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Proposal for:DRAKE CHEMICAL SUPERFUND SITE
ON-SITE SOIL INCINERATION
Lock Haven, Pennsylvania
Solicitation No. DACW45-93-R-0077
Prepared for:U.S. Army Corps of Engineers
Omaha District
RUST International Inc.100 Corporate Parkway
Meadow Brook Corporate ParkBirmingham, AL 35242
(205) 995-7878
Volume I - Technical
This proposal or quotation includes data that shall not be disclosed outside the Government and shall notbe duplicated, used, or disclosed - in whole or in part - for any purpose other than to evaluate this proposalor quotation. If, however, a contract is. awarded to this offerer or quoter as a result of - or in connectionwith - the submission of this data, the Government shall have the right to duplicate, use, or disclose thedata to the extent provided in the resulting contract. This restriction does not limit the Government's rightto use information contained in this data if it is obtained from another source without restriction. The datasubject to this restriction are contained on all pages of this proposal.
This submittal is authorized and endorsed by:
cScqtTT. Baker, P.fE. DateV.P. RUST International Inc.& President, RUST Remedial Services Inc.
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TABLE OF CONTENTS
1.0 OPERATION PLAN
1.1 PERFORMANCE SPECIFICATIONS
1.2 PAST SYSTEM PERFORMANCE
1.3 PROCESS FLOW DIAGRAMS (PFDs)
1.4 FACILITY LAYOUT PLAN
1.5 LABORATORY
1.6 CONTROL SYSTEM
1.7 EXCAVATION SEQUENCE
1.8 NONCOMBUSTIBLE DEBRIS HANDLING
1.9 WASTEWATER MANAGEMENT
1.10 AIR EMISSIONS CONTROL
1.11 PERIMETER AIR MONITORING
2.0 WORK PLAN
2.1 PREPARATION PLANNING FUNCTIONS
2.2 COMMISSIONING AND STARTUP
3.0 MOBILIZATION PLAN
4.0 DEMOBILIZATION PLAN
5.0 PROJECT MANAGEMENT
6.0 PROJECT EXECUTION APPROACH
7.0 SUBCONTRACTOR MANAGEMENT
LIST OF TABLES
Table 1.1-1 ON-SITE DISPOSAL CRITERIA
Table 1.5-1 LABORATORY ANALYSES
Table 1.5-2 ANALYTICAL METHODS
Table 1.6-1 CONDITIONS FOR INTERLOCK PRIORITY SEQUENCE
Table 1.9-1 PROBLEM PARAMETERS FOR DRAKE SITE WASTEWATERTREATMENT
Table 1.10-1 SUMMARY OF METALS EMISSION CALCULATIONS
Table 1.11-1 PERIMETER AIR SAMPLING PLAN TABLE OF CONTENTS
Table 1.11-2 QUALITY ASSURANCE PROJECT PLAN TABLE OFCONTENTS
Table 1.11-3 PERIMETER AIR MONITORING METHODS
Table 2.1-l' CHEMICAL QUALITY MANAGEMENT/SAMPLING PLAN(CQM/SP) OUTLINE
Table 2.2-1 EXAMPLE OUTLINE OF TRIAL BURN PLAN
Table 2.2-2 EXAMPLE OUTLINE OF QUALITY ASSURANCE PROJECTPLAN (QAPP)
Table 2.2-3 PROPOSED REPORT FORMAT WITH APPENDICES
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LIST OF FIGURES
Figure 1.1-1 Schematic Drawing of the PY*ROX™ 8212 Transportable IncinerationSystem
Figure 1.1-2 PY*ROX™ 8200 Transportable Incineration System
Figure 1.2-1 Bog Creek Site Excavation Cell
Figure 1.2-2 PY*ROX™ Incineration System and part of the Feed Preparation Building
Figure 1.3-1 Simplified Overall Process Flow Diagram
Figure 1.3-2 Operations Period Process Flow Diagram
Figure 1.3-3 Incineration System Overall Process Flow Diagram
Figure 1.4-1 General Arrangement Site Layout
Figure 6.0 Project Schedule
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1.0 OPERATION PLAN
The RUST Team for Drake has taken great care to address fully and adequately all USAGEspecification requirements.
RUST evaluated the site characteristics and level of contaminants to determine the most effectivethermal treatment system for the Drake Chemical project. The boiling point of 0-naphthylamineis 583°F. Soil residence time and final soil temperature are the critical variables which determinecontaminant concentration in the thermally treated ash. RUST has experience at five superfundsites using thermal treatment technologies for contaminants with similar physical properties tothose found at the Drake Chemical site. The soil temperature and residence time required tovolatilize /3-naphthylamine and achieve a 55 ppb treatment level is expected to be 900°F and 30minutes respectively. The exit soil temperature of 900°F is significantly higher than the boilingpoint of /3-naphthylamine. This higher temperature is required to allow the organic contaminantto be volatilized and removed from the inner core of the soil particles.
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1.1 PERFORMANCE SPECIFICATIONS
The Drake Chemical project involves excavating, incineration, and on-site disposal of all soilswithin the site boundaries above 545 feet mean sea level (msl) elevation. RUST will perform thiswork in accordance with the scope of work (SOW) and project requirements.
Through experience remediating three Superfund sites using on-site incineration, RUST hasselected equipment and systems for the Drake Chemical project to maximize reliability andexceed the required performance specifications. Figure 1.1-1 shows a schematic drawing of thePY*ROX™ 8212 Transportable Incineration system proposed by RUST.
The incinerator and required supporting systems are designed to ensure thermal destruction incompliance with all applicable state and Federal regulations. In this section, RUST will describethe major equipment and system components proposed to meet and exceed the performancespecifications and SOW requirements.
Excavation and feed preparation equipment which has been successfully used by RUST at otherSuperfund sites will be utilized on the Drake site. This equipment was selected to provide reliableoperation of sufficient capacity to ensure uninterrupted operation of the incinerator and to meetperformance requirements. Process flow diagrams for the excavation and feed preparationactivities are presented in Figure 1.3-2.
Excavation
Excavation activities will be performed on a five-day-per-week schedule. Excavation and storageof contaminated soil will be performed in accordance with the contract, as specified in sections02205-Contaminated Soils Removal, 02210-Excavation, Backfill, Fill and Grading, 02380-Excavation Support Systems, and other related sections. Additionally, excavation and backfilloperations will include a 20-foot separation between both activities and will provide temporarycontainment for a five-inch rainfall event.
Feed Preparation
Feed preparation at the Drake site will use equipment that sizes, blends, and prepares the feedmaterials while providing continuous feed to the incineration system. The feed preparationequipment will be capable of processing all on-site waste (excluding drums, containers and non-combustibles), including contaminated wood, railroad ties, soils, trees, shrubs, used PPE, andany other on-site or remediation-generated waste. The feed will be sized to minus two inches, andblended to ensure a maximum feed rate (while allowing the PY*ROX™ 8212 incineration systemto meet all required emission standards).
Feed preparation will utilize screening, sizing, blending, and feeding operations. Independentfeed preparation and handling unit operations were selected by RUST for this critical processingarea so that equipment breakdowns and required shutdowns for maintenance dp not interfere withthe on-line availability of the incinerator. The proj. osed material preparation equipment will meetor exceed the capacity and operational requirements of the project, including the control offugitive emissions.
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The feed preparation building will be a metal structure, completely enclosed by metal sheeting.The building will be equipped with an air-handling system to maintain a negative pressure insidethe building, allowing RUST to control fugitive VOC and paniculate emissions. The air handlingsystem consists of an induced-draft fan, a particulate filter, and vapor-phase carbon adsorptionunits.
Feed preparation equipment inside the feed preparation building includes a screen system,conveyors, shredders, and front-end loaders. All equipment is oversized in capacity to allow forpart-time operation. Oversizing this equipment allows equipment maintenance without adverselyaffecting incineration system on-stream time.
The screen is designed to mechanically screen the feed materials to a two-inch or smaller particlesize. Larger particles are rejected to a stockpile for non-combustible debris segregation andprocessing. The two-inch or smaller sized material is discharged to a series of conveyors that feedthe incinerator feed system and the prepared feed storage bin. This conveyor is specially designedwith transfer plows to divert a portion of the feed materials to the prepared feed storage bin.During periods when the feed preparation system is not in use, prepared feed from the storagebin is fed into the incinerator feed hopper.
Feed material larger than two-inches will be rejected by the screen. The incinerable materials willbe segregated from the non-combustible debris stream and will be loaded into a shredder, wherethey will be reduced in size and sent for reprocessing in the power screen. Non-incinerablematerials will be sent for decontamination and will be backfilled or disposed of off site. The size-reducing shredder is a low-speed device, can accommodate a wide variety of feed material sizesand shapes, and will shred them to a minus two-inch size without generating large amounts ofdust during processing.
Incineration System
The major components in the PY*ROX™ 8212 Transportable Incineration System consist of thefeed assembly, rotary kiln, hot cyclone, and vertical secondary combustion chamber (SCC)system. The PY*ROX™ 8212 will be used for large, on-site incinerator projects. Selection,design, and performance criteria of the PY*ROX™ 8212 have been based upon the highlysuccessful PY*ROX™ 8200 Transportable Incineration System design as shown in Figure 1.1-2.
The incineration system proposed by RUST will meet or exceed the thermal treatmentperformance and operating requirements of the Drake Chemical project. The major performancerequirements for the incineration system are listed below.
The incineration system will have a throughput capacity to process all site wasteswithin the five-year time-period requirement. The incinerator will operate 24hours per day, seven days per week, 12 months a year continuously, except formaintenance shutdowns.
The incineration system will have a computer control system for controlling theincinerator's operation and for data management reporting requirements. Thiscontrol system will meet all regulatory requirements and will include anautomatic waste feed cutoff (AWFCO) system that shuts down the waste feedwhen operating limits are exceeded.
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The incineration system will achieve a destruction and removal efficiency (DRE)of greater than the required 99.99 percent required for both naphthalene and 1,4-dichlon>benzene, in accordance with Title 25, Pennsylvania Code, Section264.343 and 40 CFR 264.343 subpart O requirements.
The incinerator combustion system will maintain a minimum combustionefficiency of 99.9 percent as a eight-hour average, with a new average calculatedeach hour.
The incineration system will thermally treat all Drake Chemical soils to meet theon-site disposal criteria.
The following sections provide a description of the incinerator feed and combustion system, alongwith the related performance standards that meet and exceed the project requirements.
Feed Assembly
Contaminated soils will be fed to the kiln by the kiln feed system. The kiln feed system consistsof a feed conveyor and a weigh belt conveyor to control automatically the feed rate to the kiln.Feed conveyors and hoppers, located outside the feed preparation building, are enclosed in dust-tight covers and housings to prevent emissions from the incinerator feed operations. Both the feedpreparation building and the rotary kiln operate under a negative draft, and any emissions fromthe feed system are treated by either the incinerator or the building's air handling system.
Rotary Kiln
The kiln's is refractory-lined with firebrick. .
Heat required for combustion is provided by proprietary burners. RUST used these burners onprevious Superfund projects.
Providing a safe operating environment for employees at the Drake Chemical site is of paramountimportance to RUST. All burner piping is equipped with double-block and bleed valving andflame safety interlocks in accordance with Industrial Risk Insurers (IRI) and Factory Mutual (FM)requirements. RUST is very proud of its safety record in operating on-site incineration systems.
At either end of the rotary kiln are feed and discharge breechings designed to enclose the of thekiln.
The feed breeching contains the faceplate, which houses the feed conveyor, lances, andcombustion system components. The discharge breeching provides an exit for processed soils androtary kiln flue gas. Both breechings provide mounting surfaces for the kiln rotary seals.
Hot Cyclone
Exhaust gases discharged from the rotary kiln pass through a hot gas cyclone equipped todischarge collected paniculate to the bottom ash handling system.
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Secondary Combustion Chamber (SCC)
After the hot exhaust gases exit the hot cyclone, they enter the SCC. The SCC is a vertical,refractory-lined vessel designed to heat the rotary kiln exhaust gases to a temperature of 1,650to 2,QOO°F (the actual operating temperature will be determined by the trial burn). The minimumresidence time of gases in the SCC will be two seconds. The trial burn test results will confirmthat the incinerator will operate with a 99.99 percent DRE, and will be used to set "permitted"operating conditions and automatic waste feed cutoff (AWFCO) requirements.
Fly Ash and Bottom Ash Control
Fly ash and bottom ash handling at the Drake Chemical site will be performed with earth-movingand material-processing equipment that has been previously used by RUST at other Superfundcleanup sites. This equipment was selected based on required capacities and proven reliableoperation, in addition to meeting or exceeding the following project requirements:
Any ash or residue that has detectable organic levels or /3-Naphthylamine levelshigher than 55 parts per billion (ppb) shall be returned to the incineration systemfor additional thermal treatment.
Any ash or residue that has TCLP metal concentrations less than the DrinkingWater Standard (DWS) can be backfilled on site.
If TCLP values exceed the DWS, but are below 25 times the DWS, the ash andresidues can be backfilled on site at elevations eight feet or more above thebottom of the excavation. Such materials can also be blended with ash or residuehaving lower metal levels, blended with clean import fill, or chemically fixed toproduce TCLP values less than the DWS, waiving the eight-foot separationrequirement.
If TCLP values exceed 25 times the DWS, but are less than the level forcharacteristic wastes in 40 CFR 261.2, the soil shall be chemically fixed toreduce the TCLP values to allow on-site backfill.
If TCLP values exceed the level for characteristic waste as described in 40 CFR261.2, the ash or residue shall be chemically fixed to reduce its TCLP valuesbelow the characteristic waste level to allow on-site backfill.
The ash handling system shall maintain the integrity of the separate residuestreams, including bottom ash and fly ash, by separately handling them until theyare ready to be backfilled.
Necessary facilities and equipment shall be provided to control fugitive emissions duringhandling and treatment of the soils, including wetting of the incinerated soils with water. Thefugitive emissions provisions of Title 25 Pennsylvania Code Section 123.1, will be complied with.
Fly Ash
The fly ash handling system consists of a series of collection and transfer conveyors designed to
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collect paniculate separately from the incinerator air pollution control system's evaporative coolerand baghouse fabric filter.
Bottom Ash
Bottom ash is separately collected from the fly ash. The bottom ash system utilizes two directconveyors in series. These two conveyors cool and moisten the soil for dust control, then depositit in a transfer conveyor. The processed soils are then distributed to the proper ash storage bin.
Stabilization
Following incineration, all ash backfilled on site will meet either drinking water standards (DWS)or DWS times 25 with regard to metals in the toxic characteristic leaching procedure (TCLP)extract (Table 1.1-1). Ash stabilization may be required to meet these standards. As a technique,stabilization reduces the hazard potential of waste by converting the contaminants into their leastsoluble, mobile, or toxic form. Essentially, the ash requiring stabilization will be treated in anenclosed stabilization system,which mixes the ash with reagents that will react with thecontaminants to insolubilize, immobilize, and encapsulate them. The resultant stabilized ash willbe less hazardous than the unstabilized ash.
RUST has extensive experience in operating stabilization facilities and will be using the mobileChem-Matrix™ stabilization system for the Drake Chemical site remediation.
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Table 1.1-1ON-SITE DISPOSAL CRITERIA3-4
ArsenicBariumCadmiumChromiumLeadMercury
SeleniumSilver
0.05
i.O
0.010.050.050.002
0.010.05
1.25
25.0
0.251.251.250.05
0.251.25
1 Drinking Water Standards as of September 29, 1988.2 Drinking Water Standards multiplied by 25.3 Ash meeting DWS may be disposed of oh-site. Ash exceeding DWS, but below DWS x 25 may be
backfilled at elevations 8 ft. or more above the bottom of the excavation.4 US EPA, Toxicity Characteristic Leaching Procedures (TCLP), Fed. Reg., Vol. 55, No. 61, March 29,
1990.
Backfill
All thermally treated and stabilized ash will be disposed of on site. Backfilling operations willbe conducted on a five-day-per-week, ten-hour-per-day schedule and will meet the moisture,density, and other requirements of the SOW, Section 02210, Excavation, Backfill, Fill andGrading.
Air Pollution Control (APC) System
The incinerator air pollution control (APC) system will control of emission from the thermaldestruction facility (TDF). This equipment has been previously demonstrated to meet and exceedthe performance requirements for the project, including:
Stack gas will be continuously monitored for CO, O2, CO2, THC, and NOX. Paniculateemissions, measured as PM10, shall not exceed 0.10 gr/sdcf, corrected to 7 percentoxygen
Hydrochloric acid (HC1) emissions shall not exceed 4 Ibs. per hour, or shall be reducedby 99 percent on an hourly average, in accordance with 40 CFR 264.343.
Carbon monoxide (CO) emissions shall not exceed 100 ppmv as an eight-hour average,with a new average calculated each hour, and shall not exceed 200 ppmv as an hourlyaverage corrected to seven percent oxygen (O , dry basis.
Dioxin and furan emissions, expressed as total dioxin/furans, shall not exceed 30 ng/percubic meter, corrected to seven percent oxygen (Oz), dry basis.
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NOX emissions, expressed as NO2, shall not exceed 300 ppmv, on a daily average(corrected to seven percent oxygen (Oj), dry basis).Metals emissions shall be incompliance with Title 25 of the Pennsylvania Code, Section 127.1, and 40 CFR 266.106.The major components of the APC system include the evaporative cooler, baghouse, IDfan, and wet scrubber.
