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SUPERFUND RECORDS CTR Site: O I Break: (o .b.lfl Q Other: GEI Consultants, Inc. 567852 SDMS DocID SOURCE CONTROL PILOT-SCALE TREATABILITY STUDY PRE-DESIGN WORK PLAN ) O'Connor Site Augusta, Maine Submitted by GEI Consultants, Inc. 0 /^\ !'J~TAr-~o Joanne O. Morin Project Manager 53 Regional Drive ' Revision 1 Concord, New Hampshire June 19, 1992 (603) 224-7979

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Page 1: Break: (o .b.lfl Q GEI Consultants, Inc. · GEI Consultants, Inc. SDMSDocID . 567852. SOURCE CONTROL . PILOT-SCALE TREATABILITY STUDY PRE-DESIGN WORK PLAN ) ... 7.5 Waste Generation

SUPERFUND RECORDS CTR

Site: OI

Break: (o .b.lfl

Q Other:

G E I C o n s u l t a n t s , I n c . 567852SDMS DocID

SOURCE CONTROL

PILOT-SCALE TREATABILITY STUDY PRE-DESIGN WORK PLAN

)

O'Connor Site Augusta, Maine

Submitted by GEI Consultants, Inc.

0/̂ \!'J~TAr-~o Joanne O. Morin Project Manager

53 Regional Drive ' Revision 1 Concord, New Hampshire June 19, 1992 (603) 224-7979

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Document SC Pilot-Scale Work Plan Revision 1

Date June 19, 1992

TABLE OF CONTENTS

TABLE OF CONTENTS LIST OF TABLES LIST OF FIGURES LIST OF APPENDICES

Page No.

1. INTRODUCTION 1

2. SITE BACKGROUND 2 2.1 Overview of EPA Remedy for Contaminated Soil and Sediment 2 2.2 Previous Treatability Testing 2 2.3 Proposed Soil Handling During SC Remediation 3

3. PURPOSE AND OBJECTIVES 5

4. HEALTH AND SAFETY 7

5. PILOT TEST SAMPLE SELECTION AND RATIONALE 8

6. COLLECTION AND PREPARATION OF MATERIALS FOR TREATABILITY TESTING 10

6.1 Excavation of Soil 10 6.2 Collection of Sediment 11 6.3 Preparation of Soil and Sediment for Treatability Testing 12

7. SOLVENT EXTRACTION PILOT-SCALE TESTING 15 7.1 Testing Program 15 7.2 Solvent Extraction Treatment Batch Preparation 15 7.3 Pilot-Scale Treatment Process Description 16 7.4 Operation 17

7.4.1 Site Preparation and Start-up 17 7.4.2 Process Control 18 7.4.3 Decontamination 19 7.4.4 Closure 20

7.5 Waste Generation 21 7.6 Quality Control and Quality Assurance 21

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Document SC Pilot-Scale Work Plan Revision 1

Date June 19, 1992

8. STABILIZATION/SOLIDIFICATION PILOT-SCALE TESTING 25

9. DEBRIS WASHING 26

10. REPORTING 28

11. SCHEDULE 29

TABLES FIGURES APPENDICES

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Document SC Pilot-Scale Work Plan Revision 1

Date June 19, 1992

LIST OF TABLES

Table1- Equipment nod Logisticslot Solvent Extraction Table 2 - Solvent Extraction Process Control Measurements Table5- Waste Generation

LIST OF FIGURES

Figure 1 - Site Location Map Figure 2 - Site Plan and Sampling Locations Figure 3 - Debris Areas and Contaminated Soil and Sediment Figure 4 - CF Systems Mobile Demonstration Treatment Unit Figure 5 - Schedule Requirements

LIST OF APPENDICES

Appendix A- Test Pit Logs

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Document SC Pilot-Scale Work Plan Revision 1

Date June 19, 1992 Page 1

1. INTRODUCTION

This document contains the Source Control (SC) Pre-Design Work Plan for Pilot-Scale Treatability Testing for the O'Connor Superfund Site in Augusta, Maine (Figure 1). lf§^' document was prepared by OB!Consultants, Inc. (Gil)of Concord, NewHampsbire foE Central Maine Power Company (CMP) of Augusta, Maine. Pilot-scale treatment of soil and sediments contaminated with polychlorinated biphenyls (PCBs) and carcinogenic polynuClear aromatic hydrocarbons (cPAHs) will be conducted by CF Systems Corporation (CF Systems) of Woburn, Massachusetts. The effectiveness of CF Systems solvent extraction technology to treat soil and sediment, and achieve cleanup standards, will be tested at pilot-scale using its mobile demonstration unit. Solidification/ stabilization testing of lead-contaminated soil will also be performed.

Prior to solvent extraction treatment, excavated soil will be dried and sieved to simulate full-scale soil handling techniques. Debris and stones will be separated from soil and sediment to meet the maximum particle size requirement for solvent extraction treatment. The effectiveness of steam-cleaning to remove contamination residuals from oversize

debris will also be examined.

This SC Pre-Design Work Plan provides a description of all field activities to be performed during the pilot-scale test program. The scope of the testing program has been developed from the results of Pre-Design and Feasibility Study bench-scale treatability testing. The results of bench-scale testing are described in the "SC Pre-Design Summary Report" submitted to the U.S. Environmental Protection Agency (EPA) on January 14, 1992.

This SC Pre-Design Work Plan is supported by the Project Operations Plan (POP) for SC activities, which has been prepared as a separate document. The POP contains the Site Management Plan, site-specific Health and Safety Plan, Community Relations Support Plan, and Sampling and Analysis Plan (SAP). The SAP contains the Field Sampling Plan (FSP) and Quality Assurance Project Plan (QAPP) for SC Pilot-Scale activities.

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2. SITE BACKGROUND

2.1 Overview of EPA Remedy for Contaminated Soil and Sediment

The Site covers approximately nine acres within a larger 65-acre parcel. Previous salvage and transformer recycling activities by the F. O'Connor Company lead to uncontrolled releases of PCB-contaminated oils at the Site. Principal features on the property include a large barn that formerly housed scrap operations, an Upland Marsh, an adjacent "low area" of fill, two surface water impoundments (Upper and Lower Lagoons), three former outdoor transformer work areas (TWAs) and a former scrap area (Figure 2). Site drainage is principally controlled by the slope extending downward from the transformer work areas toward Riggs Brook. Currently, the Upper and Lower Lagoons located on the slope serve as detention basins for surface water flow from the Upland Marsh.

Contaminated soil and sediment containing concentrations of PCBs, cPAHs, and lead above cleanup standards are to be excavated and treated on-site using a solvent extraction technology. Cleanup standards for PCBs, cPAHs and lead in soil and sediment are identified in the Record of Decision (ROD) to be 1 part per million (ppm), 1 ppm, and 248 ppm, respectively. Contaminated liquids produced during solvent extraction treatment that contain extracted PCBs and cPAHs will be destroyed off-site at a licensed Toxic Substance Control Act (TSCA) incinerator. Treated soil and sediment failing to achieve the cleanup standards will require off-site disposal.

Soil residues remaining after solvent extraction treatment that contain lead concentrations above the 248 ppm cleanup standard will be transported off-site for land disposal. If lead-contaminated soil exceeds the toxicity characteristic concentration for lead (5 ppm), determined by the Toxicity Characteristic Leaching Procedure (TCLP) then the soil will undergo further treatment using a solidification/stabilization treatment technology. The ROD also specifies decontamination, demolition and off-site disposal of the barn.

22 Previous Treatability Testing

Bench-scale treatability testing was performed during Pre-Design studies in the fall of 1991 to examine whether solvent extraction could achieve the cleanup standards of 1 ppm for PCBs and cPAHs. In particular, solvent extraction was evaluated using the CF Systems' liquified propane and Resource Conservation Company's (RCC's) B.E.S.T.® treatment technologies. The bench-scale treatability testing indicated difficulty in achieving cleanup standards when soil and sediment was contaminated with PCB concentrations greater than 100 ppm. Both technologies showed poor reproducibility of treatment effectiveness in duplicate bench-scale samples. CF Systems' liquified propane extraction system appeared to remove PCBs more efficiently in initial extraction stages compared to the RCC system.

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Pre-Design bench-scale test results were similar to results of previous bench-scale testing of solvent extraction conducted during the Feasibility Study.

Pre-Design bench-scale testing did not clearly demonstrate effectiveness in achieving the cPAH cleanupstandard of 1ppm. Pre-Design sampling encountered cPAH concentrations in soil greater than the maximum concentration detected during the Remedial Investigation (RI). Poor cPAH treatmenteffectiveness would adversely impact SCRemedy implementation and cost.

