A77
PetersonPuritan Inc SiteCumberland and Lincoln Rhode IslandFEASIBILITY STUDY WORK PLANPRIMARY SOURCE AREA (OU 1)
Final
March 1993
Prepared for
CPC International IncEnglewood Cliffs New Jersey
Prepared by
ABB Environmental Services IncWakefield Massachusetts
FEASIBILITY STUDY WORK PLAN PRIMARY SOURCE AREA (OU 1)
FINAL
Prepared for
CPC International Inc Englewood Cliffs New Jersey
Prepared by
ABB Environmental Services Inc Wakefield Massachusetts
Project No 0596024
March 1993
FEASIBILITY STUDY WORK PLAN PRIMARY SOURCE AREA (OU 1)
TABLE OF CONTENTS
Section Title Page No
10 INTRODUCTION 1-1
11 SITE DESCRIPTION 1-1 12 SITE HISTORY 1-2 13 SITE CONTAMINATION SUMMARY 1-4
20 FEASIBILITY STUDY PROCESS 2-1
21 DEVELOPMENT OF REMEDIAL ALTERNATIVES 2-1 211 Data Review 2-2 212 Compilation of Applicable or Relevant and Appropriate
Requirements 2-2 213 Development of Remedial Action Objectives 2-3 214 Development of General Response Actions 2-4 215 Identification of Area or Volume of Media 2-4 216 Technology Identification and Screening 2-4 217 Assembly of Remedial Alternatives 2-5
22 SCREENING OF REMEDIAL ALTERNATIVES 2-6 23 POST-SCREENING DATA COLLECTION 2-7 24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES 2-7 25 FEASIBILITY STUDY REPORT 2-8
30 PROJECT ORGANIZATION AND SCHEDULE 3-1
GLOSSARY OF ACRONYMS FIGURES REFERENCES
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FEASIBILITY STUDY WORK PLAN PRIMARY SOURCE AREA (OU 1)
LIST OF FIGURES
Figure Title
1-1 Site Location
1-2 Primary Source Area OU 1
1-3 Conceptual Site Model for OU 1
2-1 Alternative Development Process
2-2 Identification of Potential Remedial Technologies
3-1 Project Organization
3-2 FS Schedule Primary Source Area OU 1
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FEASIBILITY STUDY WORK PLAN PETERSONPURITAN INC SITE (OU 1)
LIST OF FIGURES
Figure Title
1-1 Site Location
1-2 Primary Source Area OU 1
1-3 Conceptual Site Model for OU 1
2-1 Alternative Development Process
2-2 Identification of Potential Remedial Technologies
3-1 Project Organization
3-2 FS Schedule Primary Source Area OU 1
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GLOSSARY OF TERMS
ABB-ES ARAR
BVSD
CERCLA
CPC
FS
NCP
OampM OU
PAC
RI
SARA
TBC TCL
USEPA USGS
VOCs
GLOSSARY OF TERMS
ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement
Blackstone Valley Sewer District
Comprehensive Environmental Response Compensation and Liability Act CPC International Inc
Feasibility Study
National Contingency Plan
operation and maintenance Operable Unit
Pacific Anchor Chemical
Remedial Investigation
Superfund Amendments and Reauthorization Act of 1986
to be considered target clean-up level
microgram per liter US Environmental Protection Agency US Geological Survey
volatile organic chemicals
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SECTION 1
10 INTRODUCTION
This Feasibility Study (FS) Work Plan has been prepared by ABB Environmental Services Inc (ABB-ES) on behalf of CPC International Inc (CPC) The FS will address Operable Unit 1 (OU 1) of the PetersonPuritan Inc Site in Cumberland Rhode Island (Figure 1-1)
The FS program will be conducted in accordance with the US Environmental Protection Agency (USEPA) Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final (USEPA 1988) USEPA Region I Statement of Work for a Remedial Investigation and Feasibility Study (USEPA 1991) and the National Contingency Plan (NCP) (USEPA 1990)
The purpose of this Work Plan is to describe ABB-ES approach to conducting the FS for OU 1 The remainder of Section 10 presents a brief site description and history Section 20 of this Work Plan describes the components of the FS process and Section 30 presents the project organization and schedule
ll SITE DESCRIPTION
The following site description and environmental setting was derived from various primary references and initially compiled for the Remedial Investigation Report for the PetersonPuritan Inc Site prepared by ABB-ES in February 1990
The CCL Custom Manufacturing Inc plant (formerly PetersonPuritan Inc) is located in an industrial park near the village of Berkeley on Martin Street in the Town of Cumberland Rhode Island The Site Study Area as defined in the Consent Order of 1987 between PetersonPuritan and USEPA includes the CCL plant and extends approximately two miles down the Blackstone Valley and as much as one-half mile to the northeast and to the southwest of the Blackstone River (Figure 1-1)
The field investigations associated with the Remedial Investigation (RI) have addressed the site study area with focus on what is referred to herein as the Primary Source Area OU 1 (Figure 1-2) This FS addresses only OU 1 contaminant problems which encompasses the industrial park and the area on the
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eastern side of the Blackstone River extending down the valley from Pacific Anchor Chemical (PAC formerly Lonza Inc) to a point approximately 2000 feet south of the CCL plant
The Blackstone River meanders through the valley on a comparatively flat floodplain between subdued river terraces The industrial park facilities are located on the northeastern (Cumberland) side of the river The CCL plant is located at the boundary between the valley sediments and the steeper bedrock upland The PAC facility is located at the base of the upland and most of the other industrial facilities in the area are underlain by the valley sediments
A small drainage channel referred to in this investigation as Brook A flows westward between the PAC and CCL plants turns south along the Providence amp Worcester railroad tracks and then is culverted along Martin Street westward to the Blackstone River This drainage feature is sustained by periodic runoff from Mendon Road the PAC and CCL properties and on a more regular basis industrial non-contact cooling water discharges from the PAC facility
The Blackstone River and Blackstone Canal are located at the boundary OU 1 The rivers headwaters begin in Worcester Massachusetts and discharge into tidewaters in the Pawtucket-Providence area The canal flows parallel to the river and was historically used to transport materials by barge within the local river corridor
12 SITE HISTORY
The Blackstone Valley was settled in the Seventeenth Century and became one of the earliest sites of the Industrial Revolution in America The river provided power supplied water and served as a conduit for material transportation and wastewater discharge Many of the industrial plants in the valley discharged untreated wastewaters directly to the Blackstone River before regulations were enacted
In a study by the US Geological Survey (USGS) Johnston and Dickerman concluded that waters of the Blackstone River were degraded by organic wastes derived chiefly from municipal sewage and textile mills (Johnston and Dickerman 1974) By 1983 the Blackstone River in the area of the CCL plant was rated as Class C under the Clean Water Act of 1972 Class C includes
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surface waters that are suitable for fish and wildlife habitat recreational boating and industrial processes and cooling and that have good aesthetic value Class C waters are not suitable for bathing other recreational uses agricultural uses or public water supply (even after treatment) This classification is consistent with the planned use of the river and canal throughout the Site Study Area for a recreational area known as the Blackstone River Valley National Heritage Corridor
Groundwater from the Blackstone Valley aquifer was first developed in the Site Study Area as a municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street well The Lenox Street well was added to Cumberlands system near the southern end of the Site Study Area in 1964 By 1979 the Martin Street well was no longer in service due to iron and manganese problems The Lenox Street well was also closed by the Town of Cumberland in 1979 due to the detection of VOCs in the groundwater
The Town of Lincoln installed three wells in the Quinnville wellfield area west of the Blackstone River between 1957 and 1975 (Figure 1-2) By the late 1950s the Town of Lincoln had become aware of iron and manganese concentrations in its water supply that exceeded US Public Health Service standards The town made an unsuccessful attempt to obtain federal grants to remove these inorganics The Quinnville wells are now all closed
Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source of water to the most heavily pumped wells in the Blackstone River area and that under conditions of sustained pumping most wells close to streams derive virtually all of their water from streamflow They concluded that infiltration of organically contaminated streamflow was a possible causative factor of high manganese concentrations in water from heavily pumped wells The potential source of these organics were from the historical discharge of wastewater all along the Blackstone River valley
The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations up to 017 micrograms per liter
(Malcolm Pirnie 1984)
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During a routine state-wide testing program for municipal wells in October 1979 by the Rhode Island Department of Health VOCs were detected in the Quinnville wells Chemicals found to be present in these wells included tetrachloroethene (PCE) and 111-trichloroethane (TCA) Some of the concentrations exceeded USEPA guidance concentrations for drinking water (Goldberg-Zoino and Associates 1982) Several attempts were made by the Town of Lincoln to flush the contaminants but no long term improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department periodically used one or more of the affected wells when contaminant concentrations declined below the USEPA drinking water standards but with those exceptions the wells have remained closed since October 1979
With the expansion of the municipal water supply systems residential wells in Cumberland and Lincoln were abandoned There are no known residential wells currently operating in the Blackstone Valley aquifer within OU 1 or the Site Study Area Local industrial use of groundwater began in the nineteenth century and peaked in the 1960s With the exception of Okonite in the industrial park the industrial use of groundwater in the area was discontinued by the early 1970s The supply well at Okonite was closed on February 21 1981 when VOCs were detected by Goldberg-Zoino and Associates (Goldberg-Zoino and Associates 1982)
13 SITE CONTAMINATION SUMMARY
The presence of contaminants (summarized below) forms the basis for conducting the FS further site characterization will be provided in the RI report This discussion is based largely on the investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April 1989)
Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary constituents affecting groundwater quality were chlorinated solvents and ketones and arsenic respectively The distribution of VOCs in groundwater is consistent with identified source area and past (pumping) and present (non-pumping) groundwater flow patterns
The VOC contaminant plume centered around the CCL property has the highest contaminant concentrations in groundwater monitoring wells located just south
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and southwest of the CCL plant In cross section the highest concentrations were detected near the shallow portion of the aquifer in the recharge area of the Blackstone River Elevated concentrations of VOCs have also been identified beneath the current chemical tank farm in subsurface soils on the CCL property Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn beneath the river previously will eventually be flushed via discharge to the river
The highest concentrations of the ketone and arsenic plume were detected on the PAC property based on 1988 and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of the PAC property Arsenic was not detected beyond the PAC property Flowlines originating beneath PAC tend to follow a path westward to the Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that of CCL
Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1shy3) identifying the contaminant sources from the CCL and PAC properties migration pathways and potential receptors The models will be refined as the RIFS process proceeds
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20 FEASIBILITY STUDY PROCESS
Based on the preliminary results of the RI separate FSs will be conducted to address the CCL and PAC properties within the Primary Source Area (OU 1) The FSs will consist of the following tasks
bull identification and screening of remedial technologies bull identification and screening of process options available within each
technology bull development of remedial alternatives bull screening of remedial alternatives bull post-screening data collection (optional) bull detailed analysis of remedial alternatives bull FS report
The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated media in OU 1 The remedial alternatives must be (1) protective of the public health and environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and local requirements as stipulated in the Consent Order of 1987 The selection of a remedial alternative may need to 1) utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for treatment that reduces toxicity mobility and volume as a principal element or provide an explanation as to why it does not
21 DEVELOPMENT OF REMEDIAL ALTERNATIVES
The development of alternatives task consists of the following subtasks as shown in Figure 2-1
bull data review bull compilation of Applicable or Relevant and Appropriate
Requirements bull development of remedial action objectives
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development of general response actions identification of area or volume of media identification and screening of technologies identification and screening of process options assembly of remedial alternatives
211 Data Review
The Development of Alternatives work element will begin with a thorough review of the RI data and information (both Phase I and Phase II) human health risk assessment and ecological risk assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater and by contaminants if this approach is believed to simplify the remediation process A review of data from the planned vapor extraction pilot study will also be made Additionally pumping test data from the recovery well and municipal well fields will be renewed
212 Compilation of Applicable or Relevant and Appropriate Requirements
Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the appropriate extent of site clean-up develop site-specific remedial response objectives develop remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA 1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs and State of Rhode Island requirements when applied legally and consistently statewide
Applicable requirements are federal and state requirements that specifically address substances or contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and state requirements that while not legally applicable can be applied if the site circumstances are sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate Applicable requirements and relevant and appropriate requirements are considered to have the same weight with respect to requiring compliance at CERCLA site cleanups
SARA also identifies a To Be Considered (TBC) category which includes federal and state non-regulatory requirements such as criteria advisories and guidance documents TBCs do not have the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs can be used to ensure that a remedy is protective
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ARARs must be attained for hazardous substances remaining on-site at the completion of the remedial action Remedial action implementation should also comply with ARARs (and TBCs as appropriate) to protect public health and the environment Generally ARARs pertain to either contaminant levels or to performance or design standards to ensure protection at all points of potential exposure ARARs are divided into three general categories chemical- location- and action-specific
ABB-ES will identify federal and state chemical- location- and action-specific ARARs and TBCs Chemical- and location-specific ARARs will be identified using RI site characterization data Action-specific ARARs with respect to each proposed alternative and compliance of each alternative with all ARARs will be discussed in the detailed analysis of alternatives section
213 Development of Remedial Action Objectives
Remedial action objectives consist of medium-specific or operable unit-specific goals to protect public health and the environment based on the ARARs the risk assessment goals (human health and ecological) time-based cleanup goals and technology based cleanup goals Remedial action objectives specify contaminants of concern by medium exposure routes and receptors and target clean-up levels (TCLs) for contaminants of concern For compounds or media of concern for which no ARARs exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be determined on the basis of risk assessments as well as the evaluation of expected exposures and associated risks of each alternative Final TCLs will be used to delineate the limits of contamination and to refine general response actions
The length of time to accomplish various levels of contaminant removal will also be addressed in accordance with USEPA Region I guidance documents (USEPA 1991)
214 Development of General Response Actions
General response actions are general purpose statements describing probable remediation activities at a given site to meet remedial action objectives Preliminary general response actions will be identified based upon understanding of the site and remedial action objectives based on readily available criteria and standards (eg ARARs TCLs) These preliminary general response actions will
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be refined throughout the FS as technologies and action-specific ARARs are identified and as a more complete understanding of a site and acceptable exposure levels is reached Like remedial action objectives general response actions may be medium- operable unit or site-specific For example typical general response actions for groundwater contamination would be
bull No ActionInstitutional Actions bull Containment Actions bull CollectionTreatment Actions
215 Identification of Area or Volume of Media
Areas or volumes of media to which general response actions might be applied will be determined based on acceptable exposure levels potential exposure routes site conditions and the nature and extent of contamination The effectiveness of applying remedial alternatives to hot spots will be considered The areas or volumes may be refined as alternatives are assembled and evaluated
216 Technology Identification and Screening
Documented information and data on technologies will be reviewed by ABB-ES to identify those technologies which best satisfy general response actions This initial assessment will involve a literature search of USEPA-published reports environmental journals and vendor information Results of this search will be presented as an identification table including the general response action category the specific technology and a brief technology description
The screening process assesses each technology for its probable effectiveness and implementability with regard to site-specific conditions known and suspected contaminants and affected environmental media The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated areas or volumes of media and meeting the contaminant reduction goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting human health during the construction and implementation phase and (3) how proven and reliable the technology is with respect to the contaminants and conditions at the site Implementability encompasses both the technical and institutional feasibility of implementing a technology These factors will be incorporated into two screening criteria waste- and site-limiting characteristics
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Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
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22
SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
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maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
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The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
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analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
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SECTION 3
30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
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bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
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REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
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FIGURE 2-1
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D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
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FEASIBILITY STUDY WORK PLAN PRIMARY SOURCE AREA (OU 1)
FINAL
Prepared for
CPC International Inc Englewood Cliffs New Jersey
Prepared by
ABB Environmental Services Inc Wakefield Massachusetts
Project No 0596024
March 1993
FEASIBILITY STUDY WORK PLAN PRIMARY SOURCE AREA (OU 1)
TABLE OF CONTENTS
Section Title Page No
10 INTRODUCTION 1-1
11 SITE DESCRIPTION 1-1 12 SITE HISTORY 1-2 13 SITE CONTAMINATION SUMMARY 1-4
20 FEASIBILITY STUDY PROCESS 2-1
21 DEVELOPMENT OF REMEDIAL ALTERNATIVES 2-1 211 Data Review 2-2 212 Compilation of Applicable or Relevant and Appropriate
Requirements 2-2 213 Development of Remedial Action Objectives 2-3 214 Development of General Response Actions 2-4 215 Identification of Area or Volume of Media 2-4 216 Technology Identification and Screening 2-4 217 Assembly of Remedial Alternatives 2-5
22 SCREENING OF REMEDIAL ALTERNATIVES 2-6 23 POST-SCREENING DATA COLLECTION 2-7 24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES 2-7 25 FEASIBILITY STUDY REPORT 2-8
30 PROJECT ORGANIZATION AND SCHEDULE 3-1
GLOSSARY OF ACRONYMS FIGURES REFERENCES
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FEASIBILITY STUDY WORK PLAN PRIMARY SOURCE AREA (OU 1)
LIST OF FIGURES
Figure Title
1-1 Site Location
1-2 Primary Source Area OU 1
1-3 Conceptual Site Model for OU 1
2-1 Alternative Development Process
2-2 Identification of Potential Remedial Technologies
3-1 Project Organization
3-2 FS Schedule Primary Source Area OU 1
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FEASIBILITY STUDY WORK PLAN PETERSONPURITAN INC SITE (OU 1)
LIST OF FIGURES
Figure Title
1-1 Site Location
1-2 Primary Source Area OU 1
1-3 Conceptual Site Model for OU 1
2-1 Alternative Development Process
2-2 Identification of Potential Remedial Technologies
3-1 Project Organization
3-2 FS Schedule Primary Source Area OU 1
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GLOSSARY OF TERMS
ABB-ES ARAR
BVSD
CERCLA
CPC
FS
NCP
OampM OU
PAC
RI
SARA
TBC TCL
USEPA USGS
VOCs
GLOSSARY OF TERMS
ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement
Blackstone Valley Sewer District
Comprehensive Environmental Response Compensation and Liability Act CPC International Inc
Feasibility Study
National Contingency Plan
operation and maintenance Operable Unit
Pacific Anchor Chemical
Remedial Investigation
Superfund Amendments and Reauthorization Act of 1986
to be considered target clean-up level
microgram per liter US Environmental Protection Agency US Geological Survey
volatile organic chemicals
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SECTION 1
10 INTRODUCTION
This Feasibility Study (FS) Work Plan has been prepared by ABB Environmental Services Inc (ABB-ES) on behalf of CPC International Inc (CPC) The FS will address Operable Unit 1 (OU 1) of the PetersonPuritan Inc Site in Cumberland Rhode Island (Figure 1-1)
The FS program will be conducted in accordance with the US Environmental Protection Agency (USEPA) Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final (USEPA 1988) USEPA Region I Statement of Work for a Remedial Investigation and Feasibility Study (USEPA 1991) and the National Contingency Plan (NCP) (USEPA 1990)
The purpose of this Work Plan is to describe ABB-ES approach to conducting the FS for OU 1 The remainder of Section 10 presents a brief site description and history Section 20 of this Work Plan describes the components of the FS process and Section 30 presents the project organization and schedule
ll SITE DESCRIPTION
The following site description and environmental setting was derived from various primary references and initially compiled for the Remedial Investigation Report for the PetersonPuritan Inc Site prepared by ABB-ES in February 1990
The CCL Custom Manufacturing Inc plant (formerly PetersonPuritan Inc) is located in an industrial park near the village of Berkeley on Martin Street in the Town of Cumberland Rhode Island The Site Study Area as defined in the Consent Order of 1987 between PetersonPuritan and USEPA includes the CCL plant and extends approximately two miles down the Blackstone Valley and as much as one-half mile to the northeast and to the southwest of the Blackstone River (Figure 1-1)
The field investigations associated with the Remedial Investigation (RI) have addressed the site study area with focus on what is referred to herein as the Primary Source Area OU 1 (Figure 1-2) This FS addresses only OU 1 contaminant problems which encompasses the industrial park and the area on the
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eastern side of the Blackstone River extending down the valley from Pacific Anchor Chemical (PAC formerly Lonza Inc) to a point approximately 2000 feet south of the CCL plant
The Blackstone River meanders through the valley on a comparatively flat floodplain between subdued river terraces The industrial park facilities are located on the northeastern (Cumberland) side of the river The CCL plant is located at the boundary between the valley sediments and the steeper bedrock upland The PAC facility is located at the base of the upland and most of the other industrial facilities in the area are underlain by the valley sediments
A small drainage channel referred to in this investigation as Brook A flows westward between the PAC and CCL plants turns south along the Providence amp Worcester railroad tracks and then is culverted along Martin Street westward to the Blackstone River This drainage feature is sustained by periodic runoff from Mendon Road the PAC and CCL properties and on a more regular basis industrial non-contact cooling water discharges from the PAC facility
The Blackstone River and Blackstone Canal are located at the boundary OU 1 The rivers headwaters begin in Worcester Massachusetts and discharge into tidewaters in the Pawtucket-Providence area The canal flows parallel to the river and was historically used to transport materials by barge within the local river corridor
12 SITE HISTORY
The Blackstone Valley was settled in the Seventeenth Century and became one of the earliest sites of the Industrial Revolution in America The river provided power supplied water and served as a conduit for material transportation and wastewater discharge Many of the industrial plants in the valley discharged untreated wastewaters directly to the Blackstone River before regulations were enacted
In a study by the US Geological Survey (USGS) Johnston and Dickerman concluded that waters of the Blackstone River were degraded by organic wastes derived chiefly from municipal sewage and textile mills (Johnston and Dickerman 1974) By 1983 the Blackstone River in the area of the CCL plant was rated as Class C under the Clean Water Act of 1972 Class C includes
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surface waters that are suitable for fish and wildlife habitat recreational boating and industrial processes and cooling and that have good aesthetic value Class C waters are not suitable for bathing other recreational uses agricultural uses or public water supply (even after treatment) This classification is consistent with the planned use of the river and canal throughout the Site Study Area for a recreational area known as the Blackstone River Valley National Heritage Corridor
Groundwater from the Blackstone Valley aquifer was first developed in the Site Study Area as a municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street well The Lenox Street well was added to Cumberlands system near the southern end of the Site Study Area in 1964 By 1979 the Martin Street well was no longer in service due to iron and manganese problems The Lenox Street well was also closed by the Town of Cumberland in 1979 due to the detection of VOCs in the groundwater
The Town of Lincoln installed three wells in the Quinnville wellfield area west of the Blackstone River between 1957 and 1975 (Figure 1-2) By the late 1950s the Town of Lincoln had become aware of iron and manganese concentrations in its water supply that exceeded US Public Health Service standards The town made an unsuccessful attempt to obtain federal grants to remove these inorganics The Quinnville wells are now all closed
Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source of water to the most heavily pumped wells in the Blackstone River area and that under conditions of sustained pumping most wells close to streams derive virtually all of their water from streamflow They concluded that infiltration of organically contaminated streamflow was a possible causative factor of high manganese concentrations in water from heavily pumped wells The potential source of these organics were from the historical discharge of wastewater all along the Blackstone River valley
The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations up to 017 micrograms per liter
(Malcolm Pirnie 1984)
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During a routine state-wide testing program for municipal wells in October 1979 by the Rhode Island Department of Health VOCs were detected in the Quinnville wells Chemicals found to be present in these wells included tetrachloroethene (PCE) and 111-trichloroethane (TCA) Some of the concentrations exceeded USEPA guidance concentrations for drinking water (Goldberg-Zoino and Associates 1982) Several attempts were made by the Town of Lincoln to flush the contaminants but no long term improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department periodically used one or more of the affected wells when contaminant concentrations declined below the USEPA drinking water standards but with those exceptions the wells have remained closed since October 1979
With the expansion of the municipal water supply systems residential wells in Cumberland and Lincoln were abandoned There are no known residential wells currently operating in the Blackstone Valley aquifer within OU 1 or the Site Study Area Local industrial use of groundwater began in the nineteenth century and peaked in the 1960s With the exception of Okonite in the industrial park the industrial use of groundwater in the area was discontinued by the early 1970s The supply well at Okonite was closed on February 21 1981 when VOCs were detected by Goldberg-Zoino and Associates (Goldberg-Zoino and Associates 1982)
13 SITE CONTAMINATION SUMMARY
The presence of contaminants (summarized below) forms the basis for conducting the FS further site characterization will be provided in the RI report This discussion is based largely on the investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April 1989)
Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary constituents affecting groundwater quality were chlorinated solvents and ketones and arsenic respectively The distribution of VOCs in groundwater is consistent with identified source area and past (pumping) and present (non-pumping) groundwater flow patterns
The VOC contaminant plume centered around the CCL property has the highest contaminant concentrations in groundwater monitoring wells located just south
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and southwest of the CCL plant In cross section the highest concentrations were detected near the shallow portion of the aquifer in the recharge area of the Blackstone River Elevated concentrations of VOCs have also been identified beneath the current chemical tank farm in subsurface soils on the CCL property Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn beneath the river previously will eventually be flushed via discharge to the river
