ENVIRONMENTALSTRATEGIESCORPORATION

ESCAR3000GI

ENVIRONMENTAL STRATEGIES CORPORATION6521 LEESBURQ PIKE, SUITE 650VIENNA, VIRGINIA 22180703.821'3700

WORK PLAN FORINITIAL RESPONSE MEASURES AND

REMEDIAL INVESTIGATION/FEASIBILITY STUDYNCR HILLSBORO, DELAWARE,

NPL SITE

ENVIRONMENTAL STRATEGIES CORPORATION8521 LEESBDRG PIKE

SUITE 650VIENNA, VIRGINIA 221BO

OCTOBER 8, 1987

/1R300002

Table of ContentsPage

1.0 INTRODUCTION 1

1.1 Project description 11.2 Objectives 21.3 Scope of Work 5

2.0 SITE BACKGROUND 8

2.1 Environmental Setting 82.1.1 Site Location and Study Area 82.1.2 Geology 102.1.3 Hydrogeology 112.1.4 Soils 152.1.5 Surface Hater Hydrology 152.1.6 Biota 152.1.7 Climate 16

2.2 Former Raw Material and Waste Management 17Facilities

3.0 HISTCRV OF RESPONSE ACTIONS AND ENVIRONMENTAL 21ASSESSMENT

3.1 RCRA Closure/Hazardous Waste Investigation 213.2 Groundwater Quality Investigation 24

3.2.1 Groundwater 253.2.2 Surface Water 333.2.3 Soils 35

3.3 Domestic Well Sampling Program 363.4 Magnetic Survey and Test Pit Program 363.5 Other Media 383.6 Characterization of Identified Chemical 38

Substances

4.0 INITIAL RESPONSE MEASURES 43

4.1 New Monitoring Well Installation and Sampling 444.2 Groundwater Recovery 464.3 Groundwater Treatment and Discharge 504.4 System Performance Evaluation 514.5 Recovery and Treatment System Duration 534.6 Data Validation 534.7 Program Schedule 59

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Table of Contents (continued)

5.0 REMEDIAL INVESTIGATION/FEASIBILITY STUDY 61

5.1 Project Management and Planning 615.1.1 Project Organization and staffing 615.1.2 Project Planning 615,1.3 Data Management 635,1.4 Project Reporting 655.1.5 Schedule 65

5.2 Site Investigation 655.2.1 QA/QC Review of Previous Investigations 675,2.2 Land Use/Demographics 675,2.3 Site Topographic Mapping 685.2.4 Waste Characterization 695.2.5 Hydrogeologic Investigation 705.2.6 Soil Vapor Monitoring 755.2.7 Soils Investigation 775.2.8 Surface Water and Stream Sediment Quality 81

Investigation5.2.9 Air Investigation/Monitoring 875.2.10 Biological/Ecological Investigations 89

5.2.10.1 Characterization of the Biological 90Community

5.2.10.2 Analysis of Bioaccumulation 92Potential

5.3 Data Validation and Analysis of RI Data 925.3.1 Data Validation 925.3.2 Data Analysis 935.3.3 Methodology 94

5.4 Endangerment Assessment 955.4.1 Introduction 955.4.2 Information Requirements 985.4.3 Risk Assessment Procedures 102

5.5 Remedial Investigation Report 1035.5.1 General 1035.5.2 Report Format 104

5.6 Feasibility Study 1055.6.1 Purpose 1055.6.2 Scope 105

6.0 REFERENCES 111

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List of Tables:

Table 3-1 Summary of Existing Hell Data 34Table 4-1 Quality Assurance/Quality Control Review 54

GroundwaterTable 4-2 Quality Assurance/Quality Control Review: 58

Surface Water and Soil

Table 5-1 Groundwater Parameters 72Table 5-2 Surface Water and Stream Sediment Sampling 84

LocationsTable 5-3 Surface Water and Stream Sediment Parameters 86

Table C-l Summary of Quarterly Groundwater Appendix CMonitoring Analytical Data

Table C-2 Groundwater Analytical Data - Volatile Appendix COrganics

List of Figures:Figure 2-1 Site Location Map 9Figure 2-2 Site-Specific Geologic Cross-Sections 12Figure 2-3 Locations of Geologic Cross-Sections 13Figure 2-4 Shallow Groundwater Flow 14Figure 2-5 Potential Waste Disposal Locations 18Figure 3-1 Distribution of Total Chromium Concentrations 22

in the Groundwater (April 25, 1985)Figure 3-2 Distribution of Total Chromium Concentrations 23

in the Groundwater (March 7, 1986)Figure 3-3A Distribution of Trichloroethylene in the 26

GroundwaterFigure 3-3B Location of Well MW24A, B, C 28Figure 3-4 Trichloroethylene Concentrations (September 24, 30

1965)Figure 3-5 Trichloroethylene Concentrations (October 9, 31

19B5)Figure 3-C Trichloroethylene Concentrations (November 26, 32

1985)Figure 3-7 Domestic Well Sampling Area 37

Figure 4-1 Monitoring Wells W25 A, B, C 45Figure 4-2 Predicted Water Table Drawdown 48Figure 4-3 Predicted Water Table Elevations 49Figure 4-4 Initial Remedial Action Schedule 60

Figure 5-1 Remedial Investigation Schedule 66Figure 5-2 Groundwater Monitoring Wells 73Figure 5-3 Groundwater Monitoring Wells 74Figure 5-4 Soil Vapor Monitoring Location 76Figure 5-5 Soil Sampling Points - Chromium Source Area 80Figure 5-6 Stream Sampling Locations 83

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List of Appendices:

Appendix A - Sampling ProtocolAppendix B - Groundwater Quality DataAppendix C - 1985 Correspondence Regarding Well PointsAppendix D - The Drawdown CalculationsAppendix E - Air Stripper Influent Concentration

CalculationsAppendix F - Health and Safety PlanAppendix G - Hazardous Substance List

flR300006

II

1.0 INTRODUCTION

1.1 PROJECT DESCRIPTION

; NCR Corporation (NCR) intends to conduct initial response

actions and a Remedial Investigation/Feasibility Study (RI/FS)i consistent with the requirements of the Comprehensive

Environmental Response Compensation and Liability Act (CERCLA) ati1 its former Millsboro, Delaware facility. The RI/FS will be

conducted in accordance with the National Oil and Hazardous

Substances Contingency Plan (NCP) 40 CFR 300.

I Investigation has revealed that the site was previously

owned Liy Dennis Mitchell Industries, Inc. (l)nl), a Pennsylvania

I Corporation owned by Irving and Daniel Berlin. From 1964 until

I about 1967, the company developed and used the manufacturing

' facilities. Industrial activities included plating, the use of

I solvents, the generation of sludges and their storage in on-site

lagoons. Specific industrial activities have been documented by

nterviews with former DMI employees, Reportedly, these activi-

ties included chromium plating and degreasinq. However, it is

I not known if trichloroethylene was used for degreasing. As part

I of the Remedial Investigation, further research will be conducted

to determine the operations of plating and chemicals used by DMI,

I NCR manufactured mechanical cash registers and electronic

calculating equipment at the facility from 1967 through 1980.

I The manufacturing process included a chromium plating operation.

i Plant wastewater was treated in the facility and discharged to

| -i- AR300007

concrete-lined basins located near the northeastern corner of the

main plant building. Sludge from the treatment basins was dis-

posed of in a lagoon near the basins, The lagoon was later

removed and its contents were disposed of in an unlined pit near

the center of the northeastern property line. Subsequently, the

sludge was excavated and removed from the site in accordance with

Resource Conservation and Recovery Act (RCRA) closure require-ments, as administered by the Delaware Department of Natural

Resources and Environmental Control (DNREC). Quarterly ground-

water sampling was initiated in November 1981, as required by

RCRA. In 1983, trichloroethylene (TCE) and other volatile

organic compounds (VOCs) were found in the groundwater, in addi-

tion to elevated chromium levels. Consequently, NCR initiated an

ongoing site investigation to determine the source(s), magnitude,

and possible environmental effects of the groundwater contamina-

tion. Results of the site investigation are summarized in thisWork Plan.

1.2 OBJECTIVES

This Work Plan presents an overall approach to the RI/FS and

the planned technical investigation. The objectives of the

Remedial Investigation are divided into two phases as described

below:Phase I

The objective of Phase I, the Initial Response Measures

(IRM), will be to prevent any continuing off-site migration of

- 2 - AR300008

• the plume of groundwater contamination. Contaminated groundwater

I will be pumped from a recovery v.'ell and treated by air stripping

before being discharged to Iron Branch Creek. This phase will be] undertaken because sufficient data currently exist to support the

implementation of the Phase I action in order to curtail offsiteI migration of contamination. In accordance with the Superfund

I Amendments and Reauthorization Act of 1986 (SARA), all requested

permit applications related to implementing the IRM will be sub-

mitted to the Delaware Department of Natural Resources and

Environmental Control for review of their compatibility with the

state and federal applicable, relevant, and appropriate require-

I ments.A further objective of Phase I wiU be to obtain groundwater

I flow and chemistry data from the residential area northeast of

the former NCR site, A new monitoring well cluster will bei! installed to facilitate this sampling.

The scope of the Phase I work may be slightly changed or

amended depending on field conditions encountered in the perform-

ance of this work. The intention is to establish a degree of

flexibility in this phase, coordinating any such changes in field

activities, sampling, or groundwater recovery with DNREC. Phase

I groundwater recovery is not considered to be a final remedial

action, but rather an initial response measure. Data gathered in

1 Phase I will be useful in determining the most appropriate alter-

native for remedial action.