Solidification/stabilization testing for lead was also performed during Pre-Design bench-scale testing by RCC on the treated sample with a total lead concentration of 440 ppm. Seven solidification/stabilization agents were tested: CRS-II, LPC-II, lime/fly ash type C, lime/fly ash type F, lime, kiln dust, and portland cement. The lowest concentration of lead in the TCLP extracts were in the samples treated with LPC-II and portland cement. However, the TCLP criteria 5 ppm was not exceeded even in the treated unsolidified soil. These results indicate that at least a portion of the soil containing lead concentrations above the cleanup standard can be disposed of as solid waste and will not require solidification.

Based on Pre-Design sampling and analysis and bench-scale studies, it is now estimated that 31,500 cubic yards (cy) of contaminated soil and sediment contain concentrations of PCBs, cPAHs, and lead above cleanup standards, and that 11,000 cy of soil and sediment will not achieve the cleanup standards during full-scale remediation. Since larger batch treatment samples are anticipated to exhibit lower treatment efficiencies during pilot testing, it is likely that the estimate of 11,000 cy of soil and sediment failing to achieve the cleanup standards will increase after pilot testing.

23 Proposed Soil Handling During SC Remediation

Based on evaluations performed during earlier Pre-Design studies, excavated material will need to besieved during full-scale remediation to separate out stones and debris exceeding 1-inch size prior to solvent extraction. Soil containing high concentrations of lead (primarily surface fill) is planned to be handled separately. Clayey soil will also be handled separately from fill and glacial till.

Excavated soil and sediment will be spread and disced to break down large soil clods and to reduce soil moisture content prior to sieving. If necessary, oversize clay clods will be broken down with a shredder prior to treatment.

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After drying, fill and glacial till soils are planned to be sieved with vibrating screens to remove stones greater than 1-inch size. Stones and non-metallic debris not passing the screens will be placed in a crusher to break up the material to minus 1-inch size. Soil passing the screen will be stockpiled in partially enclosed temporary storage areas prior to solvent extraction treatment.

Oversize non-porous debris will be sieved from the soil and transported to the debris washing pad for steam-cleaning prior to off-site disposal. Oversize porous debris will either be shredded to enable solvent extraction treatment or will be disposed off-site in asdbemlcalsiwast^andfill^ The debris washing system planned for SC remediation will consist of steam-cleaning and scrubbing performed on a decontamination pad that will also be used for earthwork equipment decontamination. Surfactants will be added to the aqueous solution for improved degreasing performance. Debris placed on the decontamination pad will be scrubbed with long-handled brushes and rinsed with a manually operated steam-cleaning unit. The decontamination pad will be designed to contain and collect all rinse solution^ Aqueous solution will be recycled by collection and filtering to remove particulates, PCBs, and other organic chemicals. Contaminated steam-Cleaning effluent is planned to be treated with granular-activated carbon and disposed on-site. Soil residues resulting from debris steam-cleaning treatment that contain lead concentrations above the 248 ppm cleanup standard will be transported off-site for land disposal. TCLPwill be performed todetermine whether thesoilsare rendered hazardous and subject to land disposal restrictions. Debris will be cleaned in batches grouped according to debris area number until representative wipe samples from each batch of debris show PCB concentrations are below maximum levels allowed for disposal in a solid waste landfill (10 /ig per 100 cm2). After cleaning, it is planned that debris will be disposed in the local landfill. EPA and the Maine Department of Environmental Protection (DEP) will be notified prior to disposal.

The diagram on the following page depicts the proposed sequencing of soil handling for full-scale remediation.

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Proposed Soil Handling for Full-Scale Remediation

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3. PURPOSE AND OBJECTIVES

The primary purpose of this pilot-scale program is to demonstrate the potential effectiveness of solvent extraction technology on pilot-scale batches of soil and sediment. Materials handling techniques used during the pilot-scale program will be similar to techniques that will be used during full-scale remediation. On-site pilot-scale testing is considered to be more representative of full-scale treatment effectiveness than previous bench-scale treatability testing.

In addition, the proposed system for decontaminating oversize non-porous debris will also be tested to determine if debris can be cleaned so that it may be disposed off-site as non­hazardous material.

Specific objectives of this pilot-scale program are:

• To determine if CF Systems' solvent extraction treatment technology can achieve the cleanup standard of 1 ppm for PCBs and cPAHs.

• To obtain quantitative information on PCB and cPAH removal efficiencies related to required number of solvent extraction washings.

• To obtain information regarding the reproducibility of treatment efficiency in the pilot-scale batch samples.

• To examine the effects that variations in soil properties such as organic content, plasticity, and moisture content have on the solvent extraction treatment process.

• To verify the current estimate of the volume of soil and sediment that were developed after bench-scale testing that may fail to meet the cleanup standards.

• To measure operational parameters, such as solvent concentration, temperature, and residence time, required to achieve treatment of on-site soil and sediments to 1 ppm, 5 ppm, and 10 ppm for PCBs and cPAHs.

• To evaluate agents to stabilize/solidify treated soil with lead concentrations exceeding the hazardous characteristic concentration of 5 ppm determined by the TCLP test.

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Document SC Pilot-Scale Work Plan Revision 1

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To examine if debris located outside of contaminated soil areas contain chemical residuals requiring steam-cleaning prior to off-site disposal as solid, non-hazardous waste.

To evaluate the effectiveness of decontaminating debris and rendering it non-hazardous for off-site disposal.

To obtain information on soil handling logistics, treatment costs, and treatment production rates needed to plan full-scale remediation.

To obtain parameters and criteria for design of full-scale remediation including preparation of plans and specifications.

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4. HEALTH AND SAFETY

The need for Level Cdermal and respiratory protection is anticipated during the following activities: soil excavation, tilling and sieving of soil and sediment, opening of any of the solvent extraction or stabilization/solidification mixing equipment, soil and sediment sampling, decontamination of oversize debris, and general decontamination of equipment.

The use of Level C respiratory protection will be based on air monitoring for volatile organic chemicals (VOCs) and particulates. Level C will be used if air monitoring detects levels of VOCs and particulates consistently above specified threshold concentrations.

The site-specific Health and Safety Plan (HSP) for SC Pilot-Scale Pre-Design field activities is presented in the Project Operations Plan (POP). All personnel performing on-site activities will be trained in accordance with the requirements of the Occupational Safety and Health Administration (OSHA) Regulation 1910.120, Hazardous Operations and Emergency Response, and will be enrolled in a comprehensive medical monitoring program. A list of personnel and subcontractors who will perform work on this project are provided in the HSP. The POP also includes the Site Management Plan (SMP) which specifies site entry and exit controls, air monitoring procedures, equipment and personnel decontamination procedures, and waste disposal.

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5. PILOT TEST SAMPLE SELECTION AND RATIONALE

Pre-Design bench-scale treatability testing indicated difficulty in achieving cleanup standards when treating soil and sediment with PCB concentrations greater than 100 ppm. Testing also indicated difficulty in reducing cPAH levels to the cleanup standards. Poor reproducibility of treatment efficiencywas observed during treatment of duplicate samples of clayey soil. Most of the soil requiring treatment are clays. In addition, bench-scale treatability data indicated that CF System's solvent extraction process may have difficulty treating sediment and soil with high moisture content. Solidification/stabilization testing has not been performed on soil contaminated with lead at concentrations approaching the maximum levels detected during RI.

Based on the results of bench-scale treatability testing, the following program for pilot-scale treatability testing has been developed:

Soil Type and PCB Contamination No. of No. of Extraction

Ranges Treatment Stages for Each Additional (Feedstock) Batches Treatment Batch Requirements

Fill, 100-500 ppm 3,6,6,6 Must contain debris, concentrations of cPAHs greater than 50 ppm, and concentrations of lead greater than 1,000 ppm

Clay, 100-500 ppm 4 3,6,6,6 Samples collected above ground water

Clay, 10-100 ppm 4 3,6,6,6 Samples collected below ground water

Clay, 1-10 ppm I Samples collected below ground water

Sediments 3 3,6,6

The Pilot-Scale TreatabilityStudy will test the predominant on-site soil type (clay) in three concentration ranges to examine the effectiveness of the selected solvent extraction technology in achieving the cleanup standards. High concentrations of cPAHs, which have been previously detected in fill, will also be tested. Duplicate and triplicate testing will provide a measure of reproducibility.

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Solidification/stabilization testing will be performed with four agents including the two most favorable agents identified during bench-scale testing j(see Section 8). Testing will be performed on the pilot-scale test sample of fill containing a high concentration of lead (greater than 1,000 ppm).

The soil treatability test samples will be collected from location TP201 shown on Figure 2. Based on previous RI and Pre-Design data described below, it is anticipated that soil from this location will fulfill the proposed pilot test program requirements.

This location is immediately adjacent to the Pre-Design test pit TP25 and the RI test pit location JTP-111 (Figure 3). As shown in the test pit logs presented in Appendix A, fill containing debris was encountered to a depth of approximately 1 foot, and silty clay was encountered to the explored depth of approximately 10 feet. Ground water, probably perched, was noted in both test pits at a depth of approximately 4 feet. Debris was noted in the fill materials of both test pits.