The highest concentrations of the ketone and arsenic plume were detected on the PAC property based on 1988 and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of the PAC property Arsenic was not detected beyond the PAC property Flowlines originating beneath PAC tend to follow a path westward to the Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that of CCL
Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1shy3) identifying the contaminant sources from the CCL and PAC properties migration pathways and potential receptors The models will be refined as the RIFS process proceeds
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20 FEASIBILITY STUDY PROCESS
Based on the preliminary results of the RI separate FSs will be conducted to address the CCL and PAC properties within the Primary Source Area (OU 1) The FSs will consist of the following tasks
bull identification and screening of remedial technologies bull identification and screening of process options available within each
technology bull development of remedial alternatives bull screening of remedial alternatives bull post-screening data collection (optional) bull detailed analysis of remedial alternatives bull FS report
The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated media in OU 1 The remedial alternatives must be (1) protective of the public health and environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and local requirements as stipulated in the Consent Order of 1987 The selection of a remedial alternative may need to 1) utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for treatment that reduces toxicity mobility and volume as a principal element or provide an explanation as to why it does not
21 DEVELOPMENT OF REMEDIAL ALTERNATIVES
The development of alternatives task consists of the following subtasks as shown in Figure 2-1
bull data review bull compilation of Applicable or Relevant and Appropriate
Requirements bull development of remedial action objectives
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development of general response actions identification of area or volume of media identification and screening of technologies identification and screening of process options assembly of remedial alternatives
211 Data Review
The Development of Alternatives work element will begin with a thorough review of the RI data and information (both Phase I and Phase II) human health risk assessment and ecological risk assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater and by contaminants if this approach is believed to simplify the remediation process A review of data from the planned vapor extraction pilot study will also be made Additionally pumping test data from the recovery well and municipal well fields will be renewed
212 Compilation of Applicable or Relevant and Appropriate Requirements
Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the appropriate extent of site clean-up develop site-specific remedial response objectives develop remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA 1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs and State of Rhode Island requirements when applied legally and consistently statewide
Applicable requirements are federal and state requirements that specifically address substances or contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and state requirements that while not legally applicable can be applied if the site circumstances are sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate Applicable requirements and relevant and appropriate requirements are considered to have the same weight with respect to requiring compliance at CERCLA site cleanups
SARA also identifies a To Be Considered (TBC) category which includes federal and state non-regulatory requirements such as criteria advisories and guidance documents TBCs do not have the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs can be used to ensure that a remedy is protective
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ARARs must be attained for hazardous substances remaining on-site at the completion of the remedial action Remedial action implementation should also comply with ARARs (and TBCs as appropriate) to protect public health and the environment Generally ARARs pertain to either contaminant levels or to performance or design standards to ensure protection at all points of potential exposure ARARs are divided into three general categories chemical- location- and action-specific
ABB-ES will identify federal and state chemical- location- and action-specific ARARs and TBCs Chemical- and location-specific ARARs will be identified using RI site characterization data Action-specific ARARs with respect to each proposed alternative and compliance of each alternative with all ARARs will be discussed in the detailed analysis of alternatives section
213 Development of Remedial Action Objectives
Remedial action objectives consist of medium-specific or operable unit-specific goals to protect public health and the environment based on the ARARs the risk assessment goals (human health and ecological) time-based cleanup goals and technology based cleanup goals Remedial action objectives specify contaminants of concern by medium exposure routes and receptors and target clean-up levels (TCLs) for contaminants of concern For compounds or media of concern for which no ARARs exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be determined on the basis of risk assessments as well as the evaluation of expected exposures and associated risks of each alternative Final TCLs will be used to delineate the limits of contamination and to refine general response actions
The length of time to accomplish various levels of contaminant removal will also be addressed in accordance with USEPA Region I guidance documents (USEPA 1991)
214 Development of General Response Actions
General response actions are general purpose statements describing probable remediation activities at a given site to meet remedial action objectives Preliminary general response actions will be identified based upon understanding of the site and remedial action objectives based on readily available criteria and standards (eg ARARs TCLs) These preliminary general response actions will
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be refined throughout the FS as technologies and action-specific ARARs are identified and as a more complete understanding of a site and acceptable exposure levels is reached Like remedial action objectives general response actions may be medium- operable unit or site-specific For example typical general response actions for groundwater contamination would be
bull No ActionInstitutional Actions bull Containment Actions bull CollectionTreatment Actions
215 Identification of Area or Volume of Media
Areas or volumes of media to which general response actions might be applied will be determined based on acceptable exposure levels potential exposure routes site conditions and the nature and extent of contamination The effectiveness of applying remedial alternatives to hot spots will be considered The areas or volumes may be refined as alternatives are assembled and evaluated
216 Technology Identification and Screening
Documented information and data on technologies will be reviewed by ABB-ES to identify those technologies which best satisfy general response actions This initial assessment will involve a literature search of USEPA-published reports environmental journals and vendor information Results of this search will be presented as an identification table including the general response action category the specific technology and a brief technology description
The screening process assesses each technology for its probable effectiveness and implementability with regard to site-specific conditions known and suspected contaminants and affected environmental media The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated areas or volumes of media and meeting the contaminant reduction goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting human health during the construction and implementation phase and (3) how proven and reliable the technology is with respect to the contaminants and conditions at the site Implementability encompasses both the technical and institutional feasibility of implementing a technology These factors will be incorporated into two screening criteria waste- and site-limiting characteristics
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Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
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22
SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
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maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
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The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
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analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
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SECTION 3
30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
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bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
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REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
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TABLE OF CONTENTS
Section Title Page No
10 INTRODUCTION 1-1
11 SITE DESCRIPTION 1-1 12 SITE HISTORY 1-2 13 SITE CONTAMINATION SUMMARY 1-4
20 FEASIBILITY STUDY PROCESS 2-1
21 DEVELOPMENT OF REMEDIAL ALTERNATIVES 2-1 211 Data Review 2-2 212 Compilation of Applicable or Relevant and Appropriate
Requirements 2-2 213 Development of Remedial Action Objectives 2-3 214 Development of General Response Actions 2-4 215 Identification of Area or Volume of Media 2-4 216 Technology Identification and Screening 2-4 217 Assembly of Remedial Alternatives 2-5
22 SCREENING OF REMEDIAL ALTERNATIVES 2-6 23 POST-SCREENING DATA COLLECTION 2-7 24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES 2-7 25 FEASIBILITY STUDY REPORT 2-8
30 PROJECT ORGANIZATION AND SCHEDULE 3-1
GLOSSARY OF ACRONYMS FIGURES REFERENCES
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LIST OF FIGURES
Figure Title
1-1 Site Location
1-2 Primary Source Area OU 1
1-3 Conceptual Site Model for OU 1
2-1 Alternative Development Process
2-2 Identification of Potential Remedial Technologies
3-1 Project Organization
3-2 FS Schedule Primary Source Area OU 1
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FEASIBILITY STUDY WORK PLAN PETERSONPURITAN INC SITE (OU 1)
LIST OF FIGURES
Figure Title
1-1 Site Location
1-2 Primary Source Area OU 1
1-3 Conceptual Site Model for OU 1
2-1 Alternative Development Process
2-2 Identification of Potential Remedial Technologies
3-1 Project Organization
3-2 FS Schedule Primary Source Area OU 1
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GLOSSARY OF TERMS
ABB-ES ARAR
BVSD
CERCLA
CPC
FS
NCP
OampM OU
PAC
RI
SARA
TBC TCL
USEPA USGS
VOCs
GLOSSARY OF TERMS
ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement
Blackstone Valley Sewer District
Comprehensive Environmental Response Compensation and Liability Act CPC International Inc
Feasibility Study
National Contingency Plan
operation and maintenance Operable Unit
Pacific Anchor Chemical
Remedial Investigation
Superfund Amendments and Reauthorization Act of 1986
to be considered target clean-up level
microgram per liter US Environmental Protection Agency US Geological Survey
volatile organic chemicals
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SECTION 1
10 INTRODUCTION
This Feasibility Study (FS) Work Plan has been prepared by ABB Environmental Services Inc (ABB-ES) on behalf of CPC International Inc (CPC) The FS will address Operable Unit 1 (OU 1) of the PetersonPuritan Inc Site in Cumberland Rhode Island (Figure 1-1)
The FS program will be conducted in accordance with the US Environmental Protection Agency (USEPA) Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final (USEPA 1988) USEPA Region I Statement of Work for a Remedial Investigation and Feasibility Study (USEPA 1991) and the National Contingency Plan (NCP) (USEPA 1990)
The purpose of this Work Plan is to describe ABB-ES approach to conducting the FS for OU 1 The remainder of Section 10 presents a brief site description and history Section 20 of this Work Plan describes the components of the FS process and Section 30 presents the project organization and schedule
ll SITE DESCRIPTION
The following site description and environmental setting was derived from various primary references and initially compiled for the Remedial Investigation Report for the PetersonPuritan Inc Site prepared by ABB-ES in February 1990
The CCL Custom Manufacturing Inc plant (formerly PetersonPuritan Inc) is located in an industrial park near the village of Berkeley on Martin Street in the Town of Cumberland Rhode Island The Site Study Area as defined in the Consent Order of 1987 between PetersonPuritan and USEPA includes the CCL plant and extends approximately two miles down the Blackstone Valley and as much as one-half mile to the northeast and to the southwest of the Blackstone River (Figure 1-1)
The field investigations associated with the Remedial Investigation (RI) have addressed the site study area with focus on what is referred to herein as the Primary Source Area OU 1 (Figure 1-2) This FS addresses only OU 1 contaminant problems which encompasses the industrial park and the area on the
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eastern side of the Blackstone River extending down the valley from Pacific Anchor Chemical (PAC formerly Lonza Inc) to a point approximately 2000 feet south of the CCL plant
The Blackstone River meanders through the valley on a comparatively flat floodplain between subdued river terraces The industrial park facilities are located on the northeastern (Cumberland) side of the river The CCL plant is located at the boundary between the valley sediments and the steeper bedrock upland The PAC facility is located at the base of the upland and most of the other industrial facilities in the area are underlain by the valley sediments
A small drainage channel referred to in this investigation as Brook A flows westward between the PAC and CCL plants turns south along the Providence amp Worcester railroad tracks and then is culverted along Martin Street westward to the Blackstone River This drainage feature is sustained by periodic runoff from Mendon Road the PAC and CCL properties and on a more regular basis industrial non-contact cooling water discharges from the PAC facility
The Blackstone River and Blackstone Canal are located at the boundary OU 1 The rivers headwaters begin in Worcester Massachusetts and discharge into tidewaters in the Pawtucket-Providence area The canal flows parallel to the river and was historically used to transport materials by barge within the local river corridor
12 SITE HISTORY
The Blackstone Valley was settled in the Seventeenth Century and became one of the earliest sites of the Industrial Revolution in America The river provided power supplied water and served as a conduit for material transportation and wastewater discharge Many of the industrial plants in the valley discharged untreated wastewaters directly to the Blackstone River before regulations were enacted
In a study by the US Geological Survey (USGS) Johnston and Dickerman concluded that waters of the Blackstone River were degraded by organic wastes derived chiefly from municipal sewage and textile mills (Johnston and Dickerman 1974) By 1983 the Blackstone River in the area of the CCL plant was rated as Class C under the Clean Water Act of 1972 Class C includes
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surface waters that are suitable for fish and wildlife habitat recreational boating and industrial processes and cooling and that have good aesthetic value Class C waters are not suitable for bathing other recreational uses agricultural uses or public water supply (even after treatment) This classification is consistent with the planned use of the river and canal throughout the Site Study Area for a recreational area known as the Blackstone River Valley National Heritage Corridor
Groundwater from the Blackstone Valley aquifer was first developed in the Site Study Area as a municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street well The Lenox Street well was added to Cumberlands system near the southern end of the Site Study Area in 1964 By 1979 the Martin Street well was no longer in service due to iron and manganese problems The Lenox Street well was also closed by the Town of Cumberland in 1979 due to the detection of VOCs in the groundwater
The Town of Lincoln installed three wells in the Quinnville wellfield area west of the Blackstone River between 1957 and 1975 (Figure 1-2) By the late 1950s the Town of Lincoln had become aware of iron and manganese concentrations in its water supply that exceeded US Public Health Service standards The town made an unsuccessful attempt to obtain federal grants to remove these inorganics The Quinnville wells are now all closed
Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source of water to the most heavily pumped wells in the Blackstone River area and that under conditions of sustained pumping most wells close to streams derive virtually all of their water from streamflow They concluded that infiltration of organically contaminated streamflow was a possible causative factor of high manganese concentrations in water from heavily pumped wells The potential source of these organics were from the historical discharge of wastewater all along the Blackstone River valley
The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations up to 017 micrograms per liter
(Malcolm Pirnie 1984)
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During a routine state-wide testing program for municipal wells in October 1979 by the Rhode Island Department of Health VOCs were detected in the Quinnville wells Chemicals found to be present in these wells included tetrachloroethene (PCE) and 111-trichloroethane (TCA) Some of the concentrations exceeded USEPA guidance concentrations for drinking water (Goldberg-Zoino and Associates 1982) Several attempts were made by the Town of Lincoln to flush the contaminants but no long term improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department periodically used one or more of the affected wells when contaminant concentrations declined below the USEPA drinking water standards but with those exceptions the wells have remained closed since October 1979
With the expansion of the municipal water supply systems residential wells in Cumberland and Lincoln were abandoned There are no known residential wells currently operating in the Blackstone Valley aquifer within OU 1 or the Site Study Area Local industrial use of groundwater began in the nineteenth century and peaked in the 1960s With the exception of Okonite in the industrial park the industrial use of groundwater in the area was discontinued by the early 1970s The supply well at Okonite was closed on February 21 1981 when VOCs were detected by Goldberg-Zoino and Associates (Goldberg-Zoino and Associates 1982)
13 SITE CONTAMINATION SUMMARY
The presence of contaminants (summarized below) forms the basis for conducting the FS further site characterization will be provided in the RI report This discussion is based largely on the investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April 1989)
Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary constituents affecting groundwater quality were chlorinated solvents and ketones and arsenic respectively The distribution of VOCs in groundwater is consistent with identified source area and past (pumping) and present (non-pumping) groundwater flow patterns
The VOC contaminant plume centered around the CCL property has the highest contaminant concentrations in groundwater monitoring wells located just south
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and southwest of the CCL plant In cross section the highest concentrations were detected near the shallow portion of the aquifer in the recharge area of the Blackstone River Elevated concentrations of VOCs have also been identified beneath the current chemical tank farm in subsurface soils on the CCL property Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn beneath the river previously will eventually be flushed via discharge to the river
The highest concentrations of the ketone and arsenic plume were detected on the PAC property based on 1988 and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of the PAC property Arsenic was not detected beyond the PAC property Flowlines originating beneath PAC tend to follow a path westward to the Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that of CCL
Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1shy3) identifying the contaminant sources from the CCL and PAC properties migration pathways and potential receptors The models will be refined as the RIFS process proceeds
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20 FEASIBILITY STUDY PROCESS
Based on the preliminary results of the RI separate FSs will be conducted to address the CCL and PAC properties within the Primary Source Area (OU 1) The FSs will consist of the following tasks
bull identification and screening of remedial technologies bull identification and screening of process options available within each
technology bull development of remedial alternatives bull screening of remedial alternatives bull post-screening data collection (optional) bull detailed analysis of remedial alternatives bull FS report
The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated media in OU 1 The remedial alternatives must be (1) protective of the public health and environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and local requirements as stipulated in the Consent Order of 1987 The selection of a remedial alternative may need to 1) utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for treatment that reduces toxicity mobility and volume as a principal element or provide an explanation as to why it does not
21 DEVELOPMENT OF REMEDIAL ALTERNATIVES
The development of alternatives task consists of the following subtasks as shown in Figure 2-1
bull data review bull compilation of Applicable or Relevant and Appropriate
Requirements bull development of remedial action objectives
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development of general response actions identification of area or volume of media identification and screening of technologies identification and screening of process options assembly of remedial alternatives
211 Data Review
The Development of Alternatives work element will begin with a thorough review of the RI data and information (both Phase I and Phase II) human health risk assessment and ecological risk assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater and by contaminants if this approach is believed to simplify the remediation process A review of data from the planned vapor extraction pilot study will also be made Additionally pumping test data from the recovery well and municipal well fields will be renewed
212 Compilation of Applicable or Relevant and Appropriate Requirements
Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the appropriate extent of site clean-up develop site-specific remedial response objectives develop remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA 1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs and State of Rhode Island requirements when applied legally and consistently statewide
Applicable requirements are federal and state requirements that specifically address substances or contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and state requirements that while not legally applicable can be applied if the site circumstances are sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate Applicable requirements and relevant and appropriate requirements are considered to have the same weight with respect to requiring compliance at CERCLA site cleanups
SARA also identifies a To Be Considered (TBC) category which includes federal and state non-regulatory requirements such as criteria advisories and guidance documents TBCs do not have the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs can be used to ensure that a remedy is protective
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ARARs must be attained for hazardous substances remaining on-site at the completion of the remedial action Remedial action implementation should also comply with ARARs (and TBCs as appropriate) to protect public health and the environment Generally ARARs pertain to either contaminant levels or to performance or design standards to ensure protection at all points of potential exposure ARARs are divided into three general categories chemical- location- and action-specific
ABB-ES will identify federal and state chemical- location- and action-specific ARARs and TBCs Chemical- and location-specific ARARs will be identified using RI site characterization data Action-specific ARARs with respect to each proposed alternative and compliance of each alternative with all ARARs will be discussed in the detailed analysis of alternatives section
213 Development of Remedial Action Objectives
Remedial action objectives consist of medium-specific or operable unit-specific goals to protect public health and the environment based on the ARARs the risk assessment goals (human health and ecological) time-based cleanup goals and technology based cleanup goals Remedial action objectives specify contaminants of concern by medium exposure routes and receptors and target clean-up levels (TCLs) for contaminants of concern For compounds or media of concern for which no ARARs exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be determined on the basis of risk assessments as well as the evaluation of expected exposures and associated risks of each alternative Final TCLs will be used to delineate the limits of contamination and to refine general response actions
The length of time to accomplish various levels of contaminant removal will also be addressed in accordance with USEPA Region I guidance documents (USEPA 1991)
214 Development of General Response Actions
General response actions are general purpose statements describing probable remediation activities at a given site to meet remedial action objectives Preliminary general response actions will be identified based upon understanding of the site and remedial action objectives based on readily available criteria and standards (eg ARARs TCLs) These preliminary general response actions will
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be refined throughout the FS as technologies and action-specific ARARs are identified and as a more complete understanding of a site and acceptable exposure levels is reached Like remedial action objectives general response actions may be medium- operable unit or site-specific For example typical general response actions for groundwater contamination would be
bull No ActionInstitutional Actions bull Containment Actions bull CollectionTreatment Actions
215 Identification of Area or Volume of Media
Areas or volumes of media to which general response actions might be applied will be determined based on acceptable exposure levels potential exposure routes site conditions and the nature and extent of contamination The effectiveness of applying remedial alternatives to hot spots will be considered The areas or volumes may be refined as alternatives are assembled and evaluated
216 Technology Identification and Screening
Documented information and data on technologies will be reviewed by ABB-ES to identify those technologies which best satisfy general response actions This initial assessment will involve a literature search of USEPA-published reports environmental journals and vendor information Results of this search will be presented as an identification table including the general response action category the specific technology and a brief technology description
The screening process assesses each technology for its probable effectiveness and implementability with regard to site-specific conditions known and suspected contaminants and affected environmental media The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated areas or volumes of media and meeting the contaminant reduction goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting human health during the construction and implementation phase and (3) how proven and reliable the technology is with respect to the contaminants and conditions at the site Implementability encompasses both the technical and institutional feasibility of implementing a technology These factors will be incorporated into two screening criteria waste- and site-limiting characteristics
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Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
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22
SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
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maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
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The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
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analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
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30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
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bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
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REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
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SOURCE USEPA 1989
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FIGURE 2-1
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FEASIBILITY STUDY WORK PLAN PRIMARY SOURCE AREA (OU 1)
LIST OF FIGURES
Figure Title
1-1 Site Location
1-2 Primary Source Area OU 1
1-3 Conceptual Site Model for OU 1
2-1 Alternative Development Process
2-2 Identification of Potential Remedial Technologies
3-1 Project Organization
3-2 FS Schedule Primary Source Area OU 1
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FEASIBILITY STUDY WORK PLAN PETERSONPURITAN INC SITE (OU 1)
LIST OF FIGURES
Figure Title
1-1 Site Location
1-2 Primary Source Area OU 1
1-3 Conceptual Site Model for OU 1
2-1 Alternative Development Process
2-2 Identification of Potential Remedial Technologies
3-1 Project Organization
3-2 FS Schedule Primary Source Area OU 1
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GLOSSARY OF TERMS
ABB-ES ARAR
BVSD
CERCLA
CPC
FS
NCP
OampM OU
PAC
RI
SARA
TBC TCL
USEPA USGS
VOCs
GLOSSARY OF TERMS
ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement
Blackstone Valley Sewer District
Comprehensive Environmental Response Compensation and Liability Act CPC International Inc
Feasibility Study
National Contingency Plan
operation and maintenance Operable Unit
Pacific Anchor Chemical
Remedial Investigation
Superfund Amendments and Reauthorization Act of 1986
to be considered target clean-up level
microgram per liter US Environmental Protection Agency US Geological Survey
volatile organic chemicals
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SECTION 1
10 INTRODUCTION
This Feasibility Study (FS) Work Plan has been prepared by ABB Environmental Services Inc (ABB-ES) on behalf of CPC International Inc (CPC) The FS will address Operable Unit 1 (OU 1) of the PetersonPuritan Inc Site in Cumberland Rhode Island (Figure 1-1)
The FS program will be conducted in accordance with the US Environmental Protection Agency (USEPA) Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final (USEPA 1988) USEPA Region I Statement of Work for a Remedial Investigation and Feasibility Study (USEPA 1991) and the National Contingency Plan (NCP) (USEPA 1990)
The purpose of this Work Plan is to describe ABB-ES approach to conducting the FS for OU 1 The remainder of Section 10 presents a brief site description and history Section 20 of this Work Plan describes the components of the FS process and Section 30 presents the project organization and schedule
ll SITE DESCRIPTION
The following site description and environmental setting was derived from various primary references and initially compiled for the Remedial Investigation Report for the PetersonPuritan Inc Site prepared by ABB-ES in February 1990
The CCL Custom Manufacturing Inc plant (formerly PetersonPuritan Inc) is located in an industrial park near the village of Berkeley on Martin Street in the Town of Cumberland Rhode Island The Site Study Area as defined in the Consent Order of 1987 between PetersonPuritan and USEPA includes the CCL plant and extends approximately two miles down the Blackstone Valley and as much as one-half mile to the northeast and to the southwest of the Blackstone River (Figure 1-1)
