^Boquilla A

182500

182230

Pta Puerto Nulaquoyo

Basa fmm US Qsdogical Sunny Puerto Rico a tstas Umitiofes 19S1

5 KILOMETERS

5 IVIILES

EXPUNATION

bull30-

^

POTENTIOMETRIC-SURFACECONTOUR-Altltude of water-table In meters above mean sea level datum Contour interval 15 meters

INFERRED GROUND-WATER FLOW DIRECTION


a3M

Figure 3-5 POTENTIOMETRIC SURFACE MAP OF THE

AYMAMON-AGUADA AQUIFER SYSTEM (March 1995) Remedial InvestigationFeasibility Study


w o

o en 00 lO

300683

File Palh cvega_baiagisvega_baia_figures3pr

m h

1500 ppm

LEGEND EMI Houses EH] Mounds EZI Yards

0 200 400 Feet

Figure 3-9 Locations of Highest XRF Lead Results at Each Trash Mound - Phase III REAC Remedial InvestigationFeasibility Study


300684

VEGA BAJA

PUBLIC SUPPLY WELLS

POTENTIAL RISK TO SURFACE WATER FROM CONTAMINED RUNOFF

B E I N G INVESTIGATED UNDER O u A ^ bullGROUNDWATER RIFS

POTENTIAL RISK TO RESIDENTS FROM SOIL CONTAMINED WITH METALS PESTICIDES AND PCBs

SOUTHERN CONTAMINATION EXTENT UNKNOWN

Not To Scale

LEGEND

m POTENTIAaY CONTAMINATED LANDFILL SOIL

UMESTONE BEDROCK V

SOIL

WATER TABLE

GARBAGE MOUNDS

bull RESIDENCES

OJ

o o ogt 00 Ul CDM

Figure 3-10 SITE CONCEPTUAL MODEL


40 WORK PLAN RATIONALE

41 DATA OUALITY OBTECTIVES

Data quality objectives (DQOs) are qualitative and quantitative statements that translate nonshytechnical project goals into technical project-specific decision goals They are derived from the regulatory objectives ofthe environmental program that the data will eventually support DQOs are based on the end uses of the data collected The data quality and level of analytical documentation necessary for a given set of samples will vary depending on the intended use of the data

As part of the Work Plan scoping effort site-specific remedial action objectives were developed Sampling data will be required to evaluate whether or not remedial alternatives can meet the objectives The intended uses of these data dictate the data confidence levels Data confidence levels will be determined and presented in the QAPP Addendum The guidance document Guidance for Data Quality Objectives Process EPA QAG-4 (EPA August 2000) was used to determine the appropriate analytical levels necessary to obtain the required confidence levels The three levels are screening data with definitive level data confirmation definitive level data and measurement-specific requirements (see Table 4-1)

The applicability of these levels of data will be further specified in the QAPP Addendum The data quality objectives will

bull Clarify the study objective bull Define the most appropriate type of data to collect bull Determine the most appropriate conditions from which to collect the data bull Specify acceptable levels of decision errors that will be used as the basis for establishing the

quantity and quality of data needed to support the design

Sampling and analytical data quality indicators such as precision accuracy representativeness corriparability completeness and sensitivity will be defined in the QAPP Addendum

42 WORK PLAN APPROACH

The remedial action objectives for the OU 2 - Soils RIFS for the Vega Baja Sohd Waste Disposal Site include contamination-source identification risk assessment and evaluation of remedial alternatives The field investigation activities will be planned to generate data to support the remedial action objectives Screening level and definitive level data will be required for these RI activities

The overall goals of the RIFS are

bull Define the nature and extent of soil contamination related to the Vega Baja Site The sampling program to achieve this goal is described in Section 53 Field Investigation

4-1 300686

I m I 4-1

Sl MM kN OI I) M V y i M l I I bull H s IMgtUltgtIgtKI 11 I OUl I S SI S

r ( r B r s ( ) i IDW s i i i)isigtc)si s r n l ( l i l PI F K I O R K O

1 4

-laquoc

DATA USES ANALYTICAL LEVEL TYPE OF ANALYSIS

Site Characterization Monitoring During Implementation Evaluation of Alternatives Engineering Design

SCREENING LEVEL WITH DEFINITIVE LEVEL CONFIRMATION

Total OrganicInorganic Vapor Detection Using Portable Instruments

Water Quality Field Measurements using Portable Instruments

Risk Assessment Site Characterization Monitoring During Implementation Evaluation of Alternatives Engineering Design

DEFiNrrrvE LEVEL

OrganicsInorganics using EPA-approved methods Mcludes CLP SOWs in addition to standard solid waste and water analyses

Analyses perfonned by laboratory

Site Characterization Engineering Design Evaluation of Alternatives

Field Instrument (see Note 1)

Measurements from field equipment Qualitative measurements

1 Measurement-specific requirements are defined in the QAPP and technical specifications

w o o crgt 00 bull J

RACS II WA 005 Disk lwptab4-Iwpd

50 TASK PLANS

The tasks identified in this section correspond directly to those in EPAs Statement of Work (SOW) forthe Vega Baja Solid Waste Disposal Site Soil RIFS dated September 282001 Of these sixteen tasks the tasks for the RIFS presented below correspond to the twelve tasks presented in the Interim Final Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA (EPA 1988a) Of these twelve RIFS tasks nine are considered part of the RI and three are part of the FS In addition EPAs SOW included tasks for post RIFS support and project close-out The order in which these tasks are presented and the task numbering scheme correspond to the work breakdown structure provided in EPAs SOW

51 TASK 1 - PROJECT PLANNING AND SUPPORT

The project planning task generally involves several subtasks that must be performed in order to develop the plans and the corresponding schedule necessary to execute the RIFS These subtasks include project administration conducting a site visit performing a review and detailed analysis of existing data attending technical meetings with EPA and other support agencies (USGS EQB) preparing this RJFS Work Plan preparing the QAPP and HSP addendums and procuring and managing subcontractors

511 PROJECT ADMINISTRATION

The project administration activity involves regular duties performed by the CDM Site Manager (SM) and the Program Support Office throughout the duration ofthis work assignment CDM will provide the following project administration support in the performance of this work assignment

The Site Manager will

Prepare the technical monthly report Review weekly financial reports Review and update the project schedule Attend quarterly internal RAC II meetings Communicate regularly (at least weekly) with the EPA Remedial Project Manager (RPM) Prepare staffing plans

The Program Support Office personnel will

Review the Work Assignment Technical and Financial Status Prepare reports for the Monthly Progress Report Provide technical resource management Review the work assignment budget Respond to questions from the EPA Project Officer and Contracting Officer Prepare and submit invoices

300688 5-1

512 ATTEND SCOPING MEETING

Following the receipt ofthis work assignment on September 282001 the CDM SM the CDM RAC n Program Manager CDM RI Task Leader and the CDM RAC II Technical Operations Manager (TOM) participated in a scoping meeting with the EPA Contracting Officer the EPA Project Officer and the EPA RPM on November 28 2001

513 CONDUCT SITE VISIT

A site visit was conducted on December 5 2001 and included the EPA RPM CDM SM and Risk Assessor The purpose ofthe site visit was to determine the technical scope for 0U2 field activities and the HHRA

514 DEVELOP DRAFT WORK PLAN AND ASSOCIATED COST ESTIMATE

CDM has prepared this RIFS Work Plan in accordance with the contract terms and conditions CDM used information from EPA guidance documents (as appropriate) and technical direction provided by the EPA RPM as the basis for preparing this RIFS Work Plan

This Work Plan includes a comprehensive description of project tasks project documentation and project schedule CDM uses internal QAQC systems and procedures to assure that this work plan and other deliverables are of professional quality requiring only minor revisions (to the extent that the scope is defined and is not modified) Specifically the Work Plan includes the following

bull Identification of RIFS project elements including planning and activity reporting documentation A detailed work breakdown structure of the RIFS that corresponds to the work breakdown structure provided in the EPA SOW dated September 28 2001

bull CDMs approach for each task to be performed including a detailed description of each task the assumptions used any information to be produced during and at the conclusion of each task and a description of the work products that will be submitted to EPA Issues relating to management responsibilities site access site security contingency procedures and storage and disposal of investigation derived wastes will also be addressed

bull A schedule with dates for completion of each required activity critical path milestones and submission of each deliverable required by the SOW and the anticipated review time for EPA (see Section 7)

bull A list of key CDM personnel that will support the project (see Section 8) and the subcontractor services required to complete the work assignment (see Section 5111)

300689 5-2

515 NEGOTIATE AND REVISE DRAFT WORK PLANBUDGET

CDM personnel will attend a work plan negotiation meeting at the specified EPA Region II office in person or via teleconference EPA and CDM personnel will discuss and agree upon the final technical approach and costs required to accomplish the tasks detailed in this Work Plan CDM will submit a Final Work Plan and budget that incorporate the agreements made in the negotiation meeting The Final Work Plan budget will include a summary ofthe negotiations CDM will submit the Final Work Plan and budget in both hard copy and electronic formats

516 EVALUATE EXISTING DATA AND DOCUMENTS

As part of the preparation of this Work Plan CDM obtained information from the EPA RPM EQB and USGS The background documents were copied reviewed and incorporated where applicable in this planning document CDM has prepared summary tables for use in this Work Plan CDM will obtain and review additional documents as part of the project planning process

5L7 QUALITY ASSURANCE PROJECT PLAN

5171 Quality Assurance Project Plan Addendum

CDM will prepare a QAPP Addendum to the approved site-specific QAPP covering the OU 1 -Groundwater RI in accordance with the current revision of EPAQAR-5 and the approved EPA Region n QAPP guidance or procedures The QAPP Addendum will make reference to the approved QAPP and will include a description ofthe project objectives and organization functional activities and QAQC protocols that will be used to achieve the required DQOs The DQOs will at a minimum reflect the use of analytical methods for identifying and addressing contamination consistent with the levels for remedial action objectives identified in the National Contingency Plan The QAPP Addendum will include only those sections applicable to the 0U2 soil investigation

The QAPP Addendum will include sample locations and frequency a list of sampling equipment personnel and equipment decontamination procedures sample handling and analysis and a breakdown of samples to be analyzed through the CLP and through other sources

The QAPP Addendum will also consist of sections addressing site management including site control and site operations The site control section describes how approval to enter the areas of investigation will be obtained along with the site security contiol measures and the field officecommand post for the field investigation The logistics of all field investigation activities will also be described

The site operations section includes a project organization chart and delineates the responsibilities of key field and office team members A schedule will be included that shows the proposed scheduling of each major field activity

300690 5-3

5172 Other Quality AssuranceQuality Control Activities

Quality assurance activities to be performed during this project may also include internal office and field or laboratory technical systems audits field planning meetings and quality assurance reviews of all project plans measurement reports and subcontractor procurement packages The quality assurance requirements are further discussed in Section 82 of this Work Plan

518 HEALTH AND SAFETY PLAN ADDENDUM

CDM will prepare a HSP Addendum to the approved site-specific HSP for the OU 1 - Groundwater RI in accordance with 40 CFR 300150 of the NCP and 29 CFR 1910120 (1)(1) and (1)(2) The HSP Addendum will incorporate the approved HSP by reference and will include the following site-specific information

a hazard assessment training requirements definition of exclusion contaminant reduction and other work zones monitoring procedures for site operations safety procedures personal protective clothing and equipment requirements for various field operations disposal and decontamination procedures other sections required by EPA The HSP also includes a contingency plan which addresses site specific conditions which may be encountered

The site HSP Addendum will address field activities conducted during the RI which at present includes but are not limited to site activities conducted by CDM

In addition to the preparation of the HSP Addendum health and safety activities will be monitored throughout the field investigation The CDM Regional Health and Safety Coordinator or designated representative will attend the initial field planning meeting and may perform a site visit to ensure that all health and safety requirements are being adhered to CDM will designate a member of the field team to serve as the onsite health and safety coordinator throughout the field program During the CDM field investigation this person will report directly to both the Field Team Leader and the Regional Health and Safety Coordinator The Health and Safety Plan will be subject to revision as necessary based on new information that is discovered during the field investigation

519 NON-RAS ANALYSES (OPTIONAL)

The implementation ofthis subtask task is considered optional If EPA decides to proceed with this task CDM will be officially tasked via a work assignment amendment In the event that this subtask is deemed needed the following requirements shall be implemented

300691 5-4

CDM will develop an EPA-approved laboratory quality assurance program that provides oversight of in-house and subcontiacted laboratories through periodic performance evaluation sample analyses andor on-site audits of operations and prescribes a system of corrective actions to be implemented in cases where the laboratorys performance does not meet the standards of this program This will include at a minimum

bull Prepare Laboratory Services Requests (eg statements of work) for all non-RAS parameters The Laboratory Services Request(s) shall include the following elements

- digestionanalytical methods - data deliverable requirements - quality control (QC) requirements - estimated number of samples - method restrictions and penalties for non-compliance - turn-around times

bull Develop QC criteria for each parameter of the approved site-specific or contract-wide QAPP that will be incorporated into the Laboratory Service Request

i bull Acceptance criteria will be included in the site specific Quality Assurance Project Plan (QAPP) Addendum and in the laboratory statement of work and will be based on the project data quality objectives

bull CDM will comply with all applicable and appropriate requirements in the acquisition and management of subcontracts for analytical services including the requirements terms and conditions ofthis contract the subcontractors corporate standard operating procedures and the applicable requirements of the Federal Acquisition Regulation (FAR) Environmental Protection Agency Acquisition Regulation (EPAAR) and other relevant Federal and Agency acquisition requirements

bull At the request of the EPA RPM the Laboratory Services Request will be submitted for EPA review prior to solicitation of an analytical services subcontract

5110 MEETINGS

CDM will participate in various meetings with EPA during the course of the work assignment For budget estimation purposes as directed by EPAs SOW CDM has assumed 12 meetings with two people in attendance for 4 hours per meeting One of these meetings will be held after the initial scoping meeting prior to the submittal ofthe draft work plan to discuss technical issues CDM will prepare meeting minutes for review by the EPA RPM

g ^ 300692

5111 SUBCONTRACT PROCUREMENT

This subtask will include the procurement of all subcontractors to complete the field investigation Procurement activities include preparation of the technical statement of work preparation of Information For Bidders (IFB) or Request For Proposals (RFP) packages conducting a pre-bid site visit (when necessary) answering technical and administrative questions from prospective bidders performing technical and administrative evaluations of received bids performing the necessary background reference financial and insurance checks preparation of consent packages for approval by the EPA Contracting Officer (when necessary) and awarding the subcontract

To support the proposed field activities the following subcontractors will be procured

raquo an analytical laboratory to perform the non-RAS sample analyses

All subcontractor procurement packages will be subject to CDMs technical and quality assurance reviews

5112 PERFORM SUBCONTRACT MANAGEMENT

The CDM SM and the CDM Subcontracts Manager will perform the necessary management and oversight of the subcontractor (identified under Section 5111) needed for the performance of this RIFS CDM will institute procedures to monitor progress and maintain systems and records to ensure that the work proceeds according to subcontract and RAC II contract requirements CDM will review and approve subcontractor invoices and issue any necessary subcontract modifications

5113 PATHWAY ANALYSIS REPORT

In accordance with OSWER Directive 92857-047 dated September 2001 entitled Risk Assessment Guidelines for Superfiind - Part D CDM will provide EPA with standard tables worksheets and supporting information forthe risk assessment as interim deliverables prior to preparation ofthe full Baseline Risk Assessment Report CDM will prepare a Pathways Analysis Report (PAR) that consists of RAGS Part D Standard Tables 1 through 6 and supporting text The PAR will summarize the key assumptions regarding potential receptors exposure pathways exposure variables chemical distribution and chemical toxicity that will be used to estimate risk in the Baseline Risk Assessment Because RAGS Part D Tables 2 and 3 summarize site data these tables ofthe PAR will be prepared once analytical data collected during the RI site investigation are available Preparation of the PAR initiates the risk assessment process whose components are described in greater detail in Section 571

CDM will coordinate with EPA to define potential exposure pathways and human receptors To accomplish this CDM will review all available information obtained from EPA pertaining to the Vega Baja Site including data generated during previous investigations CDM will integrate this information with site data generated during the RI site investigation Background information on the

5-6 300693

site will be summarized and samples collected and the chemicals analyzed for in various media will be discussed The treatment of data sets (eg duplicates splits blanks [trip field and laboratory] multiple rounds and qualified and rejected data) will be discussed and chemical-specific exposure point concentrations for each exposure scenario will be estimated Based on current knowledge potential receptors in the residential area include current and future residents and future construction workers Potential receptors in the nonresidential area include current trespassers and future residents site workers and construction workers Exposure variables to be used for the calculation of daily intakes and blood lead levels will be presented Carcinogenic and noncarcinogenic toxicity values for contaminants of concern and the sources of these values will be presented in the PAR As noted above the selection of chemicals of potential concern exposure pathways and receptors exposure concentrations exposure variables and toxicity values will be suirunarized in tabular form in accordance with the Standard Tables of RAGS Part D

Upon EPAs approval of the PAR CDM will estimate potential exposures and risks associated with the site and initiate preparation ofthe draft Baseline Risk Assessment Report as described in Section 57

52 TASK 2 - COMMUNITY RELATIONS

CDM will provide technical support to EPA during the performance of the following community relations activities throughout the RIFS in accordance with Community Relations in Superfund-A Handbook (EPA 1992a) CDM when appropriate will provide EPA with translation services during the Conmiunity Relations Task

521 COMMUNITY INTERVIEWS

Community Interviews Preparation - This task is covered under the OUl RIFS

522 COMMUNITY RELATIONS PLAN

CDM will evaluate the approved Community Relations Plan (CRP) and if needed will prepare an addendum to include any additional community activities required for support to this RIFS The existing CRP for OUl will be incorporated by reference

523 PUBLIC MEETING SUPPORT

CDM will make all the necessary logistical arrangements for public meetings including the selection and reservation of a meeting space (as directed by the EPA RPM or public affairs specialist) Per EPA direction CDM will assume that there will be a total of four public meetingssite tours

CDM will perform the following activities in support of public meetingsite tours

300694 5-7

bull Attend public meetings or availability sessions provide recording andor stenographic support prepare draft and final meeting summaries and prepare presentation materialshandouts

bull Prepare draft and final visual aids CDM will develop draft visual aids (ie transparencies sUdes and handouts) as instructed by EPA CDM will develop final visual aids incorporating all EPA comments For budgeting purposes CDM will assume 15 overhead transparencies 10 slides and 150 handouts for each public meeting CDM will prepare final visual aids that incorporate all EPA comments

bull CDM will reserve a court reporter for the four public meetingsite tours A full page original of the ti-anscripts and a four on one page copy (along with a 35 inch diskette in Word Perfect 90 format) will be provided to EPA with additional copies placed in the information repositories as required

524 FACT SHEET PREPARATION

CDM will prepare draft information lettersupdatesfact sheets pending the findings in the CRP or revised CRP for the site as per technical direction provided by the EPA RPM CDM will research write edit design lay out and photocopy the fact sheets CDM will prepare final fact sheets incorporating all EPA review conmients CDM will attach mailing labels to the fact sheets before delivering them to EPA from where they will be mailed For budgeting purposes CDM will assume 4 fact sheets two to four pages in length with three illustrations per fact sheet

525 PROPOSED PLAN SUPPORT

CDM will coordinate and assist in the preparation of one draft and one final Proposed Plan that will describe the preferred alternative and other alternatives evaluated in the Feasibility Study Each Plan will be prepared in accordance with the NCP and the EPA Community Relations in Superfund-A Handbook (the most current version) and will also describe public opportunities for involvement in the Record of Decision

526 PUBLIC NOTICES

CDM will prepare newspaper announcement(s)public notice(s) forthe various public meetingssite tours CDM will assume the development of four newspaper advertisements in local widely read newspapers For budgeting purposes CDM will assume that each advertisement will be placed in a large newspaper and a small town newspaper All of the public advertisements will be placed in a Spanish-language newspaper

527 INFORMATION REPOSITORIES

Per EPA direction CDM will not perform this activity

300695 5-8

528 SITE MAILING LIST

CDM will update the site mailing list two times during the course of the RIFS activities This activity will be conducted at the direction of the EPA RPM Each mailing list will be assumed to have approximately 330 entries CDM will provideEPA with a copy of the mailing list on diskette upon request Mailing labels will also be provided to EPA upon request The EPA will do the actual mailing of any information to the community

529 RESPONSIVENESS SUMMARY SUPPORT

CDM will provide administrative and technical support for the site Responsiveness Summary CDM will provide assistance in compiling and summarizing comments received during the public comment period on the Proposed Plan and Feasibility Study For budgeting purposes CDM will assume 150 separate comments

53 TASK 3 - FIELD INVESTIGATION

This task includes all activities related to implementing the OU 2 - Soils field investigation at the Vega Baja Solid Waste Disposal Superfund site The data generated from the field investigations will be used to support an RIFS and an HHRA satisfy DQOs and provide adequate information to develop appropriate remedial alternatives The following activities will be performed during the field investigation

bull Residential surface soil sampling bull Trash mound surface and subsurface soil sampling bull Non-residential surface and subsurface soil sampling bull Background surface soil sampling bull Residential dust sampling bull Residential tap water sampling bull Optional deep soil boring program (if directed by EPA)

531 SITE RECONNAISSANCE

CDM conducted an initial site visit to become more familiar with local and site-specific conditions On November 30th and December 11999 CDM s SM and Project Scientist along with the EPA RPM and members of the EPA Removal Branch walked through the Vega Baja Solid Waste Disposal Site and surrounding area to evaluate logistical problems relevant to the implementation of the field investigation programs

532 MOBILIZATION AND DEMOBILIZATION

This subtask will consist of field personnel orientation field office equipment mobilization and demobilization and property access Prior to field activities each field team member will review