Hot flue gases from the SCC are first conditioned in the evaporative cooler.
The cooled gases from the evaporative cooler then enter baghouse assemblies, where the finepaniculate (fly ash) is filtered from the flue gas.
The filtered air then passes through the induced draft fan. The fan is modulated by PIDcontroller, with a signal from the kiln feed hood pressure transmitter to maintain the kiln at apressure negative to atmosphere. The pressure throughout the remainder of the combustion andAPC system becomes progressively more negative up to the suction of the fan.
The exhaust gases then enter the wet scrubbing system, which is composed of three distinctsections: (1) venturi scrubber, (2) packed bed section, and (3) mist eliminator. The venturiscrubber is a wetted throat style venturi designed to further cool the hot gases to the saturationtemperature. Scrubber recycle water is flooded into the throat of the venturi by dual pumps.Constant water flow is maintained in the venturi to provide adequate cooling of the gases. Afterthe quench operation, the cooled gases enter a packed bed scrubbing section. Scrubber recyclewater is sprayed and cascaded across the packing, where it comes in contact with the gas flowfrom the venturi scrubber, allowing acid gas neutralization to occur. The scrubber solution is keptslightly alkaline by the addition of caustic solution. The flow of caustic solution is automaticallycontrolled by a pH monitor installed in the scrubber recirculation line.
Prior to entering the exhaust stack, the flue gas exiting the packed bed section passes through amist eliminator to remove the scrubber recycle water entrained in the gas stream.
To monitor and ensure proper operation of the incineration system within the required operatinglimits, a continuous emission monitoring (CEM) analyzes the stack gas.
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1.2 PAST SYSTEM PERFORMANCE
RUST's PY*ROX™ 8200 incineration system (the TDF system) successfully operated at threeformer sites and is being mobilized at a fourth site. The experience gained at each site has beenused to improve the operations of the PY*ROX™ system.
The PY*ROX™ 8200 system experience at Prentiss, Bog Creek, and Old Midland Products isdirectly applicable to the PY*ROX™ 8212. The process designs are the same; a few mechanicalchanges increase capacity and improve reliability.
The emission requirements met by the incineration system at the Prentiss Creosote Site are 99%ORE, 0.08 gr/DSCF paniculate, and 99% HC1 removal or < 4 pounds/hr. The performance ofthe unit well surpassed that required by the regulations.
At the completion of the Prentiss Creosote Site remediation, several design improvements to thesystem were implemented.
Performance Record
RUST's PY*ROX™ system has met and exceeded all environmental and regulatory requirementsat each of these sites. The PY*ROX™ system achieved 99.99% and 99.9999% destruction andremoval efficiency (DRE), less than 0.08 grains/DSCF paniculate emissions, and greater than99 percent hydrochloric acid (HC1) removal. The PY*ROX™ system has achieved this high levelof DRE in full-scale operation from site to site. The following sections provide further detail onthe performance at each location.
Prentiss Creosote Site
The Prentiss Creosote site in Mississippi was contaminated with creosote and polynucleararomatics (PNAs) from operations of a wood treatment facility. From July to December 1988,creosote sludge and contaminated soil were incinerated using the PY*ROXT" 8200.
Bog Creek Farm Site
This 12-acre site in Howell Township, New Jersey was contaminated with solvents and paintresidues from illegal dumping operations during the early 1970s. Remedial investigations (RIs)revealed a wide variety of metals and organic contaminants in the soil, with indications ofgroundwater contamination. During spring and summer, 1990, RUST performed a comprehensiveremediation effort involving site preparation, mobilization of equipment, excavation ofcontaminated soil and debris, on-site incineration, on-site water treatment, backfill of cleaned soil,and demobilization.
From March to July, 1990, The PY*ROX™ 8200 incineration system treated contaminated soiland debris at this site. Figure 1.2-1 shows the Bog Creek site with an excavation cell in theforeground and the PY*ROX™ incineration system in the background.
The PY*ROX™ incineration system removed more than 99% of the metals.
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Old Midland Products Site
This 37-acre site was contaminated with creosote and pentachlorophenol from wood-treatingoperations conducted from 1969 to 1979. The site contained a number of small structures — tanksand miscellaneous equipment — in addition to seven lagoons. The initial estimate of contaminatedmaterials was 45.000 tons of sediments, and 1,070,000 gallons of lagoon water and groundwater.Soils and lagoon sediments had pentachlorophenol and total PNA concentrations as high as12,000 and 50,000 ppm, respectively. Dioxins and rurans were found in trace quantities.
RUST began site preparation in 1991. The scope of work included mobilization of the incineratorand water treatment system, excavation of contaminated material, operation of the incinerator andwater treatment plant, backfill of clean soil, demobilization, and restoration of the site.
The PY*ROX™ 8200 incinerator treated contaminated soil and sediments during operation at theOld Midland Products Site from June 1992 through May 1993. It should be noted that 99.9999percent DRE was achieved for trichlorobenzene, which served as a surrogate for the dioxin/furancontamination in the soil.
Figure 1.2-2 shows the PY*ROX™ incineration system and part of the feed preparation building.
At the Old Midland Products site, the PY*ROX™ incineration system operated at higheravailability levels and with fewer process upsets, than any other system so far demonstrated inthe United States.
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1.3 PROCESS FLOW DIAGRAMS (PFDs)
RUST provides in this section process flow diagrams (PFDs) showing process flow informationfor all material and process streams. These PFDs include excavation, feed preparation,incineration, stabilization, water treatment, and ash backfill. The PFDs provide flow directions,flow rates, temperatures, pressures, and composition data for all major streams. The followingPFDs are included in this section:
Figure 1.3-1 Simplified Overall Process Flow DiagramFigure 1.3-2 Operations Period PFDFigure 1.3-3 Incineration System Overall PFD
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1.4 FACILITY LAYOUT PLAN
Facility layout is a critical issue on the Drake Chemical Superfund Site due to the requirementto excavate the entire site. RUST has considered several layout options, and has concluded thatthe most effective approach will be to excavate the area directly below the incinerator and ashhandling area prior to their installation. The remainder of the facilities will be installed beforethe area below them is excavated. They will either be moved during operations, or excavationwill be feasible with the facility remaining in place as described below.
Overall
The site layout is depicted in Figure 1.4-1. This drawing shows the location of all majorcomponents of the equipment for the Drake Chemical project. Prior to installing the incineratorand ash handling systems, the area to receive them will be sheetpiled to provide excavationsupport, and to separate clean material from the existing contaminated material. The incineratorand ash handling areas will then be excavated and backfilled with clean material to elevation 550msl. This will allow continuous performance of the project without requiring a shutdown of theTDU for relocation.
The utility corridor will be sheetpiled and excavated, and the utilities relocated during themobilization and construction phase, well before the incinerator erection is complete. After theutility relocation is completed, the utility corridor will provide a "clean" access road fortransporting imported fill and ash to excavated areas.
The material excavated for installation of the incinerator, ash handling area, and utility corridorwill be stockpiled for future treatment. This stockpile will be the source of material for the TrialBurn and will provide the surge capacity for continuity of operations during the operations phaseof the project. The stockpile size will vary during the course of the project.
As shown on Figure 1.4-1, the excavation boundary will be sheetpiled to provide excavationsupport.
The support facilities will be installed outside the excavation limits so that a relocation during theproject will not be necessary.
Utilities for the incinerator will be installed underground in the clean utility corridor.
Traffic flow during the operations phase will enter the Exclusion Zone at the utility corridor andproceed south. When there is no contact with the contaminated material, the vehicle will also exitvia this route. When there is potential contact with the contaminated material, the vehicle will exitvia the gate at the equipment decontamination station. During the excavation period, the haultrucks will remain in the Exclusion Zone proceeding toward the feed preparation building. Whileexcavating the area west of the utility corridor, the excavation trucks will be decontaminated priorto crossing the corridor. The ash trucks will be considered uncontaminated and will use the utilitycorridor as the primary ash haul route.
Site access control will be maintained at the gate crossing Myrtle Street. The street will remainopen for limited traffic as required by the specifications.
Incinerator
The incinerator layout is designed to facilitate erection, provide maintenance access, and provideease of operation.
Feed Preparation
The feed preparation area will be an enclosed structure. The primary equipment in the feedpreparation area will be a screening system for separation of material less than two inches andsize reduction of frozen dirt and small rocks. This screen will discharge to conveyors which willrun over the prepared feed storage area and discharge into the incinerator feed hopper.
Ash Facility
The ash storage facility will be a roof structure with concrete containment floor and bin dividerwalls.. The facility will be sized to contain, six days storage of bottom ash. The facility will alsoprovide separate storage for fly ash.
Wastewater Treatment
This facility will be designed on skid-mounted units for ease of installation and to easilyaccommodate relocation of the plant.
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1.5 LABORATORY
Various options were evaluated for the performance of the analytical work for the DrakeChemical project, including the use of a mobile or temporary on-site facility, a temporary facilitywithin the Lock Haven area, or a fixed off-site vendor facility. RUST has determined that themost effective scenario, in terms of both cost and efficiency, is to use a combination of on-siteand off-site laboratory services.
Analyses to be Performed
The analyses to be performed on the various waste streams are provided in Table 1.5-1. Themethods to be used for the various analyses are shown in Table 1.5-2.
On-Site Laboratory
The proposed on-site laboratory will consist of a laboratory trailer, subdivided into four distinctparts:.
• Sample preparation lab - Samples are checked-in this lab, and extracted or digested in oneof the four foot fume hoods. Physical testing is also conducted in this lab.
• SVOC Organic Lab - Equipped with a GC/MS for SVOC analyses, a GC/ECD forherbicide analyses, and an HPLC with fluorescence detector for /3-naphthylamineanalysis.
• Metals Lab - Equipped with an AAS (atomic absorption spectrophotometer) for metalsanalysis, and a refrigerator for sample storage.
• VOC Organics Lab - Equipped with a GC/MS/Purge & Trap for VOC analyses. This labwill be under positive pressure to avoid contamination from the sample prep lab.
Residuals from the laboratory operations will be handled in accordance with all applicable Federaland state regulations. The laboratory sinks will drain into a self-contained holding tank, with thecontents periodically transferred to the on-site water treatment plant for treatment prior todischarge. All contaminated trash, glassware, and sample and extraction residues will be collectedin appropriately marked containers. These materials will subsequently be treated in the on-siteTDF.
Off-Site Laboratory
Off-site analyses will be performed at a laboratory approved by the USAGE.
Sampling / Analytical Personnel Responsibilities
Field-sampling personnel will consist of RUST technicians trained in the appropriatesampling protocols. Sampling personnel will be responsible for obtaining the requiredsamples from the various waste streams at the specified intervals. Evaluation of theadherence to the protocols (Standard Operating Procedures) will occur during periodicQuality Assurance (QA) audits by RUST personnel. The evaluation will focus on thecompleteness, representativeness, and comparability of the sampling activities.
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Table 1.5-1LABORATORY ANALYSES
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Incinerator Feed
Incinerated Soil
APCS Solid Residue
DecontaminationResidues
Unknown Buried DrumsDecontaminatedEquipment and Debris(wipe samples or rinsate)Wastewater TreatmentPlant Effluent (decon water, scrubber water,dewatering water)
Total MetalsVOCsSVOCs/3-NaphthylamineHerbicides'TCLP MetalsVOCsSVOCsjS-NaphthylamineHerbicides'TCLP MetalsVOCsSVOCs/3-NaphthylamineHerbicides'TCLP MetalsVOCsSVOCs/3-NaphthylamineHerbicides'Fingerprint*SVOCsHerbicides'
Total MetalsVOCsSVOCs/3-NaphthylamineHerbicides'TSSPH
Herbicides analysis includes Fenac.Fingerprint analysis includes: reactivity/compatibility (air and water); physical appearance;ignitability; oxidizer screen; pH; sulfide screen; and cyanide screen.
3R306052
Table 1.5-2
ANALYTICAL METHODS
'••''•J Ss i-TCLP
ChromiumNickelSilverZincCadmiumLeadArsenicMercurySelenium
Semi-volatile oganics
/3-Naphthylamine
Herbicide (and fenac)Vola'ile organicsTSSPhysical AppearanceIgnitabilityCorapatability
Oxidizer ScreenSulfide ScreenCyanide ScreenpH
f lPBNW'iiiiiiiiii 'i-ii
. , 23133111,2
N/A
3005/71903005/75203005/77603005/79503005/71303005/74213005/70603005/7470
3005/77403550/8270HPLC with fluorescent detectorGC with high resolution MS81505030/8240160.2D4979-891010D5058-90
D4981-899030
9010150.1
13113050/71903050/75203050/77603050/79503050/71303050/74213050/70603050/7471
3050/77403550/8270
or capillary
81505030/8240
D4979-891010D5058-90D4981-89903090109040
References:1. USEPA, Test Methods for Evaluating Solid Waste (Physical/Chemical Methods) SW846,
Third Edition, September, 1986.2. USEPA, Methods for Chemical Analysis of Water and Wastes. USEPA-600/4-79-020,
Revised March, 1983.3. American Society for Testing and Materials (ASTM) Annual. Revised 1984.
flR3.06053
First-Tier Quality Assurance (QA) Responsibility
The project will have a Quality Control Manager (QCM) with oversight responsibility for alloperations, including the laboratories. In addition, a Quality Control Coordinator (QCC) will bein place to review the analytical reports, the quality of the data being produced, and adherenceof the laboratory to the terms of the contract.
Chemical Data Acquisition Plan (CDAP) Experience
RUST typically prepares Chemical Quality Control or Chemical Data Acquisitions Plans on mostmajor remedial projects. A chemical data acquisition plan (CDAP), quality assurance project plan(QAPP), and sampling and analysis plan (SAP) were prepared, submitted, and approved on theBog Creek Farm site, Old Midland Products site and the Brio project. All of these projectsinvolved on-site incineration. In each project, these plans were developed, modified, or amendedin full cooperation with the contracting agency to provide timely, cost-effective, and defensiblevalidation of completion of the project specifications, performance standards, and goals.
fl'R3.0605U
1.6 CONTROL SYSTEM
The control system designed for the PY*ROX™ 8212 incineration system was based on the safeand reliable operation of the currently operating PY*ROX™ 8200 system. The control systemdesign for the PY*ROX™ 8212 will be identical to the field tested design used with thePY*ROX™ 8200 facility, which has evolved through operating experience, has proven reliable,and exceeds Drake Chemical project requirement for incinerator control and data management.
The control system provides operators with accurate, real-time process monitoring informationso they can respond more quickly to potential upsets. Critical process parameters have beenduplicated by installing redundant, independent, on-line systems and sensors. Redundant systemsare installed for critical items such as the Data Collection System, operator work station,microprocessors, rotary kiln and SCC outlet temperature monitors, and continuous emissionsmonitoring data gathering.
All critical process parameters are also equipped with alarm points. The alarm point occurs priorto the critical alarm point and allows the operator to react prior to automatic triggering of aninterlock. The critical alarm point (high high, low low, etc.) determines which type of interlockis triggered.
Process Control and Interlocks
The rotary kiln incinerator is not an inherently difficult process to control. Due to the nature ofthe materials being processed and strict regulatory requirements concerning the operation ofhazardous waste incinerators, however, it is not sufficient to monitor only the principal processvariables of the facility. To maintain safe operation, the control system must also respond quicklyto changes in any principal process variable. It must initiate shutdowns and automatic waste feedcutoffs (AWFCO) to ensure those variables never exceed their permitted ranges wheneverhazardous waste is being fed to the facility. The process control strategies of the PY*ROX™ 8212are designed with these objectives in mind.
Interlocks
Certain critical process parameters invoke interlock conditions. On the PY*ROX™ 8212, fiveinterlock conditions exist. They are prioritized so any interlock invoked will also cause all lowerpriority interlocks to be invoked (1-1 is the highest priority). The purpose of the interlock controlsystem is to prevent injury to workers, damage to the equipment, and emissions entering theatmosphere. Conditions for invoking these interlocks are shown in Table 1.6-1.
Emergency Relief Vent
An important safety feature of the PY*ROX™ 8212 incineration system is the emergency reliefvent (ERV). The ERV, located at the top of the secondary combustion chamber (SCC), isdesigned to open under emergency conditions in order to protect operating personnel and toprevent damage to downstream air pollution control system equipment. When the ERV opens,residual heat is relieved to the atmosphere. It is important to note that the ERV is designed toopen only in case of a catastrophic event, such as loss of power. Since paniculate emissions mayresult from opening the emergency stack, this is not considered part of normal operations and isavoided if possible. Conditions which may result in opening the ERV are outlined above under
QR306055
the emergency shutdown interlock (1-1).
Utility Backup Systems
Utility backup systems for electrical power, water, and compressed air are provided to ensuresafe, reliable operation, and to provide a mechanism for an orderly shutdown in the event of lossof the power or water supply.
Electricity
The electrical system is equipped with a backup generator and automatic switching systemdesigned, in the event of main power loss, to allow operation of critical equipment and a safesystem shutdown. The generator is equipped with an automatic transfer switch that willautomatically start the generator and switch line power to the generator upon loss of main-linepower. Additionally, the control system is equipped with an uninterruptable power supply.
