Remedial Design/Remedial Action Work Plan · Remedial Design/Remedial Action Work Plan ... 7.3...

Remedial Design/Remedial Action Work Plan

AVX Corporation Olean, New York

March 1999

BBL ENVIRONMENTAL SERVICES, INC.

Remedial Action • Managementand Construction

300260

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T E C H N I C A L P L A N

Remedial Design/Remedial Action Work Plan

AVX Corporation Olean, New York

March 1999

BBL ENVIRONMENTAL SERVICES, INC. Remedial Action • Management and Construction

30 Corporate Woods, Suite 160 Rochester, New York 14623-1477 (716) 292-6740

REMEDIAL DESIGN/REMEDIAL ACTION WORK PLAN

UST OF ACRONYMS

1.1.T-TCA 1,1,1-Trichloroethane Alcas Alcas Cutlery Corporation ALCOA Aluminum Company of America ARARs Applicable or Relevant and Appropriate Requirements AVX AVX Corporation BBL Blasland, Bouck & Lee, Inc. BBLES BBL Environmental Services, Inc. Cast W.R. Casf and Sons Cutlery Co.

Comprehensive Environmental Response, Compensation and CERCLA Liability Act of 1980 CLP Contract Laboratory Program COCs Contaminants of Concern Cooper Cooper Industries Inc. DOT Department of Transportation FIT USEPA Region II Field Investigation Team GC Gas Chromatography HASCP Health and Safety/Contingency Plan IRM Initial Remedial Measure Loohn's Loohn's Dry Cleaners and Launderers McG raw-Edison Cooper Industries/McGraw-Edison Company NPL Superfund National Priorities List NYS New York State NYSDEC New York State Department of Environmental Conservation NYSDOH New York State Department of Health OU1 ROD First Operable Unit Record of Decision OU2 ROD Second Operable Unit Record of Decision OVA Organic Vapor Analyzer PESVSP Post-Excavation Soil Verification Sampling Plan PMP Project Management Plan PRGM Post Remediation Ground-Water Monitoring PRGMP Post Remediation Ground-Water Monitoring Program PRT Pre-Remediation Testing QAPP Quality Assurance Project Plan RA Remedial Action RAO Remedial Action Objectives RAR Remedial Action Report RCRA Resource Conservation and Recovery Act RCTP Remedial Construction Testing Plan RD Remedial Design RD/RA Remedial Design/Remedial Action Work Plan RI/FS Remedial Investigation/Feasibility Study SAMP Sampling. Analysis, and Monitoring Plan Site Olean Well Field Superfund Site SOW Statement of Work SRI/FS Supplemental Remedial Investigation/Feasibility Study TBC To be Considered TCE Tricholoroethene TCLP Toxicity Characteristic Locating Procedure USACF United States Army Corps of Engineers USEPA United States Environmental Protection Agency USGS United States Geological Survey VOC Volatile Organic Compound

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Table of Contents

Section 1.

Section 2.

Section 3.

Section 4.

Section 5.

Section 6.

Introduction 1-1

1.1 General 1-1 1.2 Site Description 1-1 1.3 Site History 1-2 1.4 Remedial Action Objectives and Selected

Remedy for the AVX Property 1-5 1.5 Purpose and Organization of Work Plan 1-7

Project Organization and Responsibilities 2-1

2.1 General 2-1 2.2 Project Responsibilities 2-1 2.3 Qualifications and Resumes 2-3

Pre-Design Activities 3-1

3.1 General 3-1 3.2 Monitoring Well Installation Program 3-1 3.2.1 Well Evaluation 3-2 3.2.2 Well Installation 3-3 3.3 Wetland Delineation 3-5 3.4 Pre-Remediation Testing Overview 3-6

Stage 1 Remedial Design 4-1

4.1 General 4-1 4.2 Preparation of the Stage 1 Remedial Design 4-1 4.3 Updated Project Management Plan 4-3 4.4 Updated Post-Remediation Ground-Water

Monitoring Program 4-3

Access Approvals & Permits 5-1

5.1 General 5-1 5.2 Site Access and Institutional Controls 5-1 5.3 Access Agreements for Adjacent Properties 5-1 5.4 Permitting Requirements 5-2 5.5 Off-Site Disposal Approvals 5-2

Stage 1 Remedial Action and Post-Remediation Ground-Water Monitoring 6-1

6.1 General 6-1 6.2 Task 1 - Mobilization 6-1

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BLASLAND, BOUCK & LEE, INC. engineers & scientists

Section 7.

Section 8.

Tables

Figures

Appendices

6.3 Task2-Site Preparation 6-2 6.4 Task 3 - Excavation of Impacted Soil 6-2 6.5 Task 4 - Off-Property Transportation and Disposal

of Waste 6-4 6.5.1 Non-Hazardous and Hazardous Waste

Transportation 6-5 6.5.2 Non-Hazardous and Hazardous Waste Disposal 6-6 6.6 Task 5 - Site Restoration 6-6 6.7 Task 6 - Pre-Final Site Inspection 6-7 6.8 Task 7 - Demobilization 6-7 6.9 Task 8 - Pre-Certification Site Inspection 6-8 6.10 Task 9 - Preparation of Stage 1 Remedial Action

Report 6-8 6.11 Task 10 - Post-Remediation Ground-Water

Monitoring 6-9

Monthly Reporting and Documentation 7-1

7.1 General 7-1 7.2 Monthly Reports 7-1 7.3 Miscellaneous Documentation Requirements 7-1

Project Schedule 8-1

Table 1 - Soil Borings TCL Volatile Organic Compound Concentrations Table 2 - Shallow Till and Lower Portion of Lower Aquifer

Ground-Water Volatile Organic Compound Concentrations

Figure 1 - Olean Well Field Superfund Site Figure 2 - AVX Property Map Figure 3 - Approximate Soil Excavation Area Figure 4 - Post-Remediation Ground-Water Monitoring Program Figure 5 - Schedule

Appendix A - Consent Decree Appendix A1 - Well Completion Logs Appendix B - Sampling, Analysis and Monitoring Plan (bound separately) Appendix C - Quality Assurance Project Plan (bound separately) Appendix D - Health and Safety/Contingency Plan (bound separately) Appendix E - Qualifications and Resumes

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BLASLAND, BOUCK & LEE, INC.

engineers & scientists

Section 1 BBL ENVIRONMENTAL SERVICES, INC.

Remedial Action • Management & Construction

Introduction

1. Introduction 1.1 General

1.2 Site Description

BBL Environmental Services, Inc. (BBLES), together with affiliated company Blasland, Bouck & Lee, Inc. (BBL) has prepared this detailed Remedial Design/Remedial Action (RD/RA) Work Plan for performing remediation activities at the Olean Well Field Superfund Site for the AVX Corporation (AVX) Property located at Seneca Avenue in Olean, New York. This Work Plan presents the Stage l RD/RA and Post-Remediation Ground-Water Monitoring (PRGM) activities to be performed to satisfy the requirements of the United States Environmental Protection Agency's (USEPA's) selected remedy for the AVX Property, as presented in USEPA's Second Operable Unit Record of Decision (OU2 ROD), dated September 30, 1996. This RD/RA Work Plan has been prepared in accordance with the Consent Decree, Civil Action No. 98 CV0054A(M) (Appendix A), entered between the United States of America (United States) and AVX of Myrtle Beach, South Carolina, effective March 17, 1998.

The Olean Well Field Superfund Site (Site) is located in the eastern portion of the City of Olean and the Towns of Olean and Portville in Cattaraugus County, New York (Figure 1). The Site, which occupies approximately 800 acres, is about 65 miles southeast of Buffalo, New York and 7 miles north of the New York/Pennsylvania state border. The Site is located in the Allegheny River Valley near the border of the northwestern Appalachian plateau. The Allegheny River flows west-northwest through the southern portion of the Site, and the Olean and Haskell Creeks pass through the west and east portions of the Site, respectively. The AVX Property, which is the focus of this Work Plan, is located in the north-central portion of the Site in the Town of Olean and is bordered by Seneca Avenue to the north, private Property to the east, Conrail railroad tracks to the south, and to the west by the boundary between the City and Town of Olean (Figure 2).

The Site is underlain with approximately 300 feet of unconsolidated sediments. The upper 100 feet of sediment has been divided into five lithologic units which have been grouped into four hydrogeologic units identified as the upper aquifer, upper aquitard, lower aquifer, and lower aquitard.

The upper aquifer consists of glaciofluvial coarse sands and sandy gravels and recent fluvial deposits comprising fine sands and silts with some clay. The thickest portion of the upper aquifer is found along the Allegheny River (approximately 41 feet); it then thins to the north, pinching out south of the AVX Property (i.e. it is not present beneath the AVX Property). The upper aquitard is located above the lower aquifer and consists of a low permeability till with a thickness as little as six feet in the south to more than 30 feet in the north. This is generally, the uppermost unit beneath the AVX Property. The lower aquifer, also referred to as the City Aquifer, consists of glacial outwash deposits of sand, silt, and gravel and is the main source of water for the City and Town of Olean. The lower aquifer is approximately 70 feet thick in the northern portion of the Olean Well Field and thins to approximately 30 feet south of the Allegheny River. The lower aquitard consists of silt, clay, and fine to very fine sand deposited in a preglacial environment.

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The upper aquifer is recharged by the infiltration of precipitation and the lower aquifer is recharged via leakage from the upper aquifer through the upper aquitard. The magnitude of leakage over the Site varies and is dependent on the thickness and permeability of the upper aquitard and head difference between the upper aquifer and lower aquifer.

Local and regional ground-water studies have shown different flow directions for the different flow zones. The shallow zone flow direction in the vicinity of the AVX site is primarily to the south following the topography towards the Allegheny River, while the deeper zone flow direction is more toward the west -southwest along the general direction of the river flow. The different flow patterns are developed from shallow and deep wells, primarily completed as two well clusters. The wells are located in clusters to assist in the evaluation of vertical hydraulic gradients. The deeper ground-water system also appears to be influenced locally by the pumping of the AVX production well and the Olean Municipal Well Field (Wells 18M, 37M and 38M) located in the southwest portion of the Well Field Site. Horizontal flow does not appear to be significant in the intermediate zone as gradients within this portion of the low permeability till unit are primarily downward. The potentiometric surfaces for the upper and lower aquifers showing the variation in flow patters between the two aquifers are presented in the October 1994 Supplemental Remedial Investigation Report by Geraghty and Miller, Inc. A more recent complete record of water level data for the AVX property, including the newly installed wells and the Olean Well Field is not available.