-3- AR300009

Phase IIPhase II will be initiated after Phase I, and will follow

the guidelines established by the U.S. Environmental Protection

Agency (EPA) for preparation of RI/FS documentation. Specifical-

ly, the Phase II effort will include the following activities for

the RI as needed:

• Compile and evaluate existing data for QA/QC

• Identify data gaps pertaining to the source of contam-ination, and perform additional site characterization inan effort to locate the source of contamination

• Justify a balance point between further investigationsand remedial actions

• Identify possible migration pathways and the resultingimpact on human populations and on important plant andanimal populations

• Obtain data in support of the Initial Response Measuresor the development of remedial action alternatives

• If necessary, develop additional response actionalternatives

Considerable information is currently available to achieve

most of these objectives. Careful review of this information

will be required to determine its usefulness and quality. Past

investigation and site management activities and findings will be

used to complete the RI rapidly.

Specific objectives of each RI field task are discussed

within the appropriate section of the Site Investigation (Section

5.2) of this document. These specific field objectives are based

on the need to fill data deficiencies that remain in the site

characterization and to enhance the planning for appropriate

comprehensive remedial action.

AR3000IO

The objectives of the Feasibility Study portion of the RI/FS ''"'are as follows:

• Develop specific alternatives for remedial action

• Screen developed alternatives for technical applicabil-ity to the site

• Evaluate the alternatives in terms of federal, state, orlocal standards

• Evaluate the alternatives in terms of public health,public welfare, and the environment as well as order-of-magnitude costs

• Present a management plan for remedial action based onthe screened alternatives

1.3 SCOPE OF WORK

To accomplish the objectives of the RI/FS, a scope of work

has been prepared that addresses the objectives described above.

Project Scoping and Planning

• Execute the Initial Response Measures

• Based on the results of previous investigations andresults of the Initial Response Measures, prepare thefinal RI Work Plan

» Complete Project Operation Plan and other plan documentsin preparation for field investigation

Field Investigation and Related Activities

• Continue records review and interviews with former andcurrent plant personnel

• Land Use/Demographics - Obtain information on existingland use and demographics for use in the EndangermentAssessment

- 5 - AR3000I

Topographic Mapping - Prepare photogrammetric mappingfor the site, to be used during RI data collection andassessment and FS alternatives evaluation

Surface Water Investigation - Characterize surface waterand stream sediment quality near the site

Soil Sampling - Collect additional data for use in theEndangerment Assessment and obtain information forremedial management planning

Biological Investigation - Assess the impact of the siteon significant components of the biological community innearby surface waters, as needed

Hydrogeological Investigation - Provide additionalcharacterization of physical and chemical aspects ofgroundwater at the site and surrounding area as needed,and compile all data from the groundwater samplingprogram

Air Investigation - Collect data for use in developmentof safety considerations for onsite RI work. The airprogram will include a contingency plan to implement, ifnecessary, for use in the Endangerment Assessment

Data Analysis - Analyze and evaluate data collectedduring the RI. Validate data collected in previousinvestigations

Endangerment Assessment - Evaluate public health andenvironmental risk, if any, associated with waste sourceareas and exposure routes

If necessary, conduct bench and pilot studies on wastes,soils, and water for treatability and compatibility withpotential remedial system construction materials

Feasibility Study

• Prepare a final FS Work Plan

• Describe proposed responses establishing FeasibilityStudy purpose and objectives

• List and preliminarily screen remedial technologiesbased on site conditions, waste characteristics, andtechnology requirements

• Evaluate the Initial Response Measures and determinewhether the development of alternative remedial measuresis necessary

~ 6 ~ AR3000I2

• If necessary, develop remedial alternatives based onoverall objectives, as well as site-specific objectives

• If necessary, screen applicable remedial alternativesbased on environmental protection, environmentaleffects, technical feasibility, cost, and consistencywith other alternatives

• If necessary, evaluate remedial alternatives based ontechnical, environmental, public health, institutional,and cost factors and consistency with other alternatives

• Prepare the remedial management plan and the FS report

- 7 -

2.0 SITE BACKGROUND

The site background presented below was compiled from

previous site investigation reports for the former NCR facility

in Millsboro, Delaware. Information was provided by secondary

sources, NCR documents, interviews with NCR employees, aerial

photographs, and site visits.

2.1 ENVIRONMENTAL SETTING

2.1.1 Site Location and Study Area

The former NCR facility, currently the First Freedom Center,

is situated near the approximate center of a 58-acre lot on the

northeast side of Mitchell Street in Millsboro, Sussex County,

Delaware. The facility is a large (300,000-sq ft)

semi-rectangular, concrete block structure.

A small stream (Iron Branch) borders the plant property on

the north, beyond which there is an area of low-density housing

and the Town of Millsboro (Figure 2-1). The area northeast of

the site consists of a field currently used for farming. Conrail

railroad tracks separate the former NCR facility from the

field. Iron Branch and an adjacent swamp lie northeast of the

field. Beyond Iron Branch are a low-density residential area

located on a slight topographic rise, and the Indian River. The

area to the southeast is similar, with cultivated fields and a

small stream (Wharton's Branch). The confluence of Iron Branchand Wharton's Branch is due east of the site, beyond which they

- B - AR3000II*

MIII»boro,DnlawareAR3000I5

discharge to the Indian River. Southeast of the site, there are

a few scattered houses and a mobile home dealership between

Mitchell Street and Route 113. West of Route 113 are mostly open

fields and wooded areas.

2.1.2 Geology

The site, located in the Atlantic Coastal Plain

Physiographic Province, is underlain by unconsolidated and semi-

consolidated sediments of Quaternary, Tertiary, Cretaceous, and

possibly Triassic age. These sediments rest on a basement

complex of igneous and metamorphic rock composed of gneiss,

schist, and gabbro, which occurs at a depth of between 4,200 and

7,800 feet: (Sundstrom and Pickett 1969).

The two uppermost series of sedimentary deposits, the

Pleistocene Columbia Group and the Miocene Chesapeake Group, are

of primary interest to this investigation, In the Millsboro

area, the Columbia and the Chesapeake Groups are approximately

100 and 1,000 feet thick, respectively (Sundstrom and Pickett

1969).

The Columbia Group, which is exposed at the site,

unconformably overlies the Chesapeake Group, and is generallycomposed of fine-to-coarse, moderately well-sorted quartz sand,

with considerable amounts of gravel. Thin interbeds of silt are

present in some areas, Sediments of the Columbia Group are

usually yellow to reddish-brown (Sundstrom and Pickett 1969).

Miocene sediments from the Chesapeake group consist of

predominantly gray and bluish-gray silt, containing beds of gray,

fine-to-medium sand and some shell beds (Jordan 1962),

- 1 0 - AR3000I6

Borings at the site for monitoring well installation confirmthat the property is underlain by Cine-to-coarse sand and gravelof the Columbia Group, Clay lenses of up to several feet inthickness were observed in some borings; however, there is nocontinuous confining layer to 100 feet below ground surface(Figures 2-2 and 2-3).

2.1.3 Hydrogeology

Shallow groundwater beneath the site is contained ininterconnected pores within the sand and gravel of the ColumbiaGroup, and is under water table (unconfined) conditions. Thewater table fluctuates in response to seasonal changes in

grcundvatcr recharge, with ar. annual, variation of about 2 to 4feet. The average depth to the water table'at the former NCRfacility is 12 to 13 feet below grade.

Groundwater flows slowly toward areas of lower elevation orlower hydraulic potential. A water table contour map is shown asFigure 2-4. The map indicates that the shallow groundwater is

generally flowing to the northeast. The shallow groundwaterflowing beneath the site discharges to Iron Branch along a zonenortheast of the former NCR facility. A vertical component ofgroundwater flow is indicated by differing water levels observedin well clusters. Further information on the study areahydrogeology can be found in "Groundwater Quality Investigation,"May 1985, prepared by BCM.

AR3000I7

15

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M>rlionlil Belli " 12. ~

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NCR CORPORATIONFormer NCR Facility

Millsboro, DelawareFIGURE 2-2

SITE-SPECIFICGEOLOGIC

Q CROSS SECTIONS

LEOENDMonitoring Will Uocitloni

Qftaoinitir locitloni

FIGURE 2-3Former NCR FacilityLOCATIONS OF v

GEOLOGIC CROSS SECTIONS]'Ullliboro. Dolawir* |ol

AR3000I9

tl -—1 N w«t*r Tibli EliviHon0

FIGURE 2-4

1000 contou), ft. SHALLOWunction of Ofoundw,..b 0 n .GROUNDWATER FLOWno* ffR300020 • NCR

MAY1B8B - 14 - • Misboro, Delaware

2.1.4 Soils

Soils in the study area are classified by the U.S.

Department of Agriculture - Soil Conservation Service (USDA-SCS)

as Evesboro loamy sand, loamy substratum, 0 to 2 percent

slopes. These soils were formed in alluvial sediments consisting

chiefly of silica sand with minor quantities of silt and clay.

The soil is strongly acidic. A representative profile of the

Evesboro Series would consist of a surface layer of dark grayish-

brown loamy sand, and a yellowish-brown'to brown, loose loamy

sand subsoil. The substratum is pale brown loose sand, with

strong-brown sandy loam below. Evesboro soils are excessively

drained soils.