5-9 300696

all project plans and participate in a field planning meeting conducted by the CDM SM to become familiar with the history ofthe Site health and safety requirements field procedures and related QC requirements Field personnel will also attend an onsite tailgate kick-off meeting immediately prior to the commencement of field activities All new field personnel will receive a comparable briefing if they were not at the initial field planning meeting andor the tailgate kick-off meeting Supplemental meetings may be conducted as required by any changes in Site conditions or to review field operation procedures

Equipment mobilization will entail the ordering rental and purchasing of all equipment needed for each part of the field investigation Measurement and Test Equipment forms that identify data quality requirements will be completed for rental or purchase of equipment (instruments) that will be utilized to produce field measurements The field equipment will be inspected for acceptability and instruments calibrated as required prior to use This task also involves the construction of a decontamination area for decontamination of sampling equipment and personnel A separate decontamination pad will be constructed by the drilling subcontractor for drilling equipment

Health and safety work zones including personnel decontamination areas will be established Local authorities such as the police and fire departments will be notified prior to the start of field activities

Equipment will be demobilized at the completion of each field event as necessary Demobilized equipment will include sampling equipment drilling subcontractor equipment health and safety equipment decontamination equipment and field screening laboratory equipment

If the optional soil boring program is conducted all soil boring locations will be checked for interference with overhead and underground sewer lines It should be noted that certain sampling locations may be refined at the time of the investigation to more closely reflect field conditions

533 ENVIRONMENTAL SAMPLING

Table 5-1 summarizes the number of samples and associated field and laboratory analytical parameters for the various environmental media that will be sampled during this field investigation Unless otherwise specified analysis for TCL and TAL parameters through the CLP will be performed in accordance with the niost current EPA CLP statements of work for multi-media multi-concentration analyses for organics and inorganics

Non-RAS parameters will be analyzed by EPAs DESA laboratory in Edison New Jersey or by an analytical laboratory under subcontract to CDM Quality control samples will be collected in addition to the environmental samples discussed below The number and type of quality control samples will be in accordance with the EPA Region II CERCLA QA Manual (1989c) and will be specified in the QAPP Addendum

300697 5-10

5331 Site Visits

Additional site visits will be conducted by the CDM SM and the EPA RPM to identify and discuss other scope requirements ofthe OU 2 - Soils RIFS such as I) identification of background surface soil sampling locations 2) visual identification ofthe southern extent of the landfill 3) identification of residential surface soil sampling locations and 4) identification of non-residential surface soil sampling locations

5332 Surface and Subsurface Soil Sampling

CDM will collect surface and subsurface soil samples from residential trash mound non-residential and background locations to obtain data for the site HHRA and to characterize both the nature and extent and spacial distribution of surficial soil contamination Surface soil samples will be collected following EPA-approved methodologies which will be fully detailed in the QAPP Addendum

Residential Area

CDM will collect surface soil samples at depths of 0 - 2 feet bgs from the residential area of the Site as described below

bull Surface soil samples will be collected from each of the 39 residences that were identified to contain elevated lead levels for the analysis of lead only Results from these samples will be used as data for the Integrated Exposure Uptake Biokinetic Model for Lead in Children EPA recommends that the model be applied by individual home therefore samples will be collected on a property by property basis Ten samples will be collected at each of the 39 residences for the analysis of lead by EPAs DESA laboratory if available or the CDM laboratory subcontractor for a total of 390 samples Figure 5-1 illustrates the proposed residences to be sampled for analysis of lead in soils

bull Surface soil samples will be collected for analysis of pesticides PCBs and TAL metals from 11 areas to characterize the nature and extent of contamination from these substances The Site was divided into areas by blocks These blocks were determined based on the screening level dataof contaminants of concerns present at the site A minimum often samples will be collected from each of the 11 areas and analyzed through the EPA CLP for a minimum of 110 samples Each area will be divided into a grid of appropriate size to allow for a minimum of 10 samples per area A samplingplan decision making tool like EPAs Fully Integrated Environmental Location Decision Support (FIELDS) System or Department of Energys (DOE) Visual Sample Plan (VSP) that assures the data will statistically meet the 95 upper confidence limit (UCL) as representative of each Study Area (EPA 1996c DOE 2000) This chosen sampling approach will be more fully outlined in the QAPP Addendum Figure 5-2 illustrates the proposed 11 study areas to be sampled for additional analyses

5-11 300698

It should be noted that soil sampling locations may be refined at the time ofthe investigation upon EPA approval to more closely reflect field conditions All samples will be analyzed using the most current EPA-approved methods which will be detailed in the QAPP Addendum

For cost estimation purposes it has been determined that a total of 500 surface soil samples will be collected from the residential area

Trash Mounds

CDM will collect surface and subsurface soil samples from trash mounds located in the residential area of the Site to characterize the nature of contamination in the remaining trash mounds Figure 5-3 illustrates the proposed soil sampling locations for the trash mounds It should be noted that sampling locations may be refined at the time of the investigation upon EPA approval to more closely reflect field conditions Two locations at each of the four identified trash mounds will be identified for sample collection At each location one surface soil sample (0-2 feet bgs) and one subsurface soil sample (5-7 feet bgs) will be collected for analysis of pesticides PCBs and TAL metals through the EPA CLP All samples will be analyzed using the most current EPA-approved methods which will be detailed in the QAPP Addendum

For cost estimation purposes it has been determined that a total of 16 soil samples (8 surface and 8 subsurface) will be collected

Non-Residential Area

CDM will collect surface and subsurface soil samples from grid locations in the non-residential area to characterize the nature and extent of soil contamination in the southern end ofthe Site Locations will be identified on a grid of 100 feet by 100 feet Figure 5-4 illustrates the proposed soil sampling locations in the non-residential area At each grid location one surface soil sample (0-2 feet bgs) and one subsurface soil sample (5-7 feet bgs) will be collected for analysis of pesticides PCBs and TAL metals through the EPA CLP It should be noted that sampling locations may be refined at the time of the investigation upon EPA approval to more closely reflect field conditions All samples will be analyzed using the most current EPA-approved methods which will be detailed in the QAPP Addendum


Background Samples

CDM will collect background surface soil samples from areas not affected by Site activities to provide a baseline by which to compare soil samples collected from the Site Exact locations will be determined during a site reconnaissance prior to the start of sampling activities with approval by EPA Background surface soil samples will be analyzed for pesticides PCBs and TAL metals

512 300699

through the EPA CLP All samples will be analyzed using the most current EPA-approved methods which will be detailed in the QAPP Addendum

For cost estimation purposes it has been determined that a total of ten background surface soil samples will be collected

5333 Residential Dust Sampling

CDM will collect residential dust samples from the 39 residences that were identified to contain elevatedlead levels to obtain data for the Integrated Exposure Uptake Biokinetic Model for Lead in Children Figure 5-1 illustrates the locations of proposed residences to be sampled Residential dust samples will be analyzed for lead by EPAs DESA laboratory if available or the CDM laboratory subcontractor Residential dust samples will be collected following EPA-approved methodologies which will be fully detailed in the QAPP Addendum

The number of dust samples to be collected will be based on the EPA-approved methodologies for residential dust sampling For cost estimation purposes it has been determined that a total of 39 dust samples will be collected

5334 Residential Tap Water Sampling

CDM will collect residential tap water samples from the 39 residences that were identified to contain elevated lead levels to obtain data for the Integrated Exposure Uptake Biokinetic Model for Lead in Children Figure 5-1 illustrates the locations of proposed residences to be sampled Residential tap water samples will be analyzed for lead by EPAs DESA laboratory if available or the CDM laboratory subcontractor Residential tap water samples will be collected following EPA-approved methodologies which will be fully detailed in the QAPP Addendum

The number of tap water samples to be collected will be based on the EPA-approved methodologies for residential tap water sampling For cost estimation purposes it has been determined that a total of 39 tap water samples will be collected

534 SOIL BORING DRILLING AND TESTING

5341 Optional Soil Boring Program

CDM is currently conducting a groundwater investigation at the Site If data from this investigation indicates that groundwater underlying the Site is contaminated and upon EPA direction CDM will conduct a soil boring program to determine whether groundwater contamination has resulted from Site contanninants leaching through the soil The soil boring program will include the advancement and sampling of soil borings to the top of bedrock (estimated to be between 1 and 16 feet bgs) The locations and sampling analyses of optional subsurface soil borings will be determined upon direction from EPA

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For cost estimation purposes it has been determined that a total of 300 subsurface soil samples will be collected

535 DISPOSAL QF FIELD GENERATED WASTE

If CDM field activities occur concurrently with EPAs Removal Branch activities all investigation derived waste will be disposed of by the Removal Branch contractor However if necessary CDM will procure a subcontractor that will be responsible for the removal and proper disposal of all RI generated waste soils liquids solids and personal protective equipment CDM will prepare a technical statement of work for the procurement of the waste hauling and disposal subcontractor under OUl CDM personnel will perform field oversight and health and safety monitoring during all waste disposal field activities

54 TASK 4 - SAMPLE ANALYSIS

All RAS samples will be analyzed by an EPA CLP laboratory for TCLTAL parameters using methods specified in the most current and applicable Statements of Work The analysis of samples for non-RAS parameters will be performed by EPAs DESA laboratory in Edison New Jersey If DESA does not have sufficient laboratory capacity at the time of sampling then the non-RAS parameters will be submitted to the analytical laboratory under subcontract to CDM CDMs laboratory subcontractor will be selected by EPA-approved criteria and will follow the most current CLP protocol and Region II QA requirements The CDM Regional Quality Assurance Coordinator will ensure that the laboratory meets all EPA requirements for laboratory services The samples to be collected and the parameters to be analyzed for each sample are described in this Work Plan The number of samples analytical test methods levels of detection holding times parameters field sample preservation and QC sample protocols will be listed in the QAPP Addendum

541 INNOVATIVE METHODSFIELD SCREENING SAMPLE ANALYSIS

No field screening is anticipated at this time

542 ANALYTICAL SERVICES PROVIDED VIA CLP DESA OR EPA-ERT

Section 535 presents the sampling program including those samples to be submitted for analysis by the EPA CLP Table 5-1 summarizes the sampling program All required paperwork will be completed and the samples packaged and shipped in accordance with CLP requirements Whenever possible CDM will attempt to use analytical services provided by the EPA CLP or by EPAs DESA laboratory in Edison New Jersey

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543 SUBCONTRACTOR LABORATORY FOR NON-RAS ANALYSES

If required the CDM laboratory subcontractor will analyze non-RAS parameters Non-RAS parameters include analysis for lead only See Section 5111 for a description of subcontractor procurement

55 TASK 5 - ANALYTICAL SUPPORT AND DATA VALIDATION

CDM will validate the non-RAS environmental samples (except samples analyzed by EPAs DESA laboratory) collected under Task 3 EPA will validate all other RAS analytical data generated under the other tasks of the RI

551 COLLECT PREPARE AND SfflP SAMPLES

This activity will be performed as part of the field investigation (see Section 53)

552 SAMPLE MANAGEMENT

The CDM Analytical Services Coordinator (ASC) will be responsible for all RAS CLP laboratory bookings and coordination with the Regional Sample Control Center (RSCC) for sample tracking prior to and after sampling events

For all RAS activities CDM will notify the Contract Laboratory Analytical Support Services (CLASS) to enable them to track the shipment of samples from the field to the laboratories and to ensure timely laboratory receipt of samples Sampling Trip Reports will be sent directly to the RSCC and the EPA Remedial Project Manager within ten working days of final sample shipment with a copy sent to the CDM ASC

The CLP laboratories will be responsible for providing organic and inorganic analytical data packages to the Region II shipping coordinator for data validation by EPA

Samples analyzed by the DESA laboratory will be coordinated by the ASC For samples analyzed by the laboratory under subcontract to CDM all analytical data packages will be sent directiy to CDM for data validation If requested CDM will send these validated data packages to EPA for QA review purposes The CDM SM will be responsible for subcontractor laboratory bookings and sample tracking prior to and after sampling events

553 DATA VALIDATION

All RAS samples will be analyzed by a laboratory participating in the CLP and all analytical data will be validated by EPA EPA Region n DESA laboratory samples will be vahdated as per DESA protocol The non-RAS data will be validated by CDM validators who will use the requirements and the quality control procedures outlined in the associated methods and as per the analytical statement

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of work for the laboratory subcontractor All validated data results will be presented to EPA as an Appendix to the RI report

The data validation portion of the program will verify that the analytical results were obtained following the protocols specified in the CLP statement of work and are of sufficient quality to be relied upon to prepare a HHRA to prepare the RI and FS to develop and screen remedial alternatives and to support a Record of Decision (ROD) The appropriate validation SOWs and guidelines will provided as an attachment to the QAPP Addendum

56 TASK 6 - DATA EVALUATION

This task includes efforts related to the compilation of analytical and field data All validated and unvalidated data will be entered into a relational database that will serve as a repository for data analysis risk assessment Geographical Information System (GIS) and data visualization Environmental Quality Information Systems (EQuIS) will be used as the database Tables figures and maps will be generated from the data to support preparation of the data evaluation report the RI report the HHRA report and the FS report The data from this investigation will be reviewed and carefully evaluated to identify the nature and extent of site-related contamination

561 DATA USABILITY EVALUATION

CDM will evaluate the usability ofthe data including any uncertainties associated with the data The data will be checked against the data quality indicators identified in the QAPP Any qualifications to the data will be discussed in the quality assurance section of any reports presenting data

562 DATA REDUCTION TABULATION AND EVALUATION

CDM will evaluate interpret and tabulate data in an appropriate presentation format for final data tables The following will be used as general guidelines in the preparation of data for use in the various reports

bull Tables of analytical results will be organized in a logical manner such as by sample location number sampling zone or some other logical format

bull Analytical results will not be organized by laboratory identification numbers because these numbers do not correspond to those used on sample location maps The sample locationwell identification number will always be used as the primary reference for the analytical results The sample location number will also be indicated if the laboratory sample identification number is used

bull Analytical tables will indicate the sample collection dates

bull The detection limit will be indicated in instances where a parameter was not detected

^^^ 300703

bull Analytical results will be reported in the text tables and figures using a consistent and conventional unit of measurement such as fxgL for tap water analyses and milligramskilogram (mgkg) for soil analyses

bull EPAs protocol for eliminating field sample analytical results based on laboratoryfield blank contamination results will be clearly explained

bull If the reported result has passed established data validation procedures it will be considered valid

bull Field equipment rinsate blank analytical results will be discussed in detail if decontamination solvents are believed to have contaminated field samples

Detailed information concerning the geological and physical characteristics of the site and the surrounding area will be gathered reviewed and evaluated for inclusion in the data evaluation report the RI report the RA report and the FS report The purpose of these activities will be to provide a detailed understanding of the site physical features and to assess how these features may affect contaminant source areas potential migration pathways and potential remedial alternatives

Diatabase Management

CDM will use a relational environmental database and standard industry spreadsheet software programs for managing all data related to the sampling program The system will provide data storage retrieval and analysis capabilities and be able to interface with a variety of spreadsheet word processing statistical GIS and graphics software packages to meet the full range of site and media sampling requirements necessary for this work assignment

Data collected during the RI will be organized formatted and input into the database for use in the data evaluation phase All data entry will be checked for quality contiol throughout the multiple phases of the project Data tables comparing the results of the various sampling efforts will be prepared and evaluated Data tables will also be prepared that compare analytical results with both state and federal ARARs

Data Mapping

A GIS has been developed for the site and study area by the REAC Team in order to facilitate spatial analysis of the data and to generate figures for reports and presentations The GIS has geographic base layers consisting of various kinds of maps that depict regional and local physiographic features such as roads buildings- water bodies railroads and topography Site-specific features derived from the site and study area survey results will be added to complete the base layers as needed CDM will update the GIS as samples are collected and wells are installed the locations of these will be registered Historical and current analytical results for each sample location will be added creating the capability to conduct functional spatial queries of the data to show where given parameters of

5-17 300704

interest are samples detected and exceed regulatory standards or criteria by date and depth This functionality will be used to support data interpretation for preparation ofthe remedial investigation report

The GIS will also serve as the primary platform for figure and map generation to support both the RIFS reports and presentations that will be delivered Figures will be generated in plan view and cross section to show the extent of soil contamination Graphic illustrations in the data evaluation report andor the RI report will include geological profiles cross-sections contaminant isoconcentration maps and soil maps showing chemical exceedances of Preliminary Risk Goal (PRG) levels Plan view maps and figures will be generated using GIS to facilitate plan-view spatial data analysis Figures will be generated to illustrate site features historical sample locations historical sampling results current sample locations current sampling results locations where soil contaminant concentrations exceed regulatory standards and criteria

563 MODELING

CDM will conduct this task if directed by EPA

564 TECHNICAL MEMORANDUM

Following the completion of field activities and prior to preparation of the RI report CDM will prepare a short technical memorandum including all the information gathered during the soil investigation and our conclusions regarding the potential for site soil contaminants to impact downgradient water wells or the Rio Indio The memorandum will recommend whether any additional field activities should be performed

The memorandum will be submitted for review and approval by the EPA RPM and will be finalized upon receipt of EPA comments It is anticipated that this report will include data results and will therefore require technical and QA review prior to submittal to EPA

57 TASK 7 - ASSESSMENT OF RISK

CDM will conduct a Human Health Risk Assessment for the Vega Baja Site The objective of the Vega Baja Site risk assessment is to provide a quantitative assessment of the potential for adverse health and environmental effects to occur as a result of exposure to chemical contaminants at the site

The HHRA will determine whether site contaminants pose a current or potential risk to human health in the absence of any reniedial action and will be used to determine whether remediation is necessary at the site and to focus remediation on those mediaexposure pathways that pose the greatest risk Furthermore the HHRA can provide a method for comparing the potential health impacts of various remedial altematives

5-18 deg

For the HHRA CDM will use EPAs standardized planning and reporting methods as outlined in EPAs RAGS Part D RAGS Part D provides guidance on standardized risk assessment planning reporting and review throughout the CERCLA remedial process from scoping through remedy selection and completion and periodic review of the remedial action CDM will also use EPAs models for predicting blood lead concentrations (EPA 1996b 200 Ic) to evaluate potential risks from exposure to lead

571 BASELINE RISK ASSESSMENT (HUMAN HEALTH)

The Human Health Risk Assessment will be performed in accordance with EPA guidance set forth in the following documents

Risk Assessment Guidance for Superfiind Human Health Evaluation Manual Part A (EPA 1989a)

Risk Assessment -Guidance for Superfund Human Health Evaluation Manual Part B Development of Risk Based Preliminary Remediation Goals (EPA 1991b)

Risk Assessment Guidance for Superfund Human Health Evaluation Manual Part D (EPA lOOld)

Risk Assessment Guidance for Superfund Volume I Human Health Evaluation Manual Part E (Supplemental Guidance for Dermal Risk Assessment) Final (EPA 2001 e)

Exposure Factors Handbook Vol I II and III (EPA 1997a)

Risk Assessment Guidance for Superfund Volume 1 Human Health Evaluation Manual Supplemental Guidance Standard Default Exposure Factors (EPA 1991c)

Final Guidance for Data Usability in Risk Assessment (EPA 1992b)

Dermal Exposure Assessment Principals and Applications (EPA 1992c)

Health Effects Assessment Summary Tables FY-1997 Annual [WHAT IS REFERENCE]

Integrated Risk Information System (on-line data base of toxicity measures) (EPA 2001a or most current version available after RI data is collected)

EPA Region IX Preliminary Remediation Goals (EPA 2001b or most current version available after RI data is collected)

Integrated Exposure Uptake Biokinetic (lEUBK) Model for Lead in Children (EPA 2001c)

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Statistical analysis of the data will be performed (i e tests for normal distribution calculation of upper confidence levels [UCLs])

Dose-Response Assessment - The dose-response assessment will present the general toxicological properties of the selected COPCs using the most current toxicological human health effects data Those chemicals which cannot be quantitatively evaluated due to a lack of toxicity factors will not be eliminated as COPCs on this basis These chemicals will instead be qualitatively addressed for consideration in risk management decisions for the site

Toxicological values and information regarding the potential for carcinogens and noncarcinogens to cause adverse health effects in humans will be obtained from a hierarchy of EPA sources The primary source will be EPAs Integrated Risk Information System (IRIS) on-line data base IRIS which is updated regularly provides chemical-specific toxicological values and information that have undergone peer review and represent an EPA scientific consensus If toxicity values are not available from IRIS the most recent Health Effects Assessment Summary Tables (HEAST) will be used to select toxicity values EPAs National Center for Environmental Assessment (NCEA) may also be contacted to provide toxicity information if no data are available from IRIS or HEAST

A slope factor is a plausible upper-bound estimate of the probability of a response per unit intake of a chemical over a lifetime and is usually the upper 95 percent confidence limit of the slope of the dose-response curve expressed in (mgkgday) In risk assessment a slope factor is used to estimate an upper-bound probability of an individual developing cancer as a result of a lifetime of exposure to a particular level of a potential carcinogen

For the evaluation of non-cancer effects in the risk assessment chronic and subchronic reference doses (RfDs) are used A chronic reference dose is an estimate of a daily exposure level for the human population including sensitive subpopulations that is likely to be without appreciable risk of deleterious effects during a lifetime Chronic reference doses are generally used to evaluate the potential noncancer effects associated with exposure periods between six years and a lifetime Subchronic reference doses aid in the characterization of potential non-cancer effects associated with shorter-term exposure (ie less than six years)

Toxicity endpointstarget organs for noncarcinogenic COPCs will be presented for those chemicals showing hazard quotients greater than one If the hazard index is greater than one due to the summing of hazard quotients segregation of the hazard index by critical effect and mechanism of action will be performed as appropriate

While lead is considered a probable human carcinogen and causes noncancer health effects EPA has not developed toxicity values for this chemical Instead EPA recommends using models to predict blood lead concentiations in exposed populations for comparison to blood lead levels of concern This is described further under the Risk Characterization section below