Water
Critical support areas of the incineration system have redundant pumping systems. The processwater flow to the evaporative cooler is equipped with a redundant pumping system. Theredundant pump also helps prevent damage to the downstream air pollution control equipment.Cooling and fresh process water utilities have redundant pumps installed to allow uninterrupted,cooling water flow. The scrubber recycle loop uses a redundant pump system to providecontinuous scrubber-water flow should the primary pump fail.
flR306056
Table 1.6-1
CONDITIONS FOR INTERLOCK PRIORITY SEQUENCE
,;,;,:;::.;.•'.. . ,• v/,,, ,v • ., ,v..:.; XY,, v
Wao . .1
2
3
4
5
&3tt&&&tt;4:lt*&;tt:;:BS|a;if:JSt|JfeJ!fc::;:ij;:
l-l
1-2
1-3
1-4
1-5
immBsamwmEmergencyShutdown
All Fuel Cutoff(kiln & SCC)Kiln Fuel Cutoff
AH Waste Cutoff
Solid Waste Cutoff
$S!:!?S: ^ ^*i ^ S ^ ^ ^ S i ^ ^ ^ ^ ^ ^^
Main power lossFan motor amperage dropout (indicates fan stoppage)High high scrubber inlet temperature (>250° F)High high evaporative cooler outlet temperature(>500o F)Any interlock 1 eventHigh high SCC discharge temperature (> 2,400° F)Any interlock 1 or 2 eventKiln discharge high high temperature (> 2,200° F)Both kiln burners shut down by burner managementsystemInterlock 1 through 3 eventEmergency relief vent not closedKiln internal pressure 0" w.c. instantaneously orgreater than -0.1° w.c. for 10 seconds or moreLow low SCC outlet temperature (< 1,800° F)(actual temperature to be determined from trial burn)High CO in stack gas greater than 100 ppm for onehour rolling average or greater than 500 ppminstantaneous readingScrubber packing water flow < 900 gpmLow pH in scrubber liquor <6.5 for one hour ormoreHigh high stack gas flow > 35 fpsLow low kiln flue gas discharge temperature(< 1,200° F) (actual temperature to be determinedfrom trial burn)SCC burner flames loss detection or shutdown byburner management systemKiln rotation stoppage (£0.0 rpm)Other incinerator operating permit conditions areexceededAny interlock 1 through 4 eventDischarge ash conveyor stoppage (any conveyor)Average feed rate based on an hourly rolling averagegreater than trial burn limitKiln rotation speed <0.3 rpm
flR306057
1.7 EXCAVATION SEQUENCE
RUST has prepared a comprehensive excavation sequence for the Drake Chemical project. This sequence providesfor consistent flow (feed) of soil to the incinerator while protecting human health and the environment.
Clearing and Grubbing
Clearing and grubbing of the site will occur during the site preparation phase.
Concrete, Rubble, and Railroad Spur Removal
The majority of concrete, rubble, and railroad spur removal will occur during clearing and grubbing activities.
Excavation Bracing
Excavation bracing and sheetpiling will be placed around the entire site to provide a safe, controlled excavation.It will maintain the structural integrity of the adjacent properties (including the Conrail railroad line along the eastside of the property). The method of bracing most suitable to the site will:
•Allow for vertical excavation of contaminated soils at the excavation boundary.
•Provide a safe, open excavation during material removal and backfilling operations.
•Provide structural support for loads that may be applied off site and adjacent to the excavation.
Installation of the steel sheetpiling will be accomplished by advancing the piles with a vibratory or impact hammerin a manner that minimizes any damage to adjacent properties. A template will be used to ensure properalignment of the interlocking steel sheeting. Before the completion of the remediation activities, all perimeter steelsheetpiling will be cut to at least two feet below the final grade. Sheetpiling will be installed along both sides ofthe utility relocation trench. RUST will leave this piling in place, but cut to a minimum of two feet below thefinal grade in order to avoid damaging utilities during piling removal.
Prior to removal of contaminated soil from the incinerator footprint, sheetpiling will be installed around theincinerator. The piling will be used to facilitate excavation, and to separate clean and contaminated soil. Afterthe incinerator has been dismantled, sheetpiling will be removed and decontaminated for off-site disposal orsalvage.
Excavation and Backfilling
Excavation of contaminated soils and sludges will be performed at a rate that provides the incinerator sufficientquantities for maximum operation.
Soil v. ill be excavated using an excavator to elevation 545 msl. The excavator will place the contaminated soilinto large-capacity, off-road dump trucks for transport to the feed stockpile or preparation areas.
Temporary haul roads will be constructed on site in such a way that clean trucks and backfill will not be exposed
AR306058
to the contaminated soils excavation operation. Clean haul roads will have barricade tape or safety fencing to actas a physical barrier between contaminated and clean areas. Haul routes for contaminated soil will be improvedas necessary.
Stockpile(s) will all be located outside the feed preparation building. The stockpile(s) will be established basedon the feed requirements of the incinerator.
Excavation Dewatering
RUST excavation dewatering strategy at the Drake site shall achieve the following goals:
0 Provide dewatering for excavations that are below the groundwater table0 Adequately handle estimated flow rates from the water-bearing strata0 Be flexible and time-efficient for incorporation into the excavation sequence, and0 Be engineered to avoid significant side-slope or bottom-soil instabilities.
Based on current subsurface information and data, the most favorable method of dewatering is open pumping.If site conditions change or new subsurface data become available, the dewatering methods will be re-evaluatedand modified as necessary. Open pumping will beThe dewatering system will be composed of trailer or skid-mounted pumps, one of which will be used as a backupunit. Solid sectional piping and appropriate flexible hoses will be used for conveyance to the wastewater treatmentplant (WWTP).
Erosion Control
RUST has developed an erosion control plan to outline measures necessary to provide control of soil erosion,uust, and fugitive emissions during construction and after remediation completion. Control of the potential spreadof contamination through erosion and fugitive dust emissions is crucial to the protection of human health and theenvironment.
Erosion control materials and equipment employed at the Drake site may include, but will not be limited to, thefollowing:
° Silt fences,0 Straw bales,0 Erosion control blankets,0 Riprap,0 Flood protection matting,° Clean fill for diversion berms,° Vegetative cover,0 Foam,0 HOPE and visqueen,0 Submersible or trash pumps and appurtenances required to convey on-site run-off to the wastewater
treatment system, and0 Tools and equipment as required to place erosion control materials and construct temporary diversion
structures, including berms, swales, and channels.
Prior to commencement of remediation work in the Exclusion Zone, RUST will install stormwater soil erosioncontrol measures. The following methods will be used to control soil erosion and sediment during remediation
AR306059
activities:
o Construction of temporary diversion berms and swales,o Installation of temporary sediment control including silt fences and straw bales, and° Maintenance of the erosion control system by removing sediments and making necessary repairs.
Surface water within the Exclusion Zone will not be pumped, diverted, or allowed to migrate beyond theboundaries of the zone. Control measures will conform to the changing shape of the Exclusion Zone, and willprevent impacted surface water from coming into contact with clean backfilled areas. This diversionary strategywill ensure that remediated areas do not become re-contaminated. Soil stockpile areas will be bounded by berms,silt fences, or straw bales to prevent transport of stockpiled materials through erosion.
Dust Control
Due to the potential of airborne migration of dust, remediation activities will be designed to minimize dustemissions and insure compliance with the National Ambient Air Quality Standards (NAAQS) for paniculateemissions. RUST will use controlled loading techniques to achieve compliance. For example, care will be takento lower the bucket of the backhoe into the truck as far as possible. This will minimize dust generation.
A dust suppressant will be applied to prevent, inhibit, cr reduce dust and/or paniculate emission. The dustsuppressant to be used at the Drake site will be water. In addition, a vapor suppressant foam will be used asnecessary. All material stockpiles will be covered to minimize dust generation.
flR306060
1.8 NONCOMBUSTIBLE DEBRIS HANDLING
During the Drake Chemical project, there will be a certain amount of waste that cannot be processed through theThermal Destruction Facility (TDF). This is not uncommon for large hazardous waste incineration projects.RUST has developed a unique plan for handling these occurrences,
The RUST plan for noncombustible debris management involves accurately characterizing the material beforedisposal. There are several separate testing steps that a noncombustible material must go through before ultimatedisposal is determined.
The process for handling noncombustible debris follows:
First it is determined whether the noncombustible material is a drum:
0 If yes, the material is stored away from the other materials; it is sampled using level B PPE and thecontents are characterized:
If the material is an empty drum or contains nonhazardous material, it will be disposed of off site at anapproved landfill.
If it contains an organic material, it will be disposed of off site at a RCRA or TSCA incinerator.
If it contains aqueous waste, it will be disposed of at an off-site water treatment facility.
If it contains heavy metals that require stabilization, the waste will be disposed of at an off-sitestabilization facility.
0 If the material is not a drum, -it goes to the next phase of characterization.
The next test is whether the material is combustible:
If yes, the material is reduced in size and sent to the TDF on site.
0 If no, the material is washed with a high-pressure, hot-water wash, and wipe-tested to determine if it isdecontaminated.
If the wipe test fails, the material will be washed and tested again. If this is done twice or more, and thematerial still does not pass the wipe test, RUST will notify the Contracting Officer and request that thematerial be disposed of off site as appropriate.If the wipe test passes, it will be determined whether or not the material can be reclaimed for any usefulvalue:
0 If not, the material will be backfilled on site.
0 If so, RUST will contact the CO and request that the material be sent to reclamation.
Similar techniques have been used successfully by RUST on other remedial projects.
8R30606I
1.9 WASTEWATER MANAGEMENT
Design Basis
The wastewater treatment system intended for the Drake Chemical site is designed to treat various aqueous wastesthat wiH he generated during remediation. The wastewater treatment system consists of two separate treatmentfacilities. These facilities are a wastewater treatment plant (WWTP) and a stormwater treatment facility (STF).The WWTP will treat all decontamination water, on-site laboratory water, water generated from excavationdewatering, and standing water from the leachate lagoon. The STF will treat potentially contaminated stormwatergenerated on site. Clean stormwater will be discharged directly into the existing storm sewer. Sanitary wastewater[about 1,000 gallons per day (gpd)] will not be treated by the on-site wastewater treatment system, but will besegregated from other site wastewater and directly discharged to the Lock Haven publicly owned treatment works(POTW). Process water from the thermal destruction unit (TDU) will be recycled and reused in the TDU.
Wastewater Treatment Plant (WWTP)
The WWTP is designed to treat the average levels of contaminants in the groundwater flow rate of 50 gallonsper minute (gpm). The treatment train is designed in consideration of several "problem parameters" that wereidentified in the RFP. These "problem parameters" were used to select the various unit operations that comprisethe WWTP. A summary of the "problem parameters" identified in the RFP is given in Table 1.9-1. The treatedwastewater will be discharged to Bald Eagle Creek in compliance with a NPDES permit obtained from PADER.
Table 1.9-1PROBLEM PARAMETERS FOR DRAKE SITE WASTEWATER TREATMENT
Chlorobenzene 72 - 18,000 Toluene 1.8-8,1001, 2-dichlorobenzene 4.7-440 Barium 28 - 14,8001, 4-dichlorobenzene 3.4 - 1001, 2-dichloroethane 0.1 -5,100 Lead 15,000 - 23,700Fenac 20 - 20,000 Nickel 31.5-424j3-Naphthylamine 1-3,000
WWTP Process Design and Description
The WWTP is designed to treat wastewater SO gallons per minute (gpm). The average wastewater flow rate ofthe WWTP is approximately 33 gallons per minute. The overall treatment process is based on continuousoperation, except for sludge dewatsring. Basic design considerations and descriptions of each unit operation inthe WWTP are briefly discussed below.
Wastewater Equalization
The wastewater will be stored in an equalization tank to prevent any shock loading to the treatment system. Theequalization tank can also serve as a settling tank to remove solids. A polymeric flocculant wean be introduced,to the wastewater through an in-line mixer to enhance solid settling as needed. The solids settled will be removedperiodically from the bottom of the tank and thermally treated.
flR306062
Metal Treatment and Removal
Among the three metals that need treatment, lead (Pb) and nickel (Ni) can be directly precipitated by adjustingthe pH to about 9.5.
The metal treatment and removal will be performed in one unit operation using a multi-chamber reaction unit.This unit consists of three flash-mix reaction chambers and a clarifier. The pH of the wastewater will be adjustedwith sulfuric acid (H2SO4) using an in-line mixer. A lime slurry will then be added to the second reactionchamber to precipitate metals at a pH of 9 to 10. To enhance solid separation, a polymeric flocculant (high-molecular-weight cationic polyelectrolyte) will be added and flash-mixed with the wastewater in the third reactionchamber. The solids will be settled and separated in the Lamella. The metal sludge is transferred from theLamella to the sludge-holding tank.
Air Stripping of Organic Contaminants
The problem organic contaminants are carbon-adsorbable except for 1,2- dichloroethane. However, it can beeffectively air-stripped out of water. Since most of the other organic contaminants are also air-strippable, airstripping in conjunction with carbon adsorption is selected for treatment of the organic contaminants.
The effluent from the neutralization tank will be fed to the air stripper, and air will be pumped into the stripperthrough an air-distribution system at the bottom. The wastewater and airflow will react counter-currently withthe wastewater being discharged at the bottom of the stripper. The air carrying organic constituents will leavethe stripper at the top and will be treated through vapor-phase activated carbon columns to remove the organiccompounds before discharge to the atmosphere.
Granular Medium Filtration
A granular medium filter will be used to remove suspended solids in the wastewater prior to activated carbontreatment. The effluent from the air stripper will be passed downward through the filter bed at a constant flowrate.
Activated Carbon Adsorption
Adsorption in a two-stage granular activated carbon (GAC) filter will remove residual organic contaminants inthe wastewater after air stripping and granular media filtration. Two carbon columns will be operated in series,with one acting as a primary filter and the other used for polishing the effluent. The organic contaminants in theinter-stage effluent will be periodically measured to monitor the filter performance so carbon can be replacedwhen the primary bed becomes saturated.
Sludge-Handling
Sludge generated from the metal treatment will be stored in a sludge-holding tank. This sludge-holding tank willprovide a consistent sludge stream for dewatering. The sludge will be dewatered using a recessed-plate filterpress. This type of filter press produces a filter cake with a high-percent solids content. A filter aid may beadded to the sludge and mixed in a conditioning tank prior to filtration if the sludge is difficult to dewater. Thefilter cake generated will be dropped into a box for subsequent thermal treatment. The filtrate will be pumpedback to the equalization tank for retreatment.
AR306063
Stormwater Treatment Facility (STF)
Stormwater management consists of isolating and storing stormwater from contaminated areas of the material-handling, storage, processing, and treatment areas until it can be treated. It also includes diverting run-off fromcontaminated areas to prevent it from migrating onto uncontaminated "clean" areas.
The STF is designed to treat potentially contaminated stormwater contained on site. The STF is designed to treatstormwater at a rate of 150 gallons per minute. The WWTP can be used to assist in treating potentiallycontaminated stormwater during peak storm events, providing a maximum treatment capacity of 200 gallons perminute. Stormwater generated by a 25-year, 24-hour storm event will be treated in approximately three days atthis treatment capacity. Treated stormwater will be discharged to Bald Eagle Creek in compliance with a NPDESpermit obtained through PADER.
STF Process Design and Description
The process designed by RUST for the Drake project will treat stormwater that contains a lower level ofcontamination than the process waters treated by the WWTP. It is designed for continuous operation to removesuspended solids and organic contaminants at a maximum flow rate of 150 gallons per minute. The facility isequipped with a flow equalization tank, a sand filter, and two activated carbon adsorbers.
Flow Equalization
The stormwater will be contained on site and transferred to a 50,000-gallon equalization tank for introduction tothe treatment system. Since the stormwater may contain suspended solids, the equalization tank will also serveas a settling tank to remove the solids. To enhance solid settling, a polymeric flocculant can be introduced throughan in-line mixer as needed.
Granular Media Filtration
A granular media filter will be used to remove suspended solids from the stormwater prior to activated carbontreatment. The stormwater will be passed downward through the filter bed at a constant flow rate.
Activated Carbon Adsorption
Organic contaminants in the stormwater will be removed by adsorption in a two-stage GAC filter. Two carboncolumns will be operated in series, with one acting as a primary filter and the other being used for polishing theeffluent. The organic contaminants in the inter-stage effluent will be periodically measured to monitor the filterperformance so carbon can be replaced when the primary bed becomes saturated.
1.10 AIR EMISSIONS CONTROL
RUST will perform the remediation operations at the Drake Chemical Superfund Site in such a way as tominimize emission of all airborne contaminants. These emissions include incineration system emissions, andfugitive dust from site preparation, excavation, and backfilling operations.
Site Preparation and Excavation
Due to the potential for airborne migration of dust, site preparation and excavation activities will be designed tominimize dust emissions and insure compliance with the National Ambient Air Quality Standards (NAAQS) forpaniculate emissions.
In summary, air emission control measures employed during the Site Preparation and Excavation Phase include:
0 Trucks will be equipped with bed covers when dry dusty material is transported the trucks will becovered.
° Dust suppressant will be used to minimize dust generation on haul roads and open excavation areas.
° High-density polyethylene or visqueen covers will be used on treated ash and feed stock areas.