Analytical data collected during the RI and Pre-Design studies indicate PCB concentrations in the clay near the proposed location range from 10 ppm to greater than 100 ppm. Pre-Design bench-scale test samples of clay collected from TP25 at a depth of 4 feet contained PCB concentrations ranging from 74 ppm to 113 ppm.

A fill sample selected for bench-scale treatability testing from TP25 was obtained at a depth of 0.8 feet. This sample contained the highest concentration of lead at 1,810 ppm detected in Pre-Design samples, and a PCB concentration of 535 ppm. This sample also had a relatively high cPAH concentration of 139 ppm.

The sediment sample for testing pilot-scale treatability will be collected from the Upper Lagoon (Figure 2). Based on RI and Pre-Design data, the Upper Lagoon contains the highest concentrations of PCBs in sediment. A sediment sample collected from the Upper Lagoon during Pre-Design studies contained PCBs at a concentration of 670 ppm.

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6. COLLECTION AND PREPARATION OF MATERIALS FOR TREATABILITY TESTING

6.1 Excavation of Soil

Excavation of one trench, TP201, is proposed to obtain the desired clay and fill feedstock for pilot-scale testing. The excavation will be performed with a rubber-tire backhoe (Case Model 580K or equivalent) and will extend to the vertical and lateral limits necessary to obtain the pilot-test program test batches. Sample locations will be surveyed with a tape and compass from physical features shown on the Site plans.

Excavation will be advanced at TP201 with the initial removal of fill to a depth of approximately 1 foot. Clay collected from depths between approximately 3 to 5 feet will then be excavated and stockpiled separately. This soil will provide treatment batches for clay in the 100 to 500 ppm PCB concentration range. Clay collected from depths between approximately 7 to|feet will be excavated and stockpiled to provide treatment batches of clay from below ground water with PCB concentrations in the range of 10 to 100 ppm. Gay collected from below 9 feet will be excavated or stockpiled to obtain batches of clay from below ground water with PCB concentrations front 1to 10 ppm.

During excavation, samples of clay will be collected for analysis of liquid and plastic (Atterberg) limits at GEI's laboratory in Winchester, Massachusetts. Clay samples will be collected from depths of about 2 feet, 4 feet, 6 feet, and 8 feet. The samples will be collected from the backhoe bucket. All sampling procedures are described in the Field Sampling Plan (FSP) provided as Volume II of the POP. Analytical procedures are described in the Quality Assurance Project Plan (QAPP) provided as Volume III of the POP.

In general, soil excavated from trench area TP201 will be staged in foil separate areas based on soil type. Each144-square-foot area will consist of polyethylene sheeting covered with 144 square feet of plywood sheeting. Three cubic yards of each soil feedstock type as described fa Sections (Fill: 100-500 ppm PCBs, Clay: 100-500 ppm PCBs, Clay: 10-100 ppm PCBs, and Clay;1to 10ppm) will be placed on the plywood sheeting and split into cells for composite sampling. Based on PCB field screening and other laboratory testing, feedstock in cells which exhibit contaminant concentrations in the desired range will be retained for further processing (see Section 6.3). Whan drying of the soil is not taking place, the stockpiled soil will be covered to protect from precipitation,

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Oversized dimiftotoiiiS debris will be hand-picked from the excavated till soil and placed on polyethylene sheeting. This debris will be decontaminated as described in Section 9. Oversized porous debris (wood and tires)separatedfrom excavated materials will be stockpiledadjacent toTP201andbackfilleduponcompletionoftreatability testingsample collection. In general,excavated materialswill be backfilled in thereverse order of their excavation. Nine composite soil samples will be collected in accordance with the FSP from each potential feedstock described in Section5; Clay, 1-10ppm PCBs;; Clay, 10-100 ppm PCBs; Clay, 100-500 ppm PCBs; and Fill 100-500 ppm PCBs. These samples will be analyzed in accordance with the QAPP by a GEI chemist in an on-site trailer using a Dexsil L2000 PCB/chloride analyzer (Dexsil Analyzer). The analytical results will be used to determine whether the desired PCB concentrations for treatability testing have been obtained.

If necessary, additional excavation will be performed in TWA II to obtain samples within the desired PCB concentration range. Additional samples for screening with the Dexsil Analyzer would be collected to guide further excavation activities.

After screening indicates the desired PCB concentration has been obtained in the fill, soil samples will be collected in accordance with the FSP for cPAH and lead analyses. These analyses will be performed by NET Atlantic, Inc. Verbal analytical results will be received within three days. If the desired concentrations of cPAHs and lead were not collected based on the laboratory data, additional excavation of fill near TP201 will be performed until the desired lead, PCB and cPAH concentration ranges are obtained.

The excavation trench will be covered with plastic upon completion of excavation activities. Hay bales will be placed downgradient from the excavation area to prevent downslope migration of soils* After laboratory analyses have verified that target contaminant concentrations have been obtained for each type of soil, soil not used to supply feedstock for pilot testing will be backfilled in the trench. The trench's locationwill be shown on the Site plan and marked in the field with labelled grade stakes. Measurements identifying the trench location will also be recorded in the project field book.

62 Collection of Sediment

Sediment will be obtained from the Upper Lagoon. Sediment will be scooped from shallow depth with the bucket of a rubber-tired backhoe. Water will be allowed to drain from the bucket into the Upper Lagoon before the sediment is placed in an approximately 40 square-foot bermed processing area. The processing area will be constructed of one plywood sheet edged with S-inch-wide wood timbers and covered with two layers of polyethylene sheeting. The sediment will be spread to a thickness of approximately 6 inches for further drying and processing (see Section 6.3).

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The highest concentrations of PCBs in sediment have been detected during previous studies in samples from the Upper Lagoon. Collected sediment from the Upper Lagoon will not be screened with the Dexsil Analyzer since a target range of contamination is not prescribed for sediments.

63 Preparation of Soil and Sediment for Treatability Testing

As indicated, soil and sediment will be air-dried and then sieved through a 1-inch screen to provide feedstock for solvent extraction. Drying will be facilitated with the use of a typical garden tiller. The feedstock will be tilled at least twice per day with a minimum drying time between tilling of one hour. Excess dust will becontrolled by covering air-dried soil with plastic. Soil mil also be covered with plastic during periods of rain. Soil and sediment handling procedures are detailed in the FSP, provided as Volume II of the POP.

Samples of soil and sediment will be collected during the drying process and analyzed on-site by GEI for moisture content using ASTM Method D2216-80. Drying will continue until the following moisture contents are obtained.

Feedstock Soil Treatment No. of Moisture Content PCB Batch Extraction

Concentrations Stages

Clay 1 3 < plastic limit or asymptotic 100 to 500 ppm 2 6 < plastic limit or asymptotic

3 6 < plastic limit or asymptotic 4 6 Minimum drying to enable

the soil to be sieved

Clay 1 3 < plastic limit or asymptotic 10 to 100 ppm 2 6 < plastic limit or asymptotic

3 6 < plastic limit or asymptotic 4 6 Minimum drying to enable

the soil to be sieved

1 to10 1 I i

i i i

< plastic limit or asymptotic £ plastic limit orasymptotic Minimum drying toenable thesoil tobe sieved

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Fill 1 3 Minimum drying to enable 100 to 500 ppm the soil to be sieved

2 6 Minimum drying to enable the soil to be sieved

3 6 Minimum drying to enable the soil to be sieved

4 6 Minimum drying to enable the soil to be sieved

Sediments 1 3 < plastic limit or asymptotic 2 6 < plastic limit or asymptotic 3 6 < plastic limit or asymptotic

As indicated, one treatment batch (approximately 100 pounds) of each of the clay feedstocks (clay containing 1to 10 ppm PCBs, clay containing 10 to 100 ppm PCBs, and clay containing 100 to 500 ppm PCBs) will be air-dried to the minimum amount necessary to enable the soil to pass through the 1-inch sieve without excessive plugging. Other batches within each feedstock will be air-dried to the maximum extent practicable during the drying process. Portions of the clay soil will be shoveled onto the sieve to determine if clay soil is able to pass through the sieve. Once the clay soil from each feedstock is able to pass through the sieve, a composite sample will be collected for determination of moisture content. Sufficient clay soil will be sieved to provide one treatment batch for each feedstock for solvent extraction treatability testing (approximately one-half of a 55­gallon drum for each feedstock). A composite sample will be collected from each drum of clay feedstock for PCB screening with the Dexsil Analyzer to confirm that desired soil with PCB concentrations within the PCB concentration range was collected. These feedstocks will be staged for eventual solvent extraction treatment. The wetter treatment batches will be designated as one of the 6-stage treatment batches for clay feedstock with 10 to 100 ppm PCBs and clay feedstock with 100 to 500 ppm PCBs.