1.3 Site History In the mid to late 1970s, three municipal water supply wells (18M, 37M, and 38M) were installed to draw water from the lower aquifer and to provide water for the City of Olean. Prior to the installation of these supply wells, municipal water was provided via a surface-water treatment system which drew water from Olean Creek. In January 1981, trichloroethene (TCE) and other chlorinated organic solvents were detected in the lower aquifer with TCE concentrations exceeding the acceptable drinking water standards established by the New York State Department of Health (NYSDOH). As a result, the three municipal wells were deactivated and the existing surface-water treatment system was reactivated.

Based on an evaluation conducted by the USEPA Region II Field Investigation Team (FIT) on October 23, 1981, the Site was included on the first official Superfund National Priorities List (NPL) on September 9, 1983.

A Remedial Investigation/Feasibility Study (RI/FS) was conducted at the Site between 1984-1985 by a contractor to the New York State Department of Environmental Conservation (NYSDEC). During this RI/FS, it was determined that a plume of TCE was impacting private and municipal wells in the City and Town of Olean. As a result of this condition, a focused feasibility study was performed and an Initial Remedial Measure (IRM) was conducted, which consisted of regular monitoring of private wells and installation of carbon adsorption units, until a permanent remedy was implemented.

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Between 1983-1985, USEPA issued separate administrative orders to Cooper Industries/McGraw-Edison Company (McGraw-Edison), AVX, and A leas Cutlery Corporation (Alcas) to perform investigations at their respected facilities. Based on the results of these investigations and subsequent investigations performed by the above-referenced companies, the following information was revealed:

• The soil and ground water in the upper and lower aquifers at the McGraw-Edison facility were contaminated with TCE and other volatile organic compound (VOC) solvents. Also, the investigations indicated that a pathway existed for the migration of contaminants from the McGraw-Edison facility to the municipal wells;

• The soil and ground water at the AVX facility were contaminated with TCE, 1,1,1 -trichloroethane (1,1,1 -TCA) and other VOCs. Also, the investigations demonstrated that contamination migrated downward from the surficial soils at the facility through the till and into the lower aquifer; and

• The soil at the Alcas facility was contaminated with VOCs and the upper and lower aquifer ground waters were contaminated with TCE and other VOCs.

On September 24, 1985, USEPA issued a first operable unit (OU1) ROD for the Site which required the following:

• Installing an air stripper to treat the ground water from municipal well 18M and a second air stripper to treat the ground water from municipal wells 37M and 38M;

• Extending the City of Olean's public water supply line into the Town of Olean and Portville to connect approximately 93 residences served by private wells;

• Inspecting the industrial sewer at McGraw-Edison and performing any necessary repairs to the sewer;

• Providing recommendations for institutional controls to restrict the withdrawal of contaminated ground water;

• Instituting a Site Monitoring Plan; and

• Performing a supplemental RI/FS (SRI/FS) to evaluate source control measures at facilities within the Site that are contributing to the groundwater contamination.

On February 7, 1986, USEPA issued a Unilateral Administrative Order, Index Number II Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA)-60201, under Section 106(a) of CERCLA, 42 U.S.C. §9606 (106 Order), to AVX, Alcas, McGraw-Edison, Cooper Industries, Inc. (Cooper), Aluminum Company of America (ALCOA), and W.R. Case and Sons

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Cutlery Co. (Case). The 106 Order required these companies to implement the remedial actions selected in the OU1 ROD.

On June 25, 1991, an Administrative Order on Consent, Index Number II CERCLA-10202 (the SRI/FS Order), was issued by USEPA to AVX, Alcas, McGraw-Edison, Cooper, and ALCOA. The SRI/FS Order required these companies to perform a study of their respective facilities and to prepare a site-wide SRI/FS. These companies together were known as the Olean Cooperating Industries during the SRI/FS. USEPA also conducted studies of 10 additional properties within the Site and provided their information to the above-referenced companies for incorporation into the SRI/FS.

The SRI for the AVX Property (and the other twelve properties) was conducted between 1991-93 and consisted of the collection and analysis of soil and groundwater samples. The highest results from soil and ground-water analyses from the SRI performed at the AVX Property are summarized below:

• The highest concentrations ofVOCs were measured in the southern portion of the Property in soil samples collected from soil boring SB06 (Figure 3). The maximum VOC concentrations measured in soil boring SB06 was 1,1,1-TCA at 1,300 parts per million (ppm), TCE at 500 ppm, tetrachloroethene (PCE) at 270 ppm, xylene at 73 ppm, and cis-l,2-dichloroethene (1,2-DCE) at 45 ppm. Soil VOC results from soil borings installed in 1991 and 1993 are presented in Table 1. Soil boring locations are shown on Figure 3.

• The highest concentrations of VOCs were also detected in ground-water grab samples collected from the bottom of soil boring SB06. The measured VOC concentrations in the ground-water samples from this boring were TCE at 110,000 parts per billion (ppb), 1,1,1-TCA at 360,000 ppb, 1,2-DCE at 73,000 ppb, and 1,1 -DCA at 26,000 ppb. Ground-water sample results from wells at the AVX property in 1984 and 1985 are presented in Table 2. Results for Well AVX-5D are also included from October 1997. Monitoring well locations are shown on Figure 2.

Based on the results of the SRI/FS, USEPA determined that the AVX Property, as well as the Alcas, McGraw-Edison, and Loohn's Dry Cleaners and Launderers (Loohn's) properties, contained sources of VOC contamination at levels which may impact the Site's lower and/or upper aquifer ground water. The VOC contaminated soil did not pose an unacceptable risk; however, the contaminated soil was a source for contaminated ground water and the ground water was the principal threat posed by the Site. Therefore, USEPA issued the OU2 Consent Decrees to AVX and the three other Olean Cooperating Industries to address the three identified source areas on their respective Properties. EPA has not yet signed a Consent Decree or issued a unilateral order concerning implementing the OU2 ROD at the fourth identified source area (Loohn's)

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1.4 Remedial Action The remedial action objectives (RAOs) for the AVX Source Area (and the three Objectives and other identified source areas) were developed to address the contaminated ground Selected Remedy water and soil at the AVX Property to assist in the restoration of the lower for the AVX Property aquifer to its beneficial use as a drinking water supply. These objectives are

specific goals to protect human health and the environment and are based on available information and standards such as applicable or relevant and appropriate requirements (ARARs), to be considered (TBC) guidance values, and risk-based levels established by a risk assessment.

The ground-water remedial action objectives include the removal and/or control of the source of contamination to the ground water and the removal of sources of contamination already in the ground water. The soil remedial action objectives include eliminating the leaching of contaminants of concern (COCs) from the soil within the source area into the ground water.

Based on the OU2 ROD, the selected remedy and Remedial Goals for the AVX Property consists of the following:

Stage 1

• Soil will be excavated from the source area in the area around soil borings SB04 and SB06. The horizontal and vertical extent of the excavation will be guided by the ability to achieve the soil cleanup objectives. Encountering the water table or excavating adjacent to the building may limit the extent of the excavation. Based on an estimated depth of 6 feet, it is estimated that approximately 10,000 cubic feet of contaminated soil will be excavated from the source area. The excavation may proceed up to 24 inches below the water table if soil screening indicates the presence of contamination at or below the water table. The excavation will be restricted by structural integrity of the building or excessive water. It will be necessary to implement dust, volatile emission, soil erosion, and sediment control measures during all phases of soil excavation activities;

• The excavated, contaminated soil will be evaluated to determine if it meets the definition of a Resource Conservation and Recovery Act (RCRA) characteristic hazardous waste material. All excavated soil will be transported and disposed off-site to either a permitted non-hazardous or RCRA hazardous disposal facility. RCRA hazardous waste material will be treated off site as necessary to meet applicable state and federal requirements;

• Verification soil samples will be collected and analyzed from the underlying soil and side walls of the excavation to ensure that all contaminated soil has been removed. If the excavation extends below the water table, the bottom verification samples will be evaluated as saturated soil samples.

• The cleanup goals that have been established in the OU2 ROD for the COCs in the soil and ground water includes the following:

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Contaminant

Soil Cleanup

Objective

(ppm)1

Federal Ground-Water MCL

(ppb)

New York State Water Quality Standard (ppb)

Benzene 0.06 5 0.70

2-Butanone 0.30 — 50

cis-1,2-Dichloroethene 0.30 70 5

Ethylbenzene 5.50 700 5

T etrachloroethene 1.40 5 5

1,1,1 -Trich Ioroethane 0.80 200 5

Trichloroethene 0.70 5 5

Toluene 1.50 1,000 5

Vinyl Chloride 0.20 2 2

Xylene 1.20 10,000 5

Notes:

ppm - parts per million ppb - parts per billion MCL - Maximum Contaminant Level I - Taken from the NYSDEC Technical and Administrative Guidance Memorandum (TAGM) cleanup goals, which represent concentrations of VOCs that

are protective of all future land uses and will not leach from soil and dissolve into the ground water at levels which are above federal and NYS MCL concentrations.

• Backfill excavated area(s) to the original grades using clean fill material;

• Land use/access restrictions will be placed on the source area to restrict its use until restoration of the excavated area(s) has been completed. Deed restrictions will be imposed to prevent the construction of drinking water wells on the AVX Property; and

• Implementation of a Post-Remediation Ground-Water Monitoring Program (PRGMP) after source removal activities are complete to verify the effectiveness of the soil removal activities.

Stage 2

• After remediation of the Site source areas, four years of ground-water quality results will be collected and evaluated from the PRGMP. Wells will be sampled quarterly for the first two years, at which time an evaluation will be performed that may result in a proposal to reduce the sampling frequency. Details on specific analytical parameter and wells are provided in Section B.5 of the Sampling Analysis and Monitoring Plan (SAMP). Based on the four years of data, a determination will be made whether a ground-water pump-and-treat system will need to be installed to facilitate restoration of the

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lower aquifer. The requirement for a ground-water treatment system will be assessed every four years and will be evaluated based on the ground-water analytical results from samples collected from the influents of municipal wells 18M, 37M, and 38M, as well as samples collected upgradient and downgradient from the AVX source area; and

• If a ground-water treatment system is determined to be necessary for the AVX source area, USEPA will evaluate the impact of the system on the adjacent wetlands.

In 1997, AVX negotiated with EPA and reached agreement on a Statement of Work (SOW) for the implementation of the Stage 1 RD/RA and PRGMP at the AVX Property in accordance with the OU2 ROD. On March 17, 1998, the Consent Decree (Appendix A) became effective between the United States and AVX which requires AVX to perform the SOW in accordance with the OU2 ROD.

1.5 Purpose and Organization of Work Plan

The purpose of this RD/RA Work Plan is to provide a detailed description and schedule of the activities which will be undertaken to implement the USEPA selected Stage 1 remedy for the AVX Property in accordance with the OU2 ROD. This Work Plan has been prepared to conform with EPA's "Superfiind Remedial Design and Remedial Action Guidance," dated June 1986, as well as, updates and amendments that have been provided for that document. In addition, this Work Plan has been prepared in accordance with the SOW and Consent Decree. Any modifications to this Work Plan will be first submitted to USEPA for approval prior to implementation.