^bull21 3 0 0 7 0 7

Site Conceptual Model - CDM has developed a conceptual model for the site and is discussed in Section 325 The model will be used to identify potentialor suspected sources of contamination types and concentrations of contaminants detected at the site potentially contaminated media release mechanisms and potential exposure pathways including receptors

The following factors were considered during the preparation of the site conceptual model

bull sensitive populations including but not limited to the elderly pregnant or nursing women infants and children and people suffering from chronic illness people exposed to particularly high levels of contaminants

bull circumstances where a disadvantaged population is exposed to hazardous materials (ie Environmental Justice situations)

bull significant contamination sources bull potential contaminant release mechanisms (eg volatilization fugitive dust emissions

surface runoffoverland flow tracking by humans animals soil gas generation and biodegradation)

bull contaminant transport pathways such as direct air transport downwind soil gas migration and biomagnification in the food chain

bull cross media transfereffects such as volatilization to air wet deposition dry deposition and bioaccumulation in home grown vegetables

Exposure Assessment - Exposure assessment involves the identification ofthe potential human exposure pathways at the site for present and potential future-use scenarios Potential release and transport mechanisms will be identified for contaminated source media Exposure pathways will be identified that link the sources locations types of environmental releases and environmental fate with receptor locations and activity patterns Generally an exposure pathway is considered complete if it consists of the following elements

bull a source and mechanism of release bull a transport medium bull an exposure point (ie point of potential contact with a contaminated medium) bull an exposure route (eg ingestion) at the exposure point

All present and future-use scenario exposure pathways considered will be presented however only some may be selected for quantitative analysis Justifications will be provided for those exposure pathways retained and for those eliminated

Based on the initial site visit and information regarding current and future land use the potentially complete exposure pathways include

PRESENT AND FUTURE USE

bull Residential Area - Residents (Adults and Children)

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Surface Soil - incidental ingestion - dermal

bull Non-Residential Area - Trespassers (Adolescents) Surface Soil

- incidental ingestion - dermal

(Note These trespassing exposure pathways are potentially complete However tiespassing exposures are expected to be extremely limited compared to the residential and worker exposures that will be quantified as a future use [see below] Therefore risks to trespassers will be discussed qualitatively rather than quantified)

POTENTIAL FUTURE USE

bull Both Areas - Construction Workers (Adults) Surface SoilSubsurface Soil


bull Both Areas - Residents (Adults and Children) Surface SoilSubsurface Soil


bull Non-Residential Area - Site Workers (Adults) Surface SoilSubsurface Soil


Exposure point concentrations will be developed for each COPC in the risk assessment for use in the calculation of daily intakes For chemicals other than lead the concentration is the 95 percent UCL on the arithmetic mean or the maximum detected value (whichever is lower) For lead both the Integrated Exposure Uptake Biokinetic (lEUBK) Model for Lead in Children (EPA 200 Ic) and interim adult lead model (EPA 1996b) use the arithmetic mean concentration of lead in soil The lEUBK model also uses concentrations of lead in tap water and dust to estimate blood lead concentrations in receptors

Daily intakes will be calculated for both chronic and subchronic exposures These daily intakes will be used in conjunction with toxicity data to provide quantitative estimates of carcinogenic risk and non-cancer effects

5-23 300709

Exposure assumptions used in daily intake calculations will be based on information contained in EPA guidance site-specific information and professional judgement These assumptions are generally 90th and 95th percentile parameters which represent the reasonable maximum exposure (RME) The RME is the highest exposure that is reasonably expected to occur at a site If potential risks and hazards exceed EPA target levels then Central Tendency Exposures (CTE) will be evaluated using 50th percentile exposure variables

The exposure assessment will identify the magnitude of actual or potential human exposures the frequency and duration of these exposures and the routes by which receptors are exposed The assumptions will include information from the Standard Default Exposure Factors guidance (EPA 1991a) the updated Exposure Factors Handbook (EPA 1997a) and the Integrated Exposure Uptake Biokinetic (lEUBK) and interim adult lead model guidance (EPA 1996b 2001c) Site specific information will be used where appropriate to verify or refine these assumptions In developing the exposure assessment CDM will develop reasonable maximum estimates of exposure for both current land use conditions and potential land use conditions at the site

Risk Characterization - In this section of the risk assessment toxicity and exposure assessments will be integrated into quantitative and qualitative expressions of carcinogenic risk non-cancer hazards and blood lead levels The estimates of risk hazard and blood lead levels will be presented numerically in spreadsheets contained in an appendix

Carcinogenic risks are estimated as the incremental probability of an individual developing cancer over a life time as a result of exposure to a potential carcinogen Per RAGS the slope factor converts estimated daily intakes averaged over a lifetime directly to incremental risk of an individual developing cancer This carcinogenic risk estimate is generally an upper-bound value since the slope factor is often an upper 95th percentile confidence limit of probability of response based on experimental animal data used in the multistage model

The potential for non-cancer effects will be evaluated by comparing an exposure level over a specified time period with a reference dose derived for a similar exposure period This ratio of exposure to toxicity is referred to as a hazard quotient This hazard quotient assumes that there is a level of exposure below which it is unlikely even for sensitive populations to experience adverse health effects however this value should not be interpreted as a probability Generally the greater the hazard quotient is above unity the greater the level of concern

While lead is considered a probable human carcinogen and causes noncancer health effects EPA has not developed toxicity values for this chemical Instead EPA recommends predicting blood lead concentrations in young children for residential exposures or fetal blood lead concentrations for non-residential adult exposures Young children and fetuses are considered a highly sensitive population with respect to the adverse effects of lead on development Blood lead levels of young children will be predicted with EPAs lEUBK Model for Lead in Children (EPA 2001c) Blood lead levels of fetuses of individuals exposed in a non-residential area will be estimated using

5-24 bull 300710

EPAs interim adult lead model (EPA 1996b) For both populations a concentration of 10 micrograms of lead per deciliter of blood (ugdL) is considered to be a blood lead level of concern from the standpoint of protecting the health of sensitive populations (EPA 1996b) Therefore risk to these populations will be estimated from the probability distributions of blood lead concentrations (ie the probability of exceeding 10 ugdL)

For chemicals other than lead carcinogenic risks and non-cancer hazard index (HI) values will be combined across chemicals and exposure pathways as appropriate In general EPA recommends atarget value orriskrange (ieHI= I for non-cancer effects or cancer risk = 1x10 to 1x10^) as threshold values for potential human health impacts The results presented in the spreadsheet calculations will be compared to these target levels and discussed Characterization of the potential risks associated with the site provides the EPA risk manager with a basis for determining whether additional response action is necessary at the site and a basis for determining residual chemical levels that are adequately protective of human health

Identification of LimitationsUncertainties - In any risk assessment estimates of potential carcinogenic risk and non-cancer health effects have numerous associated uncertainties The primary areas of uncertainty and limitations will be qualitatively discussed Quantitative measures of uncertainty will involve the calculation of central tendencies Central tendency evaluation involves the use of 50th percentile input parameters in risk and hazard estimates as opposed to 90th percentile parameters used in the RME calculations The 50th percentile parameters are considered representative of the general receptor population but may underestimate the true health risk to sensitive receptors The chemicals driving the risk assessment will be evaluated using these average exposure assumptions and the 95 percent UCL concentration to derive risk The central tendency risks will be discussed in relation to RME risks Central tendency analyses will only be calculated for pathways in which RME risks are considered above de minimis levels (carcinogenic risk above IxIO andor HI above 10)

CDM site manager will coordinate with the EPA RPM and submit draftinterim deliverables as outlined in the RAGS - Part D All data will be presented in RAGS Part D Format The risk assessment will provide adequate details of the activities and be presented so that individuals not familiar with risk assessment can easily follow the procedures

5712 Final Human Health Risk Assessment Report

CDM will submit the final Human Health Risk Assessment Report incorporating EPA review comments

58 TASK 8 - TREATABILITY STUDY AND PILOT TESTING

In the event that treatability studies are performed these studies will beused to better estimate the remediation cost and performance capabilities of the individual technology based on the site

5-25 300711


conditions and problems The three levels of treatability studies that may be conducted are laboratory screening bench-scale testing and pilot-scale testing The laboratory screening is used to establish the validity of a technology to treat waste Bench-scale testing is used to identify the performance of the technology specific to a type of waste Pilot-scale testing is used to provide quantitative performance cost and design information for remediation The work will be in accordance with the fact sheet Guide for Conducting Treatability Studies Under CERCLA November 1993

581 LITERATURE SEARCH

Under this task CDM will research viable technologies that may be applicable to the contaminants of concern and the site conditions encountered Upon completion of the literature search CDM will provide a technical memorandum to the EPA RPM that summarizes the results As part of this document CDM will submit a plan that recommends performance of a treatability study at one of the above levels and identifies the types and specific goals of the study The treatability study will be designed to determine the suitability of remedial technologies to site conditions and problerns Modifications to the RIFS Work Plan to include the treatability study will be prepared in accordance with the requirements described in Section 582 below

582 TREATABILITY STUDY WORK PLAN ADDENDUM (OPTIONAL)

If requested by the EPA CDM will perform the following

raquo prepare a draft addendum to the RIFS Work Plan that describes the approach for performance of the tieatability study

participate in negotiations to discuss the final technical approach and costs required to accomplish the treatability study requirements and

o prepare a final work plan addendum and supplemental budget that incorporates the agreements reached during the negotiations

The treatability study work plan addendum will describe the technology to be tested test objectives test equipment or systems experimental procedures treatability conditions to be tested measurements of performance analytical methods data management and analysis health and safety procedures and residual waste management The DQOs for the tieatability study will also be documented If pilot-scale tieatability studies are to be done the treatability study work plan addendum will also describe pilot plant installation and startup pilot plant operation and maintenance procedures and operating conditions to be tested If testing is to be performed off-site permitting requirements will be addressed A schedule for performing the treatability study will be included with specific durations and dates when available for each task and subtask including anticipated EPA review periods The schedule will also include key milestones for which completion dates should be specified Such milestones are procurement of subcontractors sample collection sample analysis and preparation of the treatabihty study report

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The treatability study work plan addendum will describe in detail the treatment process and how the proposed technology or vendor (if the technology is proprietary) will meet the performance standards for the site The treatability study work plan addendum will address how the proposed technology or vendor of the technology will meet all discharge or disposal requirements for any and all treated material airwater and expected effluents In addition the work plan addendum will explain the proposed final tieatment and disposal of all material generated by the proposed treatment system

583 CONDUCT TREATABILITY STUDIES (OPTIONAL)

CDM will conduct the treatability study in accordance with the approved treatability study addendum to the RIFS work plan QAPP and HSP to determine whether the remediation technology or vendor of the technology can achieve the performance standards

The following activities are to be performed when applicable as part of the performance of the treatability study and pilot testing

bull Procurement of Test Facility and Equipment CDM will procure the test facility and equipment necessary to execute the tests

bull Procurement of subcontractors and provide analytical services as necessary for teststudy i performance

bull Testing and Operating Equipment CDM will test the equipment to ensure proper operation and operate or oversee operation of the equipment during the testing

bull Retrieve samples for testing CDM will obtain samples for testing as specified in the treatability study work plan

bull Perform Laboratory Analysis CDM will establish a field laboratory to facilitate fast-turnaround analysis of test samples or if necessary will procure outside laboratory services to analyze the test samples and evaluate test results

bull Characterize and dispose of residual wastes

584 TREATABILITY STUDY REPORT (OPTIONAL)

CDM will prepare and submit the treatability study evaluation report that describes the performance of the technology The study results will clearly indicate the performance of the technology or vendor compared with the performance standards established for the site The report will also evaluate the treatment technologys effectiveness implementability cost and final results compared with the predicted results In addition the report will evaluate full-scale application of the technology including a sensitivity analysis that identifies the key parameters affecting full-scale operation

59 TASK 9 - REMEDIAL INVESTIGATION REPORT

CDM will develop and deliver a Remedial Investigation report that accurately establishes site conditions including the identification of contaminated media definition of the extent of contamination and the delineation of the physical boundaries of contamination CDM will obtain

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detailed data to identify key contaminants and to determine the movement and the extent of contamination in the environment Key contaminants will be identified in the report and will be selected based on toxicity persistence and mobility in the environment An estimate of key contaminant concentrations that are reaching both human and ecological receptors will be made and the effects on receptors will be evaluated

591 DRAFT REMEDIAL INVESTIGATION REPORT

A draft RI report will be prepared in accordance with the format described in EPA guidance documents such as the Interim Final Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA (EPA 1988a) A draft outiine of the report is shown in Table 5-2 This outline should be considered a draft and subject to revision based on the data obtained EPAs SOW for this work assignment has provided a detailed description of the types of information maps and figures to be included in the RI report CDM will incorporate such information to the fullest extent practicable

Upon completion the RI report will be submitted for internal technical and quality assurance reviews It will then be submitted to EPA for formal review and comment

5gt2 FINAL REMEDIAL INVESTIGATION REPORT

Upon receipt of all EPA and Commonwealth Agency written comments CDM will revise the report and submit the amended report to EPA When the EPA determines that the report is acceptable the report will be deemed the Final RI Report

510 TASK 10 - REMEDIAL ALTERNATIVES SCREENING

This task covers activities for development of appropriate remedial altematives that will undergo fulL evaluation CDM will investigate only those remedial altematives that will remediate or control contaminated media (ie soil) at the site to provide adequate protection of human health and the environment The initial screening of remedial altematives will be performed according to the procedures recommended in Interim Final Guidance for Conducting RIFS under CERCLA (EPA 1988a) CDM will also consider EPA presumptive remedy guidance documents when identifying and evaluating potential remedies for soil

The initial hst of remedial action objectives identified in Section 35 will be refined andor modified during the screening process as new technological andor site-specific data emerge CDM will prepare a draft technical memorandum that will document the remedial altematives screening analyses and evaluations processes The draft memorandum will be submitted to the EPA for review and comment

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5101 DRAFT TECHNICAL MEMORANDUM

The draft Technical Memorandum will include the following information

bull Establish Remedial Action Objectives Once existing data and data collected during the RI field investigation are evaluated CDM will develop the remedial action objectives in consultation with the EPA The remedial action objectives will take into consideration of the results of the risk assessment (Task 7) and should be developed to protect human health and the environment The objectives will specify the contaminant(s) of concem the exposure route(s) and receptor(s) and an acceptable contaminant level or range of levels for each exposure route (ie preliminary remediation goals)

bull Establish General Response Actions Based on the remedial action objectives general response actions for each medium will be formulated The response actions will take into account requirements for protectiveness as identified in the remedial action objectives as well as the chemical and physical characteristics of the Site

bull Identify and Screen Applicable Remedial Technologies CDM will identify and screen technologies based on the developed general response actions CDM will also consider EPA presumptive remedy guidance documents when identifying and evaluating potential remedies for soil Hazardous waste treatment technologies will be identified and screened to ensure that only those technologies applicable to the protection of the media contaminants present their physical matrix and other site characteristics will be considered This screening will be based primarily on a technologys ability to effectively address the contaminants at the Site but will also take into account a technologys implementability Cost will not be used to screen out a technology CDM will select representative process options as appropriate to carry forward into alternative development In addition CDM will identify the need for treatability testing for those technologies that are probable candidates for consideration during the detailed analysis

Develop Remedial Alternatives in accordance with the National Contingency Plan The potential altematives will encompass a full range of altematives in which treatment is used to reduce the toxicity mobility or volume of wastes but vary in the degree to which long-term management of residuals or untreated waste is required and-will include one or more altematives involving containment with little or no treatment as well as a no-action alternative

Screen Remedial Alternatives for Effectiveness Implementability and Cost CDM will screen altematives to identify the potential technologies or process options that will be combined into media-specific or site-wide altematives The developed altematives will be defined with respect to size and configuration ofthe representative process options time for remediation rates of flow or treatment spatial requirements distances for disposal and required permits imposed limitations and other factors necessary to evaluate the altematives If many distinct viable options are available and developed CDM will screen the altematives that undergo the detailed analysis to provide the most promising process options The

5-29 300715

I I I I I I I I I I I I I I I I I 1 I

altematives will be screened on a general basis with respect to their effectiveness implementability and cost The screening evaluation will generally focus on the effectiveness criterion with less emphasis on the implementability and relative cost criteria Technologies surviving the screening process are those that are expected to achieve the remedial action objectives for the Site either alone or in combination with others

5102 FINAL TECHNICAL MEMORANDUM

After the EPAs review of the draft Technical Memorandum CDM will incorporate EPAs comments and submit the final Technical Memorandum

511 TASK 11- REMEDIAL ALTERNATIVES EVALUATION

Remedial technologies passing the initial screening process will be grouped into remedial altematives These remedial altematives will be subjected to a detailed evaluation which will be performed in accordance with the Interim Final Guidance for Conducting Remedial InvestigationsFeasibility Studies under CERCLA (EPA 1988a) and the NCP In the guidance a set of nine evaluation criteria have been developed that are to be applied in the evaluation of each Remedial Altemative A brief description of each criterion is provided

o Overall Protection of Human Health and the Environment - This criterion provides a final check to assess whether each altemative meets the requirement that it is protective of human health and the environment The overall assessment of protection is based on a composite of factors assessed under the evaluation criteria especially long-term effectiveness and permanence short-term effectiveness and compliance with ARARs

Compliance with ARARs - This criterion is used to determine how each altemative complies with applicable or relevant and appropriate Federal and State requirements as defined in CERCLA Section 121

deg Long-Term Effectiveness - This criterion addresses the results of a remedial action in terms of the risk remaining at the Site after the response objectives have been met The primary focus of this evaluation is to determine the extent and effectiveness of the controls that may be required to manage the risk posed by tieatment residuals andor untreated wastes The factors to be evaluated include the magnitude of remaining risk (measured by numerical standards such as cancer risk levels) and the adequacy suitability and long-term reliability of management controls for providing continued protection from residuals (ie assessment of potential failure of the technical components)

Reduction of Toxicity Mobility or Volume - This criterion addresses the statutory preference for selecting remedial actions that employ treatment technologies that permanently and significantly reduce toxicity mobility or volume of the contaminants The factors to be evaluated incliide the treatment process employed the amount of hazardous material destroyed or treated

5-30 300716

the degree of reduction expected in toxicity mobility or volume and the type and quantity of treatment residuals

Short-Term Effectiveness - This criterion addresses the effects of the altemative during the construction and implementation phase until the remedial actions have been completed and the selected level of protection has been achieved Each altemative is evaluated with respect to its effects on the community and on-site workers during the remedial action environmental impacts resulting from implementation and the amount of time until protection is achieved

Implementability - This criterion addresses the technical and administrative feasibility of implementing an altemative and the availability of various services and materials required during its implementation Technical feasibility considers constmction and operational difficulties reliability ease of undertaking additional remedial action (if required) and the ability to monitor its effectiveness Administrative feasibility considers activities needed to coordinate with other agencies (eg state and local) in regard to obtaining permits or approvals for implementing remedial actions

Cost - This criterion addresses the capital costs annual operation and maintenance costs and present worth analysis Capital costs consist of direct (constmction) and indirect (non-construction and overhead) costs Direct costs include expenditures for the equipment labor and material necessary to perform remedial actions Indirect costs include expenditures for engineering financial and other services that are not part of actual installation activities but are required to complete the installation of remedial altematives Annual operation and maintenance costs are post-construction costs necessary to ensure the continued effectiveness of a remedial action These costs will be estimated to provide an accuracy of +50 percent to -30 percent A present worth analysis is used to evaluate expenditures that occur over different time periods by discounting all future costs to a common base year usually the current year This allows the cost of remedial action altematives to be compared on the basis of a single figure representing the amount of money that would be sufficient to cover all costs associated with the remedial action over its planned life

State Acceptance - This criterion evaluates the technical and administrative issues and concems the state may have regarding each ofthe altematives The factors to be evaluated include those features of altematives that the state supports reservations of the state and opposition of the state

Community Acceptance - This criterion incorporates public concems into the evaluation ofthe remedial altematives Often community (and also state) acceptance cannot be determined during development of the FS Evaluation of these criteria is postponed until the FS report has been released for state and public review These criteria are then addressed in the ROD and the responsiveness sununary

5-31 300717

Each remedial altemative will be subject to a detailed analysis according to the above evaluation criteria A comparative analysis of all altematives will then be performed to evaluate the relative benefits and drawbacks of each according to the same criteria The EPA will make the determination regarding final selection of the remedial altemative


CDM will prepare a draft technical memorandum which addresses the following (1) a technical description of each altemative that outlines the waste management strategy involved and identifies the key ARARs associated with each altemative and (2) a discussion that profiles the performance of that altemative with respect to each of the evaluation criteria CDM will also provide a table summarizing the results of this analysis


After EPAs review ofthe draft Technical Memorandum CDM will incorporate EPAs comments and submit the final Technical Memorandum

512 TASK 12 - FEASIBILITY STUDY REPORT

5121 DRAFT FS REPORT

CDM will develop an FS Report consisting of a detailed analysis of altematives and cost-effectiveness analysis in accordance with NCP 40 CFR Part 300 as well as the most recent guidance

CDM will prepare the draft FS Report according to the schedule in the Work Plan To expedite the development of the FS Report CDM will maintain close contact with the EPA RPM

The FS Report will contain the following

Results of Field Investigations and the Risk Assessment Remedial Action Objectives Identification and Screening of Remedial Technologies Remedial Altematives Description Detailed Analysis of Remedial Altematives and Comparative Analysis of Altematives

CDMs technical feasibility considerations will include the careful study of any problem that may prevent a remedial altemative from mitigating site problems Therefore the site characteristics from the RI will be kept in mind as the technical feasibility ofthe altemative is studied Specific items to be addressed are reliability safety operation and maintenance ease with which the altemative can be implemented and time needed for implementation