Drying of the sediment and excavated soil that will provide the feedstock for the remaining treatment batches will be continued until the minimum moisture content that can be practicably achieved is obtained. If the average moisture content from four composite samples is less than or equal to the plastic limit of the soil determined by laboratory Atterberg Limits determinations, the drying process will be discontinued. The drying process will also be discontinued if a plot of moisture content versus cycles of drying appears asymptotic at moisture contents above the plastic limit. This relationship would indicate that moisture content as low as the plastic limit would not be practicably attainable for that feedstock.

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Once the moisture content criterion has been met, the feedstock will be sieved through a 1-inch screen. Two 55-gallon drums will be half-filled with the sieved feedstock. The drums of sieved sediment will be staged for eventual solvent extraction treatment. A composite soil sample will be collected from each soil drum for PCB screening with the Dexsil Analyzer.

As indicated previously, PCB screening of sediment samples will not be performed prior to treatability testing, since a target PCB concentration range was not prescribed for sediments. If the desired PCB concentration range in soil is confirmed, the drums of soil feedstock will also be staged for eventual solvent extraction treatment. If the desired PCB concentration ranges are not obtained, additional soil will be sieved and tested.

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7. SOLVENT EXTRACTION PILOT-SCALE TESTING

7.1 Testing Program

CF Systems will perform treatability testing on|||f different feedstocks asdescribed below. Test batches from each source type will be subjected to 3 and 6 stages of extraction, as indicated. Duplicate and triplicate testing of 6-stage extraction will be performed to examine reproducibility of treatment effectiveness.

Soil Type and PCB Contamination Range No. of Extraction Stages

(Feedstock) No. of Treatment Batches for Each Treatment Batch

Fill, 100 - 500 ppm 4 3,6,6,6

Clay, 100 - 500 ppm 4 3,6,6,6

Clay, 10 - 100 ppm 4 3,6,6,6

Clay, 1-10 ppm | MB

Sediments 3 3,6,6

Untreated soil and sediment (i.e., feed samples) will be analyzed for PCBs and cPAHs prior to treatment. Percent moisture of each feed sample will also be determined. Analytical procedures and quality assurance requirements are described in the Quality Assurance Project Plan included as Volume III of the POP. At the completion of each treatment batch (i.e., after 3 or 6 stages of extraction^ samples of treated solids and extracted oil will also be analyzed for PCBs and cPAHs. In addition, total solids determinations will be completed on all feed samples and treated solids.

CF Systems will subcontract Chemfix Environmental Services, Inc. (Chemfix) of Metairie, Louisiana to perform on-site treatability testing on fill material containing greater than 1,000 ppm lead. The treated unfixed solids from the fill after solvent extraction treatment will be analyzed for total lead and TCLP lead concentrations. Stabilized solids will be tested for lead by TCLP extraction. Testing is anticipated to take one to two days to complete. A description of solidification/stabilization testing is provided in Section 8.

12 Solvent Extraction Treatment Batch Preparation

Solvent extraction treatment batches will be homogenized prior to treatment. One-hundred-pound treatment batches will bo placed in a pilot-scale pug mill mixer until a homogeneous mixture is achieved. Aliquots of the feed samples will be collected for laboratory analysis after homogenization.

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73 Pilot-Scale Treatment Process Description

CF Systems will utilize its mobile liquified propane extraction demonstration unit (MDU) during pilot-scale testing. Location of the soil treatment equipment area is shown on Figure 2. A generalized schematic of the unit is provided in Figure |. Detailed process equipment description and operating logic are provided under separate cover. As indicated on each page of the process information provided, these specifications are proprietary and confidential, and shall be protected in accordance with Section 104 (e) (7) of the CERCLA, 42 U.S.C. Section 9604 (e) (7) and 40 CFR Section 2.203(b).

Anticipated operating conditions are as follows:

Batch Size (pounds) 100 Maximum Particle Size (inch) 1 Solvent/Feed Ratio (volume) 5:1 Extractor Temp. (°F) 120-240 Extractor Pressure (psig) 300-700 Residence Time (minutes) 15-45

The MDU includes a 50-gallon-capacity batch extractor that facilitates the mass transfer between the contaminated material and the liquefied propane. A solvent recovery system separates the propane from the extracted organics and recycles the propane. A series of surge tanks and heat exchangers are provided to regulate the temperature and flow rate of solvent in the system.

All process equipment is designed to withstand temperatures and pressures which exceed normal operating conditions. Process equipment which contacts the solvent or feed materials is constructed of either carbon steel or 316 stainless steel. Piping and valves are 316 stainless steel. However, to guard against sudden over-pressure, each vessel has a relief valve which vents to a header system. During venting operations, propane is sent to the process header, which directs the material to a knock-out tank where solids and liquids are removed from the vented stream. The gases, which come from the knock-out vessel, pass through an activated carbon filter to remove contaminants in the propane gas. The gas is then vented to the atmosphere.

Thelota!volumeof liquid propanecontained In thetreatment unitat any given time Is estimated tobe SOQgallons,and thisquantityof propanewillbevented as vaporfrom the unitat thecompletion of thestudy* The rateatwhich propane will bevented will be 40 lbs per hour,which will require approximately 48 hoursto accomplish. During the entire venting operation, two operators will be physically located on the unit, and the environment around the unit will be monitored for propane to ensure that the concentration does not reach 10 percent of the Lower Explosive limit (LEL). If the

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concentrationof propanedoes reach10 percent1ELduringventingoperations,enalarm will sound andventing operations will cease*

The composition of the vented gases will be composed primarily of propane, (ie. >96 percent),with some additional mixture of butane, trace methane and ethane, and trace noa-condensibles, (eg*nitrogen, oxygen). Due tothe low vapor pressures of both

Results from the recently completed bench-scale treatability study performed by CF Systems indicated that for the Fill Sample, cPAH extraction efficiencies were not sufficient to meet the cPAH cleanup standard of 1 ppm. Prior to conducting this pilot-scale study, CF Systems will perform an additional bench-scale study at its testing facility in Woburn, Massachusetts to investigate the use of higher extraction temperatures (maximum 2401;F) in order to improve cPAH extraction efficiency. A letter report detailing the results of that study will be made available to EPA prior to conducting pilot-scale operations.

Utility requirements for pilot-scalesolvent extraction and solidification/stabilization testing are as follows:.

Electricity 480V AC, 3-phase, 125 amps

Process Water 10 GPM, 60-80°F inlet at 30-90 (max) psi

Potable Water 1,000-gallon storage tank Propane 400 gallon bullet,

95-97% purity Nitrogen (5)-lA size cylinders

7.4 Operation

7.4.1 Site Preparation and Start-up

As identified in the Site Management Plan, pilot-scale solvent extraction and solidification/stabilization equipment will be located to the of the barn. A rubber-tired backhoe (Case Model 580K or equivalent) will be used to prepare the area. Debris Area 1 consisting of a small pile of soil, lumber, and metal pipe, will be moved to TWA I. If necessary, the ground surface will be graded with the backhoe.

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Table 1 is a list of equipment and logistical items necessary to begin pilot-scale field work. The organization responsible for providing each item is also identified. The estimated time required for equipment set up of the MDU is three days. The following is the anticipated chronology of events:

Day 1

1. Arrive at the staging area with the MDU. 2. Find location for MDU within staging area; spot and level trailer. 3. Place various hazard signs on MDU and staging area fence. 4. Construct berm around MDU. 5. Electrician arrives to hook up power. 6. Take delivery of propane, spot tank position, and install. 7. Take delivery of nitrogen. 8. Hook up process cooling water and potable water to pilot plant. 9. Take delivery of empty sample buckets and drums. 10. Set location for all disposal items. 11. Take delivery and store sample containers, hazsuits, gloves, etc. 12. Begin to unpack MDU.

Day 2

1. Finish unpacking MDU. 2. Set up waste tarps and sock borders beneath MDU, feed prep areas,

and temporary holding areas. 3. Perform pressure test with water and nitrogen. The test is done at

1.5 times maximum process pressure to ensure the system is tight and secure. Any leaks found will be corrected.

4. Drain water and vent nitrogen.

Dav 3

1. Calibrate pilot-scale equipment and instrumentation.

7.4.2 Process Control

At the start of each demonstration day, a site inspection will be performed by CF Systems' lead operator. It will include the following activities:

1. Inspect waste feed area, note and correct leaks or spills. 2. Inspect MDU leakage. 3. Inspect waste disposal area for problems. 4. Meet with GEI Health and Safety Officer and On-Site Project

Coordinator to address any concerns.

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Process variables will be monitored to provide data for mass balance calculations, process economics, and to record CF Systems' operating conditions. Table 2 lists the process variables to be monitored and the type of data each variable will provide.

The parametersmeasured in Table 2of theSCPilot-Scale Work Plan will either be read directlyfrom gauges located on the unit, or from digital readouts in the control roomand will berecorded manually Intologbooksat the intervals shown. In addition todie parameters read and recorded manually intologbooks, the soil treatment unit containsasafety interlock system that will automaticallyshutdown thesystem in asafe manner during upset conditions.