This Work Plan has been organized into the following eight sections:

Section Description

1. Introduction Provides background information of the Site, identifies the Remedial Action Objectives and selected remedy for the AVX Property, and describes the purpose/organization of the Work Plan.

2. Project Organization and Responsibilities Identifies the project organization and responsibilities of all contractors and subcontractors proposed to be used for the Stage 1 RD/RA and PRGM activities, as part of the Project Management Plan (PMP).

3. Pre-Design Activities Identifies the current monitoring well network at the AVX Property, describes the wetland evaluation procedures, and provides an overview of the proposed pre-remediation testing.

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Section Description

4. Stage 1 Remedial Design Provides an overview of the Stage 1 Remedial Design (RD) components.

5. Access Approvals and Permitting Identifies the site access and institutional controls, as well as all access agreements, permits, and approvals that may/will be required to implement Stage 1 RD/RA and PRGM activities at the AVX Property.

6. Stage 1 Remedial Action Plan and Post-Remediation Ground-Water Monitoring

As part of the PMP, provides an overall description of the Stage 1 Remedial Action (RA) and PRGM activities to be performed at the AVX Property.

7. Reporting/Documentation Identifies the required reports and documentation that will be prepared during the performance of Stage 1 RD/RA and PRGM activities.

8. Project Schedule Provides an overall schedule to perform all Stage 1 RD/RA and PRGM activities, as part of the PMP.

In addition, the following RD/RA Work Plan support documents have been prepared to set forth the specific requirements for analytical methods and protocols and employee health and safety requirements/procedures associated with the implementation of the selected remedy for the AVX Property:

• Sampling, Analysis, and Monitoring Plan (SAMP) which describes the procedures for sampling, analyzing, and testing all soil and water samples collected during the performance of Stage 1 RD/RA and PRGM activities;

• Quality Assurance Project Plan (QAPP) which presents the analytical methods/procedures to be used by laboratories for the chemical analysis of soil and ground-water samples collected during the performance of Stage 1 RD/RA and PRGMP activities and outlines the construction quality assurance aspects of the soil excavation activities; and

• Health and Safety/Contingency Plan (HASCP) which presents the minimum health and safety requirements, procedures, and methods to be implemented by all personnel performing activities during the performance of Stage 1 RD/RA and PRGMP at the AVX Property.

The SAMP, QAPP, and HASCP are provided in Appendices B, C, and D, respectively, to this RD/RA Work Plan.

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Project Organization and Responsibilities

2. Project Organization and Responsibilities 2.1 General This section of the RD/RA Work Plan describes the project organization and

responsibilities of those who will participate in the Stage l RD/RA and PRGMP activities and is a component of the Project Management Plan (PMP), as identified in Section C5 of the SOW. This section may need to be modified based on the information included in the upcoming Stage l RD.

AVX has selected BBLES, and affiliated company BBL, to provide turn-key services to implement the Stage 1 RD/RA and PRGMP activities at the AVX Property. BBLES will act as the "Supervising Contractor," as stated in Section VI of the Consent Decree, and as such will direct all activities associated with the Stage 1 RD/RA and PRGMP, in accordance with the Consent Decree and SOW.

A description of the responsibilities of project personnel and their anticipated tasks during the Stage I RD/RA and PRGMP implementation at the AVX Property is presented below.

2.2 Project Responsibilities

BBL Environmental Services. Inc. will serve as the Supervising Contractor and will be responsible for the design, Construction Management, and implementation of all activities associated with the Stage 1 RD/RA and PRGMP activities. The proposed personnel and their responsibilities for BBLES and BBL include the following:

Mr. William B. Popham will serve as the Project Officer for AVX-and as such will have overall responsibility for all tasks associated with the Stage 1 RD/RA and PRGMP. Mr. Popham will be responsible for certifying the completion of all Stage 1 RA and PRGMP activities performed at the AVX Property.

Mr. Andrew N. Johnson. P.E. will serve as Senior Technical Supervisor and will provide direction, final review, and internal approval of all documents, design drawings, and other work products developed throughout this project. Mr. Johnson is a licensed New York State (NYS) Professional Engineer and will sign/stamp all work products developed, as necessary.

Mr. Mark F. Weider will serve as the Project Manager and will be responsible for the coordination/development of all work products provided during the performance of the Stage 1 RD/RA and PRGMP.

Mr. Joseph Molina III. P.E. will serve as the Construction Manager and will be responsible for supervising, directing, and scheduling all construction activities that will be performed at the AVX Property during the Stage 1 RD/RA and PRGMP activities.

Mr. Jav D. Keough. CIH will serve as the project Health & Safety Officer and will be responsible for the technical review and approval of the HASCP, as well as on-going review of project health and safety issues for the duration of the Stage 1 RD/RA and PRGMP activities.

Mr. Michael R. Arlauckas will serve as the on-site field/health and safety supervisor and will be responsible for overseeing construction activities and

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health & safety aspects at the AVX Property during the performance of Stage 1 RD/RA and PRGMP activities. Also, Mr. Arlauckas will be responsible for collecting any soil and water samples that are required for the project.

Nothnagle Drilling will be retained by BBL to provide all drilling services at the AVX Property associated with the Stage 1 RD/RA and PRGMP activities. This includes the installation of new monitoring wells, replacement/repair of existing monitoring wells, overdrill and abandonment of existing monitoring wells, and installation of pre-remediation soil borings.

Longworth Environmental. Inc. will be retained by BBL to provide non-Contract Laboratory Program (CLP) chemical analyses (which will generate non-Definitive Data) for all pre-remediation and pre-verification soil samples collected during the Stage 1 RD/RA using an on-site portable, laboratory grade, gas chromatograph (GC) unit.

Columbia Analytical Services. Inc. will be retained by BBL to provide definitive data by CLP chemical analyses at their off-site laboratory for soil and ground-water samples collected during the Stage 1 RD/RA and PRGMP, for the following items:

• Soil samples collected to characterize the impacted soil for off-site disposal;

• Verification soil samples collected after excavation activities to ensure that the source area has been excavated sufficiently to meet the established soil cleanup goals for the AVX Property;

• Ground-water samples collected during the implementation of the PRGMP for analysis for volatile organic compounds; and

Microseeps. Inc. will be retained by BBL to provide CLP chemical analysis at their off-site laboratoiy for analysis of ground-water samples for indicator parameters for natural attenuation during the implementation of the PRGMP.

Sterling Environmental will be retained by BBLES to provide all construction services associated with the excavation, backfilling, and restoration of the source area and any other disturbed areas on the AVX Property during the Stage 1 RA.

Transportation and Treatment/Disposal Subcontractors will be selected by BBLES upon the completion of the Stage 1 RD. These subcontractors will be retained by BBLES and will provide transportation and treatment/disposal services for all non-hazardous and RCRA characteristic hazardous waste materials generated at the AVX Property during the performance of Stage 1 RD/RA and PRGMP activities. Transportation of the waste will be performed using permitted and licensed haulers in accordance with Department of Transportation (DOT) guidelines as stated in 49 CFR, Parts 171 through 179, 6NYCRR Part 364, and any other applicable state and local regulations. All waste materials will be transported to either an approved/permitted Subtitle C or Subtitle D waste disposal facility.

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2.3 Qualifications and Resumes

The qualifications and resumes of key personnel from BBLES and BBL, as well as the qualifications for all other BBLES analytical subcontractors are included in Appendix E.

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Pre-Design Activities

3. Pre-Design Activities 3.1 General This section of the work plan addresses the activities that will be performed prior

to the preparation of the Remedial Design. These activities include:

• Evaluation of existing monitoring wells (performed in November 1987);

• Preparation and implementation of the monitoring well installation plan (new wells installed in April 1998);

• Review of wetland status of lands south of the AVX facility; and

• Performance of the Pre-Remediation Testing (PRT) program to define the area and depth of impacted soil that will be excavated and disposed off property.

The PRT is the only remaining pre-design activity to be completed.

The PRT program is based on the existing information, primarily soil boring SB-06, and will present the sample spacing, collection, and screening methods that will supply meaningful data for the Remedial Design. The area to be tested is located around previous boring SB-06 on the south side of the building as shown on Figure B-l in Appendix B.

3.2 Monitoring Well As stated in the SOW, the purpose of the PRGMP is to determine the impact of Installation Program the Stage 1 Remedial Action (soil removal) on ground-water quality. In order to

observe the anticipated improvement in water quality, it is necessary to install the complete long-term network and initiate sampling and analyses prior to the time of the source removal activity. One round of ground-water samples will be obtained prior to source removal with post-remediation ground-water monitoring beginning after source removal activities are completed.

Prior to the initiation of pre-design activities, there were 15 monitoring wells and one production well at the AVX Property that have been used for previous investigation programs and other long-term monitoring programs, 13 of which are shown on Figure 2. An up-gradient well, CDM-14, installed in the early 1980s, could not be located after several searches. In addition, there exists two downgradient clusters of wells (CW-9 and CW-10) south of the facility and south of the Consolidated Rail Corporation tracks that are part of the entire Olean Well Field Site monitoring network.

The on-site wells are designated as "S" for wells screened in the shallow overburden zone, which consists of low permeability lodgement till. The upper aquifer, which is located above the till and is present at other locations in the Olean Well Field, pinches out in the area south of the AVX Property and thus is not present Wells designated as "I" wells are screened in an intermediate zone, which is also in the glacial till at a slightly lower depth compared to the "S" wells. This till layer, which consists of greater than 50% silt and clay, is referred to as the upper aquitard at the Site. Wells designated as "D" wells are screened in the deeper zone, referred to as the upper part of the lower aquifer, which consists of

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glacial outwash deposits of sand, silt and gravel, at a depth of approximately 40 feet. This same well designation scheme is continued for new wells.

The current quarterly Olean Well Field Site Monitoring Program includes AVX-5D and nearby off-site wells CW-10 & 10A and CW-9 & 9A, all of which are downgradient of the site, are screened in the lower aquifer which is up to 70 feet thick in the northern part of the Olean Well Field.

The objectives of the PRGMP are to develop a database of ground-water information that will allow an evaluation as to:

• The effectiveness of the soil removal program to be implemented at the AVX facility (i.e., is ground-water quality improving immediately downgradient of the excavation area); and

• Whether natural attenuation (including phytoremediation) of residual ground-water impacts is occurring downgradient of the excavation area.

Phytoremediation is a technology which uses plants and their associated rhizospheric microoganisms to remove, degrade, or contain chemical contaminants in soil, sediment, and groundwater. It is an emerging technology that is the subject of a report titled "Phytoremediation of TCE using Populus" prepared for the USEPA Technology Innovation Office. Because this may be a suitable site for phytoremediation, the PRGMP data will be reviewed for an indication of this activity.

