PERFORMANCE OF REMEDIAL RESPONSE U.S. EPA … · PERFORMANCE OF REMEDIAL RESPONSE ... 2.2.2...

V w •»*

PERFORMANCE OF REMEDIAL RESPONSEACTIVITIES AT UNCONTROLLED HAZARDOUS

WASTE SITES (R£M II)

U.S. EPA CONTRACT NO.: 68-01-6939

WORK PLANFOR

PRISTINE, INC. SITE READING, OHIO

VOLUME 1

DOCUMENT NO.: 115-WP1-WP-ALKW-2

WORK ASSiaWENT NO.: 15-5L56.0

PREPARED BY:

ROY F. WESTON, INC.Bannockburn, Illinois

EPA Region 6 Records Ctr.

09

223793

TABLE OF CONTENTS

ITEM PAGE

TOLCME I

1.0 Introduction 1

1.1 Background 11.2 Objectives 9

2.0 Technical Approach 10

2.1 Introduction 102.2 Remedial Investigation 11

2.2.1 Work Plan Memorandum Activities 11

Site Definition 11Project Plans ' 11Work Plan 12

2.2.2 Detailed Site Characterization Studies 13

Mobilization 13Identify Preliminary Remedial Options 14Field Program 14Tecnnical Memoranda 27

2.2.3 Site Evaluation 27

Site Investigation Summary 31Risk Assesment 31

2.2.4 Remedial Investigation Report 36

Draft RI Report 36Review Meeting 37

2.3 Feasibility Study 37

2.3.1 Development of Alternatives 38

Development of Remedial Response Objectives 38Identification of Remedial Technologies 38Identification and Development of Remedial Alternatives 39

TABLE OF CONTENTS

ITEM

2.3.2 Initial Screening of Alternatives 39

Implsnentability and Reliability 39Environmental Protection 39Cost 40Technical Memorandum 41

2.3.3 Laboratory Studies 412.3.4 Detailed Analysis of Alternatives 42

Detailed Description and Analysis of Remaining Alternatives 42Environmental Assessment 44Public Health Analysis 44Detailed Cost Estimation 45

2.3.5 Evaluation and Selection cf Cost-Effactive Alternative 452.3.6 Draft Feasibility Study Report 462.3.7 Conceptual Design 472.3.8 Revised Report 49

2.4 Ccrttnunity Relations Support 492.5 Project Administration 50

3.0 Schedule and Deliverables 53

4.0 Project Team 58

VOLUME II

1.0 Introduction

2.0 Form 60s

3.0 Spreadsheets

3.1 RI Labor by Firm3.2 RI Expenses3.3 RI Other Direct Costs3.4 FS Labor by Firm3.5 FS Expenses3.6 FS Other Direct Costs

4.0 Cost Tables for Work Plan Phase

LIST OF TABLES

TABLE PAGE

1 Summary of Sampling Effort 152 Surrmary of Sampling and Analysis Program 163 Key to Symbols used in Quality Control Plan 57

LIST OF FIGURES

FIGURE PAGE

1 Location Map 22 Vicinity Map 33 Site Map 44 Site Conditions October-November 1980 55 Site Conditions March-April 1982 66 Site Conditions May-July 1984 77 Stormwater Sample Locations 208 Surface Water Sample Locations 219 Sediment Sample Locations 2310 water Supply Sample Locations 2411 Soil Sample Locations 2512 Monitoring Well and Groundwater Sample Locations 2613 Construction Details Three-Well Nest 2814 Construction Details Two-Well Nest 2915 Construction Details Single-Well Installation 3016 Estimated Project Schedule 5417 Schedule of Deliuerables 5618 Project Organization Chart 59

LIST OF APPENDICES

Professional Profiles

111

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALKW-2March 1, 1985Page No:l

SECTION 1

INTRODUCTION

1.1 BACKGROUND

The Pristine, Inc. site occupies approximately five acres in thenortheast quarter of Section 33, Township 4, Range 1 in the City ofReading, Hamilton County, Ohio (Figures 1 and 2). The site isbordered by industrial and residential areas (Figure 3). The landnorth of the site is owned by the City of Reading. Three municipalwater supply wells, which are about 300 feet from the northwesterncorner of the site, are located on this property. Industrialfacilities operated by Cincinnati Drum Service and Carstab Corporationare located west and south, respectively, of the Pristine, Inc. site.Cincinnati Drum Service cleans, reclaims and recycles steel drums.Carstab Corporation manufact-ores synthetic stabilizers andplasticizers. The Conrail railroad runs along the eastern side of thesite. On the other side of the tracks is an industrial facilityinvolved in grain-handling to the east and southeast and a trailerpark to the northeast. The site may be reached only from the westthrough the Cincinnati Dram Service property because access to thesite is restricted on the north, east and south by chain-link fencing.

The Pristine, Inc. site is situated over the buried valley of the DeepStage Cincinnati River, a glacial-aged river fed by meltwater thateroded several hundred feet into shale and limestone bedrock. Outwashand other glacially derived sediments, which are 150 to 180 feetthick in the vicinity of the site, were subsequently deposited in thisvalley. The Pristine, Inc. site is situated on a low terrace that isabout 10 feet higher than the active floodplain of Mill Creek, whichnow drains the valley. The scarp of this terrace coincides with thewestern edge of the site; thus, the City of Reading well field and theCincinnati Drum Service facility are both on the floodplain. Runofffrom the Pristine, Inc. site reaches Mill Creek by way of two ditches,~2 each along the northern and southern sides of the Cincinnati DrumService property.

At one time, as many as 8,000 to 10,000 drums and several hundredthousand gallons of bulk liquids were stored on the Pristine, Inc.site (Figures 3, 4,and 5). The wastes stored on-site werepredominantly solvents and acids. The solvents and other organics —including pesticides — were incinerated, and the acids were

Source RAMP prepared ay CH2M HILL November 1983

FIGURE 1 SITE LOCATION MAP, PRISTINE INC.

« I

•'V'TTJ • • • * - " * R''--\ /i 4»i"I-"v^^. i - • «u,..: i..'- -.* t

AHI ^V^HV j-' "•/-tea^=1 ^' LUCK LAN li ;iYJ«A..-.rr. 1A ?

-i*1 ».!-'• r- •- il ' " X\ .

I I Ilino oi i i i i i

nimi

4imoi

Fiom USGS To|>ogra|>hic Map. 1'fi Minnie Series. Cincinnati East Quadi angle

FIGURE 2 VICINITY MAP, PRISTINE INC.

Cincinnati DrumService. Inc.

' Approximate Site- Boundaries

MunicipalWellField

MunicipalFly-AshDisposal

Grain FacilitiesTrailer Park

FIGURE 3 SITE MAP, PRISTINE, INC.

Mj(i A«»c>>«IIOOI»Of PA kwnutl.om lum Wmilot

S«.hwa<kji0i D.iMfOOLlolMli b. I'JWWaste InventoryDrums: 4615Tanks: 154.479 Gallons (Documented)h "."(> by K*n 11.11 Hi. (»>«) E MA

()(.kAM.M II4HI

FIGURE 4 SITE CONDITIONS, PRISTINE, INC. READING, OH OCTOBER-NOVEMBER, 1980

o ; 0 ( •- - . . . - j — f . T . . ,576. 2X ( _ ,

1 1 1 1 1 1 1 1-

-1 o o

?S7S;8 ..-'"" " "" 'i r — <._;. » . ,c—

575. 7 X _!:."•> 0

• -

-—*—-: ^^ „ J^c/ ° J "

~ =T• I • • • • » 1 1 1 « H' '

U*.'.lU.ii.h^ I'Jfl?

IIHlltii i Hytn 'j

Waste InventoryDrums: 870Tanks: 18 7.000 GallonsBulk: 300 Drum Equivalents (In Dumpsters)

FIGURE 5 SITE CONDITIONS, PRISTINE, INC. READING, OH MARCH-APRIL, 1982

576.2X ( , ' A

Slii.-lihM.lpUyU.liy If sun II Si IT*l>.milM.ii I'JM Alt.iiltiilKi

M<M>M»ly ll.M kuwj Ih prat

Waste InventoryDrums: 0Tanks: Emptied and CleanedSoil Removed: 420 to 525 Cubic Yards

FIGURE 6 SITE CONDITIONS, PRISTINE, INC. READING, OH MAY-JULY, 1984

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALKW-2March 1, 1985Page No:8

neutralized. Through various removal actions by the responsibleparties and the U.S. EPA, the drummed wastes have been removed. Thebulk storage tanks have been emptied and decontaminated; however, saneof the tanks and pits have partially refilled with precipitation.Only a small part of the process structures left from former siteactivities (sulfuric acid manufacture) were used for incineration byPristine, Inc. Chunks of crystalline sulfur have been observed atmany locations throughout the site. The surficial soils were noted tobe somewhat sandier than anticipated from the boring logs. Much ofthe site is unvegetated and shows evidence of the recent soil removalactivities (May through July 1984). A concrete pad is present in thearea north of the buildings which used to be the mixing area. The padis uneven and pitted and contains numerous cracks.

The stormwater collection pit, which was over-excavated to removecontaminated soil, has not yet been re-lined and contains snail poolsof water. The sides of the pit are wet, suggesting a small amount ofseepage. The stormwater collection trench can be identified in thefield; and a small trickle has been observed at the outfall to thepit.

A considerable amount of ponded water is present in the former mixingarea. This water is discolored, and is flowing across the collectiontrench and access road and then down the embankment at the westernedge of the site.

Based on descriptions of former waste activities, the following areashave been identified as likely to contain residual soil contamination:

o Immediately south of the stormwater collection pit andrelatively close to the access road (pesticides).

o Further south of the pit but north of a wooden utility pole,between the road and the rail spur (solvents and otherhazardous organic chemicals).

o The former mixing area and adjacent storage, all underlain bya concrete pad and situated south of a defunct tank trailerand north of the buildings (solvents and other flammable andhazardous materials).

o The building and tank complex in the south-central part ofthe site (solvents, organic chemicals PCB's, and acids).

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALKW-2March 1, 1985Page No:9

o South of the building and tank complex, north of the twolarge bulk storage tanks and near the access road (solventsand acids).

o Southeast corner of the site (possible burial of dumped bulkliquids of unknown characteristics).

1.2 OBJECTIVES

The purpose of the Remedial Investigation/Feasibility Study (RI/FS) isto evaluate the potential extent and magnitude of on-sitecontamination and, if appropriate based upon this RI, recommend a costeffective, viable, remedial action alternative for mitigating thehazard posed by the contamination. The objectives of the RI/FS are:

o Determine if the Pristine site poses a risk to health or theenvironment.

o Determine the characteristics, extent and magnitude ofcontamination remaining on the site.

o Define the pathways of contaminant migration from the site.

o Define on-site physical features and facilities that couldaffect contaminant migration, containment, or cleanup.

o Develop viable remedial action alternatives.

o Evaluate and screen remedial action alternatives.

o Reccmmend the most cost-effective remedial actionalternatives which adequately protects health, welfare andthe environment.

o Prepare a conceptual design of the recommended alternative.