Pressure gauges or transmitters utilized in the MDU are typical Bourdon C-tube with indicator linkage mechanisms. The solvent flowmeter is a Coriolis-force, strain gauge. Movement of the material through flexible tubing is sensed by strain-sensitive, electric wires. The change in electric current through the wires is translated, through empirical relationships, to a mass flow rate. The weight scale is a typical twin-beam, force balance. The electric power meter is a standard, domestic kilowatt-hour meter. The cooling water flowmeter is a rotameter. The cooling water thermometers (input/output) are in-line thermocouples. The propane "percent use" gauge is a Bourdon C-tube with an indicator linkage mechanism.

Emergency shutdown will occur only if system malfunction threatens to jeopardize worker safety. The emergency shutdown circuit consists of two "kill" switches on the unit which, when activated by the operator, will disconnect power to the unit. There are two combustible gas detectors that will also disconnect power to the unit if an explosive environment is detected. The shutdown circuit is tested daily.

The following is the daily shutdown procedure for CF Systems' MDU:

1. Circulate propane through the extractors and solvent recovery column for two hours to sufficiently clean the solvent.

2. Shut off compressor. 3. Close all manual valves. 4. Drain extract from Extract Product Tank.

7.43 Decontamination

Phot-scaletreatmentwill proceedfromsoilswith thelowest tohighestcontaminant concentrations. Seven samples of rinsewater will be collected and analyzed for PCBs andcPAHs toverifydecontamination procedures. Rinsewater sampleswill be collected between sourcetypes and betweeneach treatment batch of themost contaminated clay (FS2: 100 to 500 ppm PCBs).

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The proposed decontamination scheme is as follows:

1. Circulate propane through system for a minimum of two hours. 2. Collect organics from Extract Product Tank. 3. Clean the interior of the vessels with toluene. Toluene (5-gal) is

placed into the extractor, heated propane is then allowed to flow into the extractor to contact the toluene. The mixer is turned on at high speed for a minimum of 20 minutes. The propane/toluene mixture is then allowed to flow into the extract surge drum, distillation column, and extract product drum. After decontamination, the toluene will be containerized in 55-gallon drums for disposal.

4. One toluene wash will be performed between each treatment batch. A minimum of three toluene washes will be required between each source type, and at the completion of pilot-scale testing.

5. The equipment will be rinsed with water to remove residual toluene. The rinse water will be collected and stored in a 1,000-gallon tank.

6. Vent propane to header system, through carbon bed and out to atmosphere.

7. Steam-clean system. 8. Wash other auxiliary equipment used in the study with soap and

water followed by a toluene rinse.

7.4.4 Closure

When the final decontamination process is complete, staging area Closure can begin. The first step is to prepare the CF Systems' MDU for transport. This procedure, to be performed by CF Systems personnel, includes the following:

1. Vent all residual propane from the system by filling all vessels with nitrogen.

2. Disconnect MDU cooling and water lines 3. Disconnect MDU electric service (to be performed by an electrician

under CF Systems' supervision). 4. Ready MDU for travel.

GEI shall observe and check removal of all equipment and materials from the staging area by a separate earthwork contractor (see POP). GEI shall also oversee removal of fences, gates, electrical equipment, portable toilets, and electrical services associated with the pilot treatment unit. CMP will contract a hazardous waste hauler to remove all generated hazardous wastes. GEI shall coordinate waste removal and all staging area closure activities including propane tank removal and personnel trailer return.

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7.5 Waste Generation

Process and decontamination waste that will be generated as a result of treatability testing islisted inTable 3. All waste scheduled for off-site disposal atdie conclusion of Pilot-Scale activities will be placed in drums which will be stored in the Drum Storage Area. Solid processwasteswillbe storedintheSolidWasteStorageArea{SeeSiteManagement Plan}!!

Filtratemid rimewatermay bedisposedof on-site. Filtrate water will be generated from the water used to remove treated solids from the extractor. Filtrate water will only have contact with treated solids and is expected to be relatively free of contamination. It will be discharged onto the decontamination pad for ultimate discharge to the Lower Lagoon. Rinse water will be generated after the solvent extraction equipment is decontaminated with toluene. It will be stored in a 1,000-gallon tank. At the completion of treatability testing, a sample will be collected from the storage tank and analyzed for toluene,11® iMHl These results will be used to determine proper disposal. Disposal options include:

• treatment of water prior to on-site disposal, utilizing the MOM activated carbon treatment system;

• discharge of water to the Upper Lagoon without treatment; or • off-site disposal

Unused feed and treated solids will be stored on-site in drums until final disposal during the Remedial Action. CMP will subcontract a hazardous waste hauler for proper waste characterization and disposal of the drummed waste listed below (see POP).

• Contaminated trash, such as gloves, Tyvek suits, paper towels, etc. • Spent solvent generated during the decontamination of the MDU • Concentrated PCB-contaminated extract • One 55-gallon canister of activated carbon

Drums will be labelled accurately according to the contents. A log will be kept of all drums containing waste.

7.6 Quality Control and Quality Assurance

CF Systems will provide GEI with split samples of all feed and treated solids. All split samples will be analyzed for PCBs and cPAHs. Split samples of the feed batches of fill will also be analyzed for total lead. The same analytical procedures will be utilized by CF Systems' laboratory, General Physics Corporation, and GEI's laboratory, NET Atlantic, Inc., as described in the Quality Assurance Project Plan. The Quality Assurance Project Plan is included as Volume III of the POP.

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GEI field personnel will provide full-time observation of treatability study activities. The Treatability Studies Manager (a senior waste treatment engineer) will audit approximately 30 percent of the pilot-scale solvent extraction treatability testing. The Treatability Studies Manager will be present during start-up operations and remain on-site for a minimum of one week or until testing is proceeding as specified in the Work Plan. Audits will be conducted regularly throughout the rest of pilot-scale testing.

If non-conformance to the SC Work Plan is noted during the audits, the Treatability Studies Manager will take the following steps:

a. The Treatability Studies Manager will notify the Quality Assurance Officer (QAO) and GEI's Project Manager of the nonconformance.

b. The QAO will assist GEI's Project Manager and CF Systems' Project Manager in remediating the non-conformance.

c. If the non-conformance cannot be corrected easily, results in a significant delay in the project, or is judged to have a potential impact on the testing results, work will stop and the QAO will complete a Non-Conformance Report.

d. A copy of the Non-Conformance Report will be submitted to the GEI and CF Systems Project Managers, who will in turn submit the report to the Project Coordinator for CMP. Additionally, a copy of the Non-Conformance Report will be submitted to EPA and DEP.

e. Work will continue after EPA approval of the plan to rectify the non­conformance.

The following general equation will be used to perform material balances:

Input + Generation - Output - Consumption = Accumulation

where;

Input = Material entering the system boundaries

Generation = Material produced within system boundaries

Output = Material leaving the system boundaries

Consumption = Material consumed within system boundaries

Accumulation = Material build-up within system boundaries

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Physical accumulation within the system is the primary explanation for incomplete balance closure. Material losses may occur as a result of particulate filters that are used to protect operating equipment. In addition, many residues have a tendency to adhere to tanks, piping and other equipment. According to CF Systems, balances performed on the total mass processed in the system generally approach 93 to 98 percent closure.

Balances performed on individual organic species which are initially present at low to moderate concentrations are inherently more difficult. For example, processing 100 pounds of feed containing one percent total organics would only produce one pound of extract. A minor amount of accumulation of these organics within the system can lead to significant errors.

The following data collection procedures will encourage acceptable mass balance closure for each extraction test:

• Accurate weight of material entering the process. Before and after weights taken of sample container(s).

• Accurate weights of raffinate and extract generated during test.

• Solvent wash of system vessels at the conclusion of each extraction test.

• Before and after weights taken of system hardware such as strainers, filter casings, filter elements, etc.

• Obtaining representative samples of feed, raffinate and extract so that sampling biases are minimized providing accurate and precise analytical results.

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8. STABILIZATION/SOLIDIFICATION PILOT-SCALE TESTING

CF Systems will subcontract Chemfix Environmental Services, Inc. (Chemfix) of Metairie, Louisiana to perform on-site treatability testing on fill material containing greater than 1,000 ppm lead. The treated unfixed solids from the fill after solvent extraction treatment will be analyzed for total lead and TCLP lead concentrations. The four batches of treated solids will be mixed with the following agents: LPC-II, portland cement, CHEMSET1-20, and C-220. The agents, LPCII and portland cement, were identified as effective agents during Pre-Design bench-scale treatability testing. CHEMSET 1-20 and C-220 are Chemfix's proprietary fixation reagents that also have been shown to be effective for fixation of lead in soil. Stabilized solids will be tested for lead by TCLP extraction.