532 300718

5122 FINAL FS REPORT

Upon receipt of all of the EPAs and other Federal and State Agency written comments CDM will revise the FS report and submit the revised report to the EPA When the EPA determines that the report is acceptable the report will be deemed the Final FS Report

513 TASK 13 - POST RIFS SUPPORT

CDM will provide technical support required for the preparation of the ROD for the site excluding community relations activities already addressed under Task 2 CDMs support activities include

bull Attendance at public meetings briefings and technical meetings to provide site updates bull Review of presentation materials

bull reg Technical support for the preparation of the draft and final Responsiveness Summary Proposed Plan and ROD and

_ -bull- RreparationofaFeasibility^StudyAddendumXitrequired)based_oiLthejina^ for the site covering issues arising after finalization of the basic RIFS documents

514 TASK 14 - NEGOTIATION SUPPORT

This task is currenfly not required by EPA at this time If EPA determines it is in the best interest ofthe Govemment to consider whether a potentially responsible party (PRP) or PRP group should take over part or all of the RIFS or subsequent activities [eg remedial design (RD)] then CDM will be tasked with providing negotiation support to EPA

5141 ATTENDPROVIDE TECHNICAL SUPPORT AT NEGOTIATION MEETINGS

This task is not required by EPA at this time

5142 REVIEWCOMMENT ON PRP DOCUMENTS


515 TASK 15 - ADMINISTRATIVE RECORD


516 TASK 16 - PROIECT CLOSEOUT

Upon notification from EPA that the technical work is complete CDM will close-out the work assignment in accordance with the requirements of the contract

533 300719

5161 WORK ASSIGNMENT CLOSEOUT REPORT

CDM will prepare a Work Assignment Closeout Report (WACR) The WACR will include a breakdown of professional level of effort hours by P-leyel and costs

5162 DOCUMENT INDEXING

CDM will organize the work assignment files in its possession in accordance with the currently approved file index stmcture [eg Administrative Record Index EPA Superfund Site File Index andor ARCS Guidelines for Closeout of Work Assignment (June 1991)] For the Superfund program Section 113(k)(l) of CERCLA as amended by SARA requires EPA to establish an Administrative Record (AR) which contains all the information considered by the Agency in selecting a response action The AR for the selection of a remedial action or response decision must be made available for public inspection at the commencement of the remedial investigation phase (when the RIFS work plan is approved) The format to be used in compiling ARs is outlined in the memorandum from Don R Clay former Assistant Administrator OSWER entitled Guidance on Administrative Records for Selecting CERCLA Response Actions dated December 31990 (EPA 1990)

5J163 D O C U M E N T RETENTIONCONVERSION

CDM will convert all pertinent paper files into an appropriate long-term storage form such as microfiche If it is determined that microfiche will be used for the long term storage then the following distribution will be adhered to

Silver Halide Original Set- EPA Region 2 Diazo Duplicate - EPA Region 2 Hard Copies - EPA Region 2 Silver Hahde Original Set - CDM

5-34 300720

TABLE 5-1

SUMMARY OF SAMPLING AND ANALYSIS PROGRAM REMEDIAL INVESTIGATIONFEASIBILITY STUDY OPERABLE UNIT 2 - SOILS


Sampling Locations _

Surface Soil Sampling Residential Area

Trash Mounds Non-Residential Area Background

Subsurface Soil Sampling Trash Mounds Non-Residential Area

Residential Dust Sampling

Residential Tap Water Sampling

ltType ^ 1 - raquo V

Soil

Soil

Dust

Water

r-s^yiCAnalyticalJParameter

Pesticides PCBs TAL metals Lead only Pesticides PCBs TAL metals Pesticides PCBs TAL metals Pesticides PCBs TAL metals

Pesticides PCBs TAL metals Pesticides PCBs TAL metals

Lead only

Lead only

Field Parameters

NA

NA

NA

pH Cond Turb Temp Eh DO

îtAYSampHn|Fi |queftcyJn J -laquofgtt-Interval ( sK fl tidf

0-2 feet bgs 10 per block 0-2 feet bgs 10 per household 0-2 feet bgs 2 per trash mound 0-2 feet bgs 1 per grid point 0-2 feet bgs

5-7 feet bgs 2 per trash mound 5-7 feet bgs 1 per grid point

1 per household

1 per household

TotarNumber ltof Investigative

Samples

110 390

8 70 10

8 70

39

39

Notes

Samples associated with the optional deep soil boring program are not included Cond - Conductivity DO- Dissolved Oxygen Eh- Oxidation-Reduction Potential Temp - Temperature Turb - Turbidity

Tszooe

- 1

TAJBLE5-2

- - gt PROPOSED RI REPORT-FORMAT

10 Introduction 11 Purpose of Report 12 Site Background

121 Site Description 122 Site History 123 Previous Investigations

13 Report Organization

20 Study Area Investigation 21 Surface Features (topographic mapping etc) (natural and manmade

features) 22 Contaminant Source Investigations 23 Soil Investigation 24 Human Population Surveys

30 Physical Characteristics of Site 31 Topography 32 Meteorology 33 Surface Water and Sediment 34 Geology 35 Hydrogeology 36 Soils 37 Air Quality 38 Demographics and Land Use

40 Nature and Extent of Contamination 41 Sources of Contamination 42 Soils

50 Contaminant Fate and Transport 51 Routes of Migration 52 Contaminant Persistence 53 Contaminant Migration

OJ o o

to

RACS II WA 005 Disk 1 wBtab5-2wpd

TABLE 5-2

PROPOSED RI REPORT FORMAT - REMEDIAL ESVESTIGATIONFEXSIBILITY STUDY OPERABLE UNIT 2 - SOILS VEGABAJASOLro WA^STE DISPOSAL SITE

^ X viGA3AJA PtJERTO MCO ^ - u ^^^^^ ^7^^^ gt ^-~ ^^^ - ^ bull -

60 Baseline Risk Assessment 61 Human Health Evaluation

611 Exposure Assessment 612 Toxicity Assessment 613 Risk Characterization

70 Summary and Conclusions 71 Source(s) of Contamination 72 Nature and Extent of Contamination 73 Fate and Transport 74 Risk Assessment 75 Data Limitations and Recommendations for Future Work 76 Recommended Remedial Action Objectives

Appendices Analytical DataQAQC Evaluation Results Boring Logs Risk Assessment Models Toxicity Profiles

o o

to U)

RACS 11 WA 005 Disk 1 wptab5-2wpd

SHORT-TERM EFFECTIVENESS

Protection of community during remedial action Protection of workers during remedial actions

Time until remedial response objectives are achieved Environmental impacts

LONG-TERM EFFECTIVENESS

Magnitude of risk remaining at the site after the response objectives have been met Adequacy of controls Rehability of controls

REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT

Treatment process and remedy Amount of hazardous material destroyed or treated Reduction in toxicity mobility or volume of the contaminants Irreversibility of the treatment Type and quantity of treatment residuals

IMPLEMENTABILITY

Ability to construct technology Rehability of technology Ease of undertaking additional remedial action if necessary Monitoring considerations Coordination with other agencies Availability of treatment storage capacity and disposal services Availability of necessary equipment and specialists Availability of prospective technologies

RAC II WA 02 DISK lwptab5-3wpd

300724

I BI I 5-^

DFT ILED EV VI U VI ION lt UNI iilA1 OU K 1 M E D I A L A L T E R N A T I V E S

REMFDI VL INVESTIG VI ION J EAbmiLfDrSTUDV OPERVB1LE UNIT S- SOILS V EG V B VJA SOilD^W^SaiE DISPOS AL SITE - ^

COMPLIANCE WITH ARARs

Compliance with chemical-specific ARARs Compliance with action-specific ARARs

- Compliance with location-specific ARARs Compliance with appropriate criteria advisories and guidance

OVERALL PROTECTION OF HUMAN HEALTH AND ENVIRONMENT

STATE ACCEPTANCE

COMMUNITY ACCEPTANCE

RAC 11 WA 02 DISK lwptab5-3wpd

300725

10 Introduction 11 Purpose and Organization of Report 12 Site Description and History 13 Physical Characteristics ofthe Site 14 Source(s) of Contamination 15 Nature and Extent of Contamination 16 Contaminant Fate and Transport 17 Baseline Risk Assessment

20 Identification and Screening of Techno logics 21 Remedial Action Objectives

- Contaminants of Interest - Allowable Exposure Based on Risk Assessment - Allowable Exposure Based on ARARs - Development of Remedial Action Objectives

22 General Response Actions - Volumes - Containment - Technologies

23 Screening ofTechnology and Process Options 231 Description of Technologies 232 Evaluation of Technologies 233 Screening of Altematives - Effectiveness - Implementability - Cost

30 Development of Altematives 31 Development of Altematives 32 Screening of Altematives

321 Altemative 1 322 Altemative 2 323 Alternative 3

40 Detailed Analysis of Altematives 41 Description of Evaluation Criteria

- Short-Term Effectiveness - Long-Term Effectiveness and Permanence - Implementability

RAC II WAOl Disk lwptab5-4wpd

300726

42 Individual Analysis of Altematives -421 Altemative 1 422 Altemative 2 423 Altemative 3

43 Summary

50 Comparative Analysis of Altematives 51 Comparison Among Altematives

RAC 11 WA 01 Disk lwptab5-4wpd

300727

RIe Path cve3a_bâgisvegabaa_figun9sapr

300728

I I I I I

R I B Path cvega_bajagtsvQga_baiaJtsures-apr

I I I I I I

Figure 5-2 TAL Metals PCB and

Pesticide Sampling Blocks Remedial investigationFeasibility Study


300729

Rle P^h cAve9a_b3Ja9Svega_baja_figurBS^pr

LEGEND A Proposed Sampling Locations

1 ^ Houses bull i Mounds CZH Properties E 3 Wooded Area

A CDM 200 400 Feet

Figure 5-3 Proposed Locations of Trash Mound

Surface and Subsurface Soil Samples Remedial InvestigationFeasibility Study


3 0 0 7 3 0

FHa Panr avega_(i^ysvoga_baiaJiaums3raquoif

100 X 100 Foot Gri

Survey Control Lines

LEGEND CZ] Yards Ei3 Wooded Area

CDM

A N

200 400 Feet i

Figure 5-4 Proposed Locations for Non-Residential



3 0 0 7 3 1

60 COSTS AND KEY ASSUMPTIONS

The estimated costs for the RIFS are shown separately in Volume II of the Work Plan The proposed project schedule is included in Section 70 of this Work Plan

CDM has made the following assumptions in estimating the costs of this project

bull CDM has assumed that there will be no significant delays due to severe tropical weather conditions

bull CDM has assumed that all field activities will be performed in modified Level D or Level C health and safety protection

6-1 300732

70 SCHEDULE

A project schedule for the R]FS is presented in Figure 7-1 It is anticipated that the project schedule will be based on assumptions for durations and conditions of key events occurring on the critical and non-critical path These assumptions are as follows

bull The schedule for the field activities is dependent on access to all properties being obtained by EPA without difficulty

bull Field activities will not be significantly delayed due to severe tropical weather conditions (hurricanes and heavy rains)

bull The schedule for the field activities is dependent on dmely review and approval of the Work Plan and QAPP Addendum and the provision of adequate funding by EPA

bull The schedule for the field investigation is dependent all field activities being performed in Level D or Level C health and safety protection

bull CDM will receive validated data for analyses performed by the EPAs Contract Laboratory Program 10 weeks after sample collection

_ 300733

Figure 7-1 Proposed Project Schedule

Vega Baja Solid V ^ e Disposal Site OU2 Soils Investigation RIFS


ID Task Name Duration Start Finish 2002 2003

Sep I Oct I Nov I Dec I Jan | Feb i ~Mar I Apr | May i Jun I Jui Aug Sep I Oct Nov | Dec I Jan I Feb I Mar j Apr May I Jun i Jul I Aug Sep i Oct i Nov j Dec

10

11

12

13

14

15

16

17

18

19

20

21

22

23

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

24 bull

TASK 1 - Proiect Plannino S Support

11 Project Administation

12 Scoping Meeting

13 Conduct Site Visit

14 Develop Draft Work Plan amp Associated Cost Estimate

PrepareSubmit Draft Work Plan

EPA ReviewPRP Review

15 Negotiate amp Revise Draft Work Plan

Negotiate Budget

PrepareSubmit Final Worilt Plan

16 Evaluate Existing Data amp Documents

17 Quality Assurance Project Plan Addendum (QAPPA)

PrepareSubmit Draft lt2APPA

EPA Review

PrepareSubmit Rnal QAPPA

18 Health a Safety Plan

19 Non-RAS Analyses (Not Applicable)

110 Meetings

Meeting 1- Initial Technical Meeting

Meeting 2 - Draft Work Plan Negotiation

Meeting 3 - Draft RI Report

Meeting 4 - Rnal RI Report

Meeting 5 - Draft HHRA Report

Meeting 6 - Screening of Altematives

Meeting 7 - Draft FS Report

Meeting 8 - Final FS Report

111 Subcontractor Procurement

Analytical Laboratory

112 Perfomi Subcontract Management


113 Pathway Anaysis Report

TASK 2 - Communitv Relations

21 Community Interviews

22 Community Relations Plan

23 Public Meeting Support

24 Fact Sheet Prepartation

25 Proposed Plan Support

26 Public Notices

27 Information Repositories (Not Applicable)

28 Site Mailing List

29 Responsiveness Summary Support

TASK 3 - Field Investigation

31 Site Reconnaissance (Not Applicable)

32 Mobilization and Demobilization

Mobilization

Demobilization

35 Environmental Sampling

Background Sample Survey

Southern Site Delineation Survey

Background Surface Soil Sampling

465 days

400 days

1 day

Iday

63 days

42 days

21 days

94 days

Iday

13 days

32 days

36 days

14 days

11 days

11 days

6 days

Odays

423 days

1 day

Iday

1 day

1day

Iday

1 day

Iday

Iday

45 days

45 days

35 days

35 days

69 days

129 days

2 days

todays

75 days

75 days

30 days

Iday

Odays

Iday

Iday

370 days

Odays

125 days

15 days

5 days

46 days

5 days

3 days

2 days

1012001

1012001 bull

11282001

125C001

11222001

11222001

1212002

2192002

2192002

6122002

1012001

7222002

7222002

8^2002

8262002

7222002

11282001

11282001

2192002

4142003

522003

2172003

552003

623C003

7112003

6192002

6192002

8122002

812C002

12162002

862002

862002

8262002

10212002

10212002

8162002

10C12002

9122002

9132002

1012001

992002

992002

2242003

9302002

9302002

1072002

10102002

7112003

4112003

11282001

125C001

2182002

118OT02

2182002

5282002

2192002

6282002

11132001

992002

882002

8232002

992002

7292002

7112003

11282001

2192002

414laquo003

522003

2172003

5laquoQ003

6232003

7112003

820Q002

8202002

9272002

9272002

320Q003

1312003

872002

962002

1312003

1312003

9262002

10212002

9122002

9132002

2282003

2282003

9272002

2282003

1222002

1042002

1092002

10112002

w

w

o o -J w

Project 41 schedule Date 6272002

CDM

Task Summary


Vega Baja Solid V ^ t e Disposal Site 0U2 Soils Investigation RIFS


ID i Task Name ration 16 days

10 days

10 days

2 days

24 days

60 days

60 days

60 days

60 days

93 days

39 days

39 days

69 days

122 days

60 days

60 days

11 days

65 days

65 days

40 days

15 days

10 days

Odays

Odays

65 days

40 days

10 days

15 days

30 days

15days

todays

5 days

30 days

15 days

todays

5 days

45 days

20 days

10 days

15 days

40 days

20 days

20 days

Odays

Odays

40 days

10 days

20 days

todays

Start 10142002

10142002

10142002

10282002

10302002

12A32002

10102002

10102002

10102002

10102002

10102002

10102002

11132002

11132002

272003

11132002

2122003

2122003

2122003

212^003

4laquo2003

4302003

2122003

2122003

4^2003

4C32003

4laquo2003

4laquo2003

4302003

5142003

4302003

4002003

5212003

642003

5212003

5C12003

6182003

722003

7282003

7282003

8C52003

9222003

9222003

106C003

1132003

Finish 1142002

10252002

10Q52002

10292002

1222002

2242003

112003

112003

112003

2172003

12A32002

12A32002

2172003

512003

512003

24C003

2262003

5132003

5132003

482003

4292003

5132003

5132003

482003

4222003

5132003

5202003

4292003

5132003

5202003

6102003

5202003

6laquo2003

6102003

7222003

6172003

712003

7222003

9192003

8222003

9192003

11142003

1032003

10312003

11142003

2002 2003 Sep j Oct i Nov j Dec Jan I Feb I Mar I Apr | May | Jun i Jul I Aug Sep i Oct I Nov Dec I Jan Feb I Mar i Apr i May 1 Jun Jul i Aug | Sep I Oct Nov | Uec

51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

67

70

71

72

73

74

75

76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

99

Residential Surtece Soil Sampling



Trash Mound SurfaceSubsurface Soil Sampling

Non-Residential SurtaceSutjsurtace Sampling

38 IDW Characterization and Disposal

TASK 4 - Sample Analysis

42 Analytical Services Provided Via CLP or DESA

43 Non-Routine Analytical Services (Subcontracted Analytical Services)

TASK 5 - Analytical Support a Data Validation

51 Collect Prepare and Ship Samples

52 Sample Management

53 Data Validation

TASK 6 - Data Evaluation

61 Data Usability Evaluation

62 Data Reduction Tabulation and Evaluation

64 Technical Memorandum (Data Evaluation Report)

TASK 7 - Assessment of Risk

71 Baseline Risk Assessment (Human Health)

Draft Baseline Risk Assessment (Human Health)

EPA Review

Rnal Baseline Risk Assessment (Human Health)

72 Ecological Risk Assessment (Not Applicable)

TASK a - Treatability Study and Pilot Testing (Not Applicable)

TASK 9 - Remedial Investiaation Report

91 Draft RI Report

EPA Review

93 Final RI Report

TASK 10 - Remedial Alternative Screening

101 Draft Technical Memorandum

EPA Review

102 Final Technical Memorandum

TASK 11 - Remedial Alternative Evaluation


EPA Review

112 Rnal Technical Memorandum

Task 12 - Feasibility Study Report

121 Draft Feasibility Study Report

EPA Review

122 Final Feasibility Study Report

Task 13 - Post RIFS Support

131 FS Addendum

132 Technical Support

Task 14 - Negotiation Support (Not Applicable)

Task 15 - Administrative Record (Not Applicable)

Task 16 - Worilt Assignment Closeout

161 Worilt Assignment Closeout Report (WACR)

162 Document Indexing

163 Document RetentionConversion

wmmmmm Wmmm WyfiSvm^

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Project 41 schedule Date 5a7r2Sa2

Task Summary

CDM Page 2

80 PROJECT MANAGEMENT APPROACH

81 ORGANIZATION AND APPROACH

The proposed project organization is presented on Figure 8-1

The SM Mr Michael Valentino PO has primary responsibility for plan development and implementation of the RIFS including coordination with the FS Task Manager and support staff development of bid packages for subcontractor services acquisition of engineering or specialized technical support and all other aspects of the day-to-day activities associated with the project The SM identifies staff requirements directs and monitors site progress ensures implementation of quality procedures and adherence to applicable codes and regulations and is responsible for performance within the established budget and schedule

Ms Nancy Rodriguez will serve as the RI Task Manager and will be responsible for technical support during the field investigation coordination with the CDM subcontractor the analysis interpretation and presentation of data acquired relative to the Site and will be responsible for the preparation of the RI report

The FS Task Manager Mr Daniel Gilroy ^yill work closely with the SM to ensure that the field investigation generates the proper type and quantity of data for use in the initial screening of remedial technologiesalternatives detailed evaluation of remedial altematives development of requirements for and evaluation of treatability studypilot testing if required and associated cost analysis The FS Report will be developed by the FS technical group

The Project Geologist Ms Lisa Campbell is responsible for the activities conducted by CDM such as equipment mobilization sampling and the work performed by subcontractors

The Regional Quality Assurance Coordinator (RQAC) is Ms Jeniffer Oxford The RQAC is responsible for overall project quality including development of the QAPP Addendum review of specific task QAQC procedures and auditing of specific tasks The RQAC reports to the CDM Quality Assurance Director (QAD) The RQAC will review and approve the Draft Work Plan and QAPP Addendum

The CDM QAD RoseMary Gustin is responsible for overall project quality and will have approved Quality Assurance Coordinators (QACs) perform the required elements ofthe RAC It QA program of specific task QAQC procedures and auditing of specific tasks at estabhshed intervals These QACs report to CDMs Corporate QA Director and are independent of the SMs reporting structure

The Analytical Services Coordinator Mr Scott Kirchner will ensure that the analytical laboratories will perform analyses as described in the QAPP Addendum The ASC provides assistance with meeting EPA sample management and paperwork requirements

8-1 300736

The task numbering system for the RIFS effort is described in Section 5 of this Work Plan Each of these tasks have been scheduled and will be tracked separately during the course of the RIFS work For the RAC n contract the key elements of the Monthly Progress Report will be submitted within 20 calendar days after the end of each reporting period and will consist of a summary of work completed during that period and associated costs

Project progress meetings will be held as needed to evaluate project status discuss current items of interest and review major deliverables such as the work plan QAPP Addendum RI and FS reports

82 OUALITY ASSURANCE AND DOCUMENT CONTROL

All work by CDM on this work assignment will be performed in accordance with the following guidance documents or subsequent revisions

bull CDM RAC n Quality Management Plan (QMP) December 2001

The RQAC will maintain QA oversight of the project for the duration of the work assignment and has reviewed this Work Plan for QA requirements The RQAC will participate in the field planning meeting process It has been determined that a QAPP Addendum that governs field sampling and analysis is required It will be submitted to an approved QAC for review and approval before submittal to EPA Any reports for this work assignment which present measurement data generated during the work assignment will include a QA section addressing the quality of the data and its limitations Such reports are subject to QA review following technical review Statements of work for subcontractor services purchase requisitions for measurement and testing items and subcontractor bids and proposals will receive technical and QA review