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALKW-2March 1, 1984Page No: 10

SECTION 2

TECHNICAL APPROACH

2.1 INTRODUCTION

The Pristine, Inc. Work Assignment (WA No: 15-5L56.0) identified thefollowing tasks for the RI/PS:

o Task 1 — Preparation of Work Plan

c Task 2 —' Site Definition

o Task 3 — Detailed Site Characterization Studies

o Task 4 — Site Evaluation

o Task 5 — Remedial Investigations Report

o Task 6 — Reporting Requirements

o Task 7 — Development of Alternatives •

o Task 8 — Initial Screening of Alternatives

o Task 9 — Laboratory Studies (Optional)

o Task 10 — Detailed Analysis of Alternatives

o Task 11 — Evaluation and Selection of Cost-Effective Alternatives

o Task 12 — Conceptual Design

o Task ,13 — Final Report

o Task 14 — Community Relations

For the purpose of presenting the technical approach to the RI/FS,these tasks have been organized as follows:

o Remedial Investigation - includes Tasks 1through 5.

o Feasibility Study - includes Tasks 7 through 13.

o Ccmmunity Relations - Task 14.

o Project Administration - Task 6.


2.2 REMEDIAL INVESTIGATION

The activities included in Tasks 1 and 2, as defined by the workassignment, are being performed under an interim authorization asdescribed in the Work Plan Memorandum (Document No. 115-WP1-W-AJLA-1). These activities, which have been integrated into thedevelopment of this work plan, are briefly reviewed below. Based ondiscussions between the REM II site team and the U.S. EPA siteofficer, the scope and objectives of Task 3, the detailed sitecharacterization studies, have changed somewhat from those presentedin the work assignment. No changes were made in the scope of Tasks 4or 5.

2.2.1 Work Plan Memorandum Activities

The REM II approach to preparation of a work plan results in areorganization of the initial WA tasks. Basically, the sitedefinition activities (which include compiling, reviewing andevaluating existing data, and preparation of health and safety plansand quality assurance plans) are performed prior to preparation of thework plan. Thus, the work plan is prepared with a better knowledge ofsite conditions and fewer modifications should be needed as workproceeds.

Site Definition

Existing available information concerning the Pristine, Inc. site wasgathered, reviewed and evaluated. An Existing Conditions Memorandumand a set of Compiled Site Plans were prepared to summarize thefindings of this activity.

The Existing Conditions Memorandum included a review of the sitesetting; a summary of a site visit on October 9, 1984; an up-datedchronology covering waste treatment, storage and disposal operations,and remedial response activities; summaries of environmental studiesand sampling events; and a discussion of available data and data gaps.

The Compiled Site Plans consisted of three overlays to be used inconjunction with the existing topographic base map. The overlays weredeveloped from field sketch maps prepared by various state and federalagency personnel; and as indicated on Figures 4, 5 and 6, they showsite conditions for the periods October-November 1980, March-April1982, and May-July 1984. Waste inventory information is included onthe overlays.

Project Plans

The project plans address specific issues of project execution thatrequire more detailed treatment than the scope of a typical work planwould include. The following six plans, having individual scopes asdescribed below, have been or are being prepared. The final Project


Plans will be prepared incorporating these individual plans afterGarments have been received from U.S. EPA and Ohio EPA.

o Health and Safety Plan - prepared on a Site Evaluation Form(SEF); covers personal protective equipment needed dependingon location and activity within the site, contingency plansand emergency procedures, field monitoring equipment, anddecontamination procedures.

o Quality Assurance Project Plan - covers QA data measurementobjectives, sampling objectives and procedures, samplecustody, calibration procedures, interval QC checks, QAperformance audits, QA reports, preventive maintenance, dataassessment procedures, corrective action, and fieldprotocols.

o Sampling and Analysis Plan - covers data collectionobjectives, sample locations, sample numbering, samplingequipment and procedures, sample analysis and handling,sample docjmentation and tracking, sampling teamorganization, and sampling schedule. This is a document tobe used in the field, as well as in project planning.

o Site Management Plan - covers project operations at the siteincluding site access and security, site office anddecontamination facilities, equipment and materials needs andstorage, conmunications and support functions, andcoordination of sampling activities.

o Data Management Plan - covers office procedures forcollecting and organizing site investigative data and forcontrolling its availability, use and distribution.

o Quality Control Plan - covers REM II review procedures forall deliverables. It can not be finalized until U.S. EPAapproval of the work plan and notice is given to proceed withthe project.

work Plan

This work plan presents the site background, the technical approach tosite investigation and feasibility study activities, schedule forproject execution, budget estimate, and project staffing forconducting an RI/FS at the Pristine, Inc. site in Reading, Ohio. Adraft work plan will be submitted for U.S. EPA and Ohio EPA review.After completion of the review, the REM II site team will meet withthe agencies to discuss the draft document. Review comments will beincorporated in a final work plan document, which will be submittedwithin 10 working days following receipt of written agency comments.Copies of all subcontract agreements will be forwarded to the U.S. EPAsite officer for information purposes.


2.2.2 Detailed Site Characterization Studies

The work assignment provides for investigative sampling and analysisof stormwater, surface water, sediment, water supply wells, soils andgroundwater; and for a hydrogeologic study. As indicated above, thescope of these studies has been modified slightly (by mutual agreementbetween U.S. EPA and ourselves) from that proposed in the work .assignment. Instead of determining the areal extent and magnitude ofoff-site contaminant migration from the site, the detailed studieswill characterize the amount and nature of contamination currentlymigrating across the site boundaries along various migration pathways.This change was made because the down gradient, off-site areas —namely Cincinnati Drum Service property and Mill Creek — are likelyto contain contamination from sources other than Pristine, Inc.Characterizing other potential sources, so that the relativecontribution of Pristine, Inc. to the total contaminant load in theseareas could be identified, was felt to be outside the scope of thisRI/FS.

The scope of the hydrogeologic study was expanded to include theinstallation of a greater number of monitoring wells. The workassignment had indicated that at least four additional wells beinstalled on the assumption that three wells installed by FIT in 1981were still useable. These wells have been destroyed/abandoned. Inaddition, the review of the existing hydrogeologic data brought tolight seme discrepancies in earlier interpretations of on- andoff-site soil stratigraphy and in the definition of hydrostratigraphicunits. The need to characterize three rather than twohydrostratigraphic units, and the need to determine the relationshipof on-site soil stratigraphy (remnant terrace deposits) to off-sitesoil stratigraphy (active floodplain deposits) necessitated expansionof the scope to at least twelve new wells. The fact that the longdimension of the site, which contains potential pollutant sourcesthroughout, is perpendicular to the direction of groundwater flownecessitated a further expansion of the scope to a total of eighteennew monitoring wells.

Mobilization

Prior to initiating the detailed site characterization studies, itwill be necessary to establish field support facilities; procuresubcontractor services; and identify, obtain and mobilize equipmentand materials. As indicated above, a detailed description of thesefacilities and the required equipment and materials is presented inthe Site Management Plan, which is included in the Project OperationsPlan. The facilities to be established include an office trailer withsecured storage areas for samples and equipment and a telephone; asheltered equipment decontamination area; a lined, gravel washdownpad, which drains to the existing stormwater collection pond, fordecontamination of the drilling rig; and a fenced, materials storage


area. The fenced area will also be used for temporary storage ofwastes generated during the RI field work. Equipment and materialneeds include sampling equipment, decontamination supplies, samplebottles, shipping supplies, disposable personnel protective equipment,field instruments, well construction materials, drums for temporary RIwaste storage ana documentation supplies. The drilling rig andbackhoe would be mobilized the first day needed.

Identify Preliadnary Remedial Options

An initial evaluation of preliminary remedial options suitable for thesite will be made at the earliest possible point in the RI process.This will obviously be done in broad terms, but is consideredessential to insure that the field program addresses those areas thatcould be included in the remedial program.

Field Program

The field program for the detailed characterization studiesencompasses the sampling of stormwater, surface water, sediment, watersupplies, soil, and groundwater. A total of 179 samples will becollected for chemical and geotechnical analysis. The sampling effortis presented in Table 1, and the sampling and analysis program issunmarized in Table 2.

Eighteen monitoring wells will be installed in soil borings sampled atclose intervals to define the soil stratigraphy and hydrogeologicconditions at the site. As indicated above, a detailed description ofthe sampling and field investigation activities is presented in theSampling and Analysis Plan, which is included in the Project Plans.The objectives and scope of the various components of the fieldprogram are summarized below:

o Sampling and analysis of stormwater:

To determine if stormwater on or migrating from the siteis contaminated.

One round of three samples each (plus QA samples) atlocations shown in Figure 7.

o Sampling and analysis of surface water:

To determine if surface water on or migrating fron thesite is contaminated.

One round of four samples each (plus QA samples) atlocations shown in Figure 3.

Pristine, Inc.Work PlanDocunentNo.: 115-WPI-WP-ALKW-2February 21, 1985Page No: 15

TABLE 1

SUMMARY OF SAMPLING EFFORT

L

L

Type Investigative Duplicate

Stormwater (SR)

Surface Water (SF) unfilteredfiltered

Sediment (SD)

Water Supply (WS) III

Soil Areas (SA)

Soil Borings (SB)

Soil Trench (ST)

Groundwater (GVi) I filteredI unfilteredII filteredII unfiltered

SubtotalsSolidLiquid

Subtotal

Chemical Subtotal

Geotechnial*

Gectechnical Subtotal

Grand Total

3

42

7

88

14.

30

4

183183

5567

122

155

21

24

179

1

11

1

11

' 2

3

1

2121

711

18

3

Blank

1

1-

1

11

2

3

1

2-2-

78

15

-

•Samples for geotechnical testing collected during monitoringwell installation.