Material Handling
Emissions from material handling operations can occur from excavation, transport, and storage of both feedmaterials and incinerator ash. RUST will incorporate dust-suppression techniques during each phase of thematerial-handling operations, as described below. All feed preparation will be done inside the feed preparationbuilding, which is completely enclosed and ventilated through a fan equipped with a particulate filter and vapor-phase carbon units. This ventilation keeps the entire building under a negative pressure, which forces anygenerated dust and volatile organic constituents through the filters. Ventilation filters and carbon units will bechanged when necessary to prevent dust or vapor breakthrough.
The ash handling equipment RUST plans to use for the Drake Chemical project will transport the bottom ash andfly ash for separate analysis and treatment in a safe and controlled manner to prevent fugitive emissions. Thebottom ash is collected, combined, and discharged through a combination dry-bottom conveyor and wet-bottomconveyor system. By wetting the ash, fugitive dust is eliminated as the ash is discharged. The fly ash is handledin a series of screw conveyors which collect fly ash from the evaporative cooler and baghouse. The bottom andfly ash are discharged into the ash handling structure, which is designed to prevent exposure of the dischargedash to rain or wind. Even though the ash is protected from the elements, inspection and wetting is done asnecessary to minimize dust emissions.
Incineration System
The PY*ROX™ 8212 incineration system is designed to meet or exceed all emission standards set forth in Section13590 of the RFP. The PY*ROX™ 8212 is equipped with a state-of-the-art air pollution control system (APCS)designed to demonstrate best available control technology (BACT) for incineration of hazardous waste. Inaddition, all PY*ROX™ 8212 components are designed for airtight operation to prevent fugitive emissions to theatmosphere.
AR3Q6065
Incineration System Fugitive Emissions
The entire incineration system is designed to minimize escape of fugitive emissions including dust. To preventfugitive emissions, the incineration system is operated under negative-pressure conditions at all times. The controlsystem is designed to stop waste feeds automatically if the pressure at the rotary kiln faceplate becomes positive.The incinerator feed system is completely enclosed from the feed preparation building to the rotary kiln faceplate.The interface between the feed conveyor and the feed building is sealed to prevent leakage from the feed buildingto atmosphere, the rotary kiln is equipped with rotary seals to minimize leakage.
Monitoring and Control System
The PY*ROX™ 8212 incineration system is equipped with a monitoring and control system to insure compliancewith all air emission limits. A Continuous Emission Monitoring System (CEMS) is used to measure stack gasconcentrations of carbon monoxide, oxygen, carbon dioxide, total hydrocarbons, and nitrogen oxides. Dual,redundant analyzers are used for each constituent for backup data gathering and alarm capability.
Stack gas flow rate is measured with a velocity transmitter, which is then correlated back to flue gas flow exitingthe secondary combustion chamber (SCC). This allows continuous monitoring of SCC residence time. An SCCresidence time of two seconds or greater, combined with sufficiently high temperature and oxygen concentration,provide assurance that thermal destruction of the organic contaminants is accomplished on an continuous basis.
The PY*ROX™ 8212 incineration system is equipped with a control system designed to automatically maintainprocess conditions in order to allow continuous operation of the system within regulatory limits. Should any ofthe air emission parameters fall outside the acceptable range, the control system's automatic interlock system willbe activated.
Metals Emissions
The PY*ROX™ 8212 will comply with Title 25 of the Pennsylvania Code, Section 127.1 and 40 CFR 266.106(Federal Standard to control metals emissions) with regard to metals emissions. Operation of the PY*ROX™ 8212will result in ground level metal concentrations which are significantly lower than the acceptable Reference AirConcentrations for noncarcinogenic metals (40 CFR, Part 266, Appendix IV) and Risk Specific Doses forcarcinogenic metals (40 CFR, Part 266, Appendix V).
Table 1.10-1 provides a summary of expected metals emissions calculations. Of the ten metals listed in 40 CFR266.106, four carcinogenic metals (As, Be, Cd, Cr), and four noncarcinogenic metals (Ag, Ba, Hg, Pb) wereconsidered. Two noncarcinogenic metals, Antimony and Thallium, were not included in these calculations becausethey were not reported in either the Treatability Study or Remedial Investigation reports. Soil/sediment metalconcentrations used for this evaluation are from the 17 soil characterization samples taken for the TreatabilityStudy, with the exception of Beryllium. Beryllium was not reported in the Treatability Study, so data from theRemedial Investigation were used.
flR306066
Table 1.10-1
SUMMARY OF METALS EMISSION CALCULATIONS;/t;!!l:^Arsenic Cadmiu Chromi Berylliu Aggreg
1) Metals Concentration inSoil/Sediments, ppm:Average
Maximum
18.6
79.6
1.4
11.8
26.8
52.0
1.1
2.3
Barium
105
284
Lead
127
495
Mercur Silver
0.3
0.5
3.5
12.2
2) PY*ROX™ 8212 Metal Emmissions, g/sec:
Average
Maximum1.79E
7.63E
1.20E
l.OOE
2.09E
4.05E
3.88E
8.12E
6.7 IE
1.83E
2.48E
9.72E
2.04E
3.53E
2.29E
8.07E
3) Maximum Annual Average Ground-level Concentration based on ISC2 model. rtg/m}:
Average metals in soil
Maximum metals in soil
5.01E
2.14E
3.35E
2.80E
5.84E
1.13E
1.09E
2.28E
1.88E
5. HE
6.96E
2.72E
5.70E
9.90E
6.42E
2.26E
4) Maximum Annual Average Ground-level Concentration based on Valley model, Mg/m3:
Average metals in soil
Maximum metals in soil
5) Risk Specific Dose
6) Reference Air
2.32E
9.92E
0.0023
1.56E
1.31E
0.0055
2.71E
S.26E
0.00083
5.05E
1.06E
0.0041
8.73E
2.37E
50
3.23E
1.26E
0.09
2.65E
4.59E
0.08
2.98E
1.05E
37) Maximum Annual Ground Level Concentration as a percentage of RSD or RAC:
ISCLT2 model, average
ISCLT2 model,
Valley model, average
Valley model, maximum
2.18%
9.30%
10.10%
43.15%
0.61%
5.10%
2.83%
23.65%
7.04*
13.66%
32.66%63.39%
0.27%
0.56%
1.23%2.58%
10.09%
28.62%
46.83%
132.76
0.00%
0.01%
0.02%
0.05%
0.08%
0.30%
0.36%
1.40%
0.71%
1.24%
3.31%
5.74%
0.00%
0.01%
0.01%
0.03%
I) Metals data from die treatability study soil characterization samples, except for Beryllium data, which is from the remedial investigation.2) PY*ROX™ 8212 metal emissions based on maximum soil throughout.3) ISC2 results based on rural land use option.4) Valley results based on rural" land use option.5,6) RSDs and RACs from "Technical Implementation Document for EPA's Boiler and Industrial Furnace Regulations, March, 1992.
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Both average and maximum soil metals concentrations were used in estimating incinerator emissions and ground-level concentrations. PY*ROX™ 8212 incinerator emissions were calculated using the soil metals concentrationsand expected system removal efficiencies, at a maximum soil feed rate. System Removal Efficiencies used werethose expected to be demonstrated by the PY*ROX™ 8212. Ground-level concentrations were estimated usingdispersion modeling, based on both average and maximum incinerator stack metals emissions.
The BIF rules set forth Risk Specific Doses (RSDs) for carcinogenic metals, and Reference Air Concentrations(RACs) for noncarcinogenic metals which are designed to limit potential exposure to the theoretical maximumexposed individual (MEI). The maximum annual average ground level concentrations predicted by the ISC2 andValley models were compared to the RSDs and RACs. Line 7 of Table 1.10-1 shows the values predicted as apercentage of the RSDs and RACs for average and maximum soils metal content. All values are less than 100percent, except for the aggregate risk for carcinogenic metals using the Valley model with maximum soils metalcontent which represents a worst-case scenario. The Valley model is a screening tool which generally producesupper-limit estimates. In addition, RUST intends to blend soils prior to feeding the incinerator in order tomaintain metals concentrations near average values. Finally, RSDs and RACs are based on 70 years of continuousexposure. The PY*ROX™ 8212 will be in operation for approximately one year. An argument could be made thatthe maximum allowable ground-level concentration should be 70 times the RSD and RAC concentrations.
In summary, based on this preliminary yet conservative evaluation, RUST's PY*ROX™ 8212 will comply with40 CFR 266.106 with regard to metals emissions. No soil throughput restrictions will be required in order toachieve metals emissions compliance.
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1.11 PERIMETER AIR MONITORING
RUST will characterize potential pollutant transport via the applicable exposure pathways during each step of theDrake Chemical site project. Specific air monitoring program objectives involving air pathway analysis follow:
0 To document that the controls being applied to on-site operations are effective in controlling fugitiveemissions of contaminants from the handling and excavation activities; and
0 ' To insure on-site operations do not create an unacceptable public health risk to the community.
To insure the highest degree of accuracy and precision is available during all aspects of the monitoring ofemissions at the site, RUST will develop a comprehensive program for perimeter monitoring, and associateddocumentation. Through this Perimeter Air Sampling Plan (PASP), RUST will state how the perimeter monitoringprogram will be organized, conducted and documented.
The PASP will specify minimum procedures that must be used to ensure that the accuracy, precision,completeness, and representativeness of the resulting measurement data are known, documented, and sufficientto achieve contract requirements. RUST will prepare a PASP that will meet all USEPA and the PennsylvaniaDepartment of Environmental Resources (PADER) regulatory requirements. The PASP will include the mainplan, and a stand-alone quality assurance project plan (QAPP) for perimeter air monitoring.
The PASP will include monitoring methodology used to check compliance with established action levels for bothlong- and short-term compliance monitoring. RUST will address both short- and long-term monitoring activitiesin this document. Examples of the proposed Table of Contents for the PASP, and QAPP are illustrated in Table1.11-1 and Table 1.11-2, respectively.
Sampling Methods
Selection of the proper sampling and analytical method for the site target list is dependent on several interrelatedfactors. These include the compound or compounds of interest, the level of detection required, the degree ofselectivity needed, and the purpose of the data collected.
The sampling and analytical methodology selection criteria for the Drake Chemical site reflects RUST's evaluationof established method availability, QA/QC database applicability to Superfund monitoring, cost effectiveness, andsafety. In general, sampling and analytical methods were selected from the following publications:
° Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air, W. T.Winberry, Midwest Research Institute, EPA-600/4-89-018;
° Air/Superfund National Technical Guidance Study Series, EPA-450/1-89-002; and0 Final Statement of Work for the Analysis of Air Toxics Taken at Superfund Sites as Part of EPA's
Contract Laboratory Program at Superfund Sites, W. T. Winberry, Midwest Research Institute,December, 1991.
To meet the monitoring objectives specified in the RFP, RUST recommends monitoring methods, which are bothtime-integrated and continuous. Table 1.12-3 identifies the proposed methods.
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Table 1.11-1PERIMETER AIR SAMPLING PLAN TABLE OF CONTENTS
Section 1.0
Section 2.0Section 3.0
Section 4.0
Section 5.0
Section 6.0Appendix A
Appendix B
Appendix C
Appendix D
Project Objectives, Objectives of the Perimeter Air Sampling Plan (nASP)1.1 Project Objectives1.2 Perimeter Air Sampling Plan (PASP) Objectives1 .3 Project OrganizationBackgroundSampling and Analytical Methodology Selection3.1 Time Integrated Monitoring3.2 Real-Time MonitoringFixed Sampling Activities Drake Chemical Supertund Site4. 1 List of Field Equipment, Containers, and Supplies4.2 Sampling Locations4.3 Sampling and Analytical Methods and FrequencySample Chain-of-Custody, Packing, and Transportation5.1 Chain-of-Custody Procedure5.2 Sample Packing5.3 Sample TransportationData Reduction. Validation, and DocumentationCalibration, sampling, and analytical procedures for Total Suspended Paniculate (TSP) matter and metalanalysis at Drake Chemical Supertund Site utilizing high-volume sampler (Federal Reference Method)Calibration, sampling, and analytical procedures for semi-volatile organic compounds (including FenacNaphthylamine) in ambient air at Drake Chemical Superfund Site utilizing high-volume PUF sampler(Compendium Method TO- 13)
and/3-
Calibration, sampling, and analytical procedures for volatile organic compounds in ambient air at DrakeChemical Supertund Site utilizing pressurized SUMMA* canisters (Compendium Method TO-14)Real-Time Monitoring for volatile utilizing the HNU model 501 DP gas chromatograph with 10-pointsequential sampling probes.
Table 1.11-2QUALITY ASSURANCE PROJECT PLAN TABLE OF CONTENTS
Title Page - QAPP approval by project manager, QA coordinator, remedial project manager, or on-site coordinatorTable of Contents - Specifies number of pages, revision number, and date of last revisionProject Description - General description of measurement programProject Organization and Responsibility - Organization chart identifying ail key individualsData Quality Objectives - Specification for precision, accuracy, and completeness of measurement systemsSite Selection and Sampling Procedures - Documentation of proposed monitoring site locations and rationaleCalibration Procedures - Description of calibration procedures and their frequency, along with "out-of-control" conditionsAnalytical Equipment and Procedures - Discussion of EPA-approved procedures referenced in the PASPData Reduction, Validation, and Reporting - Discussion of all equations, flagging and validating data, reporting.procedures (both real-time and time-integrated) referenced in the PASPInternal Quality Control - Procedures, control limits, corrective action and frequency with which QC checks will beperformed on real-time and time-integrated monitorsPerformance and System Audits - Discussion of methods used to achieve QA goals and objectivesPreventative Maintenance - Discussion of scheduled preventative maintenance to insure and monitor availability of 90percentProcedure to Evaluate Data Precision, Accuracy, and Completeness - Discussion of specific procedures to be referencedin the PASPCorrective Action - A plan for initiating and implementing corrective actionQA Reports to USEPA, PADER and USAGE - Discussion of mechanism for reports ^^^
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Table 1.11-3PERIMETER AIR MONITORING METHODS
Qrganics
• Volatile
• Semi-volanles(i.e., Fenac, fi-Naphthylamine, etc.)
Inorganics
• Particulates and Metals
Meteorological
Data acquisition system
&i:jja:l::;:;:S;;::e;gliiifp:;:!!!!*!!^
I. Real-time monitoring of ambient aircollected through sample loop andanalyzed by GC/PED
II Time-integrated monitoring bycollection in stainless steel SUMMA*canisters utilizing pump system(Compendium Method TO 14)
Collection on polyurethane foam (PUF/XAD-2) plugs in a high volume sampling apparatus(Compendium Method TO-13)
Collected on 8 inch x 1 1 inch glass fiberfilters utilizing EPA high volume samplingtechnique (Federal Reference Method)
Real-time measurements involving windspeed, wind direction, ambient temperature.Delta T, and radiation (Federal ReferenceMethod)Data management systems for the transfer,storage, and manipulation of data to createmonthly reports for on-site assessment ofenvironmental emissions
Gas chromatography equipped withphototonization detector for real-time analysis
Analysis by cryogenic concentration followedby gas chromatography/mass spectroscopy(GC/MS) analysisSoxhlet extraction, concentration of theextract, and analysis using gaschromatography (GC) with massspectroscopy (MS) detection or high-performance liquid chromatography (HPLC)with appropriate detectors
Gravimetric weighing of filter for TSPfollowed by filter extracted in HCI/HNQ,,microwave extraction and analyzed byinductively coupled argon plasmaspectroscopy (ICAP) analysis for metalsReal-time measurements involving windspeed, wind direction, ambient temperature.Delta T, and radiation
Data management systems for the transfer,storage, and manipulation of data to createmonthly reports for on-site assessment ofenvironmental emissions
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Number and Location of Sampling Sites
RUST suggests that four stations will be located at approximately 90° intervals around the site. The mobile stationcontaining a PS-1 semi-volatile and high-volume TSP monitor will be used as part of the QA/QC program toserve as a co-located sampler during each integrated sampling events.
The base station and office for the perimeter air monitoring program will house the real time GC (HNu) analyzerfor real-time speciated VOC monitoring, and the Central computer system, as part of the ESC Model 8800 AirMonitoring Data Acquisition System, which will log the HNu data and the data from the 10-meter meteorologicalstation.
The base station will be a weather-resistant building and will house all of the monitoring equipment. Thecomponents of the base monitoring station include: (1) weather-resistant shed, approximately 10 by 12 feet; (2)HVAC equipment to constantly maintain a temperature of 60 to 80°F and a relative humidity of 45 to 65 percent;(3) rock pad to support the housing; and (4) utilities necessary to support routine environmental monitoring.
The base station will monitor VOC emissions at each of the perimeter stations. This will be accomplished byutilizing the HNu Model 301 Multi-Point Sequencer. Sampling lines will extend out to the perimeter samplingstations and along the western perimeter of the American Color and Chemical Corporation property, up to 1,000feet from the station. In operation, a fresh sample is extracted from the inlet of the sampling probe to the HNuGC system sequentially from each of the sampling points. This HNu system will also be used to monitor aminimum of four locations within the workplace, when deemed necessary by the HSO. By utilizing this approach,a well-defined characterization of the air pollutants can be documented either entering or leaving the site.