In accordance with the SOW, the PRGMP well network will provide groundwater quality and hydrogeologic data for a minimum of 4 years after the completion of the soil excavation activity at AVX and the soil remediation activities at the other Olean Well Field Sites. This data will be used in the preparation of the PRGMP Report to determine if:

• The OU2 Remedial Action Objectives have been achieved and no further action is necessary;

• A Stage 2 Remedial Action for ground water will be necessary (extraction and treatment or an alternative remedy); or

• The monitoring program shall continue for at least four additional years to be followed by another PRGMP Report and recommendations.

3.2.1 Well Evaluation A monitoring well network evaluation task was completed on November 25,1997 to assess the condition of the existing wells to determine if the wells will be able to provide accurate hydrogeologic data during the upcoming four-year (or longer) ground-water monitoring period. The recommendations of that survey were the following:

• Clear or abandon well AVX-4D, due to blockage, and replace it with a new well;

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• Repair the surface seals on wells AVX-5S, AVX-5D and AVX-6S; and

• Make certain all wells in the network have an inner cap and outer lock.

Other recommendations of the well evaluation survey were to abandon wells AVX-1B and AVX-4I which were blocked, and which were not proposed to be part of the PRGMP network. These two wells have since been abandoned by overdrilling the well and tremie grouting the borehole in accordance with Decommissioning Procedures (April, 1993) prepared for NYSDEC Division of Hazardous Waste Remediation.

Well AVX-4D was probed in an attempt to clear the obstruction. A piece of steel, several pieces of wood and rocks were removed from this well. The well was pumped/redeveloped to clear the well and determine if there was any damage to the screen. No sand pack or formation material was observed in the return flow indicating that the well is sound and suitable for use.

3.2.2 Well Installation The recently installed new wells, shown on Figure 2, were located to support the Site PRGMP data needs. New well AVX-8D is located upgradient of the facility and the contaminant source area. It will provide background water quality data necessary to evaluate water quality influences from locations upgradient of the Site. AVX-8D consists of a single well screened in the upper portion of the lower aquifer. Because the upper aquifer is not present at this location, a shallow well has not been installed. New well cluster AVX-9 (AVX-9S & AVX-9D) is located south west of AVX-5 midway between the AVX-5 cluster and CW-9 cluster. This cluster consists of a shallow till well (AVX-9S) and a well screened in the upper portion of the lower aquifer (AVX-9D). The AVX-9D well will be important in the evaluation of the deeper southwest flowing system in an area downgradient of the elevated concentrations detected at AVX-S. The third new well location, AVX-10 (AVX-10S & AVX-10D), is located in the area south of the proposed excavation and situated between the AVX-4 and AVX-6 well clusters. This location is also upgradient of the AVX-5 well cluster, which has historically shown some of the highest concentrations of VOCs in ground water. The new AVX-10 wells are placed to more directly monitor the ground water quality downgradient from the existing source area and to provide a more rapid detection of trends after the soil excavation activity is complete. This well cluster consists of an shallow till well (AVX-1 OS) and a well screened in the upper portion of the lower aquifer (AVX- 10D).

AVX continues to be concerned about the representativeness of the data from samples collected in AVX-5D. After well clusters AVX-9 and AVX-10 have been sampled and analyzed, AVX may propose additional investigation of AVX-5D.

The installation of the new AVX monitoring wells AVX-8D, AVX-9S, AVX-9D, AVX-1 OS, and AVX-10D, the rehabilitation of AVX-4D, and the abandonment of wells AVX-IB and AVX-4I was completed between April 15, 1998, and April 30,1998, in accordance with the revised Well Installation Work

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Plan submitted to USEPA on April 10, 1998. Mobilization was initiated based on verbal approval from USEPA, followed by written approval from USEPA on April 17,1998.

All wells proposed for the PRGMP are located on AVX Property (Figure 4). The PRGMP well network consists of the following existing and new monitoring wells:

Well Status Monitored Zone

Casing & Screen

Diameter (in.) Screened Interval

AVX-8D (Up gradient)

New Upper Portion of Lower Aquifer

2 34.9-39.9 feet

AVX-2 Existing Upper Portion of Lower Aquifer

4 70.0-80.04 feet

AVX-2A Existing Shallow Till 1.5 8.0-13.0 feet

AVX-4S Existing Shallow Till 4 2.7-8.0 feet

AVX-4D Existing Upper Portion of Lower Aquifer

4 32.55-39.85 feet



4 34.5-39.8 feet



4 31.2-36.5 feet

AVX-9S New Shallow Till 2 12.6-17.6 feet

AVX-9D New Upper Portion of Lower Aquifer

2 43.6-48.6 feet

AVX-1 OS New Shallow Till 2 6.3-11.3 feet

AVX-10D New Upper Portion of Lower Aquifer

2 32.8-37.8 feet

Total: 13 Wells

Analytical results from semi-annual sampling of off-site downgradient wells C W-9A and CW-10A will be in incorporated into the monitoring database. Attemps

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3.3 Wetland Delineation

will be made to synchronized the AVX PRGMP sampling with the Olean Well Field sampling.

The existing wells are constructed of stainless steel well screens and steel risers; the new wells are constructed of stainless steel screens and risers. Well completion logs showing soil boring information, well construction details, and field screening results for the newly installed wells are provided in Appendix A1.

A site survey is planned as part of the RA program that will include the location and elevation of the new and previously existing monitoring wells.

The status of the wetland area located south of the anticipated excavation area is presented in this section due to the future monitoring activities that include a portion of the area. A wetland investigation has been conducted on a portion of the Olean Well Field Site south and east of the AVX facility. The field investigation was conducted by Ebasco Services, Inc. on April 27-29,1992, with the results reported in the "Draft Wetland Declination Report, Olean Well Field Site, Olean, New York," January, 1993, under a contract with USEPA. Based on vegetation, soil and hydrological indicators, approximately 18.5 acres of wetlands were identified in the area bounded by AVX on the north, Conrail right of way to the south, and Dugan Road on the east.

This 1992 draft report performed for USEPA does, therefore, identify potential wetlands in this area. The status of any final determination of wetlands in this area is unknown. Regardless of the final status, all future sampling and monitoring activity in or near the draft delineated wetland (primarily at AVX-5, AVX-9 and AVX-10) will be performed in accordance with procedures approved by USEPA.

The future ground-water sampling events of the AVX-5, AVX-9 and AVX-10 clusters may involve work in or near potential wetland areas. As part of this plan, the applicability of State and Federal wetlands regulations was reviewed with the following findings:

• The entire area south of the facility and between Clark Street and Dugan Road southward to the Allegheny River is not a New York State designated Wetland. Mr. David Keil of the NYSDEC office in Olean, New York, indicated that the area may be wet in places; but it is not large enough (> 12.4 acres) for State designation.

• The US Army Corps of Engineers (USACE) in Buffalo, New York, was contacted and Mr. Gary McDannel with the USACE indicated that because the site is a Federal Superfund site, the USACE will not be involved. Issues of delineation, permitted activity and mitigation will continue to be coordinated through the USEPA.

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3.4 Pre-Remediation Testing Overview

All drilling and sampling activities in the wetland area will be approved by USEPA. No soil excavation activity is planned at this time based on preliminary subsurface work which indicated the estimated 40-by-40 foot excavation is located within the fenced area of the facility, out of the identified wetland. Pre-remediation testing will delineate the extent of excavation, at which time any issues that may impact the wetlands will be addressed in the Remedial Design. Pre-remediation testing will delineate the extent of excavation, at which time any issues that may impact the wetlands will be addressed in the Remedial Design.

In accordance with of the SOW, Pre-Remediation Testing (PRT) will be performed to better define the area and depth boundaries of Impacted Soil to be excavated and to properly characterize soil for off-Property treatment/disposal purposes. The boundary of the Impacted Soil at the AVX Property will be based on the soil clean up objectives presented in Section 1.4.

The PRT for delineating impacted soil will consist of installing a minimum of 25 soil borings in the vicinity of previously identified soil contamination, obtaining representative samples from each boring, and screening the samples using a organic vapor analyzer (OVA), specifically a Flame Ionization Detector (FID). The initial distribution of the soil borings is presented on Figure B-1 of Appendix B, Sampling, Analysis, and Monitoring Plan. Borings will be on a 10 feet by 10 feet grid spacing with modification of the spacing dependent on on-site screening results. Samples will be collected with continuous split spoon samples to 8 feet (anticipated to be below the water table). Samples will be warmed prior to screening. If screening levels are above the 100 ppm, a hydrophobic dye test such as SUDAN IV, or equivalent, will be used to determine the presence of NAPL in unsaturated soils. Following initial screening using the OVA, more specific, but still screening level (i.e. it will not produce Definitive Data) analytical procedures will be performed on soils from each soil boring using an on-site, laboratory-grade GC. The on-site GC will be set up in a controlled environment at the AVX Property and will be capable of low parts per billion detection of organic compound. The analytical results from the portable GC will then be compared to the recommended soil cleanup objectives outlined in Appendix II, Table 1 of the ROD to delineate the horizontal and vertical limits of excavation. This procedure will continue until the horizontal and vertical limits of the area to be excavated have been confirmed.

The impacted soil will be characterized for disposal purposes as part of the PRT once the limits of excavation have been identified. Up to four soil sample will be collected for characterization of various portions of the area of imported soil. The characterization will consist of off-site laboratory analysis of composited representative soil samples collected during the soil boring activities (VOCs will be laboratory composited). Selected samples will be submitted for TCLP analysis. Specific TCLP analytes will be determined in conjunction with the potential disposal facility's permit requirements. These analytical results will be used to determine whether the impacted soil will be managed as a non-hazardous or RCRA characteristic hazardous waste.

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The sampling and analytical procedures that will be used to perform the PRT are described in detail in the SAMP in Appendix B. The analytical data obtained from the PRT will then be used to prepare the Stage 1 RD.

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Stage 1 Remedial Design

4. Stage 1 Remedial Design 4.1 General

4.2 Preparation of the Stage 1 Remedial Design

In accordance with the SOW, the Stage l RD will include a discussion of the Performance Standards and RAOs, with an emphasis on the ability to meet the Standards and RAOs successfully. The Stage l RD will also include a basis of design (or design analysis) with documentation of how the design and associated plans and specifications will meet the requirements of the OU2 ROD.