The field investigations associated with the Remedial Investigation (RI) have addressed the site study area with focus on what is referred to herein as the Primary Source Area OU 1 (Figure 1-2) This FS addresses only OU 1 contaminant problems which encompasses the industrial park and the area on the
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eastern side of the Blackstone River extending down the valley from Pacific Anchor Chemical (PAC formerly Lonza Inc) to a point approximately 2000 feet south of the CCL plant
The Blackstone River meanders through the valley on a comparatively flat floodplain between subdued river terraces The industrial park facilities are located on the northeastern (Cumberland) side of the river The CCL plant is located at the boundary between the valley sediments and the steeper bedrock upland The PAC facility is located at the base of the upland and most of the other industrial facilities in the area are underlain by the valley sediments
A small drainage channel referred to in this investigation as Brook A flows westward between the PAC and CCL plants turns south along the Providence amp Worcester railroad tracks and then is culverted along Martin Street westward to the Blackstone River This drainage feature is sustained by periodic runoff from Mendon Road the PAC and CCL properties and on a more regular basis industrial non-contact cooling water discharges from the PAC facility
The Blackstone River and Blackstone Canal are located at the boundary OU 1 The rivers headwaters begin in Worcester Massachusetts and discharge into tidewaters in the Pawtucket-Providence area The canal flows parallel to the river and was historically used to transport materials by barge within the local river corridor
12 SITE HISTORY
The Blackstone Valley was settled in the Seventeenth Century and became one of the earliest sites of the Industrial Revolution in America The river provided power supplied water and served as a conduit for material transportation and wastewater discharge Many of the industrial plants in the valley discharged untreated wastewaters directly to the Blackstone River before regulations were enacted
In a study by the US Geological Survey (USGS) Johnston and Dickerman concluded that waters of the Blackstone River were degraded by organic wastes derived chiefly from municipal sewage and textile mills (Johnston and Dickerman 1974) By 1983 the Blackstone River in the area of the CCL plant was rated as Class C under the Clean Water Act of 1972 Class C includes
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surface waters that are suitable for fish and wildlife habitat recreational boating and industrial processes and cooling and that have good aesthetic value Class C waters are not suitable for bathing other recreational uses agricultural uses or public water supply (even after treatment) This classification is consistent with the planned use of the river and canal throughout the Site Study Area for a recreational area known as the Blackstone River Valley National Heritage Corridor
Groundwater from the Blackstone Valley aquifer was first developed in the Site Study Area as a municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street well The Lenox Street well was added to Cumberlands system near the southern end of the Site Study Area in 1964 By 1979 the Martin Street well was no longer in service due to iron and manganese problems The Lenox Street well was also closed by the Town of Cumberland in 1979 due to the detection of VOCs in the groundwater
The Town of Lincoln installed three wells in the Quinnville wellfield area west of the Blackstone River between 1957 and 1975 (Figure 1-2) By the late 1950s the Town of Lincoln had become aware of iron and manganese concentrations in its water supply that exceeded US Public Health Service standards The town made an unsuccessful attempt to obtain federal grants to remove these inorganics The Quinnville wells are now all closed
Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source of water to the most heavily pumped wells in the Blackstone River area and that under conditions of sustained pumping most wells close to streams derive virtually all of their water from streamflow They concluded that infiltration of organically contaminated streamflow was a possible causative factor of high manganese concentrations in water from heavily pumped wells The potential source of these organics were from the historical discharge of wastewater all along the Blackstone River valley
The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations up to 017 micrograms per liter
(Malcolm Pirnie 1984)
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During a routine state-wide testing program for municipal wells in October 1979 by the Rhode Island Department of Health VOCs were detected in the Quinnville wells Chemicals found to be present in these wells included tetrachloroethene (PCE) and 111-trichloroethane (TCA) Some of the concentrations exceeded USEPA guidance concentrations for drinking water (Goldberg-Zoino and Associates 1982) Several attempts were made by the Town of Lincoln to flush the contaminants but no long term improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department periodically used one or more of the affected wells when contaminant concentrations declined below the USEPA drinking water standards but with those exceptions the wells have remained closed since October 1979
With the expansion of the municipal water supply systems residential wells in Cumberland and Lincoln were abandoned There are no known residential wells currently operating in the Blackstone Valley aquifer within OU 1 or the Site Study Area Local industrial use of groundwater began in the nineteenth century and peaked in the 1960s With the exception of Okonite in the industrial park the industrial use of groundwater in the area was discontinued by the early 1970s The supply well at Okonite was closed on February 21 1981 when VOCs were detected by Goldberg-Zoino and Associates (Goldberg-Zoino and Associates 1982)
13 SITE CONTAMINATION SUMMARY
The presence of contaminants (summarized below) forms the basis for conducting the FS further site characterization will be provided in the RI report This discussion is based largely on the investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April 1989)
Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary constituents affecting groundwater quality were chlorinated solvents and ketones and arsenic respectively The distribution of VOCs in groundwater is consistent with identified source area and past (pumping) and present (non-pumping) groundwater flow patterns
The VOC contaminant plume centered around the CCL property has the highest contaminant concentrations in groundwater monitoring wells located just south
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and southwest of the CCL plant In cross section the highest concentrations were detected near the shallow portion of the aquifer in the recharge area of the Blackstone River Elevated concentrations of VOCs have also been identified beneath the current chemical tank farm in subsurface soils on the CCL property Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn beneath the river previously will eventually be flushed via discharge to the river
The highest concentrations of the ketone and arsenic plume were detected on the PAC property based on 1988 and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of the PAC property Arsenic was not detected beyond the PAC property Flowlines originating beneath PAC tend to follow a path westward to the Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that of CCL
Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1shy3) identifying the contaminant sources from the CCL and PAC properties migration pathways and potential receptors The models will be refined as the RIFS process proceeds
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20 FEASIBILITY STUDY PROCESS
Based on the preliminary results of the RI separate FSs will be conducted to address the CCL and PAC properties within the Primary Source Area (OU 1) The FSs will consist of the following tasks
bull identification and screening of remedial technologies bull identification and screening of process options available within each
technology bull development of remedial alternatives bull screening of remedial alternatives bull post-screening data collection (optional) bull detailed analysis of remedial alternatives bull FS report
The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated media in OU 1 The remedial alternatives must be (1) protective of the public health and environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and local requirements as stipulated in the Consent Order of 1987 The selection of a remedial alternative may need to 1) utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for treatment that reduces toxicity mobility and volume as a principal element or provide an explanation as to why it does not
21 DEVELOPMENT OF REMEDIAL ALTERNATIVES
The development of alternatives task consists of the following subtasks as shown in Figure 2-1
bull data review bull compilation of Applicable or Relevant and Appropriate
Requirements bull development of remedial action objectives
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development of general response actions identification of area or volume of media identification and screening of technologies identification and screening of process options assembly of remedial alternatives
211 Data Review
The Development of Alternatives work element will begin with a thorough review of the RI data and information (both Phase I and Phase II) human health risk assessment and ecological risk assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater and by contaminants if this approach is believed to simplify the remediation process A review of data from the planned vapor extraction pilot study will also be made Additionally pumping test data from the recovery well and municipal well fields will be renewed
212 Compilation of Applicable or Relevant and Appropriate Requirements
Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the appropriate extent of site clean-up develop site-specific remedial response objectives develop remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA 1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs and State of Rhode Island requirements when applied legally and consistently statewide
Applicable requirements are federal and state requirements that specifically address substances or contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and state requirements that while not legally applicable can be applied if the site circumstances are sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate Applicable requirements and relevant and appropriate requirements are considered to have the same weight with respect to requiring compliance at CERCLA site cleanups
SARA also identifies a To Be Considered (TBC) category which includes federal and state non-regulatory requirements such as criteria advisories and guidance documents TBCs do not have the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs can be used to ensure that a remedy is protective
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ARARs must be attained for hazardous substances remaining on-site at the completion of the remedial action Remedial action implementation should also comply with ARARs (and TBCs as appropriate) to protect public health and the environment Generally ARARs pertain to either contaminant levels or to performance or design standards to ensure protection at all points of potential exposure ARARs are divided into three general categories chemical- location- and action-specific
ABB-ES will identify federal and state chemical- location- and action-specific ARARs and TBCs Chemical- and location-specific ARARs will be identified using RI site characterization data Action-specific ARARs with respect to each proposed alternative and compliance of each alternative with all ARARs will be discussed in the detailed analysis of alternatives section
213 Development of Remedial Action Objectives
Remedial action objectives consist of medium-specific or operable unit-specific goals to protect public health and the environment based on the ARARs the risk assessment goals (human health and ecological) time-based cleanup goals and technology based cleanup goals Remedial action objectives specify contaminants of concern by medium exposure routes and receptors and target clean-up levels (TCLs) for contaminants of concern For compounds or media of concern for which no ARARs exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be determined on the basis of risk assessments as well as the evaluation of expected exposures and associated risks of each alternative Final TCLs will be used to delineate the limits of contamination and to refine general response actions
The length of time to accomplish various levels of contaminant removal will also be addressed in accordance with USEPA Region I guidance documents (USEPA 1991)
214 Development of General Response Actions
General response actions are general purpose statements describing probable remediation activities at a given site to meet remedial action objectives Preliminary general response actions will be identified based upon understanding of the site and remedial action objectives based on readily available criteria and standards (eg ARARs TCLs) These preliminary general response actions will
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be refined throughout the FS as technologies and action-specific ARARs are identified and as a more complete understanding of a site and acceptable exposure levels is reached Like remedial action objectives general response actions may be medium- operable unit or site-specific For example typical general response actions for groundwater contamination would be
bull No ActionInstitutional Actions bull Containment Actions bull CollectionTreatment Actions
215 Identification of Area or Volume of Media
Areas or volumes of media to which general response actions might be applied will be determined based on acceptable exposure levels potential exposure routes site conditions and the nature and extent of contamination The effectiveness of applying remedial alternatives to hot spots will be considered The areas or volumes may be refined as alternatives are assembled and evaluated
216 Technology Identification and Screening
Documented information and data on technologies will be reviewed by ABB-ES to identify those technologies which best satisfy general response actions This initial assessment will involve a literature search of USEPA-published reports environmental journals and vendor information Results of this search will be presented as an identification table including the general response action category the specific technology and a brief technology description
The screening process assesses each technology for its probable effectiveness and implementability with regard to site-specific conditions known and suspected contaminants and affected environmental media The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated areas or volumes of media and meeting the contaminant reduction goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting human health during the construction and implementation phase and (3) how proven and reliable the technology is with respect to the contaminants and conditions at the site Implementability encompasses both the technical and institutional feasibility of implementing a technology These factors will be incorporated into two screening criteria waste- and site-limiting characteristics
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Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
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22
SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
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maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
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The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
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analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
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30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
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bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
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REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
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SOURCE USEPA 1989
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FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
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AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
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FEASIBILITY STUDY WORK PLAN PETERSONPURITAN INC SITE (OU 1)
LIST OF FIGURES
Figure Title
1-1 Site Location
1-2 Primary Source Area OU 1
1-3 Conceptual Site Model for OU 1
2-1 Alternative Development Process
2-2 Identification of Potential Remedial Technologies
3-1 Project Organization
3-2 FS Schedule Primary Source Area OU 1
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GLOSSARY OF TERMS
ABB-ES ARAR
BVSD
CERCLA
CPC
FS
NCP
OampM OU
PAC
RI
SARA
TBC TCL
USEPA USGS
VOCs
GLOSSARY OF TERMS
ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement
Blackstone Valley Sewer District
Comprehensive Environmental Response Compensation and Liability Act CPC International Inc
Feasibility Study
National Contingency Plan
operation and maintenance Operable Unit
Pacific Anchor Chemical
Remedial Investigation
Superfund Amendments and Reauthorization Act of 1986
to be considered target clean-up level
microgram per liter US Environmental Protection Agency US Geological Survey
volatile organic chemicals
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SECTION 1
10 INTRODUCTION
This Feasibility Study (FS) Work Plan has been prepared by ABB Environmental Services Inc (ABB-ES) on behalf of CPC International Inc (CPC) The FS will address Operable Unit 1 (OU 1) of the PetersonPuritan Inc Site in Cumberland Rhode Island (Figure 1-1)
The FS program will be conducted in accordance with the US Environmental Protection Agency (USEPA) Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final (USEPA 1988) USEPA Region I Statement of Work for a Remedial Investigation and Feasibility Study (USEPA 1991) and the National Contingency Plan (NCP) (USEPA 1990)
The purpose of this Work Plan is to describe ABB-ES approach to conducting the FS for OU 1 The remainder of Section 10 presents a brief site description and history Section 20 of this Work Plan describes the components of the FS process and Section 30 presents the project organization and schedule
ll SITE DESCRIPTION
The following site description and environmental setting was derived from various primary references and initially compiled for the Remedial Investigation Report for the PetersonPuritan Inc Site prepared by ABB-ES in February 1990
The CCL Custom Manufacturing Inc plant (formerly PetersonPuritan Inc) is located in an industrial park near the village of Berkeley on Martin Street in the Town of Cumberland Rhode Island The Site Study Area as defined in the Consent Order of 1987 between PetersonPuritan and USEPA includes the CCL plant and extends approximately two miles down the Blackstone Valley and as much as one-half mile to the northeast and to the southwest of the Blackstone River (Figure 1-1)
The field investigations associated with the Remedial Investigation (RI) have addressed the site study area with focus on what is referred to herein as the Primary Source Area OU 1 (Figure 1-2) This FS addresses only OU 1 contaminant problems which encompasses the industrial park and the area on the
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eastern side of the Blackstone River extending down the valley from Pacific Anchor Chemical (PAC formerly Lonza Inc) to a point approximately 2000 feet south of the CCL plant
The Blackstone River meanders through the valley on a comparatively flat floodplain between subdued river terraces The industrial park facilities are located on the northeastern (Cumberland) side of the river The CCL plant is located at the boundary between the valley sediments and the steeper bedrock upland The PAC facility is located at the base of the upland and most of the other industrial facilities in the area are underlain by the valley sediments
A small drainage channel referred to in this investigation as Brook A flows westward between the PAC and CCL plants turns south along the Providence amp Worcester railroad tracks and then is culverted along Martin Street westward to the Blackstone River This drainage feature is sustained by periodic runoff from Mendon Road the PAC and CCL properties and on a more regular basis industrial non-contact cooling water discharges from the PAC facility
The Blackstone River and Blackstone Canal are located at the boundary OU 1 The rivers headwaters begin in Worcester Massachusetts and discharge into tidewaters in the Pawtucket-Providence area The canal flows parallel to the river and was historically used to transport materials by barge within the local river corridor
12 SITE HISTORY
The Blackstone Valley was settled in the Seventeenth Century and became one of the earliest sites of the Industrial Revolution in America The river provided power supplied water and served as a conduit for material transportation and wastewater discharge Many of the industrial plants in the valley discharged untreated wastewaters directly to the Blackstone River before regulations were enacted
In a study by the US Geological Survey (USGS) Johnston and Dickerman concluded that waters of the Blackstone River were degraded by organic wastes derived chiefly from municipal sewage and textile mills (Johnston and Dickerman 1974) By 1983 the Blackstone River in the area of the CCL plant was rated as Class C under the Clean Water Act of 1972 Class C includes
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surface waters that are suitable for fish and wildlife habitat recreational boating and industrial processes and cooling and that have good aesthetic value Class C waters are not suitable for bathing other recreational uses agricultural uses or public water supply (even after treatment) This classification is consistent with the planned use of the river and canal throughout the Site Study Area for a recreational area known as the Blackstone River Valley National Heritage Corridor
Groundwater from the Blackstone Valley aquifer was first developed in the Site Study Area as a municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street well The Lenox Street well was added to Cumberlands system near the southern end of the Site Study Area in 1964 By 1979 the Martin Street well was no longer in service due to iron and manganese problems The Lenox Street well was also closed by the Town of Cumberland in 1979 due to the detection of VOCs in the groundwater
The Town of Lincoln installed three wells in the Quinnville wellfield area west of the Blackstone River between 1957 and 1975 (Figure 1-2) By the late 1950s the Town of Lincoln had become aware of iron and manganese concentrations in its water supply that exceeded US Public Health Service standards The town made an unsuccessful attempt to obtain federal grants to remove these inorganics The Quinnville wells are now all closed
Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source of water to the most heavily pumped wells in the Blackstone River area and that under conditions of sustained pumping most wells close to streams derive virtually all of their water from streamflow They concluded that infiltration of organically contaminated streamflow was a possible causative factor of high manganese concentrations in water from heavily pumped wells The potential source of these organics were from the historical discharge of wastewater all along the Blackstone River valley
The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations up to 017 micrograms per liter
(Malcolm Pirnie 1984)
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During a routine state-wide testing program for municipal wells in October 1979 by the Rhode Island Department of Health VOCs were detected in the Quinnville wells Chemicals found to be present in these wells included tetrachloroethene (PCE) and 111-trichloroethane (TCA) Some of the concentrations exceeded USEPA guidance concentrations for drinking water (Goldberg-Zoino and Associates 1982) Several attempts were made by the Town of Lincoln to flush the contaminants but no long term improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department periodically used one or more of the affected wells when contaminant concentrations declined below the USEPA drinking water standards but with those exceptions the wells have remained closed since October 1979
With the expansion of the municipal water supply systems residential wells in Cumberland and Lincoln were abandoned There are no known residential wells currently operating in the Blackstone Valley aquifer within OU 1 or the Site Study Area Local industrial use of groundwater began in the nineteenth century and peaked in the 1960s With the exception of Okonite in the industrial park the industrial use of groundwater in the area was discontinued by the early 1970s The supply well at Okonite was closed on February 21 1981 when VOCs were detected by Goldberg-Zoino and Associates (Goldberg-Zoino and Associates 1982)
13 SITE CONTAMINATION SUMMARY
The presence of contaminants (summarized below) forms the basis for conducting the FS further site characterization will be provided in the RI report This discussion is based largely on the investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April 1989)
Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary constituents affecting groundwater quality were chlorinated solvents and ketones and arsenic respectively The distribution of VOCs in groundwater is consistent with identified source area and past (pumping) and present (non-pumping) groundwater flow patterns
The VOC contaminant plume centered around the CCL property has the highest contaminant concentrations in groundwater monitoring wells located just south
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and southwest of the CCL plant In cross section the highest concentrations were detected near the shallow portion of the aquifer in the recharge area of the Blackstone River Elevated concentrations of VOCs have also been identified beneath the current chemical tank farm in subsurface soils on the CCL property Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn beneath the river previously will eventually be flushed via discharge to the river
The highest concentrations of the ketone and arsenic plume were detected on the PAC property based on 1988 and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of the PAC property Arsenic was not detected beyond the PAC property Flowlines originating beneath PAC tend to follow a path westward to the Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that of CCL
Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1shy3) identifying the contaminant sources from the CCL and PAC properties migration pathways and potential receptors The models will be refined as the RIFS process proceeds
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20 FEASIBILITY STUDY PROCESS
Based on the preliminary results of the RI separate FSs will be conducted to address the CCL and PAC properties within the Primary Source Area (OU 1) The FSs will consist of the following tasks
bull identification and screening of remedial technologies bull identification and screening of process options available within each
technology bull development of remedial alternatives bull screening of remedial alternatives bull post-screening data collection (optional) bull detailed analysis of remedial alternatives bull FS report
The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated media in OU 1 The remedial alternatives must be (1) protective of the public health and environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and local requirements as stipulated in the Consent Order of 1987 The selection of a remedial alternative may need to 1) utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for treatment that reduces toxicity mobility and volume as a principal element or provide an explanation as to why it does not
21 DEVELOPMENT OF REMEDIAL ALTERNATIVES
The development of alternatives task consists of the following subtasks as shown in Figure 2-1
bull data review bull compilation of Applicable or Relevant and Appropriate
Requirements bull development of remedial action objectives
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development of general response actions identification of area or volume of media identification and screening of technologies identification and screening of process options assembly of remedial alternatives
211 Data Review
The Development of Alternatives work element will begin with a thorough review of the RI data and information (both Phase I and Phase II) human health risk assessment and ecological risk assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater and by contaminants if this approach is believed to simplify the remediation process A review of data from the planned vapor extraction pilot study will also be made Additionally pumping test data from the recovery well and municipal well fields will be renewed
212 Compilation of Applicable or Relevant and Appropriate Requirements
Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the appropriate extent of site clean-up develop site-specific remedial response objectives develop remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA 1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs and State of Rhode Island requirements when applied legally and consistently statewide
Applicable requirements are federal and state requirements that specifically address substances or contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and state requirements that while not legally applicable can be applied if the site circumstances are sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate Applicable requirements and relevant and appropriate requirements are considered to have the same weight with respect to requiring compliance at CERCLA site cleanups
SARA also identifies a To Be Considered (TBC) category which includes federal and state non-regulatory requirements such as criteria advisories and guidance documents TBCs do not have the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs can be used to ensure that a remedy is protective
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ARARs must be attained for hazardous substances remaining on-site at the completion of the remedial action Remedial action implementation should also comply with ARARs (and TBCs as appropriate) to protect public health and the environment Generally ARARs pertain to either contaminant levels or to performance or design standards to ensure protection at all points of potential exposure ARARs are divided into three general categories chemical- location- and action-specific
ABB-ES will identify federal and state chemical- location- and action-specific ARARs and TBCs Chemical- and location-specific ARARs will be identified using RI site characterization data Action-specific ARARs with respect to each proposed alternative and compliance of each alternative with all ARARs will be discussed in the detailed analysis of alternatives section
213 Development of Remedial Action Objectives
Remedial action objectives consist of medium-specific or operable unit-specific goals to protect public health and the environment based on the ARARs the risk assessment goals (human health and ecological) time-based cleanup goals and technology based cleanup goals Remedial action objectives specify contaminants of concern by medium exposure routes and receptors and target clean-up levels (TCLs) for contaminants of concern For compounds or media of concern for which no ARARs exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be determined on the basis of risk assessments as well as the evaluation of expected exposures and associated risks of each alternative Final TCLs will be used to delineate the limits of contamination and to refine general response actions
The length of time to accomplish various levels of contaminant removal will also be addressed in accordance with USEPA Region I guidance documents (USEPA 1991)
214 Development of General Response Actions