2.1.5 Surface Water Hydrology

The former NCR facility is located within the Iron Branch

Stream Basin (DNREC 1985). Iron Branch is located north of the

facility and flows to the east, discharging into the Indian

River. Wharton's Branch, located southeast of the facility,

joins Iron Branch approximately 3,000 feet east of the facility,

and 1,500 feet from Indian River. The Indian River is*a tidal,

saline estuary that discharges into the Indian River Bay, which

in turn is connected to the Atlantic Ocean.

2.1.6 BiotaNo site-specific information is available on the biota in

the former NCR facility area. Information on the Indian River

Estuary, included here, is available from the Final Environmental

Impact Statement, Delmarva Power and (light Company (1977).

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The Indian River Estuary extends from the coast to a small

dam in Millsboro, Delaware. Tidal input to the estuary dominates

the hydraulic conditions of the estuary. Freshwater input is

low, although freahwater forms inhabit the upper estuary by the

freshwater tributaries.

Nutrient concentrations in the estuary are at high levels

that result from the effects of agricultural drainage and

domestic and industrial discharges into the upper portion ofIndian River.

The marshes and upland vegetation habitats are typical of

coastal plain habitats in the Delmarva Peninsula. Wooded areas

typically consist of pine and mixed hardwoods, The estuary

contains wildlife typical of the mid-Atlantic coastal area.

2.1.7 Climate

The former NCR facility is in the region of a convergence

zone of a number of major storm tracks; this provides a

relatively uniform precipitation of about 45 inches per year

(Delmarva Power and Light 1977). The wettest period typically

occurs in mid-August; the driest period typically occurs in early

May. The annual average monthly temperature for the region is

about 56° F. The warmest period typically occurs in July

(maximum temperatures average near 90° F). Winter temperatures

average from the mid-20s to the upper 40s, Prevailing surface

winds are from the southwest from May through September and from

the northwest from October through April. The annual mean windspeed is 8.9 mph,

- 16 - AR300022

' 2.2 FORMER RAW MATERIAL AND WASTE MANAGEMENT FACILITIES

IInvestigation has revealed that the site was previously

I owned by Dennis Mitchell Industries, Inc. (DMI), a Pennsylvania

Corporation owned by Irving and Daniel Berlin. From 1964 untilabout 1967, the company developed and used the manufacturing

I facilities. Industrial activities included plating, the use of

solvents, the generation of sludges and their storage in on-site

lagoons. Specific industrial activities have been documented by

interviews with former DMI employees. At the Millsboro plant

I site, NCR manufactured cash registers and similar electronic cal-

I culating equipment from 1967 until November 1980, The history of

NCR's waste management at the site is documented in a report

I titled "Hazardous Waste Investigation," prepared by BCM and sub-

mitted to DNREC in October 1981. Based on a review of NCR plant

I plans and records, and discussions with plant employees, the fol-

lowing raw material and waste disposal locations, were identified

(Figure 2-5):1. Onsite industrial wastewater treatment plant

The onsite industrial wastewater treatment plant was

used from 1967 until late 1978 or early 1979. Waste-water was treated in the building (Figure 2-5; location

1A) and transported through underground PVC piping to

the wastewater treatment plant basins (location IB).

Sludges from the wastewater treatment plant basins were

; disposed of onsite in a lagoon located near the basins

, (location 1C). This lagoon was later removed, and its

~1?" RR300023

FIGURE 2-5Former NCR Facility

20° ,ri. POTENTIAL WASTE> - 18 -fl R 3 0 0 0 21< DISPOSAL LOCATIONS

contents and miscellaneous construction and demolition

rubble were disposed of in an unlined pit and covered

(location ID). In September 1981, the contents of the

pit were excavated in accordance with RCRA closure regu-

lations and were removed from the site. It has been

suggested by a former NCR employee that sludges from thewastewater treatment plant basins may also have been

disposed of on the north side of the basins.

2. Underground Cutting Oil Tanks

Two tanks were used to hold cutting oil, one for clean

oil and the other for used oil. The used oil may have

contained trace amounts of trichloroethylene (TCE),

probably resulting from the miscellaneous use of TCE in

cleaning machinery during manufacturing. The tanks,

which were emptied in 1981, remain in place unused. A

few inches of oil remain,

3. Underground Fuel Oil Tank

An underground fuel oil tank remains in place along with

a feed pipe to the building and a pipe running to the

removed aboveground fuel oil tank, The underground tanki| was once accidentally filled with TCE. It has been

• emptied and there remains only a residue of oil and

' water. The residue was sampled in June 1985 and showed

I low concentrations of TCE and tetrachloroethylene (PCE).4. Removed Aboveground Fuel Oil Tank

I Two concrete slabs remain; they served as a base for the

- aboveground fuel oil tank (no known spills or leaks).

~ 1 9 ~ flR300025

-J

5. Drum Storage Area

Fifty five-gallon drums of waste material generated by

the manufacturing process were stored on concrete decks.

6. Removed Aboveground TCE Tank

The removed aboveground TCE tank rested on a concrete

base next to the building. A buried pipe used for

filling the tank ran to the underground fuel oil tank

area. Spills were observed in the filling area.

7. Degreasing Areas

TCE was used for degreasing parts and equipment in two

areas within the plant building. A large open-topped

stainless steel tank was located in an inset in the con-

crete floor (Figure 2-5; location 7A). In addition,

several small degreasing tanks were located in a room

near the eastern corner of the building (location 7B).

TCE was supplied to this area via ceiling-mounted pipes

from the aboveground TCE tank.

8. Underground Gasoline Tanks

These gasoline tanks are currently in use as a pumping

station for vehicles. One is the former aboveground

fuel oil tank, installed as a gasoline tank by the First

Freedom Center.

9. Remove Aboveground Liguified Petroleum Gas Tanks

- 20 - AR300026

3.0 HISTORY OF RESPONSE ACTIONS AND ENVIRONMENTAL ASSESSMENT

I3.1 RCRA CLOSURE/HAZARDOUS WASTE INVESTIGATION

In 1981, in compliance with RCRA closure regulations, all

known hazardous materials were removed from the site and areas of

hazardous material storage were decontaminated. Groundwater

monitoring wells were installed to determine the presence of

plating waste constituents in the groundwater. Post-closure

monitoring was described in a report titled "Excavated Sludge

Disposal Site - Post-Closure Monitoring and Groundwater Quality

Assessment," prepared by BCM in April 1984. Chromium was found

in grou?.dwater at elevated concentrations, "o remediation beyond

the excavation of ' the buried sludge was required. Routine

quarterly groundwater monitoring was implemented.

The quarterly groundwater monitoring of total chromium

concentrations showed levels slightly exceeding the Delaware

State primary drinking water standard of 0.05 mg/1 in wells 4, 9,

10, and 11A. The most recent data (March 7, 1986) indicate

concentrations of 0.075 mg/1, 0.421 mg/1, 0.100 mg/1, and 0.550

mg/1 for wells 4, 9, 10, and HA, respectively. A map depicting

the groundwater total chromium concentrations for these wells on

April 25, 1985, is shown as Figure 3-1. In addition, a map

depicting groundwater total chromium concentrations for all wells

on March 7, 1986, is shown as Figure 3-2. Appendix C includes

tables containing groundwater quality data for total chromium and

hexavalent chromium from the quarterly sampling events from

November 1981 to March 1986.

-"- AR300027

FIGURE 3-1DISTRIBUTION OF TOTAL CHROMIUM

CONCENTRATIONS (MG/L)GROUNDWATER

4/25/86

I _,. 0.550'0.100 ' f\ A<%4 "*™° "M"™ * «"m"1

I i~,

0.075»MU <l

»•*! •\

ae in* «•— fl H."ri\

'ir F"

"t" 6

MTCHQ1 STREET

FIGURE 3-2 x-"DISTRIBUTION OF TOTAL CHROMIUM

CONCENTRATIONS (M&Ab n n n 9 Q- 23 - IN THE GROUNDWATEfP

3/7/B6

' 3.2 GROUNDHATER QUALITY INVESTIGATION

Samples collected in April 1983, as part of the aforemen-

tioned monitoring program, revealed the presence of TCE in the

groundwater. At that time, NCR implemented a groundwater quality

investigation that included the installation, sampling, and anal-

ysis of new monitoring wells; hydraulic conductivity testing;aquifer testing to determine aquifer characteristics; soil

sampling and analysis; and surface water sampling and analysis.

A report describing the results of this investigation was sub-

mitted to the DNREC in April 1984 ("Groundwater Quality

Investigation and Groundwater Quality Management Plan, Interim

Report," prepared by BCM).

Since then, NCR has conducted additional site characteriza-

tion to further define groundwater flow, contaminant transport,

and the extent of TCE and chromium in groundwater and surface

water. In May 1985, a report was submitted to DNREC which

described the results of all site investigation work to date

("Groundwater Quality Investigation," prepared by BCM). Since

May 1985, additional site characterization has been conducted to

determine whether TCE is present in residential wells and to

locate subsurface non-aqueous phase TCE, which is apparently

continuing to be a source of dissolved TCE in groundwater.

The investigations mentioned above were conducted using the

sampling protocol outlined in Appendix A.

Following is a brief summary of the results of these

investigations.

- 24 - AR300030

3.2.1 Groundwater

Groundwater quality investigations at the site have beenconducted since at least 1973. Since the implementation of RCRA

in 1980, significant effort has been expended in characterizingthe hydrogeology of the site. As discussed below, the confirma-

tion of water quality anomalies in some areas has guided inten-sive groundwater quality assessments, which are ongoing today.