The CDM SM is responsible for implementing appropriate QC measures on this work assignment Such QC responsibilities include

bull Implementing the QC requirements referenced or defined in this work plan and in the QAPP Addendum

bull Adhering to the CDM RAC Management Information System (RACMIS) document control system

^ Organizing and maintaining work assignment files

bull Conducting field planning meetings as needed in accordance with the RAC II QMP

bull Completing measurement and test equipment forms that specify equipment requirements

8-2 300737

Technical and QA review requirements as stated in the QMP will be followed on this work assignment

Document control aspects of the program pertain to controlling and filing documents CDM has developed a program filing system that conforms to the requirements of the EPA to ensure that the documents are properly stored and filed This guideline will be implemented to control and file all documents associated with this work assignment The system includes document receipt control procedures a file review an inspection system and file security measures

The RAC n QA program includes both self-assessments and independent assessments as checks on quality of data generated on this work assessment Self assessment include management system audits trend analyses calculation checking data validation and technical reviews Independent assessments include office field and laboratory audits and the submittal of performance evaluation samples to laboratories

A QA internal system audit field technical system audit andor laboratory technical system audit may be conducted by the CDM QA staff in accordance with QMP Performance audits (ie performance evaluation samples) may be administered by CDM as required for any analytical parameters An audit report will be prepared and distributed to the audited group to CDM management and to EPA EPA may conduct or arrange a system or performance audit

83 PROTECT COORDINATION

The SM will coordinate all project activities with the EPA RPM Regular telephone contact will be maintained to provide updates on project status Field activities at the Site will require coordination among federal state and local agencies and coordination with involved private organizations Coordination of activities with these agencies is described below

EPA is responsible for overall direction and approval of all activities for the Vega Baja Solid Waste Disposal Site EPA may designate technical advisors and experts from academia or its technical support branches to assist on the Site Agency advisors could provide important sources of technical information and review which the CDM team could use from initiation of RIFS activities through final reporting

Sources of technical information include EPA EQB and USGS These sources can be used for background information on the Site and surrounding areas

Puerto Rico through EQB may provide review direction and input during the RIFS EPAs RPM will coordinate contact with EQB personnel

Local agencies that may be involved include departments such as planning boards zoning and building commissions police fire and health department and utilities (water and sewer) Contacts with these local agencies will be coordinated through EPA

^ ^ 3 0 0 7 3 8

Private organizations requiring coordination during the RIFS include concerned residents in the area and public interest groups such as environmental organizations and the press Coordination with these interested parties will be performed through EPA

8-4 300739

FIGURE 8-1 PROJECT ORGANIZATION

Vega Baja Solid Waste Disposal Site Soil RIFS Vega Baja Puerto Rico

CORPORATE QA DIRECTOR ROSEMARY GUSTIN (P-4)

PROGRAM MANAGER ROBERT D GOLTZ PE (P-4)

TECHNICAL OPERATIONS MANAGER JEANNE LITWIN (P-4)

I

QUALITY ASSURANCE COORDINATOR

JENIFFER OXFORD (P-3) 1 SITE MANAGER

MICHAEL VALENTINO (P-3)

I

EPA PRQ JECT OFFICER FERNANDO ROSADO

EPA REMEDIAL PROJECT MANAGER

RAMON TORRES

HEALTH amp SAFETY OFFICER

CHUCK MYERS CIH (P-4)

SUBCONTRACTORS

to o o v j

o

ANALYTICAL LABORATORY

REMEDIAL INVESTIGATION LEADER

NANCY RODRIGUEZ (P-3)

FEASIBILITY STUDY LEADER

DAN GILROY (P-3)

PROJECT TEAM

J Mayo Senior Scientist (P-3) L Campbell Project Geologist (P-2) K EdeliTian Human Health Risk Assessor (P-3) J Oxford ChemistQAQC (P-3)

ANALYTICAL SERVICES

COORDINATOR SCOTT KIRCHNER (P-3)

EPAs raquoCLI

l _ l J i I

REFERENCES (continued)

US Environmental Protection Agency (EPA) 1988a Interim Guidance for Conducting Remedial InvestigationsFeasibility Studies under CERCLA Office of Emergency and Remedial Response OSWER Directive No 93553-01 Interim Final October

1989a Risk Assessment Guidance for Superfund Human Health Evaluation Manual Part A Office of Solid Waste and Emergency and Remedial Response US Environmental Protection Agency EPA5401-89002 OSWER Directive 9285701 A

1989b Risk Assessment Guidance for Superfund Vol 2 Environmental Evaluation Manual Office of Emergency and Remedial Response US Environmental Protection Agency EPA5401-89001

US EPA 1989c Region n CERCLA Quality Assurance Manual Final

1990 Guidance on Administrative Records for Selecting CERCLA Response Actions Office of Emergency and Remedial Response OSWER Directive No 98333A-1 December 3

I99la Human Health Evaluation Manual Supplemental Guidance Standard Default Exposure Factors Office of Solid Waste and Emergency Response US Environmental Protection Agency OSWER Directive 92856-03

1991b Risk Assessment Guidance for Superfund Human Health Evaluation Manual Part B Development of Risk-Based Preliminary Remediation Goals Office of Emergency and Remedial Response US Environmental Protection Agency EPA540R-92003

1992a Community Relations in Superfund A Handbook EPA-54092009

1992b Guidance for Data Useability in Risk Assessment Final Office of Emergency and Remedial Response Washington DC US Environmental Protection Agency OSWER Directive 92857-09A

1993 Guide for Conducting Treatability Studies Under CERCLA EPA540R-92071 A

1996a Soil Screening Guidance Users Guide Office of Sohd Waste and Emergency Response US Environmental Protection Agency EPA540R-96018

1996b Recommendations ofthe Technical Review Workgroup for Lead for an Interim Approach to Assessing Risks Associated with Adult Exposures to Lead in Soil

9-2 300741


1996c Region 5 Fully Integrated Environmental Location Decision Support (FIELDS) Version 10 Beta

1997a Exposure Factors Handbook Vols 1 2 and 3 Office of Research and Development US Environmental Protection Agency EPA600P-95002Fa 002Fb and 002Fc

i997h Health Effects Assessment Summary Tables FY 1997 Update EPA-540-R-97-036 July

2000 Guidance for die Data Quality Objectives Process EPA QAG-4 Office of Research and Development U S Environmental Protection Agency Washington DC EPA600R-96055 August

2001a Integrated Risk Information System On-line database of toxicity measures lthttp w w w epa go vn gispgm3iri sgt

2001b Region 9 Preliminary Remediation Goals lthttpwwwepagovregion09waste sfundprgindex htmgt

200 Ic Users Guide for the Integrated Exposure Uptake Biokinetic Model for Lead in Children (lEUBK) Windows version Prepared for the Technical Review Workgroup for Lead (TRW) by Syracuse Research Corporation 540-K-01-005

____ 200 Id Risk Assessment Guidance for Superfund Human Health Evaluation Manual Part D Office of Emergency and Remedial Response US Environmental Protection Agency Final No 92857-47 September

__ 2001e Risk Assessment Guidance For Superfund Vol 1 Human Health Evaluation Manual Part E (Supplemental Guidance Dermal Risk Assessment) Interim EPA540R99005 September

US Geological Survey (USGS) 1971 Geologic Map of the Manati Quadrangle Puerto Rico US Geological Survey Miscellaneous Geological Investigations Map 1-671

1995 Potentiometric Surface and Hydrologic Conditions ofthe Upper Aquifer in the Manati - Vega Baja Area North-Central Puerto Rico Vega Baja Puerto Rico US Geological Survey Water Resources Report 96-4184 1 pi

1999 Assessment of Nitrate Contamination ofthe Upper Aquifer in the Manati Vega Baja Puerto Rico US Geological Survey Water Resources Investigations Report 99-4040

9-3 300742

100 GLOSSARY OF ABBREVIATIONS

amsl above mean sea level ARARs Applicable or Relevant and Appropriate Requirements ASC Analytical Services Coordinator ATSDR Agency for Toxic Substances and Disease Registry bgs below ground surface BNA Base Neutral Acid CDM CDM Federal Programs Corporation CERCLA Comprehensive Environmental Response Compensation and Liability Act of 1980 CFR Code of Federal Regulations CLASS Contract Laboratory Analytical Support Services CLP Contract Laboratory Program COPC Chemical of Potential Concem CRDL Contract Required Detection Limit CRP Community Relations Plan CTE Central Tendency Exposures DDT Dichlorodiphenyltrichloroethene DESA Division of Science and Assessment DOE Department of Energy DOT Department of Transportation DQO Data Quality Objectives Eh Oxidation Reduction Potential EPA United States Environmental Protection Agency EPAAR EPA Acquisition Regulation EQB Environmental Quality Board EQuIS Environmental Quality Information System ESI Expanded Site Inspection FAR Federal Acquisition Regulation FIELDS Fully Integrated Environmental Location Decision Support FS Feasibility Study ftd feet per day GIS Geographical Information System HSP Health and Safety Plan HEA Health Effects Summary HEAST Health Effects Assessment Summary Tables HHRA Human Health Risk Assessment HI Hazard Index HRS Hazard Ranking System ICAP Inductively Coupled Argon Plasma lEUBK Integrated Exposure UptakeBiokinetic IFB Invitation for Bid

10-1 300743

GLOSSARY OF ABBREVIATIONS (continued)

IRIS Integrated Risk Information System masl meters above sea level mgkg milHgrams per kilogram mgL milligrams per liter ugkg micrograms per kilogram ugL micrograms per liter UgdL micrograms per deciliter NAAQC National Ambient Air Quality Standards NCEA National Center for Environmental Assessment NCP National Contingency Plan NLP Northern Limestone Province NPL National Priorities List OU Operable Unit PAR Pathway Analysis Report PCBs Polychlorinated biphenyls ppb parts per billion ppm parts per million PRASA Puerto Rico Aqueduct and Sewer Authority PRG Preliminary Remediation Goal PRHD Puerto Rico Housing Department PRLA Puerto Rico Land Authority PRP Potentially Responsible Party QAQC Quality AssuranceQuality Control QAC Quality Assurance Coordinator QAD Quality Assurance Director QAPP Quality Assurance Project Plan QMP Quality Management Plan RA Risk Assessment RACMIS RAC Management Information System RAGS Risk Assessment Guidance for Superfund RAS Routine Analytical Services RCRA Resource Conservation and Recovery Act RD Remedial Design RfD Reference Dose REAC Response Engineering and Analytical Contract RFP Request for Proposal RIFS Remedial InvestigationFeasibihty Study RI Remedial Investigation RME Reasonable Maximum Exposure ROD Record of Decision

300744

10-2

I I I

bull i 125 Maiden LaneSth Roor New York New York 10038 tel 212 785-9123 fax 212 785-6114

June 28 2002

Ms Helen Eng Project Officer US Environmental Protection Agency 290 Broadway - 18 Floor New York NY 10007-1866

Mr Ramon Torres Remedial Project Manager US Environmental Protection Agency Caribbean Enviroimiental Protection Division Gentro Europa Building Suite 417 1492 Ponce de Leon Avenue Stop 22 Santurce Puerto Rico 00907-4127

PROJECT RAC n Contract No 68-W-98-210 Woric Assignment No 048-RICO-02HJ

DOC CONTROL NO 3220-048-PP-WKPN-03247

SUBJECT Final Work Plan Volume I Vega Baja Solid Waste Disposal Site Remedial InvestigationFeasibility Study Operable Unit 2 - Soils Investigation Vega Baja Puerto Rico

Dear Ms Eng and Mr Torres

CDM Federal Programs Corporation (CDM) on behalf of our entire RAC II Team is pleased to submit this Final WbrkPlan Volimie I for the Remedial InvestigationFeasibility Study Operable Unit2 - Soils Investigationat the Vega Baja Soiid Waste Disposal Site in Vega Baja Puerto Rico This Final WorkPlan reflects EPA comments dated May 32002

If you have any questions regarding this work plan please contact me at your earliest convenience at (212) 785-9123

Very truly yours

CDMFEDERAL PROGRAMS CORPORATION

Robert D Goltz PI RAC n Program Manager

RDGmd Enclosure

cc D Buder EPA Region II J Litwin CDM B Irons CDM L Villatora EPA

M Valentino CDM N Rodriguez CDM RAC n Document Control

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LEGEND

SITE BOUNDARY

SUBSITE BOUNDARY

APPROX SCALE 1=20a

CDM

Figure 1-2 SITE MAP












^^ 300654







2-2 300655








2^ 300656







2-4 300657














2-5 300658




2^ 300659






3-3 300660








3-4 300661




315 CLIMATE









3-5 300662











3-6 300663







3-7 300664







3-8 300665












3-9 3 0 0 6 6 6














3-10 300667








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Commonwealth




Federal


314 300671




Commonwealth





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3-15 300672


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3^6 300673










3-17 300674









o 0 3 0 0 6 7 5

3-18

TABLE 3-1



[ Compound

Naphthalene

Pyrene


Di-n-butyl phthiate


Dieldrin

[Aroclor-1254

Range of Detection

ND-22J

ND-22J

ND-73J

ND-28J

ND-65

ND-36

ND-15


ESI 1997

ESI 1997

ESI 1997

ESI 1997 1

ESI 1997

ESI 1997

ESI 1997

Notes


3 0 0 6 7 6

TABLE 3-2



Analyte

Arsenic

Antimony

Cadmium

Chromium

Copper

Lead

Mercury

Nickel

Zinc

Range of Detection

ND-541J

ND-432J

ND-207

ND-266

ND-3600

ND-26300

ND-17

ND-287J

ND-3860




5563 Calle Arturas


5782 Los Ortiz

5462 Santa Maria

5378 Santa Maria



Notes


3 0 0 6 7 7

6715

1830

1800 mdash

Rlnc6n

6700 4 5 30

T 15

T eeoo

ATLANTIC OCEAN

Arecibo Barceloneta


45 6530

QUATERNARY

MIOCENE

EXPLANATION


CAMUY FORMATION

AYMAM6NI UMESTONE



OUGOCENE


MUCARABONES SAND

I I 1 I M bull 1

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LARES UMESTONE

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Umestone Member and


LARES UMESTONE

MIDDLE 1 ^

SAN SEBASTIAN


^ ^ -



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ly 0

600

1000 J 35000

_ _ J 30000 25000

-L J_ J_ 20000 15000 10000


I 5000

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I J J

O O O l 00 O


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663000 662230 183000


Pg^Boquilla A

182500

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5 KILOMETERS

5 IVIILES

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LEGEND


UMESTONE BEDROCK V

SOIL

WATER TABLE

GARBAGE MOUNDS

bull RESIDENCES

OJ

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I m I 4-1



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300690 5-3










300691 5-4








5110 MEETINGS


g ^ 300692











5-6 300693












300694 5-7








526 PUBLIC NOTICES




300695 5-8












5-9 300696









300697 5-10

5331 Site Visits




Residential Area




5-11 300698



Trash Mounds






Background Samples


512 300699












5-13 300700










5-14 300701












553 DATA VALIDATION


5-15 300702













^^^ 300703









Data Mapping


5-17 300704



563 MODELING








5-18 deg
















5-19 300706








^bull21 3 0 0 7 0 7















5-22 300708














5-23 300709







5-24 bull 300710









5-25 300711











5-26 300712















^^^ 300713










5-28 300714








5-29 300715











5-30 300716







5-31 300717













532 300718


















533 300719








5-34 300720

TABLE 5-1










Soil

Soil

Dust

Water




Lead only

Lead only

Field Parameters

NA

NA

NA





1 per household

1 per household


Samples

110 390

8 70 10

8 70

39

39

Notes


Tszooe

- 1

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to


TABLE 5-2







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IMPLEMENTABILITY



300724

I BI I 5-^







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300725











300726


43 Summary



300727


300728

I I I I I


I I I I I I




300729




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200 400 Feet i




3 0 0 7 3 1






6-1 300732

70 SCHEDULE







_ 300733






10

11

12

13

14

15

16

17

18

19

20

21

22

23

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

24 bull



12 Scoping Meeting






Negotiate Budget





EPA Review




110 Meetings




















26 Public Notices







Mobilization

Demobilization





465 days

400 days

1 day

Iday

63 days

42 days

21 days

94 days

Iday

13 days

32 days

36 days

14 days

11 days

11 days

6 days

Odays

423 days

1 day

Iday

1 day

1day

Iday

1 day

Iday

Iday

45 days

45 days

35 days

35 days

69 days

129 days

2 days

todays

75 days

75 days

30 days

Iday

Odays

Iday

Iday

370 days

Odays

125 days

15 days

5 days

46 days

5 days

3 days

2 days

1012001

1012001 bull

11282001

125C001

11222001

11222001

1212002

2192002

2192002

6122002

1012001

7222002

7222002

8^2002

8262002

7222002

11282001

11282001

2192002

4142003

522003

2172003

552003

623C003

7112003

6192002

6192002

8122002

812C002

12162002

862002

862002

8262002

10212002

10212002

8162002

10C12002

9122002

9132002

1012001

992002

992002

2242003

9302002

9302002

1072002

10102002

7112003

4112003

11282001

125C001

2182002

118OT02

2182002

5282002

2192002

6282002

11132001

992002

882002

8232002

992002

7292002

7112003

11282001

2192002

414laquo003

522003

2172003

5laquoQ003

6232003

7112003

820Q002

8202002

9272002

9272002

320Q003

1312003

872002

962002

1312003

1312003

9262002

10212002

9122002

9132002

2282003

2282003

9272002

2282003

1222002

1042002

1092002

10112002

w

w

o o -J w


CDM

Task Summary

Page 1





10 days

10 days

2 days

24 days

60 days

60 days

60 days

60 days

93 days

39 days

39 days

69 days

122 days

60 days

60 days

11 days

65 days

65 days

40 days

15 days

10 days

Odays

Odays

65 days

40 days

10 days

15 days

30 days

15days

todays

5 days

30 days

15 days

todays

5 days

45 days

20 days

10 days

15 days

40 days

20 days

20 days

Odays

Odays

40 days

10 days

20 days

todays

Start 10142002

10142002

10142002

10282002

10302002

12A32002

10102002

10102002

10102002

10102002

10102002

10102002

11132002

11132002

272003

11132002

2122003

2122003

2122003

212^003

4laquo2003

4302003

2122003

2122003

4^2003

4C32003

4laquo2003

4laquo2003

4302003

5142003

4302003

4002003

5212003

642003

5212003

5C12003

6182003

722003

7282003

7282003

8C52003

9222003

9222003

106C003

1132003

Finish 1142002

10252002

10Q52002

10292002

1222002

2242003

112003

112003

112003

2172003

12A32002

12A32002

2172003

512003

512003

24C003

2262003

5132003

5132003

482003

4292003

5132003

5132003

482003

4222003

5132003

5202003

4292003

5132003

5202003

6102003

5202003

6laquo2003

6102003

7222003

6172003

712003

7222003

9192003

8222003

9192003

11142003

1032003

10312003

11142003


51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

67

70

71

72

73

74

75

76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

99













53 Data Validation








EPA Review





91 Draft RI Report

EPA Review

93 Final RI Report



EPA Review




EPA Review




EPA Review



131 FS Addendum









|ijj|

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CDM











8-1 300736













8-2 300737











^ ^ 3 0 0 7 3 8


8-4 300739






I




I



RAMON TORRES



SUBCONTRACTORS

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DAN GILROY (P-3)

PROJECT TEAM


ANALYTICAL SERVICES


EPAs raquoCLI

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9-2 300741














9-3 300742



10-1 300743



300744

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LEGEND

SITE BOUNDARY

SUBSITE BOUNDARY

APPROX SCALE 1=20a

CDM

Figure 1-2 SITE MAP












^^ 300654







2-2 300655








2^ 300656







2-4 300657














2-5 300658




2^ 300659






3-3 300660








3-4 300661




315 CLIMATE









3-5 300662











3-6 300663







3-7 300664







3-8 300665












3-9 3 0 0 6 6 6














3-10 300667








^bull^^ 300668










2_j2 300669







300670 3-13



Federal




Commonwealth




Federal


314 300671




Commonwealth





Federal







3-15 300672


Commonwealth











3^6 300673










3-17 300674









o 0 3 0 0 6 7 5

3-18

TABLE 3-1



[ Compound

Naphthalene

Pyrene


Di-n-butyl phthiate


Dieldrin

[Aroclor-1254

Range of Detection

ND-22J

ND-22J

ND-73J

ND-28J

ND-65

ND-36

ND-15


ESI 1997

ESI 1997

ESI 1997

ESI 1997 1

ESI 1997

ESI 1997

ESI 1997

Notes


3 0 0 6 7 6

TABLE 3-2



Analyte

Arsenic

Antimony

Cadmium

Chromium

Copper

Lead

Mercury

Nickel

Zinc

Range of Detection

ND-541J

ND-432J

ND-207

ND-266

ND-3600

ND-26300

ND-17

ND-287J

ND-3860




5563 Calle Arturas


5782 Los Ortiz

5462 Santa Maria

5378 Santa Maria



Notes


3 0 0 6 7 7

6715

1830

1800 mdash

Rlnc6n

6700 4 5 30

T 15

T eeoo

ATLANTIC OCEAN

Arecibo Barceloneta


45 6530

QUATERNARY

MIOCENE

EXPLANATION


CAMUY FORMATION

AYMAM6NI UMESTONE



OUGOCENE


MUCARABONES SAND

I I 1 I M bull 1

-w LARES LIMESTONE



CDM




8Z900e




UJ

LU o o

CAMUY FORMATION

AYMAMON LIMESTONE


LU z m o O CD

AYMAMON UMESTONE



LATE

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UPPER MEMBER


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Umestone Member and


LARES UMESTONE


LARES UMESTONE

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE

MIDDLE 1 ^

SAN SEBASTIAN


^ ^ -



CDM




ly 0

600

1000 J 35000

_ _ J 30000 25000

-L J_ J_ 20000 15000 10000


I 5000

EXPLANATION



I J J

O O O l 00 O


CDM





663000 662230 183000


Pg^Boquilla A

182500

182230



5 KILOMETERS

5 IVIILES

EXPUNATION

bull30-

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a3M




w o

o en 00 lO

300683


m h

1500 ppm


0 200 400 Feet



300684

VEGA BAJA

PUBLIC SUPPLY WELLS





Not To Scale

LEGEND


UMESTONE BEDROCK V

SOIL

WATER TABLE

GARBAGE MOUNDS

bull RESIDENCES

OJ

o o ogt 00 Ul CDM















4-1 300686

I m I 4-1



1 4

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DEFiNrrrvE LEVEL









50 TASK PLANS










300688 5-1












300689 5-2











300690 5-3










300691 5-4








5110 MEETINGS


g ^ 300692











5-6 300693












300694 5-7








526 PUBLIC NOTICES




300695 5-8












5-9 300696









300697 5-10

5331 Site Visits




Residential Area




5-11 300698



Trash Mounds






Background Samples


512 300699












5-13 300700










5-14 300701












553 DATA VALIDATION


5-15 300702













^^^ 300703









Data Mapping


5-17 300704



563 MODELING








5-18 deg
















5-19 300706








^bull21 3 0 0 7 0 7















5-22 300708














5-23 300709







5-24 bull 300710









5-25 300711











5-26 300712















^^^ 300713










5-28 300714








5-29 300715











5-30 300716







5-31 300717













532 300718


















533 300719








5-34 300720

TABLE 5-1










Soil

Soil

Dust

Water




Lead only

Lead only

Field Parameters

NA

NA

NA





1 per household

1 per household


Samples

110 390

8 70 10

8 70

39

39

Notes


Tszooe

- 1

TAJBLE5-2










OJ o o

to


TABLE 5-2







o o

to U)