ANALYSIS PRDQttM

InvestigativeSamples

No. Freq. Total

3 1 3

3 1 3

3 1 3

3 1 3

4 1 4

4 1 4

2 1 2

4 1 4

4 1 4

•

QA San?Duplicate

_No. Freq. Total

1 1 1

1 1 1

1 1 1

1 1 1

1 1 1

1 1 1

1 1 1

1 1 1

1 1 1

Pristine, Inc.Work PlanDocunentNo.: 115-WPI-WP-ALKW-2March 1, 1985Page No: 16

BlankNo. Freq. Total

1 1 1

1 1 1

1 1 1

1 1 1

1 1 1

1

1

1

1

1

1

Matrix Total

5

5

5

5

6

6

3

6

6

7

7

7

1

1

1

7

7

7

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

9

9

9

Sanple Matrix

Water Supplies

Field Parameters

PH

Specific conductance

Taiperature

TABLE 2 (cor

SIMARY OF SAMPLING A>

Laboratory Parameters

Acid extractables and base/neutralextractables fron CRL

Pesticides and PCBs frcn CRL

Volatile organics from CKL

Metals from CRL - unfiltered samples

Cyanide frcn CRL - unfiltered samples

Minerals from CRL (acidity, alkalinity,chloride, fluoride, sulfate)

Nutrients from CRL (ammonia , TWJ,nitrate-nitrite, TOC, phosphorous)

Soil-Areas Not applicable RAS organics package from CLP including30 tentatively identified parameters

RAS inorganics package/metals from CLP

RAS inorganics package/cyanide from CLP

SAS for fluoride

Note: Field parameters will be determined for investigative and duplicate samples only.

a*\

Pristine, Inc.Work Plan

M] DooiKitNo.: 115-WPI-WP-ALKW-2

t^LYSIS FJCGAM

InvestigativeSanples

to. Fredj. Total

8 2 16

8 2 16

8 2 16

8 2 16

8 2 16

8 2 16

8 2 16

14 1 14

14 1 14

^14 1 14

14 1 14

March 1, 1985Page No: 17

4

Oft SanplesDuplicate Blank

No. IFreq. Total No. Freg. Total

1 2 2 1 2 2

1 2 2 1 2 2

1 2 2 1 2 2

1 2 2 1 2 2

1 2 2 1 2 2

1 2 2 1 2 2

1 2 2 1 2 2

2 1 2 2 1 2

2 1 2 2 1 2

2 1 2 2 1 2

2 1 2 2 1 2

Matrix Total

20

20

20

20

20

20

20

18

18

18

18

TABLE 2 (coi

SUtPJRY OF SAMPLING A

Sample Matrix

Soil-Borings

Field Parameters

Qualitative organicvapor screeningwith CVA and HNu

T aboratory Parameters

RAS organics package from CLP including30 tentatively identified parameters

RAS inorganics package/metals from CLP

RAS inorganics package/cyanide fron CLP

SAS for fluoride

pH from field laboratory

Soil-Trench Qualitative organicvapor screeningwith CVA and HNu


RAS inorganics package /metals from CLP

RAS inorganics package/cyanide from CLP

round-water PH

Specific conductance

Temperature


RAS inorganics package/metals from CLPfiltered samples

RAS inorganics package/metals & SAS forsuspended solids - unfiltared samples

RAS inorganics package /cyanide from CLPfiltered samples

SAS for fluoride - filtered samples

-te: Field parameters will be determined for investigative and duplicate samples only.

jiued)

IS PROGRAM

;igat>les•ec.

1

1

1

1

1

1

1

1

2

2

2

2

2

:ive

Total

30

30

30

30

30

4

4

4

36

36

6

36

36

DuplicateNo. Free.

3

3

3

3

3

1

1

1

2

2

1

2

2

1

1

1

1

1

1

1

1

2

2

2

2

2


t

QA SamplesBlank

Total No. Free. Total

3 3 1 3

3 3 1 3

3 3 1 3

3 3 1 3

3 3 1 3

1 1 1 1

1 1 1 1

1 1 1 1

4 2 2 4

4 ' 2 2 4

2 . . .

4 2 2 4

4 2 2 4

Matix Total

36

36

36

36

36

6

6

6

44

44

8

44

44

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Pristine, Inc.Work Plan

jiued) Document No.: H5-WPI-WP-ALKW-2March 1, 1985Page No: 19

ANALYSIS PROGWM

nvestigative Qft SamplesSamples . Duplicate BlankFreq. Total No. Freq. Total No. Freq. Total Matrix Total

1 9 1 1 1 - • - - • 1 0

1 6 1 1 1 - _ _ 7

1 6 1 1 1 . . . 7

w/.

.

»»-|:'.t ' l£ V

/11 /i .-'-.. '/ ""•/•/ jn ^ r\f-\r mit

• """

FIGURE 7 STORMWATER SAMPLE LOCATIONS, PRISTINE INC.

i ;

n ?> 7• 'l I • " •'•

/

\

//

/ /./

\ .

i /-~'.^;,K •'* ''"K 1

'& !.

no 4;

I ")• ':"•' »v«- -J f / A ^

(r ! ,i

/ 7 -"' #r.'c/^-- ./'/I f iC\ ' . ••': ./I, ^ ;' '

-•SF05:\ j • i i .l-.l

J lF04l

'

V. •

FIGURE 8 SURFACE WATER SAMPLE LOCATIONS, PRISTINE INC.

,*'~/^HF^^ -fi-i "*,T /SI v'^/ . /;/ i te"l'^x^~^-^^ .yv* ' - ' ' - ^ v</2^j . /••»*'• iL""";:- " "v<v -isr-i.'/ . / m m ^«^ ,• * 4U. • ;.f ! / . • ! _ * • . ../.'."if i^ :„...•.... •"•

.

.. -.*.:-?*:•»/:•.. "' —~-U«• "":;.'' ' '^""'S;:;: /if'

FIGURE 10 WATER SUPPLY SAMPLE LOCATIONS, PRISTINE INC.

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALRW-2March 1, 1984Page do: 22

o Sampling and analysis of sediment:

To determine if sediment on or migrating from the site iscontaminated.

Seven samples each (plus QA samples) at locations shownin Figure 9.

o Sampling and analysis of water supply wells:

To determine if groundwater currently being pumped bymunicipal or industrial water supply wells in theimmediate vicinity is contaminated with prioritypollutants.

Two rounds of 8 samples each (plus QA samples) atlocations shown in Figure 10. All water supply wellssamples will be directed to the U.S. EPA Regional VCentral Regional Laboratory for analysis.

o Sampling and analysis of soil:

To determine the presence, character and extent ofresidual contamination in the near-surface soils on site.

Fourteen composite samples of near-surface soils, 30samples from six soil borings, and four samples from atest trench (plus QA samples) at locations shown inFigure 11.

o Sampling and analysis of groundwater:

To determine the presence, character and magnitude ofgroundwater contamination in the soils overlying thewell-defined, gray, silty clay layer, both on-site and inimmediately adjacent, downgradient, off-site areas.

Two rounds of 18 samples each (plus QA samples) atlocations shown in Figure 12.

o Hydrogeologic study:

To evaluate the details of on-site soil stratigraphy andits relationship to soil stratigraphy in immediatelyadjacent, downgradient, off-site areas.

To determine the position and configuration of thewater table on-site and in immediately adjacent,downgradient, off-site areas.

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" Mi i/ ':

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To evaluate the hydrogeologic conditions within the soilsoverlying a well-defined, gray, silty clay layer (i.e.,the upper 25 to 30 feet of soil), including the presenceand rate of vertical as well as horizontal groundwaterflow, both on site and in iirroediately adjacent,downgradient, off-site areas.

To determine potenticroetric heads, groundwater flow, andgroundwater quality at the top of the aquifer utilizedfor water supply.

Installation of the 18 wells shown in Figure 12, asdetailed in Figures 13 through 15, using cable-tooldrilling methods with casing.

Technical Memoranda

Technical memoranda will be prepared upon completion of the field workto document actual activities and present the findings. Memorandawill be prepared for the following subjects: •

o Sampling and analysis of stormwater; surface water andsediment; identification of on-site contaminant levels;elevation of off-site contaminant migration.

o Sampling and analysis of shallow on-site soils;identification of on-site contaminant levels including araalextent and depth; evaluation of contaminant mobility andattenuation.

o Sampling and analysis of water supply wells and groundwater;identification of contaminant levels in all threehydrostratigraphic units investigated both on- and off-site;evaluation of potential contaminant migration across the siteboundary and into the water supply aquifer.

o Hydrogeologic conditions in the study area; identificationand characterization of soil stratigraphy and arealrelationships of soil deposits; identification andcharacterization of hydrostratigraphic units and arealrelationships; evaluation of groundwater flow systems, flowdirections, flow rates and recharge-discharge distribution.

2.2.3 Site Evaluation

The objectire of this task is to ensure that the investigation dataare sufficient in quality and quantity to support the feasibilitystudy and to determine whether or not the surface water runoff,groundwater, or contaminated soil at the site present an existing orfuture hazard to human health or welfare, or to the environment.

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FIGURE 13 CONSTRUCTION DETAILS THREE-WELL NEST

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FIGURE 14 CONSTRUCTION DETAILS TWO-WELL NEST

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FIGURE 15 CONSTRUCTION DETAILS SINGLE-WELL INSTALLATION

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALKW-2March 1, 1984Page So: 31

Site Investigation Surmiary

The existing technical memoranda will be consolidated and merged intoa comprehensive technical memorandum covering all site investigationsand their results. This memorandum will form a substantial part ofthe draft RI report. The memorandum will be reviewed by the membersof the project team that have responsibility for the FS to assess thesufficiency of the data base.

Risk Assessment

The comprehensive technical memorandum will serve as the basis forassessing the risk potential of the site. In close coordinationwiththe U.S. EPA, this assessment will consider the existing siteconditions relative to the extent and severity of impacts to thepublic health, welfare or the environment from releases or potentialreleases of hazardous substances. Both existing environmentalstandards and toxicological risks will be considered in theassessment. A risk assessment memorandum, capable of standing as anindependent document, will be prepared to summarize the assessmentprocedures and its findings. This memorandum will also be included inthe draft RI report.

Specifically, the contractor shall perform an environmental riskassessment based on the results of the site investigation analysis andthe initial characterization of the type and extent of thecontaminants found at the Pristine, Inc. site. The assessment willalso be based on the characterization of current migration ofcontaminants across the site boundary via various migration pathways(see Section 2.2.2). The use of modeling should be considered inevaluating exposure to potential receptors.

This assessment shall be performed consistent with current (draft)U.S. EPA policy and current (draft) U.S. EPA guidance documents on theconduct of risk assessments. It will be designed and performed toconstitute the Public Health and Environmental Analysis of the"No-Action" alternative. As a minimum it will include the followingsubtasks:

o Select chemicals for hazard assessment.

o Select exposure pathways for detailed assessment.

o Assess human exposure.

o Assess toxicity.

o Assess risks to human populations.


o Assess environmental impacts,

o Assess welfare impacts,

o Assess risk.

c Draft Risk Assessment Memorandum.

Select Chemicals for Hazard Assessment

After the wastes and contaminants found at the site have beencharacterized in the site investigation analysis, a subset ofchemicals shall be selected for detailed study based on an initialassessment of their relative likelihood to give rise tosignificantrisks to potential receptors. This selection shall bebased on the relative toxicity, persistence, mobility andconcentration of each chemical detected at the site. Other factorsthat may give rise to hazards, such as volatility, flamnability,corrosivity, bioconcentration, and exotoxicity will also be consideredin this selection process. The number of chemicals chosen shall besomewhat dependent on the number of contaminants found at the sits. Aproposed list of chemicals for detailed assessment shall be preparedand presented in a briefing to U.S. EPA for approval prior toproceeding with the toxicity assessment described below.