In association with applications for water supply wells and

an industrial wastewater treatment permit in about 1973, NCR was

directed (by DNREC) to install five monitoring wells (Wells 1

through 5, Figure 3-3A). The well locations, depths, and manners

of construction were specified by Frank Moorshead (supervisor,

Hater Supply and Subaqueous Lands) in a letter to Mr. J. N,

Holmes of NCR in July 19, 1973, Four more wells (wells 6, 7, 8A,

and 9) were installed in November 1981.

Elevated concentrations of chromium were detected in some of

the wells, at levels up to 0.125 mg/1. In March 1982, four

additional monitoring wells were installed (wells 10, 11, 11A,

and 12, Figure 3-3A). The source of chromium (buried plating

waste sludge) had been removed in accordance with RCRA. A

quarterly groundwater monitoring program was initiated in

November 1981. Since that time, 18 sets of groundwater samples

have been analyzed for chromium. Chromium concentrations have

been variable, with no definitive trend. The maximum concentra-

tion detected was 0.78 mg/1 in well W-11A. Additional wells for

monitoring TCE in groundwater were installed in August and

September 1983 (wells 13 through 16), and in December 1983 (wells v~'1'

- 2 5 - AR30003I

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—————————————————————RGURE 3-3 A——————1/4/84 ' DISTRIBUTION OF (\R300032

- 26 - TRICHLOROETHYLENE (UG/L)IN THE GROUNDWATER

I17A and 17B through 22). A TCE plume was found extending from f~~ )

well W-20 northeast toward Iron Branch (see Figure 3-3A). The

maximum observed TCE concentration as of January 1984 was 115,000

| ug/1, in a sample from well W-20. A fifth set of wells (wells

W8B, WBC, W24A, W24B, and W24C (Figure 3-3B) was installed in

July 1984 to determine (1) the vertical distribution of TCE in

the aquifer and (2) concentrations near Iron Branch. Relativelylow levels of TCE were found at the base of the Columbia

i aquifer. Concentrations near Iron Branch were found up to 113

• ug/1.I Other organic compounds were detected in some of the

I monitoring wells in relatively low concentrations, including:

tr3ns-l,2-dichloroethylene, tetrachlornsthene, chloroform, 1,1,1-I ' trichloroethane, carbon tetrachloride, cis-l,3-dichloropropene, '

methylene chloride, 1,2-dichloroethane, and 1,1-dichloroethane.

I Appendix B includes tables containing the groundwatei quality

i data from the semi-annual sampling events from May 1983 to April

1985.

' A 48-hour aquifer test was performed using a former plant

production well. Drawdown was measured in all monitoring wells

at the site. The test was conducted at a rate of 242 gallons per

minute (gpm). Based on the test results and hydraulic head

measurements, it was estimated that the natural rate of ground-

! water flow is in the range of 4.3 to 19.6 feet per day.i

A group of well points was installed in September 1985 to

help determine the source of TCE (WP1 through WP10). These well

I points were sampled on September 24, 1985, and October 9, 1985, ^

- 27 - AR300033

FIGURE 3-3BJANUARY 19BS LOCATION OF WELL

1000 Trichloroethylene (ug/1) W24A,B,CLEOEND NCR* —— K24A K24B W24C MPsboro, Delaware

"

- 2 8 -

TCE concentrations detected on these dates are shown on Figures3-4 and 3-5, respectively. Based on the September 1985 and

October 1985 sampling results, 5 well points (WP1, 2, 3, 5, and

10) were removed, and 12 new well points were installed to try

and locate the source of dissolved TCE in the groundwater. Well

points were installed in areas where high concentrations of TCEwere observed in previous samples. Correspondence between BCM

and NCR describing this work is contained in Appendix C. Well

point's were sampled again on November 26, 1985. Some concentra-tions greater than 100 mg/1 were detected, but a specific source

was not found (Figure 3-6).

A vertical component of groundwater flow is indicated by the

differing water levels observed in well clusters (BCM May 1985).

Monitoring wells 8A, 8B, and 8C indicate that groundwater has a

downward component in the area of that well, while wells 11A,

11B, 24A, 24B, and 24C indicate an upward component of flow

(Figures 3-3A and 3-3B). The horizontal/vertical anisotropy of

the Columbia Formation deposits is discussed in Section 4.2.2 of

BCM's report "Groundwater Quality Investigation for NCR

Corporation, May 1985." Concentrations of TCE in these wells

have varied significantly over successive sampling events. Well

24C has shown the greatest variation. On August 7, 1984, 113 ppb

of TCE were detected; on February 4, 1985, 0.4 ppb of TCE was

detected; and on the most recent sampling date, April 25, 1985,

no TCE was detected. Levels exceeding 12 ppb were never detected

in deep wells (wells 8C and 11B) closer to the source area,

indicating that the August 1984 level in well 24C may have been

-"- HR300035

anomalous. This question will be investigated further by futureI sampling, ss described in Section 5.2.5.

The public water supply for the Town of Millsboro is ob-

| tained from wells located northeast of the former NCR facility.

Private wells are not permitted within the town limits; however,

numerous wells are in use outside the town limits. A domestic

well sampling program was implemented in May 1985 in order to

monitor domestic wells potentially affected by groundwater con-tamination downgradient from the site (see Section 3.3),

There are two industrial wells, which are not currently in

use, located on the plant property. They have been used in

| recent years for the facility air conditioner and for watering

the plant grounds.

i Table 3-1 summarizes the completion dates and construction

information for the site monitoring wells.

3.2.2 Surface Water

Surface water samples were obtained from Iron Branch inI October 1983, January 1984, and April 1985. The highest TCE

concentration detected occurred in a zone directly downgradient

! from the TCE plume that was delineated in groundwater. The

October 1983 samples were analyzed for TCE and PCE. The highest

TCE concentration detected was 17,000 ug/1. Samples from other

{ locations (between the railroad and Wharton's Branch) were allI

found to contain less than 50 ug/1 of TCE. Trace amounts of PCE

(<5 ug/1) were also detected. The January 1984 surface water

I samples from a denser stream sampling network were analyzed for

- 33 - RR300039

TABLE 3-1

SUrMRY OF EXISTING WILL DATAREMEDIAL INVESTIGATION/FEASIBILITY STUDYNCR CORPORATION! H1HS60RO, DELAWARE SITE

ScreenInstallation Screen Setting Cailnq

Hell Oite (depth, 1n feet) (I.0., Inches) Screen/Cislno Hiterlil

1 N/A N/A 2 N/A2 N/A N/A 2 N/A3 N/A N/A 2 N/A4 N/A N/A 2 N/A5 N/A N/A 2 N/A6 11/25/81 12-22' 1,25 N/A7 11/24/61 14,5-24.5' 3 N/ABA 11/25/81 15-25' 3 N/ABB 07/31/84 40-50' 4 0.03" Slot PVCBC 07/27/84 80-90' 4 0.03" Slot PVC9 11/25/61 12.5-22,5' 3 N/A10 03/09/82 14.5-24,5' 3 N/A11A 03/09/82 14,5-24.5' 3 0,01" Slot PVC11B 09/01/83 50-60' 4 N/A12 03/09/82 li-25' 3 N/A13 03/08/82 14-24' 3 N/A17A 12/05/83 50-60' 4 0.016" Slot PVC17B 12/07/83 10-25' 4 0.0'16" Slot PVCIB 12/07/83 10-25' 4 0.016" Slot PVC19 12/OB/B3 10-25' 4 0,016" Slot PVC20 12/08/63 10-25' 4 0.016" Slot PVC21 12/OB/B3 10-25' 4 0,016" Slot PVC22 12/09/63 10-25' 4 0.016" Slot PVC24A 07/30/84 25-35' 4 0.03" Slot PVC246 07/30/64 55-66' 4 0,03" Slot PVC24C 07/25/64 BO-90' 4 0,03" Slot PVCPiezo-meter A Ofl/30/83 15-25' 2 N/APlezo-iwter B OB/31/63 10-20' 2 N/APiezo-meter C Ofl/31/63 10-20' 2 N/AHP-1 09/23/85 18-20' 2 0,016 Slot Gluvanlzed SteelHP-2 09/23/65 18-20' 2 0.016 Slot Giuvinlzed SteelHP-3 09/24/65 18-20' 2 0,016 Slot Gluvinlzefl SteelHP-4 09/23/65 16-20' 2 0.016 Slot Gluvintzed SteelHP-5 09/23/65 16-20' 2 0.016 Slot Giunnlzed SteelHP-6 09/23/65 16-20' 2 0.016 Slot Gluvinlzed SteelHP-7 09/23/65 IB-20' 2 0.016 Slot Gluvinlzed SteelHP-6 09/24/65 16-20' 2 0,016 Slot Gtuvinlzed SteelHP-9 09/23/65 16-20' 2 0.016 Slot Gtuvinlzed SteelHP-10 09/24/65 16-20' 2 0.016 Slot Gluvinlied SteelHP-11 11/26/65 19.5-22' 2 0.016 Slot Giuvtnlied SteelHP-12 11/2C/65 19,5-22' 2 0.016 Slot Gtuvinlzed SteelHP-13 11/26/85 19,5-22' 2 0.016 Slot Gtuvinlzed SteelHP-14 11/26/65 19.5-22' • 2 0.016 Slot Gluvinlzed SteelHP-15 11/25/65 19.5-22' 2 0.016 Slot Gluvinlzed SteelHP-16 11/26/85 19.5-22' 2 0,016 Slot Siuvintzed SteelHP-17 11/25/65 19.5-22' 2 0.016 Slot Gluvinlzed SteelHP-16 11/25/65 19.5-22' 2 0.016 Slot Gluvtntzed SteelHP-19 11/26/65 19.5-22' 2 0.016 Slot Gluvinlzed SteelHP-20 11/26/65 19,5-22' 2 0,016 Slot Gluvinlzed SteelHP-21 11/26/85 19.5-22' 2 0.016 Slot Gluvinlzed SteelHP-22 11/27/85 19,5-22' 2 0.016 Slot Gluvinlzed Steel

N/A • Information Not AvailableSource: BCM Eastern Inc

purgeable halocarbons. The highest TCE concentration detected

(1,400 ug/1) was obtained from a sampling location slightly

downstream from the location where the highest TCE concentration

was found in October 1983. Additional samples were collected at

the January 1984 sampling locations in April 1985. Results of

these analyses were similar to the January 1984 results.