IMPLEMENTABILITY



300724

I BI I 5-^







STATE ACCEPTANCE



300725











300726


43 Summary



300727


300728

I I I I I


I I I I I I




300729




A CDM 200 400 Feet




3 0 0 7 3 0


100 X 100 Foot Gri



CDM

A N

200 400 Feet i




3 0 0 7 3 1






6-1 300732

70 SCHEDULE







_ 300733






10

11

12

13

14

15

16

17

18

19

20

21

22

23

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

24 bull



12 Scoping Meeting






Negotiate Budget





EPA Review




110 Meetings




















26 Public Notices







Mobilization

Demobilization





465 days

400 days

1 day

Iday

63 days

42 days

21 days

94 days

Iday

13 days

32 days

36 days

14 days

11 days

11 days

6 days

Odays

423 days

1 day

Iday

1 day

1day

Iday

1 day

Iday

Iday

45 days

45 days

35 days

35 days

69 days

129 days

2 days

todays

75 days

75 days

30 days

Iday

Odays

Iday

Iday

370 days

Odays

125 days

15 days

5 days

46 days

5 days

3 days

2 days

1012001

1012001 bull

11282001

125C001

11222001

11222001

1212002

2192002

2192002

6122002

1012001

7222002

7222002

8^2002

8262002

7222002

11282001

11282001

2192002

4142003

522003

2172003

552003

623C003

7112003

6192002

6192002

8122002

812C002

12162002

862002

862002

8262002

10212002

10212002

8162002

10C12002

9122002

9132002

1012001

992002

992002

2242003

9302002

9302002

1072002

10102002

7112003

4112003

11282001

125C001

2182002

118OT02

2182002

5282002

2192002

6282002

11132001

992002

882002

8232002

992002

7292002

7112003

11282001

2192002

414laquo003

522003

2172003

5laquoQ003

6232003

7112003

820Q002

8202002

9272002

9272002

320Q003

1312003

872002

962002

1312003

1312003

9262002

10212002

9122002

9132002

2282003

2282003

9272002

2282003

1222002

1042002

1092002

10112002

w

w

o o -J w


CDM

Task Summary

Page 1





10 days

10 days

2 days

24 days

60 days

60 days

60 days

60 days

93 days

39 days

39 days

69 days

122 days

60 days

60 days

11 days

65 days

65 days

40 days

15 days

10 days

Odays

Odays

65 days

40 days

10 days

15 days

30 days

15days

todays

5 days

30 days

15 days

todays

5 days

45 days

20 days

10 days

15 days

40 days

20 days

20 days

Odays

Odays

40 days

10 days

20 days

todays

Start 10142002

10142002

10142002

10282002

10302002

12A32002

10102002

10102002

10102002

10102002

10102002

10102002

11132002

11132002

272003

11132002

2122003

2122003

2122003

212^003

4laquo2003

4302003

2122003

2122003

4^2003

4C32003

4laquo2003

4laquo2003

4302003

5142003

4302003

4002003

5212003

642003

5212003

5C12003

6182003

722003

7282003

7282003

8C52003

9222003

9222003

106C003

1132003

Finish 1142002

10252002

10Q52002

10292002

1222002

2242003

112003

112003

112003

2172003

12A32002

12A32002

2172003

512003

512003

24C003

2262003

5132003

5132003

482003

4292003

5132003

5132003

482003

4222003

5132003

5202003

4292003

5132003

5202003

6102003

5202003

6laquo2003

6102003

7222003

6172003

712003

7222003

9192003

8222003

9192003

11142003

1032003

10312003

11142003


51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

67

70

71

72

73

74

75

76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

99













53 Data Validation








EPA Review





91 Draft RI Report

EPA Review

93 Final RI Report



EPA Review




EPA Review




EPA Review



131 FS Addendum









|ijj|

w

o o laquoJ w I m i


Task Summary

CDM Page 2











8-1 300736













8-2 300737











^ ^ 3 0 0 7 3 8


8-4 300739






I




I



RAMON TORRES



SUBCONTRACTORS

to o o v j

o





DAN GILROY (P-3)

PROJECT TEAM


ANALYTICAL SERVICES


EPAs raquoCLI

l _ l J i I














9-2 300741














9-3 300742



10-1 300743



300744

10-2














bull 3 0 0 6 4 5














-iii-300646





r Section Page J













0


70 SCHEDULE 7-1


-iv- 3 00647

n








-vn-300648

10 INTRODUCTION








1-1 300649









1-2 300650














1-3 300651

i -c^^- ^ gt ^ 4g--l- M



CDM



LEGEND

SITE BOUNDARY

SUBSITE BOUNDARY

APPROX SCALE 1=20a

CDM

Figure 1-2 SITE MAP












^^ 300654







2-2 300655








2^ 300656







2-4 300657














2-5 300658




2^ 300659






3-3 300660








3-4 300661




315 CLIMATE









3-5 300662











3-6 300663







3-7 300664







3-8 300665












3-9 3 0 0 6 6 6














3-10 300667








^bull^^ 300668










2_j2 300669







300670 3-13



Federal




Commonwealth




Federal


314 300671




Commonwealth





Federal







3-15 300672


Commonwealth











3^6 300673










3-17 300674









o 0 3 0 0 6 7 5

3-18

TABLE 3-1



[ Compound

Naphthalene

Pyrene


Di-n-butyl phthiate


Dieldrin

[Aroclor-1254

Range of Detection

ND-22J

ND-22J

ND-73J

ND-28J

ND-65

ND-36

ND-15


ESI 1997

ESI 1997

ESI 1997

ESI 1997 1

ESI 1997

ESI 1997

ESI 1997

Notes


3 0 0 6 7 6

TABLE 3-2



Analyte

Arsenic

Antimony

Cadmium

Chromium

Copper

Lead

Mercury

Nickel

Zinc

Range of Detection

ND-541J

ND-432J

ND-207

ND-266

ND-3600

ND-26300

ND-17

ND-287J

ND-3860




5563 Calle Arturas


5782 Los Ortiz

5462 Santa Maria

5378 Santa Maria



Notes


3 0 0 6 7 7

6715

1830

1800 mdash

Rlnc6n

6700 4 5 30

T 15

T eeoo

ATLANTIC OCEAN

Arecibo Barceloneta


45 6530

QUATERNARY

MIOCENE

EXPLANATION


CAMUY FORMATION

AYMAM6NI UMESTONE



OUGOCENE


MUCARABONES SAND

I I 1 I M bull 1

-w LARES LIMESTONE



CDM




8Z900e




UJ

LU o o

CAMUY FORMATION

AYMAMON LIMESTONE


LU z m o O CD

AYMAMON UMESTONE



LATE

o

o m a O

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE


LARES UMESTONE

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE

MIDDLE 1 ^

SAN SEBASTIAN


^ ^ -



CDM




ly 0

600

1000 J 35000

_ _ J 30000 25000

-L J_ J_ 20000 15000 10000


I 5000

EXPLANATION



I J J

O O O l 00 O


CDM





663000 662230 183000


Pg^Boquilla A

182500

182230



5 KILOMETERS

5 IVIILES

EXPUNATION

bull30-

^




a3M




w o

o en 00 lO

300683


m h

1500 ppm


0 200 400 Feet



300684

VEGA BAJA

PUBLIC SUPPLY WELLS





Not To Scale

LEGEND


UMESTONE BEDROCK V

SOIL

WATER TABLE

GARBAGE MOUNDS

bull RESIDENCES

OJ

o o ogt 00 Ul CDM















4-1 300686

I m I 4-1



1 4

-laquoc







DEFiNrrrvE LEVEL









50 TASK PLANS










300688 5-1












300689 5-2











300690 5-3










300691 5-4








5110 MEETINGS


g ^ 300692











5-6 300693












300694 5-7








526 PUBLIC NOTICES




300695 5-8












5-9 300696









300697 5-10

5331 Site Visits




Residential Area




5-11 300698



Trash Mounds






Background Samples


512 300699












5-13 300700










5-14 300701












553 DATA VALIDATION


5-15 300702













^^^ 300703









Data Mapping


5-17 300704



563 MODELING








5-18 deg
















5-19 300706








^bull21 3 0 0 7 0 7















5-22 300708














5-23 300709







5-24 bull 300710









5-25 300711











5-26 300712















^^^ 300713










5-28 300714








5-29 300715











5-30 300716







5-31 300717













532 300718


















533 300719








5-34 300720

TABLE 5-1










Soil

Soil

Dust

Water




Lead only

Lead only

Field Parameters

NA

NA

NA





1 per household

1 per household


Samples

110 390

8 70 10

8 70

39

39

Notes


Tszooe

- 1

TAJBLE5-2










OJ o o

to


TABLE 5-2







o o

to U)









IMPLEMENTABILITY



300724

I BI I 5-^







STATE ACCEPTANCE



300725











300726


43 Summary



300727


300728

I I I I I


I I I I I I




300729




A CDM 200 400 Feet




3 0 0 7 3 0


100 X 100 Foot Gri



CDM

A N

200 400 Feet i




3 0 0 7 3 1






6-1 300732

70 SCHEDULE







_ 300733






10

11

12

13

14

15

16

17

18

19

20

21

22

23

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

24 bull



12 Scoping Meeting






Negotiate Budget





EPA Review




110 Meetings




















26 Public Notices







Mobilization

Demobilization





465 days

400 days

1 day

Iday

63 days

42 days

21 days

94 days

Iday

13 days

32 days

36 days

14 days

11 days

11 days

6 days

Odays

423 days

1 day

Iday

1 day

1day

Iday

1 day

Iday

Iday

45 days

45 days

35 days

35 days

69 days

129 days

2 days

todays

75 days

75 days

30 days

Iday

Odays

Iday

Iday

370 days

Odays

125 days

15 days

5 days

46 days

5 days

3 days

2 days

1012001

1012001 bull

11282001

125C001

11222001

11222001

1212002

2192002

2192002

6122002

1012001

7222002

7222002

8^2002

8262002

7222002

11282001

11282001

2192002

4142003

522003

2172003

552003

623C003

7112003

6192002

6192002

8122002

812C002

12162002

862002

862002

8262002

10212002

10212002

8162002

10C12002

9122002

9132002

1012001

992002

992002

2242003

9302002

9302002

1072002

10102002

7112003

4112003

11282001

125C001

2182002

118OT02

2182002

5282002

2192002

6282002

11132001

992002

882002

8232002

992002

7292002

7112003

11282001

2192002

414laquo003

522003

2172003

5laquoQ003

6232003

7112003

820Q002

8202002

9272002

9272002

320Q003

1312003

872002

962002

1312003

1312003

9262002

10212002

9122002

9132002

2282003

2282003

9272002

2282003

1222002

1042002

1092002

10112002

w

w

o o -J w


CDM

Task Summary

Page 1





10 days

10 days

2 days

24 days

60 days

60 days

60 days

60 days

93 days

39 days

39 days

69 days

122 days

60 days

60 days

11 days

65 days

65 days

40 days

15 days

10 days

Odays

Odays

65 days

40 days

10 days

15 days

30 days

15days

todays

5 days

30 days

15 days

todays

5 days

45 days

20 days

10 days

15 days

40 days

20 days

20 days

Odays

Odays

40 days

10 days

20 days

todays

Start 10142002

10142002

10142002

10282002

10302002

12A32002

10102002

10102002

10102002

10102002

10102002

10102002

11132002

11132002

272003

11132002

2122003

2122003

2122003

212^003

4laquo2003

4302003

2122003

2122003

4^2003

4C32003

4laquo2003

4laquo2003

4302003

5142003

4302003

4002003

5212003

642003

5212003

5C12003

6182003

722003

7282003

7282003

8C52003

9222003

9222003

106C003

1132003

Finish 1142002

10252002

10Q52002

10292002

1222002

2242003

112003

112003

112003

2172003

12A32002

12A32002

2172003

512003

512003

24C003

2262003

5132003

5132003

482003

4292003

5132003

5132003

482003

4222003

5132003

5202003

4292003

5132003

5202003

6102003

5202003

6laquo2003

6102003

7222003

6172003

712003

7222003

9192003

8222003

9192003

11142003

1032003

10312003

11142003


51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

67

70

71

72

73

74

75

76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

99













53 Data Validation








EPA Review





91 Draft RI Report

EPA Review

93 Final RI Report



EPA Review




EPA Review




EPA Review



131 FS Addendum









|ijj|

w

o o laquoJ w I m i


Task Summary

CDM Page 2











8-1 300736













8-2 300737











^ ^ 3 0 0 7 3 8


8-4 300739






I




I



RAMON TORRES



SUBCONTRACTORS

to o o v j

o





DAN GILROY (P-3)

PROJECT TEAM


ANALYTICAL SERVICES


EPAs raquoCLI

l _ l J i I














9-2 300741














9-3 300742



10-1 300743



300744

10-2














-iii-300646





r Section Page J













0


70 SCHEDULE 7-1


-iv- 3 00647

n








-vn-300648

10 INTRODUCTION








1-1 300649









1-2 300650














1-3 300651

i -c^^- ^ gt ^ 4g--l- M



CDM



LEGEND

SITE BOUNDARY

SUBSITE BOUNDARY

APPROX SCALE 1=20a

CDM

Figure 1-2 SITE MAP












^^ 300654







2-2 300655








2^ 300656







2-4 300657














2-5 300658




2^ 300659






3-3 300660








3-4 300661




315 CLIMATE









3-5 300662











3-6 300663







3-7 300664







3-8 300665












3-9 3 0 0 6 6 6














3-10 300667








^bull^^ 300668










2_j2 300669







300670 3-13



Federal




Commonwealth




Federal


314 300671




Commonwealth





Federal







3-15 300672


Commonwealth











3^6 300673










3-17 300674









o 0 3 0 0 6 7 5

3-18

TABLE 3-1



[ Compound

Naphthalene

Pyrene


Di-n-butyl phthiate


Dieldrin

[Aroclor-1254

Range of Detection

ND-22J

ND-22J

ND-73J

ND-28J

ND-65

ND-36

ND-15


ESI 1997

ESI 1997

ESI 1997

ESI 1997 1

ESI 1997

ESI 1997

ESI 1997

Notes


3 0 0 6 7 6

TABLE 3-2



Analyte

Arsenic

Antimony

Cadmium

Chromium

Copper

Lead

Mercury

Nickel

Zinc

Range of Detection

ND-541J

ND-432J

ND-207

ND-266

ND-3600

ND-26300

ND-17

ND-287J

ND-3860




5563 Calle Arturas


5782 Los Ortiz

5462 Santa Maria

5378 Santa Maria



Notes


3 0 0 6 7 7

6715

1830

1800 mdash

Rlnc6n

6700 4 5 30

T 15

T eeoo

ATLANTIC OCEAN

Arecibo Barceloneta


45 6530

QUATERNARY

MIOCENE

EXPLANATION


CAMUY FORMATION

AYMAM6NI UMESTONE



OUGOCENE


MUCARABONES SAND

I I 1 I M bull 1

-w LARES LIMESTONE



CDM




8Z900e




UJ

LU o o

CAMUY FORMATION

AYMAMON LIMESTONE


LU z m o O CD

AYMAMON UMESTONE



LATE

o

o m a O

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE


LARES UMESTONE

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE

MIDDLE 1 ^

SAN SEBASTIAN


^ ^ -



CDM




ly 0

600

1000 J 35000

_ _ J 30000 25000

-L J_ J_ 20000 15000 10000


I 5000

EXPLANATION



I J J

O O O l 00 O


CDM





663000 662230 183000


Pg^Boquilla A

182500

182230



5 KILOMETERS

5 IVIILES

EXPUNATION

bull30-

^




a3M




w o

o en 00 lO

300683


m h

1500 ppm


0 200 400 Feet



300684

VEGA BAJA

PUBLIC SUPPLY WELLS





Not To Scale

LEGEND


UMESTONE BEDROCK V

SOIL

WATER TABLE

GARBAGE MOUNDS

bull RESIDENCES

OJ

o o ogt 00 Ul CDM















4-1 300686

I m I 4-1



1 4

-laquoc







DEFiNrrrvE LEVEL









50 TASK PLANS










300688 5-1












300689 5-2











300690 5-3










300691 5-4








5110 MEETINGS


g ^ 300692











5-6 300693












300694 5-7








526 PUBLIC NOTICES




300695 5-8












5-9 300696









300697 5-10

5331 Site Visits




Residential Area




5-11 300698



Trash Mounds






Background Samples


512 300699












5-13 300700










5-14 300701












553 DATA VALIDATION


5-15 300702













^^^ 300703









Data Mapping


5-17 300704



563 MODELING








5-18 deg
















5-19 300706








^bull21 3 0 0 7 0 7















5-22 300708














5-23 300709







5-24 bull 300710









5-25 300711











5-26 300712















^^^ 300713










5-28 300714








5-29 300715











5-30 300716







5-31 300717













532 300718


















533 300719








5-34 300720

TABLE 5-1










Soil

Soil

Dust

Water




Lead only

Lead only

Field Parameters

NA

NA

NA





1 per household

1 per household


Samples

110 390

8 70 10

8 70

39

39

Notes


Tszooe

- 1

TAJBLE5-2










OJ o o

to


TABLE 5-2







o o

to U)









IMPLEMENTABILITY



300724

I BI I 5-^







STATE ACCEPTANCE



300725











300726


43 Summary



300727


300728

I I I I I


I I I I I I




300729




A CDM 200 400 Feet




3 0 0 7 3 0


100 X 100 Foot Gri



CDM

A N

200 400 Feet i




3 0 0 7 3 1






6-1 300732

70 SCHEDULE







_ 300733






10

11

12

13

14

15

16

17

18

19

20

21

22

23

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

24 bull



12 Scoping Meeting






Negotiate Budget





EPA Review




110 Meetings




















26 Public Notices







Mobilization

Demobilization





465 days

400 days

1 day

Iday

63 days

42 days

21 days

94 days

Iday

13 days

32 days

36 days

14 days

11 days

11 days

6 days

Odays

423 days

1 day

Iday

1 day

1day

Iday

1 day

Iday

Iday

45 days

45 days

35 days

35 days

69 days

129 days

2 days

todays

75 days

75 days

30 days

Iday

Odays

Iday

Iday

370 days

Odays

125 days

15 days

5 days

46 days

5 days

3 days

2 days

1012001

1012001 bull

11282001

125C001

11222001

11222001

1212002

2192002

2192002

6122002

1012001

7222002

7222002

8^2002

8262002

7222002

11282001

11282001

2192002

4142003

522003

2172003

552003

623C003

7112003

6192002

6192002

8122002

812C002

12162002

862002

862002

8262002

10212002

10212002

8162002

10C12002

9122002

9132002

1012001

992002

992002

2242003

9302002

9302002

1072002

10102002

7112003

4112003

11282001

125C001

2182002

118OT02

2182002

5282002

2192002

6282002

11132001

992002

882002

8232002

992002

7292002

7112003

11282001

2192002

414laquo003

522003

2172003

5laquoQ003

6232003

7112003

820Q002

8202002

9272002

9272002

320Q003

1312003

872002

962002

1312003

1312003

9262002

10212002

9122002

9132002

2282003

2282003

9272002

2282003

1222002

1042002

1092002

10112002

w

w

o o -J w


CDM

Task Summary

Page 1





10 days

10 days

2 days

24 days

60 days

60 days

60 days

60 days

93 days

39 days

39 days

69 days

122 days

60 days

60 days

11 days

65 days

65 days

40 days

15 days

10 days

Odays

Odays

65 days

40 days

10 days

15 days

30 days

15days

todays

5 days

30 days

15 days

todays

5 days

45 days

20 days

10 days

15 days

40 days

20 days

20 days

Odays

Odays

40 days

10 days

20 days

todays

Start 10142002

10142002

10142002

10282002

10302002

12A32002

10102002

10102002

10102002

10102002

10102002

10102002

11132002

11132002

272003

11132002

2122003

2122003

2122003

212^003

4laquo2003

4302003

2122003

2122003

4^2003

4C32003

4laquo2003

4laquo2003

4302003

5142003

4302003

4002003

5212003

642003

5212003

5C12003

6182003

722003

7282003

7282003

8C52003

9222003

9222003

106C003

1132003

Finish 1142002

10252002

10Q52002

10292002

1222002

2242003

112003

112003

112003

2172003

12A32002

12A32002

2172003

512003

512003

24C003

2262003

5132003

5132003

482003

4292003

5132003

5132003

482003

4222003

5132003

5202003

4292003

5132003

5202003

6102003

5202003

6laquo2003

6102003

7222003

6172003

712003

7222003

9192003

8222003

9192003

11142003

1032003

10312003

11142003


51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

67

70

71

72

73

74

75

76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

99













53 Data Validation








EPA Review





91 Draft RI Report

EPA Review

93 Final RI Report



EPA Review




EPA Review




EPA Review



131 FS Addendum









|ijj|

w

o o laquoJ w I m i


Task Summary

CDM Page 2











8-1 300736













8-2 300737











^ ^ 3 0 0 7 3 8


8-4 300739






I




I



RAMON TORRES



SUBCONTRACTORS

to o o v j

o





DAN GILROY (P-3)