CF Systems will notify Chemfix to mobilize to the site after treatment of the fill material with solvent extraction has been completed. Solidification/stabilization testing is anticipated to take one to two days to complete and will occur concurrently with the solvent extraction treatment program.

Chemfix will perform stabilization/solidification testing in a pug mill mixer mounted on an approximately 6-foot by 4-foot trailer. The trailer will be towed into the treatability test equipment area shown on Figure 2. Treated solids will be placed in 20-gallon pre­cleaned plastic pails by CF Systems. Chemfix will manually place the solids in the mixer. Water will be added until soil moisture is approximately 50 percent. After adding the fixation agents, the soil will be mixed for approximately five minutes.

A sample of the fixed soil will be collected directly from the mixer for TCLP analysis. The remainder of the fixed soil will be returned to the 20-gallon pail for storage on-site. Description of the on-site storage area is provided in the Site Management Plan (POP Volume1);

The mixer will be decontaminated between treatment batches and at the completion of testing with high-pressure steam. This water will be collected and discharged onto the decontamination pad. All personal protective gear used during testing will be placed in drums to be disposed of with the rest of the waste materials from Site activities.

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9. DEBRIS WASHING

Pilot-scale debriswashing will be performed to evaluate theeffectiveness of steam-cleaning to render non-porous debris non-hazardous for disposal in a local landfill. Oversized porous debris{wood and tires) will beseparated and stockpiled for backfillingintoTP20L During ball-scale remediation* oversized porousdebris will be either shredded toenable it tobe treated bysolventextraction orbedisposed of off-siteInachemical wastelandfall.

Nomporous debris will be hand picked from fill soil during excavation activities. Pilot-scale debris washing will begin by placing the debris in an 8-foot square wooden tray within the on-site decontamination pad and applying high-pressure steam. Surfactants (Alconox™) will be added to the water supply for the steam cleaner for improved degreasing capability. Debris will be agitated by hand or with the backhoe bucket to expose all contaminated surfaces to the pressure wash. Wash water will be drained from the tray onto the underlying decontamination pad. Wipe samples will be collected from non-porous materials prior to and following steam-cleaning to evaluate the decontamination process. The following general procedures will be used during debris washing:

• Place approximately 1/3 cy of debris on the wooden tray; • Collect one wipe sample from each treatment batch prior to

decontamination; • Apply high-pressure steam to all exposed surfaces of each treatment batch

of debris for a specified time; • Turn debris manually or with backhoe; • Scrub exposed surface of debris with a long handled brush; • Repeat steam cleaning for the same duration of time as before; • Collect four wipe samples from each treatment batch from non-porous

debris surfaces; • Remove washed debris from the tray and place in 55-gallon steel drums.

Three batches of debris will be tested. To the extent practicable, each treatment batch will consist of similar debris. The duration of steam-cleaning will be 5 minutes for the first treatment batch, 10 minutes for the second, and 15 minutes for the third. Four wipe samples of the cleaned debris per treatment hatch will be collected.

Wipe samples will also be collected from on-site debris located in areas outside the extent of contaminated soil and sediment to examine whether decontamination is necessary for all debris. Wipe samples will be collected from square metal containers observed in Debris Area (DA) 7, from meter housing scrap metal observed in DA14, and from porcelain insulator fragments observed in DA13. Debris areas are shown on Figure 3.

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All wipe sampleswill beanalyzed for PCBs. Six wipe samples will alsobe analyzed far cPAUsiatldilead, as described in the Field Sampling Plan. The TSCA spill policy performance standard of 10 Mg PCBs per 100 cm2 wiped will be used to assess the effectiveness of the procedure. Storage, labelling and handling procedures for washed debris are discussed in the Site Management Plan.

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10. REPORTING

A summary report will be prepared by CF Systems that will include, as a minimum, the following:

• Description of all test procedures, test equipment, operating parameters,and analytical methods used;

• All analytical results including PCB and cPAH mass balance computation, PCB, cPAH and lead analyses, and quality control results;

• A discussion on the effect of moisture content, soil type, and soil particle size on the efficiency of the solvent extraction technology;

• A discussion of PCB and cPAH removal efficiencies and evaluation of whether the treatment technology can achieve the cleanup standards;

• Results of the lead solidification/stabilization testing;

• Operational parameters and estimated effectiveness and reproducibility for full-scale implementation;

• Cost estimates for full-scale implementation.

Independent Quality Assurance Review of the Pilot-scale Treatability Testing Report will be provided by Chapman, Inc. (Chapman) of Atlanta Highlands, New Jersey. Chapman will review the Treatability Testing Report from CF Systems prior to its inclusion in the final Source Control Pilot-Scale Summary Report. The report summarizing Chapman's review will be submitted as part of the SC Pilot-Scale Summary Report. Chapman is an environmental consulting firm experienced in the design, fabrication, and field operations of innovative remedial technologies for the cleanup of contaminated soils and ground water. Chapman is identified as part of the Independent Quality Assurance Team in the document Initial Remedial Steps submitted to EPA on December 12, 1990.

The SC Pilot-Scale Summary report will include results of treatability testing, evaluation of soil handling techniques, and evaluation of the debris washing system. The results of the pilot-scale treatability testing will be used to reevaluate the feasibility and cost of the selected remedy for the Site. This reevaluation will involve examining the operational parameters needed to achieve the cleanup standards, estimating the volume of soil that may require off-site disposal because of failure to meet the cleanup standards, and reviewing the cost of the SC Remedy. Based on the results of pilot-scale testing, recommendations regarding the design and implementation of the SC Remedy will be made.

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11. SCHEDULE

Initiation of work will be constrained by two factors: availability of CF Systems' mobile demonstration treatment unit, and completion of the Management of Migration (MOM) aquifer test. If CF is not given authorization to mobilize between July 1and July 31,1992, it will be unable to mobilize its mobile demonstration treatment unit until the spring of 1993. EPA approval or modification of the SC Pilot Test Work Plan is, therefore, required by June 1, 1992 to enable completion of pilot testing of solvent extraction during 1992. Due to the planned use of sensitive water level recording instruments during the aquifer test, SC Pilot-Scale site activities cannot occur simultaneouslywith the aquifer test. If EPA authorization for MOM pilot-scale activities is received by April 1, 1992, it is anticipated that MOM well installation and aquifer testing will be completed by the end of May 1992.

SC activities will begin within 30 days after receiving notification by EPA of approval or modification of this Work Plan, subject to limitations discussed below. Within one­hundred-eighty-nine (189) days after receiving notification of approval or EPA modification of the SC Pre-Design Work Plan, CMP will submit a Pre-Design SC Pilot-Scale SummaryReport describingall methodologies and analysis of results and conclusions developed for Pre-Design SC Pilot-Scale Investigations^ As discussed with EPA previously, more time will be needed to complete SC pilot-scale testing than the 120-day period scheduled in the O'Connor Site Statement of Work attached to the Consent Decree. Approximately two additional months are required to provide sufficient time for on-site operation of the CF Systems' MDU, independent review of treatability results by Chapman, Inc. and interim review of results by CMP. The proposed schedule is shown on Figure 5.

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TABLE 1 - EQUIPMENT AND LOGISTICS FOR SOLVENT EXTRACTION SC Pilot-Scale Testing O'Connor Site Augusta, Maine

Item

Drums of Feed Material to be Processed Potable Water Supply Sanitary Facilities Electric Service Personnel Trailer 10' x 20' (Air Conditioned) Furniture (Tables and/or Desks)

Drinking Water First Aid Kit

Water Chiller (10 GPM) and All Hook-Ups (2) 1,000-gallon Water Storage Tank

Sampling Equipment and Jars Wash Tubs and Brushes (4) 55-gallon Drums Toluene (20) 5-gallon Containers Deionized Water Activated Carbon for Water Treatment Laboratory-grade, Non-phosphate Detergent

(60) Clean 55-gallon Drums (25) Clear Plastic 10-gallon paiis (5) Cases of Tyvek Suits, Large and Extra Large, with Hoods and Boots (5) Cases of Safety Gloves, Suitable for Hazardous Waste Respirators and SCBA

Lumber for Feed Prep Area and Polyethylene for Containment Areas Spill Control (Adsorbents)

Hazard Signs

Propane, 400-gallon Storage Tank (5) Nitrogen, 1A Cylinders

Scales Electrical Cords

Steam Cleaner

Notes:

GEI GEI Consultants, Inc. CF CF Systems Corporation

Providing Organization

Northland GEI

Northland CMP

Northland Northland

Northland GEI/CF

CF Northland

CF CF

Northland Northland

CF GEI

Northland Northland

CF CF CF

Northland CF

CF

Northland Northland

CF CF

Northland

Northland Northland Management (earthwork and site preparation subcontractor) CMP Central Maine Power Company

Revision 1 Project 90393

GEI Consultants, Inc. June 19, 1992

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TABLE 2 - SOLVENT EXTRACTION PROCESS CONTROL MEASUREMENTS SC Pilot-Scale Testing O'Connor Site Augusta, Maine

Name/Type

Extractor Pressure Gauge

Extractor Temperature Gauge

Solvent Mass Flow Meter

Feed Weight Scale

Extract Weight Scale

Electric Power Meter

Cooling Water Flow Meter

Cooling Water Thermometer

Propane "Percent Use" Gauge

Notes:

Location

Atop Extractor

Atop Extractor

Readout inside control room

Free-standing scale positioned in waste feed area behind CF trailer

Laboratory-type triple beam balance

Outside CF Unit trailer

Discharge line from CF Unit trailer

In influent and effluent water lines

On propane bullet

Rationale

Verify operating conditions

Verify operating conditions

Verify operating conditions

Mass balance, calculations

Mass balance calculations

Process Economics

Process Economics

Process Economics

Process Economics

Monitor Frequency

15 min.