Iron Branch is not a source of drinking water, but the

Delaware "Water Quality Standards for Streams" (DNREC September

1985) designates protected uses for Iron Branch, which include:

• Industrial water supply

• Primary contact recreation (designated for freshwatersegments only)

• Secondary contact recreation

• Fish, aquatic life, and wildlife

» Agriculture (designated for freshwater segments only)

3.2.3 Soils

Soil samples were obtained with a hand auger near the

northeast corner of the main building and several other locations

(see BCM's April 1984 report). Selected soil samples were

analyzed for TCE, PCE, and 1,1,1-trichloroethane, TCE and PCE

were present in several samples at concentrations up to

5.8 mg/kg.Additional soil samples were collected on June 13, 1985,

from nine borings located near the underground fuel oil tank and

the site of the former aboveground TCE tank. The borings were

drilled using hollow-stem augers and samples were collected using

split spoons. Selected soil samples were analyzed for TCE and

- 35 - AR300041

PCE. The highest TCE and PCE concentrations detected in thesesamples were 1,30 mg/kg and 0.12 mg/Kg, respectively.

While these results seem to indicate low concentrations ofTCE in several locations, they are not indicative of a majorsource of the TCE observed in groundwater.

3.3 DOMESTIC WELL SAMPLING PROGRAM

NCR implemented a domestic well sampling program in May1985. Three sets of groundwater samples have been taken from 10wells in the residential area northeast of the former NCR facil-

ity, across Iron Branch (Figure 3-7). All well samples wereanalyzed for TCE, PCE, and total chromium, To date, neither TCE

nor PCE has been detected. Concentrations of chromium up to0,009 mg/1 were detected in the third set, but were also detectedat 0.009 mg/1 in the trip and field blanks used for QA/QC, thus

indicating that the detected levels may have been a result of labcontamination or instrument error.

3.4 MAGNETIC SURVEY AND TEST PIT PROGRAM

In an effort to locate any previously unknown buried tanksor drums, a magnetic survey was conducted at the former NCRfacility in February 1986. The survey was conducted in an800 x 125-foot area adjacent to the northeastern corner of the

main building. Magnetic anomalies were found which were attri-buted to well casings, roof-drains, and the formerly used buried

NCR CORPORATION

\ .. , —110 «SAV • \ --iq-z?*

pOMESTIC WELLSAMPLING AREA

Landing••—' i

AlFormer NCR Facility

LIQEND* DoiMlllo W«lli

__ Figure 3-7« north

0 ' ' 1000 f*.! "WW1H5

NCR CORPORATIONFormer NCR Facility. Millsboro, DE

DOMESTIC WELLSAMPLING AREA

fuel tank. No unaccounted-for anomalies were found. A report

has been prepared describing the results of the magnetic survey

("Magnetic Survey Report," March 1986, prepared by BCM).

Backhoe pits were excavated near the northeastern corner of

the building in August 1965, in an attempt to find unaccounted-

for buried tanks or pipes. BCM interviewed former NCR employeeswho guided the excavations in the field. Unaccounted-for tanks

and pipes were nob found. Soil samples were not taker, from theseexcavations.

3.5 OTHER MEDIA

Air

No data are available on the air quality of the study

area. Volatilization of compounds into the air from the soil and

groundwater is not expected, since the concentrations in the soil

are below 6 mg/kg and the water table is 12 to 13 feet below

ground level.

Biota

No studies of the biota with respect to bioaccumulation ofwaste constituent compounds have been conducted to date.

3.6 CHARACTERIZATION OF IDENTIFIED CHEMICAL SUBSTANCES

TCE has been detected in groundwater monitoring wells at theNCR site as well as relatively low concentrations of the

following other organic compounds:

Trans-l,2-dichloroethylene >PCEChloroform1,1,1-Trichloroethane1,2-DichloroethaneCarbon tetrachloride*cip-1,3-Dichloropropene*Methylene chloride*1,1-Dichloroethane*

In addition, chromium has been detected at levels exceeding0.050 mg/1 in four monitoring wells,

A cursory look at the characteristics of the above-mentionedcompounds are as follows. This section of the RI document willbe greatly expanded to reflect a comprehensive evaluation ofcomparative toxicity standards and effects.

• TrichloroethyleneColorless, nonflammable, mobile liquid. Characteristic

odor resembling that of chloroform. Practically insol-uble in water; miscible with ether, alcohol, chloro-form, Specific gravity = 1.46; Viscosity = 0.57 cp,

LD50 orally in rats: 4.92 ml/kg.Human Toxicity: Moderate exposures may cause symptomssimilar to alcohol inebriation. Higher concentrationscan have narcotic effect. Severe exposure may result incardiac failure (Merck 1976).

• Trans-1,2-DichloroethyleneColorless, volatile liquid; pleasant odor; insoluble inwater; soluble in alcohol, ether, most organic solvents.Specific gravity = 1.27; Viscosity = 0.41 cp.

AR3000L»5

Human Toxicity: Exposure may result in narcosis and and

irritation of the central nervous system (Documentationof the Threshold Limit Values 1980).Tetrachlorethylene

Colorless, nonflammable liquid; ethereal odor; soluble

in approximately 10,000 vol water; miscible with

alcohol, ether, chloroform, benzene. Specific gravity =

1.63. LD50 orally in mice: 8.85 mg/kg.

Human Toxicity: Narcotic in high concentrations.

Defatting action on skin can lead to dermatitis (Merck1976).

Chloroform

Nonflammable, heavy, very volatile, sweet-tasting

liquid; characteristic odor. Miscible with alcohol,

benzene, ether, carbon tetrachloride, carbon disulfide,

oils. Specific gravity = 1.50; Viscosity = 0.54 cp.

Human Toxicity: Inhalation of large doses may cause

hypotension, respiratory and myocardial depression anddeath (Merck 1976),

1,1,1-Trichloroethane

Colorless liquid; nonflammable; insoluble in water.

Soluble in acetone, benzene, carbon tetrachloride,methanol, ether, Specific gravity = 1.35; Viscosity =

1.2 cp.

Human Toxicity: Narcotic in high concentrations. May

cause cardiac arrest when inhaled massively (Sax 1984),

.40- AR3000l>6

1,2-Dichloroethane

Colorless, heavy liquid; burns with smoky flame;

pleasant odor; sweet taste; vapors are irritating.

Soluble in 120 parts water; miscible with alcohol,

chloroform, ether. Specific gravity = 1,18; Viscosity =

0.68 cp. LD50 in rats: 770 mg/kg.

Human Toxicity: Irritation of the eyes, nose, and

throat followed by dizziness, nausea, vomiting, in-

creasing stupor, cyanosis, rapid pulse, and loss ofconsciousness (Sax 1975).

Carbon Tetrachloride

Colorless, clear, nonflammable, heavy liquid; charac-

teristic cdor. One ml dissolves in 2,000 ml water;

miscible with alcohol, benzene, chloroform, ether, •-•'

carbon disulfide, petroleum ether, oils. Specific

gravity = 1.59; Viscosity = 0.97 cp.

Human Toxiciby: Poisoning by inhalation, ingestion, or

skin absorption. Acute exposure may lead to nausea,

vomiting, diarrhea, headache, stupor, renal damage

leading to anuria and azotemia, liver injury. Can be

fatal. Chronic exposure may lead primarily to liver

damage; kidney injury and visual disturbances also

occur. Skin contact can lead to dermatitis (Merck

1976).Cis-1,3-Dichloropropene

Clear, light straw-colored liquid with a sharp, sweet,

and irritating odor. Specific gravity = 1,22. *""'

- 41 - RR3000U

Human Toxicity: Irritant to eyes and nose(Documentation of the Threshold Limit Values 1970).

• Methylene ChlorideColorless liquid; vapor is not flammable or explosivewhen mixed with air. Soluble in 50 parts water;miscible with alcohol, ether, dimethyl formamide.Specific gravity = 1.33; Viscosity = 0.44 cp. LD50 in

rats: 1.6 ml/kg.Human Toxicity: Narcotic in high concentrations (Merck1976).

• 1,1-DichloroethaneColorless, oil liquid; odor and taste as of chloroform.

Soluble in approximately 200 parts water; miscible withalcohol, Specific gravity = 1.18; Viscosity = 0.68 cp.Human Toxicity: Narcotic in high concentrations (Merck1976).

• Chromium CompoundsProperties vary depending on specific compound.Human Toxicity: Corrosive action on skin and mucousmembranes (Sax 1984).