PROJECT TEAM


ANALYTICAL SERVICES


EPAs raquoCLI

l _ l J i I














9-2 300741














9-3 300742



10-1 300743



300744

10-2





r Section Page J













0


70 SCHEDULE 7-1


-iv- 3 00647

n








-vn-300648

10 INTRODUCTION








1-1 300649









1-2 300650














1-3 300651

i -c^^- ^ gt ^ 4g--l- M



CDM



LEGEND

SITE BOUNDARY

SUBSITE BOUNDARY

APPROX SCALE 1=20a

CDM

Figure 1-2 SITE MAP












^^ 300654







2-2 300655








2^ 300656







2-4 300657














2-5 300658




2^ 300659






3-3 300660








3-4 300661




315 CLIMATE









3-5 300662











3-6 300663







3-7 300664







3-8 300665












3-9 3 0 0 6 6 6














3-10 300667








^bull^^ 300668










2_j2 300669







300670 3-13



Federal




Commonwealth




Federal


314 300671




Commonwealth





Federal







3-15 300672


Commonwealth











3^6 300673










3-17 300674









o 0 3 0 0 6 7 5

3-18

TABLE 3-1



[ Compound

Naphthalene

Pyrene


Di-n-butyl phthiate


Dieldrin

[Aroclor-1254

Range of Detection

ND-22J

ND-22J

ND-73J

ND-28J

ND-65

ND-36

ND-15


ESI 1997

ESI 1997

ESI 1997

ESI 1997 1

ESI 1997

ESI 1997

ESI 1997

Notes


3 0 0 6 7 6

TABLE 3-2



Analyte

Arsenic

Antimony

Cadmium

Chromium

Copper

Lead

Mercury

Nickel

Zinc

Range of Detection

ND-541J

ND-432J

ND-207

ND-266

ND-3600

ND-26300

ND-17

ND-287J

ND-3860




5563 Calle Arturas


5782 Los Ortiz

5462 Santa Maria

5378 Santa Maria



Notes


3 0 0 6 7 7

6715

1830

1800 mdash

Rlnc6n

6700 4 5 30

T 15

T eeoo

ATLANTIC OCEAN

Arecibo Barceloneta


45 6530

QUATERNARY

MIOCENE

EXPLANATION


CAMUY FORMATION

AYMAM6NI UMESTONE



OUGOCENE


MUCARABONES SAND

I I 1 I M bull 1

-w LARES LIMESTONE



CDM




8Z900e




UJ

LU o o

CAMUY FORMATION

AYMAMON LIMESTONE


LU z m o O CD

AYMAMON UMESTONE



LATE

o

o m a O

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE


LARES UMESTONE

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE

MIDDLE 1 ^

SAN SEBASTIAN


^ ^ -



CDM




ly 0

600

1000 J 35000

_ _ J 30000 25000

-L J_ J_ 20000 15000 10000


I 5000

EXPLANATION



I J J

O O O l 00 O


CDM





663000 662230 183000


Pg^Boquilla A

182500

182230



5 KILOMETERS

5 IVIILES

EXPUNATION

bull30-

^




a3M




w o

o en 00 lO

300683


m h

1500 ppm


0 200 400 Feet



300684

VEGA BAJA

PUBLIC SUPPLY WELLS





Not To Scale

LEGEND


UMESTONE BEDROCK V

SOIL

WATER TABLE

GARBAGE MOUNDS

bull RESIDENCES

OJ

o o ogt 00 Ul CDM















4-1 300686

I m I 4-1



1 4

-laquoc







DEFiNrrrvE LEVEL









50 TASK PLANS










300688 5-1












300689 5-2











300690 5-3










300691 5-4








5110 MEETINGS


g ^ 300692











5-6 300693












300694 5-7








526 PUBLIC NOTICES




300695 5-8












5-9 300696









300697 5-10

5331 Site Visits




Residential Area




5-11 300698



Trash Mounds






Background Samples


512 300699












5-13 300700










5-14 300701












553 DATA VALIDATION


5-15 300702













^^^ 300703









Data Mapping


5-17 300704



563 MODELING








5-18 deg
















5-19 300706








^bull21 3 0 0 7 0 7















5-22 300708














5-23 300709







5-24 bull 300710









5-25 300711











5-26 300712















^^^ 300713










5-28 300714








5-29 300715











5-30 300716







5-31 300717













532 300718


















533 300719








5-34 300720

TABLE 5-1










Soil

Soil

Dust

Water




Lead only

Lead only

Field Parameters

NA

NA

NA





1 per household

1 per household


Samples

110 390

8 70 10

8 70

39

39

Notes


Tszooe

- 1

TAJBLE5-2










OJ o o

to


TABLE 5-2







o o

to U)









IMPLEMENTABILITY



300724

I BI I 5-^







STATE ACCEPTANCE



300725











300726


43 Summary



300727


300728

I I I I I


I I I I I I




300729




A CDM 200 400 Feet




3 0 0 7 3 0


100 X 100 Foot Gri



CDM

A N

200 400 Feet i




3 0 0 7 3 1






6-1 300732

70 SCHEDULE







_ 300733






10

11

12

13

14

15

16

17

18

19

20

21

22

23

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

24 bull



12 Scoping Meeting






Negotiate Budget





EPA Review




110 Meetings




















26 Public Notices







Mobilization

Demobilization





465 days

400 days

1 day

Iday

63 days

42 days

21 days

94 days

Iday

13 days

32 days

36 days

14 days

11 days

11 days

6 days

Odays

423 days

1 day

Iday

1 day

1day

Iday

1 day

Iday

Iday

45 days

45 days

35 days

35 days

69 days

129 days

2 days

todays

75 days

75 days

30 days

Iday

Odays

Iday

Iday

370 days

Odays

125 days

15 days

5 days

46 days

5 days

3 days

2 days

1012001

1012001 bull

11282001

125C001

11222001

11222001

1212002

2192002

2192002

6122002

1012001

7222002

7222002

8^2002

8262002

7222002

11282001

11282001

2192002

4142003

522003

2172003

552003

623C003

7112003

6192002

6192002

8122002

812C002

12162002

862002

862002

8262002

10212002

10212002

8162002

10C12002

9122002

9132002

1012001

992002

992002

2242003

9302002

9302002

1072002

10102002

7112003

4112003

11282001

125C001

2182002

118OT02

2182002

5282002

2192002

6282002

11132001

992002

882002

8232002

992002

7292002

7112003

11282001

2192002

414laquo003

522003

2172003

5laquoQ003

6232003

7112003

820Q002

8202002

9272002

9272002

320Q003

1312003

872002

962002

1312003

1312003

9262002

10212002

9122002

9132002

2282003

2282003

9272002

2282003

1222002

1042002

1092002

10112002

w

w

o o -J w


CDM

Task Summary

Page 1





10 days

10 days

2 days

24 days

60 days

60 days

60 days

60 days

93 days

39 days

39 days

69 days

122 days

60 days

60 days

11 days

65 days

65 days

40 days

15 days

10 days

Odays

Odays

65 days

40 days

10 days

15 days

30 days

15days

todays

5 days

30 days

15 days

todays

5 days

45 days

20 days

10 days

15 days

40 days

20 days

20 days

Odays

Odays

40 days

10 days

20 days

todays

Start 10142002

10142002

10142002

10282002

10302002

12A32002

10102002

10102002

10102002

10102002

10102002

10102002

11132002

11132002

272003

11132002

2122003

2122003

2122003

212^003

4laquo2003

4302003

2122003

2122003

4^2003

4C32003

4laquo2003

4laquo2003

4302003

5142003

4302003

4002003

5212003

642003

5212003

5C12003

6182003

722003

7282003

7282003

8C52003

9222003

9222003

106C003

1132003

Finish 1142002

10252002

10Q52002

10292002

1222002

2242003

112003

112003

112003

2172003

12A32002

12A32002

2172003

512003

512003

24C003

2262003

5132003

5132003

482003

4292003

5132003

5132003

482003

4222003

5132003

5202003

4292003

5132003

5202003

6102003

5202003

6laquo2003

6102003

7222003

6172003

712003

7222003

9192003

8222003

9192003

11142003

1032003

10312003

11142003


51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

67

70

71

72

73

74

75

76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

99













53 Data Validation








EPA Review





91 Draft RI Report

EPA Review

93 Final RI Report



EPA Review




EPA Review




EPA Review



131 FS Addendum









|ijj|

w

o o laquoJ w I m i


Task Summary

CDM Page 2











8-1 300736













8-2 300737











^ ^ 3 0 0 7 3 8


8-4 300739






I




I



RAMON TORRES



SUBCONTRACTORS

to o o v j

o





DAN GILROY (P-3)

PROJECT TEAM


ANALYTICAL SERVICES


EPAs raquoCLI

l _ l J i I














9-2 300741














9-3 300742



10-1 300743



300744

10-2








-vn-300648

10 INTRODUCTION








1-1 300649









1-2 300650














1-3 300651

i -c^^- ^ gt ^ 4g--l- M



CDM



LEGEND

SITE BOUNDARY

SUBSITE BOUNDARY

APPROX SCALE 1=20a

CDM

Figure 1-2 SITE MAP












^^ 300654







2-2 300655








2^ 300656







2-4 300657














2-5 300658




2^ 300659






3-3 300660








3-4 300661




315 CLIMATE









3-5 300662











3-6 300663







3-7 300664







3-8 300665












3-9 3 0 0 6 6 6














3-10 300667








^bull^^ 300668










2_j2 300669







300670 3-13



Federal




Commonwealth




Federal


314 300671




Commonwealth





Federal







3-15 300672


Commonwealth











3^6 300673










3-17 300674









o 0 3 0 0 6 7 5

3-18

TABLE 3-1



[ Compound

Naphthalene

Pyrene


Di-n-butyl phthiate


Dieldrin

[Aroclor-1254

Range of Detection

ND-22J

ND-22J

ND-73J

ND-28J

ND-65

ND-36

ND-15


ESI 1997

ESI 1997

ESI 1997

ESI 1997 1

ESI 1997

ESI 1997

ESI 1997

Notes


3 0 0 6 7 6

TABLE 3-2



Analyte

Arsenic

Antimony

Cadmium

Chromium

Copper

Lead

Mercury

Nickel

Zinc

Range of Detection

ND-541J

ND-432J

ND-207

ND-266

ND-3600

ND-26300

ND-17

ND-287J

ND-3860




5563 Calle Arturas


5782 Los Ortiz

5462 Santa Maria

5378 Santa Maria



Notes


3 0 0 6 7 7

6715

1830

1800 mdash

Rlnc6n

6700 4 5 30

T 15

T eeoo

ATLANTIC OCEAN

Arecibo Barceloneta


45 6530

QUATERNARY

MIOCENE

EXPLANATION


CAMUY FORMATION

AYMAM6NI UMESTONE



OUGOCENE


MUCARABONES SAND

I I 1 I M bull 1

-w LARES LIMESTONE



CDM




8Z900e




UJ

LU o o

CAMUY FORMATION

AYMAMON LIMESTONE


LU z m o O CD

AYMAMON UMESTONE



LATE

o

o m a O

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE


LARES UMESTONE

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE

MIDDLE 1 ^

SAN SEBASTIAN


^ ^ -



CDM




ly 0

600

1000 J 35000

_ _ J 30000 25000

-L J_ J_ 20000 15000 10000


I 5000

EXPLANATION



I J J

O O O l 00 O


CDM





663000 662230 183000


Pg^Boquilla A

182500

182230



5 KILOMETERS

5 IVIILES

EXPUNATION

bull30-

^




a3M




w o

o en 00 lO

300683


m h

1500 ppm


0 200 400 Feet



300684

VEGA BAJA

PUBLIC SUPPLY WELLS





Not To Scale

LEGEND


UMESTONE BEDROCK V

SOIL

WATER TABLE

GARBAGE MOUNDS

bull RESIDENCES

OJ

o o ogt 00 Ul CDM















4-1 300686

I m I 4-1



1 4

-laquoc







DEFiNrrrvE LEVEL









50 TASK PLANS










300688 5-1












300689 5-2











300690 5-3










300691 5-4








5110 MEETINGS


g ^ 300692











5-6 300693












300694 5-7








526 PUBLIC NOTICES




300695 5-8












5-9 300696









300697 5-10

5331 Site Visits




Residential Area




5-11 300698



Trash Mounds






Background Samples


512 300699












5-13 300700










5-14 300701












553 DATA VALIDATION


5-15 300702













^^^ 300703









Data Mapping


5-17 300704



563 MODELING








5-18 deg
















5-19 300706








^bull21 3 0 0 7 0 7















5-22 300708














5-23 300709







5-24 bull 300710









5-25 300711











5-26 300712















^^^ 300713










5-28 300714








5-29 300715











5-30 300716







5-31 300717













532 300718


















533 300719








5-34 300720

TABLE 5-1










Soil

Soil

Dust

Water




Lead only

Lead only

Field Parameters

NA

NA

NA





1 per household

1 per household


Samples

110 390

8 70 10

8 70

39

39

Notes


Tszooe

- 1

TAJBLE5-2










OJ o o

to


TABLE 5-2







o o

to U)









IMPLEMENTABILITY



300724

I BI I 5-^







STATE ACCEPTANCE



300725











300726


43 Summary



300727


300728

I I I I I


I I I I I I




300729




A CDM 200 400 Feet




3 0 0 7 3 0


100 X 100 Foot Gri



CDM

A N

200 400 Feet i




3 0 0 7 3 1






6-1 300732

70 SCHEDULE







_ 300733






10

11

12

13

14

15

16

17

18

19

20

21

22

23

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

24 bull



12 Scoping Meeting






Negotiate Budget





EPA Review




110 Meetings




















26 Public Notices







Mobilization

Demobilization





465 days

400 days

1 day

Iday

63 days

42 days

21 days

94 days

Iday

13 days

32 days

36 days

14 days

11 days

11 days

6 days

Odays

423 days

1 day

Iday

1 day

1day

Iday

1 day

Iday

Iday

45 days

45 days

35 days

35 days

69 days

129 days

2 days

todays

75 days

75 days

30 days

Iday

Odays

Iday

Iday

370 days

Odays

125 days

15 days

5 days

46 days

5 days

3 days

2 days

1012001

1012001 bull

11282001

125C001

11222001

11222001

1212002

2192002

2192002

6122002

1012001

7222002

7222002

8^2002

8262002

7222002

11282001

11282001

2192002

4142003

522003

2172003

552003

623C003

7112003

6192002

6192002

8122002

812C002

12162002

862002

862002

8262002

10212002

10212002

8162002

10C12002

9122002

9132002

1012001

992002

992002

2242003

9302002

9302002

1072002

10102002

7112003

4112003

11282001

125C001

2182002

118OT02

2182002

5282002

2192002

6282002

11132001

992002

882002

8232002

992002

7292002

7112003

11282001

2192002

414laquo003

522003

2172003

5laquoQ003

6232003

7112003

820Q002

8202002

9272002

9272002

320Q003

1312003

872002

962002

1312003

1312003

9262002

10212002

9122002

9132002

2282003

2282003

9272002

2282003

1222002

1042002

1092002

10112002

w

w

o o -J w


CDM

Task Summary

Page 1





10 days

10 days

2 days

24 days

60 days

60 days

60 days

60 days

93 days

39 days

39 days

69 days

122 days

60 days

60 days

11 days

65 days

65 days

40 days

15 days

10 days

Odays

Odays

65 days

40 days

10 days

15 days

30 days

15days

todays

5 days

30 days

15 days

todays

5 days

45 days

20 days

10 days

15 days

40 days

20 days

20 days

Odays

Odays

40 days

10 days

20 days

todays

Start 10142002

10142002

10142002

10282002

10302002

12A32002

10102002

10102002

10102002

10102002

10102002

10102002

11132002

11132002

272003

11132002

2122003

2122003

2122003

212^003

4laquo2003

4302003

2122003

2122003

4^2003

4C32003

4laquo2003

4laquo2003

4302003

5142003

4302003

4002003

5212003

642003

5212003

5C12003

6182003

722003

7282003

7282003

8C52003

9222003

9222003

106C003

1132003

Finish 1142002

10252002

10Q52002

10292002

1222002

2242003

112003

112003

112003

2172003

12A32002

12A32002

2172003

512003

512003

24C003

2262003

5132003

5132003

482003

4292003

5132003

5132003

482003

4222003

5132003

5202003

4292003

5132003

5202003

6102003

5202003

6laquo2003

6102003

7222003

6172003

712003

7222003

9192003

8222003

9192003

11142003

1032003

10312003

11142003


51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

67

70

71

72

73

74

75

76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

99













53 Data Validation








EPA Review





91 Draft RI Report

EPA Review

93 Final RI Report



EPA Review




EPA Review




EPA Review



131 FS Addendum









|ijj|

w

o o laquoJ w I m i


Task Summary

CDM Page 2











8-1 300736













8-2 300737











^ ^ 3 0 0 7 3 8


8-4 300739






I




I



RAMON TORRES



SUBCONTRACTORS

to o o v j

o





DAN GILROY (P-3)

PROJECT TEAM


ANALYTICAL SERVICES


EPAs raquoCLI

l _ l J i I














9-2 300741














9-3 300742



10-1 300743



300744

10-2

10 INTRODUCTION








1-1 300649









1-2 300650














1-3 300651

i -c^^- ^ gt ^ 4g--l- M



CDM



LEGEND

SITE BOUNDARY

SUBSITE BOUNDARY

APPROX SCALE 1=20a

CDM

Figure 1-2 SITE MAP












^^ 300654







2-2 300655








2^ 300656







2-4 300657














2-5 300658




2^ 300659






3-3 300660








3-4 300661




315 CLIMATE









3-5 300662











3-6 300663







3-7 300664







3-8 300665












3-9 3 0 0 6 6 6














3-10 300667








^bull^^ 300668










2_j2 300669







300670 3-13



Federal




Commonwealth




Federal


314 300671




Commonwealth





Federal







3-15 300672


Commonwealth











3^6 300673










3-17 300674









o 0 3 0 0 6 7 5

3-18

TABLE 3-1



[ Compound

Naphthalene

Pyrene


Di-n-butyl phthiate


Dieldrin

[Aroclor-1254

Range of Detection

ND-22J

ND-22J

ND-73J

ND-28J

ND-65

ND-36

ND-15


ESI 1997

ESI 1997

ESI 1997

ESI 1997 1

ESI 1997

ESI 1997

ESI 1997

Notes


3 0 0 6 7 6

TABLE 3-2



Analyte

Arsenic

Antimony

Cadmium

Chromium

Copper

Lead

Mercury

Nickel

Zinc

Range of Detection

ND-541J

ND-432J

ND-207

ND-266

ND-3600

ND-26300

ND-17

ND-287J

ND-3860




5563 Calle Arturas


5782 Los Ortiz

5462 Santa Maria

5378 Santa Maria



Notes


3 0 0 6 7 7

6715

1830

1800 mdash

Rlnc6n

6700 4 5 30

T 15

T eeoo

ATLANTIC OCEAN

Arecibo Barceloneta


45 6530

QUATERNARY

MIOCENE

EXPLANATION


CAMUY FORMATION

AYMAM6NI UMESTONE



OUGOCENE


MUCARABONES SAND

I I 1 I M bull 1

-w LARES LIMESTONE



CDM




8Z900e




UJ

LU o o

CAMUY FORMATION

AYMAMON LIMESTONE


LU z m o O CD

AYMAMON UMESTONE



LATE

o

o m a O

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE


LARES UMESTONE

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE

MIDDLE 1 ^

SAN SEBASTIAN


^ ^ -



CDM




ly 0

600

1000 J 35000

_ _ J 30000 25000

-L J_ J_ 20000 15000 10000


I 5000

EXPLANATION



I J J

O O O l 00 O


CDM





663000 662230 183000


Pg^Boquilla A

182500

182230



5 KILOMETERS

5 IVIILES

EXPUNATION

bull30-

^




a3M




w o

o en 00 lO

300683


m h

1500 ppm


0 200 400 Feet



300684

VEGA BAJA

PUBLIC SUPPLY WELLS





Not To Scale

LEGEND


UMESTONE BEDROCK V

SOIL

WATER TABLE

GARBAGE MOUNDS

bull RESIDENCES

OJ

o o ogt 00 Ul CDM















4-1 300686

I m I 4-1



1 4

-laquoc







DEFiNrrrvE LEVEL









50 TASK PLANS










300688 5-1












300689 5-2











300690 5-3










300691 5-4








5110 MEETINGS


g ^ 300692











5-6 300693












300694 5-7








526 PUBLIC NOTICES




300695 5-8












5-9 300696









300697 5-10

5331 Site Visits




Residential Area




5-11 300698



Trash Mounds






Background Samples


512 300699












5-13 300700










5-14 300701












553 DATA VALIDATION


5-15 300702













^^^ 300703









Data Mapping


5-17 300704



563 MODELING








5-18 deg
















5-19 300706








^bull21 3 0 0 7 0 7















5-22 300708














5-23 300709







5-24 bull 300710









5-25 300711











5-26 300712















^^^ 300713










5-28 300714








5-29 300715











5-30 300716







5-31 300717













532 300718


















533 300719








5-34 300720

TABLE 5-1










Soil

Soil

Dust

Water




Lead only

Lead only

Field Parameters

NA

NA

NA





1 per household

1 per household


Samples

110 390

8 70 10

8 70

39

39

Notes


Tszooe

- 1

TAJBLE5-2










OJ o o

to


TABLE 5-2







o o

to U)