The Stage 1 RD will include the following items, in accordance with the SOW:

• The results of the PRT and any other sampling and testing performed under the SAMP to date;

• Provisions (if necessary) for re-evaluating the selected OU2 remedy (excavation) should the results of the PRT indicate the presence of contamination significantly beyond the estimated limits outlined in the OU2 ROD;

• A description of the excavation work to be performed, including the depth of the proposed excavation, provisions for shoring of the excavation, if required, lateral extent of the proposed excavation, and provisions for off-site disposal of the excavated materials in accordance with USEPA and NYSDEC requirements;

• The methods by which the effectiveness of the excavation in meeting the RAOs will be measured including the number, depth, and location of samples to be collected; the method(s) to be used for sample collection and associated methods of sample analyses; and identification of both screening and Definitive Data methods and data points;

• Drawings illustrating the proposed excavation including the limits of excavation for the source area;

• The equipment to be utilized during excavation activities;

• The methods by which ground water encountered will be controlled and/or contained during excavation activities;

• A schedule for conducting the excavation;

• The on-site and off-site transportation routes;

• A description of temporary on-site staging areas, including drawings illustrating the staging areas;

• A description of post-excavation activities including the source(s) of imported clean fill and the types of fill material to be used; and

• A description of restoration activities including final grading and contouring of each area.

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The Stage 1 RD will also include engineering plans representing an accurate identification of existing Site conditions and an illustration of proposed work. Items that will be provided on the drawings include the following:

• A title sheet including (at a minimum) the title of the project, a key map, the name of the designer, date prepared, sheet index, and USEPA/NYSDEC Project Identification;

• Property data including owners within 200 feet of the affected Property;

• The distance and bearings of all Property lines that identify and define the Project Affected Property;

• Easements, rights-of-way, and reservations within 200 feet of the Affected Property, if any;

• All buildings, structures, wells, facilities, equipment on the Property (existing and proposed), including interim remedial measures within 200 feet of the Affected Property, if any;

• A topographic survey extending out 200 feet from the Affected Property, including existing and proposed contours and spot elevations for all areas that will be affected by the Stage 1 RA, based on United States Geological Survey (USGS) data;

• All utilities, existing and on-Property proposed within 200 feet of the Affected Property;

• The location and identification of all significant natural features including inter alia, wooded areas, water courses, wetlands, flood hazard areas, and depressions within 200 feet of the Affected Property;

• Flood hazard data and delineation, if applicable, within 200 feet of the Affected Property;

• The north arrow, scale, sheet numbers, and the person responsible for preparing each sheet;

• Decontamination areas, staging areas, on-Property borrow areas, and stockpiling areas;

• Miscellaneous detail sheets; and

• The definitions of all symbols and abbreviations.

Additionally, the Stage 1 RD will include the following items:

• A plan for photographic documentation of the Stage 1 RA work;

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• A discussion of how the Stage 1 RA will achieve the Performance Standards; and

• A schedule for Stage 1 RA activities and a preliminary schedule for PRGM activities to be approved by USEPA. The schedule will show remedial construction activities reflecting completion of construction and preliminary schedule for Post-Remediation Groundwater Monitoring activities to be approved by USEPA. The schedule will be in the form of a Task/Subtask activity bar chart and indicate all required deliverables.

4.3 Updated Project Management Plan

4.4 Updated Post-Remediation Ground-Water Monitoring Program

As part of the Remedial Design, the PMP, will be updated based on information developed during the Pre-Design Activities. Updates may include modifications of the anticipated excavation program, including the sequencing and methods of excavation, decontamination and restoration. Factors such as proximity to the existing structure or the adjacent wetlands, based on the PRT results, may alter the program.

Any program modifications which result in a change in project staffing or subcontractors will be noted in the updated PMP. The updated PMP will also include, as necessary, preparations for security, utilities, decontamination facilities, storage and temporary office space. Coordination of excavation, transportation and disposal, along with the AVX Facility operations (pick-ups and deliveries, etc.), will be addressed; traffic issues, if any, will be coordinated with local authorities.

Control of the work site will be addressed, including security and 24-hour entry and access to the work area. Finally, equipment decontamination and dust control will be addressed.

Because the volumes of soil to be excavated and the relative ease of access, the duration of the excavation activity should be brief with existing site fencing providing a large measure of site control.

The PRGMP will be re-evaluated as part of the Stage IRD activities. If the PRT data or other inputs to the RD suggest that the source area is substantially different in size, thickness, shape, location, or composition than currently estimated, the PRGMP will be modified, if necessary, to provide for collection of appropriate data based on the new conditions.

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5. Access Approvals & Permits 5.1 General This section identifies the Site access and institutional controls, as well as any

Property access agreements, permits, and off-site disposal approvals (excluding those necessary from EPA) that may/will be required to implement the Stage l RD/RA and PRGM activities at the AVX Property. Any agreements, permits, and approvals, if required, will be obtained by BBLES and reviewed with USEPA prior to performing the Stage 1 RD. This section of the RD/RA Work Plan may need to be modified based on the information included in the Stage 1 RD.

In accordance with Section 25a of the Consent Decree, access to the AVX Property will be provided to USEPA and NYSDEC, and their representatives, for the duration of the Stage 1 RD/RA. Also, in accordance with Section 25b of the Consent Decree, the following land use/water restrictions will be implemented at the AVX Property for the duration of the Stage 1 RD/RA:

• Refrain from installing or using any ground-water wells downgradient or upgradient of the source area, except for any production wells or monitoring wells currently being used at the AVX Property, new monitoring wells that will be used for the PRGMP, or as approved by USEPA;

• Refrain from decreasing the rate of withdraw from the production wells currently being used at the AVX Property unless for routine business operations or as approved by USEPA. (According to the ROD, the AVX production well is pumping at approximately 50 gpm.);

• Refrain from excavating areas within the AVX Property, other than the proposed excavation for the Stage 1 RA; for the maintenance, repair, or removal of utility facilities; or as approved by USEPA; and

• Refiain from constructing or erecting any temporary or permanent structure over the Affected Property, other than that required for the implementation of the Stage 1 RD/RA or as approved by USEPA.

5.3 Access Agreements In accordance with the OU2 ROD, USEPA has identified the source area to be for Adjacent on the AVX Property around soil borings SB04 and SB06, with an estimated Properties excavation volume of approximately 10,000 cubic feet (based on a maximum

depth of six feet). Although the limits of excavation may increase based on the results of the pre-remediation testing (previously discussed under Section 3.4), the OU2 ROD does not require soil excavation to continue beyond the AVX Property line. Based on this information, it is anticipated that all construction activities associated with the Stage 1 RD/RA and PRGMP will be performed within the AVX Property; therefore, Property access agreements from adjacent Property owners should not be required for this project.

Based on the review of previous site drawings, the McGraw-Edison sanitary sewer easement runs across the southern portion of the AVX Property, south of the fenced portion of the Site. During the performance of Stage 1 RD/RA and PRGMP construction activities, access within this easement area may be required.

5.2 Site Access and Institutional Controls

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Therefore, an easement access agreement with McGraw-Edison will be obtained, if necessary, for the duration of the project, in accordance with Section 26 of the Consent Decree.

5.4 Permitting Requirements

5.5 Off-Site Disposal Approvals

In accordance with Section V - General Provisions, Item 8 - Permits of the Consent Decree, no environmental permit will be required for the Stage 1 RD/RA and PRGMP work since it is identified as an on-site remedial action. However, the selected off-site waste disposal facilities that will be receiving waste materials from the AVX Property will be required to possess all appropriate environmental permits necessary to dispose the waste materials in accordance with all federal, state, and local laws.

At this time, it is not anticipated that any non-environmental construction permit or approval is required during the performance of Stage 1 RD/RA and PRGMP. However, during the performance of the Stage 1 RD, BBL will contact the local municipalities to confirm whether or not any non-environmental construction permits) or approval(s) are required.

During the implementation of Stage 1 RD/RA and PRGMP activities, solid and liquid waste materials that are generated from the AVX Property will be disposed of at either an approved off-site permitted Subtitle C or Subtitle D waste disposal facility. Prior to transporting waste materials off site, samples of the waste materials will be collected and submitted to an off-site laboratory for Toxicity Characteristic Leaching Procedure (TCLP) analyses and any other analyses required by the disposal facility to characterize the waste and determine whether the waste will be managed as a RCRA characteristic hazardous or non-hazardous waste.

Once the waste materials have been properly characterized, a waste profile will be prepared for each waste stream and submitted to the selected waste disposal facility for approval. Each waste disposal facility will review each corresponding waste profile and provide written verification stating their regulatory authority and their approval to accept the specified waste stream at their facility.

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Stage 1 Remedial Action and Post-Remediation Ground-Water Monitoring

6. Stage 1 Remedial Action and Post-Remediation Ground-Water Monitoring

6.1 General This section identifies the Stage l RA and PRGMP activities that will be implemented at the AVX Property by BBLES, in accordance with the OU2 ROD, SOW, and Consent Decree. These Stage 1 RA and PRGMP activities will be implemented after receiving the USEPA's approval of the Stage 1 RD, the Stage 1 RA schedule, and remedial construction contractor, and is anticipated to consist of the following tasks:

Task 1 Mobilization;

Task 2 Site Preparation;

Task 3 Excavation;

Task 4 Waste Transportation and Disposal;

Task 5 Site Restoration;

Task 6 Pre-Final Site Inspection;

Task 7 Demobilization;

Task 8 Pre-Certification Site Inspection;

Task 9 Preparation of Stage 1 Remedial Action Report; and

Task 10 Post-Remediation Ground-Water Monitoring.

The Schedule for the Stage 1 RD/ RA and PRGMP is a component of the PMP, as identified in Section C5 of the SOW, and may need to be modified based on the information included in the Stage 1 RD.

6.2 Task 1-Mobilization Under this task, all required manpower, materials, construction equipment, and decontamination equipment will be mobilized at the Site for the implementation of Stage 1 RA activities. Also, the mobilization task will include:

• Identifying the location and staking out all above-ground and/or underground utility lines and structures that may be in the vicinity of the Remedial Action activities;

• Ensuring that all necessary construction permits, if any, are acquired and available at the Site;

• Staking out the limits of excavation and locations of other Site facilities;

• Providing an office trailer or equivalent for BBLES and their subcontractors) at the Affected Property;

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• Providing potable water at the Affected Property;

• Providing and maintaining an on-site portable toilet facility and any other necessary support facilities at the Affected Property; and

• Ensuring that RA Site personnel have the proper training and medical monitoring documentation to perform Site activities.