General response actions are general purpose statements describing probable remediation activities at a given site to meet remedial action objectives Preliminary general response actions will be identified based upon understanding of the site and remedial action objectives based on readily available criteria and standards (eg ARARs TCLs) These preliminary general response actions will
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be refined throughout the FS as technologies and action-specific ARARs are identified and as a more complete understanding of a site and acceptable exposure levels is reached Like remedial action objectives general response actions may be medium- operable unit or site-specific For example typical general response actions for groundwater contamination would be
bull No ActionInstitutional Actions bull Containment Actions bull CollectionTreatment Actions
215 Identification of Area or Volume of Media
Areas or volumes of media to which general response actions might be applied will be determined based on acceptable exposure levels potential exposure routes site conditions and the nature and extent of contamination The effectiveness of applying remedial alternatives to hot spots will be considered The areas or volumes may be refined as alternatives are assembled and evaluated
216 Technology Identification and Screening
Documented information and data on technologies will be reviewed by ABB-ES to identify those technologies which best satisfy general response actions This initial assessment will involve a literature search of USEPA-published reports environmental journals and vendor information Results of this search will be presented as an identification table including the general response action category the specific technology and a brief technology description
The screening process assesses each technology for its probable effectiveness and implementability with regard to site-specific conditions known and suspected contaminants and affected environmental media The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated areas or volumes of media and meeting the contaminant reduction goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting human health during the construction and implementation phase and (3) how proven and reliable the technology is with respect to the contaminants and conditions at the site Implementability encompasses both the technical and institutional feasibility of implementing a technology These factors will be incorporated into two screening criteria waste- and site-limiting characteristics
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Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
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22
SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
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maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
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The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
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analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
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SECTION 3
30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
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bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
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REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
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SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
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FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
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FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
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GLOSSARY OF TERMS
ABB-ES ARAR
BVSD
CERCLA
CPC
FS
NCP
OampM OU
PAC
RI
SARA
TBC TCL
USEPA USGS
VOCs
GLOSSARY OF TERMS
ABB Environmental Services Inc Applicable or Relevant and Appropriate Requirement
Blackstone Valley Sewer District
Comprehensive Environmental Response Compensation and Liability Act CPC International Inc
Feasibility Study
National Contingency Plan
operation and maintenance Operable Unit
Pacific Anchor Chemical
Remedial Investigation
Superfund Amendments and Reauthorization Act of 1986
to be considered target clean-up level
microgram per liter US Environmental Protection Agency US Geological Survey
volatile organic chemicals
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SECTION 1
10 INTRODUCTION
This Feasibility Study (FS) Work Plan has been prepared by ABB Environmental Services Inc (ABB-ES) on behalf of CPC International Inc (CPC) The FS will address Operable Unit 1 (OU 1) of the PetersonPuritan Inc Site in Cumberland Rhode Island (Figure 1-1)
The FS program will be conducted in accordance with the US Environmental Protection Agency (USEPA) Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final (USEPA 1988) USEPA Region I Statement of Work for a Remedial Investigation and Feasibility Study (USEPA 1991) and the National Contingency Plan (NCP) (USEPA 1990)
The purpose of this Work Plan is to describe ABB-ES approach to conducting the FS for OU 1 The remainder of Section 10 presents a brief site description and history Section 20 of this Work Plan describes the components of the FS process and Section 30 presents the project organization and schedule
ll SITE DESCRIPTION
The following site description and environmental setting was derived from various primary references and initially compiled for the Remedial Investigation Report for the PetersonPuritan Inc Site prepared by ABB-ES in February 1990
The CCL Custom Manufacturing Inc plant (formerly PetersonPuritan Inc) is located in an industrial park near the village of Berkeley on Martin Street in the Town of Cumberland Rhode Island The Site Study Area as defined in the Consent Order of 1987 between PetersonPuritan and USEPA includes the CCL plant and extends approximately two miles down the Blackstone Valley and as much as one-half mile to the northeast and to the southwest of the Blackstone River (Figure 1-1)
The field investigations associated with the Remedial Investigation (RI) have addressed the site study area with focus on what is referred to herein as the Primary Source Area OU 1 (Figure 1-2) This FS addresses only OU 1 contaminant problems which encompasses the industrial park and the area on the
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eastern side of the Blackstone River extending down the valley from Pacific Anchor Chemical (PAC formerly Lonza Inc) to a point approximately 2000 feet south of the CCL plant
The Blackstone River meanders through the valley on a comparatively flat floodplain between subdued river terraces The industrial park facilities are located on the northeastern (Cumberland) side of the river The CCL plant is located at the boundary between the valley sediments and the steeper bedrock upland The PAC facility is located at the base of the upland and most of the other industrial facilities in the area are underlain by the valley sediments
A small drainage channel referred to in this investigation as Brook A flows westward between the PAC and CCL plants turns south along the Providence amp Worcester railroad tracks and then is culverted along Martin Street westward to the Blackstone River This drainage feature is sustained by periodic runoff from Mendon Road the PAC and CCL properties and on a more regular basis industrial non-contact cooling water discharges from the PAC facility
The Blackstone River and Blackstone Canal are located at the boundary OU 1 The rivers headwaters begin in Worcester Massachusetts and discharge into tidewaters in the Pawtucket-Providence area The canal flows parallel to the river and was historically used to transport materials by barge within the local river corridor
12 SITE HISTORY
The Blackstone Valley was settled in the Seventeenth Century and became one of the earliest sites of the Industrial Revolution in America The river provided power supplied water and served as a conduit for material transportation and wastewater discharge Many of the industrial plants in the valley discharged untreated wastewaters directly to the Blackstone River before regulations were enacted
In a study by the US Geological Survey (USGS) Johnston and Dickerman concluded that waters of the Blackstone River were degraded by organic wastes derived chiefly from municipal sewage and textile mills (Johnston and Dickerman 1974) By 1983 the Blackstone River in the area of the CCL plant was rated as Class C under the Clean Water Act of 1972 Class C includes
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surface waters that are suitable for fish and wildlife habitat recreational boating and industrial processes and cooling and that have good aesthetic value Class C waters are not suitable for bathing other recreational uses agricultural uses or public water supply (even after treatment) This classification is consistent with the planned use of the river and canal throughout the Site Study Area for a recreational area known as the Blackstone River Valley National Heritage Corridor
Groundwater from the Blackstone Valley aquifer was first developed in the Site Study Area as a municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street well The Lenox Street well was added to Cumberlands system near the southern end of the Site Study Area in 1964 By 1979 the Martin Street well was no longer in service due to iron and manganese problems The Lenox Street well was also closed by the Town of Cumberland in 1979 due to the detection of VOCs in the groundwater
The Town of Lincoln installed three wells in the Quinnville wellfield area west of the Blackstone River between 1957 and 1975 (Figure 1-2) By the late 1950s the Town of Lincoln had become aware of iron and manganese concentrations in its water supply that exceeded US Public Health Service standards The town made an unsuccessful attempt to obtain federal grants to remove these inorganics The Quinnville wells are now all closed
Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source of water to the most heavily pumped wells in the Blackstone River area and that under conditions of sustained pumping most wells close to streams derive virtually all of their water from streamflow They concluded that infiltration of organically contaminated streamflow was a possible causative factor of high manganese concentrations in water from heavily pumped wells The potential source of these organics were from the historical discharge of wastewater all along the Blackstone River valley
The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations up to 017 micrograms per liter
(Malcolm Pirnie 1984)
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During a routine state-wide testing program for municipal wells in October 1979 by the Rhode Island Department of Health VOCs were detected in the Quinnville wells Chemicals found to be present in these wells included tetrachloroethene (PCE) and 111-trichloroethane (TCA) Some of the concentrations exceeded USEPA guidance concentrations for drinking water (Goldberg-Zoino and Associates 1982) Several attempts were made by the Town of Lincoln to flush the contaminants but no long term improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department periodically used one or more of the affected wells when contaminant concentrations declined below the USEPA drinking water standards but with those exceptions the wells have remained closed since October 1979
With the expansion of the municipal water supply systems residential wells in Cumberland and Lincoln were abandoned There are no known residential wells currently operating in the Blackstone Valley aquifer within OU 1 or the Site Study Area Local industrial use of groundwater began in the nineteenth century and peaked in the 1960s With the exception of Okonite in the industrial park the industrial use of groundwater in the area was discontinued by the early 1970s The supply well at Okonite was closed on February 21 1981 when VOCs were detected by Goldberg-Zoino and Associates (Goldberg-Zoino and Associates 1982)
13 SITE CONTAMINATION SUMMARY
The presence of contaminants (summarized below) forms the basis for conducting the FS further site characterization will be provided in the RI report This discussion is based largely on the investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April 1989)
Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary constituents affecting groundwater quality were chlorinated solvents and ketones and arsenic respectively The distribution of VOCs in groundwater is consistent with identified source area and past (pumping) and present (non-pumping) groundwater flow patterns
The VOC contaminant plume centered around the CCL property has the highest contaminant concentrations in groundwater monitoring wells located just south
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and southwest of the CCL plant In cross section the highest concentrations were detected near the shallow portion of the aquifer in the recharge area of the Blackstone River Elevated concentrations of VOCs have also been identified beneath the current chemical tank farm in subsurface soils on the CCL property Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn beneath the river previously will eventually be flushed via discharge to the river
The highest concentrations of the ketone and arsenic plume were detected on the PAC property based on 1988 and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of the PAC property Arsenic was not detected beyond the PAC property Flowlines originating beneath PAC tend to follow a path westward to the Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that of CCL
Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1shy3) identifying the contaminant sources from the CCL and PAC properties migration pathways and potential receptors The models will be refined as the RIFS process proceeds
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20 FEASIBILITY STUDY PROCESS
Based on the preliminary results of the RI separate FSs will be conducted to address the CCL and PAC properties within the Primary Source Area (OU 1) The FSs will consist of the following tasks
bull identification and screening of remedial technologies bull identification and screening of process options available within each
technology bull development of remedial alternatives bull screening of remedial alternatives bull post-screening data collection (optional) bull detailed analysis of remedial alternatives bull FS report
The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated media in OU 1 The remedial alternatives must be (1) protective of the public health and environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and local requirements as stipulated in the Consent Order of 1987 The selection of a remedial alternative may need to 1) utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for treatment that reduces toxicity mobility and volume as a principal element or provide an explanation as to why it does not
21 DEVELOPMENT OF REMEDIAL ALTERNATIVES
The development of alternatives task consists of the following subtasks as shown in Figure 2-1
bull data review bull compilation of Applicable or Relevant and Appropriate
Requirements bull development of remedial action objectives
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development of general response actions identification of area or volume of media identification and screening of technologies identification and screening of process options assembly of remedial alternatives
211 Data Review
The Development of Alternatives work element will begin with a thorough review of the RI data and information (both Phase I and Phase II) human health risk assessment and ecological risk assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater and by contaminants if this approach is believed to simplify the remediation process A review of data from the planned vapor extraction pilot study will also be made Additionally pumping test data from the recovery well and municipal well fields will be renewed
212 Compilation of Applicable or Relevant and Appropriate Requirements
Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the appropriate extent of site clean-up develop site-specific remedial response objectives develop remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA 1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs and State of Rhode Island requirements when applied legally and consistently statewide
Applicable requirements are federal and state requirements that specifically address substances or contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and state requirements that while not legally applicable can be applied if the site circumstances are sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate Applicable requirements and relevant and appropriate requirements are considered to have the same weight with respect to requiring compliance at CERCLA site cleanups
SARA also identifies a To Be Considered (TBC) category which includes federal and state non-regulatory requirements such as criteria advisories and guidance documents TBCs do not have the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs can be used to ensure that a remedy is protective
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ARARs must be attained for hazardous substances remaining on-site at the completion of the remedial action Remedial action implementation should also comply with ARARs (and TBCs as appropriate) to protect public health and the environment Generally ARARs pertain to either contaminant levels or to performance or design standards to ensure protection at all points of potential exposure ARARs are divided into three general categories chemical- location- and action-specific
ABB-ES will identify federal and state chemical- location- and action-specific ARARs and TBCs Chemical- and location-specific ARARs will be identified using RI site characterization data Action-specific ARARs with respect to each proposed alternative and compliance of each alternative with all ARARs will be discussed in the detailed analysis of alternatives section
213 Development of Remedial Action Objectives
Remedial action objectives consist of medium-specific or operable unit-specific goals to protect public health and the environment based on the ARARs the risk assessment goals (human health and ecological) time-based cleanup goals and technology based cleanup goals Remedial action objectives specify contaminants of concern by medium exposure routes and receptors and target clean-up levels (TCLs) for contaminants of concern For compounds or media of concern for which no ARARs exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be determined on the basis of risk assessments as well as the evaluation of expected exposures and associated risks of each alternative Final TCLs will be used to delineate the limits of contamination and to refine general response actions
The length of time to accomplish various levels of contaminant removal will also be addressed in accordance with USEPA Region I guidance documents (USEPA 1991)
214 Development of General Response Actions
General response actions are general purpose statements describing probable remediation activities at a given site to meet remedial action objectives Preliminary general response actions will be identified based upon understanding of the site and remedial action objectives based on readily available criteria and standards (eg ARARs TCLs) These preliminary general response actions will
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be refined throughout the FS as technologies and action-specific ARARs are identified and as a more complete understanding of a site and acceptable exposure levels is reached Like remedial action objectives general response actions may be medium- operable unit or site-specific For example typical general response actions for groundwater contamination would be
bull No ActionInstitutional Actions bull Containment Actions bull CollectionTreatment Actions
215 Identification of Area or Volume of Media
Areas or volumes of media to which general response actions might be applied will be determined based on acceptable exposure levels potential exposure routes site conditions and the nature and extent of contamination The effectiveness of applying remedial alternatives to hot spots will be considered The areas or volumes may be refined as alternatives are assembled and evaluated
216 Technology Identification and Screening
Documented information and data on technologies will be reviewed by ABB-ES to identify those technologies which best satisfy general response actions This initial assessment will involve a literature search of USEPA-published reports environmental journals and vendor information Results of this search will be presented as an identification table including the general response action category the specific technology and a brief technology description
The screening process assesses each technology for its probable effectiveness and implementability with regard to site-specific conditions known and suspected contaminants and affected environmental media The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated areas or volumes of media and meeting the contaminant reduction goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting human health during the construction and implementation phase and (3) how proven and reliable the technology is with respect to the contaminants and conditions at the site Implementability encompasses both the technical and institutional feasibility of implementing a technology These factors will be incorporated into two screening criteria waste- and site-limiting characteristics
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Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
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22
SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
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maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
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The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
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analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
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SECTION 3
30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
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bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
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REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
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FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
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AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
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SECTION 1
10 INTRODUCTION
This Feasibility Study (FS) Work Plan has been prepared by ABB Environmental Services Inc (ABB-ES) on behalf of CPC International Inc (CPC) The FS will address Operable Unit 1 (OU 1) of the PetersonPuritan Inc Site in Cumberland Rhode Island (Figure 1-1)
The FS program will be conducted in accordance with the US Environmental Protection Agency (USEPA) Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final (USEPA 1988) USEPA Region I Statement of Work for a Remedial Investigation and Feasibility Study (USEPA 1991) and the National Contingency Plan (NCP) (USEPA 1990)
The purpose of this Work Plan is to describe ABB-ES approach to conducting the FS for OU 1 The remainder of Section 10 presents a brief site description and history Section 20 of this Work Plan describes the components of the FS process and Section 30 presents the project organization and schedule
ll SITE DESCRIPTION
The following site description and environmental setting was derived from various primary references and initially compiled for the Remedial Investigation Report for the PetersonPuritan Inc Site prepared by ABB-ES in February 1990
The CCL Custom Manufacturing Inc plant (formerly PetersonPuritan Inc) is located in an industrial park near the village of Berkeley on Martin Street in the Town of Cumberland Rhode Island The Site Study Area as defined in the Consent Order of 1987 between PetersonPuritan and USEPA includes the CCL plant and extends approximately two miles down the Blackstone Valley and as much as one-half mile to the northeast and to the southwest of the Blackstone River (Figure 1-1)
The field investigations associated with the Remedial Investigation (RI) have addressed the site study area with focus on what is referred to herein as the Primary Source Area OU 1 (Figure 1-2) This FS addresses only OU 1 contaminant problems which encompasses the industrial park and the area on the
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eastern side of the Blackstone River extending down the valley from Pacific Anchor Chemical (PAC formerly Lonza Inc) to a point approximately 2000 feet south of the CCL plant
The Blackstone River meanders through the valley on a comparatively flat floodplain between subdued river terraces The industrial park facilities are located on the northeastern (Cumberland) side of the river The CCL plant is located at the boundary between the valley sediments and the steeper bedrock upland The PAC facility is located at the base of the upland and most of the other industrial facilities in the area are underlain by the valley sediments
A small drainage channel referred to in this investigation as Brook A flows westward between the PAC and CCL plants turns south along the Providence amp Worcester railroad tracks and then is culverted along Martin Street westward to the Blackstone River This drainage feature is sustained by periodic runoff from Mendon Road the PAC and CCL properties and on a more regular basis industrial non-contact cooling water discharges from the PAC facility
The Blackstone River and Blackstone Canal are located at the boundary OU 1 The rivers headwaters begin in Worcester Massachusetts and discharge into tidewaters in the Pawtucket-Providence area The canal flows parallel to the river and was historically used to transport materials by barge within the local river corridor
12 SITE HISTORY
The Blackstone Valley was settled in the Seventeenth Century and became one of the earliest sites of the Industrial Revolution in America The river provided power supplied water and served as a conduit for material transportation and wastewater discharge Many of the industrial plants in the valley discharged untreated wastewaters directly to the Blackstone River before regulations were enacted
In a study by the US Geological Survey (USGS) Johnston and Dickerman concluded that waters of the Blackstone River were degraded by organic wastes derived chiefly from municipal sewage and textile mills (Johnston and Dickerman 1974) By 1983 the Blackstone River in the area of the CCL plant was rated as Class C under the Clean Water Act of 1972 Class C includes
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surface waters that are suitable for fish and wildlife habitat recreational boating and industrial processes and cooling and that have good aesthetic value Class C waters are not suitable for bathing other recreational uses agricultural uses or public water supply (even after treatment) This classification is consistent with the planned use of the river and canal throughout the Site Study Area for a recreational area known as the Blackstone River Valley National Heritage Corridor
Groundwater from the Blackstone Valley aquifer was first developed in the Site Study Area as a municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street well The Lenox Street well was added to Cumberlands system near the southern end of the Site Study Area in 1964 By 1979 the Martin Street well was no longer in service due to iron and manganese problems The Lenox Street well was also closed by the Town of Cumberland in 1979 due to the detection of VOCs in the groundwater
The Town of Lincoln installed three wells in the Quinnville wellfield area west of the Blackstone River between 1957 and 1975 (Figure 1-2) By the late 1950s the Town of Lincoln had become aware of iron and manganese concentrations in its water supply that exceeded US Public Health Service standards The town made an unsuccessful attempt to obtain federal grants to remove these inorganics The Quinnville wells are now all closed
Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source of water to the most heavily pumped wells in the Blackstone River area and that under conditions of sustained pumping most wells close to streams derive virtually all of their water from streamflow They concluded that infiltration of organically contaminated streamflow was a possible causative factor of high manganese concentrations in water from heavily pumped wells The potential source of these organics were from the historical discharge of wastewater all along the Blackstone River valley
The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations up to 017 micrograms per liter
(Malcolm Pirnie 1984)
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During a routine state-wide testing program for municipal wells in October 1979 by the Rhode Island Department of Health VOCs were detected in the Quinnville wells Chemicals found to be present in these wells included tetrachloroethene (PCE) and 111-trichloroethane (TCA) Some of the concentrations exceeded USEPA guidance concentrations for drinking water (Goldberg-Zoino and Associates 1982) Several attempts were made by the Town of Lincoln to flush the contaminants but no long term improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department periodically used one or more of the affected wells when contaminant concentrations declined below the USEPA drinking water standards but with those exceptions the wells have remained closed since October 1979
With the expansion of the municipal water supply systems residential wells in Cumberland and Lincoln were abandoned There are no known residential wells currently operating in the Blackstone Valley aquifer within OU 1 or the Site Study Area Local industrial use of groundwater began in the nineteenth century and peaked in the 1960s With the exception of Okonite in the industrial park the industrial use of groundwater in the area was discontinued by the early 1970s The supply well at Okonite was closed on February 21 1981 when VOCs were detected by Goldberg-Zoino and Associates (Goldberg-Zoino and Associates 1982)
13 SITE CONTAMINATION SUMMARY
The presence of contaminants (summarized below) forms the basis for conducting the FS further site characterization will be provided in the RI report This discussion is based largely on the investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April 1989)
Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary constituents affecting groundwater quality were chlorinated solvents and ketones and arsenic respectively The distribution of VOCs in groundwater is consistent with identified source area and past (pumping) and present (non-pumping) groundwater flow patterns
The VOC contaminant plume centered around the CCL property has the highest contaminant concentrations in groundwater monitoring wells located just south
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and southwest of the CCL plant In cross section the highest concentrations were detected near the shallow portion of the aquifer in the recharge area of the Blackstone River Elevated concentrations of VOCs have also been identified beneath the current chemical tank farm in subsurface soils on the CCL property Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn beneath the river previously will eventually be flushed via discharge to the river
The highest concentrations of the ketone and arsenic plume were detected on the PAC property based on 1988 and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of the PAC property Arsenic was not detected beyond the PAC property Flowlines originating beneath PAC tend to follow a path westward to the Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that of CCL
Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1shy3) identifying the contaminant sources from the CCL and PAC properties migration pathways and potential receptors The models will be refined as the RIFS process proceeds
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20 FEASIBILITY STUDY PROCESS
Based on the preliminary results of the RI separate FSs will be conducted to address the CCL and PAC properties within the Primary Source Area (OU 1) The FSs will consist of the following tasks