Select Exposure Pathways for Detailed Assessment

Simultaneously with the above selection of chemicals, an initialcharacterization shall be performed of possible pathways of exposureto chemicals from the site, and a subset of pathways yielding thegreatest potential for significant exposure shall be selected fordetailed assessment. In this initial characterization, possiblepathways of exposure shall be listed, and a preliminary assessment ofthe likely magnitude of exposure of potential receptors shall be madefor each. This preliminary assessment may involve the use of simplemodels of transport and exposure. To the extent possible, the resultsof these preliminary assessments of exposure shall be presented incommensurable units and shall be compared with measures of thetoxicity for the chemicals to which the receptors will be exposed.

Preliminary review of information on the site suggests that directcontact with contaminated soils on-site and transport off-site viagroundwater and surface water are the pathways most likely to giverise to significant exposure, but volatilization and other pathwayswill be considered. A proposed list of exposure pathways for detailedassessment shall be prepared and presented in a briefing to U.S. EPAand Ohio EPA for approval prior to proceeding with the assessment ofhuman exposure.


Assess Human Exposure

For each of the exposure pathways selected above, a detailedassessment of the likely magnitude of human exposure shall beconducted. This assessment may include the construction of exposurescenarios.

Each exposure scenario shall define the route of transport (foroff-site exposures), the receptors at risk, and the likelycircumstances and routes of exposure. For each exposure scenario,ambient concentrations of the chemicals selected at the locations ofthe receptors shall be calculated. For off-site exposure viagroundwater, this will probably require the construction of a model topredict ambient concentrations at off-site locations at various timesin the present and future, taking into account the contribution ofanycontamination from adjacent sites. Assumptions about the rates ofintake of chemicals by receptors (e.g., activity patterns, consumptionof groundwater, breathing rates, absorption factors) shall be statedclearly and documented to the extent possible. The assumptionsselected should represent a "most likely case" and a "reasonable .worstcase" of exposure and will be consistent with current U.Si EPA policy.

For each exposure scenario, calculations of exposure shall be made foreach category of receptor. The results may be presented in tabularform to facilitate comparisons. The information to be presented shallinclude:

o Characterization of receptors (including number of personspotentially exposed, age, sex, or other information specificto the exposure pathway or necessary to estimate dose-rate);

o Frequency and duration of exposure; quantity of thecontaminated medium or media contacted in exposure;

o Average and/or range of ambient concentrations of eachchemical;

o Fraction of material contacted that is expected to beabsorbed; and

o Calculation of dose-rates (expressed in mgAg/day), presentedas dose per exposure, and average lifetime dose.

The exposure assessment for each exposure pathway shall include acharacterization of the variability in exposure and the range ofuncertainties in the estimates.

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALKW-2March 1, 1984Page Ho: 34

Assess Toxicity

A toxicity profile shall be prepared for each chemical selected fordetailed assessment. These toxicity profiles shall be prepared in amanner that is consistent with U.S. EPA's current procedures andguidelines for qualitative assessment of toxicity data andquantitative assessment of risks. They may be based on andincorporate by reference authoritative reviews, including U.S. EPA'sHealth Evaluation Documents and Ambient Water Quality Criteria andassessments by U.S. EPA's Carcinogen Assessment Group (CAG). However,they should include at a minimum:

o A summary of the toxic effects of the chemical reported tohave occurred in humans and animals;

o A summary and critical evaluation of the study or studies onwhich the quantitative risk assessment is based;

o A summary and critical evaluation of the quantitative riskassessment procedures;

o A summary and critical evaluation of any significant studiespublished since the compilation of the most recentauthoritative review, including any qualifications ormodifications of the quantitative risk assessment that may benecessitated by such new information.

The results of quantitative risk assessments shall be presented in thefollowing form:

o For carcinogens, the "unit-risk" coefficient in units of(mg/kg/day) ,•

o For noncarcinogens, the estimated acceptable daily intake(ADI) in units of mg/kg/day;

o For chemicals for which insufficient information is availableto establish a unit risk or ADI, a semiquantitativecharacterization based on any pertinent information that isavailable (e.g., subchronic toxicity studies or structuralanalogies).

A discussion of possible interactions (additive toxicity, synergismsor antagonisms) among different chemicals originating at the site, orbetween these chemicals and others to which the receptors might beexposed, shall be presented. This discussion shall be based on anyinformation available on the occurence of such interactions amongthese or structurally-related chemicals.


Assess Risks to Human Populations

The results of the previous two subtasks will be combined to yieldassessment of risks to exposed human populations, as follows:

o For each carcinogen, the estimated rates of exposure shall beconpared with unit risks to yield estimates of lifetimecancer risks to exposed persons. These comparisons shouldtake into account frequency, duration, and timing of exposureby making appropriate assumptions about the effects ofintermittent or partial-lifetime exposures. Additive orpossible synergistic effects of different chemicals shall betaken into account and an estimate of the total carcinogenicrisk resulting from the site shall be presented.

o For each noncarcinogen, the estimated rates of exposure shallbe compared with ADIs to determine whether an adequate marginof safety exists. Where this comparison indicates that anadequate margin of safety exists for long-term averageexposure, estimates of short-term exposure should be reviewedto determine whether risks of acute or subchronic toxicitymay exist. Additive or possible synergistic effects ordifferent chemicals may be considered by calculating riskindices.

Risk assessments shall be conducted separately for each exposurepathway. Results should be presented separately for "most probablecase" and "realistic worst case" exposure assumptions, and may bepresented in tabular form to facilitate comparisons. The riskassessment for each exposure pathway should include a characterizationof the variability in risks and the range of uncertainties in theestimates.

Assess Environmental Impacts

The potential for impacts to the environment, including plants,animals, ecosystems, and other aesthetic resources, shall be assessed.This is focussed assessment of the effect of chemicals and compoundsat the site relative to the topic areas listed above. The scope isfocussed, and is not an NEPA process. This assessment shall be basedon the estimates of ambient concentrations of chemicals in soil andsurface waters. For aquatic organisms, information on toxicity shallbe drawn from the reviews in U.S. EPA's Ambient Water Quality CriteriaDocuments, including revisions proposed in 1984. For terrestrialorganisms, information on toxicity shall be drawn from any sourcesavailable. The likelihood of significant exposure of predatoryspecies via the food chain shall also be considered. Information onspecies at risk may be derived from site visits, or from federal orstate wildlife agencies.


Assess Welfare Impacts

Any potential impacts of the site on natural resources or publicwelfare shall be identified. These impacts may include effects ongroundwater resources, public water supply, property values, or thepotential for future commercial or residential development. Wherewelfare costs may be incurred to prevent public health impacts (e.g.,by the provision of alternative water supplies), these costs shall beestimated in the Feasibility Study. Other welfare impacts shall beidentified and characterized semi-quantitatively. Detailed economicanalysis is not included in this subtask.

Assess RISK

The results of the above three subtasks will be conbined to yield anassessment of the overall risk posed by the site. To the extentpossible, the degree of risk shall be assessed separately for eachpathway of exposure to facilitate the analysis of remedialalternatives.

Draft Risk Assessment Memorandum

The contractor shall prepare and submit to U.S. EPA a draft reportsummarizing the results of this effort. The scope of this report willbe dependent on the number of chemicals selected for study and thenumber of exposure pathways selected for detailed study.

2.2.4 Remedial Investigation Report

Draft RI Report

After consultation with U.S. EPA and Ohio EPA, a draft remedialinvestigation report will be prepared to consolidate and summarize thedata obtained and documented in previously prepared technicalmemoranda during the remedial investigation.

In addition to a thorough discussion of the conditions at the site,including characterization of surficial processes, hydrogeologicsystems and waste material distribution, the draft report willpresent:

o Reccmmendations regarding whether or not to proceed with anevaluation of remedial action alternatives.

o A discussion of remedial technologies that could be appliedto the site.

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALN -2March 1, 1984Page "Jo: 37

o Remedial action alternatives that must be included in anevaluation, namely, the "no-action", RCRA on-site and RCRAoff-site alternatives.!

The draft remedial investigation report will be submitted for reviewby U.S. EPA and Ohio EPA.

Review Meeting

Upon completion of agency review, a meeting will be held among the REMII project team, U.S. EPA project staff and representatives of OhioEPA. The purposes of the meeting are as follows:

o To discuss the-contents of the remedial investigation report,

o To determine the remedial action objectives.

o To identify alternative operable units and associatedremedial actions to be addressed in the feasibility study.

A list of operable units and potential remedial actions will beprepared by the project team prior to the meeting to provide a basisfor the discussion.

On the basis of the review meeting, agreement on the remedial actionalternatives to be carried into the feasibility study will besummarized in a project memorandum. A public meeting will be held atthis time. Community Relations Activities are discussed separatelyin Section 2.5, Project Administration. The scope of the feasibilitystudy, as presented in this work plan, will be reviewed and modifiedas appropriate to incorporate the results of the review meeting.

2.3 FEASIBILITY STUDY

The feasibility study will consist of identification, development andevaluation of alternative remedial action plans based on engineeringfeasibility, environmental impacts and costs for the selection of analternative or combination of alternatives that are cost effective,reliable, implementable and mitigate the hazards present at the site.Close coordination will be maintained with the U.S. EPA and Ohio EPAduring the feasibility study to satisfy the cleanup objectives atthe site.

The RCRA on-site and off-site alternatives are alternatives for onor off-site remedial action that are in full compliance with RCRA.

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALFW-2March 1, 1984Page No: 3d

The feasibility study will be inplenented through several tasks:

o Development of Alternatives.

o Initial Screening of Alternatives.

o Laboratory Studies (optional).

o Detailed Analysis of Alternatives.

o Evaluation and Selection of Cost Effective Alternative.

o Draft Feasibility Report.

o Conceptual Design.

o Revised Report.

2.3.1 Development of Alternatives

The development of alternatives will require definition of remedialresponse objectives, identification of remedial technologies, and •identification and development of remedial alternatives.

Development of Remedial Response Objectives/Criteria

During preparation of the Remedial Investigation Report in Task 2.4,the remedial action objectives for the site will be established andreviewed by U.S. EPA. These objectives will be based on theendangerment assessment developed for the Pristine, Inc. site.

Criteria for meeting these objectives will be developed in closeconsultations with the U.S. EPA and Ohio EPA. They will includecompliance with 40 CFR 300.68 of the National Contingency Plan, U.S.EPA interim guidance, input fron the U.S. EPA. and Ohio EPA,applicable federal and/or state laws, consideration of existing levelswl contamination, and risk factors for identified sources, pathwaysand receptors.

Identification of Remedial Technologies

Remedial technologies capable of meeting the remedial responseobjectives for the site specific cleanup requirements will beidentified, described and listed for assembly into a set of viablealternatives. Applicable technologies will be based on the nature ofthe contamination at the site, including the geology and hydrogeology;technical literature; and the past experience of team members. Thetechnologies identified will be on a media-specific basis (i.e.groundwater, soil etc.) as well as interrelationships between media.