6.3 Task 2 - Site Preparation

6.4 Task 3 - Excavation of Impacted Soil

The Site preparation activities will include all activities, as necessary, to prepare the Affected Property for the implementation of Stage 1 RA activities. At a minimum, site preparation activities will include the following:

• Construction of an on-site decontamination pad at a location that will not impede the movement of vehicles at the Affected Property. The decontamination pad will be used to decontaminate equipment/vehicles used during remediation activities and will consist of a six-inch high perimeter berm, a plastic liner along the bottom of the pad, approximately six inches of gravel over the liner, and a sump to collect any water that accumulates in the pad;

• Installation and maintenance of temporary erosion control/protection devices, as necessary, between the limits of excavation and any adjacent existing drainage pathways/structures. Sediment will be controlled to minimize off-site immigration;

• Clearing of vegetation around the limits of excavation and any other access areas;

• Construction of an on-site temporary access road, as necessary, to accommodate construction equipment during remediation activities;

• Construction of an on-site support area, as necessary, to store equipment and construction materials;

• Construction of temporary diversion ditches/swales, as necessary, to divert any runoff away from the proposed limits of excavation and to maintain the flow of any existing drainage pathways; and

• Installation of temporary orange construction fencing to limit unauthorized access into the portion of the Affected Property impacted by remediation activities.

This task includes the excavation of soil from the proposed limits of excavation, as outlined in the Stage 1 RD. The limits of excavation will be determined based on the results of the pre-remediation testing (Section 3.4). Based on the information included in the OU2 ROD, the excavated soils will contain VOCs as identified in Section 1.4.

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During excavation activities, the following control measures will be implemented:

• Surface water will be directed away from the excavation to prevent erosion and flow of surface water into the excavation (as discussed previously in Section 6.3). This will be monitored continuously during the performance of the excavation activities;

• Excavated sloped surfaces will be protected, as necessary, to prevent erosion and/or sloughing. Excavation near buildings, if necessary, will be sloped away from the structure at a 1.5 : 1 slope;

• Areas surrounding the excavation will be monitored during excavation activities to ensure that it is draining effectively. Also, the temporary erosion control/protection devices will be monitored continuously during the performance of excavation activities;

• Traffic routes will be established and monitored continuously for construction equipment and transport vehicles on site during remediation activities to minimize the potential interruption of activities at the AVX facility. Also, traffic routes will be established off-site for transport vehicles to minimize the impact of traffic within the local community and ensure that the transport vehicles are traveling on the appropriate roadways, in accordance with DOT requirements;

• Adjacent public roadways will be visually monitored and cleaned, as necessary, to remove any materials that may spill on the roadway as a result of the on-site construction activities;

• Measures will be provided, if necessary, to control any odors or dust that may emit from the impacted soils during excavation activities. These odor or dust control measures may need to be applied to exposed soils within the excavation and/or the soil container of the transport vehicle;

• The excavation will be dewatered, as required, using a submersible or centrifugal pump. All accumulated water will be pumped to an on-site 1,000-gallon polyethylene holding tank and will be characterized to determine proper disposal requirements;

• Air monitoring will be provided in the breathing zone within and along the downwind perimeter of the excavation in accordance with the HASCP (Appendix D);

• Excavation activities that are conducted near any identified under-ground utility and/or structure will be excavated manually, as necessary, to protect the integrity of the utility and/or structure; and

• At the end of each work day, the excavated area will be barricaded appropriately (i.e., orange construction fencing, barriers, or yellow caution

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tape) to prevent unauthorized individuals from entering the excavation when RA personnel are off the site.

It is anticipated that excavation activities will be conducted using a track excavator and that the excavated soil will be loaded directly into transport vehicles for transport to the appropriate non-hazardous or RCRA characteristic hazardous waste disposal facility. If soil screening results during excavation indicate contamination at or below the water table, die excavation will proceed to a depth of up to 24 inches below the water table, pending other restrictions such as structural integrity of the building foundation or excessive water. Soils may be segrated into non-hazardous and hazardous soils based on Pre-Remediation Testing results from PRT borings which will be located on ten-foot spacing. It is anticipated that the transport vehicles will be positioned along the temporary access road and the track excavator will be positioned within the proposed limits of excavation. Any excavated soil that is saturated will be addressed appropriately (i.e., solidification) to ensure that the soil is suitable for off-site transportation/disposal and that free liquids (per paint filter test) are not present in the excavated soil.

Upon the removal of impacted soil from the limits of excavation, post-remediation verification samples will be collected from the base and sidewalls of the excavation, in accordance with the Post-Excavation Soil Verification Sampling Plan (Appendix B, Section B.4.1). These samples will be analyzed for die COCs to determine if the clean-up goals for each compound have been achieved. If the analytical results indicate that the clean-up goal for each compound have not been achieved, additional excavation and sampling will be required until the clean-up goal has been achieved for each COC or the excavation is up to the limits of the AVX Affected Property. Once die analytical data indicates that the clean-up goal for each COC has been achieved or the excavation is at the limits of the AVX Affected Property, backfilling will commence as discussed in Section 6.6.

Prior to loading excavated soil into a transport vehicle, die transport vehicles's soil container will be lined with polyethylene sheeting or an appropriate bed liner. After the vehicle has been loaded, a tarpaulin will be placed over the top of the transport vehicle's container and secured. Prior to exiting the Site, the wheels and undercarriage of the transport vehicle will be inspected for any accumulated soil and will be decontaminated, if necessary, at the on-site decontamination pad to prevent tracking off site. Also, a non-hazardous or hazardous manifest form will be filled out and signed appropriately for each transport vehicle before die vehicle departs from the Site.

This section will outiine the procedures for transporting and disposing of any non-hazardous or RCRA characteristic hazardous solid or liquid wastes generated at the AVX Property during Stage 1 RD/RA and PRGMP activities. These wastes will be properly managed to minimize environmental impacts and to comply with all applicable federal, state, local laws and regulations. These procedures, in conjunction with applicable non-hazardous and hazardous waste manifests, will govern the waste from its point of origin to its final destination.

6.5 Task 4-Off-Property Transportation and Disposal of Waste

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Prior to performing excavation activities at the AVX Property, written verification from each proposed USEPA-approved non-hazardous and RCRA characteristic hazardous waste transporter and disposal facility will be provided based on the existing soil and water waste characterization analytical data, which will be generated during the pre-remediation testing (Section 3.4). The proposed waste transporters and disposal facilities will be in compliance with all applicable federal, state, and local laws and regulations and will have all of the required licenses and permits.

6.5.1 Non-Hazardous All solid and liquid waste will be transported off site by a licensed USEPA-and Hazardous approved hauler, in accordance with the DOT guidelines as outlined in 49 CFR, Waste Parts 171 through 179, 6NYCRR Part 364, and any other applicable state and Transportation local regulations. Each shipment of solid or liquid waste generated at the AVX

Property must be properly characterized, containerized, loaded, and manifested prior to exiting the Site. Also, the waste transporters must carry with them a copy of the applicable waste transporter's permit and license, as required.

A non-hazardous bill of lading or hazardous manifest will be prepared and completed for each shipment of solid or liquid waste prior to exiting the Site. The bill of lading or manifest will include, at a minimum, the following information:

• Sufficient information for the waste transporters to do their job safely and lawfully;

• Sufficient information for emergency response personnel who would respond in the event of an incident or spill involving the waste;

• The waste classification and the estimated weight or volume of the waste material;

• The names of the waste generator (AVX Corporation), transporter, and waste disposal facility and their USEPA Identification Numbers, where required;

• A declaration that the generator of the waste has characterized the waste properly before asking the transporter to haul the waste. This will require a signature from either the generator or the generator's representative; and

• A signature from the driver of the transport vehicle which acknowledges receipt/acceptance of the waste material and acceptance of responsibility for the transportation of the waste material to the appropriate waste disposal facility.

The transporter must possess the signed non-hazardous bill of lading or hazardous waste manifest when transporting the waste material to the waste disposal facility. The transporter also will be responsible for traveling along the designated truck routes. Also, the transporter must have the proper labels and placards on the waste containers when transporting the waste materials off site. Once arriving at

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the waste disposal facility, the manifest must be given to the waste disposal facility as it accepts the waste material at their facility.

6.5.2 Non-Hazardous and Hazardous Waste Disposal

6.6 Task5-Site Restoration

All solid and liquid waste materials generated at the AVX Property will be characterized as a specific waste stream and will be managed as either a non-hazardous or RCRA characteristic hazardous waste. The solid and liquid waste materials will be characterized for disposal purposes in accordance with the procedures identified in Appendix B Sections B.2.2 and B.4.2, respectively.

Solid waste materials generated at the AVX Property during the Stage 1 RD/RA and PRGMP activities include, but are not limited to, contaminated soil from excavating the source area; roots; tree stumps; concrete; asphalt; rocks/cobbles; and construction materials (i.e., stone, polyethylene, fence posts, silt fence, personal protective equipment, piping). The solid waste materials will be disposed of as follows:

• All solid RCRA characteristic hazardous waste materials removed from die AVX Property will be transported to an USEPA-approved and permitted Subtitle C waste disposal facility for treatment (via a chemical oxidation process) followed by landfilling. A Certificate of Disposal will then be issued by the waste disposal facility to verify that the hazardous waste specified on the corresponding manifest was properly disposed in accordance with all local, state, and federal regulations; and

• All non-hazardous waste materials removed from the AVX Property will be transported to an USEPA-approved, state permitted Subtitle D waste disposal facility for landfilling.

Liquid waste materials which are generated at the AVX Property during the Stage 1 RD/RA and PRGMP activities include, but are not limited to, decontamination water, and contaminated surface water. The liquid waste materials will be disposed of as follows:

• All liquid RCRA characteristic hazardous waste materials removed from the AVX Property will be transported to an USEPA-approved and permitted Subtitle C waste disposal facility for treatment; and

• All non-hazardous waste materials removed from the AVX Property will be either transported to an USEPA-approved, state permitted Subtitle D waste disposal facility for treatment or discharged to AVX's on-site wastewater treatment system, if allowable under the Facility's industrial pretreatment permit or by specified permission of the City of Olean.

Once the analytical results of the post-remediation verification sampling have determined that the excavated area has achieved the established clean-up goals for the COCs, the excavated area will be backfilled with clean suitable imported backfill material(s) to restore the area and match the original grades/contours.

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Any equipment used during the excavation phase will be decontaminated prior to being used for backfilling activities. The backfilling and quality control procedures that will be used for placing die material will be included in detail in the Stage 1 RD.

To verify that no contaminants are present in the imported backfill material(s), samples of soil from each backfill source will be collected, prior to restoration activities, and submitted to an off-Property laboratory for analyses, as discussed in Appendix B, Section B.3.

Also, all other areas that were disturbed during the performance of Stage 1 RA activities (i.e., asphalt or concrete areas, grass areas, structures, monitoring wells, chain link fencing, underground utilities) will be restored back to their original conditions. Specific procedures for implementing these restoration activities at the AVX Property will be described in detail in the Stage 1 RD.