bull identification and screening of remedial technologies bull identification and screening of process options available within each
technology bull development of remedial alternatives bull screening of remedial alternatives bull post-screening data collection (optional) bull detailed analysis of remedial alternatives bull FS report
The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated media in OU 1 The remedial alternatives must be (1) protective of the public health and environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and local requirements as stipulated in the Consent Order of 1987 The selection of a remedial alternative may need to 1) utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for treatment that reduces toxicity mobility and volume as a principal element or provide an explanation as to why it does not
21 DEVELOPMENT OF REMEDIAL ALTERNATIVES
The development of alternatives task consists of the following subtasks as shown in Figure 2-1
bull data review bull compilation of Applicable or Relevant and Appropriate
Requirements bull development of remedial action objectives
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development of general response actions identification of area or volume of media identification and screening of technologies identification and screening of process options assembly of remedial alternatives
211 Data Review
The Development of Alternatives work element will begin with a thorough review of the RI data and information (both Phase I and Phase II) human health risk assessment and ecological risk assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater and by contaminants if this approach is believed to simplify the remediation process A review of data from the planned vapor extraction pilot study will also be made Additionally pumping test data from the recovery well and municipal well fields will be renewed
212 Compilation of Applicable or Relevant and Appropriate Requirements
Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the appropriate extent of site clean-up develop site-specific remedial response objectives develop remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA 1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs and State of Rhode Island requirements when applied legally and consistently statewide
Applicable requirements are federal and state requirements that specifically address substances or contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and state requirements that while not legally applicable can be applied if the site circumstances are sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate Applicable requirements and relevant and appropriate requirements are considered to have the same weight with respect to requiring compliance at CERCLA site cleanups
SARA also identifies a To Be Considered (TBC) category which includes federal and state non-regulatory requirements such as criteria advisories and guidance documents TBCs do not have the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs can be used to ensure that a remedy is protective
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ARARs must be attained for hazardous substances remaining on-site at the completion of the remedial action Remedial action implementation should also comply with ARARs (and TBCs as appropriate) to protect public health and the environment Generally ARARs pertain to either contaminant levels or to performance or design standards to ensure protection at all points of potential exposure ARARs are divided into three general categories chemical- location- and action-specific
ABB-ES will identify federal and state chemical- location- and action-specific ARARs and TBCs Chemical- and location-specific ARARs will be identified using RI site characterization data Action-specific ARARs with respect to each proposed alternative and compliance of each alternative with all ARARs will be discussed in the detailed analysis of alternatives section
213 Development of Remedial Action Objectives
Remedial action objectives consist of medium-specific or operable unit-specific goals to protect public health and the environment based on the ARARs the risk assessment goals (human health and ecological) time-based cleanup goals and technology based cleanup goals Remedial action objectives specify contaminants of concern by medium exposure routes and receptors and target clean-up levels (TCLs) for contaminants of concern For compounds or media of concern for which no ARARs exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be determined on the basis of risk assessments as well as the evaluation of expected exposures and associated risks of each alternative Final TCLs will be used to delineate the limits of contamination and to refine general response actions
The length of time to accomplish various levels of contaminant removal will also be addressed in accordance with USEPA Region I guidance documents (USEPA 1991)
214 Development of General Response Actions
General response actions are general purpose statements describing probable remediation activities at a given site to meet remedial action objectives Preliminary general response actions will be identified based upon understanding of the site and remedial action objectives based on readily available criteria and standards (eg ARARs TCLs) These preliminary general response actions will
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be refined throughout the FS as technologies and action-specific ARARs are identified and as a more complete understanding of a site and acceptable exposure levels is reached Like remedial action objectives general response actions may be medium- operable unit or site-specific For example typical general response actions for groundwater contamination would be
bull No ActionInstitutional Actions bull Containment Actions bull CollectionTreatment Actions
215 Identification of Area or Volume of Media
Areas or volumes of media to which general response actions might be applied will be determined based on acceptable exposure levels potential exposure routes site conditions and the nature and extent of contamination The effectiveness of applying remedial alternatives to hot spots will be considered The areas or volumes may be refined as alternatives are assembled and evaluated
216 Technology Identification and Screening
Documented information and data on technologies will be reviewed by ABB-ES to identify those technologies which best satisfy general response actions This initial assessment will involve a literature search of USEPA-published reports environmental journals and vendor information Results of this search will be presented as an identification table including the general response action category the specific technology and a brief technology description
The screening process assesses each technology for its probable effectiveness and implementability with regard to site-specific conditions known and suspected contaminants and affected environmental media The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated areas or volumes of media and meeting the contaminant reduction goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting human health during the construction and implementation phase and (3) how proven and reliable the technology is with respect to the contaminants and conditions at the site Implementability encompasses both the technical and institutional feasibility of implementing a technology These factors will be incorporated into two screening criteria waste- and site-limiting characteristics
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Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
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22
SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
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maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
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The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
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analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
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30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
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bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
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REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
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R-l
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SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
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FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
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AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
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SECTION 1
eastern side of the Blackstone River extending down the valley from Pacific Anchor Chemical (PAC formerly Lonza Inc) to a point approximately 2000 feet south of the CCL plant
The Blackstone River meanders through the valley on a comparatively flat floodplain between subdued river terraces The industrial park facilities are located on the northeastern (Cumberland) side of the river The CCL plant is located at the boundary between the valley sediments and the steeper bedrock upland The PAC facility is located at the base of the upland and most of the other industrial facilities in the area are underlain by the valley sediments
A small drainage channel referred to in this investigation as Brook A flows westward between the PAC and CCL plants turns south along the Providence amp Worcester railroad tracks and then is culverted along Martin Street westward to the Blackstone River This drainage feature is sustained by periodic runoff from Mendon Road the PAC and CCL properties and on a more regular basis industrial non-contact cooling water discharges from the PAC facility
The Blackstone River and Blackstone Canal are located at the boundary OU 1 The rivers headwaters begin in Worcester Massachusetts and discharge into tidewaters in the Pawtucket-Providence area The canal flows parallel to the river and was historically used to transport materials by barge within the local river corridor
12 SITE HISTORY
The Blackstone Valley was settled in the Seventeenth Century and became one of the earliest sites of the Industrial Revolution in America The river provided power supplied water and served as a conduit for material transportation and wastewater discharge Many of the industrial plants in the valley discharged untreated wastewaters directly to the Blackstone River before regulations were enacted
In a study by the US Geological Survey (USGS) Johnston and Dickerman concluded that waters of the Blackstone River were degraded by organic wastes derived chiefly from municipal sewage and textile mills (Johnston and Dickerman 1974) By 1983 the Blackstone River in the area of the CCL plant was rated as Class C under the Clean Water Act of 1972 Class C includes
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surface waters that are suitable for fish and wildlife habitat recreational boating and industrial processes and cooling and that have good aesthetic value Class C waters are not suitable for bathing other recreational uses agricultural uses or public water supply (even after treatment) This classification is consistent with the planned use of the river and canal throughout the Site Study Area for a recreational area known as the Blackstone River Valley National Heritage Corridor
Groundwater from the Blackstone Valley aquifer was first developed in the Site Study Area as a municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street well The Lenox Street well was added to Cumberlands system near the southern end of the Site Study Area in 1964 By 1979 the Martin Street well was no longer in service due to iron and manganese problems The Lenox Street well was also closed by the Town of Cumberland in 1979 due to the detection of VOCs in the groundwater
The Town of Lincoln installed three wells in the Quinnville wellfield area west of the Blackstone River between 1957 and 1975 (Figure 1-2) By the late 1950s the Town of Lincoln had become aware of iron and manganese concentrations in its water supply that exceeded US Public Health Service standards The town made an unsuccessful attempt to obtain federal grants to remove these inorganics The Quinnville wells are now all closed
Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source of water to the most heavily pumped wells in the Blackstone River area and that under conditions of sustained pumping most wells close to streams derive virtually all of their water from streamflow They concluded that infiltration of organically contaminated streamflow was a possible causative factor of high manganese concentrations in water from heavily pumped wells The potential source of these organics were from the historical discharge of wastewater all along the Blackstone River valley
The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations up to 017 micrograms per liter
(Malcolm Pirnie 1984)
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During a routine state-wide testing program for municipal wells in October 1979 by the Rhode Island Department of Health VOCs were detected in the Quinnville wells Chemicals found to be present in these wells included tetrachloroethene (PCE) and 111-trichloroethane (TCA) Some of the concentrations exceeded USEPA guidance concentrations for drinking water (Goldberg-Zoino and Associates 1982) Several attempts were made by the Town of Lincoln to flush the contaminants but no long term improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department periodically used one or more of the affected wells when contaminant concentrations declined below the USEPA drinking water standards but with those exceptions the wells have remained closed since October 1979
With the expansion of the municipal water supply systems residential wells in Cumberland and Lincoln were abandoned There are no known residential wells currently operating in the Blackstone Valley aquifer within OU 1 or the Site Study Area Local industrial use of groundwater began in the nineteenth century and peaked in the 1960s With the exception of Okonite in the industrial park the industrial use of groundwater in the area was discontinued by the early 1970s The supply well at Okonite was closed on February 21 1981 when VOCs were detected by Goldberg-Zoino and Associates (Goldberg-Zoino and Associates 1982)
13 SITE CONTAMINATION SUMMARY
The presence of contaminants (summarized below) forms the basis for conducting the FS further site characterization will be provided in the RI report This discussion is based largely on the investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April 1989)
Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary constituents affecting groundwater quality were chlorinated solvents and ketones and arsenic respectively The distribution of VOCs in groundwater is consistent with identified source area and past (pumping) and present (non-pumping) groundwater flow patterns
The VOC contaminant plume centered around the CCL property has the highest contaminant concentrations in groundwater monitoring wells located just south
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and southwest of the CCL plant In cross section the highest concentrations were detected near the shallow portion of the aquifer in the recharge area of the Blackstone River Elevated concentrations of VOCs have also been identified beneath the current chemical tank farm in subsurface soils on the CCL property Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn beneath the river previously will eventually be flushed via discharge to the river
The highest concentrations of the ketone and arsenic plume were detected on the PAC property based on 1988 and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of the PAC property Arsenic was not detected beyond the PAC property Flowlines originating beneath PAC tend to follow a path westward to the Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that of CCL
Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1shy3) identifying the contaminant sources from the CCL and PAC properties migration pathways and potential receptors The models will be refined as the RIFS process proceeds
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20 FEASIBILITY STUDY PROCESS
Based on the preliminary results of the RI separate FSs will be conducted to address the CCL and PAC properties within the Primary Source Area (OU 1) The FSs will consist of the following tasks
bull identification and screening of remedial technologies bull identification and screening of process options available within each
technology bull development of remedial alternatives bull screening of remedial alternatives bull post-screening data collection (optional) bull detailed analysis of remedial alternatives bull FS report
The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated media in OU 1 The remedial alternatives must be (1) protective of the public health and environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and local requirements as stipulated in the Consent Order of 1987 The selection of a remedial alternative may need to 1) utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for treatment that reduces toxicity mobility and volume as a principal element or provide an explanation as to why it does not
21 DEVELOPMENT OF REMEDIAL ALTERNATIVES
The development of alternatives task consists of the following subtasks as shown in Figure 2-1
bull data review bull compilation of Applicable or Relevant and Appropriate
Requirements bull development of remedial action objectives
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development of general response actions identification of area or volume of media identification and screening of technologies identification and screening of process options assembly of remedial alternatives
211 Data Review
The Development of Alternatives work element will begin with a thorough review of the RI data and information (both Phase I and Phase II) human health risk assessment and ecological risk assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater and by contaminants if this approach is believed to simplify the remediation process A review of data from the planned vapor extraction pilot study will also be made Additionally pumping test data from the recovery well and municipal well fields will be renewed
212 Compilation of Applicable or Relevant and Appropriate Requirements
Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the appropriate extent of site clean-up develop site-specific remedial response objectives develop remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA 1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs and State of Rhode Island requirements when applied legally and consistently statewide
Applicable requirements are federal and state requirements that specifically address substances or contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and state requirements that while not legally applicable can be applied if the site circumstances are sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate Applicable requirements and relevant and appropriate requirements are considered to have the same weight with respect to requiring compliance at CERCLA site cleanups
SARA also identifies a To Be Considered (TBC) category which includes federal and state non-regulatory requirements such as criteria advisories and guidance documents TBCs do not have the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs can be used to ensure that a remedy is protective
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ARARs must be attained for hazardous substances remaining on-site at the completion of the remedial action Remedial action implementation should also comply with ARARs (and TBCs as appropriate) to protect public health and the environment Generally ARARs pertain to either contaminant levels or to performance or design standards to ensure protection at all points of potential exposure ARARs are divided into three general categories chemical- location- and action-specific
ABB-ES will identify federal and state chemical- location- and action-specific ARARs and TBCs Chemical- and location-specific ARARs will be identified using RI site characterization data Action-specific ARARs with respect to each proposed alternative and compliance of each alternative with all ARARs will be discussed in the detailed analysis of alternatives section
213 Development of Remedial Action Objectives
Remedial action objectives consist of medium-specific or operable unit-specific goals to protect public health and the environment based on the ARARs the risk assessment goals (human health and ecological) time-based cleanup goals and technology based cleanup goals Remedial action objectives specify contaminants of concern by medium exposure routes and receptors and target clean-up levels (TCLs) for contaminants of concern For compounds or media of concern for which no ARARs exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be determined on the basis of risk assessments as well as the evaluation of expected exposures and associated risks of each alternative Final TCLs will be used to delineate the limits of contamination and to refine general response actions
The length of time to accomplish various levels of contaminant removal will also be addressed in accordance with USEPA Region I guidance documents (USEPA 1991)
214 Development of General Response Actions
General response actions are general purpose statements describing probable remediation activities at a given site to meet remedial action objectives Preliminary general response actions will be identified based upon understanding of the site and remedial action objectives based on readily available criteria and standards (eg ARARs TCLs) These preliminary general response actions will
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be refined throughout the FS as technologies and action-specific ARARs are identified and as a more complete understanding of a site and acceptable exposure levels is reached Like remedial action objectives general response actions may be medium- operable unit or site-specific For example typical general response actions for groundwater contamination would be
bull No ActionInstitutional Actions bull Containment Actions bull CollectionTreatment Actions
215 Identification of Area or Volume of Media
Areas or volumes of media to which general response actions might be applied will be determined based on acceptable exposure levels potential exposure routes site conditions and the nature and extent of contamination The effectiveness of applying remedial alternatives to hot spots will be considered The areas or volumes may be refined as alternatives are assembled and evaluated
216 Technology Identification and Screening
Documented information and data on technologies will be reviewed by ABB-ES to identify those technologies which best satisfy general response actions This initial assessment will involve a literature search of USEPA-published reports environmental journals and vendor information Results of this search will be presented as an identification table including the general response action category the specific technology and a brief technology description
The screening process assesses each technology for its probable effectiveness and implementability with regard to site-specific conditions known and suspected contaminants and affected environmental media The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated areas or volumes of media and meeting the contaminant reduction goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting human health during the construction and implementation phase and (3) how proven and reliable the technology is with respect to the contaminants and conditions at the site Implementability encompasses both the technical and institutional feasibility of implementing a technology These factors will be incorporated into two screening criteria waste- and site-limiting characteristics
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Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
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SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
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maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
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The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
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analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
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30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
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bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
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REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
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SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
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FIGURE 2-1
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SECTION 1
surface waters that are suitable for fish and wildlife habitat recreational boating and industrial processes and cooling and that have good aesthetic value Class C waters are not suitable for bathing other recreational uses agricultural uses or public water supply (even after treatment) This classification is consistent with the planned use of the river and canal throughout the Site Study Area for a recreational area known as the Blackstone River Valley National Heritage Corridor
Groundwater from the Blackstone Valley aquifer was first developed in the Site Study Area as a municipal water supply source in 1950 when the Town of Cumberland installed the Martin Street well The Lenox Street well was added to Cumberlands system near the southern end of the Site Study Area in 1964 By 1979 the Martin Street well was no longer in service due to iron and manganese problems The Lenox Street well was also closed by the Town of Cumberland in 1979 due to the detection of VOCs in the groundwater
The Town of Lincoln installed three wells in the Quinnville wellfield area west of the Blackstone River between 1957 and 1975 (Figure 1-2) By the late 1950s the Town of Lincoln had become aware of iron and manganese concentrations in its water supply that exceeded US Public Health Service standards The town made an unsuccessful attempt to obtain federal grants to remove these inorganics The Quinnville wells are now all closed
Johnston and Dickerman (1974) observed that recharge induced from streams is the principal source of water to the most heavily pumped wells in the Blackstone River area and that under conditions of sustained pumping most wells close to streams derive virtually all of their water from streamflow They concluded that infiltration of organically contaminated streamflow was a possible causative factor of high manganese concentrations in water from heavily pumped wells The potential source of these organics were from the historical discharge of wastewater all along the Blackstone River valley
The pesticide dieldrin which was commonly used in textile mills from 1959 to 1979 for the permanent moth-proofing of wool was detected in monthly water samples taken from the Quinnville wellfield by the Rhode Island Department of Health from 1974 to 1977 at concentrations up to 017 micrograms per liter
(Malcolm Pirnie 1984)
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During a routine state-wide testing program for municipal wells in October 1979 by the Rhode Island Department of Health VOCs were detected in the Quinnville wells Chemicals found to be present in these wells included tetrachloroethene (PCE) and 111-trichloroethane (TCA) Some of the concentrations exceeded USEPA guidance concentrations for drinking water (Goldberg-Zoino and Associates 1982) Several attempts were made by the Town of Lincoln to flush the contaminants but no long term improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department periodically used one or more of the affected wells when contaminant concentrations declined below the USEPA drinking water standards but with those exceptions the wells have remained closed since October 1979
With the expansion of the municipal water supply systems residential wells in Cumberland and Lincoln were abandoned There are no known residential wells currently operating in the Blackstone Valley aquifer within OU 1 or the Site Study Area Local industrial use of groundwater began in the nineteenth century and peaked in the 1960s With the exception of Okonite in the industrial park the industrial use of groundwater in the area was discontinued by the early 1970s The supply well at Okonite was closed on February 21 1981 when VOCs were detected by Goldberg-Zoino and Associates (Goldberg-Zoino and Associates 1982)
13 SITE CONTAMINATION SUMMARY
The presence of contaminants (summarized below) forms the basis for conducting the FS further site characterization will be provided in the RI report This discussion is based largely on the investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April 1989)
Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary constituents affecting groundwater quality were chlorinated solvents and ketones and arsenic respectively The distribution of VOCs in groundwater is consistent with identified source area and past (pumping) and present (non-pumping) groundwater flow patterns
The VOC contaminant plume centered around the CCL property has the highest contaminant concentrations in groundwater monitoring wells located just south
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and southwest of the CCL plant In cross section the highest concentrations were detected near the shallow portion of the aquifer in the recharge area of the Blackstone River Elevated concentrations of VOCs have also been identified beneath the current chemical tank farm in subsurface soils on the CCL property Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn beneath the river previously will eventually be flushed via discharge to the river
The highest concentrations of the ketone and arsenic plume were detected on the PAC property based on 1988 and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of the PAC property Arsenic was not detected beyond the PAC property Flowlines originating beneath PAC tend to follow a path westward to the Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that of CCL
Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1shy3) identifying the contaminant sources from the CCL and PAC properties migration pathways and potential receptors The models will be refined as the RIFS process proceeds
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20 FEASIBILITY STUDY PROCESS
Based on the preliminary results of the RI separate FSs will be conducted to address the CCL and PAC properties within the Primary Source Area (OU 1) The FSs will consist of the following tasks
bull identification and screening of remedial technologies bull identification and screening of process options available within each
technology bull development of remedial alternatives bull screening of remedial alternatives bull post-screening data collection (optional) bull detailed analysis of remedial alternatives bull FS report
The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated media in OU 1 The remedial alternatives must be (1) protective of the public health and environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and local requirements as stipulated in the Consent Order of 1987 The selection of a remedial alternative may need to 1) utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for treatment that reduces toxicity mobility and volume as a principal element or provide an explanation as to why it does not
21 DEVELOPMENT OF REMEDIAL ALTERNATIVES
The development of alternatives task consists of the following subtasks as shown in Figure 2-1
bull data review bull compilation of Applicable or Relevant and Appropriate
Requirements bull development of remedial action objectives
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development of general response actions identification of area or volume of media identification and screening of technologies identification and screening of process options assembly of remedial alternatives
211 Data Review