Stations 1, 2, 3, and 4 will be located on approximately. 90° intervals arround the site. These stations will containa PS-1 semi-volatile and high-volume TSP monitor. Station 1 serves as the predominant upwind site based uponthe previous five (5) year meteorological data, which includes the 1992-1993 meteorological daia base. Station5 serves as a co-located mobile station during each of the integrated sampling events. The station is a mobile unit,able to be positioned at any of the other perimeter sites. This station will contain a PS-1 semi-volatile and high-volume TSP monitor.
Sampling Periods and Frequencies
The following sampling periods have been selected for the different classes of compounds at the site: (1)volatiles- continuous and time-integrated; (2) semi-volatiles-time-integrated; (3) particles and metals-time-integrated; and (4) meteorological-continuous.
RUST has selected sampling frequencies for the site that are commensurate with program objectives and theSolicitation during each stage of the remediation effort.
Meteorological Station
RUST proposes to locate the 10-meter tower meteorological station at the northern (upwind) portion of the site.
Meteorological variables will be collected continuously at the site. These variables include mean wind speed, winddirection, ambient air temperature, solar radiation, and precipitation.
The measurements taken at the meteorological station will be recorded and stored on a data collection node(DCN) on the 10-meter tower as part of the ESC Air Monitoring Data Acquisition system. This system will be
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hard-wired to the base station.
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2.0 WORK PLAN
Development and implementation of the Work Plans are critical to successful projectperformance. RUST will use the Work Plans to communicate to individual employees andsubcontractors to ensure that all work is performed in the manner agreed to by USAGE. RUSTPlans for the Drake Chemical site remediation project require integration of technical expertiseand management proficiency. RUST will therefore assign corporate resources and staff to WorkPlan development beyond the minimum required by the USAGE and the Drake contractspecifications, while maintaining a cost-effective approach. RUST will use specialists inappropriate disciplines to assist the Project Manager and his staff to develop complete, accurate,and effective Work Plans which comply with the specification requirements.
RUST has previously developed and successfully implemented Work Plans on two large-scaleincineration remediation projects: Bog Creek Farms and Old Midland Products (OMP). Theexperience gained in developing the work plans for these two projects means effectivedevelopment of quality work plans for the Drake Chemical project. Several key people assignedto the Drake Chemical project were involved in the development and implementation of WorkPlans for one or both of these projects: Project Manager - OMP; and Process Manager - bothprojects.
The following provides summaries of some of the critical Work Plans, and explain how RUSTintends to approach Work Plan development, commissioning, mobilization, and demobilizationof the Drake Chemical project.
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2.1 PREPARATION PLANNING FUNCTIONS
RUST will meet all preoperational planning requirements as defined in the SOW. The ProjectManager (PM) will assemble the team to finalize work plans for submittal to the USAGE. Allwork on submittals will be under the direction of the PM. All submittals listed on EngineeringForm 4288, "Submittal Schedule", in Section 01300 of the Scope of Work (SOW) will besubmitted in accordance with the schedule. Following approval and certification by RUST'sQuality Control Manager (QCM), all submittals will be transmitted under the cover of a properlycompleted Engineering Form 4025, "Transmittal of Shop Drawings, Equipment Data, MaterialSamples, or Manufacturer's Certificates of Compliance". The following sections briefly describethe Chemical Quality Management Sampling Plan, the Health and Safety Plan, and the ContractorQuality Control Plan which will be developed during the planning phase of the project.
Chemical Quality Management/Sampling Plan (CQMSP)The goal of the CQMSP is to establish guidance for producing high-quality analytical data thatare accurate, technically sound, and legally defensible during the execution of the DrakeChemical project. The CQMSP that RUST will implement will be based on "Chemical DataQuality Management for Hazardous Waste Remedial Activities" from USAGE ER 1110-1-263,Appendix D. The chemical quality assurance (QA) program that RUST used at the Old MidlandProducts site in Arkansas and the Bog Creek Farm site in New Jersey was very similar to theCQMSP to be employed at the Drake Chemical site. This section briefly describes a few of thekey components of the Drake project CQMSP, an outline of which is presented in Table 2.1-1.
Analytical CapabilitiesRUST is fully capable of analyzing all streams and constituents specified in the SOW to thePractical Quantitation Limits listed therein. RUST will analyze samples from each of thefollowing streams:
° Contaminated soil from excavation activities.° Incinerator ash and air pollution control system residue prior to backfilling on site.° Ambient air and incinerator stack emissions° Materials from personnel health samples° Wastewater treatment plant discharge to verify compliance with the National Pollutant
Discharge Elimination System (NPDES) requirements.° Nonincinerable solids to verify decontamination.0 Drums uncovered during excavation.° Wipes and rinsate samples which were used to verify equipment decontamination.
To optimize performance, RUST will use an on-site and off-site approved laboratories.
Field Sampling ProtocolAll sampling activities performed by RUST or its subcontractor will be in accordance with theRUST CQMSP, which will be based on specific USEPA, USAGE, NIOSH, and ASTM(American Society for Testing and Materials) guidelines.
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Table 2.1-1
CHEMICAL QUALITY MANAGEMENT/SAMPLINGPLAN (CQM/SP) OUTLINE
1) Project Description2) Chemical Data Quality Objectives3) Drake Chemical Superfund Project Organization4) Field Sampling Activities
List of field equipmentSampling locationsContainers, preservations, and holding itemsSampling protocols
5) Sample Handling6) Laboratory Analytical Procedures
Sample preparation and sub-samplingAnalytical methodsMethod-specific data quality objectivesPreventive maintenance instrument calibration andfrequencyInternal quality control checksCorrective actionData reduction, validation and documentation
7) CQM/SP Deliverables
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All samples for NPDES discharge will follow the guidelines of 40 CFR 136. Sampledocumentation will include sampling locations, sample preservatives, waste name, sampleidentification, sampler's initials or signature, date and time of sampling, and Quantity of field-collected quality control and/or split samples. This information is recorded as appropriate, onchain-of-custody records, sample labels, and bound field logbooks. Samples to be shipped off sitefor chemical analysis will be packed to prevent breakage.
Quality Assurance/Quality Control PolicyResponsibility for QA/QC with regard to the CQMSP rests primarily with the lab manager (LM)and the staff of chemists and technicians in the laboratories. All laboratory personnel will becompletely versed in the QA/QC provisions of the CQMSP. The quality control manager (QCM)will provide an independent QA/QC assessment.
The RUST CQMSP will address the percentage and types of QC checks, including blanks,duplicates, splits, spikes, and reference standards. Internal laboratory QC will include one spikeand one spike duplicate per 20 samples, and one laboratory blank per 20 samples. Field QAsamples will include at least 10 percent blanks and split/duplicates. In addition, 10 percent blankand 10 percent split/duplicates will be collected for external QA analysis by USAGE'S MissouriRiver Division Laboratory.
For the duration of the Drake project, laboratory instrumentation and equipment will be calibratedusing known concentrations traceable to nationally recognized standards. Prior to analysis, eachinstrument and procedure will be calibrated according to applicable methodology. Calibrationswill be properly recorded and periodically reviewed by the LM. If equipment inconsistency ordeterioration is detected, immediate corrective action will be taken. Any significant problem withanalytical data or instrument calibration will be reported immediately to the CO,
Daily Chemical Quality Control Reports will be submitted to the USAGE and will includeinformation such as test results, calibration documents, inspection reports, and corrective actions.Every six months, a Quality Control Project Summary Report covering practices, problems, andcorrective actions will be submitted to the CO.
Health and Safety RequirementsRUST maintains an ongoing health and safety program that implements the requirements ofOSHA 29 CFR 1910.120 - "Hazardous Waste Operations and Emergency Response". Whileworking at the Drake site, RUST will also comply with the USAGE "Safety and HealthRequirements Manual" (EM 385-1-1) and the USAGE "Safety and Occupational HealthDocument, Requirements for Hazardous Waste Site Remedial Actions" (EM 385-1-92), as wellas all other applicable regulations and publications.
RUST has extensively studied the hazards and planned work tasks at the Drake Chemical site.The SSHP will identify the safety and health hazards of each phase of site operations, and specifythe requirements and procedures for employee protection. RUST has developed a unique andappropriate approach to addressing the hazards at the Drake Chemical site. RUST's cost-effective, on-site /3-naphthylamine (BNA)-contamination-detection system ensures a highlyeffective, unique method of preventing employee exposure, minimizing contamination spread, andreducing risk as much as possible. RUST's comprehensive corporate health and safety programensures that the Drake SSHP will be not only a useful document, but also an ongoing process.RUST will continuously review the methods and procedures used to control site hazards,
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providing the highest protection for workers, USAGE, and the public.
Health and Safety Staff and CoordinationThe RUST health and safety team for the Drake site includes a Certified Industrial Hygienist(CIH), Health and Safety Specialist (HSS), and Health and Safety Monitors (HSMs). All RUSTpersonnel chosen to support the Drake project have excellent credentials and experience exceedingthe minimum requirements specified in the SOW. This will ensure that the project receiveseffective health and safety support. Consistent implementation of the SSHP will be accomplishedby maintaining at least one member of the RUST health and safety team on site wheneveroperations are in progress. In addition, all health and safety personnel assigned to the Drake sitewill be RUST employees.
Staff ResponsibilitiesThe CIH is responsible for the overall development, implementation, and oversight of the RUSThealth and safety program. The CIH, together with the HSS, will verify that the SSHP addressessite hazards during all phases of the Drake Chemical project. Any additions or modifications tothe SSHP will be approved by the CIH prior to submission to the contracting officer (CO). TheCIH will also develop and deliver site-specific health and safety training. At a minimum, the CIHwill be on site during initial site-specific employee training, the first week of remediation, andperiodically for the duration of the project. The CIH will also be available for emergencies.
The HSS will serve as the on-site health and safety representative with the responsibility ofassisting operations in the implementation and enforcement of the SSHP. Recognizing that theoverall responsibility for health and safety at the Drake site lies with the Project Manager, theHSS will report directly to the PM for daily assignments and activities. In addition, the HSS willhave direct ties to corporate health and safety personnel to assure independent and authoritativeproblem resolution by the health and safety function.
The RUST team of HSMs will report directly to the HSS. The HSMs will provide coverage forthe active work area. HSMs will be responsible for employee exposure monitoring, anddocumentation of any potential employee exposures.
Emergency ResponseRUST will implement an emergency response and contingency plan for the Drake Chemical siteas specified in 29 CFR 1910.120 (1). The plan will be designed to prevent and minimize theimpact of unplanned events that could threaten the health and safety of site workers or the localcommunity. These events could include:
0 Employee injury/illness,0 Fire/explosion,0 Environmental release,° Severe weather conditions, and° Adverse community reaction.
RUST will provide plans for and implement the following specific items in order to prepare forthese potential emergencies:
° Emergency Response Training,° Contingency Planning,° Emergency Medical Care,
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° Lines of Communication,o Emergency Warning Systems, and° Evacuation Plan.
TrainingRUST is committed to providing qualified employees for the Drake site, Al! RUST employeeswill receive initial health and safety training required by their position descriptions before the arepermitted to engage in hazardous waste operations or handle hazardous substances. Fieldpersonnel working with hazardous materials at the Drake site will have completed at least 40hours of OSHA-required hazardous waste operations training as specified in 29 CFR 1910.120,followed by close on-site supervision for at least three days. Elements of the initial employeetraining for the Drake site will include at least the following elements:
0 Project organization and function,0 Site description,0 Work-plan review,0 Basic job site hazards,0 Drake site hazard communications program,0 Medical surveillance reporting requirements,0 Safe work practices,° Personal protective equipment (PPE),° Work zones and decontamination,° Emergency procedures and notification, and0 Air monitoring (and surface monitoring) requirements.
Depending upon job responsibilities, initial employee training may also include specialized healthand safety training and information, such as CPR/First aid, or Fire protection/flrefighting. Allfield supervisors shall have completed, as a minimum, an additional eight hours of training inhazardous waste site supervision. Successful completion of health and safety training courses iscontingent upon completion of an examination that documents subject proficiency. Certificatesare issued to employees meeting these requirements.
To assist site personnel in conducting their activities safely, health and safety information updatesare provided at safety briefings conducted at the beginning of each work shift. All RUST and.subcontractor personnel are required to attend. Personnel arriving at the site at a later time arerequired to complete an individual briefing with the HSS or HSM before beginning work.
Amendments to SSHPThe Drake SSHP will be reviewed and approved by the RUST CIH and submitted to theContracting Officer (CO) for approval prior to commencing any work. After the initial SSHP isapproved by the CO, it may become necessary for RUST to develop amendments to adequatelyaddress new information or unexpected hazards. Modifications to the initial plan may bewarranted as the results of previously collected data become available. All proposed changes tothe SSHP will be reviewed by the RUST CIH. If approved by the CIH, the proposed changes willthen be submitted to the CO for approval.
Site Access Control .The main intent of site security is to control project activities in order to minimize the transferof potential hazardous substances from the site. This will be accomplished by the implementationof a security force responsible for the security and well-being of all site personnel, visitors,
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equipment, vehicles, and field facilities. Site control requires the establishment of a regulatedarea, designated work zones, evacuation protocol, and site security;
Adequate security personnel will be employed so that continuous security is present on the DrakeChemical site. Shifts will rotate and overlap to provide continuity between Security Officers (SOs)in regard to site activities, reporting, and security matters. Security personnel will be fullydevoted to monitor, authorize entry, and inspect all areas of the Drake Chemical site on acontinuing basis, and will not serve in production work effort. Site access will be controlled byimplementing the following programs:
0 Visitor and Traffic Control - Control of all activities at the entrance gate will be theresponsibility of the security personnel on duty. All unauthorized vehicles and personnelwill be excluded from the site.
0 Security Checks and Patrols - SOs will frequently patrol the site and the perimeter fence,and will ensure that all on-site equipment is secure from theft or vandalism.
0 Protocol for Security Breaches - Unauthorized personnel attempting to enter the Site willbe advised by the SO that they will be prosecuted for unauthorized entrance. In the eventthat unauthorized persons have entered the site, they will be detained if possible, and thePM and the local police authority will be notified.
Medical SurveillanceRUST employees receive baseline and periodic medical evaluations in accordance with 29 CFR1910.120. The medical surveillance program is administered and maintained by the RUST CIHand the RUST consulting Occupational Physician (OP). RUST has also implemented a Drug-FreeWorkplace policy, which includes pre-employment and random drug screening. Medicalsurveillance examinations will include a number of special tests to address the contaminants atthe Drake site. RUST will comply with the medical examination aspects of the OSHA standardfor jS-Naphthylamine (29 CFR 1910.1009). These tests will be performed in addition to thestandard preplacement and annual examinations provided for all hazardous waste workers.
Each prospective employee will have a pre-project, baseline medical evaluation to determinefitness for the job assignment prior to work at his or her site. The candidate's assignment to theproject is contingent upon the examining physician's opinion that the candidate meets the medicalcriteria established for the job and can perform the essential functions of the job. At the discretionof the OP, the baseline medical examination for the Drake project will include the following:
. i
° Complete medical and occupational work history° General physical examination0 Complete blood count° Electro-cardiogram° SMAC/21 blood chemistry screen° Urinalysis with microscopic examination° /3-Naphthylamine urinalysis screeno Pulmonary function test (FVC and FEV 1.0)° Chest X-Ray (no more frequently than every two years)° Audiogram
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o Visual acuity measuremento Ability to wear respirator° Stress exam
Based on the results of this examination and other pertinent information, a medical certificationas to the fitness for employment on this project, or any restrictions on that employee's ability toutilize personal protective equipment, will be provided to the CO. Each RUST employee whomay be potentially exposed to waste materials or who must wear a respirator for more than 30days per year will receive an annual examination. RUST will also perform special examinationsas directed by the OP to address the special health hazards posed by the Drake Chemical site.Special medical examinations or consultants will be arranged for all employees exposed in anemergency situation or without adequate protection to hazardous substances at concentrationsabove the Permissible Exposure Limit (PEL).
Contractor Quality Control (CQC)Contractor Quality Control is the means by which RUST will assure that all prime andsubcontract work complies with the requirements of the contract plans and specifications withrespect to quality of materials, workmanship, construction, finish, functional performance, andaccuracy of data.
ApproachEstablished RUST quality assurance/quality control (QA/QC) procedures will be implemented atthe project. The main theme of RUST's QA/QC procedures stems from RUST's definition ofQuality: Conformance to Requirements. All systems are designed to ensure that designspecifications and drawing requirements are achieved and documented.
Quality Assurance (QA) by RUST includes all activities necessary to ensure a structure, item, orsystem will function satisfactorily in service. RUST quality assurance includes QA programdevelopment; specification, drawing, and design reviews; vendor surveillance; and independentverification of construction and related testing activities. QA also provides technical expertise inspecialty areas, such as welding technology and inspection, nondestructive examination, postweldheat treatment, and civil technology and testing. The RUST QA effort at the Drake site willinclude inspection and testing of concrete, structural steel, piping, equipment installation, andelectrical/instrumentation installation. RUST will conduct a three-phase inspection and testingprogram (preparatory, initial, and follow-up inspections) for construction activities to ensure therequirements of the engineering documents are met. Quality control (QC) is the first-lineinspection and verification that quality is built into the final product. QC is the responsibility ofeveryone in construction operations, including management, engineering, constructionsupervision, subcontractor coordinators, and receiving.