6.7 Task 6 - Pre-Final At least 14 days prior to the completion of the Stage 1 RA, AVX and its Site Inspection Supervising Contractor will request and accompany USEPA personnel (or

representatives) on a pre-final inspection of the Affected Property. The pre-final inspection will consist of a Site walk of the Affected Property to determine the completeness of the Stage 1 RA and consistency with the Stage 1 RD, Consent Decree, SOW, OU2 ROD, and applicable federal, state, and local laws, rules, and regulations. Based on the expected duration of the excavation activity, the USEPA personnel will be notified of an expected date for a pre-final inspection prior to the start of the excavation activity.

Upon the completion of the pre-final inspection, USEPA will either determine that the Stage 1 RA is complete or will specify the necessary corrective action(s) to be implemented to the Stage 1 RA, including a brief description of the deficient construction items (i.e., punch list). If corrective action(s) is required, the appropriate corrective measures will be implemented in accordance with a schedule approved by the USEPA. Within 14 days after the corrective action(s) have been completed, AVX and its Supervising Contractor will accompany USEPA personnel (or representatives) again to perform a pre-final inspection on the corrective action(s). This procedure will continue until USEPA has determined that the Stage 1 RA is complete.

6.8 Task 7 - Once USEPA has determined that die Stage 1 RA is complete, all equipment will Demobilization be decontaminated, as required, and all temporary erosion control/protection

devices, access roads, staging areas, diversion ditches/swales, and the decontamination pad will be removed and the areas will be restored to their original conditions. All construction materials associated with these items will be transported and disposed off-Property appropriately.

Next will follow the demobilization of site facilities, construction equipment, materials, supplies, and personnel, as well as the termination of any site-specific permits that may have been associated with the Stage 1 RA.

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Within 90 days after AVX and its Supervising Contractor conclude that the Stage 1 RA has been completed and the RAOs and Performance Standards have been achieved, AVX and its Supervising Contractor will schedule and conduct a pre-certification inspection of the Property with USEPA (or representatives).

Upon completion of the pre-certification site inspection, a Draft Stage 1 Remedial Action Report (RAR) will be prepared and submitted to USEPA and NYSDEC, in accordance with Section G.4.c of the SOW and Section XIV of the Consent Decree. This written report will be signed and stamped by a NYS-licensed professional engineer and will summarize all Stage 1 RA activities conducted at the Affected Property and document how the Performance Standards have been met in accordance with the Consent Decree, SOW, and OU2 ROD.

The Draft Stage 1 RAR will include the following information:

• Notice of Completion - This will acknowledge and certify that the Stage 1 RA has been completed in full satisfaction of the requirements of the USEPA RD/RA Work Plan, Stage 1 RD Report, SOW, and applicable federal and state laws. This section will be signed and stamped by a NYS-licensed Professional Engineer;

• Performance Standards and Construction Quality Control - This will include documentation to verify that the Performance Standards have been achieved at the AVX Property in accordance with the Consent Decree and OU2 ROD. The performance standard shall be addressed by providing each standard, the maximum level permissible, the basis for determing that the standard is met, the location and frequency of the tests and the results of field sampling. It will also provide a summary of the Construction Quality Assurance Project Plan implementation and provide an assurance that the Stage 1 RA was completed in accordance with the Stage 1 RD Report, OU2 ROD, and Consent Decree;

• Construction Activities - This will include a narrative description of the construction activities performed during the Stage 1 RA, including appropriate time frames; materials and equipment used; quantities of solid and liquid waste transported and disposed off Property, analytical results of soil and water samples collected; the names and role of the design and Stage 1 RA contractors; and a statement verifying that all construction equipment used during construction has been decontaminated and demobilized from the Site. If the Stage 1 Remedial Action, as implemented, differs in any way from the approved plans and specifications of the final Stage 1 Design Report, the modification and reason for the modification will be reported in detail;

• As-Built Engineering Drawings - This will include as-built engineering drawings for the RA which will be signed and stamped by a NYS-licensed Professional Engineer;

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6.9 Task 8 - Pre-Certification Site Inspection

6.10 Task 9-Preparation of Stage 1 Remedial Action Report

• Photographs - This will include photographs and/or slides and video tapes that show the AVX Property prior to commencing Stage 1 RA activities, progress of Remedial Construction activities, and appearance of the AVX Property after Stage 1 RA activities have been completed;

• Final Inspections - This will document the pre-final and final inspections by USEPA, AVX, and the Supervising Contractor. This will also include a description of the deficient construction items reported, including final resolution of all deficient items, and a list of attendees at the inspections;

• Summary of Project Costs - This will include a summary of the final costs for the Stage 1 RA and a comparison with the original Stage 1 RA estimate; and

• Certification Statement - This will include a statement signed by a responsible corporate official of AVX or AVX's Project Coordinator, consisting of the following:

"To the best of my knowledge, after thorough investigation, I certify that the information contained in or accompanying this submission is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."

The USEPA will either approve the Draft Stage 1 Remedial Action Report (RAR), thus making it the Final Stage 1 RAR, or require modifications of it in accordance with Section XI in the Consent Decree. Upon approval of the Final Stage 1 RAR, USEPA will certify completion of the Stage 1 RA.

6.11 Task 10-Post-Remediation Ground-Water Monitoring

Within 30 days of the Pre-Certification Inspection, AVX will submit to EPA any updates and/or amendments to the RD/RA Work Plan, if necessary, to implement the PRGMP and to finalize the PRGMP Schedule. Upon the completion of Stage 1 RA activities, the USEPA-approved PRGMP Plan (Appendix B, Section B.5) will be implemented to monitor the ground-water quality within the AVX Property and to evaluate the effectiveness of the Stage 1 RA. Individual monitoring reports will be submitted after each sampling round detailing the results of that round. Within 4 years of the completion of the soil remediations at the AVX source area, a Draft PRGMP Report will be submitted by AVX which evaluates the results of the PRGM to date, including the ground-water quality data, and the rate of improvement in the ground-water quality.

In general, the Draft PRGMP Report will document the work performed and summarize the analytical data generated through the PRGMP, in accordance with the USEPA-approved PRGMP Plan. In addition, the Draft PRGMP Report will apply the criteria included in the OU2 ROD as a basis for USEPA to make one of the following decisions:

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• The 0U2 RAOs have been achieved and no further remedial action is need and the PRGMP is complete;

• The OU2 ROD Stage 2 RA (ground-water pump and treat system) will be initiated. This will include the development and implementation of another SOW for the design, construction, and operation of the Stage 2 RA; or

• The PRGMP will be continued for at least another four years, followed by the preparation of another PRGMP Report.

The Draft PRGMP Report will include a statement indicating that the PRGMP was implemented in full satisfaction of the Consent Decree, SOW, and OU2 ROD and all plans, specifications, schedules, reports and other items developed under SOW. USEPA will then review the Draft PRGMP Report and either approve it or require modification^). Upon approval of the draft PRGM Report, EPA will determine whether: 1) Post Remedial Ground-Water monitoring is complete; 2) the Stage Two Remedial Action is required; or 3) the PRGM shall be conducted for an additional four years followed by the submittal of an additional PRGM Report.

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Monthly Reporting and Documentation

7. Monthly Reporting and Documentation

7.1 General

7.2 Monthly Reports

This section identifies the monthly reporting and documentation requirements that will be implemented during the performance of the Stage 1 RD/RA and PRGMP activities, in accordance with Section X of the Consent Decree. A description of the monthly reporting and documentation requirements is presented below.

During the performance of Stage 1 RD/RA, written monthly progress reports will be prepared, in accordance with Paragraph 30 of the Consent Decree, and submitted to USEPA and NYSDEC by the tenth day of every month until USEPA certifies completion of the Stage 1 RD/RA and PRGMP. These monthly reports will include:

• A description of the actions that have been taken toward achieving the Consent Decree during the previous month;

• A summary of all sampling analytical results and all other data received or generated during the previous month;

• A summary of all work plans, reports, or other deliverables required for the project that were completed and submitted during the previous month;

• A description of all actions which are scheduled for the next six weeks and other information related to the progress of construction;

• Information regarding the percentage of the project complete;

• Information regarding any unresolved delays encountered or anticipated that may affect the future schedule and a description of efforts to be made to mitigate those unresolved or anticipated delays;

• A summary of any modifications made to work plans or schedules that have been proposed to or approved by the USEPA during the previous month; and

• A description of all activities undertaken in support of the Community Relations Plan during the previous month and to be undertaken in the next six weeks.

7.3 Miscellaneous In accordance with Paragraphs 31,32,33,34, and 35 of the Consent Decree, the Documentation following miscellaneous document requirements will be implemented during the Requirements performance of Stage 1 RD/RA and PRGMP activities:

• USEPA will be notified of any change in the schedule described in the monthly reports for the performance of any activity no later than seven days prior to the performance of the activity or within a shorter period, if in the event of an emergency and the required seven-day notice can not be provided;

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• The USEPA will be orally notified upon the occurrence of any event during the Stage 1 RD/RA and PRGM that requires a report pursuant to Section 103 of CERCLA, 42 U.S.C. §9603, or Section 304 of the Emergency Planning and Community Right-to-know Act (EPCRA), 42 U.S.C. §11001 et seq. Within 20 days of the onset of this type of an event, a written report will be submitted to the Plaintiff, signed by AVX's Project Coordinator, identifying the events that occurred and the measures taken, and to be taken, in response thereto. Within 30 days of the conclusion of such an event, a report will be submitted to the Plaintiff identifying all actions implemented in response thereto;

• Copies of all plans, reports, and data required by the USEPA-approved RD/RA Work Plan, Consent Decree, and SOW will be submitted to the individuals at the addresses specified below:

1. Three copies submitted to:

Chief, New York Remediation Branch Emergency and Remedial Response Division U.S. Environmental Protection Agency, Region II 290 Broadway, 20th Floor New York, NY 10007-1866 Attn: Mr. Damien Hughes, Olean Wellfield Superfund Site Remedial

Project Manager

2. Two copies submitted (unless the document is a plan or report, in which case 4 copies will be submitted) to:

Director, Division of Environment Remediation New York State Department of Environmental Conservation Room 242 50 Wolf Road Albany, NY 12233-7010 Attn: Mr. Wayne Mizerak

3. Seven copies submitted to:

CENWK-PE-EB 601 East 12th Street Kansas City, MO 64106-2895

4. One copy submitted to:

Chief, New York/Caribbean Superfund Branch Office of Regional Counsel U.S. Environmental Protection Agency, Region II 290 Broadway, 17th Floor New York, NY 10007-1866 Attn: Ms. Sharon Kivowitz, Olean Wellfield Superfund Site Attorney

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Mr. Vivek Nattanmai New York State Department of Environmental Conservation 50 Wolf Road Albany, NY 12233

Chief, Environmental Enforcement Section Environment and Natural Resources Division U.S. Department of Justice P.O. Box 7611 Washington, D.C. 20044-7611 Re: DOJ#90-11 -2-181B

Mr. Larry Blue, Corporate Env. Engineer AVX Corporation 17th Avenue South P.O. Box 867 Myrtle Beach, SC 29577

Mr. G. Robert Witmer, Jr. and Ms. Libby Ford Nixon, Hargrave, Devans & Doyle, LLP P.O. Box 1051 Rochester, NY 14603-1051

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Section 8 BBL ENVIRONMENTAL SERVICES. INC.