A more comprehensive characterization of these compounds will beprovided in the Remedial Investigation report.

AR300048

4.0 INITIAL RESPONSE MEASURES

Based on the results of previous site investigations, aninitial response is deemed appropriate in order to investigate

the possibility of underflow beneath Iron Branch, to preventfurther offsite migration of TCE, and to finalize the RI/FS workplan. Initial response actions will be conducted prior to theinitiation of Phase II of the RI/FS. Information obtained fromthe initial response will be further evaluated in the RI/FS, and

the results will be used to plan additional remedial measures ifdeemed necessary by the endangerment assessment.

The objectives of the initial response are as follows:

1. Obtain multi-depth hydraulic head data and groundwater'chemistry data from the residential area northeast ofIron Branch.

2. Recover TCE-bearing groundwater from the northeasternpart of the former NCR facility.

3. Prevent offsite migration of TCE via groundwater.

4. Conduct a preliminary evaluation of recovery andtreatment system effectiveness.

5. Conduct a detailed Quality Assurance/Quality Control(QA/QC) evaluation of existing data.

6. Based on the results of Phase I tasks, finalize thePhase II (RI/FS) work plan.

These objectives will be accomplished by the tasks described

below.

- 43 - AR3000H9

4.1 NEW MONITORING WELL INSTALLATION AND SAMPLING

A new monitoring well cluster (W25 A, B, C) will be

installed in the residential area northeast of Iron Branch Creek

(Figure 4-1). Hell screens will be installed on the top, middle,

and base of the Columbia Group aquifer, in a manner consistentwith the construction of well cluster W-24. The new well cluster

will provide multi-level head data from the northeast side of

Iron Branch which, when combined with head data from other

monitoring wells, will help determine whether the contamination

plume is flowing under Iron Branch. Groundwater chemistry

samples from the new wells will also be used to evaluate the

possibility of underflow, Analytical parameters are shown in

List B, Table 5-1. Wells W25 A, B, and C will also be sampled

during the RI/FS phase of this project, as described in Section

5.2.5 of this work plan.

Depending on the results obtained from Wells W25 A, B, and C

during Phase I, the hydrogeology portion of the RI/FS may be

modified from that described in Section 5.2.5 of this work

plan. Monitoring wells W25 A, B, and C will be installed as soon

as possible after final approval of this work plan. The

assistance of the DNREC may be required in order to obtain legal

authorization to install these wells off of the former NCR

property.

- 4 4 - AR300050

FIGURE 4-1MONITORING WELLS

W25,A,B,CNCR

Mllliboro, DtlawirtAR30005I

4.2 GROUNDHATER RECOVERY

Groundwater will be pumped from a recovery well installed

northeast of the former NCR facility building, downgradient fromthe TCE source area (Figure 4-1). Preliminary recovery well

specifications are as follows: the well will be constructed with10-inch nominal I.D. galvanized steel screen and casing. The

well will be screened in the upper third of the unconfirmed

aquifer, from depths of 15 to 35 feet. Screening of the upper

third of the aquifer is based on existing data, which indicate

that concentrations of TCE in the deep part of the aquifer

(beneath the site) are less than 5 ug/1. Screening of the upper

third of the aquifer will maximize the lateral extent of the

capture zone. It is anticipated that the well will induce

upwelling from the deep part of the aquifer, However, if it is

shown during the initial response measures that significant

levels of TCE are leaving the site in the deep part of the

aquifer, one or more additional recovery wells may be

installed.The effects of groundwater recovery in this location have

been predicted based on aquifer characteristics determined from

an aquifer test conducted in August 1984 on a former plant water

supply well, as described in BCH's report "Groundwater Quality

Investigation," dated May 1985. Water table drawdown was

predicted for various points in the aquifer using the Theis

equation, as explained in Appendix D. Resulting values were then

subtracted from static (nonpumping) water table elevations todetermine the resultant water table configuration,

- 46 -AR300052

Figure 0-2 illustrates water table drawdown that will result

after the recovery well has been pumped at a rate of 200 gpm for

30 days. Under these conditions, the water table is calculated

to drop from 1.5 to 3.0 feet throughout that part of the plant

site in which TCE-bearing groundwater was observed. The

resultant water table configuration and directions of groundwater

flow are shown on Figure 4-3. Following an initial period ofequilibration, the recovery well will capture groundwater flowing

northeastward from the building. The extent of the capture 'zone

has been predicted for steady-state conditions using a method

described by Todd (1959). This area may be considered as the

maximum extent of the capture zone for the assumed pumping rate

and aquifer conditions. The steady-state method indicates a

maximum width of about 400 feet for the well's capture zone at

200 gpm.In actual practice, the extent of the capture zone may

differ somewhat from that shown on Figure 4-3. Periodic natural

recharge events will cause the capture zone to be smaller thanpredicted for steady-state conditions. However, this will be

partially mitigated by the fact that the recovery well will only

partially penetrate the aquifer, thereby creating more drawdownper unit discharge than predicted.

An aquifer test will be performed during the initial part of

the recovery period in order to determine the optimal long-termpumping rate of the recovery well (see Section 4.3).

- 47 - AR300053

Mtunpwxu:0-MOgpmTtnfJMiviT-14,000 f|2/diy

June us? ,„„., Figure 4-2PREDICTED WATER-TABLE

*—1.0 WMiMiWe Driwdgwn Contour (It.)

JU»IIB? . Figure 4-3AIM* MI PREDICTED WATER-TABLE

Mwnpttom: ——5 W.tr.Tit*" .tkx, C«r,touri ELEVATIONS___pr^r Form., NCR Facility

T A R 3 0 0 0 5 S""boro'Dtlawwe

4.3 GROUNDWATER TREATMENT AND DISCHARGE

Water pumped by the recovery well will be conveyed to an air

stripper by buried pipeline. The air stripper will be located

near the unused wastewater treatment facilities, approximately

350-400 feet from the northeastern corner of the former NCR

facility (Figure 4-2). The treated effluent will be discharged

into a drainage ditch which flows into Iron Branch and which was

formerly used for discharging the plant's treated wastewater,

TCE will be removed from the water by countercurrent air

stripping in a packed column. Well water will be admitted to the

top of the column, above a bed of inert packing material. This

packing is highly permeable and has a large surface area. Water

will cascade through the column and spread in thin layers over

the surfaces of the packing material. At the same time, air will

be blown up through the packing material. Upon contact with the

air, organic compounds in the water will volatilize and be

discharged to the atmosphere with the air. The theory and

application of air stripping columns to groundwater contaminationproblems are reviewed by Dyksen and Hess (1982), Love and Eilers

(1982), and Stover (1982).

In a previous version of this plan, preliminary air stripperspecifications were provided based on an assumed influent TCE

concentration of 1,000 ug/1. This concentration was derived from

the distribution observed downgradient from the site in 1984, In

1986, additional data were obtained which suggests that influent

TCE concentrations may be higher (Section 3.2.1), Based on these

-5°- AR300056

new data, a new estimate has been made (Appendix E), which

suggests that the influent concentration may be on the order of

25 mg/1. This concentration would result in a proportionallyhigher rate of air emissions. It is recognized that this may

necessitate an emission treatment system such as granulated

activated carbon filtration. The need for such a system will beevaluated during the initial system performance evaluation. The

preliminary design specifications for the groundwater recovery

and treatment system are detailed in the report "Design

Specifications for a Groundwater Recovery and Treatment System,"

ESC 1987.

4.4 SYSTEM PERFORMANCE EVALUATION

System performance will be monitored on a regular basis

during the recovery period. Monitoring will consist of water

quality analysis of raw water from the recovery well and treated

effluent, as well as periodic water level measurements and

analyses of groundwater from selected monitoring wells asspecified in the following section. The wells to be monitored

will be outlined in the project operation plan.

An aquifer test will be conducted during the first 72 hours

of system operation to establish the optimal long-term recovery

rate. During this test the recovery well will be pumped at a

continuous rate of 200 gpm. Water quality samples will be taken

from the recovery well, air stripper effluent, and selected

monitoring wells at least four times during this 72-hour -•

- 51 - AR300057

period, Results will comprise baseline data for future

determinations of system performance. Following an evaluation of

aquifer test results, the recovery rate may be adjusted to

maximize recovery and treatment effectiveness.

During the remaining period of system operation, laboratory

analysis of the groundwater will be conducted as follows:

1. Raw water from the recovery well and effluent from the

treatment system will be analyzed according to thefollowing schedule:

a. every 2 weeks for the first 2 months of operationb. once monthly for the next 4 months of operationc. quarterly for the duration of operation

2. Head measurements and water quality samples will be

taken from selected monitoring'wells according to the

following schedule:

a, every 2 weeks for the first 4 months of operationb. once monthly for the next 4 months of operationc. quarterly for the duration of operation

If there are substantial recovery rate changes during system

operation, additional samples may be taken. Water quality

samples will be analyzed for purgeable halocarbons (601 Series)

and any metals of concern based upon previous groundwater data.

Results of the sampling described in Step 2a (above) will be

evaluated and will be used to finalize the Phase II RI/FS tasks.

The chromium concentration in the recovered groundwater is

expected to be less than 0.05 mg/1. However, a determination on

the necessity for treating the recovered groundwater to remove

- 52 - AR300058

chromium will be made during the initial system performance

evaluation. The DNREC will be kept apprised of all efforts

regarding this matter. If chromium treatment is necessary,

design specifications for the treatment system will be submitted

for approval before proceeding further with the initial response

measure.