Subcontractors will be responsible for providing or calling for inspection and testing, whicheveris required in their contractual documents. RUST will provide the third-party testing facilitiesthrough a subcontract arrangement with a local, industry-recognized lab. .
Experience in Preparing Contractor QC PlanRUST has a staff of 21 field QC personnel at its corporate headquarters, each averagingapproximately 20 years of professional experience and 15 years of direct QC experience. Mostof these people have had extensive experience preparing QC plans for projects in which the U.S.Army Corps of Engineers (USAGE) was involved.
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2.2 COMMISSIONING AND STARTUP
RUST'S PY*ROX™ 8212 Thermal Destruction Facility (TDF) will be delivered to the site, willbe brought on-line, and will achieve regulatory compliance in the following steps:
° Foundation installation° Incineration system delivery and staging° Incinerator system set-up° Mechanical check-out and commissioningo Readiness testing0 Mini-burn testing° Trial burn testing
Foundation installation will be preceded by excavation of contaminated soil and placement ofclean fill. Incineration system delivery will be coordinated using the option of an off-site stagingarea for major components.
Incineration system set-up will begin with installation of the large process components, such asthe rotary kiln and the secondary combustion chamber (SCC), on the cured foundations. Next,preassembled, modular ancillary equipment, such as burner systems and pump skids, will beinstalled. After all equipment has been placed, piping and wiring will connect pre-wired,equipment-mounted terminal boxes with the electrical and instrument trailers that house the motorcontrol center and control room. Mechanical check-out and commissioning entails continuitychecks for electrical circuits, motor rotation confirmation, pressure testing of all piping, burnerlight-off, and final curing of all refractory. ,
Readiness testing will be conducted using clean imported soil to prove the incineration system ismechanically and thermally ready to treat contaminated soil. During readiness testing, theincineration system will be operated as if contaminated soil is being treated. During the test,system performance will be evaluated. To fine-tune the incinerator, a "mini-burn" will beconducted to provide a data set nearly identical to that of the official trial burn.
The comprehensive trial burn will be conducted to provide documented proof of the PY*ROX™8212 system's environmental compliance. The trial burn will include testing for destruction andremoval efficiency (DRE) of the principal organic hazardous constituents (POHCs), stack gaspaniculate concentration, metals emission levels and removal efficiency, hydrochloric acid (HC1)emissions and hydrochloric acid removal efficiency, and dioxin/furan emissions.
Trial BurnRUST will subcontract to perform stack sampling and data collection during the comprehensivetrial burn, in accordance with the latest USEPA and PADER requirements and guidance. Trialburn results will be compiled and reported as specified in the general format established by theUSEPA handbook, "Guidance on Setting Permit Conditions and Reporting Trial Bum Results,"USEPA/625/6-89/019, January, 1989. The trial burn will consist of one test condition withtriplicate testing, for a total of three test runs. A pretrial burn test (miniburn) will be conductedapproximately two weeks before the trial burn. Prior to performing the trial burn, RUSTwillperform the following r
° Prepare a Trial Burn Plan (TBP) with a Quality Assurance Project Plan (QAPP) and a
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Trial Burn Report format.° Provide preliminary drafts for review by the regulatory agencies.0 Prepare written responses to the regulatory agencies' comments.0 Revise the three documents to include agreed-upon changes.
Prepare Trial Burn Plan (TBP)RUST will prepare a comprehensive Trial Burn Plan (TBP) and a Quality Assurance Project Plan(QAPP). RUST will be totally responsible for all contract operation and will review all activities.RUST will provide a preliminary draft for review by USAGE; a draft for submission to USEPA,Region III, and the Pennsylvania Department of Environmental Resources (PADER); and a finalplan.
The Trial Burn Plan will meet all USEPA and PADER regulatory requirements, and will bedesigned to demonstrate adherence to the current hazardous waste incinerator regulations.Method clarifications and assumptions will be delineated in the Trial Burn Plan. The trial burnwill be performed at one set of conditions using on-site contaminated soil for the waste feed.
To accomplish this objective, RUST will work closely with USAGE representatives to (1) developa TBP that includes effective test protocols, (2) meet contractual requirements of the TBP, and(3) manage the successful implementation of the TBP.
Trial Burn Plan (TBP) FormatThe TBP format and contents will be prepared to meet current Federal and State of Pennsylvaniaguidelines. The Trial Burn Plan will include a main test plan and a QAPP. An example formatfor the TBP is shown in Table 2.2-1, and an example format for the QAPP is shown in Table2.2-2.The TBP and QAPP will be prepared in accordance with the most recent regulatory guidancedocuments, including:
° "Guidance on Setting Permit Conditions and Reporting Trial Burn Results,"USEPA/625/6-89/019, January, 1989.
° "Hazardous Waste Incineration Management Guidance Manual," USEPA/625/6-89/021,June, 1989.
° "Guidance on Metals and Hydrogen Chloride Controls for Hazardous WasteIncinerators," Draft, USEPA, March, 1989.
o "Guidance on PIC Controls for Hazardous Waste Incinerators," Draft, USEPA, April,1989.
0 "Proposed Methods for Stack Emissions Measurement of CO, O2, THC, HC1 and Metalsat Hazardous Waste Incinerators," Draft, USEPA, November, 1989.
° "Quality Assurance/Quality Control Procedures for Hazardous Waste Incineration,"USEPA/625/6-89-023, January, 1990.
o "Technical Implementation Document for EPA's Boiler and Industrial FurnaceRegulations," USEPA/530-R-92-01, March, 1992.
The TBP will include an engineering description based on the design and technical informationof the incinerator.
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Table 2.2-1
EXAMPLE OUTLINE OF TRIAL BURN PLAN
Preface
1.0 Introduction2,0 Facility Description3.0 Trial Burn Conditions
3.1 Number of test runs3.2 Operating conditions for the trial bum3.3 Wast feed characteristics3.4 Selection of proposed principal organic hazardous constituents (POHCs)3.5 Analyze amounts collected in sampling trains3.6 Limit of quantitation (LOQ) to be detemined for POHC emissions
4.0 Sampling and Monitoring Plan4.1 Sampling and monitoring locations4.2 Sampling and analysis protocol4.3 Process monitoring protocol4.4 'Waste feed spiking
5.0 Sampling Procedures5.1 Stack emissions sampling5.2 Waste feed sampling5.3 Auxiliary fuel sampling5.4 Scrubber effluent sampling
6.0 Sample Handling and Analysis6.1 Sample handling and preparation6.2 Sample analysis
7.0 Reporting of Results7.1 POHC destruction and removal efficiency7.2 Paniculate matter emissions7.3 Hydrogen chloride and chlorine emissions7.4 Metals emissions7.5 PCDD/PCDF emissions7.6 Waste feed analysis7.7 Scrubber effluent analysis7.8 GEM results7.9 Proposed report outline including appendices
8.0 Permit Compliance Objectives
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Table 2.2-2EXAMPLE OUTLINE OF QUALITY ASSURANCE PROJECT PLAN (QAPP)
1. Title Page2. Contents3. Project Description4. • Project Organization and Responsibilities5. Procedures for Assessing Data Quality6. Sampling Procedures7. Sampling Control8. Calibration Procedures and Frequency9. Analytical Procedures
10. Data Reduction, Validation, and Reporting11. Internal Quality Control Checks12. Audits13. Preventive Maintenance14. Specific Procedures Used to Assess Data Quality15. Remedial and Corrective Actions16. QA Reports to Management
The TBP will also include detailed procedures (or incorporate procedures by reference, asappropriate) for collecting and analyzing all samples during the trial burn. RUST will use theprocedures normally required by USEPA and PADER for Resource Conservation and RecoveryAct (RCRA) trial burns.
Quality Assurance/Quality Control (QA/QC) requirements and procedures for sampling,monitoring, and analysis activities will be clearly defined in the QAPP to ensure that datagenerated during the trial burn will be suitable for their intended use. An outline of specificmeasurement (i.e., data quality objectives) will be provided in the QAPP.
Permit-Related ObjectivesRUST will assist USACE in ensuring that the trial burn addresses confirmation of Groups A, B,and C control parameters according to USEPA guidelines, as required in the record of decision(ROD). Key waste characteristics and process operating parameters are to be identified in theTBP, along with the values or quantities expected to be achieved during the trial burn. RUST willfollow the approach in the "Guidance on Setting Permit Conditions and Reporting Trial BumResults". RUST is very familiar with this approach.
Conduct Trial Burn Test and Prepare Trial Burn ReportA subcontractor to RUST will supply necessary personnel and equipment for stack sampling anddata collection during the comprehensive trial bum. Prior to the trial, a miniburn test will beconducted to verify operating conditions.
The main objectives of the trial burn are to measure:
° The destruction and removal efficiencies (DREs) for principal organic hazardousconstituents (POHCs).
° The stack gas paniculate matter concentration.
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° The metals removal efficiency and emission levels.° The polychlorinated dibenzo-p-dioxin/polychlorinated dibenzofuran (PCDD/PCDF)
emission levels.o The stack gas hydrochloric acid (HC1) and chlorine (C12) emissions and HC1 removal
efficiency.° The iS-naphthylamine concentration in the treated fly and bottom ash.0 The volatiles and semi-volatiles concentration in the treated fly and bottom ash.
All trial burn runs will include (1) manual logging of process operating parameters; (2) samplingand analysis of soil feed for metals, proximate analysis, and semivolatile POHCs; (3) stacksampling and analysis for PM/HC1/C12 using a Method 5-based train according to USEPA Method0050; (4) stack sampling and analysis for semi-volatile POHCs, 10 largest peaks for PICs,PCDD/PCDFs, using a semi-volatile organic sampling train (SVOST) according to USEPAMethod 0010; (5) stack sampling and analysis for metals (Ag, As, Ba, Be, Cd, Cr, Hg, Pb, Sb,and Tl), using USEPA's latest draft method for multiple metals emissions sampling (USEPAMethod 29).
The pretrial burn test (miniburn) will consist of one run conducted under one test condition. Thistest run will include: (1) sampling and analysis of soil feed for POHCs; (2) stack sampling andanalysis for PM/HC1/C12 using a Method 5-based train according to USEPA Method 0050; (3)stack sampling and analysis for semi-volatile POHCs using a SVOST according to USEPAMethod 0010 as modified per Method 23; (4) stack sampling and analysis for metals (As, Cd,Cr, Be, Hg, and Pb).
Establishment of Trial Burn Test ConditionA system check-out on clean soil will be performed prior to introducing contaminated material.A pretrial burn test (miniburn) will be conducted two weeks prior to the trial burn. This miniburnwill be conducted to demonstrate that any changes made in the system operating conditions resultin 99.99% ORE for POHCs. Sampling and analytical techniques will be evaluated and refined,if necessary, during this phase.
Demonstration of the performance of the incinerator facility will be conducted during the trialburn using three independent runs. During each run, process parameters will be measured, andsamples collected, to develop independent assessment of all performance standards. RUST may,with the concurrence of the regulators, elect to perform a fourth run at the same test condition.The primary purpose of the fourth test run is to protect against sample loss, and to ensure theachievement of the completeness objectives set forth in the QAPP.
The purpose of the trial burn is to provide data on DRE for POHCs, paniculate concentration,hydrogen chloride removal efficiency and emission rates, chlorine emission rates, and metalremoval efficiency rates. It is proposed that during the trial burn, the contaminated soil on sitebe used. To ensure that detection limits required for POHC sampling of the stack gas areachieved, this waste will be spiked with POHCs or other constituents as necessary to achieve thedesired concentration.
RUST will recommend waste-feed rates and review waste-feed constituents and concentrationssuch as chlorine, metals, and POHCs which will demonstrate the required performance standards.Detection limits for POHCs arid metals, and recommend feed concentrations for these constituentswill be established.
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RUST proposes that the amount of POHC (naphthalene and 1,4-dichlorobenzene) used to "spike"the feed be increased above that shown in Section 13590 of the RFP to ensure that the detectionlimits for the POCHs in the stack gas samples are adequate to demonstrate the required DRE.POHCs will be spiked into the waste-feed stream in sealed containers. A specified number ofsealed POHC-containing containers will be dropped into the kiln feed belt and fed to the kiln.
The trial burn is designed to demonstrate operating conditions for the kiln, SCC, and APC. Bothcombustion chamber exit temperatures will be maintained at the lowest levels desired for normaloperation, while the combustion gas flow rates will be maintained at the highest level desired.This will result in demonstration of POHC DRE under the "worst-case" operating conditions ofminimum combustion temperature and maximum combustion gas velocity (minimum gasresidence time).
The trial burn is also designed to demonstrate that the level of/3-naphthylamine in the incineratedash will be destroyed to levels below 55 ppb and establish acceptable levels of volatiles and semi-volatiles that can remain in the ash. The TBP includes provisions to measure jS-Naphthylamine,volatiles and semi-volatiles concentrations in the incinerator ash to establish this ash treatmentcriteria, based on an on-site disposal requirement for j8-Naphthylamine of 55 ppb or below.
Trial Burn ReportRUST will prepare a Trial Bum Report that will document the test procedures and results. Thisreport is to incorporate process data obtained during the trial burn, analytical and quality controldata generated for the trial burn samples. It will also include a section that will discuss how thetest meets the permit confirmation objectives, based upon die system performance asdemonstrated during the trial burn. The Trial Burn Report is to be prepared in accordance withthe guidelines presented in the USEPA Handbook, "Guidance on Setting Permit Conditions andReporting Trial Burn Reports," EPA/625/6-89/019, January, 1989.
An example format for the Trial Burn Report is given in Table 2.2-3 and will generally followthe recommendations for reporting given in "Guidance on Setting Permit Conditions andReporting Trial Burn Results."
Quality Assurance/Quality Control (QA/QC) ApproachIn general, RUST will follow recommendations in the USEPA handbook on "QualityAssurance/Quality Control Procedures for Hazardous Waste Incineration." However, someminor modifications to the recommendations hi the USEPA QA/QC handbook, which will resultin cost savings to USACE and/or improved data quality to meet USACE's objectives, are beingconsidered. These modifications will be delineated in the Trial Burn Plan. RUST believes thesechanges will not have an impact on the overall quality of the trial burn results, and is preparedto justify these recommendations to the regulatory agencies.
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Table 2.2-3*PROPOSED REPORT FORMAT WITH APPENDICES
Executive Summary
1.0 Introduction
2.0 Summary of Results
3.0 Incinerator Description and Operating Data3.1 Incinerator description3.2 Operating data
4.0 Test Results4.1 Soil feed characteristics4.2 Method 5 test data and paniculate emissions4.3 DREforPOHCs4.4 HC1/C12 emissions4.5 Metals emissions4.6 PCDD/PCDF emissions4.7 Semi-volatile PIC emissions4.8 Scrubber effluent analysis4.9 Continuous emission monitoring data
5.0 Quality Assurance Audit Report
6.0 Demonstration of Permit Compliance
Volume 2 - Appendices
Part A Appendix A - Description of sampling and analysis proceduresAppendix B - List of samples collectedAppendix C - Field sample data and sample traceability
Part B Appendix D - Process and waste feed rate dataAppendix E - Modified Method 5 calculationsAppendix F - Galbraith Laboratory resultsAppendix G - Semi-volatile analysis resultsAppendix H - Metals and analysis resultsAppendix I - Continuous emission monitor data
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3.0 MOBILIZATION PLAN
RUST has prepared a comprehensive mobilization plan for the Drake site remediation. This planwill begin following completion of the surveying of the excavation limits. Components of thisplan follow.
Site PreparationThe following sections highlight work that is required prior to full-scale operations.
EarthworkClearing and grubbing of the site shall begin after the excavation area has been surveyed. Thisactivity will extend to the boundaries determined by the survey. Clearing of the site will consistof felling, trimming, and cutting into sections all standing trees. These trees, along with brushand debris, will be removed and transported to the feed stockpile area. Following the start of fullincinerator operations, the material stockpiled will be processed through a chipper, thenincinerated.
Debris RemovalDuring the clearing and grubbing activities, RUST expects to encounter demolition debris andrubble. The rubble will be moved to the incineration area. The noncombustible rubble will bedecontaminated by steam and pressure washing, then used as backfill or, if directed by theContracting Officer, transported off site for disposal. .Concrete slabs and foundations from thebuildings will be broken, decontaminated, crushed, and used as backfill material. RUST willremove the railroad spur located across the south portion of the site. The steel tracks will bedecontaminated and removed from the site as scrap metal. The ties will be chipped and stockpiledwith the chips from clearing and grubbing, then incinerated.
Contaminated Soils RemovalExcavation of the incinerator area shall begin prior to any other intrusive work. The footprintof the facility will be cleared and grubbed, and sheet piling will be installed around the perimeterprior to excavation. The excavated material will be loaded and taken to the contaminated stockpilearea. This stockpile material will be covered and incinerated during the course of remedialactivities. Structural backfill will be used for the entire incinerator area. This backfall will beimported from an off-site location.
Wastewater ManagementRUST will develop an erosion control plan detailing the measures necessary to control soilerosion, dust, and fugitive emissions during construction, and after remediation activities arecompleted.