15 min.

10 min

Initial feed and all subsequent raffinates at end of pass

End of pass

Beginning and end of each pass

15 min.

15 min for influent and effluent

Beginning and endi of each operating day

Units

psig

psig

lbs.

lbs.

lbs.

kW-hr

GPM

lbs.

psig pounds per square inch gauge pressure lbs pounds kW-hr kilowatts per hour ° F degrees Fahrenheit GPM gallons per minute

Revision 1 Project 90393

GEI Consultants, Inc. June 19, 1992

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TABLE 3 - WASTE GENERATION SC Pilot-Scale Studies O'Connor Site Augusta, Maine

Type Source Estimated Testing Disposal Quantity

Dry solid waste Tyvek, paper products, plastics, 1 5 - 3 0 d r u m s Aptus1(1) Off-site at an EPA-gloves, etc. approved facility

Methanol waste Rinse water from decontamination 5 drums Aptus(1) Off-site at an EPA-approved facility

PCB oily-extracts From soil treatment 1 drum Aptus1(D Off-site at an EPA-approved facility

Toluene Decontamination of soil treatment 1 drum Aptus1(D Off-site at an EPA-unit approved facility

Treatment unit rinse Rinsing Of soil treatment unit after 7 - 1 5 d r u m s Toluene, PCBs, cPAHs Potentially on-site or off-water decontamination with toluene site®

Filtrate water Discharge of treated solids from 1 0 - 1 8 d r u m s Not necessary Decon pad soil treatment unit

Non-contact process For cooling of soil treatment unit 300 gallons Not necessary Upper Lagoon water

Untreated soil/sediment Soil treatability study 4 drums PCBs, cPAHs and lead Remains on-site

Treated soil/sediment Soil treatability study 4 drums PCBs, cPAHs and lead Remains on-site

Activated carbon Propane vent from soil treatment 1 drum Aptus10) Off-site at an EPA-unit approved facility

Note:

(1) The waste disposal subcontractor, Aptus, will determine necessary testing to obtain acceptance of material at an EPA-approved facility. (2) Depending on results of analyses and approval by EPA, the rinse water will either be disposed of in an on-site lagoon or will be disposed

off-site by the waste disposal subcontractor.

Project 90393 GEi Consultants, Inc. June 18, 1992

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TABLE 1- EQUIPMENT AND LOGISTICS FOR SOLVENT EXTRACTION SC Pilot-Scale Testing O'Connor Site Augusta, Maine

Item

Drums of Feed Material to be Processed Potable Water Supply Sanitary Facilities Electric Service Personnel Trailer 10' x 20' (Air Conditioned) Furniture (Tales and/or Desks)

Drinking Water First Aid Kit

Water Chiller (10 GPM) and All Hook-Ups (2) y1,000-gallon Water Storage Tank

Sampling Equipment and Jars Wash Tubs and Brushes (4) 55-gallon Drums Toluene (20) 5-gallon Containers Deionized Water Activated Carbon for Water Treatment Laboratory-grade, Non-phosphate Detergent

(60) Clean 55-gallon Drums (25) Clear Plastic 10-gallon pails (5) Cases of Tyvek Suits, Large and Extra Large, with Hoods and Boots (5) Cases of Safety Gloves, Suitable for Hazardous Waste Respirators and SCBA

Lumber for Feed Prep Area and Polyethylene for Containment Areas Spill Control (Adsorbents)

Hazard Signs

Propane, 400-gallon Storage Tank (5) Nitrogen, 1A Cylinders

Scales Electrical Cords

Steam Cleaner

Notes:

GEI GEI Consultants, Inc. CF CF Systems Corporation

Providing Organization

Northland GEI

Northland CMP

Northland Northland

Northland GEI/CF

CF Northland

CF CF

Northland Northland

CF GEI

Northland Northland

CF CF CF

Northland CF

CF

Northland Northland

CF CF

Northland

Northland Northland Management (earthwork and site preparation subcontractor) CMP Central Maine Power Company

Revision 0 Project 90393

GEI Consultants, Inc. January 31, 1992

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TABLE 2 - SOLVENT EXTRACTION PROCESS CONTROL MEASUREMENTS SC Pilot-Scale Testing O'Connor Site Augusta, Maine

Name/Type

Extractor Pressure Gauge

Extractor Temperature Gauge

Solvent Mass Row Meter

Feed Weight Scale

Extract Weight Scale

Electric Power Meter

Cooling Water Row Meter

Cooling Water Thermometer

Propane "Percent Use" Gauge

Notes:

Location

Atop Extractor

Atop Extractor

Readout Inside control room

Free-standing scale positioned in waste feed area behind CF trailer

Laboratory-type triple beam balance

Outside CF Unit trailer

Discharge line from CF Unit trailer

In influent and effluent water lines

On propane bullet

Rationale

Verify operating conditions

Verify operating conditions

Verify operating conditions

Mass balance calculations

Mass balance calculations

Process Economics

Process Economics

Process Economics

Process Economics

Monftor Frequency

15 min.

15 min.

10 min

Initial feed and all subsequent raffinates at end of

End of pass

Beginning and end of each pass

15 min.

15 min for influent and effluent

Beginning and end of each operating day

Units

psig

psig

lbs.

lbs.

lbs.

kW-hr

GPM

lbs.

psig pounds per square inch gauge pressure lbs pounds kW-hr kilowatts per hour a F degrees Fahrenheit GPM gallons per minute

Revision 0 Project 90393

GEI Consultants, Inc. January 31, 1992

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Source: USGS Topographic Sheets Togus Pond (1982) Approximate Scale (ft) and Augusta (1980), Maine

2,500 5,000 Scale: 1:30,000 (reduced 20% from Original);

Contour nterval = 10 feet

Central Maine Power Company SITEPre-Design Studies Augusta, Maine O'Connor Site LOCATION

Augusta, Maine MAP

4> GEI Consultants, Inc. Project 90393 Jan. 31,1992 Fig. 1

0

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I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

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--

- - ---

- --

--------- ------ ----------------

I

. •· . PTC 90393F7C

FENCE LINE 0 \o----oLEGEND ---~ /

'I ( , INTERPRETED BOUNDARY OF SOIL AND SEDIMENT I : r.

CONTAMINATED WITH GREATER THAN 1· ppm PCBs 0

- - DAI- - - LOCATION AND NUMBER OF DEBRIS AREA (DA) LOCATED BY GEi DURING JUNE AND AUGUST, 1991. SEE SECTION 4.4 IN TEXT. '' . j 0

- TWA I- APPROXIMATE LOCATION '

OF FORMER TRANSfORMER WORK AREA . I ' J'.(

TEST PIT LOCATION FROM PREVIOUS PRE-DESIGN STUDIES II DA14

TEST PIT LOCATION FROM PREVIOUS REMEDIAL INVESTIGATION I ..DA12' I o 0

I Ir;_ .. \\ \ .. .· • J NOTES I Q

I .. .. \ ·.I / ­ fl 1. LOCATIONS AND EXTENTS OF DEBRIS AREAS WERE ESTABLISHED IN THE FIELD I

I 0 I \ ~ .. ,,," " /

/.. \ .. .. . \• USING TAPE AND COMPASS METHODS, AND ARE APPROXIMATE ONLY. "' --~ 0 I2. BASE MAP SOURCE FROM A SITE SURVEY MAP PREPARED BY ACHERON ( \

I' . "'--,...- . _)'~ ENGINEERING SERVICES MAY, 1985 AND A SITE SURVEY MAP PREPARED BY .. \ HOLDEN ENGINEERING JUNE AND AUGUST, 1991. SOURCE OF ADDITIONAL j • . • I .. SITE FEATURES FROM E.C. JORDAN CO. FEASIBILITY STUDY (FS) \ . '\.........._ \ . \

( \

FIGURE 1-3 DATED JUNE, 1989. 0'

\ f"' ,,\ .,

o _:..--- o .:----t" o---- o -;-:....,L_ \ I ':° ..._ ..._:-...,... \ I.. ·(3. ELl"YATIONS REPORTED IN FEET ABOVE NGVD.