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALKW-2March 1, 1985Page 3o: 39

Identification and Development of Remedial Alternatives

The remedial technologies identified in Subtask 2.3.1.2 will beassembled into potential remedial alternatives in close consultationwith the U.S.EPA and Ohio EPA. The alternatives selected shall becapable of meeting each response objectives as developed in Section2.3.1.1. These alternatives will include "no-action", cleanup on oroff-site treatment for soil, groundwater treatment) and non-cleanupmeasures such as solidification or encapsulation of on-site soilcontamination, alternate water supply etc. At a minimum, a threealternatives will be considered: no action; off-site management withfull RCRA compliance; and on-site management with full RCRAcompliance. A brief description of the alternatives will be developedincluding the objectives to be met and criteria to be used in theevaluation of the alternatives.

2.3.2 Initial Screening of Alternatives

The alternatives approved by U.S. EPA and Ohio EPA will be furtherevaluated in this task. The purpose of screening would be toeliminate alternatives that are clearly not feasible or appropriateand would be based primarily on engineering judgement.

Criteria to be included in the evaluation will include:

o Implementability and reliability.

o Environmental protection.

o Cost.

Implementability and Reliability

Remedial action plans will be evaluated based on implementability,reliability and operability of each set of technologies that comprisethe alternative plan. An impleroentable alternative is one that mustbe able to be successfully applied or accomplished in a reasonabletime frame. A reliable alternative is one that must be dependable andproven (not state-of-the-art). An alternative that is operable mustbe both practical and feasible.

Environmental Protection

In the process of analyzing potential remedial actions, applicabletechnologies will be evaluated on the basis of their ability toaccomplish a set of environmental goals. These goals should include,at a minimum, the following:

o To perform the desired environmental cleanup action.

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALKW-2March 1, 1985Page Mo: 40

o To create no additional negative impacts upon air, surfacewater or groundwater quality.

o To minimize or eliminate groundwater and surface watercontamination.

o To create minimal impact upon soil.

If these goals can be met by the remedial alternatives, they will beconsidered to be protective of the environment. Those remedialalternatives that exceed these goals will be rated higher than thosethat minimally meet or cannot meet the selected goals.

Analysis of environmental effects resulting from the implementation ofa remedial strategy is also an important evaluation factor. Thepurpose of the remedial action is to rectify existing and potentialnegative environmental impacts. Alternatives that create additionallong-term impacts should be avoided. By considering and minimizingenvironmental effects that may result from each alternative, responseobjectives will be met -and public welfare and the environment will beprotected.

Thus, alternatives will be evaluated to determine the extent to whichthey will control the source of contamination and to determine if thealternatives will result in adverse environmental impact. Forinstance, the risks of moving wastes off site could be anenvironmental risk in sane circumstances. Those alternatives that donot adequately control the source of contamination and result insignificant adverse impacts will be eliminated from furtherconsideration.

Cost

The remedial action program for the Pristine, Inc. site must not onlybe technically capable of addressing the environmental concerns, butit must also be implemented and operated in a cost-effective manner.For cost effectiveness screening, the cost of all applicabletechnologies can be compared using the following cost factors:

o Capital costs.

o Monitoring costs.

o Operation and Maintenance costs.

The purpose of the cost analysis will be to provide a basis forcomparing the economic features of various remedial actionalternatives. These costs will be based on site specific conditionssuch as, the extent of soil contamination, and will also consider

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALKW-2March 1, 1985Page 4o: 41

costs specific to on-site or off-site disposal options. For initialscreening purposes, the final costs will be estimated with an accuracyof +100 percent.

The ratio of capital costs to the monitoring and maintenance costswill be considered. Capital costs are encountered during theimplementation phase for remedial action, but monitoring andmaintenance costs continue during the post-closure phase (design lifetypically 30 years). Monitoring and maintenance operations canrepresent a substantial portion of the cost of remedial actionstrategy, depending on the alternative chosen. This is particularlytrue for treatment options, such as groundwater treatment.Strategies requiring significant maintenance and monitoring will beavoided. However, some level of monitoring and maintenance will berequired to evaluate the effectiveness of the remedial action.

An alternative that has higher costs compared to other alternativesevaluated and that does not provide substancially greater health orenvironmental benefits will be excluded from further consideration.

To ensure that these criteria are met, emphasis will be placed onproven technologies for actions to mitigate contamination on andmigrating from the Pristine site.

Technical Memorandum

A technical memorandum will be prepared and submitted to U.S. EPA andOhio EPA summarizing the response objectives, the identification ofremedial technologies and remedial alternatives, and the initialscreening. The purpose of this memorandum would be to provide anopportunity for agency personnel to review the alternatives selectedand to obtain concurrance on the list of remedial alternatives thatwill undergo detailed evaluation. Only those alternatives approved byU.S. EPA and Ohio EPA will be evaluated in the detailed analysis ofalternatives.

2.3.3 Laboratory Studies

During the development of alternatives and the initial screening ofalternatives, laboratory and bench scale studies may be needed todetermine the overall implementability, operability, reliability andcost effectiveness of a particular alternative.

Laboratory studies or pilot scale studies or supplement studies todetermine engineering design and operating criteria for full-scaleoperation of the chosen technologies may include:

L

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALRW-2March 1, 1985Page Ho: 42

o Groundwater modelling to estimate impacts of alternatives ongroundwater quality after implementation of a remedialaction.

o Waste fixation technologies to ensure that any encapsulationalternatives will effectively provide containment of thewastes on the site.

o Pump tests, above and beyond those scheduled in the field, todetermine the transmissivity of water. A test such as thismay be needed to determine the effectiveness of pumping andtreating groundwater.

o Treatability with a physical/chemical or biological processto determine loading effectiveness, required sizing, chemicaland other material requirements for groundwater and/or stormwater runoff from the site.

If the laboratory studies are deemed necessary based on workactivities, a separate work plan, schedule and budget will bedeveloped for Ohio EPA and U.S. EPA approval. This work plan will besubmitted in a time frame that maintains steady progress of theoverall feasibility study.

2.3.4 Detailed Analysis of Alternatives

Once Ohio EPA and U.S. EPA have reviewed and commented on initialscreening activities described above, a detailed investigation of thepreferred remedial action alternatives will be initiated.

The following items will be considered in the evaluation:

o Detailed development of the remaining alternatives.

o Environmental assessment of each alternative.

o Public health analysis.

o Detailed cost estimation.

Detailed Description and Analyses of Remaining Alternatives

The detailed description of alternative remedial action plans willinclude:

o A description of the remedial technologies for eachalternative will be developed. This will include verbaldescriptions as well as conceptual drawings and/or processflow sheets of each aspect of the technology, such as wastetreatment, contaminated groundwater treatment, etc.


Special engineering considerations required to implement thealternatives will be identified. These items could includea pilot treatment facility or other additional studiesrequired before proceeding with final remedial design.

Operation and maintenance requirements of the completedremedial alternative will also be identified. Thedescription will highlight the type and frequency ofoperation and maintenance requirements. This will allow forstate input on the desirability of each alternative sinceultimately, the State of Ohio will be responsible for theoperation and maintenance of the remedial technology.

Monitoring requirements will be identified. Monitoringactivities needed for the selected remedial alternative willbe similar to the IOA post-closure monitoring andmaintenance requirements. Monitoring should take place whenwastes remain on site to determine if they are, in fact,retained on site. Monitoring is also needed, at least in theshort term to determine if any groundwater contaminationpresent has been mitigated.

Off-site disposal needs and transportation plans will beidentified for each alternative. Waste characterization willdetermine the types of off-site facilities that would be.required for disposal. From this information, facilitiesavailable to handle these materials can be identified.Recommendations of suitable sites will be requested from OhioEPA. In addition, transportation plans will be developed forthe local area. Generally transportation plans are developedonly for the local area and will identify transportationroutes to major interstate highways for transportation ofwaste to be managed off site.

Temporary storage requirements will be identified. Thismay include storage of waste materials or wastewater beforetransport from the site. Any temporary storage facility willbe designed to minimize the potential for environmentalimpacts. This may require the erection of a temporarybuilding, pads for run-on diversion, runoff collection orother actions. Any temporary storage requirements will beidentified for each alternative. Also included will be adescription of the length of time awaste may remain in storage and the maximum quantity ofmaterial that would be in storage at any one time.

Safety requirements unique to implementation of specificplans will be identified. Both on and off site health and

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALKW-2March 1, 1985Page Jto: 44

safety will be considered. Safety concerns will be addressedfor both during and after the cleanup action.

o Potential for Phasing.. A description of how thealternative could be phased into individjial operable units,as appropriate. The description will include a discussion ofhow various operable units of the total remedy could beimplemented individually or in groups, resulting in asignificant improvement to the environment or savings incosts.

Environmental Assessment

A focussed assessment of the environmental impacts will be performedfor each of the remedial alternatives which are evaluated in detail.The assessment will address the environmental impacts of thesealternatives and will identify measures to be taken during the designand implementation to mitigate any adverse effects that may occur fromimplementation of the alternative. This environmental assessment willalso identify any physical or legal constraints that will impair oraffect the ability to implement each of the alternatives. Compliancewith CERCLA, RCRA and, in particular, the National Contingency Plan,will also be evaluated in this environmental assessment.

This action is not being taken under the National Environmental PolicyAct. Its scope is considerably less and is focussed on any impactthat will oe created in alternative implementation. This assessmentalso identifies impacts to public health, welfare or the environmentif the "no action" alternative is chosen. This is the result of therisk assessment undertaken in the RI. The assessment will provide abasis for comparison of improved benefits to public health, welfareand environment that would result from implementation of otherremedial action alternatives.

Public Health Analysis

ine contractor will perform a public health analysis of each remedialalternative. This analysis shall be performed in accordance withcurrent (draft) U.S. EPA policy and guidelines. The results of theenvironmental risk assessment will serve as the baseline for thiseffort.

For each remedial alternative, predicated changes in source strengthand/or in release rate shall be calculated. These changes will beused to calculate changes in ambient concentrations and human exposureby modifying the model parameters in the risk assessment.Corresponding changes in human health risks will be calculated bymodifying the assessments in the risk assessment. These changes willbe calculated for each exposure pathyway, and the results will becombined to characterize the degree of risk expected to result after


the implementation of each remedial alternative. The results of thisanalysis should be presented in tabular form to facilitate comparisonamong the remedial alternatives.

Detailed Cost Estimation

A cost analysis will be developed for each of the remainingalternatives. This analysis will be more definitive than costeffectiveness analysis in the screening of alternatives, and will fallin the range of -30 to +50% accuracy. Each cost item will beidentified and costed in 1985 dollars. An agreed-upon interest ratewill be used in determining the prasent worth cost of those portionsof the projects that may extend over time, such as pumping andtreatment of groundwater and long-term monitoring of the site (up to 3years). In addition to the present worth cost, annual operations andmaintenance cost will be developed for each alternative.