Prior to beginning remediation work in the exclusion zone, RUST will install stormwater soilerosion control measures, The following methods will be used to control soil erosion andsediment during remediation activities:
° Construction of temporary diversion berms and swales.0 Installation of temporary sediment control including silt fences and straw bales, and0 Maintenance of the erosion control system by removing sediments and making necessary
repairs.
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Support ZoneRUST will construct a Support Zone to facilitate controlled access to the exclusion zone by on-site personnel. The Support Zone will consist of the following components:
° Personnel parkingo Administrative and support trailers° Equipment loading/unloading area° Controlled access to Exclusion Zone0 Laboratory0 Personnel decontamination facilities
The Support Zone will be constructed prior to commencement of any site remediation activities.Contaminated soils will be removed and placed in the contaminated stockpile area. The groundsurface will be restored with uncontaminated materials. A stable subgrade will be constructed ofan eight-inch compacted layer of crushed stone over a geotextile.
Security FenceRUST will provide a security fence to limit site access to controlled locations. Portions of theDrake site not now fully enclosed by fencing will receive new fencing, or the existing fence willbe repaired or realigned. The fence will be extended to include the Gorham Property, forinstance. Gates will be installed between the Support Zone and the Exclusion Zone. Gates willbe provided at the entrance to the site from Myrtle Street.
Utility UtilizationRUST's mobilization plan for the Drake site will include all steps necessary to utilize theavailable utility services: water supply, electrical power, telephone service, and sanitaryfacilities. The plan will cover the site mobilization period as well as TDF operations. RUST willalso manage the closure phase, during which all temporary utility tie-ins will be restored to theiroriginal state.
RUST will carry out the utility utilization program in conformance with Technical SpecificationsSection 01590, Facilities and Utilities; and Section 02680, Gas Supply.
RUST has already contacted the representatives of the utilities listed hi the request for proposal(RFP) and obtained the information needed to establish electrical power, telephone, and waterconnections. This information will be shown on the submittal drawings required for approvalprior to moving on the site.
Utility services activities at the Drake site will consist of the two basic categories: (1) thoseutilities related to past, present, or future services other than site remediation; and (2) thosetemporary utilities required specifically for site remediation. Each item in these two categorieswill be handled in accordance with the drawings and specifications included in the RFP.
Site-Specific UtilitiesDisposition of these utilities will be in one of three following categories:
0 Abandon/Remove/Secure: - Storm drain (24 inches) - Gas line (3 inches)o Protect/Clean/Leave: - Storm sewer
Pressure wastewater line° Relocate/Improve/Leave: - 18- to 24-inch sanitary sewer
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12-inch water lineFire line and hydrantPP&L power line
RUST will coordinate and execute a contract with Pennsylvania Power and Light (PP&L) torelocate the existing power line on the north end of site to a location north of Myrtle Street.
An 18-inch terra cotta sewer line and a 12-inch water pipeline are currently present and orientedin a north-south direction through the site. RUST will relocate these utilities within the site, asshown on Drawing CER69-400E C-8 and C-9, during the remediation activities. Before utilityplacement, RUST will install a sheetpile retaining wall to maintain trench wall stability, minimizeexcavations during the installation, and segregate clean backfill from contaminated material.Water services interruption will be kept to a minimum during the relocation. The sewer line willbe relocated without service interruption.
All pipes to be left in place shall be protected and supported during excavation. Contaminatedsoil will be removed from around pipes. Pipes will be brushed clean to expose pipe material.
RUST will remove a three-inch gas line within the Drake site and cap the remaining line at theexcavation boundary. RUST will relocate existing water hydrants and water valves outside theexcavation limit. The 24-inch storm drain and inlet will be removed.
Temporary Facility UtilitiesUtilities for TDF and support facilities operation include electricity, natural gas, water, sanitarysewerage, and telephone. Storage units for compressed air and oxygen will be installed on-site.
RUST will coordinate and install sewer and water lines as required during the construction phase.RUST will secure required permits from the city of Lock Haven. RUST will coordinate withlocal utility companies for gas, electricity, and telephone lines, and will establish connectionpoints outside site limits. RUST will provide connections between these points and site equipmentor facilities. Excavation of utility trenches will be performed hi accordance with OSHA Standard29 CFR 1926 Subpart P. Utilities will be bedded and backfilled in accordance with local buildingcodes, using clean material from an off-site location.
At site closing, all temporary utilities will be removed in an approved manner.
Hot Zone Identification, Isolation, and ControlRUST will establish a program to identify, isolate, and control contaminated areas of the Drakesite. The objective of this program will be to minimize potential contamination of workers,protect the public from the site hazards, and prevent vandalism.
Work zones shall be established based on work to be performed and the anticipated contaminationlevel. Actual zone boundaries shall be marked using barrier tapes or other suitable methods.Within these zones, prescribed operations shall occur using personal protective equipment (PPE)appropriate to the task and work area. Movement between areas shall be controlled at accesspoints using well-delineated corridors. The planned zones typically include the following:
0 Exclusion Zone (contaminated)0 Contamination Reduction Zone (CRZ) with a clean break station
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0 Equipment Decontamination Zoneo Support Zone (noncontaminated)
Exclusion Zone Isolation and ControlThe number of personnel and equipment allowed in the Exclusion Zone will be kept to aminimum, consistent with effective operations.
Access to the Exclusion Zone will be restricted to personnel who are wearing the proper PPE,have received the required medical surveillance, and have undergone the health and safetytraining required for the Drake site. Eating, drinking, and smoking will be prohibited in this area.The Exclusion Zone will be expanded by the HSS if site conditions so warrant.
An entry checkpoint or portal shall be established at the periphery of the Exclusion Zone tocontrol the flow of personnel and equipment between contiguous zones and to make certain thatthe procedures established to enter and exit the zones are followed. A personnel tracking systemsuch as a logbook or in/out pegboard will be used to monitor workers in the Exclusion Zone.
The buddy system will be adhered to for work in the Exclusion Zone. Workers in high-hazardareas, including excavation and contaminated soil and debris-handling, will be within the line ofsight of at least one other person at all times. Operators of the incinerator will maintain with theirsupervisors at least periodic radio and/or visual contact.
Site Security PlanSuccessful control of the Exclusion Zone is also dependent upon effective implementation of thesite security plan.
Personnel TrainingRUST will provide general and specialized training for all company and subcontractor personnelworking at the Drake site. Depending on the individual's assignments, he or she will receive mostor all of the following types of training:
° Initial 40-hour OSHA hazardous waste site training° On-the-job training° Site-specific training0 Daily safety meetings° Hazard communication training0 Emergency response training0 Annual 8-hour update (OSHA hazardous waste site training)0 Supervisory training° First aid and CPR° Fire extinguisher training° Fork-lift operation0 Defensive driving training
Three of the types of training—health and safety, job, and site-specific—are briefly describedbelow.
Health and Safety TrainingHealth and safety training, including initial 40-hour, annual updates, and site-specific training arepreviously described.
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Job TrainingRUST intends to use a core of experienced people in the various task types who are experiencedin the task and in hazardous waste operations. This core of people will assist the managers intraining local hires in performance of the various tasks.
Additional training will be required for positions in quality assurance/quality control andlaboratory operations. This training will be provided by the quality assurance/quality control andlaboratory managers. The training will emphasize the chemical data quality management,contractor quality control, and sampling plans. This will ensure that all quality control work isperformed in accordance with the approved work plans.
Site-specific TrainingIn addition to the site-specific health and safety training, employees will be trained in therequirements of the approved work plans for the Drake Chemical project. Emphasis will beplaced on the work plan requirements for the specific task each employee is expected to perform.This training will ensure that all work is performed in accordance with the specifications andwork plans.
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4.0 DEMOBILIZATION PLAN
The RUST demobilization plan for the Drake Chemical project will comply with all requirementsof the contract, and will proceed to project and closeout in an orderly fashion.
Project Closeout PlanRUST will submit to the Contracting Officer (CO) for approval a Project Closeout Plan. As thework progresses, RUST will provide any necessary waste manifests and decontaminationcertificates. The Project Closeout Plan will include details and schedules for cleanup of thespecific areas of the Drake Chemical site, with proposed sequences for removing soil orsediment, backfilling, grading, topsoiling, seeding, and restoring each area of the entire site.
Backfill of Previously Contaminated SitePrior to backfilling, RUST will submit to the CO for approval a Removal Completion Survey.The surveys and actual work will meet or exceed the requirements of Sections 02205 and 02210.
Backfill will be maintained to a clearance of 20 ft. between the backfill line and any area not yethaving an approved Removal Completion Survey, unless an alternate separation technique isapproved by the CO.
Fill Layer 1Imported fill to a height of 2 ft. above the approved removal completion survey will be placedand compacted in 8-12 in. loose lifts. This material will be compacted by a vibratory compactorto 95 percent of maximum dry intensity. To confirm compaction, every 3,000 yd2 for each liftwill be tested according to ASTM D2922. To verify compaction, testing will be performedaccording to ASTM D1556 at the rate of at least one test per 10 tests by nuclear density.
Fill Layer 2Approved incinerator ash containing less than the Drinking Water Standard (DWS) metals contentwill be backfilled up to MSL 553 over the tested and approved imported fill layer. The approvedash material will be placed in 8-12 in. lifts and compacted by a vibratory compactor to 90 percentof maximum dry intensity. To confirm compaction, every 3,000 yd2 for each lift will be testedfollowing ASTM D2922. To verify compaction, testing will be performed according to ASTMD1556 at the rate of at least one test per 10 test by nuclear density.
Fill Layer 3Approved incinerator ash containing less than 25 times the DWS metals content will bebackfilled above MSL 553. Compaction and testing procedures will be the same as those for ashbelow MSL 553.
Fill Layer 4Imported fill cover of 18 in. will then be installed over the entire excavation area. Compactionand testing procedures will be the same as those for the ash.
GradingFollowing installation of the 18-in. imported fill cover, the site will be graded to conform to thefinal slopes and contours set forth in the Drawings, and in accordance with Sections 02210 and02480 of the RFP.
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Topsoil and SeedingThe existing subgrade will be loosened or scarified to a minimum depth of 3 in. prior tospreading topsoil.. The subgrade will be free of large stones debris, and other extraneousmaterial. Topsoil will not be placed when the subgrade or topsoil materials contain excessivemoisture or frost. Upon completion of placement of the 18-inch cover over the incineratedmaterial, topsoil shall placed and spread to a finished thickness of 6 inches. To bring the site tothe final grades, the topsoil will be spread in the areas as directed by the project drawings. Thetopsoil will be compacted using a light landscaping roller to avoid excessive compaction.
Following the placement of the limestone, fertilizer shall be applied at the rate of 13 Ibs. per1,000 ft2 unless recommended differently by the seed supplier. The fertilizer shall have acommercial designation of 10-20-10, and will contain a minimum of 5 percent nitrogen, 10percent available phosphoric acid, and 5 percent soluble potash.
The seed used on-site shall conform to the Type-B grass seed mixture outlined in thespecifications. The seed will be applied at the rate of 3 Ibs. per 1,000 ft2. RUST will schedulework so seeding can take place between February 15 to May 1, or August 15 to October 15.
Off-Site Disposal of Contaminated WasteThis section discusses the procedure that RUST will follow for the off-site disposal of eitherRCRA-non-hazardous or hazardous wastes as determined by 40CFR Part 261, Identification and'Listing of Hazardous Waste. All waste streams, as identified on the process flow diagram, thatare treated and disposed of on-site in accordance with the remediation work plan are managedas CERCLA wastes and, as such, are not subject to certain regulations, such as RCRA LandDisposal restrictions. Conversely, there are certain waste streams, as identified in the projectspecifications or as determined during remedial action, that cannot be left on-site and therefore,must be managed for off-site treatment and/or disposal. Those waste streams managed outsideof the CERCLA-operable units will be subject, as applicable, to regulation under RCRA orCWA.
Waste Stream IdentificationAll facilities used for off-site disposal will be in compliance with the USEPA Off-site Policy,which is explained in the agency's memorandum, Revised Procedures for Planning andSupplementing Off-Site Response Actions, November 13, 1987. In essence, each facility thatreceives waste generated from a CERCLA remedial action site must be a RCRA-permitted facilityand must not have any outstanding agency notices of violation issues. The list of off-site facilitiesapproved for CERCLA wastes is managed by the respective USEPA Region.
Disposal ProceduresEach RCRA-hazardous waste stream will be tested for full RCRA characterization. The applicablewaste code will be assigned depending on the analytical results, such as those from performinga toxic characteristic leaching procedure (TCLP). The analytical results will be used to establisha waste profile at the designated TSDF. Following facility approval of the waste stream, it willbe prepared for off-site transportation, and will meet EPA requirements. Hazardous Wastedestined for off-site disposal will be properly manifested using the consignment state's manifestform, and the licensed, hazardous waste transporter will conduct operations in compliance withthe RCRA transportation requirements for hazardous waste (40 CFR Part 263).
Procedures for Equipment Disassembly, Decontamination and Site Closure
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After all soil and materials incineration, the PY*ROX™ 8212 unit will be shut down for completedecontamination and disassembly and removal from the Drake site.
Except for services and power to perform the necessary decontamination, all utilities to equipmentwill be turned off and secured for safety. Disassembly and removal will take place in five majorphases:
1. Major buildings and structures within the Exclusion Zone.2. PY*ROXm 8212 equipment.3. Utilities and utility support equipment.4. Trailers and support structures within the Exclusion Zone.5. Trailers and support structures outside the Exclusion Zone.
Major Buildings and Structures within the Exclusion ZoneFollowing complete decontamination, all electrical water, gas, air, and other utility services willbe turned off, secured, and removed from the buildings. All air systems, ventilation equipment,ducts, and building appurtenances will be removed. Filters from the air systems will be removedand will be properly disposed of. All equipment with salvage value will be tagged withdisposition clearly marked. Other equipment and material will be taken to approved disposalareas.
Metal structure buildings will have all sheet metal removed for reuse. The framework will bedismantled and removed from the site for reuse.
PY*ROX" 8212 EquipmentAfter complete decontamination, all utilities to the PY*ROX™ equipment will be turned off andsecured. The refractory will have to be removed from the rotary kiln due to weight limitationsfor transporting the largest unit assembly. The refractory >vill then be properly disposed of off-site. Other units will be mechanically disassembled into the largest possible transportable units.
Utilities and Utility Support EquipmentAll above and below ground water, air, natural gas, and oxygen pipe lines that serve the siteoperation will be isolated, secured, and purged as required. Units needing decontaminated willbe broken into sections and taken to the equipment decontamination station before removal fromthe Drake site. All above and below ground electrical cables and wires will be properly isolatedand secured for safety before disconnection and removal. Cable trays, cable tray supports (somealso serve as pipe supports), conduit, raceways, poles, and other related equipment will beremoved. If required, sections will be decontaminated before removal from the site.
Exclusion Zone Trailers and Support EquipmentThe electrical, instrument, and control trailers will be removed after all utilities have beendisconnected. The emergency generator will also be removed. This equipment will have beeninstalled in a clean fill area; however, each will be thoroughly inspected and any requireddecontamination will be done. Equipment removal from the Exclusion Zone will be completedto the extent needed to allow site restoration, including drainage relocation. After Myrtle Streetrepair and all other site activities have been completed, the Support Zone will be cleaned, graded,topsoiled, and seeded.
Concrete DecontaminationThe exposed surfaces of the concrete for the incinerator pad and ash structure areas will be
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decontaminated using a high-pressure hot water wash. A grab sample from this wash will be usedto confirm decontamination effectiveness. After decontamination and inspection and approval bythe CO and HSS, the concrete'will be broken with a hydraulic ram on a trackhoe and removedto a local sanitary landfill.
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5.0 PROJECT MANAGEMENT
Project management is one of the most critical aspects of the Drake Chemical project.RUST will provide to USAGE effective project management for the Drake Chemicalproject through:
0 Project planning that includes:Establishment of the best organizational structure,Filling positions with competent, experienced personnel,Definition of work requirements, andDefinition of required material, equipment and subcontract resources.
0 Project monitoring to sustain the highest possible quality and production standardsfrom planning through closure:
Tracking progress,Comparing actual to projected,Analyzing impacts, andMaking adjustments to correct variance in a timely fashion.
0 Providing professional, energic leadership for the successfull execution of thecontract.
To RUST, successful project management means completing a project on time, withinbudget, at the desired level of quality, and using all project resources effectively and.efficiently. RUST will accomplish these tasks for the Drake Chemical project and, at thesame time, provide USAGE with the following benefits:
0 Identification of and accounting for all key responsibilities to assure everyone isconsistently on track to successful project completion.
0 Identification of potential problems so immediate preventive actions can be taken.0 Determination of critical path activities, schedule durations, and milestones.0 Measurement of planned versus actual progress.0 Development of simplified, but highly efficient, Drake site-specific documentation
procedures.
Taking all under consideration, the RUST project management team will provide USACEwith substantial value at low risk for the Drake Chemical project.
ORGANIZATION PLAN
RUST will provide a site management team dedicated to safe, timely, and cost-effectivecompletion of the Drake Chemical Superfund project. This site management team isexperienced in performing on-site hazardous waste thermal treatment, civil construction,and hazardous waste operations. The team will be supported by an Executive Sponsorwho will insure that sufficient company resources are available to the team whenever
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needed.
The key positions and responsibilities are described below.