;....i~--- I O ----\ Gate \ · " a< __ ..... l° 0 - '

1.,DA7 1/ I -- ' .... , . ) ~·~~- -­-- \ \ ,,,- ' ...... -,·/' --,~, .......

\ \/ --- . ·"...._ '-... I·~

.\ /,- ',' 0~:"110 ./

/..--/. J (' ---­I

\ ( '~ ' 0 I

,.

,,

/ / ) .. .. ... --................_ .. _. \ '\ ' ........ '"~'"',.' 0 I

• .I

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.(.·... --..

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/ /I ,',1 , ,- , \\ \ 0.....• ( - ·./.. ::!' I··/, . _/ ............... \\ ­I / '1.7 ' /17WA JI / . ........_ \ \ -/ r~ /y· / ~7 'DAB I -......... \ I.0 .. .. ..

/ / H / I

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11 . / ,..1\() 00 >- / / / () -.0 ,,:.,( ~\ ... (( ,, ....---- ,

0 0 \ . - · --- I I I'// '"'I\;ol 'I . I I Io\

• . \ E'jl·O :"" \ ( I I . I I

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---.... , .._ - \I 0

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0 8 ',:' ' ',,' ' I '· • ' ' · ·· ·· · \ I10/ "'-..... \\

le§/ ....._I\ .. 1 (DA4 /:: / .. > ··mi..·

I tJ 1 ~-.·UPPER · 1 · I u 1 LAGOON 0

' I ' ' I ~ I TWA I0 0 ---:.....1----f-~ ........ ! \\ \ ........_ I . ·',. / ( I DA 15 I 11\ 1\ ..... -- f I .. '-...\ ,'\ I I I I \ ~ - '1:\. 1' '·

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o D.•':A/ :

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' . 0 '0 'll//: "

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: i .. ( ..

( : ...,.,,,...,.--~ 0 0 ( 1.(;M 1

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r:= o . i' G[ \

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.. i 'O . . ~--'1'---o_Lo !: ·.·. ~):~•\ o o LINE o I 0 o. --,----o o FENCE o I I .. .. ..0 \ '\ oOOo 0 0 . ' 0 _}j- ' \_ )' I ' \

..............._ __________________ ....,. __ .,.....,. __ _,. . . . . i,1 / II _, I ' , . ----------------------,."I_./ ------------------_::________________ __, JI \,....... . ·. . I /.· 1·, .

-------------------- ~-----------------------------------l-----~-----TO AUGUSTA '~

RT. 17 TO ROCKLAND t-1~- ,I I I

---------- -------------------------- - ----- - - - - ----- - ~- - - - ~ - - - - --- - - .------------------....--------+------------.--------------------1 ICentral Maine ·

Power Company Pre-Design Studies DEBRIS AREAS40 ·. 0 40' 80 Augusta, Maine O'Connor Site AND CONTAMINATED

Augusta, MaineI '

SCALE, FEET SOIL AND SEDIMENT •

.' G EI Consultants, Inc. · • Pro·EfCt 90393 Januar 31,1992 Fi 3

, " Ii

,.,

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EPA Approval of Work Plan

Excavation and Son Screening

d)CF Mobizatton

Receipt of cPAH and Lead Results

Solvent Extraction Treatment

Debris Washing

CF Demobizabon

CMP Review of Interim Results

CF Report Preparation

CMP Review

Preparation of Summary Report

QEI In-House Consultant Review

CMP Review

Submittal to EPA

Note: If CF Systems Is not given authorization to mobilize between July 1 and July 31, 1992, CF Systems' mobile demonstration treatment unit will not be available

WEEKS

10 11 12 13 14 1S 16 17 18 19 20 21 22 23 24 25 28 27 28 29 30

mm

10 11 12 13 14 18 18 17 IB 19 20 21 22 23 24 25 28 27 28 29 X

Central Maine Power Company Pre-Design Studies SCHEDULE Augusta, Maine O'Connor Site REQUIREMENTS

Augusta, Maine until the spring of 1993. CD̂ G E I C o n s u l t a n t s , I n c . Project 90393 June 19, 1992 pjg 5

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EPA Approval of Work Plan

Excavation and So* Screening

0)CF Mobilization

Receipt of cPAH and Lead Results

Solvent Extraction Treatment

Debris Washing

CF Demobilization

CMP Review of Interim Results

CF Report Preparation

Chapman and QEIEvaluation of Results

CMP Review

Preparation of Summary Report

QEI In-House Consultant Review

CMP Review

Submittal to EPA

Note: H CF Systems is not given authorization to mobilize between July 1 and July 31, 1002, CF Systems' mobile demonstration treatment unit will not be available until the spring of 1903.

WEEKS

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30

mam

4 5 8 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 28 27 28 29 30

Central Maine Power Company Pre-Design Studies SCHEDULE Augusta, Maine O'Connor Site REQUIREMENTS

Augusta, Maine

o G E I C o n s u l t a n t s , I n c . January 31, 1992 Fig.5Project 90393

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Document SC Pilot-Scale Pre-Design Work Plan Revision 0

Date January 31, 1992

APPENDIX A

Test Pit Logs

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PROJECT LOCATION­

CLIENT CONTRACTOR EQUIPMENT CAPACITY/REACH WEATHER OBSERVED BY CHECKED BY

DEPTH SAMPLE (ft.) NO.

AND TYPE

1.0 554(C,S) 555 (S)

0.8 0.8

SS1 (S) 1.5

2.0

SS2(S) 2.4

3.0 SS6(S) 2.8

4.0 SS7(S) SS3(S) SS9(C,S)

3.9 4.0 4.0

5.0 SS8(S) 5.0

TEST PIT LOG / TP25

PRE-DESIGN STUDIES F. O'CONNOR SITE AUGUSTA. MAINE CENTRAL MAINE POWER H, E. SARGENT CASE MOOEL 5SO BACK-HOE

Partly cloudy. light breeze. 70's" BPS / REP RES

SAMPLE DEPTH (ft.)

PAGE 1 of 1

LOCATION See Figure 2

GROUND EL. 224.A DATUM NGVD fFT. MSI! PROJECT NO. 90393 DATE STARTED/COMPLETED 06/05/91

SOIL DESCRIPTIONS

Fill; 60X fine siAj-angular sand, "40X low plasticity fines, debris (insulator fragments^ I scrap metal), brown "

Fill; "60X fine sub-angular sand, "40X low plasticity fines, debris(insulator fragments I

scrap metal, cable), black, stained

Lean clay(CL); blocky, slightly plastic, grey

Slow seepage at 4.0*

Bottom of pit 5.0'

REMARKS:

1:—SS.» sample location for CLP and/or GEI field screening analysis _££ - CLP laboratory analysis. S = GEI field screening analysis)

PIT DIMENSIONS(FT) LENGTH 20 WIDTH 2

= Aooroximate depth of around water seepage observed in excavation DEPTH 5

* GEI CONSULTANTS, INC.

1

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LOG OF JTP-ll l

224.51SURFACE ELEV. LOCATIONDATE TEST RESULTS

Ul DESCRIPTION

Brown si l ty medium fine sand with some organic material and refuse (ceramic and metal), dry, loose, non-plastic, stained

1—

Grayish-brown clayey sil t . , dry slightly moist, f irm slightly st iff , fractured, slightly plastic

2 ­

'3­

Gray sil ty clay, moist, blocky, fractured, slightly moderate plastic, apparent oil odor, stiff non­4— plastic, blocky fragments increasing with depth

6 ­

'Similar to above but clay is becoming hard, fractures are less frequent and fracture faces have dark gray staining, inside pieces are dry

8 ­

9 ­

COMPLETION DEPTH .

TEST PIT DIMENSION

Tip Bkg = 5.0 Reading © spoils pile 30

Tip reading in pit @ 30

(Perched watertable)

JTP 11.1-05 Spit-Dup HSL

JTP 1:11-06 Spit t ip reading 32 in bucke t @ 6.0'

JTP 111-08 Spit, PAH t ip reading in bucket

70

JTP 111-09 spit Tip reading 300

10. 5 1 DEPTH TO WATER 4-1 3X19 PROJECT NO. 4903-18

JORDAN GORRILL ASSOCIATES CONSULTING ENGINEERS

SHEET NO.

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LOG OF JTP-lll

224.51 DATE */in/«7 SURFACE ELEV. LOCATION

TEST RESULTS CO Ui o aa 4J 0. DESCRIPTION

Sg -J

< 2 >2

co CO

10­ JTP 111-10Similar co above but odor has decreased and sraalL Spi.tsecondary desicratlon cracks have increased

*B0TP @ 10.5'BOTP1 1—

1 2 ­

COMPLETION DEPTH 10. V •DEPTH TO WATER fc-il

TEST PIT DIMENSION 3x19 PROJECT NO. 4903-18

JOROAN GORRILL ASSOCIATES

CONSULTING ENGINEERS SHEET NO. JL°f