2.3.5 Evaluation and Selection of Cost-Effective Alternative

Once the detailed development of the alternatives has been completed,a final comparison of these remedial action alternatives and theircomponent technologies will be conducted. The evaluation criteriawill include:

o Reliability.

o Implementability.

o Environmental Effects.

o Institutional Considerations.

o Health and Safety Requirements.

o Cost (Present Worth).

The most cost effective reccnmendation will result from a detailedevaluation of the alternatives. Each of the alternatives will beranked for each of the six criteria. Except for cost, all othercriteria are subjective in nature. To evaluate these subjectivefactors, a weighting system will be developed in coordination withOhio EPA and U.S. EPA and will be used to objectively compare allalternatives. A summation of the values for each alternative providesa general ranking of its potential application. In addition, tocompliment the evaluation and prior to recommendation of' the most costeffective alternative, institutional factors should also be identifiedand evaluated.

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALKW-2March 1, 1985Page ito: 46

Technical feasibility and cost-effectiveness do not insureimplementation. Therefore, institutional factors must be consideredin the evaluation and selection of the remedial action strategy. Soreof the factors that should kse considered include:

o Public acceptance.

o Needed permits or licenses.

o Zoning or other land use ordinances.

o Identification of long-term management agencies.

Permits and licenses will be required by state or local units ofgovernment. These can include wastewater discharge permits;processing, landfill, or transportation licenses; and construction oroperation permits. Zoning or other land use ordinances can alsoimpact this assessment and implementation of remedial action strategy.Existing zoning, as well as modification to ordinances, may impactthe proposed strategies.

Long-term management agencies must be identified by the State duringthe feasibility study. This agency (state or local) will be requiredto implement the long-term monitoring and maintenance program. Thiswill include funding, staffing coordinating, and keeping records onmonitoring the site groundwater; maintenance and security; andlong-term care costs. As such the long-term management agency shouldbe identified by the State during the feasibility study process andshould have input in selection of the final alternative.

In addition to these criteria, an important factor in the selection ofthe preferred remedial action alternative is the assessment ofpotential risks associated with its implementation. Risk assessmentfor each potential action will be considered in this evaluation.

By adding an institutional factor analysis and risk assessmentanalysis, additional information on the implementability, reliabilityas well as the public acceptance of the chosen remedial alternativecan be obtained. The resulting output after the completion of thistask will be identification of a recommended alternative forimplementation.

2.3.6 Draft Feasibility Study Report

A proposed outline of the draft report will be submitted to U.S. EPAprior to preparation to obtain concurrence with the reportorganization. The draft report presenting the results of evaluationconducted in tasks described in Sections 2.3.1 through 2.3.5 will be


prepared. On the basis of the entire evaluation process, onealternative or a combination of alternatives will be recommended forconsideration in the conceptional design. The draft report will besubmitted to U.S. EPA and Ohio EPA for review. Following receipt ofreview comments, the conceptual design task will be initiated.

A minimum 3 week comment period will be held on the draft FeasibilityStudy report. A public meeting will be held during this period toreceive Garments and questions on the recommended remedialalternatives. A responsiveness summary will be prepared followingthis public comment period (REM II support for these activities isdiscussed in detail in Section 2.4).

2.3.7 Conceptual Design

A conceptual design package for the selected remedial alternative willbe prepared for submittal to U.S. EPA and Ohio EPA. This conceptualdesign package will contain information collected over the course ofthe remedial investigation and feasibility study. This informationwill be prepared as a preliminary engineering package to be suppliedto the agencies to allow development of the final plans andspecifications for implementation of the selected plan.

The conceptual design will identify the rationale for each technologythat comprises the chosen alternative. It will identify and citereasons for the engineering criteria developed for each technology.An implementation schedule for each component will be developed. Theimplementation schedule will address potential phasing and segmentingconsiderations. Management and institutional requirements will behighlighted and refined based on discussions with U.S. EPA and OhioEPA, as well as other state and local units of government that mayimpact or be impacted by implementation of the chosen alternative.Budget cost estimates will be defined including the cost ofimplementing the draft safety plan.

This information will be assembled into a comprehensive, concisepackage to be used for the development of plans and specifications andincorporation into the bid package. Weston will be available to workwith the entity selected to develop the plans and specifications andthe bid package to ensure that all questions have been answerad, andthat the rationale and purpose for each action identified in theconceptual design is well understood.

The conceptual design package will include at least the following:

o Conceptual design criteria and rationale for the selection ofthis criteria.

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALKW-2March 1, 1985Page Mo: 48

o Conceptual plan view drawings and layouts of the overall siteand facilities.

o Equipment types with approximate capacities, sizes andm construction materials.

o Process flow sheets with mass balances.

o Operational, description of process units or otherfacilities, including preliminary piping and instrumentationdrawings delineating capacities and rationale for selection.

o Estimates of material or equipment quantities required andrationale.

o A description of the structural concepts for any neededfacilities.

o Identification of construction material requirements andrationale.

o A description of the utility requirements and the rationalefor those needs.

o An evaluation of potential construction problems, risks andsolutions.

o Outlines of technical specifications, operations andmaintenance manuals, safety plans (including cost impact),closure and long-term monitoring requirements.

o Right-of-way requirements.

o Identification of additional engineering data required toproceed with design.

o Construction permit requirements, including who isresponsible for obtaining them.

o Temporary material storage and disposal requirements andrationale.

o Off-site disposal procedures, including transportation andvehicle constraints and final disposal and treatment facilityoptions.

o Performance standards to define levels of cleanup required tocomplete the remedial action (this will form the basis forthe measurement and payment section in the specifications).

L.

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALKW-2March 1, 1985Page do: 49

o Data and document control requirements during construction.

o Criteria for subcontractor selection.

o Budget level cost estimate, including operation andmaintenance cost.

o Project schedule.

2.3.8 Revised Report

A revised report will be prepared to include the alternativeevaluation process and conceptual design of the selected remedialaction plan. Two copies (each} of the report will be submitted toOhio EPA and U.S. EPA for review. Agency comments will beincorporated into the document, and final copies submitted.

2.4 COMMUNITY RELATIONS SUPPORT

The U.S. EPA will assume primary responsibility for communityrelations activities during the RI/FS Phase of the project.Assistance will be provided by the project team and will be requiredat regular intervals throughout the RI/FS process. The cotmunityrelations role of the project team will be limited to providing adviseor assistance to the U.S. EPA when requested to do so. ICF, Inc. willbe responsible for supporting U.S. EPA's community relations programthroughout the Remedial Response action.

Based on conversations between U.S. EPA, Region V Public AffairsOffice personnel, ICF, Inc., and Weston, the community relationssupport needed at the Pristine, Inc. site has been scoped. Theobjectives of this support task.is to assist U.S. EPA in implementingthe existing community relations plan developed for the Pristine site.Connunity relations implementation support provided by the REM IIteam will be a two-fold effort:

o Responding to specific task assignments from EPA (e.g.,preparing fact sheets and a responsiveness summary); and

o Providing a range of as yet unspecified support services.

The following tasks reflect conversations between REM II communityrelations staff and U.S. EPA Region V staff concerning expectedcontractor support work for the Pristine site:

o Prepare fact sheets to be used at three (3) public meetingsto be held on the Pristine site. The public meetings will beheld concurrent with the following technical milestones:


— Start of remedial investigation;— Completion of remedial investigation; and— Completion of draft feasibility study.

o General support for the three (3) public meetings willinclude:

— Providing advertisements for each of the public meetingsin the local newspaper(s); and

— Providing a court reporter to record minutes of thepublic meeting on the draft feasibility study.

o Prepare a community relations responsiveness summary afterconpletion of the public eminent period on the draftfeasibility study.

o Revise the community relations plan prior to the start of theremedial design phase to account for any changes in cuiuiunityconcerns as a result of the selection of a remedialalternative.

2.5 PROJECT ADMINISTRATION

Project Administration enconpases the following subtasks:

o Technical review and oversight.

o Financial review and oversight.

o Meetings.

o Technical and financial reporting.

Technical review and oversight includes the technical direction andmanagement provided by the Regional Managers and the Site Manager tothe site team, from project initiation to completion on topics thatare not task-specific.

Financial review and oversight includes the monitoring of budgetstatus, and internal team rebudgeting, as necessary, depending on thelevel of effort provided by the project team. It also includesmonitoring work efforts and forecasting of budget and manpower toschedule the personnel needed for the project.

The subtask for meetings includes meetings that are general ormanagement in nature and cannot be assigned to a specific task orsubtask. This includes meetings such as the monthly RSPO/REM II SiteManagers meeting held in October.

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALKW-2March 1, 1985Page do: 51

Reporting includes the efforts involved in preparing the requiredmonthly technical and financial progress reports and computer inputforms requested by U.S. EPA.

Two types of monthly progress reports are required. These are:

o Technical Progress Reports.

o Financial Management Report.

Technical Progress Report will include the following:

o Site identification and activity.

o Status of work tasks and progress to date with percent ofcompletion defined.

o Difficulties encountered or anticipated during the reportingperiod.

o Actions being taken to resolve problem situations,

o Key activities to be performed in the next month,

o Changes in personnel.

The monthly progress report will list target and actual completiondates for each activity, including project conpletion. The reportwill also include an explanation of any deviation from the milestonesin the work plan schedule.

Financial management report will include the following:

o Actual costs for direct labor, expenses and subcontractsexpended each month during the reporting period, includingbase fee.

- o Cumulative costs and direct labor hours from contactinception to date through the reporting period, includingfee.

o Projection of costs for completing the project, including anexplanation of any significant variations from the plannedcost.

o Projected versus actual expenditures (plus fee) and acomparison of actual versus planned direct labor hours.

o Projection of costs through completion for both.

Pristine, Inc.Work PlanDocument No.: 115-WPI-WP-ALKW-2March 1, 1985Page So: 52

Four copies each of the Technical Progress and Financial Managementreports.will be distributed monthly as follows:

Contract Officer/Project Officer(EPA Headquarters) - 2 copiesRegional Project Officer - 2 copies


SECTION 3

SCHEDULE AND DELIVERABLES

The schedule for completion of work defined in the technical approach(Section 2) is presented in Figure 16. It identifies significantmilestones as well as elapsed time for each task. The estimated timefor completion of this project is 17 months from the date that thework plan is approved and authorization to proceed has been received.This includes 9 months for the remedial investigation and 9 months forthe development of the feasibility study and the conceptual design.There is a one-month overlap of RI and FS.

Figure 17 identifies and provides a schedule for the deliverablesanticipated over the life of the project. These deliverables will besubject to internal (REM II Team) quality control and qualityassurance procedures prior to submittal to U.S. EPA. The schedule ofdeliverables outlines the level and degree of quality control thatwill be provided for deliverables under this project. Table 3provides the key to the symbols used in the Quality Control Plan ofFigure 17.