The Development of Alternatives work element will begin with a thorough review of the RI data and information (both Phase I and Phase II) human health risk assessment and ecological risk assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater and by contaminants if this approach is believed to simplify the remediation process A review of data from the planned vapor extraction pilot study will also be made Additionally pumping test data from the recovery well and municipal well fields will be renewed
212 Compilation of Applicable or Relevant and Appropriate Requirements
Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the appropriate extent of site clean-up develop site-specific remedial response objectives develop remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA 1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs and State of Rhode Island requirements when applied legally and consistently statewide
Applicable requirements are federal and state requirements that specifically address substances or contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and state requirements that while not legally applicable can be applied if the site circumstances are sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate Applicable requirements and relevant and appropriate requirements are considered to have the same weight with respect to requiring compliance at CERCLA site cleanups
SARA also identifies a To Be Considered (TBC) category which includes federal and state non-regulatory requirements such as criteria advisories and guidance documents TBCs do not have the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs can be used to ensure that a remedy is protective
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ARARs must be attained for hazardous substances remaining on-site at the completion of the remedial action Remedial action implementation should also comply with ARARs (and TBCs as appropriate) to protect public health and the environment Generally ARARs pertain to either contaminant levels or to performance or design standards to ensure protection at all points of potential exposure ARARs are divided into three general categories chemical- location- and action-specific
ABB-ES will identify federal and state chemical- location- and action-specific ARARs and TBCs Chemical- and location-specific ARARs will be identified using RI site characterization data Action-specific ARARs with respect to each proposed alternative and compliance of each alternative with all ARARs will be discussed in the detailed analysis of alternatives section
213 Development of Remedial Action Objectives
Remedial action objectives consist of medium-specific or operable unit-specific goals to protect public health and the environment based on the ARARs the risk assessment goals (human health and ecological) time-based cleanup goals and technology based cleanup goals Remedial action objectives specify contaminants of concern by medium exposure routes and receptors and target clean-up levels (TCLs) for contaminants of concern For compounds or media of concern for which no ARARs exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be determined on the basis of risk assessments as well as the evaluation of expected exposures and associated risks of each alternative Final TCLs will be used to delineate the limits of contamination and to refine general response actions
The length of time to accomplish various levels of contaminant removal will also be addressed in accordance with USEPA Region I guidance documents (USEPA 1991)
214 Development of General Response Actions
General response actions are general purpose statements describing probable remediation activities at a given site to meet remedial action objectives Preliminary general response actions will be identified based upon understanding of the site and remedial action objectives based on readily available criteria and standards (eg ARARs TCLs) These preliminary general response actions will
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be refined throughout the FS as technologies and action-specific ARARs are identified and as a more complete understanding of a site and acceptable exposure levels is reached Like remedial action objectives general response actions may be medium- operable unit or site-specific For example typical general response actions for groundwater contamination would be
bull No ActionInstitutional Actions bull Containment Actions bull CollectionTreatment Actions
215 Identification of Area or Volume of Media
Areas or volumes of media to which general response actions might be applied will be determined based on acceptable exposure levels potential exposure routes site conditions and the nature and extent of contamination The effectiveness of applying remedial alternatives to hot spots will be considered The areas or volumes may be refined as alternatives are assembled and evaluated
216 Technology Identification and Screening
Documented information and data on technologies will be reviewed by ABB-ES to identify those technologies which best satisfy general response actions This initial assessment will involve a literature search of USEPA-published reports environmental journals and vendor information Results of this search will be presented as an identification table including the general response action category the specific technology and a brief technology description
The screening process assesses each technology for its probable effectiveness and implementability with regard to site-specific conditions known and suspected contaminants and affected environmental media The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated areas or volumes of media and meeting the contaminant reduction goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting human health during the construction and implementation phase and (3) how proven and reliable the technology is with respect to the contaminants and conditions at the site Implementability encompasses both the technical and institutional feasibility of implementing a technology These factors will be incorporated into two screening criteria waste- and site-limiting characteristics
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Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
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SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
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maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
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The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
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analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
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30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
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bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
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REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
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SOURCE USEPA 1989
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FIGURE 2-1
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SECTION 1
During a routine state-wide testing program for municipal wells in October 1979 by the Rhode Island Department of Health VOCs were detected in the Quinnville wells Chemicals found to be present in these wells included tetrachloroethene (PCE) and 111-trichloroethane (TCA) Some of the concentrations exceeded USEPA guidance concentrations for drinking water (Goldberg-Zoino and Associates 1982) Several attempts were made by the Town of Lincoln to flush the contaminants but no long term improvement in the water quality was achieved From 1979 to 1981 the Lincoln Water Department periodically used one or more of the affected wells when contaminant concentrations declined below the USEPA drinking water standards but with those exceptions the wells have remained closed since October 1979
With the expansion of the municipal water supply systems residential wells in Cumberland and Lincoln were abandoned There are no known residential wells currently operating in the Blackstone Valley aquifer within OU 1 or the Site Study Area Local industrial use of groundwater began in the nineteenth century and peaked in the 1960s With the exception of Okonite in the industrial park the industrial use of groundwater in the area was discontinued by the early 1970s The supply well at Okonite was closed on February 21 1981 when VOCs were detected by Goldberg-Zoino and Associates (Goldberg-Zoino and Associates 1982)
13 SITE CONTAMINATION SUMMARY
The presence of contaminants (summarized below) forms the basis for conducting the FS further site characterization will be provided in the RI report This discussion is based largely on the investigation by Malcolm Pirnie (1983) and the Consent Order facility inspection (Versar April 1989)
Investigations of soil and groundwater at the CCL and PAC facilities identified that the primary constituents affecting groundwater quality were chlorinated solvents and ketones and arsenic respectively The distribution of VOCs in groundwater is consistent with identified source area and past (pumping) and present (non-pumping) groundwater flow patterns
The VOC contaminant plume centered around the CCL property has the highest contaminant concentrations in groundwater monitoring wells located just south
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and southwest of the CCL plant In cross section the highest concentrations were detected near the shallow portion of the aquifer in the recharge area of the Blackstone River Elevated concentrations of VOCs have also been identified beneath the current chemical tank farm in subsurface soils on the CCL property Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn beneath the river previously will eventually be flushed via discharge to the river
The highest concentrations of the ketone and arsenic plume were detected on the PAC property based on 1988 and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of the PAC property Arsenic was not detected beyond the PAC property Flowlines originating beneath PAC tend to follow a path westward to the Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that of CCL
Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1shy3) identifying the contaminant sources from the CCL and PAC properties migration pathways and potential receptors The models will be refined as the RIFS process proceeds
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20 FEASIBILITY STUDY PROCESS
Based on the preliminary results of the RI separate FSs will be conducted to address the CCL and PAC properties within the Primary Source Area (OU 1) The FSs will consist of the following tasks
bull identification and screening of remedial technologies bull identification and screening of process options available within each
technology bull development of remedial alternatives bull screening of remedial alternatives bull post-screening data collection (optional) bull detailed analysis of remedial alternatives bull FS report
The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated media in OU 1 The remedial alternatives must be (1) protective of the public health and environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and local requirements as stipulated in the Consent Order of 1987 The selection of a remedial alternative may need to 1) utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for treatment that reduces toxicity mobility and volume as a principal element or provide an explanation as to why it does not
21 DEVELOPMENT OF REMEDIAL ALTERNATIVES
The development of alternatives task consists of the following subtasks as shown in Figure 2-1
bull data review bull compilation of Applicable or Relevant and Appropriate
Requirements bull development of remedial action objectives
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development of general response actions identification of area or volume of media identification and screening of technologies identification and screening of process options assembly of remedial alternatives
211 Data Review
The Development of Alternatives work element will begin with a thorough review of the RI data and information (both Phase I and Phase II) human health risk assessment and ecological risk assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater and by contaminants if this approach is believed to simplify the remediation process A review of data from the planned vapor extraction pilot study will also be made Additionally pumping test data from the recovery well and municipal well fields will be renewed
212 Compilation of Applicable or Relevant and Appropriate Requirements
Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the appropriate extent of site clean-up develop site-specific remedial response objectives develop remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA 1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs and State of Rhode Island requirements when applied legally and consistently statewide
Applicable requirements are federal and state requirements that specifically address substances or contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and state requirements that while not legally applicable can be applied if the site circumstances are sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate Applicable requirements and relevant and appropriate requirements are considered to have the same weight with respect to requiring compliance at CERCLA site cleanups
SARA also identifies a To Be Considered (TBC) category which includes federal and state non-regulatory requirements such as criteria advisories and guidance documents TBCs do not have the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs can be used to ensure that a remedy is protective
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ARARs must be attained for hazardous substances remaining on-site at the completion of the remedial action Remedial action implementation should also comply with ARARs (and TBCs as appropriate) to protect public health and the environment Generally ARARs pertain to either contaminant levels or to performance or design standards to ensure protection at all points of potential exposure ARARs are divided into three general categories chemical- location- and action-specific
ABB-ES will identify federal and state chemical- location- and action-specific ARARs and TBCs Chemical- and location-specific ARARs will be identified using RI site characterization data Action-specific ARARs with respect to each proposed alternative and compliance of each alternative with all ARARs will be discussed in the detailed analysis of alternatives section
213 Development of Remedial Action Objectives
Remedial action objectives consist of medium-specific or operable unit-specific goals to protect public health and the environment based on the ARARs the risk assessment goals (human health and ecological) time-based cleanup goals and technology based cleanup goals Remedial action objectives specify contaminants of concern by medium exposure routes and receptors and target clean-up levels (TCLs) for contaminants of concern For compounds or media of concern for which no ARARs exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be determined on the basis of risk assessments as well as the evaluation of expected exposures and associated risks of each alternative Final TCLs will be used to delineate the limits of contamination and to refine general response actions
The length of time to accomplish various levels of contaminant removal will also be addressed in accordance with USEPA Region I guidance documents (USEPA 1991)
214 Development of General Response Actions
General response actions are general purpose statements describing probable remediation activities at a given site to meet remedial action objectives Preliminary general response actions will be identified based upon understanding of the site and remedial action objectives based on readily available criteria and standards (eg ARARs TCLs) These preliminary general response actions will
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be refined throughout the FS as technologies and action-specific ARARs are identified and as a more complete understanding of a site and acceptable exposure levels is reached Like remedial action objectives general response actions may be medium- operable unit or site-specific For example typical general response actions for groundwater contamination would be
bull No ActionInstitutional Actions bull Containment Actions bull CollectionTreatment Actions
215 Identification of Area or Volume of Media
Areas or volumes of media to which general response actions might be applied will be determined based on acceptable exposure levels potential exposure routes site conditions and the nature and extent of contamination The effectiveness of applying remedial alternatives to hot spots will be considered The areas or volumes may be refined as alternatives are assembled and evaluated
216 Technology Identification and Screening
Documented information and data on technologies will be reviewed by ABB-ES to identify those technologies which best satisfy general response actions This initial assessment will involve a literature search of USEPA-published reports environmental journals and vendor information Results of this search will be presented as an identification table including the general response action category the specific technology and a brief technology description
The screening process assesses each technology for its probable effectiveness and implementability with regard to site-specific conditions known and suspected contaminants and affected environmental media The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated areas or volumes of media and meeting the contaminant reduction goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting human health during the construction and implementation phase and (3) how proven and reliable the technology is with respect to the contaminants and conditions at the site Implementability encompasses both the technical and institutional feasibility of implementing a technology These factors will be incorporated into two screening criteria waste- and site-limiting characteristics
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Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
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22
SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
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maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
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The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
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analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
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30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
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bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
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REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
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R-l
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SOURCE USEPA 1989
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FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
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FIGURE 3-1
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SECTION 1
and southwest of the CCL plant In cross section the highest concentrations were detected near the shallow portion of the aquifer in the recharge area of the Blackstone River Elevated concentrations of VOCs have also been identified beneath the current chemical tank farm in subsurface soils on the CCL property Flowlines originating beneath CCL tended to follow the base of the sand and gravel aquifer During operation of the Quinnville wellfield contaminant migration remained at depth as it passed beneath the Blackstone River toward the pumping well screens In the absence of pumping at the Quinnville wellfield groundwater flowing at depth resumed discharge to the river Contaminants drawn beneath the river previously will eventually be flushed via discharge to the river
The highest concentrations of the ketone and arsenic plume were detected on the PAC property based on 1988 and 1989 groundwater sampling data Lower concentrations of ketones have been detected south of the PAC property Arsenic was not detected beyond the PAC property Flowlines originating beneath PAC tend to follow a path westward to the Blackstone River Although some plume mixing with CCL chlorinated solvents may occur at the southern extent of the ketone plume it appears that the PAC plume is primarily distinct from that of CCL
Based on this RI data a conceptual site model of OU 1 was prepared (Figure 1shy3) identifying the contaminant sources from the CCL and PAC properties migration pathways and potential receptors The models will be refined as the RIFS process proceeds
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20 FEASIBILITY STUDY PROCESS
Based on the preliminary results of the RI separate FSs will be conducted to address the CCL and PAC properties within the Primary Source Area (OU 1) The FSs will consist of the following tasks
bull identification and screening of remedial technologies bull identification and screening of process options available within each
technology bull development of remedial alternatives bull screening of remedial alternatives bull post-screening data collection (optional) bull detailed analysis of remedial alternatives bull FS report
The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated media in OU 1 The remedial alternatives must be (1) protective of the public health and environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and local requirements as stipulated in the Consent Order of 1987 The selection of a remedial alternative may need to 1) utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for treatment that reduces toxicity mobility and volume as a principal element or provide an explanation as to why it does not
21 DEVELOPMENT OF REMEDIAL ALTERNATIVES
The development of alternatives task consists of the following subtasks as shown in Figure 2-1
bull data review bull compilation of Applicable or Relevant and Appropriate
Requirements bull development of remedial action objectives
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development of general response actions identification of area or volume of media identification and screening of technologies identification and screening of process options assembly of remedial alternatives
211 Data Review
The Development of Alternatives work element will begin with a thorough review of the RI data and information (both Phase I and Phase II) human health risk assessment and ecological risk assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater and by contaminants if this approach is believed to simplify the remediation process A review of data from the planned vapor extraction pilot study will also be made Additionally pumping test data from the recovery well and municipal well fields will be renewed
212 Compilation of Applicable or Relevant and Appropriate Requirements
Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the appropriate extent of site clean-up develop site-specific remedial response objectives develop remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA 1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs and State of Rhode Island requirements when applied legally and consistently statewide
Applicable requirements are federal and state requirements that specifically address substances or contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and state requirements that while not legally applicable can be applied if the site circumstances are sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate Applicable requirements and relevant and appropriate requirements are considered to have the same weight with respect to requiring compliance at CERCLA site cleanups
SARA also identifies a To Be Considered (TBC) category which includes federal and state non-regulatory requirements such as criteria advisories and guidance documents TBCs do not have the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs can be used to ensure that a remedy is protective
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ARARs must be attained for hazardous substances remaining on-site at the completion of the remedial action Remedial action implementation should also comply with ARARs (and TBCs as appropriate) to protect public health and the environment Generally ARARs pertain to either contaminant levels or to performance or design standards to ensure protection at all points of potential exposure ARARs are divided into three general categories chemical- location- and action-specific
ABB-ES will identify federal and state chemical- location- and action-specific ARARs and TBCs Chemical- and location-specific ARARs will be identified using RI site characterization data Action-specific ARARs with respect to each proposed alternative and compliance of each alternative with all ARARs will be discussed in the detailed analysis of alternatives section
213 Development of Remedial Action Objectives
Remedial action objectives consist of medium-specific or operable unit-specific goals to protect public health and the environment based on the ARARs the risk assessment goals (human health and ecological) time-based cleanup goals and technology based cleanup goals Remedial action objectives specify contaminants of concern by medium exposure routes and receptors and target clean-up levels (TCLs) for contaminants of concern For compounds or media of concern for which no ARARs exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be determined on the basis of risk assessments as well as the evaluation of expected exposures and associated risks of each alternative Final TCLs will be used to delineate the limits of contamination and to refine general response actions
The length of time to accomplish various levels of contaminant removal will also be addressed in accordance with USEPA Region I guidance documents (USEPA 1991)
214 Development of General Response Actions
General response actions are general purpose statements describing probable remediation activities at a given site to meet remedial action objectives Preliminary general response actions will be identified based upon understanding of the site and remedial action objectives based on readily available criteria and standards (eg ARARs TCLs) These preliminary general response actions will
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be refined throughout the FS as technologies and action-specific ARARs are identified and as a more complete understanding of a site and acceptable exposure levels is reached Like remedial action objectives general response actions may be medium- operable unit or site-specific For example typical general response actions for groundwater contamination would be
bull No ActionInstitutional Actions bull Containment Actions bull CollectionTreatment Actions
215 Identification of Area or Volume of Media
Areas or volumes of media to which general response actions might be applied will be determined based on acceptable exposure levels potential exposure routes site conditions and the nature and extent of contamination The effectiveness of applying remedial alternatives to hot spots will be considered The areas or volumes may be refined as alternatives are assembled and evaluated
216 Technology Identification and Screening
Documented information and data on technologies will be reviewed by ABB-ES to identify those technologies which best satisfy general response actions This initial assessment will involve a literature search of USEPA-published reports environmental journals and vendor information Results of this search will be presented as an identification table including the general response action category the specific technology and a brief technology description
The screening process assesses each technology for its probable effectiveness and implementability with regard to site-specific conditions known and suspected contaminants and affected environmental media The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated areas or volumes of media and meeting the contaminant reduction goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting human health during the construction and implementation phase and (3) how proven and reliable the technology is with respect to the contaminants and conditions at the site Implementability encompasses both the technical and institutional feasibility of implementing a technology These factors will be incorporated into two screening criteria waste- and site-limiting characteristics
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Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
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22
SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
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maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
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SECTION 2
The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
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analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
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SECTION 3
30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
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SECTION 3
bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
ABB Environmental Services Inc
REMALTSC 5960-24
3-2
REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
ABB Environmental Services Inc
REMALTSC 5960-24
R-l
SOURCE USGS TOPOGRAPHIC 7J MWUTE SERIES bdquobdquo_-bdquo_bdquo_ PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975
2000 4000
SCALE FEET
Ann FIGURE 1-1 SITE LOCATION ABB Environmental
Mill Services Inc PETERSON PURITAN INC SITE ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN
CUMBERLAND AND LINCOLN RHODE ISLAND
lt ~ UJ Z Q
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0 t- pound 8 f
i^
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C
PRO
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TY
8|
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Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
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ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
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SECTION 2
20 FEASIBILITY STUDY PROCESS
Based on the preliminary results of the RI separate FSs will be conducted to address the CCL and PAC properties within the Primary Source Area (OU 1) The FSs will consist of the following tasks
bull identification and screening of remedial technologies bull identification and screening of process options available within each
technology bull development of remedial alternatives bull screening of remedial alternatives bull post-screening data collection (optional) bull detailed analysis of remedial alternatives bull FS report
The overall objective of the FS is to develop and evaluate remedial alternatives for the contaminated media in OU 1 The remedial alternatives must be (1) protective of the public health and environment (2) implementable (3) cost effective (4) meet requirements of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and (5) meet Rhode Island and local requirements as stipulated in the Consent Order of 1987 The selection of a remedial alternative may need to 1) utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable and 2) satisfy the preference for treatment that reduces toxicity mobility and volume as a principal element or provide an explanation as to why it does not
21 DEVELOPMENT OF REMEDIAL ALTERNATIVES
The development of alternatives task consists of the following subtasks as shown in Figure 2-1
bull data review bull compilation of Applicable or Relevant and Appropriate
Requirements bull development of remedial action objectives
ABB Environmental Services Inc
REMALTSC 5960-24 2-1
SECTION 2
development of general response actions identification of area or volume of media identification and screening of technologies identification and screening of process options assembly of remedial alternatives
211 Data Review
The Development of Alternatives work element will begin with a thorough review of the RI data and information (both Phase I and Phase II) human health risk assessment and ecological risk assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater and by contaminants if this approach is believed to simplify the remediation process A review of data from the planned vapor extraction pilot study will also be made Additionally pumping test data from the recovery well and municipal well fields will be renewed