Project Manager (PM)The Project Manager (PM) will be responsible for execution of all aspects of the DrakeChemical project. This individual will be the primary contact point between USAGE andRUST, and will have full authority to act on behalf of RUST with regard to makingfinancial and schedule commitments to USAGE.
The PM will have the authority and responsibility for managing all activities andpersonnel at the Drake Chemical site. This includes the authority, with USAGEconcurrence where appropriate, to appoint or change subcontractors and personnel,except the Health and Safety Officer and the Quality Control Manager, who will beappointed by the RUST Vice President of Environment, Health and Safety.
The PM will have on-site staff specializing in the various skills needed for the project.
The PM will have extensive experience in hazardous waste operations and projectmanagement. He will also assure health and safety of all on-site personnel.
Health and Safety Specialist (HSS)The Health and Safety Specialist (HSS) will be appointed by the RUST Vice Presidentof Environment, Health and Safety. The HSS will report to the Project Manager and theproject Certified Industrial Hygienist (CIH). This separate reporting relationship insuresthat the HSS maintains an independent assessment of the safety performance at the site.
The HSS will have the following responsibilities:
0 Work with the project management team to implement the SSHP;0 Manage the off-site air-monitoring program;0 Perform site inspections and report any concerns to the PM;0 Review changing regulatory requirements and develop plans for insuring
compliance with the changes;0 Perform and analyze personnel and work area monitoring, with the assistance of
the Cffl;° Modify personal protective equipment (PPE) requirements based on the results of
personnel and work area monitoring;° Conduct site-specific training for employees;0 Develop and implement daily safety briefing topics; and0 Manage the on-site Health and Safety Monitors (HSMs).
The HSS will have the authority and responsibility to stop work on an activity should hediscover conditions that present a risk to workers or the public, or that are not incompliance with regulations or the SSHP.
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Certified Industrial Hygienist (CIH)The RUST CIH is responsible for the overall development, implementation, andoversight of the PUST health and safety program and the SSHP. The project Health andSafety Specialist will report to the CIH, who will report directly to the Vice President,Environment, Health and Safety and coordinate his activities with the Project Manager.The CIH will oversee and provide appropriate health and safety guidance to all jobsiteactivities. He will have the following specific responsibilities:
° Develop the Site Safety and Health Plan (SSHP);0 Review and interpret air monitoring results;0 Perform safety audits and inspections;° Conduct employee health and safety training;° Assure OSHA compliance at jobsite; and° Prepare/approve health and safety data and reports.
Quality Control Manager (QCM)The Quality Control Manager (QCM) will be appointed by RUST Vice President ofEnvironment, Health and Safety. He will report to the Environmental Manager whoreports to the Vice President of Environment, Health and Safety. This separate reportingrelationship insures that the QCM maintains an independent assessment of theperformance at the site.
The QCM will have the following responsibilities:
° Assist in developing the Quality Assurance Project Plan (QAPP) and the site-specific Environmental Compliance Plan (ECP);
0 Work with the project team to ensure correct implementation of the QAPP, site-specific ECP, site-specific Chemical Quality Management/Sampling Plan(CQMP), and any other required laboratory plans;
° Inspect work for conformance to the contract requirements, QAPP, CQMP, andECP;
° Insure all data used in evaluating the site meet the quality assurance/qualitycontrol (QA/QC) requirements of the contract and the QAPP;
o Manage all QA/QC activities, including sampling, inspection, and reporting;° Submit results of inspections and data to USAGE; and0 Maintain the project records.
The QCM will have the authority and responsibility to stop work on an activity shouldit be discovered that the work is not being performed in accordance with the contract,ECP, CQMP, or QAQCP.
Construction ManagerThe Construction Manager will have responsibility for installation and construction bysubcontractors, and for construction by in-house forces. He will report to the ProjectManager. He will supervise the Field Engineering staff, who will monitor detailedtechnical conformance of subcontractor work. The Construction Manager will ensure
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that subcontractors provide appropriate access to their work in order that the Health andSafety Specialist and Quality Control Manager can perform required and appropriateoversight activities. The Construction Manager will also ensure that the FieldEngineering Staff assists in these oversight activities as appropriate. The ConstructionManager will manage the following major subcontracts:
° Incineration unit installation;o Water, sanitary, and gas service;0 Electrical power service, wiring, and instrumentation;0 General site work;° General building work; and0 Mechanical equipment.
The Construction Manager will manage subcontractor activities under long-establishedproject procedures of RUST. These procedures ensure that the Construction Manageraccomplishes the following functions:
° Coordinate all construction activities;0 Perform pre-construction planning and preparation;0 Schedule construction tasks and assign resources/personnel;° Mobilize construction staff and subcontractors;° Coordinate construction materials shipments with procurement staff;° Assure secure and orderly storage of construction
materials;° Inspect on-going and completed construction; and° Assuie that appropriate data is input to RUST's Management and Control System
at the appropriate time to ensure proper project control at the jobsite.
Process ManagerThe Process Manager will report to the Project Manager. His primary responsibilitiesare as listed below:
0 Coordinate process activities with the HSS and QCM to ensure that all work isperformed in accordance with the contract, regulations, and approved work plans.
0 Supervise the workforce in the processing areas to make certain that work isperformed in a manner that protects the health and safety of personnel and thenearby community.
0 Manage thermal destruction facility (TDF), ash stabilization, and wastewatertreatment operations:
Schedule work and workforce to meet the processing requirements;Supervise workforce in the processing units;Prepare operations reports for the processing units; andInsure all processing equipment: is maintained and inspected on a routinebasis.
The Process Manager will have extensive experience in the thermal treatment area.
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Engineering ManagerThe Engineering Manager will report to the PM. He will also be responsible for finaldesign of all temporary facilities and will assist the project team with developing andimplementing design changes required during construction or operations.
Operations ManagerThe Operations Manager will report to the PM. His primary responsibilities will includethe following:
0 Coordinate activities with the HSS and QCM to insure all work is performed inaccordance with the contract, regulations, and approved work plans.
0 Supervise the workforce in the nonprocessing areas to insure work is performedin a manner that protects the health and safety of personnel and the nearbycommunity.
° Manage excavation, backfilling, decontamination, equipment maintenance,transportation, disposal, security, and support activities. These administrativeduties will include:
Schedule work and workforce to meet the project requirements;Supervise workforce outside of the processing units;Prepare project progress reports; andInsure equipment is maintained and inspected on a routine basis.
During the remediation phase, this individual may perform the duties of the DeputyProject Manager.
The Operations Manager will have extensive experience in the construction andhazardous waste remediation areas. .
Project Controls ManagerThe Project Controls Manager reports to the PM and will be responsible for thefollowing:
° Developing a detailed critical path method (CPM) schedule for submittal toUSAGE;
° Tracking progress against the CPM schedule and reporting any variances to thePM;
° Assisting the Operations and Process Managers with planning activities to ensurethe project schedule is maintained;
° Tracking cost using the RUST's Management and Control System (RMACS);° Managing the support staff; ando Field purchasing.
The Project Controls Manager will have extensive experience in scheduling, executionplanning, and cost control.
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Laboratory Manager (LM)The RUST Laboratory Manager (LM) will have responsibility for laboratory resourcesand activities, and the successful processing and analysis of laboratory samples. He willreport to the PM. The LM will perform the following functions:
0 Coordinate laboratory activities;0 Coordinate activities of on-site and subcontractor labs;0 Assure efficient sample handling and transport;0 Prioritize-schedule sample analysis;0 Assure laboratory compliance with the CQMP;0 Supervise laboratory data entry;0 Prepare/approve laboratory reports and documentation;0 Maintain adequate supplies for lab analysis; and0 Enforce laboratory-specific Health and Safety rules.
Environmental ManagerThe Environmental Manager (EM) reports to the Vice President of Environment, Healthand Safety. He provides an independent reporting relationship for the QCM andLaboratory Manager. The EM will assist the PM in insuring that all work plans are hiaccordance with the contract, approved work plans, and applicable regulations. He willprovide technical guidance to the PM, QA/QC and Laboratory departments on regulatoryissues.
The EM will conduct periodic audits of the QA/QC and Laboratory departments toindependently review their adherence to the Contract, including the QA/QC andChemical Quality Management/Sampling plans. This independent review will be usedto assist the PM in insuring compliance with all applicable requirements. The EM willalso inspect the facility and records for compliance with all applicable regulations.Although the EM will not be located at the site, he will be available any tune the PM,LM, or QCM needs assistance.
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6.0 PROJECT EXECUTION APPROACH
The Drake Chemical project can be separated into four phases:
° Design and submittals;0 Mobilization and construction;0 Remediation operations; and0 Demobilization and closure.
RUST proposes to vary the project support staff during these various phases to insurepeople with the needed expertise are on site during the various phases.
Design and Submittals PhaseThe design and submittals phase is expected to last four months while the followingprimary tasks are being completed:
° Develop and obtain approval for the work plan submittals.0 Finalize die project CPM schedule.° Finalize contracts with subcontractors for work that occurs during mobilization.° Finalize detailed design; procure and arrange for delivery of the wastewater
treatment system, off-site air monitoring system, utilities distribution systems, andfeed and ash-handling facilities.
0 Hire local labor required for the mobilization phase of the project.° Establish an office in Lock Haven.
Mobilization & Construction PhaseThe mobilization and construction phase is expected to last 10 months while thefollowing primary tasks are being completed:
° Preparing the site, including upgrading off-site roads, excavating process facilityareas, setting up on-site offices, and installing utility supply systems.
° Sheetpiling the site.° Erecting and installing the processing facilities.0 Hiring local labor required for the remediation phase.o Finalizing contracts with subcontractors for work and materials needed during the
remediation phase.0 Establishing the site security system.
Remediation Operations PhaseThe remediation operations phase is expected to last 18 months. The following primarytasks will be completed during this pnase:
0 Excavating contaminated soils;0 Thermally treating contaminated soils;
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° Stabilizing soil when required;° Confirming that backfill material meets the treatment standards;° Backfilling treated material at the site; and° Treating groundwater and storm water prior to discharge.
Dismantling and ClosureThe dismantling and closure phase is expected to last five months, with the followingprimary tasks being completed during this phase:
0 Dismantle the incinerator, wastewater treatment plant, air monitoring systems,and other temporary systems installed at the Drake Chemical site;
0 Remove the on-site TDF;0 Backfill previously contaminated site;0 Dispose of residual contaminated materials and close staging areas;0 Decontaminate equipment and materials; and° Restore the site, via:
Site grading,Top soiling,Seeding
Schedule
Figure 6.0 provides the phase schedule which RUST will follow during performance ofthe Drake Chemical Superfund Project.
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7.0 SUBCONTRACTOR MANAGEMENT
To maximize effectiveness at the Drake Chemical site, RUST has selected severalqualified subcontractors to implement specific elements of the contract. As primecontractor to the U.S. Army Corps of Engineers (USAGE), RUST will be responsiblefor the management of all work under the contract.
RUST's subcontractor management plan incorporates the policies and procedures outlinedin FAR Parts 44 and 52.244-5, and is based on RUST's corporate commitment toprovide clients with the most competitive proposals in the industry, as measured bytechnical merit, environmental compliance, and cost. RUST will maintain effectivecontrol of all subcontracted activities through unifying project schedules, preparing scopeof work (SOW) statements for each subcontractor, and using proven construction contractadministration and management procedures.
RUST understands that a key concern in the development of the subcontracting plan isthe implementation of an effective Small Business (SB)/Small Disadvantaged Business(SDB) Plan. RUST has evaluated many potentials for using SBs and SDBs. RUSTproposes to use SBs and SDBs in many facets of the project, ranging from the highlytechnical area of laboratory analysis to incinerator erection to general supplies. RUSTis committed to meeting and exceeding the SB/SDB participation goals of the DrakeChemical Superfund project.
SubcontractsRUST intends to use numerous subcontractors for various types of services. Section 2.5.of this volume outlines services that will be awarded to small and small disadvantagedbusinesses. The major work items and contractors who will perform them are listedbelow:
Work Item Proposed ContractorOverall contract management RUSTSampling RUSTLaboratory SubcontractorTDF manufacturer RUSTTDF installation SubcontractorTrial burn/ Subcontractor
perimeter air monitoringTDF operations RUSTOn-site quality assurance (QA) RUST
and health and safety
Work Item Proposed ContractorNatural gas supply SubcontractorOxygen supply SubcontractorSheetpile material supply Subcontractor
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Subcontractor ManagementRUST will determine the most productive method of construction. This method will inturn determine the actual number and size of subcontracts.
During remediation activities, RUST will coordinate subcontractors' daily work andmonitor their safety, quality, schedule, and costs.
SafetyRUST will require all personnel to attend a safety indoctrination, and will monitorsubcontractors to ensure compliance under local and OSHA regulations. RUST willformalize a follow-up system to ensure that audit and incident investigationrecommendations are implemented. RUST will provide a drug-testing and substance-abuse program.
QualitySubcontractors will be required to develop and implement a Drake Chemical site-specificquality control (QC) program.
RUST will audit all QA activities with its QA/QC staff witnessing portions of work ofeach subcontractor at the beginning of each feature of work. RUST will verifycompletion of all work inspections and tests and will assemble test and inspection reports.
SchedulingRUST will identify construction milestones in the project schedule and convey them tosubcontractors' schedules. Subcontractors will be required tc provide weekly updates tothe schedule and projected completion dates. RUST will audit these schedules to ensurethat subcontractors are in compliance with project goals.
Administration of Service SubcontractsThe RUST team will implement construction contract administration procedures that willprovide the project's management personnel with a framework hi which they caneffectively manage the various subcontracted tasks. These procedures will channel the.work flow and alert project management personnel to issues that could affect the scopeof work, schedule, and cost of the project. Additionally, materials and equipmentprocured at the site will be done on a competitive basis.
The administration of subcontracts will be initiated during the mobilization phase of theproject. Following a notice to proceed, defined SOWs will be written for eachsubcontractor by the PCM and the PM. These will be incorporated into the standardcontractual agreement.
Adherence to the original SOW will be strictly enforced. However, to provide RUSTwith a mechanism to make changes or add to the SOW due to changes in the field, RUSThas established procedures for affecting orderly changes in the contract scope.Authorized changes hi the scope of work will be handled under change orders.
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By definition, a change order constitutes a substitution, addition, or deletion within thefunctional scope of the contract. An extra work order means work outside the originalcontract. Both result in revisions to the contract between RUST and the subcontractor.The contract dollar amount and/or schedule may be affected. To control the applicationand use of change orders and extra work orders, both will be scrutinized through thefollowing three-step procedure:
1. A request for change or extra work can be initiated by USAGE, RUST, or asubcontractor. Following internal approval by the PM, the subcontractor will berequested to provide a proposal or quote for a modification to the work.
2. The subcontractor will submit a proposal or quote response to RUST inpreviously agreed-upon timeframe.
3. After review of the submittal, the PM can authorize work to be done, can rescindthe order, or can request modification to the proposal.
To document the changes in the scope of work or extra work and to assure that upperlevel management has reviewed the changes, a system of forms is used to channel thework flow.
° All change orders or extra work order requests should be presented to the PCMusing a change order/extra work order request for proposal, in addition to anysupporting documentation. The PCM will review the request, resolve anyprocedural problems, and log the request. Copies of the requests are sent to thesubcontractors after the job site files have been properly documented.
0 The subcontractor will then prepare an appropriate proposal and submit it toRUST.
0 All submitted or revised proposals for change orders or extra work orders willbe reviewed by the PM. After reviewing and logging the proposal, a changeorder/extra work order will be distributed for review, with an approval formattached. Each person reviewing the order should, if acceptable, sign theapproval form, include any comments, and route the complete document packagefor further review. The review panel will include the PCM and thecorresponding manager to that area of work. For example, the site Health andSafety Specialist responsible for perimeter air monitoring would approve anychange orders or extra work orders for that area of work.
° When the process is complete, the PCM will update the log and return anyunapproved orders to the initiator for resolution of any problems. Uponresolution, the approval process should begin again. Approved orders will benumbered and delivered to the subcontractor. A copy of the approved order willbe filed in the on-site general files and the RUST regional office.
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Procurement of SubcontractorsEqually important in controlling costs and managing subcontractors is the procurementof equipment, materials, and services. This is accomplished through obtainingcompetitive bids from subcontractors whenever feasible, issuing detailed instructions tothe subcontractor or vendor in the form of a purchase order, and properly processing thevendor's invoices.
When the need arises for the procurement of materials and equipment, a purchaserequisition must be initiated. The initiator must indicate all relevant instructions andspecifications. After the purchase requisition has been approved by die appropriateauthorized personnel, the initiator will forward the requisition to the PCM. The PCMwill enter the purchase into a requisition log, which will track the purchase fromrequisition date to the date of purchase-order confirmation.
When materials and equipment are estimated to cost in excess of the guidelinesestablished by FAR Part 44, the PCM will obtain at least two estimates. The initiatorwill then suggest vendors. In addition, the initiator will be encouraged to solicit bids andsubmit them with the purchase requisition.
Final review of the bids will be completed by the PCM, the PM, and the initiator of theprocurement. Upon selection of a vendor, the PCM will issue a purchase order. A copywill be sent to the PM, who will maintain an open order file until receipt of the vendor'sinvoice. The PCM will be responsible for maintaining a purchase-order log that trackspurchases from die order date to the date goods are received and vendors paid.
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