Both the schedule of activities and the schedule of deliverables arebased on, essentially, a two-week governmental review of documentssubmitted by the REM II Team and no longer than a two-week turn aroundby the REM II Team for response to comments provided by U.S. EPA andOhio EPA on draft material submitted.

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FIGURE 1C PROJECT SCHEDULE (CONTINUED)FEASIBILITY STUDY

FIGURE 17SCHEDULE OF DELJVERABLES

DELIVERABLE

Final Work Plan

111 Technical HMOS

SUe Investigation SiMnary

Risk Assessment Nemo

Draft Rl Report

Review Meeting Memo

Revised Rl Report

Screening Memo

Draft FS Report

Final Draft FS

Responsiveness Summary

RevKed FS 1 CD Report

L

WORKASSIGNMENT

AUTH.

9-4-84

3-23

3-23

3-23

3-23

3-23

3-23

3-23

3-23

3-23

3-23

3-23

DUE

3-1-85

7-5

9-6

9-27

10- IB

11-15

11-29

12-13

3-21-86

4-18

5-30

6-27

QUALITYCONTROL PLAN

(OCR).

ACTIVITY

A. 3

A.I. a

A.I. a

A.I. a

A. 3

A.I. a

A. 3

A.I. a

A. 3

A.I. a

A.I. a

A. 3

DATE

6-28

8-30

9-20

10-4

11-1B

11-15

12-6

3-7-86

4-11

5-23

6-13

QUALITYSURVEIL1ANCC

ACTIVITY DATE

OEM II APPROVAL

2a

3-1

6-28

8-30

9-20

10-4

1-18

11-15

12-6

)-7

-11

-23

-13

2OK

3-1

7-1

9-2

9-2

10-6

11-11

11-18

12-9

3-10

4-14

5-26

6-16

2MI

3-1

9-23

10-6

11-18

2<u.

3-1

9-23

10-6

ll-l

11-1

12-9

3-10

4-14

5-26

6-16

USEPAREVIEW

Oa.

3-1

10-1

1-Z9

3-21

4-16

5-30

6-27

Ou

j-i

0-18

11-29

1-21

*-18

5-30

6-27

O

c

3-1

9-27

10-1

11-1

11-39

12-j:

3-21

4-18

5-30

6-27

0a.ina

j-l

7-5

9-6

9-27

10-1

11-l'j

11-29

12-13

3-21

4-18

5-30

6-27

STATEREVIEW

SW

OO

3-1

7-5

9-6

9-27

10-1

ll-l

11-29

1?-13

i-21

-10

-30

-27

O

3-1

9-2

10-1

ll-l!

11-29

12-1J

3-21

4-U

5-31

6-2

OTHERREVIEW

See Table 3 for explanation of Quality Control Review activities.


TABLE 3

TYPES OF QUALITYCONIRQL REVIEWS

Quality Control Program Activities Legend

A. Single Person Review & Signoff

1. Supervisor

a. Regional Managerb. Health & Safety Managerc. Technical Operations Managerd. Finance & Administration Director

2. Peer Review & Signoff*

3. Technical Expert Review & Signoff*(Identify individual, provide resume & scheduletime)

B. Coimittee Review & Signoff

1. Assembled coimittee

2. Blind contnittee(appropriate technical disciplines must beidentified, resume provided, chairmanidentified & time scheduled)

Signoff consists of approval signature block onthe transmittal page of the deliverable signedand dated by the responsible party(ies) orcanmittee chairman prior to electronicsubmittal to the NPMO for release to the U.S.EPA region.


SECTION 4

PROJECT TEAM

A project team has been assembled to meet the needs of the RI/FS atthe Pristine Inc., site. Figure 18 shows the organization chart forthe completion of this project. Resumes of the key personnel for thisproject are included as Appendix D.

The REM II Team Region V Manager is Mr. John W. Hawthorne, P.E. Mr.Hawthorne has the overall responsibility for completing the project tosatisfaction of the U.S. EPA and the Ohio EPA. Mr. Hawthorne providesupper leva! management contact between the REM II Team, the REMNational Program Management Office and EPA Region V managementpersonnel. He will resolve any conflicts that arise and has ultimateresponsibility for the successful conpletion of this project.

Mr. John W. Thorsen, P.E. has been selected as the Site Manager. Mr.Tnorsen has more than five years of experience on hazardous wastemanagement and has managed several projects similar in scope andbudget to the Pristine Inc. site.

Mr. Thorsen will be supported by a project team of personnel from RoyF. Weston, Inc., ICF Inc., and Clement Associates. Weston will beresponsible for conducting the bulk of the technical and managementwork activities under this project while ICF and Clement will providespecialized services in the area of community relations andendangerment and risk assessment, respectively. Mr. Edward A. Need,Senior Project Hydrogeologist with Weston, will serve as Site TeamLeader and principal investigator for the remedial investigation. Dr.P. Krishnan, P.E. will serve as lead project engineer and will be theprinciple investigator for the feasibility study portion of theproject. Dr. James S. Smith and Ms. Diane Therry will provide datavalidation services.

Dr. Ian T. Nesbit, Ph.D. will act as Lead Investigator for theEndangerment Assessment and Risk Assessment tasks of this project.Ms. Carol Andress will serve as principle support staff in thecommunity relations area. Other personnel will support theseindividuals on an as needed basis during the various phases of theproject, with the largest need for support being during the fieldinvestigation.

Professional Profiles of key staff have been included in Appendix Cfor your review.

I

Regional Site Project Officer

M P Tyson. US. EPA

REM II Region V Manager

J W. Hawthorne. P.E:

I| Pristine, Inc. Site Manager

J W. Thorsen, P E.

RemedialInvestigation

E A Need

FeasibilityStudy

Dr. P. Krishnan

ConceptDesign

M. Corbin

RiskAssessment

Clement Assoc.

CommunityRelations

ICF. Inc.

FIGURE 18 PROJECT ORGANIZATION

APPENDIX A

PROFESSIQXAL PROFILES

- V...

John W. Thorsen, P.E.

Registration

Registered Professional Engineer m the States ofWisconsin and Pennsylvania.

Fitlds of Competence

Solid and hazardous waste management investigationand facility design including identification, treatment,reutihzation. disposal, and remedial engineering andemergency response, industrial waste and sludgemanagement facility design and permitting; hazardouswaste spill containment, evaluation and cleanup.Wastewater facil ity design and water quality manage-ment planning.

Experience Summary

Eleven years of engineering and program/projectmanagement experience m the environmental engineer-ing field, including specific experience m:

Hazardous waste management—All aspects ofRCRA compliance, including facil i ty design and per-mitting; fie'd investigation concept engineering, anddesign of remedial action programs at uncontrolledhazardous waste sites: oil and hazardous materialspill planning and response, including managementof a state spni cleanup fund.

Solid waste management—Landfill design and per-mitting; compliance evaluations; and policy analysis.

Water Quality and water resources planning —Development and evaluation of SPCC plans:municipal sewerage facilities concept design andpermitting; river casm water quality plans; and sludgemanagement.

Credentials

B S . Chemical Engineering —Purdue University (1972)

M S.. Environmental Planning —Southern Illinois Univer-sity (1975)

Environmental Protection Agency Fellowship, Univer-sity Of Wisconsin (1977)

Dipiomate, American AcademyEngineers

Employment History

of Environmental

1981-Present

1978-1981

1977-1978

1974-1977

1972-1974

Key Projects

WESTON

State of WisconsinChief, Hazardous Waste Manage-ment Section

State of WisconsinMunicipal Sewerage Systems

State of Wisconsin

Southwestern IllinoisRegional Planning Commission

As Senior Project Manager with WESTON. conductedfeasibility studies and provided engineering design andpermit assistance for hazardous waste managementfacilities in the chemical, metalworking, and wastemanagement industries.

Project Manager of several large (10) and small (2C) pro-jects that provided remedial action engineering servicesincluding investigation, feasibility, design and construc-tion management at uncontrolled hazardous wastedisposal areas (including landfills, drum disposal sites.and uncontrolled hazardous material spills). Wastetypes have included solvents, oil production wastes.PCB's, and laooratory and miscellaneous cnemicais.

Conducted environmental compliance audits in thepharmaceutical, textile, metalworkmg, and cnemicai in-dustries for wastewater and solid and hazardous wasteregulatory compliance.

Proiect Manager of hazardous waste management pro-gram m Wisconsin. Involved m review and modificationof large solid and hazardous waste land disposal sitesincluding review and modification of technical ap-proach, and design and construction surveillance. In-volved m the development and issuance of permitswhich control the construction and operational aspectsfor a wide variety of hazardous waste storage, treat-

Professional Profile

ment, and disposal facilities including chemical in-cinerators, pathological incinerators, solvent recoveryfacilities, and battery reclamation facilities, as well as awide variety of storage applications.

Extensive experience in environmental investigations ofimproper management and disposal. This work includedcontainment of spilled materials, investigation of theextent of contamination, and cleanup of the con-taminated area. Work in this area has involved PCSwastes, solvents, arsenic, chromium, lead, ink wastes,agricultural wastes including fertilizers and pesticides,and plating wastes.

Familiar with all aspects of RCRA compliance in thehazardous waste area, particularly the permittingaspects involving compliance with detailed Federalregulations.

Wide variety of experience in wastewater and waterquality management, specifically in the areas of concep-tual design, equipment selection, and sludge disposal,particularly land application of wastewater sludges.

As Chief for a Hazardous Waste Management Section,was responsible for the spill response and cleanupaspects of the program.Experience in waste identification and characterizationas hazardous or non-hazardous, and waste audits of in-dustries to identify waste streams, and developwastewater and solid waste compliance plans.

Publications

Has participated at conferences and seminars, and haslectured in the following areas: hazardous waste regula-tions, technology, compliance facility design, and per-mitting; spill response and cleanup; remedial actionplanning, field investigation, safety procedures, and pro-gram implementation; sludge management; landfilldesign; and wastewater treatment facility planning anddesign.

Has authored more than 15 papers in the Mela's of haz-ardous waste management, remedial action engineeringpractices, and RCRA compliance.

Edward A. Need

Fields of Competence

Hydrogeoiogic studies: assessment of organic and in-organic groundwater contamination; evaluation of sitesuitability for solid and hazardous waste landfills; inter-pretation of geological and hydrogeoiogical conditionsrelative to civil engineering and construction projects;remedial investigation planning; site characterization ofuncontrolled hazardous waste facilities; environmentalsampling of groundwater. surface water, soil and sedi-ment.

Experience Summary

Four years of professional experience involvinggeological and hydrogeoiogical aspects of engineeringand environmental protects. Responsibilities have in-cluded field supervision of well installation and en-vironmental sampling; monitoring welt network design;investigation planning including cost and scheduleestimates; site evaluation and remedial action develop-ment; and proiect management. Projects have involvedcontamination of soil and ground and groundwater withvolatile organic compounds: impacts to surface andgroundwater from wastes of wood treating, cementmanufacture and foundry industries: regional screeningand site-specific suitability studies for landfills;geotechmcai and environmental hazards at chemicalmanufacturing and petroleum storage facilities: andfeasibility planning 'or sewer system improvements.