212 Compilation of Applicable or Relevant and Appropriate Requirements
Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the appropriate extent of site clean-up develop site-specific remedial response objectives develop remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA 1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs and State of Rhode Island requirements when applied legally and consistently statewide
Applicable requirements are federal and state requirements that specifically address substances or contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and state requirements that while not legally applicable can be applied if the site circumstances are sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate Applicable requirements and relevant and appropriate requirements are considered to have the same weight with respect to requiring compliance at CERCLA site cleanups
SARA also identifies a To Be Considered (TBC) category which includes federal and state non-regulatory requirements such as criteria advisories and guidance documents TBCs do not have the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs can be used to ensure that a remedy is protective
ABB Environmental Services Inc
REMALTSC 5960-24 2-2
SECTION 2
ARARs must be attained for hazardous substances remaining on-site at the completion of the remedial action Remedial action implementation should also comply with ARARs (and TBCs as appropriate) to protect public health and the environment Generally ARARs pertain to either contaminant levels or to performance or design standards to ensure protection at all points of potential exposure ARARs are divided into three general categories chemical- location- and action-specific
ABB-ES will identify federal and state chemical- location- and action-specific ARARs and TBCs Chemical- and location-specific ARARs will be identified using RI site characterization data Action-specific ARARs with respect to each proposed alternative and compliance of each alternative with all ARARs will be discussed in the detailed analysis of alternatives section
213 Development of Remedial Action Objectives
Remedial action objectives consist of medium-specific or operable unit-specific goals to protect public health and the environment based on the ARARs the risk assessment goals (human health and ecological) time-based cleanup goals and technology based cleanup goals Remedial action objectives specify contaminants of concern by medium exposure routes and receptors and target clean-up levels (TCLs) for contaminants of concern For compounds or media of concern for which no ARARs exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be determined on the basis of risk assessments as well as the evaluation of expected exposures and associated risks of each alternative Final TCLs will be used to delineate the limits of contamination and to refine general response actions
The length of time to accomplish various levels of contaminant removal will also be addressed in accordance with USEPA Region I guidance documents (USEPA 1991)
214 Development of General Response Actions
General response actions are general purpose statements describing probable remediation activities at a given site to meet remedial action objectives Preliminary general response actions will be identified based upon understanding of the site and remedial action objectives based on readily available criteria and standards (eg ARARs TCLs) These preliminary general response actions will
ABB Environmental Services Inc
REMALTSC 5960-24
2-3
SECTION 2
be refined throughout the FS as technologies and action-specific ARARs are identified and as a more complete understanding of a site and acceptable exposure levels is reached Like remedial action objectives general response actions may be medium- operable unit or site-specific For example typical general response actions for groundwater contamination would be
bull No ActionInstitutional Actions bull Containment Actions bull CollectionTreatment Actions
215 Identification of Area or Volume of Media
Areas or volumes of media to which general response actions might be applied will be determined based on acceptable exposure levels potential exposure routes site conditions and the nature and extent of contamination The effectiveness of applying remedial alternatives to hot spots will be considered The areas or volumes may be refined as alternatives are assembled and evaluated
216 Technology Identification and Screening
Documented information and data on technologies will be reviewed by ABB-ES to identify those technologies which best satisfy general response actions This initial assessment will involve a literature search of USEPA-published reports environmental journals and vendor information Results of this search will be presented as an identification table including the general response action category the specific technology and a brief technology description
The screening process assesses each technology for its probable effectiveness and implementability with regard to site-specific conditions known and suspected contaminants and affected environmental media The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated areas or volumes of media and meeting the contaminant reduction goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting human health during the construction and implementation phase and (3) how proven and reliable the technology is with respect to the contaminants and conditions at the site Implementability encompasses both the technical and institutional feasibility of implementing a technology These factors will be incorporated into two screening criteria waste- and site-limiting characteristics
ABB Environmental Services Inc
REMALTSC 5960-24 2-4
SECTION 2
Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
ABB Environmental Services Inc
REMALTSC 5960-24
2-5
22
SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
ABB Environmental Services Inc
REMALTSC 5960-24
2-6
SECTION 2
maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
ABB Environmental Services Inc
REMALTSC 5960-24
2-7
SECTION 2
The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
ABB Environmental Services Inc
REMALTSC 5960-24
2-8
SECTION 2
analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
ABB Environmental Services Inc
REMALTSC 5960-24
2-9
SECTION 3
30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
ABB Environmental Services Inc
REMALTSC 5960-24 3-1
SECTION 3
bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
ABB Environmental Services Inc
REMALTSC 5960-24
3-2
REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
ABB Environmental Services Inc
REMALTSC 5960-24
R-l
SOURCE USGS TOPOGRAPHIC 7J MWUTE SERIES bdquobdquo_-bdquo_bdquo_ PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975
2000 4000
SCALE FEET
Ann FIGURE 1-1 SITE LOCATION ABB Environmental
Mill Services Inc PETERSON PURITAN INC SITE ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN
CUMBERLAND AND LINCOLN RHODE ISLAND
lt ~ UJ Z Q
ui O 55 3 lt
isii O
pound3 E
U- O
DC Ul O
U
bull bull bull
--
ujzo
O- mdashmdash
bull Ill bull
UJ
bullo
cc bull UJGO
1DE
RM
AL
CO
NTA
CT
DE
RM
AL
| C
ON
TAC
T N
OU
S3O
NI
lsect a3
ui i- gtbull ^
1
U sect UI C U 2 S
OC11 jJ _ g
4 s8 ^ i 1 fl Uj3 c
bull
ecu
U)
^ 111 bdquo_
OCCsect
poundS =
V J ^
iltt
j
bull
gt^f s gt UI
SU
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CE
W
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ER
SU
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_j - i S gtJ5 0
bullgtbull - ^mdash ^
UI in
gtbull UI i u 2 OC z
ISTO
RIC
SI
FAR
M S
PI
CC til ji01X2 iS
3O lt C ui a5 eOC11 id 1Iiz
X
bullj
1
0 t- pound 8 f
i^
PA
C
PRO
PER
TY
8|
Si 8 K i lsk^ ill
Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
5-J
Ii gt 3 u i CUT I
Si I yK DC
sect^li00 Q-2lt
3 mdash Ill UQ
Y T DC UJ m 2 U
-bullalto So 35
I
a
Ul gti lt ^ a |ffpO
c o
1
i|m u
ltUJ
gt8
lti
22 w
E pound o
pound ii If Tplusmn
Si S
Ul CO
2
f CO
aF Z
Ul O
Ul 0
I
lt= ltsect F 0 5 gt 2 bull2Z a bdquobull deg-
lego
sect55 O O I mdash 111 U Q
111 oc
s I
latrade wuj^o OQ r
CD d)ltw
lt
II
J__T
r^zuzo
bull ltn
u-O amp
pound
1 I1gt mshyUJpound
lti
Si
UIZ g UJ CO
i sI ILU
Q
Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
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SECTION 2
development of general response actions identification of area or volume of media identification and screening of technologies identification and screening of process options assembly of remedial alternatives
211 Data Review
The Development of Alternatives work element will begin with a thorough review of the RI data and information (both Phase I and Phase II) human health risk assessment and ecological risk assessment OU 1 may be divided into separate media such as unsaturated soils and groundwater and by contaminants if this approach is believed to simplify the remediation process A review of data from the planned vapor extraction pilot study will also be made Additionally pumping test data from the recovery well and municipal well fields will be renewed
212 Compilation of Applicable or Relevant and Appropriate Requirements
Applicable or Relevant and Appropriate Requirements (ARARs) are used to determine the appropriate extent of site clean-up develop site-specific remedial response objectives develop remedial action alternatives and direct site clean-up SARA (Section 121) the NCP (USEPA 1990) and the Consent Order require that CERCLA remedial actions comply with federal ARARs and State of Rhode Island requirements when applied legally and consistently statewide
Applicable requirements are federal and state requirements that specifically address substances or contaminants and actions at CERCLA sites Relevant and appropriate requirements are federal and state requirements that while not legally applicable can be applied if the site circumstances are sufficiently similar to those covered by jurisdiction and if use of the requirement is appropriate Applicable requirements and relevant and appropriate requirements are considered to have the same weight with respect to requiring compliance at CERCLA site cleanups
SARA also identifies a To Be Considered (TBC) category which includes federal and state non-regulatory requirements such as criteria advisories and guidance documents TBCs do not have the same status as ARARs however if no ARAR exists for a chemical or particular situation TBCs can be used to ensure that a remedy is protective
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ARARs must be attained for hazardous substances remaining on-site at the completion of the remedial action Remedial action implementation should also comply with ARARs (and TBCs as appropriate) to protect public health and the environment Generally ARARs pertain to either contaminant levels or to performance or design standards to ensure protection at all points of potential exposure ARARs are divided into three general categories chemical- location- and action-specific
ABB-ES will identify federal and state chemical- location- and action-specific ARARs and TBCs Chemical- and location-specific ARARs will be identified using RI site characterization data Action-specific ARARs with respect to each proposed alternative and compliance of each alternative with all ARARs will be discussed in the detailed analysis of alternatives section
213 Development of Remedial Action Objectives
Remedial action objectives consist of medium-specific or operable unit-specific goals to protect public health and the environment based on the ARARs the risk assessment goals (human health and ecological) time-based cleanup goals and technology based cleanup goals Remedial action objectives specify contaminants of concern by medium exposure routes and receptors and target clean-up levels (TCLs) for contaminants of concern For compounds or media of concern for which no ARARs exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be determined on the basis of risk assessments as well as the evaluation of expected exposures and associated risks of each alternative Final TCLs will be used to delineate the limits of contamination and to refine general response actions
The length of time to accomplish various levels of contaminant removal will also be addressed in accordance with USEPA Region I guidance documents (USEPA 1991)
214 Development of General Response Actions
General response actions are general purpose statements describing probable remediation activities at a given site to meet remedial action objectives Preliminary general response actions will be identified based upon understanding of the site and remedial action objectives based on readily available criteria and standards (eg ARARs TCLs) These preliminary general response actions will
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be refined throughout the FS as technologies and action-specific ARARs are identified and as a more complete understanding of a site and acceptable exposure levels is reached Like remedial action objectives general response actions may be medium- operable unit or site-specific For example typical general response actions for groundwater contamination would be
bull No ActionInstitutional Actions bull Containment Actions bull CollectionTreatment Actions
215 Identification of Area or Volume of Media
Areas or volumes of media to which general response actions might be applied will be determined based on acceptable exposure levels potential exposure routes site conditions and the nature and extent of contamination The effectiveness of applying remedial alternatives to hot spots will be considered The areas or volumes may be refined as alternatives are assembled and evaluated
216 Technology Identification and Screening
Documented information and data on technologies will be reviewed by ABB-ES to identify those technologies which best satisfy general response actions This initial assessment will involve a literature search of USEPA-published reports environmental journals and vendor information Results of this search will be presented as an identification table including the general response action category the specific technology and a brief technology description
The screening process assesses each technology for its probable effectiveness and implementability with regard to site-specific conditions known and suspected contaminants and affected environmental media The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated areas or volumes of media and meeting the contaminant reduction goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting human health during the construction and implementation phase and (3) how proven and reliable the technology is with respect to the contaminants and conditions at the site Implementability encompasses both the technical and institutional feasibility of implementing a technology These factors will be incorporated into two screening criteria waste- and site-limiting characteristics
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Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
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22
SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
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maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
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The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
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analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
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SECTION 3
30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
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bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
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REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
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SOURCE USEPA 1989
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Combine Media-Specific Technologies into
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FIGURE 2-1
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FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
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ARARs must be attained for hazardous substances remaining on-site at the completion of the remedial action Remedial action implementation should also comply with ARARs (and TBCs as appropriate) to protect public health and the environment Generally ARARs pertain to either contaminant levels or to performance or design standards to ensure protection at all points of potential exposure ARARs are divided into three general categories chemical- location- and action-specific
ABB-ES will identify federal and state chemical- location- and action-specific ARARs and TBCs Chemical- and location-specific ARARs will be identified using RI site characterization data Action-specific ARARs with respect to each proposed alternative and compliance of each alternative with all ARARs will be discussed in the detailed analysis of alternatives section
213 Development of Remedial Action Objectives
Remedial action objectives consist of medium-specific or operable unit-specific goals to protect public health and the environment based on the ARARs the risk assessment goals (human health and ecological) time-based cleanup goals and technology based cleanup goals Remedial action objectives specify contaminants of concern by medium exposure routes and receptors and target clean-up levels (TCLs) for contaminants of concern For compounds or media of concern for which no ARARs exist ABB-ES will consider TBCs and risk-based TCLs will be developed Final TCLs will be determined on the basis of risk assessments as well as the evaluation of expected exposures and associated risks of each alternative Final TCLs will be used to delineate the limits of contamination and to refine general response actions
The length of time to accomplish various levels of contaminant removal will also be addressed in accordance with USEPA Region I guidance documents (USEPA 1991)
214 Development of General Response Actions
General response actions are general purpose statements describing probable remediation activities at a given site to meet remedial action objectives Preliminary general response actions will be identified based upon understanding of the site and remedial action objectives based on readily available criteria and standards (eg ARARs TCLs) These preliminary general response actions will
ABB Environmental Services Inc
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SECTION 2
be refined throughout the FS as technologies and action-specific ARARs are identified and as a more complete understanding of a site and acceptable exposure levels is reached Like remedial action objectives general response actions may be medium- operable unit or site-specific For example typical general response actions for groundwater contamination would be
bull No ActionInstitutional Actions bull Containment Actions bull CollectionTreatment Actions
215 Identification of Area or Volume of Media
Areas or volumes of media to which general response actions might be applied will be determined based on acceptable exposure levels potential exposure routes site conditions and the nature and extent of contamination The effectiveness of applying remedial alternatives to hot spots will be considered The areas or volumes may be refined as alternatives are assembled and evaluated
216 Technology Identification and Screening
Documented information and data on technologies will be reviewed by ABB-ES to identify those technologies which best satisfy general response actions This initial assessment will involve a literature search of USEPA-published reports environmental journals and vendor information Results of this search will be presented as an identification table including the general response action category the specific technology and a brief technology description
The screening process assesses each technology for its probable effectiveness and implementability with regard to site-specific conditions known and suspected contaminants and affected environmental media The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated areas or volumes of media and meeting the contaminant reduction goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting human health during the construction and implementation phase and (3) how proven and reliable the technology is with respect to the contaminants and conditions at the site Implementability encompasses both the technical and institutional feasibility of implementing a technology These factors will be incorporated into two screening criteria waste- and site-limiting characteristics
ABB Environmental Services Inc
REMALTSC 5960-24 2-4
SECTION 2
Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
ABB Environmental Services Inc
REMALTSC 5960-24
2-5
22
SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
ABB Environmental Services Inc
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2-6
SECTION 2
maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
ABB Environmental Services Inc
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SECTION 2
The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
ABB Environmental Services Inc
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SECTION 2
analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
ABB Environmental Services Inc
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SECTION 3
30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
ABB Environmental Services Inc
REMALTSC 5960-24 3-1
SECTION 3
bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
ABB Environmental Services Inc
REMALTSC 5960-24
3-2
REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
ABB Environmental Services Inc
REMALTSC 5960-24
R-l
SOURCE USGS TOPOGRAPHIC 7J MWUTE SERIES bdquobdquo_-bdquo_bdquo_ PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975
2000 4000
SCALE FEET
Ann FIGURE 1-1 SITE LOCATION ABB Environmental
Mill Services Inc PETERSON PURITAN INC SITE ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN
CUMBERLAND AND LINCOLN RHODE ISLAND
lt ~ UJ Z Q
ui O 55 3 lt
isii O
pound3 E
U- O
DC Ul O
U
bull bull bull
--
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1DE
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AL
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CT
DE
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| C
ON
TAC
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OU
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lsect a3
ui i- gtbull ^
1
U sect UI C U 2 S
OC11 jJ _ g
4 s8 ^ i 1 fl Uj3 c
bull
ecu
U)
^ 111 bdquo_
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poundS =
V J ^
iltt
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gt^f s gt UI
SU
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CE
W
AT
ER
SU
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_j - i S gtJ5 0
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UI in
gtbull UI i u 2 OC z
ISTO
RIC
SI
FAR
M S
PI
CC til ji01X2 iS
3O lt C ui a5 eOC11 id 1Iiz
X
bullj
1
0 t- pound 8 f
i^
PA
C
PRO
PER
TY
8|
Si 8 K i lsk^ ill
Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
5-J
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sect^li00 Q-2lt
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Y T DC UJ m 2 U
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lego
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ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
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219
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A
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DE
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ER
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LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
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OU I
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ill
Ser
vice
s Inc
PE
TERS
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EA BR
OWN B
OVEII
F
EA
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ILIT
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RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
SECTION 2
be refined throughout the FS as technologies and action-specific ARARs are identified and as a more complete understanding of a site and acceptable exposure levels is reached Like remedial action objectives general response actions may be medium- operable unit or site-specific For example typical general response actions for groundwater contamination would be
bull No ActionInstitutional Actions bull Containment Actions bull CollectionTreatment Actions
215 Identification of Area or Volume of Media
Areas or volumes of media to which general response actions might be applied will be determined based on acceptable exposure levels potential exposure routes site conditions and the nature and extent of contamination The effectiveness of applying remedial alternatives to hot spots will be considered The areas or volumes may be refined as alternatives are assembled and evaluated
216 Technology Identification and Screening
Documented information and data on technologies will be reviewed by ABB-ES to identify those technologies which best satisfy general response actions This initial assessment will involve a literature search of USEPA-published reports environmental journals and vendor information Results of this search will be presented as an identification table including the general response action category the specific technology and a brief technology description
The screening process assesses each technology for its probable effectiveness and implementability with regard to site-specific conditions known and suspected contaminants and affected environmental media The effectiveness evaluation focuses on (1) whether the technology is capable of handling the estimated areas or volumes of media and meeting the contaminant reduction goals identified in the remedial action objectives (2) the effectiveness of the technology in protecting human health during the construction and implementation phase and (3) how proven and reliable the technology is with respect to the contaminants and conditions at the site Implementability encompasses both the technical and institutional feasibility of implementing a technology These factors will be incorporated into two screening criteria waste- and site-limiting characteristics
ABB Environmental Services Inc
REMALTSC 5960-24 2-4
SECTION 2
Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
ABB Environmental Services Inc
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2-5
22
SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
ABB Environmental Services Inc
REMALTSC 5960-24
2-6
SECTION 2
maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
ABB Environmental Services Inc
REMALTSC 5960-24
2-7
SECTION 2
The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
ABB Environmental Services Inc
REMALTSC 5960-24
2-8
SECTION 2
analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
ABB Environmental Services Inc
REMALTSC 5960-24
2-9
SECTION 3
30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
ABB Environmental Services Inc
REMALTSC 5960-24 3-1
SECTION 3
bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
ABB Environmental Services Inc
REMALTSC 5960-24
3-2
REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
ABB Environmental Services Inc
REMALTSC 5960-24
R-l
SOURCE USGS TOPOGRAPHIC 7J MWUTE SERIES bdquobdquo_-bdquo_bdquo_ PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975
2000 4000
SCALE FEET
Ann FIGURE 1-1 SITE LOCATION ABB Environmental
Mill Services Inc PETERSON PURITAN INC SITE ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN
CUMBERLAND AND LINCOLN RHODE ISLAND
lt ~ UJ Z Q
ui O 55 3 lt
isii O
pound3 E
U- O
DC Ul O
U
bull bull bull
--
ujzo
O- mdashmdash
bull Ill bull
UJ
bullo
cc bull UJGO
1DE
RM
AL
CO
NTA
CT
DE
RM
AL
| C
ON
TAC
T N
OU
S3O
NI
lsect a3
ui i- gtbull ^
1
U sect UI C U 2 S
OC11 jJ _ g
4 s8 ^ i 1 fl Uj3 c
bull
ecu
U)
^ 111 bdquo_
OCCsect
poundS =
V J ^
iltt
j
bull
gt^f s gt UI
SU
RFA
CE
W
AT
ER
SU
RFA
CE
_j - i S gtJ5 0
bullgtbull - ^mdash ^
UI in
gtbull UI i u 2 OC z
ISTO
RIC
SI
FAR
M S
PI
CC til ji01X2 iS
3O lt C ui a5 eOC11 id 1Iiz
X
bullj
1
0 t- pound 8 f
i^
PA
C
PRO
PER
TY
8|
Si 8 K i lsk^ ill
Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
5-J
Ii gt 3 u i CUT I
Si I yK DC
sect^li00 Q-2lt
3 mdash Ill UQ
Y T DC UJ m 2 U
-bullalto So 35
I
a
Ul gti lt ^ a |ffpO
c o
1
i|m u
ltUJ
gt8
lti
22 w
E pound o
pound ii If Tplusmn
Si S
Ul CO
2
f CO
aF Z
Ul O
Ul 0
I
lt= ltsect F 0 5 gt 2 bull2Z a bdquobull deg-
lego
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ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
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ITY
DE
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NT
OF
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ES
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(6
219
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A
RE
VIS
ED
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DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
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vice
s Inc
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TERS
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D
SECTION 2
Waste-limiting characteristics consider the effect exerted on a technology by contaminant types individual compound properties (eg volatility solubility specific gravity adsorption potential and biodegradability) and interactions that may occur between mixtures of compounds (eg reactions and increased solubility) Site-Limiting characteristics consider site-specific physical features including topography buildings underground utilities available space and proximity to sensitive operations Waste-Limiting characteristics largely determine effectiveness and performance of a technology site-Limiting characteristics affect implementability of a technology
The primary contaminants of concern associated with the CCL property are chlorinated solvents in the unsaturated and saturated zone soils and shallow groundwater The primary contaminants of concern associated with the PAC property are acetone and arsenic hi the unsaturated zone soils and shallow groundwater Figure 2-2 identifies potential remedial technologies for the different contaminated media in OU 1
217 Assembly of Remedial Alternatives
A range of remedial alternatives will be developed by combining technologies retained through screening which as a group address all remedial response objectives established for a particular site The range of alternatives will reflect (1) a no action alternative (2) various volumes of media andor areas of the site (3) several degrees of long-term management and (4) differences in reduction of mobility toxicity and volume
Development of a complete range of treatment alternatives may not be practical in some cases For example it would not be reasonable to develop a treatment or disposal alternative to eliminate the need for long-term management of the contaminated soils beneath the CCL plant because of the extreme costs that would be involved For each alternative developed a narrative description will be provided including the logic used to develop the alternative and other information describing its implementation
ABB Environmental Services Inc
REMALTSC 5960-24
2-5
22
SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
ABB Environmental Services Inc
REMALTSC 5960-24
2-6
SECTION 2
maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
ABB Environmental Services Inc
REMALTSC 5960-24
2-7
SECTION 2
The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
ABB Environmental Services Inc
REMALTSC 5960-24
2-8
SECTION 2
analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
ABB Environmental Services Inc
REMALTSC 5960-24
2-9
SECTION 3
30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
ABB Environmental Services Inc
REMALTSC 5960-24 3-1
SECTION 3
bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
ABB Environmental Services Inc
REMALTSC 5960-24
3-2
REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
ABB Environmental Services Inc
REMALTSC 5960-24
R-l
SOURCE USGS TOPOGRAPHIC 7J MWUTE SERIES bdquobdquo_-bdquo_bdquo_ PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975
2000 4000
SCALE FEET
Ann FIGURE 1-1 SITE LOCATION ABB Environmental
Mill Services Inc PETERSON PURITAN INC SITE ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN
CUMBERLAND AND LINCOLN RHODE ISLAND
lt ~ UJ Z Q
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U- O
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U
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iltt
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i^
PA
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PRO
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TY