4.5 RECOVERY AND TREATMENT SYSTEM DURATION

TCE concentrations in raw water from the recovery well will

be used as a guide for determining the program endpoint. These

duration concentrations will be evaluated according to criteria

established in the Endangerment Assessment of the RI/FS.

4.6 DATA VALIDATION

An extensive inventory of the data has been conducted; the

results are presented in Tables 4-1 and 4-2. A detailed, sample-

by-sample data validation has been conducted by BCM on all

existing samples. The results of this quality assurance review

will be reviewed by ESC as the first task of the initial response

measures. The results of this validation will determine what

gaps exist in the data and will be used to finalize the Phase II

RI/FS tasks.

AR300059

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Tible 4-1 (continued)

NOTES:Note#l '

N310242 4 Hell No. 2 09/06/B3 Tnchlorethylene, Tetrschlorethene,COD, Cr, Pb, pH, Sp. Cond., Cl,

"310243 Mell No. 4 09/06/83 TMchlorethylene, Tetrachlorethene,COD, Cr, Pb, pH, Sp. Cond., C),

K310244 Hell Ho. 5 09/06/B3 TMchlorethylene, Tetnchlorethenc,COD, Cr, Pb, pH, Sp. Cond., C),

H310245 Nell No. 6 09/06/83 tflchlorethylene, Tetrjchlorethene,COD, Cr, Pb, pH, Sp. Cond., Cl,

M310246 Veil Ho. 6A 09/06/83 -TMchlorethytene, Tetrjchlorethene,COD, Cr, Pb, pH, Sp. Cond., Cl,

N310247 Hell No. 9 09/06/83 T?1chlorethylene, Tetrjchlorethene,COD, Cr, Pb, pH, Sp. Cond., Cl,

H310248 Hell No. 10 09/06/83 Trlchlorethylene, Tetrjchlorethene,COD, Cr, Pb, pH, Sp. Cond., Cl,

11310249 Hell No. HA 09/06/83 THchlorethylene, Tetnchlor-thene,COD, Cr, Pb, pH, Sp. Cond., Cl,

H310251 Well No. 11B 09/06/83 TrYchlorethylene, Tetrjchlorethene,MO, Cr, PI), pH, Sp. Cond., Cl,

N310252 Hell No. 12 09/06/83 Trichlorethylene, Tetrjchlorethene, ...COD, Cr, Pb, pH, Sp. Cond., Cl,

H310253 Hell No. 13 09/06/83 Trlchlorethylene, Tetrjchlorethene,COD, Cr, Pb, pti, Sp. Cond., Cl,

Note *2 CnN400231 Hell No. 2 01/05/84 601'$, Cl, Cy, COO, Cr, Cr*. Ds, Pb

H400232 Hell Ho. 4 01/05/84 Soi'S'ct"?;, COD, Cr, Cr2, Ds, PbNJ00233 Hell Ho. 5 . ' 01/05/84 Soi'J'pflp'., Cond,"400234 Htll#o.6 01/05/84 Cl, Cy, COO, Cr, Cr*i, Ds, Pb, pH,

R400235 Well Ho. 8 01/05/84 eoi-f""'H400236 Hell No. 9 01/05/84 601 '«, Cl, Cy, COD, Cr, Cr+2, DS,

H400237 Hell Ho. 10 01/05/84 K l ' c ' , , Cr, Cr+2, DS,

H400238 Well Ho. 11 . 01/05/84 Mi' 'circ cV Cr, Cr+2, OS,H400239 Hel^Ho. 118 '. 01/05/84 Jgj.f- Sp- Cond-H400240 Hell No. 12 01/05/84 601'i, Cy, Cr, Cr*. Pb, «H.,

Sp. Cond,H400241 Hell No. 13 01/05/84 601' s,H400242 Hell No. 17A 01/05/84 601 'i, Cy, COD, CrH400243 Hell No. 178 01/05/84 601 'i, Cy COD CrN400244 Mell No. 18 01/05/84 601 'iH400245 Mell No. 19 01/05/84 601' iN40D246 Hell No. 20 01/05 84 601'i. Cy, COD. CrN400247 Hell No. 21 01/.-5/B4 601 '5'H40024B Mell No. 22 01/05/84 601' I

- 57 - AR300063

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AR300061*

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4.7 PROGRAM SCHEDULE

Implementation of this program will be in accordance with

the schedule shown on Figure 4-4. The schedule is expressed in

terms of months following EPA/DNREC approval of this plan and theassociated consent order.

- 5 9 - AR300065

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flR300066

r-5.0 REMEDIAL INVESTIGATION/FEASIBILITY STUDY

5.1 PROJECT MANAGEMENT AND PLANNING

5.1.1 Project Organization and Staffing

NCR Key PersonnelProject Manager: William S. Brewer

Contractor (ESC) Key Personnel' Principal-In-Charge: Michael J. Murphy

Chairman and ChiefExecutive Officer

Project Manager: Richard E. FreudenbergerVice President

Senior Technical Reviewer: James P. Bulman

. Project QA/QC Manager: flans Plugge

Safety Manager: James P. Bulman

Field investigations and project support will be provided by

contractor engineers, geologists, safety specialists, biologists,

technicians, and subcontractors who are qualified as required.

5.1.2 Project PlanningThis project has been planned and objectives developed

according to the following guidelines:

Available background data have been reviewed andevaluated with regard to plant operating history andwaste disposal history. The result of these offer's todate is presented in Section 2.2 of this document -"Former Raw Material and Waste Management Facilities."

A Work Plan has been developed to act as an overallremedial investigation control document. The Work Plandescribes technical and management aspects of the

- 6 1 - AR300067

project. It includes technical outlines of tasks,project staffing, scheduling, background, andobjectives.

As part of the project management and planning, the

following documents will be finalized before beginning the field

investigation:

Project Operation Plan (POP)The POP is the control document for all technical project

tasks. The POP will include:'

Background to the project - A summary of the backgroundinformation and previous investigation results containedwithin the Work Plan, and other source documents

Project Objectives - The specific objective of eachproject task .

Specifications for all technical work - Landuse/demographic study, site mapping, surface water andsediment studies, soils sampling and boring, biologicalinvestigation, hydrogeological studies, and airinvestigationProject schedule - Detailed schedule

Sampling protocols - Methodology, chain-of-custody,analytical (see QA Project Plan, ESC 1987)

Data Management - Detailed specifications for theprocessing, management and control of all project data(background research, interviews, field observations,sampling analytical results, chain-of-custody, bench andpilot studies, health and safety information, airmonitoring data, QA/QC reports and plans, and contractsand subcontracts)

The POP is a dynamic document and will be developed and

modified as the project progresses.

- 62 - flR300068

Quality Assurance Project Plan (QAPjP)Describes quality assurance/quality control procedures for

RI. Includes sampling and laboratory procedures, monitoring,rationale, data uses, and data accuracy requirements for futuresampling and analysis. Quality Assurance/Quality Control Programfor the contract laboratories conducting work under this projectare described in the ESC "Quality Assurance Project Plan," June25, 1987.

Health and Safety Plan (HASP)Describes safety procedures to be observed during any onsite

work (See Appendix F for preliminary plan).

Community Relations PlanAs part of the Remedial Investigation/Feasibility Study

(RI/FS) process, and in cooperation with DNREC, NCR intends toimplement an ongoing public awareness and community involvementprogram. The program will be expanded as needed to allow theaffected local citizenry to participate in the process.

Interested citizens, local organizations, and communityleaders will be provided with information on the RI/FS, be givenan opportunity to express concerns and ideas, and be apprised ofRI/FS activities at the former NCR facility.

5.1.3 Data ManagementDetailed data management specifications will be developed

for inclusion in the POP. Highlights of the Data Managementsystem will include the following elements:

- 6 3 - flR300069

Sample Analysis and QA/QC

Analytical procedures will be in accordance with EPA-

approved methodologies unless such methodologies do not exist for

a particular compound. These methodologies are specified with

the project QAPjP. The QAPjP also specifies procedures for

logging field data and establishing sample control (chain-of-

custody) in order to ensure that analytical results reflectactual field conditions.

Document Control

The document control system will include a serial numbering

system allowing for cross-referencing to major topics and RI/FS

tasks. RI/FS documents will be protected from intentional or

accidental destruction or damage by instituting a dual filing

system incorporating (1) a file set for access by the Project

Manager, the Data Processing Coordinator, or appropriate project

personnel, and (2) a separate comprehensive general file. Any

documents that may be designated "proprietary" or otherwise

sensitive will be maintained separately and will be given limited

access.

Health and Safety Records

Careful monitoring of all onsite personnel will be

maintained in accordance with the Project HASP as well as with

contractors' safety policies.

- 6 4 - flR300070

5.1.4 Project Reporting ^

The following reports will be developed from the datacollected during the RI:

Remedial Investigation Report

• The results and conclusions of the RI study andpreliminary remedial technologies will be evaluated.The RI report will include the Endangerment AssessmentReport which evaluates human health and environmentalrisks related to the study area, as needed. Emphasiswill be on pathways of migration and levels oftoxicity.

Feasibility Study Report

• This details remedial alternatives and recommendsappropriate remedial technology, as needed and specifiesrisks associated with various technologies.

5.1.5 Schedule

A detailed project schedule will be included (and presented

graphically) in the Project Operations Plan. Initial estimates

indicate that the data gathering and analysis, the endangerment

assessment, and the RI report will take approximately B months.