IMPLEMENTABILITY



300724

I BI I 5-^







STATE ACCEPTANCE



300725











300726


43 Summary



300727


300728

I I I I I


I I I I I I




300729




A CDM 200 400 Feet




3 0 0 7 3 0


100 X 100 Foot Gri



CDM

A N

200 400 Feet i




3 0 0 7 3 1






6-1 300732

70 SCHEDULE







_ 300733






10

11

12

13

14

15

16

17

18

19

20

21

22

23

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

24 bull



12 Scoping Meeting






Negotiate Budget





EPA Review




110 Meetings




















26 Public Notices







Mobilization

Demobilization





465 days

400 days

1 day

Iday

63 days

42 days

21 days

94 days

Iday

13 days

32 days

36 days

14 days

11 days

11 days

6 days

Odays

423 days

1 day

Iday

1 day

1day

Iday

1 day

Iday

Iday

45 days

45 days

35 days

35 days

69 days

129 days

2 days

todays

75 days

75 days

30 days

Iday

Odays

Iday

Iday

370 days

Odays

125 days

15 days

5 days

46 days

5 days

3 days

2 days

1012001

1012001 bull

11282001

125C001

11222001

11222001

1212002

2192002

2192002

6122002

1012001

7222002

7222002

8^2002

8262002

7222002

11282001

11282001

2192002

4142003

522003

2172003

552003

623C003

7112003

6192002

6192002

8122002

812C002

12162002

862002

862002

8262002

10212002

10212002

8162002

10C12002

9122002

9132002

1012001

992002

992002

2242003

9302002

9302002

1072002

10102002

7112003

4112003

11282001

125C001

2182002

118OT02

2182002

5282002

2192002

6282002

11132001

992002

882002

8232002

992002

7292002

7112003

11282001

2192002

414laquo003

522003

2172003

5laquoQ003

6232003

7112003

820Q002

8202002

9272002

9272002

320Q003

1312003

872002

962002

1312003

1312003

9262002

10212002

9122002

9132002

2282003

2282003

9272002

2282003

1222002

1042002

1092002

10112002

w

w

o o -J w


CDM

Task Summary

Page 1





10 days

10 days

2 days

24 days

60 days

60 days

60 days

60 days

93 days

39 days

39 days

69 days

122 days

60 days

60 days

11 days

65 days

65 days

40 days

15 days

10 days

Odays

Odays

65 days

40 days

10 days

15 days

30 days

15days

todays

5 days

30 days

15 days

todays

5 days

45 days

20 days

10 days

15 days

40 days

20 days

20 days

Odays

Odays

40 days

10 days

20 days

todays

Start 10142002

10142002

10142002

10282002

10302002

12A32002

10102002

10102002

10102002

10102002

10102002

10102002

11132002

11132002

272003

11132002

2122003

2122003

2122003

212^003

4laquo2003

4302003

2122003

2122003

4^2003

4C32003

4laquo2003

4laquo2003

4302003

5142003

4302003

4002003

5212003

642003

5212003

5C12003

6182003

722003

7282003

7282003

8C52003

9222003

9222003

106C003

1132003

Finish 1142002

10252002

10Q52002

10292002

1222002

2242003

112003

112003

112003

2172003

12A32002

12A32002

2172003

512003

512003

24C003

2262003

5132003

5132003

482003

4292003

5132003

5132003

482003

4222003

5132003

5202003

4292003

5132003

5202003

6102003

5202003

6laquo2003

6102003

7222003

6172003

712003

7222003

9192003

8222003

9192003

11142003

1032003

10312003

11142003


51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

67

70

71

72

73

74

75

76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

99













53 Data Validation








EPA Review





91 Draft RI Report

EPA Review

93 Final RI Report



EPA Review




EPA Review




EPA Review



131 FS Addendum









|ijj|

w

o o laquoJ w I m i


Task Summary

CDM Page 2











8-1 300736













8-2 300737











^ ^ 3 0 0 7 3 8


8-4 300739






I




I



RAMON TORRES



SUBCONTRACTORS

to o o v j

o





DAN GILROY (P-3)

PROJECT TEAM


ANALYTICAL SERVICES


EPAs raquoCLI

l _ l J i I














9-2 300741














9-3 300742



10-1 300743



300744

10-2









1-2 300650














1-3 300651

i -c^^- ^ gt ^ 4g--l- M



CDM



LEGEND

SITE BOUNDARY

SUBSITE BOUNDARY

APPROX SCALE 1=20a

CDM

Figure 1-2 SITE MAP












^^ 300654







2-2 300655








2^ 300656







2-4 300657














2-5 300658




2^ 300659






3-3 300660








3-4 300661




315 CLIMATE









3-5 300662











3-6 300663







3-7 300664







3-8 300665












3-9 3 0 0 6 6 6














3-10 300667








^bull^^ 300668










2_j2 300669







300670 3-13



Federal




Commonwealth




Federal


314 300671




Commonwealth





Federal







3-15 300672


Commonwealth











3^6 300673










3-17 300674









o 0 3 0 0 6 7 5

3-18

TABLE 3-1



[ Compound

Naphthalene

Pyrene


Di-n-butyl phthiate


Dieldrin

[Aroclor-1254

Range of Detection

ND-22J

ND-22J

ND-73J

ND-28J

ND-65

ND-36

ND-15


ESI 1997

ESI 1997

ESI 1997

ESI 1997 1

ESI 1997

ESI 1997

ESI 1997

Notes


3 0 0 6 7 6

TABLE 3-2



Analyte

Arsenic

Antimony

Cadmium

Chromium

Copper

Lead

Mercury

Nickel

Zinc

Range of Detection

ND-541J

ND-432J

ND-207

ND-266

ND-3600

ND-26300

ND-17

ND-287J

ND-3860




5563 Calle Arturas


5782 Los Ortiz

5462 Santa Maria

5378 Santa Maria



Notes


3 0 0 6 7 7

6715

1830

1800 mdash

Rlnc6n

6700 4 5 30

T 15

T eeoo

ATLANTIC OCEAN

Arecibo Barceloneta


45 6530

QUATERNARY

MIOCENE

EXPLANATION


CAMUY FORMATION

AYMAM6NI UMESTONE



OUGOCENE


MUCARABONES SAND

I I 1 I M bull 1

-w LARES LIMESTONE



CDM




8Z900e




UJ

LU o o

CAMUY FORMATION

AYMAMON LIMESTONE


LU z m o O CD

AYMAMON UMESTONE



LATE

o

o m a O

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE


LARES UMESTONE

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE

MIDDLE 1 ^

SAN SEBASTIAN


^ ^ -



CDM




ly 0

600

1000 J 35000

_ _ J 30000 25000

-L J_ J_ 20000 15000 10000


I 5000

EXPLANATION



I J J

O O O l 00 O


CDM





663000 662230 183000


Pg^Boquilla A

182500

182230



5 KILOMETERS

5 IVIILES

EXPUNATION

bull30-

^




a3M




w o

o en 00 lO

300683


m h

1500 ppm


0 200 400 Feet



300684

VEGA BAJA

PUBLIC SUPPLY WELLS





Not To Scale

LEGEND


UMESTONE BEDROCK V

SOIL

WATER TABLE

GARBAGE MOUNDS

bull RESIDENCES

OJ

o o ogt 00 Ul CDM















4-1 300686

I m I 4-1



1 4

-laquoc







DEFiNrrrvE LEVEL









50 TASK PLANS










300688 5-1












300689 5-2











300690 5-3










300691 5-4








5110 MEETINGS


g ^ 300692











5-6 300693












300694 5-7








526 PUBLIC NOTICES




300695 5-8












5-9 300696









300697 5-10

5331 Site Visits




Residential Area




5-11 300698



Trash Mounds






Background Samples


512 300699












5-13 300700










5-14 300701












553 DATA VALIDATION


5-15 300702













^^^ 300703









Data Mapping


5-17 300704



563 MODELING








5-18 deg
















5-19 300706








^bull21 3 0 0 7 0 7















5-22 300708














5-23 300709







5-24 bull 300710









5-25 300711











5-26 300712















^^^ 300713










5-28 300714








5-29 300715











5-30 300716







5-31 300717













532 300718


















533 300719








5-34 300720

TABLE 5-1










Soil

Soil

Dust

Water




Lead only

Lead only

Field Parameters

NA

NA

NA





1 per household

1 per household


Samples

110 390

8 70 10

8 70

39

39

Notes


Tszooe

- 1

TAJBLE5-2










OJ o o

to


TABLE 5-2







o o

to U)









IMPLEMENTABILITY



300724

I BI I 5-^







STATE ACCEPTANCE



300725











300726


43 Summary



300727


300728

I I I I I


I I I I I I




300729




A CDM 200 400 Feet




3 0 0 7 3 0


100 X 100 Foot Gri



CDM

A N

200 400 Feet i




3 0 0 7 3 1






6-1 300732

70 SCHEDULE







_ 300733






10

11

12

13

14

15

16

17

18

19

20

21

22

23

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

24 bull



12 Scoping Meeting






Negotiate Budget





EPA Review




110 Meetings




















26 Public Notices







Mobilization

Demobilization





465 days

400 days

1 day

Iday

63 days

42 days

21 days

94 days

Iday

13 days

32 days

36 days

14 days

11 days

11 days

6 days

Odays

423 days

1 day

Iday

1 day

1day

Iday

1 day

Iday

Iday

45 days

45 days

35 days

35 days

69 days

129 days

2 days

todays

75 days

75 days

30 days

Iday

Odays

Iday

Iday

370 days

Odays

125 days

15 days

5 days

46 days

5 days

3 days

2 days

1012001

1012001 bull

11282001

125C001

11222001

11222001

1212002

2192002

2192002

6122002

1012001

7222002

7222002

8^2002

8262002

7222002

11282001

11282001

2192002

4142003

522003

2172003

552003

623C003

7112003

6192002

6192002

8122002

812C002

12162002

862002

862002

8262002

10212002

10212002

8162002

10C12002

9122002

9132002

1012001

992002

992002

2242003

9302002

9302002

1072002

10102002

7112003

4112003

11282001

125C001

2182002

118OT02

2182002

5282002

2192002

6282002

11132001

992002

882002

8232002

992002

7292002

7112003

11282001

2192002

414laquo003

522003

2172003

5laquoQ003

6232003

7112003

820Q002

8202002

9272002

9272002

320Q003

1312003

872002

962002

1312003

1312003

9262002

10212002

9122002

9132002

2282003

2282003

9272002

2282003

1222002

1042002

1092002

10112002

w

w

o o -J w


CDM

Task Summary

Page 1





10 days

10 days

2 days

24 days

60 days

60 days

60 days

60 days

93 days

39 days

39 days

69 days

122 days

60 days

60 days

11 days

65 days

65 days

40 days

15 days

10 days

Odays

Odays

65 days

40 days

10 days

15 days

30 days

15days

todays

5 days

30 days

15 days

todays

5 days

45 days

20 days

10 days

15 days

40 days

20 days

20 days

Odays

Odays

40 days

10 days

20 days

todays

Start 10142002

10142002

10142002

10282002

10302002

12A32002

10102002

10102002

10102002

10102002

10102002

10102002

11132002

11132002

272003

11132002

2122003

2122003

2122003

212^003

4laquo2003

4302003

2122003

2122003

4^2003

4C32003

4laquo2003

4laquo2003

4302003

5142003

4302003

4002003

5212003

642003

5212003

5C12003

6182003

722003

7282003

7282003

8C52003

9222003

9222003

106C003

1132003

Finish 1142002

10252002

10Q52002

10292002

1222002

2242003

112003

112003

112003

2172003

12A32002

12A32002

2172003

512003

512003

24C003

2262003

5132003

5132003

482003

4292003

5132003

5132003

482003

4222003

5132003

5202003

4292003

5132003

5202003

6102003

5202003

6laquo2003

6102003

7222003

6172003

712003

7222003

9192003

8222003

9192003

11142003

1032003

10312003

11142003


51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

67

70

71

72

73

74

75

76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

99













53 Data Validation








EPA Review





91 Draft RI Report

EPA Review

93 Final RI Report



EPA Review




EPA Review




EPA Review



131 FS Addendum









|ijj|

w

o o laquoJ w I m i


Task Summary

CDM Page 2











8-1 300736













8-2 300737











^ ^ 3 0 0 7 3 8


8-4 300739






I




I



RAMON TORRES



SUBCONTRACTORS

to o o v j

o





DAN GILROY (P-3)

PROJECT TEAM


ANALYTICAL SERVICES


EPAs raquoCLI

l _ l J i I














9-2 300741














9-3 300742



10-1 300743



300744

10-2














1-3 300651

i -c^^- ^ gt ^ 4g--l- M



CDM



LEGEND

SITE BOUNDARY

SUBSITE BOUNDARY

APPROX SCALE 1=20a

CDM

Figure 1-2 SITE MAP












^^ 300654







2-2 300655








2^ 300656







2-4 300657














2-5 300658




2^ 300659






3-3 300660








3-4 300661




315 CLIMATE









3-5 300662











3-6 300663







3-7 300664







3-8 300665












3-9 3 0 0 6 6 6














3-10 300667








^bull^^ 300668










2_j2 300669







300670 3-13



Federal




Commonwealth




Federal


314 300671




Commonwealth





Federal







3-15 300672


Commonwealth











3^6 300673










3-17 300674









o 0 3 0 0 6 7 5

3-18

TABLE 3-1



[ Compound

Naphthalene

Pyrene


Di-n-butyl phthiate


Dieldrin

[Aroclor-1254

Range of Detection

ND-22J

ND-22J

ND-73J

ND-28J

ND-65

ND-36

ND-15


ESI 1997

ESI 1997

ESI 1997

ESI 1997 1

ESI 1997

ESI 1997

ESI 1997

Notes


3 0 0 6 7 6

TABLE 3-2



Analyte

Arsenic

Antimony

Cadmium

Chromium

Copper

Lead

Mercury

Nickel

Zinc

Range of Detection

ND-541J

ND-432J

ND-207

ND-266

ND-3600

ND-26300

ND-17

ND-287J

ND-3860




5563 Calle Arturas


5782 Los Ortiz

5462 Santa Maria

5378 Santa Maria



Notes


3 0 0 6 7 7

6715

1830

1800 mdash

Rlnc6n

6700 4 5 30

T 15

T eeoo

ATLANTIC OCEAN

Arecibo Barceloneta


45 6530

QUATERNARY

MIOCENE

EXPLANATION


CAMUY FORMATION

AYMAM6NI UMESTONE



OUGOCENE


MUCARABONES SAND

I I 1 I M bull 1

-w LARES LIMESTONE



CDM




8Z900e




UJ

LU o o

CAMUY FORMATION

AYMAMON LIMESTONE


LU z m o O CD

AYMAMON UMESTONE



LATE

o

o m a O

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE


LARES UMESTONE

UPPER MEMBER


Quebrada Arenas

Umestone Member and


LARES UMESTONE

MIDDLE 1 ^

SAN SEBASTIAN


^ ^ -



CDM




ly 0

600

1000 J 35000

_ _ J 30000 25000

-L J_ J_ 20000 15000 10000


I 5000

EXPLANATION



I J J

O O O l 00 O


CDM





663000 662230 183000


Pg^Boquilla A

182500

182230



5 KILOMETERS

5 IVIILES

EXPUNATION

bull30-

^




a3M




w o

o en 00 lO

300683


m h

1500 ppm


0 200 400 Feet



300684

VEGA BAJA

PUBLIC SUPPLY WELLS





Not To Scale

LEGEND


UMESTONE BEDROCK V

SOIL

WATER TABLE

GARBAGE MOUNDS

bull RESIDENCES

OJ

o o ogt 00 Ul CDM















4-1 300686

I m I 4-1



1 4

-laquoc







DEFiNrrrvE LEVEL









50 TASK PLANS










300688 5-1












300689 5-2











300690 5-3










300691 5-4








5110 MEETINGS


g ^ 300692











5-6 300693












300694 5-7








526 PUBLIC NOTICES




300695 5-8












5-9 300696









300697 5-10

5331 Site Visits




Residential Area




5-11 300698



Trash Mounds






Background Samples


512 300699












5-13 300700










5-14 300701












553 DATA VALIDATION


5-15 300702













^^^ 300703









Data Mapping


5-17 300704



563 MODELING








5-18 deg
















5-19 300706








^bull21 3 0 0 7 0 7















5-22 300708














5-23 300709







5-24 bull 300710









5-25 300711











5-26 300712















^^^ 300713










5-28 300714








5-29 300715











5-30 300716







5-31 300717













532 300718


















533 300719








5-34 300720

TABLE 5-1










Soil

Soil

Dust

Water




Lead only

Lead only

Field Parameters

NA

NA

NA





1 per household

1 per household


Samples

110 390

8 70 10

8 70

39

39

Notes


Tszooe

- 1

TAJBLE5-2










OJ o o

to


TABLE 5-2







o o

to U)









IMPLEMENTABILITY



300724

I BI I 5-^







STATE ACCEPTANCE



300725











300726


43 Summary



300727


300728

I I I I I


I I I I I I




300729




A CDM 200 400 Feet




3 0 0 7 3 0


100 X 100 Foot Gri



CDM

A N

200 400 Feet i




3 0 0 7 3 1






6-1 300732

70 SCHEDULE







_ 300733






10

11

12

13

14

15

16

17

18

19

20

21

22

23

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

24 bull



12 Scoping Meeting






Negotiate Budget





EPA Review




110 Meetings




















26 Public Notices







Mobilization

Demobilization





465 days

400 days

1 day

Iday

63 days

42 days

21 days

94 days

Iday

13 days

32 days

36 days

14 days

11 days

11 days

6 days

Odays

423 days

1 day

Iday

1 day

1day

Iday

1 day

Iday

Iday

45 days

45 days

35 days

35 days

69 days

129 days

2 days

todays

75 days

75 days

30 days

Iday

Odays

Iday

Iday

370 days

Odays

125 days

15 days

5 days

46 days

5 days

3 days

2 days

1012001

1012001 bull

11282001

125C001

11222001

11222001

1212002

2192002

2192002

6122002

1012001

7222002

7222002

8^2002

8262002

7222002

11282001

11282001

2192002

4142003

522003

2172003

552003

623C003

7112003

6192002

6192002

8122002

812C002

12162002

862002

862002

8262002

10212002

10212002

8162002

10C12002

9122002

9132002

1012001

992002

992002

2242003

9302002

9302002

1072002

10102002

7112003

4112003

11282001

125C001

2182002

118OT02

2182002

5282002

2192002

6282002

11132001

992002

882002

8232002

992002

7292002

7112003

11282001

2192002

414laquo003

522003

2172003

5laquoQ003

6232003

7112003

820Q002

8202002

9272002

9272002

320Q003

1312003

872002

962002

1312003

1312003

9262002

10212002

9122002

9132002

2282003

2282003

9272002

2282003

1222002

1042002

1092002

10112002

w

w

o o -J w


CDM

Task Summary

Page 1





10 days

10 days

2 days

24 days

60 days

60 days

60 days

60 days

93 days

39 days

39 days

69 days

122 days

60 days

60 days

11 days

65 days

65 days

40 days

15 days

10 days

Odays

Odays

65 days

40 days

10 days

15 days

30 days

15days

todays

5 days

30 days

15 days

todays

5 days

45 days

20 days

10 days

15 days

40 days

20 days

20 days

Odays

Odays

40 days

10 days

20 days

todays

Start 10142002

10142002

10142002

10282002

10302002

12A32002

10102002

10102002

10102002

10102002

10102002

10102002

11132002

11132002

272003

11132002

2122003

2122003

2122003

212^003

4laquo2003

4302003

2122003

2122003

4^2003

4C32003

4laquo2003

4laquo2003

4302003

5142003

4302003

4002003

5212003

642003

5212003

5C12003

6182003

722003

7282003

7282003

8C52003

9222003

9222003

106C003

1132003

Finish 1142002

10252002

10Q52002

10292002

1222002

2242003

112003

112003

112003

2172003

12A32002

12A32002

2172003

512003

512003

24C003

2262003

5132003

5132003

482003

4292003

5132003

5132003

482003

4222003

5132003

5202003

4292003

5132003

5202003

6102003

5202003

6laquo2003

6102003

7222003

6172003

712003

7222003

9192003

8222003

9192003

11142003

1032003

10312003

11142003


51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

67

70

71

72

73

74

75

76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

99













53 Data Validation








EPA Review





91 Draft RI Report

EPA Review

93 Final RI Report



EPA Review




EPA Review




EPA Review



131 FS Addendum









|ijj|

w

o o laquoJ w I m i


Task Summary

CDM Page 2











8-1 300736













8-2 300737











^ ^ 3 0 0 7 3 8


8-4 300739






I




I



RAMON TORRES



SUBCONTRACTORS

to o o v j

o





DAN GILROY (P-3)

PROJECT TEAM


ANALYTICAL SERVICES


EPAs raquoCLI

l _ l J i I














9-2 300741














9-3 300742



10-1 300743



300744

10-2

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