Credentials

B.A.. Geology—Williams College (1978)

M.S.. Geology—University o< Wisconsin, Madison (1980)

M.S., Water Resources Management—University ofWisconsin, Madison (1981)

Geological Society of America

National Water Well Association, Technical Division

American Quaternary Association

Sigma Xi

Employment History

1984-Present WESTON

1981-1984

1980-1981

Key Projects

O'Appolonia Consulting Engineers,lnc./D'Appolonia Waste Manage-ment Services, Inc.

Wisconsin Geological and NaturalHistory Survey

Project geologist and Project Manager for investigationof heaving problems caused by interaction of clay soilsand spillea caustic soda at major chemical manufacturingfacility.

Project Hydrogeologist for investigation of surface andgroundwater contamination resulting from disposal ofcement kiln dust in an abandoned, water-filled Quarry.

Project Hydrogeologist on project involving extensivecontamination of shallow drinking water supply withvolatile organic solvents, requiring interaction withpublic interest organizations and state agencies (health,regulatory, scientific and legal).

Project Hydrogeologist for comprehensive study of soiland groundwater contamination at site of former wood-treating operation including investigation, feasibilityand remedial action design.

Protect Geologist on multi-firm geotechmcai engineer-ing team responsible for evaluating glacial and post-glacial soil material with respect to feasibility of CSOsewer construction and WWTP lake fill expansion.

Publications

Need. E.A. and Costeiio. M.J.. Hydrogeoiogic Aspects ofSlurry Wall Isolation Systems in Areas of HighDownward Gradients, in Proceedings of ffte Fourth Na-tional Symposium ana Exposition on Aquifer Restora-tion ana Groundwater Monitoring. National Water WeilAssociation. Columbus. Ohio. 1984.

Professional Profile

Schneider. A.F. and Need, E.A.. "Litnologic andStratigraphic Evidence for a Late Mid-Woodfordian Pro-glacial Lake in the Lake Michigan Basin." GeologicalSociety of America Abstracts Vol. 15, No. 6, p. 680,1983.Need. E.A., "The Quaternary Stratigraphy of the LowerMilwaukee and Menomonee River Valleys. Milwaukee,Wisconsin." Lake Pleistocene History of SoutheasternWisconsin. Mickelson. O.M. and L Clayton, eds., Geos-cience Wisconsin, Vol. 7. pp. 24-42, 1983.

Costeiio, M.J.. Scherze. 0.. Need, E.A.. "Foundry Wasteand Its Reuse for Construction." Sixth Annual MadisonConference of Applied Research and Practice onMun'cipal and Industrial Waste. Engineering and Ap-plied Science. University of Wisconsin Extension,Madison, Wisconsin. 1963.

Need. E.A., Johnson, M.O.. and Mickelson. D.M., "TillStratigraphy and Glacial History Along the WesternShoreline of Wisconsin's Bayfleld Peninsula."Geological Society of America Abstracts. Vol. 13, No. 6.p. 311. 1981.

P. Krishnan, Ph.D., P.E.

Registration

Registered Professional Engineer m the State of Penn-sylvania.


Process/project engineering and management with em-phasis on industrial wastewater treatment and sludgedisposal and hazardous waste management and control.Areas of expertise include problem definition surveysand wastewater cnaractenzation. laboratory/pilot scaletreatability studies, process design of physical.chemical and Dioiogical treatment, sludge handling anddisposal and neavy metals removal, and environmentalpermuting.

Experience Summary

Sixteen years professional experience in various areasof environmental engineering related to industrialwastewater treatment. Project assignments covered awide range of industry: pulp and paper petroleum refin-ing; petrochemicals: organic and intermediatechemicals: metals finishing; sugar refining; edible oilreining; text i le mills: automotive industry; gasonolmanufac:unng; steei mills including coke manufactur-ing; coal gasification: paints and resms: steam and elec-tric power generation

Credentials

B.E.. Civil Engineering—University of Madras. India

M SC.. Public Health Engineering—University ofMadras. India

Ph.D.. Environmental Engineering—Oklahoma StateUniversity

Water Pollution Control Federation

American Academy of Environmental Engineers

Honors and Awards

Recipient of Wiliem Rudolfs medal 'or outstanding con-tribution m industrial waste control.

Employment History

1982-Present WESTON

1979-1982 Davy McKee Corporation

1977-1979 Harza Engineering Company

1967-1977 WESTON

Key Projects

Planning and execution of pilot scale treatabilitystudies, using sandfilter-activated carbon and pilotscale evaluation of two stage centrifugation. for sludgedewatering and oil recovery for a petroleum refiningcomplex located in Marcus Hook. PA. Resulted indesign and construction of sandfilter-activated carbonadsorption facilities.

Planning and execution of a 5-year wastewater surveyfor establishment of wasteioad allocation forwastewater discharge to the Delaware River, and evalua-tion of in-plant modifications for waste load reductionto achieve compliance with the existing dischargeregulations for a sugar refinery located m Philadelphia.PA. Resulted m meeting the discharge requirement withvarious m-piant modifications instead of enc-o'-pipetreatment.

Evaluated technical alternatives and economical evalua-tion of various sludge disposal options for siucgeresulting from biological treatment of wastewaterdischarges from a petroleum refining located <n BatonRouge. LA and a pulp and paper mill located inPasadena, TX.

Pilot scale treatability studies using plastic mes;a ^ex-ling fi l ter and activated sludge systems. Results wereused to obtain parameters for the design of bioioc:caitreatment facilities for a petrochemical complex ocatecin Baton Rouge. LA.

Preparation of Remedial Action Master Plan (RAMP) 'ora hazardous landfill site containing PCS wastes.

Overseas assignment m Egypt for the wastewarer treat-ment evaluation for an edible oil refining and a tex tuemill.

Professional Profile4 84

Principal author of a comprehensive design guidelineson "Upgrading Existing Municipal Treatment Facilities"prepared for the Technology Transfer Group of the En-vironmental Protection Agency.

Publications

"Studies on the Response of Activated Sludge to ShockLoadings". Bio Tech and Bio Eng., Vol. 7, 1965

"Mechanisms and Kinectics of Substrate Utilization atHigh Biological Solids Concentration." Presented at the21 st industrial Waste Conference. Purdue University.May. 1966.

"Wastewater from Production of Parchment Papers."Presented at the 3rd Mid Atlantic industrial Waste Con-ference, University of Maryland. November, 1969.

"Dynamic Optimization for Industrial Waste TreatmentDesign". Journal Water Pollution Control Federation,Vol. 41, No. 10, 1969.

"System Optimization of Pulp and Paper IndustrialWastewater Treatment Design." Presented at the 1st In-ternational Congress on Industrial Water, Stockholm,Sweden. November, 1970.

"Systems Approach to Microscale Problems of WaterPollution Control." Presented at the American Associa-tic.i for the Advancement of Science, Chicago. IL,December 1970.

"Use of Sand Filter Activated Carbon System forRefinery Wastewater treatment." Presented at the 26thIndustrial Waste Conference, Purdue University, May,1971.

"Non-Biological Treatment of Refinery Wastewater",Journal Water Pollution Control Federation. Vol. 44. No.11, 1972.

"Response of Activated Sludge to Quantitative ShockLoadings Under Variety of Operation Conditions." Jour-nal Water Pollution Control Federation. Vol. 48. 1976."Pollution Problems of the Steam Generating In-dustry—A state of the Art." Presented at the 8th AnnualPollution Conference, Chicago, IL, November 1975."Column Scaling Tests for Flocculant Suspension-Discussion of Technical Paper", Journal of AmericanSociety of Civil Engineers. Vol. 102, No. EE1, February,1976.

Registration

Registered Professional Engineer in Pennsylvania andthe Commonwealth of Virginia


industrial waste and Hazardous waste management in-cluding treatment, disposal, collection, storage.transfer, waste reduction, and recovery; solid wastedisposal and sludge management: disposal facilitydesign and permitting.

Experience Summary

Ten years of diversified engineering and operational ex-perience m the field of hazardous and industrial wastemanagement including interaction with regulatory agen-cies, optimization of industrial waste systems, handlingof hazardous wastes, and disposal-site evaluation.

Credentials

B.S.. Mechanical Engineering—University of Virginia11970)

M.S.. Mechanical Engineering—Massachusetts In-stitute of Technology (1972)

Tau Beta Pi. Sigma Xi. American Academy of En-vironmental Engineers

Employment History

1976-Present WESTON

1972-1976 County of Fairfax. Virginia

1970-1972 Massachusetts Institute ofTechnology

Key Projects

Served as Proiect Engineer for the following WESTONhazardous and industrial waste management protects:

Design and permitting of a secure landfill and closure

Michael H. Corbin, P.E.

of a 30-acre sludge basin for an integrated steel millin Pennsylvania.

Design and permitting of a secure land disposalfacility for a New Jersey metals processor.

Preparation of the Hazardous Waste ManagementPlan and facility siting for the State of Alabama.

Optimization of an industrial waste handling anddisposal system for a major West Virginia chemicalfirm.

Design of a secure landfill and closure of 11 sludgebasins for a New Jersey hazardous waste processor.

Preparation of an industrial and hazardous wastemanagement program for a maior Texas chemicalfirm.

Development of an oily waste processing, recovery,disposal, and land-farm system for a major Westernrefinery.

Design of a clean-up program for two maior aban-doned PCS sites and PCB-contaminated spill areas mPennsylvania.

Preparation of the design, specifications, and field in-spections for clean-up of a drum disposal site mPhiladelphia involving up to 15,000 buried drums.

Design of a hazardous waste materials handling anaincinerator system for a Georgia chemical plant.

Preparation of in-situ closure plans for two low-levelradioactive waste disposal sites in St. Louis,Missouri and Canonsburg, Pennsylvania.

Preparation of plans, design, and specifications forremedial action at two major Superfund sites.

As Deputy Director of the Di"ision of Solid Waste forFairfax County. Virginia, was responsible for the collec-tion and disposal of all solid waste generated m theCounty, including the operation of a 1.500-ton/daysanitary landfill and a 40-vehicie collection fleet.

As Engineer in the Wastewater Treatment Division forFairfax County, was responsible for the operation ofnine sewage treatment plants, including sludge han-dling and disposal.

Professional ProJila•2 33

Publications/Technical Paper*

"The Handbook of Hazardous Wast* Management."Ticfinomics. co-author with A.A. Metry.

"Industrial Solid Waste Containment: Upgrading Ex-isting Landfills," by M.H. Corbin and W.H. Porter.

"Management Aspects of Potentially Hazardous andSpecial Wastes." by M.H. Corbin, A.A. Metry, and K.M.Peii. -

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