8|
Si 8 K i lsk^ ill
Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
5-J
Ii gt 3 u i CUT I
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Y T DC UJ m 2 U
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a
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Ul 0
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lego
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111 oc
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latrade wuj^o OQ r
CD d)ltw
lt
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r^zuzo
bull ltn
u-O amp
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1 I1gt mshyUJpound
lti
Si
UIZ g UJ CO
i sI ILU
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Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
22
SECTION 2
SCREENING OF REMEDIAL ALTERNATIVES
During screening alternatives are quantitatively defined to allow differentiation with respect to the criteria of effectiveness implementability and cost This is achieved through refinement of estimates of volume or areas of contaminated media the size and configuration of onsite extraction and treatment systems as well as time frames to achieve remediation goals rates or flows of treatment spatial requirements distances for disposal technologies and required permits for off-site actions and imposed limitations Innovative technologies may be carried through the screening process if there is reason to believe they offer significant advantages in the form of better treatment performance implementability fewer adverse impacts or lower costs
The three screening criteria conform with remedy selection requirements of CERCLA and the NCP The screening step eliminates impractical alternatives or higher cost alternatives (ie order of magnitude) that provide little or no increase in effectiveness or implementability over their lower-cost counterparts By eliminating these alternatives early more time and effort can be devoted to detailed analysis of the more promising alternatives The no-action alternative will not be evaluated according to screening criteria it will pass through screening to be evaluated during detailed analysis as a baseline for the other retained alternatives (USEPA 1988)
The effectiveness criterion evaluates the effectiveness of each alternative in protecting human health and the environment and the degree to which treatment alternatives reduce the mobility toxicity or volume of the waste material Both short- and long-term aspects will be evaluated Short-term aspects refer to risks posed to the community and workers during the construction and implementation period the alternatives compliance with chemical- and location-specific ARARs and the time required to achieve remedial action objectives Long-term aspects which apply after the remedial action has been completed consider the magnitude of the remaining risk due to untreated wastes and waste residuals and the adequacy and reliability of specific technical components and control measures
Implementability is a measure of technical and administrative feasibility In the assessment of short-term technical feasibility ABB-ES will consider the availability of a technology for construction or mobilization and operation as well as compliance with action-specific ARARs during the remedial action After the remedial action is complete technical feasibility focuses on operation and
ABB Environmental Services Inc
REMALTSC 5960-24
2-6
SECTION 2
maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
ABB Environmental Services Inc
REMALTSC 5960-24
2-7
SECTION 2
The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
ABB Environmental Services Inc
REMALTSC 5960-24
2-8
SECTION 2
analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
ABB Environmental Services Inc
REMALTSC 5960-24
2-9
SECTION 3
30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
ABB Environmental Services Inc
REMALTSC 5960-24 3-1
SECTION 3
bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
ABB Environmental Services Inc
REMALTSC 5960-24
3-2
REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
ABB Environmental Services Inc
REMALTSC 5960-24
R-l
SOURCE USGS TOPOGRAPHIC 7J MWUTE SERIES bdquobdquo_-bdquo_bdquo_ PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975
2000 4000
SCALE FEET
Ann FIGURE 1-1 SITE LOCATION ABB Environmental
Mill Services Inc PETERSON PURITAN INC SITE ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN
CUMBERLAND AND LINCOLN RHODE ISLAND
lt ~ UJ Z Q
ui O 55 3 lt
isii O
pound3 E
U- O
DC Ul O
U
bull bull bull
--
ujzo
O- mdashmdash
bull Ill bull
UJ
bullo
cc bull UJGO
1DE
RM
AL
CO
NTA
CT
DE
RM
AL
| C
ON
TAC
T N
OU
S3O
NI
lsect a3
ui i- gtbull ^
1
U sect UI C U 2 S
OC11 jJ _ g
4 s8 ^ i 1 fl Uj3 c
bull
ecu
U)
^ 111 bdquo_
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poundS =
V J ^
iltt
j
bull
gt^f s gt UI
SU
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CE
W
AT
ER
SU
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CE
_j - i S gtJ5 0
bullgtbull - ^mdash ^
UI in
gtbull UI i u 2 OC z
ISTO
RIC
SI
FAR
M S
PI
CC til ji01X2 iS
3O lt C ui a5 eOC11 id 1Iiz
X
bullj
1
0 t- pound 8 f
i^
PA
C
PRO
PER
TY
8|
Si 8 K i lsk^ ill
Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
5-J
Ii gt 3 u i CUT I
Si I yK DC
sect^li00 Q-2lt
3 mdash Ill UQ
Y T DC UJ m 2 U
-bullalto So 35
I
a
Ul gti lt ^ a |ffpO
c o
1
i|m u
ltUJ
gt8
lti
22 w
E pound o
pound ii If Tplusmn
Si S
Ul CO
2
f CO
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Ul 0
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lt= ltsect F 0 5 gt 2 bull2Z a bdquobull deg-
lego
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111 oc
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bull ltn
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lti
Si
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Oa l II Qs 2I I gQ
TTTT
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ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
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F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
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IVE
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VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
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MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
SECTION 2
maintenance (OampM) replacement and monitoring of technical controls of residuals and untreated wastes ABB-ES assessment of administrative feasibility will address coordination with regulatory and other agencies and the availability of required services and trained specialists or operators
The cost analysis will include an estimate of both capital and OampM expenditures Absolute accuracy of cost estimates during screening is not critical the focus is to identify costs of primary technical components to facilitate a consistent comparative analysis among the alternatives with relative accuracy This will permit cost decisions among alternatives to be sustained as the accuracy of the cost estimates improves beyond the screening process (USEPA 1988)
The information discussed in Subsections 21 and 22 Development and Screening of Remedial Alternatives respectively will be compiled and presented as a Draft Screening of Remedial Alternatives interim deliverable ABB-ES will prepare a Comment Response Package for comments received on this interim deliverable and incorporate these comments into the context of the Draft FS Report
23 POST-SCREENING DATA COLLECTION
It is ABB-ES opinion that sufficient data has been gathered for OU 1 to properly identify and evaluate potential remedial technologies and develop remedial alternatives If future data gaps are identified ABB-ES will coordinate with CPC USEPA and RIDEM prior to initiating additional field investigations
24 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
The detailed analysis presents the relevant information that allows a site remedy selection The detailed analysis of each remedial alternative includes the following
bull detailed descriptions of each remedial alternative with emphasis on application of the various technologies as components in the alternative and
bull detailed analysis of each remedial alternative relative to the evaluation criteria established to address CERCLA requirements
ABB Environmental Services Inc
REMALTSC 5960-24
2-7
SECTION 2
The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
ABB Environmental Services Inc
REMALTSC 5960-24
2-8
SECTION 2
analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
ABB Environmental Services Inc
REMALTSC 5960-24
2-9
SECTION 3
30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
ABB Environmental Services Inc
REMALTSC 5960-24 3-1
SECTION 3
bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
ABB Environmental Services Inc
REMALTSC 5960-24
3-2
REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
ABB Environmental Services Inc
REMALTSC 5960-24
R-l
SOURCE USGS TOPOGRAPHIC 7J MWUTE SERIES bdquobdquo_-bdquo_bdquo_ PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975
2000 4000
SCALE FEET
Ann FIGURE 1-1 SITE LOCATION ABB Environmental
Mill Services Inc PETERSON PURITAN INC SITE ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN
CUMBERLAND AND LINCOLN RHODE ISLAND
lt ~ UJ Z Q
ui O 55 3 lt
isii O
pound3 E
U- O
DC Ul O
U
bull bull bull
--
ujzo
O- mdashmdash
bull Ill bull
UJ
bullo
cc bull UJGO
1DE
RM
AL
CO
NTA
CT
DE
RM
AL
| C
ON
TAC
T N
OU
S3O
NI
lsect a3
ui i- gtbull ^
1
U sect UI C U 2 S
OC11 jJ _ g
4 s8 ^ i 1 fl Uj3 c
bull
ecu
U)
^ 111 bdquo_
OCCsect
poundS =
V J ^
iltt
j
bull
gt^f s gt UI
SU
RFA
CE
W
AT
ER
SU
RFA
CE
_j - i S gtJ5 0
bullgtbull - ^mdash ^
UI in
gtbull UI i u 2 OC z
ISTO
RIC
SI
FAR
M S
PI
CC til ji01X2 iS
3O lt C ui a5 eOC11 id 1Iiz
X
bullj
1
0 t- pound 8 f
i^
PA
C
PRO
PER
TY
8|
Si 8 K i lsk^ ill
Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
5-J
Ii gt 3 u i CUT I
Si I yK DC
sect^li00 Q-2lt
3 mdash Ill UQ
Y T DC UJ m 2 U
-bullalto So 35
I
a
Ul gti lt ^ a |ffpO
c o
1
i|m u
ltUJ
gt8
lti
22 w
E pound o
pound ii If Tplusmn
Si S
Ul CO
2
f CO
aF Z
Ul O
Ul 0
I
lt= ltsect F 0 5 gt 2 bull2Z a bdquobull deg-
lego
sect55 O O I mdash 111 U Q
111 oc
s I
latrade wuj^o OQ r
CD d)ltw
lt
II
J__T
r^zuzo
bull ltn
u-O amp
pound
1 I1gt mshyUJpound
lti
Si
UIZ g UJ CO
i sI ILU
Q
Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
SECTION 2
The detailed description of each remedial alternative will emphasize the technologies used and the components of each alternative Where appropriate the description will present preliminary design calculations process flow diagrams sizing of key components preliminary site layouts and a discussion of limitations assumptions and uncertainties concerning each alternative
As part of the criteria analysis remedial alternatives will be examined with respect to requirements stipulated in CERCLA (Section 121) as amended by SARA CERCLA emphasizes the evaluation of long-term effectiveness and related considerations for each remedial alternative ABB-ES will address the CERCLA statutory requirements by evaluating each remedial alternative and presenting individual analyses based on the following criteria
Threshold Criteria (must be met by each alternative) bull overall protection of human health and the environment bull compliance with ARARs
Primary Criteria (basis of alternative evaluation) bull long-term effectiveness and permanence bull reduction of toxicity mobility or volume through treatment bull short-term effectiveness bull implementability bull cost
These criteria are seven of the nine criteria outlined in the USEPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA (USEPA 1988) USEPA Region I guidance (USEPA 1991) and Section 300430e9 of the NCP The State and Community Acceptance criteria are the final two criteria and will be addressed after comments on the RIFS and Proposed Plan have been received These nine criteria will be presented in tabular form for all remaining remedial alternatives to be used as an aid in the selection of the preferred alternative
25 FEASIBILITY STUDY REPORT
Each Draft FS Report will be produced to compile the Initial Screening of Alternatives and Detailed Analysis of Alternatives Additionally each Draft FS Report will include a comparative analysis of alternatives The comparative
ABB Environmental Services Inc
REMALTSC 5960-24
2-8
SECTION 2
analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
ABB Environmental Services Inc
REMALTSC 5960-24
2-9
SECTION 3
30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
ABB Environmental Services Inc
REMALTSC 5960-24 3-1
SECTION 3
bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
ABB Environmental Services Inc
REMALTSC 5960-24
3-2
REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
ABB Environmental Services Inc
REMALTSC 5960-24
R-l
SOURCE USGS TOPOGRAPHIC 7J MWUTE SERIES bdquobdquo_-bdquo_bdquo_ PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975
2000 4000
SCALE FEET
Ann FIGURE 1-1 SITE LOCATION ABB Environmental
Mill Services Inc PETERSON PURITAN INC SITE ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN
CUMBERLAND AND LINCOLN RHODE ISLAND
lt ~ UJ Z Q
ui O 55 3 lt
isii O
pound3 E
U- O
DC Ul O
U
bull bull bull
--
ujzo
O- mdashmdash
bull Ill bull
UJ
bullo
cc bull UJGO
1DE
RM
AL
CO
NTA
CT
DE
RM
AL
| C
ON
TAC
T N
OU
S3O
NI
lsect a3
ui i- gtbull ^
1
U sect UI C U 2 S
OC11 jJ _ g
4 s8 ^ i 1 fl Uj3 c
bull
ecu
U)
^ 111 bdquo_
OCCsect
poundS =
V J ^
iltt
j
bull
gt^f s gt UI
SU
RFA
CE
W
AT
ER
SU
RFA
CE
_j - i S gtJ5 0
bullgtbull - ^mdash ^
UI in
gtbull UI i u 2 OC z
ISTO
RIC
SI
FAR
M S
PI
CC til ji01X2 iS
3O lt C ui a5 eOC11 id 1Iiz
X
bullj
1
0 t- pound 8 f
i^
PA
C
PRO
PER
TY
8|
Si 8 K i lsk^ ill
Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
5-J
Ii gt 3 u i CUT I
Si I yK DC
sect^li00 Q-2lt
3 mdash Ill UQ
Y T DC UJ m 2 U
-bullalto So 35
I
a
Ul gti lt ^ a |ffpO
c o
1
i|m u
ltUJ
gt8
lti
22 w
E pound o
pound ii If Tplusmn
Si S
Ul CO
2
f CO
aF Z
Ul O
Ul 0
I
lt= ltsect F 0 5 gt 2 bull2Z a bdquobull deg-
lego
sect55 O O I mdash 111 U Q
111 oc
s I
latrade wuj^o OQ r
CD d)ltw
lt
II
J__T
r^zuzo
bull ltn
u-O amp
pound
1 I1gt mshyUJpound
lti
Si
UIZ g UJ CO
i sI ILU
Q
Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
SECTION 2
analysis will identify the advantages and disadvantages of each alternative relative to one another in relation to the seven evaluation criteria
Each FS Report will be issued as follows
bull Draft bull Receipt of Regulator comments bull Revised Draft bull Public Comment bull Final
ABB Environmental Services Inc
REMALTSC 5960-24
2-9
SECTION 3
30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
ABB Environmental Services Inc
REMALTSC 5960-24 3-1
SECTION 3
bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
ABB Environmental Services Inc
REMALTSC 5960-24
3-2
REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
ABB Environmental Services Inc
REMALTSC 5960-24
R-l
SOURCE USGS TOPOGRAPHIC 7J MWUTE SERIES bdquobdquo_-bdquo_bdquo_ PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975
2000 4000
SCALE FEET
Ann FIGURE 1-1 SITE LOCATION ABB Environmental
Mill Services Inc PETERSON PURITAN INC SITE ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN
CUMBERLAND AND LINCOLN RHODE ISLAND
lt ~ UJ Z Q
ui O 55 3 lt
isii O
pound3 E
U- O
DC Ul O
U
bull bull bull
--
ujzo
O- mdashmdash
bull Ill bull
UJ
bullo
cc bull UJGO
1DE
RM
AL
CO
NTA
CT
DE
RM
AL
| C
ON
TAC
T N
OU
S3O
NI
lsect a3
ui i- gtbull ^
1
U sect UI C U 2 S
OC11 jJ _ g
4 s8 ^ i 1 fl Uj3 c
bull
ecu
U)
^ 111 bdquo_
OCCsect
poundS =
V J ^
iltt
j
bull
gt^f s gt UI
SU
RFA
CE
W
AT
ER
SU
RFA
CE
_j - i S gtJ5 0
bullgtbull - ^mdash ^
UI in
gtbull UI i u 2 OC z
ISTO
RIC
SI
FAR
M S
PI
CC til ji01X2 iS
3O lt C ui a5 eOC11 id 1Iiz
X
bullj
1
0 t- pound 8 f
i^
PA
C
PRO
PER
TY
8|
Si 8 K i lsk^ ill
Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
5-J
Ii gt 3 u i CUT I
Si I yK DC
sect^li00 Q-2lt
3 mdash Ill UQ
Y T DC UJ m 2 U
-bullalto So 35
I
a
Ul gti lt ^ a |ffpO
c o
1
i|m u
ltUJ
gt8
lti
22 w
E pound o
pound ii If Tplusmn
Si S
Ul CO
2
f CO
aF Z
Ul O
Ul 0
I
lt= ltsect F 0 5 gt 2 bull2Z a bdquobull deg-
lego
sect55 O O I mdash 111 U Q
111 oc
s I
latrade wuj^o OQ r
CD d)ltw
lt
II
J__T
r^zuzo
bull ltn
u-O amp
pound
1 I1gt mshyUJpound
lti
Si
UIZ g UJ CO
i sI ILU
Q
Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
SECTION 3
30 PROJECT ORGANIZATION AND SCHEDULE
The project organization structure is illustrated in Figure 3-1 Details of the function and responsibilities of key project personnel are described below
The Project Manager for the OU 1 FS Mr Paul Exner PE has the day-to-day responsibility for conducting the FS project including
bull ensuring the appropriateness and adequacy of the technical or engineering services provided for a specific task
bull developing the technical approach and level of effort required to address each element of a task
bull supervising day-to-day conduct of the work including integrating the efforts of all supporting disciplines and subcontractors
bull overseeing the preparation of all reports and plans
bull providing for quality control and quality review during the performance of the work
bull ensuring technical integrity clarity and usefulness of task work products and
bull developing and monitoring task schedules
Mr David Heislein will serve as the Engineering Leader for the OU 1 FS effort The Functional Leader for Engineering assumes responsibility for all aspects of the FS including treatability tests risk assessment and ARARs In this position Mr Heislein will be responsible for
bull identification of ARARs
bull coordination with the RI and risk assessment teams to identify and correct any data gaps that may occur
ABB Environmental Services Inc
REMALTSC 5960-24 3-1
SECTION 3
bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
ABB Environmental Services Inc
REMALTSC 5960-24
3-2
REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
ABB Environmental Services Inc
REMALTSC 5960-24
R-l
SOURCE USGS TOPOGRAPHIC 7J MWUTE SERIES bdquobdquo_-bdquo_bdquo_ PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975
2000 4000
SCALE FEET
Ann FIGURE 1-1 SITE LOCATION ABB Environmental
Mill Services Inc PETERSON PURITAN INC SITE ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN
CUMBERLAND AND LINCOLN RHODE ISLAND
lt ~ UJ Z Q
ui O 55 3 lt
isii O
pound3 E
U- O
DC Ul O
U
bull bull bull
--
ujzo
O- mdashmdash
bull Ill bull
UJ
bullo
cc bull UJGO
1DE
RM
AL
CO
NTA
CT
DE
RM
AL
| C
ON
TAC
T N
OU
S3O
NI
lsect a3
ui i- gtbull ^
1
U sect UI C U 2 S
OC11 jJ _ g
4 s8 ^ i 1 fl Uj3 c
bull
ecu
U)
^ 111 bdquo_
OCCsect
poundS =
V J ^
iltt
j
bull
gt^f s gt UI
SU
RFA
CE
W
AT
ER
SU
RFA
CE
_j - i S gtJ5 0
bullgtbull - ^mdash ^
UI in
gtbull UI i u 2 OC z
ISTO
RIC
SI
FAR
M S
PI
CC til ji01X2 iS
3O lt C ui a5 eOC11 id 1Iiz
X
bullj
1
0 t- pound 8 f
i^
PA
C
PRO
PER
TY
8|
Si 8 K i lsk^ ill
Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
5-J
Ii gt 3 u i CUT I
Si I yK DC
sect^li00 Q-2lt
3 mdash Ill UQ
Y T DC UJ m 2 U
-bullalto So 35
I
a
Ul gti lt ^ a |ffpO
c o
1
i|m u
ltUJ
gt8
lti
22 w
E pound o
pound ii If Tplusmn
Si S
Ul CO
2
f CO
aF Z
Ul O
Ul 0
I
lt= ltsect F 0 5 gt 2 bull2Z a bdquobull deg-
lego
sect55 O O I mdash 111 U Q
111 oc
s I
latrade wuj^o OQ r
CD d)ltw
lt
II
J__T
r^zuzo
bull ltn
u-O amp
pound
1 I1gt mshyUJpound
lti
Si
UIZ g UJ CO
i sI ILU
Q
Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
SECTION 3
bull - based on the RI Report identify and analyze feasible alternatives for remediation of contaminated media
bull coordinate and conduct appropriate process identification and testing evaluations and
bull coordinate and oversee the production of the FS Report in accordance with the contract requirements that accurately reflect the data and project findings
The members of the ABB-ES Project Review Committee for this task are Mr Willard Murray PhD PE Mr Doug Pierce PG and Mr Dennis Tuttle PE Mr Murray will serve as technical director and will be responsible for the overall technical quality of the work performed he will also serve as chairman of the review committee The function of this group of senior technical andor management personnel is to provide guidance and oversight on the technical aspects of the project This is accomplished through periodic reviews of the services provided to ensure they represent the accumulated experience of the firm are being produced in accordance with corporate policy and live up to the objectives of the program as established by ABB-ES and CPC
The FS schedule presented in Figure 3-2 assumes the following review elements for primary and secondary documents
Regulatory review of Screening of Remedial Alternatives Deliverable 15 days ABB-ES Preparation of Comment Response Package 15 days Regulatory review of Comment Response Package 15 days Regulatory review of Draft FS 15 days
The reporting requirements for the Draft Screening of Remedial Alternatives deliverable specify the above schedule only through Preparation of Comment Response Package Finalization of the interim document will be in the context of each Draft FS Report
ABB Environmental Services Inc
REMALTSC 5960-24
3-2
REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
ABB Environmental Services Inc
REMALTSC 5960-24
R-l
SOURCE USGS TOPOGRAPHIC 7J MWUTE SERIES bdquobdquo_-bdquo_bdquo_ PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975
2000 4000
SCALE FEET
Ann FIGURE 1-1 SITE LOCATION ABB Environmental
Mill Services Inc PETERSON PURITAN INC SITE ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN
CUMBERLAND AND LINCOLN RHODE ISLAND
lt ~ UJ Z Q
ui O 55 3 lt
isii O
pound3 E
U- O
DC Ul O
U
bull bull bull
--
ujzo
O- mdashmdash
bull Ill bull
UJ
bullo
cc bull UJGO
1DE
RM
AL
CO
NTA
CT
DE
RM
AL
| C
ON
TAC
T N
OU
S3O
NI
lsect a3
ui i- gtbull ^
1
U sect UI C U 2 S
OC11 jJ _ g
4 s8 ^ i 1 fl Uj3 c
bull
ecu
U)
^ 111 bdquo_
OCCsect
poundS =
V J ^
iltt
j
bull
gt^f s gt UI
SU
RFA
CE
W
AT
ER
SU
RFA
CE
_j - i S gtJ5 0
bullgtbull - ^mdash ^
UI in
gtbull UI i u 2 OC z
ISTO
RIC
SI
FAR
M S
PI
CC til ji01X2 iS
3O lt C ui a5 eOC11 id 1Iiz
X
bullj
1
0 t- pound 8 f
i^
PA
C
PRO
PER
TY
8|
Si 8 K i lsk^ ill
Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
5-J
Ii gt 3 u i CUT I
Si I yK DC
sect^li00 Q-2lt
3 mdash Ill UQ
Y T DC UJ m 2 U
-bullalto So 35
I
a
Ul gti lt ^ a |ffpO
c o
1
i|m u
ltUJ
gt8
lti
22 w
E pound o
pound ii If Tplusmn
Si S
Ul CO
2
f CO
aF Z
Ul O
Ul 0
I
lt= ltsect F 0 5 gt 2 bull2Z a bdquobull deg-
lego
sect55 O O I mdash 111 U Q
111 oc
s I
latrade wuj^o OQ r
CD d)ltw
lt
II
J__T
r^zuzo
bull ltn
u-O amp
pound
1 I1gt mshyUJpound
lti
Si
UIZ g UJ CO
i sI ILU
Q
Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
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RK
PLA
NC
UM
BE
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ND
AN
D L
INC
OLN
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HO
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IS
LAN
D
REFERENCES
LIST OF REFERENCES
Goldberg-Zoino amp Associates 1982 LincolnCumberland Wellfield Contamination Study Newton Upper Falls MA prepared for USEPA and JRB Associates Inc March 1982
Johnston HE and DC Dickerman 1974 Geologic and Hydrogeologic Data for the Blacktone River Area Rhode Island Rhode Island Water Resources Board Hydrologic Bulletin No 7 1974b
Malcolm-Pirnie 1983 Investigation of Volatile Organic Chemical Groundwater Contamination PetersonPuritan Inc Cumberland Rhode Island June 1983
Malcolm-Pirnie 1984 Recovery Well Program PetersonPuritan Inc Cumberland Rhode Island January 1984
US Environmental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA Interim Final EPA540G-89004 October 1988
USEPA 1990 National Oil and Hazardous Substances Pollution Contingency Plan Code of Federal Regulations Title 40 Part 300 March 8 1990 Final Rule Federal Register Vol 55 No 46 pp 8666 et seq
USEPA 1991 Draft RIFS Statement of Work USEPA Region I 1991
Versar 1989 Draft Blackstone Valley-PetersonPuritan Remedial Investigation Feasibility Study Subtask 2G - Soil Sources Sampling and Analysis Round 2 Springfield VA prepared for PetersonPuritan April 1989
ABB Environmental Services Inc
REMALTSC 5960-24
R-l
SOURCE USGS TOPOGRAPHIC 7J MWUTE SERIES bdquobdquo_-bdquo_bdquo_ PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975
2000 4000
SCALE FEET
Ann FIGURE 1-1 SITE LOCATION ABB Environmental
Mill Services Inc PETERSON PURITAN INC SITE ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN
CUMBERLAND AND LINCOLN RHODE ISLAND
lt ~ UJ Z Q
ui O 55 3 lt
isii O
pound3 E
U- O
DC Ul O
U
bull bull bull
--
ujzo
O- mdashmdash
bull Ill bull
UJ
bullo
cc bull UJGO
1DE
RM
AL
CO
NTA
CT
DE
RM
AL
| C
ON
TAC
T N
OU
S3O
NI
lsect a3
ui i- gtbull ^
1
U sect UI C U 2 S
OC11 jJ _ g
4 s8 ^ i 1 fl Uj3 c
bull
ecu
U)
^ 111 bdquo_
OCCsect
poundS =
V J ^
iltt
j
bull
gt^f s gt UI
SU
RFA
CE
W
AT
ER
SU
RFA
CE
_j - i S gtJ5 0
bullgtbull - ^mdash ^
UI in
gtbull UI i u 2 OC z
ISTO
RIC
SI
FAR
M S
PI
CC til ji01X2 iS
3O lt C ui a5 eOC11 id 1Iiz
X
bullj
1
0 t- pound 8 f
i^
PA
C
PRO
PER
TY
8|
Si 8 K i lsk^ ill
Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
5-J
Ii gt 3 u i CUT I
Si I yK DC
sect^li00 Q-2lt
3 mdash Ill UQ
Y T DC UJ m 2 U
-bullalto So 35
I
a
Ul gti lt ^ a |ffpO
c o
1
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gt8
lti
22 w
E pound o
pound ii If Tplusmn
Si S
Ul CO
2
f CO
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lt= ltsect F 0 5 gt 2 bull2Z a bdquobull deg-
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111 oc
s I
latrade wuj^o OQ r
CD d)ltw
lt
II
J__T
r^zuzo
bull ltn
u-O amp
pound
1 I1gt mshyUJpound
lti
Si
UIZ g UJ CO
i sI ILU
Q
Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
SOURCE USGS TOPOGRAPHIC 7J MWUTE SERIES bdquobdquo_-bdquo_bdquo_ PAWTUCKET RJ-MASS 1949 PHOTOREVISED 1970 AND 1975
2000 4000
SCALE FEET
Ann FIGURE 1-1 SITE LOCATION ABB Environmental
Mill Services Inc PETERSON PURITAN INC SITE ASEA BROWN BOVERI FEASIBILITY STUDY WORK PLAN
CUMBERLAND AND LINCOLN RHODE ISLAND
lt ~ UJ Z Q
ui O 55 3 lt
isii O
pound3 E
U- O
DC Ul O
U
bull bull bull
--
ujzo
O- mdashmdash
bull Ill bull
UJ
bullo
cc bull UJGO
1DE
RM
AL
CO
NTA
CT
DE
RM
AL
| C
ON
TAC
T N
OU
S3O
NI
lsect a3
ui i- gtbull ^
1
U sect UI C U 2 S
OC11 jJ _ g
4 s8 ^ i 1 fl Uj3 c
bull
ecu
U)
^ 111 bdquo_
OCCsect
poundS =
V J ^
iltt
j
bull
gt^f s gt UI
SU
RFA
CE
W
AT
ER
SU
RFA
CE
_j - i S gtJ5 0
bullgtbull - ^mdash ^
UI in
gtbull UI i u 2 OC z
ISTO
RIC
SI
FAR
M S
PI
CC til ji01X2 iS
3O lt C ui a5 eOC11 id 1Iiz
X
bullj
1
0 t- pound 8 f
i^
PA
C
PRO
PER
TY
8|
Si 8 K i lsk^ ill
Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
5-J
Ii gt 3 u i CUT I
Si I yK DC
sect^li00 Q-2lt
3 mdash Ill UQ
Y T DC UJ m 2 U
-bullalto So 35
I
a
Ul gti lt ^ a |ffpO
c o
1
i|m u
ltUJ
gt8
lti
22 w
E pound o
pound ii If Tplusmn
Si S
Ul CO
2
f CO
aF Z
Ul O
Ul 0
I
lt= ltsect F 0 5 gt 2 bull2Z a bdquobull deg-
lego
sect55 O O I mdash 111 U Q
111 oc
s I
latrade wuj^o OQ r
CD d)ltw
lt
II
J__T
r^zuzo
bull ltn
u-O amp
pound
1 I1gt mshyUJpound
lti
Si
UIZ g UJ CO
i sI ILU
Q
Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
lt ~ UJ Z Q
ui O 55 3 lt
isii O
pound3 E
U- O
DC Ul O
U
bull bull bull
--
ujzo
O- mdashmdash
bull Ill bull
UJ
bullo
cc bull UJGO
1DE
RM
AL
CO
NTA
CT
DE
RM
AL
| C
ON
TAC
T N
OU
S3O
NI
lsect a3
ui i- gtbull ^
1
U sect UI C U 2 S
OC11 jJ _ g
4 s8 ^ i 1 fl Uj3 c
bull
ecu
U)
^ 111 bdquo_
OCCsect
poundS =
V J ^
iltt
j
bull
gt^f s gt UI
SU
RFA
CE
W
AT
ER
SU
RFA
CE
_j - i S gtJ5 0
bullgtbull - ^mdash ^
UI in
gtbull UI i u 2 OC z
ISTO
RIC
SI
FAR
M S
PI
CC til ji01X2 iS
3O lt C ui a5 eOC11 id 1Iiz
X
bullj
1
0 t- pound 8 f
i^
PA
C
PRO
PER
TY
8|
Si 8 K i lsk^ ill
Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
5-J
Ii gt 3 u i CUT I
Si I yK DC
sect^li00 Q-2lt
3 mdash Ill UQ
Y T DC UJ m 2 U
-bullalto So 35
I
a
Ul gti lt ^ a |ffpO
c o
1
i|m u
ltUJ
gt8
lti
22 w
E pound o
pound ii If Tplusmn
Si S
Ul CO
2
f CO
aF Z
Ul O
Ul 0
I
lt= ltsect F 0 5 gt 2 bull2Z a bdquobull deg-
lego
sect55 O O I mdash 111 U Q
111 oc
s I
latrade wuj^o OQ r
CD d)ltw
lt
II
J__T
r^zuzo
bull ltn
u-O amp
pound
1 I1gt mshyUJpound
lti
Si
UIZ g UJ CO
i sI ILU
Q
Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
bull bull bull
--
ujzo
O- mdashmdash
bull Ill bull
UJ
bullo
cc bull UJGO
1DE
RM
AL
CO
NTA
CT
DE
RM
AL
| C
ON
TAC
T N
OU
S3O
NI
lsect a3
ui i- gtbull ^
1
U sect UI C U 2 S
OC11 jJ _ g
4 s8 ^ i 1 fl Uj3 c
bull
ecu
U)
^ 111 bdquo_
OCCsect
poundS =
V J ^
iltt
j
bull
gt^f s gt UI
SU
RFA
CE
W
AT
ER
SU
RFA
CE
_j - i S gtJ5 0
bullgtbull - ^mdash ^
UI in
gtbull UI i u 2 OC z
ISTO
RIC
SI
FAR
M S
PI
CC til ji01X2 iS
3O lt C ui a5 eOC11 id 1Iiz
X
bullj
1
0 t- pound 8 f
i^
PA
C
PRO
PER
TY
8|
Si 8 K i lsk^ ill
Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
5-J
Ii gt 3 u i CUT I
Si I yK DC
sect^li00 Q-2lt
3 mdash Ill UQ
Y T DC UJ m 2 U
-bullalto So 35
I
a
Ul gti lt ^ a |ffpO
c o
1
i|m u
ltUJ
gt8
lti
22 w
E pound o
pound ii If Tplusmn
Si S
Ul CO
2
f CO
aF Z
Ul O
Ul 0
I
lt= ltsect F 0 5 gt 2 bull2Z a bdquobull deg-
lego
sect55 O O I mdash 111 U Q
111 oc
s I
latrade wuj^o OQ r
CD d)ltw
lt
II
J__T
r^zuzo
bull ltn
u-O amp
pound
1 I1gt mshyUJpound
lti
Si
UIZ g UJ CO
i sI ILU
Q
Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
Repeat Previous Scoping Steps - Determine New Data Needs - Develop Sampling Strategies
and Analytical Support to Acquire Additional Data
- Amend QAPPFSP HSP and Work Plan as Appropriate
- Repeat Steps in RJ Site Characterization
SOURCE USEPA 1989
Determine Remedial Acscn Objectives Based on Risk Assessment and ARARs
Identification
Develop General Response Actions Describing Areas or Volumes of Media to wnich
Containment Treatment or bull Removal Actions may be Aoolied
Identify Potential Treatment and
Disposal Technologies and Screen Based on
Technical Implementability
Evaluate Process Options Based on Effectiveness Implementabiiity
and Relative Cost to Select a Representative Process for each
Technology Type
YES Reevaiuate Data Needs
Combine Media-Specific Technologies into
Alternatives
Screening of Alternatives
FIGURE 2-1
A ALTERNATIVE DEVELOPMENT PROCESS ABB Environmental PETERSON PURITAN INC SITE Services Inc
FEASIBILITY STUDY WORK PLAN ASEA BROWN BOVERI
CUMBERLAND AND LINCOLN RHODE ISLAND 05960-24
mdash iur o
UJ
5-J
Ii gt 3 u i CUT I
Si I yK DC
sect^li00 Q-2lt
3 mdash Ill UQ
Y T DC UJ m 2 U
-bullalto So 35
I
a
Ul gti lt ^ a |ffpO
c o
1
i|m u
ltUJ
gt8
lti
22 w
E pound o
pound ii If Tplusmn
Si S
Ul CO
2
f CO
aF Z
Ul O
Ul 0
I
lt= ltsect F 0 5 gt 2 bull2Z a bdquobull deg-
lego
sect55 O O I mdash 111 U Q
111 oc
s I
latrade wuj^o OQ r
CD d)ltw
lt
II
J__T
r^zuzo
bull ltn
u-O amp
pound
1 I1gt mshyUJpound
lti
Si
UIZ g UJ CO
i sI ILU
Q
Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
mdash iur o
UJ
5-J
Ii gt 3 u i CUT I
Si I yK DC
sect^li00 Q-2lt
3 mdash Ill UQ
Y T DC UJ m 2 U
-bullalto So 35
I
a
Ul gti lt ^ a |ffpO
c o
1
i|m u
ltUJ
gt8
lti
22 w
E pound o
pound ii If Tplusmn
Si S
Ul CO
2
f CO
aF Z
Ul O
Ul 0
I
lt= ltsect F 0 5 gt 2 bull2Z a bdquobull deg-
lego
sect55 O O I mdash 111 U Q
111 oc
s I
latrade wuj^o OQ r
CD d)ltw
lt
II
J__T
r^zuzo
bull ltn
u-O amp
pound
1 I1gt mshyUJpound
lti
Si
UIZ g UJ CO
i sI ILU
Q
Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
22 w
E pound o
pound ii If Tplusmn
Si S
Ul CO
2
f CO
aF Z
Ul O
Ul 0
I
lt= ltsect F 0 5 gt 2 bull2Z a bdquobull deg-
lego
sect55 O O I mdash 111 U Q
111 oc
s I
latrade wuj^o OQ r
CD d)ltw
lt
II
J__T
r^zuzo
bull ltn
u-O amp
pound
1 I1gt mshyUJpound
lti
Si
UIZ g UJ CO
i sI ILU
Q
Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
J__T
r^zuzo
bull ltn
u-O amp
pound
1 I1gt mshyUJpound
lti
Si
UIZ g UJ CO
i sI ILU
Q
Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
Si
UIZ g UJ CO
i sI ILU
Q
Oa l II Qs 2I I gQ
TTTT
ui UJ oc UJ shyCD I
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
ARABS
N ROUSE
INTERNATIONAL
PROJECT MAKASER
P EXNER PE
PS LEADER
D HEISLEIN
RISK ASSESSMENT
J SULLIVAN
CORPORATE OFFICER
D ERTZ P E
QUALITY ASSURANCE
E COOL Ph D
PROJECT REVIEW COMMITTEE
W MURRAY Ph 0 D PIERCE PG D TUTTLE PE
ENVIRONMENTAL ENGINEERING
D BELCHER
FIGURE 3-1
AI PROJECT ORGANIZATION ABB Environmental PETERSON PURITAN INC SITE Services Inc
ASEA BROWN BOVEH FEASIBILITY STUDY WORK PLAN CUMBERLAND AND LINCOLN RHODE ISLAND
05960-24
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
AC
TIV
ITY
DE
VE
LOP
ME
NT
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
SC
RE
EN
ING
OF
R
EM
ED
IAL
ALT
ER
NA
TIV
ES
DE
TA
ILE
D E
VA
LUA
TIO
N O
F
RE
ME
DIA
L A
LTE
RN
AT
IVE
S
uraquo N
r-
IA
XI
in
B ~
-
eo
i
laquo ~
in
5 _
in
ft ~ -1
^ 1
in s ~
s ~
ugt
^
SC
RE
EN
ING
OF
RE
ME
DIA
L A
LTE
RN
AT
IVE
S D
ELI
VE
RA
BLE
(3
159
3)
pound
RE
GU
LAT
OR
Y C
OM
ME
NTS
RE
CE
IVE
D
|
CO
MM
EN
T R
ES
PO
NS
E P
AC
KA
GE
DE
LIV
ER
AB
LE
^
DR
AF
T F
S D
ELI
VE
RA
BLE
(6
219
3)
A
RE
VIS
ED
FS
DE
LIV
ER
AB
LE (
726
93)
FIG
UR
E 3
-2
A IIII
AB
B E
nviro
nmen
tal
FS S
CHED
ULE
FOR
OU I
M
ill
Ser
vice
s Inc
PE
TERS
ON
PURI
TAN
INC
SIT
E AS
EA BR
OWN B
OVEII
F
EA
SIB
ILIT
Y S
TU
DY
WO
RK
PLA
NC
UM
BE
RLA
ND
AN
D L
INC
OLN
R
HO
DE
IS
LAN
D
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