Project Schedule

8. Project Schedule The project schedule for implementing the Stage 1 RD/RA and PRGMP is presented on Figure 5. This project schedule presents milestones for completing all components identified in the RD/RA Work Plan and includes assumed timeframes for the USEPA and NYSDEC to review and approve documents associated with the work. To the extent these assumed review and approvals time frames are not met, all subsequent milestones will automatically be extended/shortened by an appropriate amount of time. The schedule has been prepared to outline the order and timing of events necessary to perform the Stage 1 RD/RA and PRGMP, in accordance with the Consent Decree, SOW, and OU2 ROD. The implementation of the Stage 1 RD/RA and PRGMP begins with EPA's authorization to proceed and ends with the USEPA's approval of the PRGMP Report. Any changes/modifications to this project schedule will be submitted to USEPA for review and approval prior to implementation. The project schedule is a component of the PMP, as identified in Section C5 of the SOW, and may need to be modified based on the information included in the Stage 1 RD.

The Stage 1 Remedial Activity is currently scheduled to be performed during the early spring months. A pre-design field work schedule will be provided to EPA at least 14 days prior to mobilization. The notice will include:

1. Mobilization start and completion date. 2. Dates and durations for all site work efforts.

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Tables

B B L E N V I R O N M E N T A L S E R V I C E S . I N C .

TABLE 1 AVX Facility

Olean, New York Soil Borings

TCL Volatile Organic Compound Concentrations November-1991

Parameter*

Acetone -J Benzene -J Bromodichloromethane -J Bromoform -J Bromomethane -J 2-Butanone • J Carbon Disulfide -J Carbon Tetrachloride -J Chlorobenzene -J Chloroethane -J Chloroform -J Chloramethane -J tie -1.3 - Oichloropropane -J

-J 1,1 -OkJiioroethane -J 1,1 - Dichioroethene -J 1,2-Olchiotoethane -J 1,2 - Dichioroethene (total) -J 1,2-Dtchk>rpropane -J Ethyl benzene -J 2-Hexanone -J Methylene chloride -J 4 - Methyl - 2 - pentanone • J Styrene -J Tetrachloroethene 14 J 1,1 A2 - Tetrachloroethane -J 1,1,1 - Trichloroethane -J 1,1 J! - Trichloroethane -J Toluene -J trans -1,3 - Dichloropropene -J Trichloroethene -J Vinyl Chloride -J Xylene (total) -J

28 UJ 13 OJ

130

24 UJ

4 J

3 J

13000 UJ* * J

1400 U' 13 UJ 210 J 43 34

26

UJ

Notes: * All concentrations in micrograms per kilogram (ug/kg) dry weight -: The compound was analyzed for, but not detected at the sample quantitation limit (quantitation limit x dilution factor). J: Estimated value U: The compound was analyzed for, but not detected at the limit indicated. **: Compound concentration is at a secondary dilution factor of 180. ***: Compound concentration is at a secondary dilution factor of 140. Source: Supplemental Remedial Investigation Report Olean Wbll Field, Olean, New York, October 1994 by Geraghty and Miller. Inc.

avxsb1.xls Page 1 of2 12/24/98

TABLE 1 (cont) AVX Facility

Olean, New York Soil Borings

TCL Volatile Organic Compound Concentrations March-1993

• i • Si© 'I*

: • ....... . , , | i ' I . . 'fSc' | . 1 -J,i

! . . riMi' • i •i&i ... aBLii . -JeSi . 1 -J,i JllL** J L. i ; . . j |

Parameter*

Acetone 280 U J 17 U J 66000 J 110000J 76000 J 24000 J

Benzene -J * -J

Bromodichloromethane -J - -J

Bromoform -J - -J

Bromomethane -J - -J

2-Butanone -J -J - -J

Carbon Disulfide -J - -J

Carbon Tetrachloride -J - -J

Chlorobenzene -J - -J

Chloroethane -J -J -J -J -J - J

Chloroform -J - -J

Chloromethane -J -J -J -J - J

cis -1,3 - Dichloropropane -J - -J

Dibromochloromethane -J - - J

1,1 - Dichloroethane 1300 J - 2200 J

1,1 - Dichloroethene -J - -J

1,2 - Dichloroethane -J • -J

1,2 - Dichloroethene (total) 5400 J 45000 J 5200 J

1,2 - Dichlorpropane -J - - J *

Ethyl benzene 4000 J - 1000 J

2 - Hexanone -J -J - -J

Methylene chloride 2 J 17000 UJ - 9300 U J

4 - Methyl - 2 - pentanone -J -J -J - -J

Styrene - -J - -J 430 J Tetrachloroethene 610 53 92000 J 270000 J 24000J 430 J

1.1,2.2 - Tetrachloroethane -J - -J

1,1,1 - Trichloroethane 54 J 220000 J 1300000 J 140000J

1,1,2 -Trichloroethane -J -

Toluene 16000 UJ - -J

trans -1,3 - Dichloropropene -J - -J

Trichloroethene 29 J 92000 J 500000 J 52000J

Vinyl Chloride -J - -J 480 J | Xylene (total) 9 J 28000 J 73000 J 7000 J 480 J |

Notes: * All concentrations in micrograms per kilogram (ug/kg) dry weight. -: The compound was analyzed for, but not detected at the sample quantitation limit (quantitation limit x dilution factor). J : Estimated value U : The compound was analyzed for, but not detected at the limit indicated. ** : Compound concentration is at a secondary dilution factor of 180. ***: Compound concentration is at a secondary dilution factor of 140. Source: Supplemental Remedial Investigation Report Olean Well Field, Olean, New York, October 1994 by Geraghty and Miller, Inc.

avxsbl xls Page 2 of 2 12/24/98

TABLE 2 AVX Facility

Olean, New York Shallow Till and Lower Portion of Lower Aquifer

Ground-Water Volatile Organic Compound Concentrations October 1984 to November 1984

Parameters *

Chloroethane Chloroform 1 , 1 - D i c h l o r o e t h a n e 1 . 1 - D i c h l o r o e t h y l e n e 1 . 2 - D i c h l o r o e t h a n e 1,2- Dichloroethylene Methylene chloride Tetrachloroethylene Trans -1,2- Dichloroethylene Trichloroethylene 1,1,1-Tri chloroethane Vinyl chloride

280

950 14

TR 210 200 270

1100 51 52 180

Notes: * All concentrations in parts per billion (ppb). Blank spaces indicate concentrations less than detection limit.

(R) = replicate sample. Source: Characterization of Shallow Ground-Water Conditions at the AVX Facility, Olean, NewYork, August

1985, Geraghty and Miller. Inc.and Site Monitoring Plan Fourth Quarter 1997 Olean Well Field Site, Earth Science Consultants, Inc. December 1997.

avxgw1.xls 1 of3 12/22/98


Olean, New York Shallow Till

Ground-Water Volatile Organic Compound Concentrations April 1985 to May 1985

Parameters *

Chloroethane Chloroform 1 , 1 - D i c h l o r o e t h a n e 1 . 1 - D i c h l o r o e t h y l e n e 1 . 2 - D i c h l o r o e t h a n e 1,2- Dichloroethylene Methylene chloride Tetrachloroethylene Trans -1,2- Dichloroethylene Trichloroethylene 1,1,1-Trichloroethane Vinyl chloride

19

110 44 32 4900 5200 150 2700 2300 1100 600

11 5.4 4.7 3700 3900 48 320 2100 2100

20 290 9.1 1300 1600 5.7 180 800 700 200 180

280 59 84 39000 40000 96 140 16000 14000 180 160 93 14000 15000 12 170 5400 5300 320 340 50 54000 54000 250 4700 28000 29000 7900 8400

160


(R) = replicate sample. Source: Characterization of Shallow Ground-Water Conditions at the AVX Facility, Olean, NewYork, August 1985, Geraghty and Miller, Inc.

and Site Monitoring Plan Fourth Quarter 1997 Olean Well Field Site, Earth Science Consultants, Inc. December 1997.

avxgw1.xls 2 of 3 12/22/98


Olean, New York Upper Portion of Lower Aquifer

Ground-Water Volatile Organic Compound Concentrations April 1985 to May 1985; October 1997

Parameters *

Chloroethane Chloroform cis -1 ,2 - Dichloroethylene 1,1- Dichloroethane 1 . 1 - D i c h l o r o e t h y l e n e 1 . 2 - D i c h l o r o e t h a n e 1,2- Dichloroethylene Methylene chloride Tetrachloroethylene Trans -1,2- Dichloroethylene Trichloroethylene 1,1,1 Trichloroethane Vinyl chloride

11000

0.5 0.3 1.5 20 17 9.9 1900 1200

53 2 220

0.5 52 47 26 <10

0.2 0.5 0.2 10 8.5 41 1400 11 5 8.5 8.4 2.9 6300

360


(R) = replicate sample. Source: Characterization of Shallow Ground-Water Conditions at the AVX Facility, Olean, NewYork, August 1985, Geraghty and Miller, Inc.

and Site Monitoring Plan Fourth Quarter 1997 Olean Well Field Site, Earth Science Consultants, Inc. December 1997.

avxgwl .xls 3 of 3 12/22/98

BBL ENVIRONMENTAL SERVICES. INC. Remedial Action • Management & Construction

JN^Sch No .5

_Boa rd rnanSv l l l e 'J~ A,:: ' aeNCSEE j " f ~ a T ~

iCtovv; S - E a a t C l e a n •'Qoariifj.?

WPO»>c« Svh No 1 F f r t .

Olean Well Field Location

AVX Facility

Seneca™ bm Heights_ J4S

Borrow Pit

Wfestow s" kr. Mills - Old Baldy /

s -As/ » v- • 7\""*

/ i i ••••• 7 y >"»s

REFERENCE: BASE MAP USGS 7.5 MIN. QUAD. OLEAN, NEW YORK, 1961. AVX CORPORATION

OLEAN WELL FIELD SUPERFUND SITE OLEAN, NEW YORK RD/RA WORK PLAN

SITE LOCATION MAP

BLASLAND, BOUCK & LEE, INC. e n g i n e e r s & s c i e n t i s t s

FIGURE

05/98 SYR-D54-DJH 48086003/48086n01 .cdr

AREA LOCATION •\V,

Approximate Scale: 1" = 2000"

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