A preliminary RI/FS schedule is shown on Figure 5-1. Thisschedule does not include interim reviews by agencies.

5.2 SITE INVESTIGATION

The site investigation will include environmentalcharacterization of the former NCR plant site and surrounding

- 6 5 - RR30007

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FIR300072

area, in accordance with EPA RI/FS guidelines. The site investi-

gation activities described in the following section will provide

data as needed to conduct a comprehensive RI/FS, consistent with

EPA guidelines.

5.2.1 Quality Assurance/Quality Control Review of PreviousInvestigations

Much of the characterization of the NCR site has already

been completed and is described in reports, cited previously,

which were submitted to the DNREC. The data gathered from these

previous investigations will be evaluated according to the QA/QC

criteria established by the RI/FS and the criteria established by

CERCLA in accordance with the NCP. The National Functional

Guidelines for Organic Data Review will be used to evaluate data

gathered from previous investigations.

5.2.2 Land Use/Demographics

Information on existing land use and demographics in thevicinity of the facility is required to fully characterize the

\site and surrounding area and to provide background for an

endangerment assessment.

Information will be collected on existing and projected land

use and demographics in the vicinity of the facility. Most of

the task will be based on secondary data. Sources will include

state agencies, the Sussex County Planning Department, Millsboro,

and the 1980 Census. The required information includes existing

land uses, proposed land uses (based on the County Comprehensive

Plan), existing population and census data, projected population

levels, details on nearby population centers, and county wide

demographics. Because the site is near the Indian River, recrea-

tional activities will be an important component. Delaware's

Inland Bays are an important resource heavily used for boating,

fishing, and other water-related activities. Use of the immedi-

ate area for recreation will be determined. Existing and poten-tial uses of the river and aquifers for water supply will also beincluded.

5.2.3 Site Topographic Happing

A study area topographic map will be produced as specified

below. The map will include the entire study area and willinclude:

2-foot contour intervals (plus spot elevations asneeded)

Scale of 1" = 100'

36-inch by 48-inch format

Polyester stable base material, suitable for reproduc-tion

National Geodetic Vertical Datum

USGS horizontal controlProperty boundaries from existing records

Buildings and waste management facility locations andelevationsSurface waters

Location of above and underground piping, materialtransport systems, and utilities from existing recordsand site observations

Fences and rights-of-way

-«- AR30007l|

5.2.4 Waste Characterization ' 'Chromium wastes were removed from the site during lagoon

closure in 1981. An effort to define the location, volume, and

extent of subsurface non-aqueous phase TCE has been underway

since 1983, and has consisted of the following:

• Interviews with current and former employees

• Interviews with previously employed solvent vendors

• Soil sampling in the suspected TCE source area

• Groundwater sampling in the suspected TCE source area

• Backhoe excavations to locate a possible unaccounted-forsolvent storage tank

• A magnetometer survey northeast of the main building tolocate possible unknown buried tanks or drums

Results of these investigations are documented in the BCM

reports titled "Groundwater Quality Investigation" (May 1985) and

"Magnetic Survey Report, Former Facility, Millsboro, Delaware"

(March 1986), as well as in correspondence and file documents.

Based on these results, it is believed that the TCE observed

in groundwater at the site originated in the vicinity of the

northeast corner of the main building. However, the exact

location of non-aqueous phase TCE in the subsurface and themanner of emplacement remain unknown.

During the Remedial Investigations, efforts will continue todefine the location, extent, and volume of non-aqueous phase TCE

in the subsurface. Each of the tasks listed above may be

reinstituted as new evidence indicates the most likely location

>f the source. The following new tasks will be used:

- e g - flR300075

Soil vapor monitoring, using slam bar and OVA on a gridnortheast of the main building

Soil borings and sampling on a grid northeast of themain building.

5.2.5 Hydrogeologic Investigation

NCR has conducted an extensive groundwater investigation at

the site from 1982 to the present. Several reports (cited above)

have been prepared detailing the results of this investigation,

and have been submitted to the Water Resources Section of the

Delaware DNREC. The results have been summarized in Section 3.0

of this work plan.

Briefly, groundwater samples have been taken from 41

monitoring wells, well points, and water supply wells at and near

the former NCR facility. A TCE plume has been delineated near

the northeastern corner of the main building at the facility.

TCE was found downgradient from the facility as far as Iron

Branch. Domestic wells northeast of Iron Branch were tested for

volatile compounds, but none were found. Chromium has been

observed in four wells (4, 9, 10 and 11A) at levels exceeding

0.05 mg/1 downgradient from the former wastewater treatment

basins and associated former sludge disposal pit. The sludge pit

was excavated in 1981, Chromium concentrations did not exceed

0.05 mg/1 in monitoring wells near Iron Branch or in domesticwells northeast of Iron Branch.

As described in Section 4.1, a new monitoring well cluster

(W25 A, B, C) will be installed northeast of Iron Branch Creek

(see Figure 4-1). The well cluster will provide head and water

- 7 0 - flR300076

quality data from the northeast side of Iron Branch to determinewhether the plume is flowing under Iron Branch. The cluster willbe sampled during Phase I (Initial Response Action) and duringPhase II (RI/FS). Phase I results from well cluster H25 A, B,

and C may prompt a modification of the Phase II hydrogeologicinvestigation. Phase I results will be included in the RI/FSProject Operation Plan. Current plans for the RI/FShydrogeologic investigation are described below.

Groundwater sampling will be performed during the RI/FS toconfirm previous results and determine whether concentrations are

changing over time, Groundwater samples from monitoring wells W-20, W-11A, and H-11B will be analyzed for Group A parameters as

shown on Table 5-1. Groundwater samples from the followingonsite monitoring wells and the offsite monitoring well clusters

(W-24, W-25) will be analyzed for Group B parameters as shown onTable 5-1: Wells 1 to 6, Ba, 8b, 10, 12, 17a, 17b, 18 to 22, WP-

4, WP-6, WP-9, wp-14, WP-15, and WP-22. All the remaining wells

will be sampled for TOX only. Well locations are shown inFigures 5-2 and 5-3. Also, 10 domestic wells downgradient from

the site will be resampled and analyzed for Group B groundwaterparameters (see Figure 3-5). In the event that non-volatileorganic compounds are found in the Group A analyses, all wells

will be considered for resampling and analysis, depending on theconcentrations found. The distribution of compounds detectedwill be used to help determine sources of contamination. The

soils investigation outlined below (Sections 5.2.6 and 5.2.7) maybe changed accordingly, if determined necessary by the results

- 71 - flR300077

TABLE 5-1

GROUNDWATER PARAMETERS

List ACERCLA CLP Organic Hazardous Substance List (CLP/HSL Organic*)Priority Pollutant MetalsHexavalent ChromiumPHSpecific ConductanceHardnessTOX ' '

List BVolatile Organic CompoundsTotal ChromiumHexavalent ChromiumPHSpecific ConductanceHardnessTOX

- 72 -

AR300078

N• lie IMIMI

RQURE6-2Former NCR FacilityGROUNDWATER

MONITORING WELLSMWJboro. Dtlcwirt__

- 73 - AR300079

of the groundwater analyses, to identify potential sources of TCE!

contamination. Well sampling methods and other QA/QC procedures

will be set forth in the site-specific QAPjP. NCR will also

determine if the TOX concentrations can be correlated with the

halogen compounds detected. If a close correlation is indicated,

TOX may be used as an indicator parameter in lieu of the 601 orHSL analytical profiles.

Potentiometric levels will be measured in all wells at the

time of sampling. Well casings have been surveyed to the nearest

0.01 foot. Potentiometric data will be plotted in plan view and

in cross section to verify lateral and vertical hydraulic

gradients. An aquifer test was conducted at the site using a

pi?."*: production well and all monitoring wells. Slug tests have

also been performed. An aquifer test will be conducted on the

Phase I recovery well, as described in Section 4.4 of this work

plan. Hydraulic parameters calculated from this test, and

potentiometric levels from all monitoring wells, will be used to

refine current knowledge of groundwater flow and contaminant

transport.

5.2.6 Soil Vapor Monitoring

A soil vapor investigation will be conducted behind the

former NCR facility in the area shown in Figure 5-4. The

objectives of the soil vapor monitoring are as follows:

I| -'5- AR30008

rDetect and quantify levels of volatile organic compoundsin surface soil vapors

Determine the areal distribution of VOCs in soil vapors

Assuming a correlation between soil vapor levels andgroundwater concentrations, use results to guide theselection of any new monitoring well locations

There is a significant volume of existing groundwater and

soils data which will be used in the system performance

evaluation of the IRM.

Soil vapor monitoring points will be located on a 50-foot

grid, which will be surveyed and staked prior to sampling. Real-

time soil vapor sampling will be conducted using a Photovac 10S50

portable gas chromatograph. Supplemental points will be sampled

in the area(s) of high TCE concentrations, thereby converging on

a detailed characterization of the TCE distribution in soil

vapors. Results of the soil-vapor survey will be used to guide

the soil-sampling investigation described below.

5.2.7 Soils InvestigationSoils have been sampled near the northeastern corner of the

main building at the site, as described in the BCM report"Groundwater Quality Investigation and Groundwater Quality

Management Plan, Interim Report" (April 1984) and summarized in

Section 3.2.3 of this report. Additional soil sampling will be

conducted in an effort to define the location, extent, and volumeof non-aqueous phase TCE, which is presumed to be the source of

dissolved TCE in groundwater. It should be noted that the

purpose of this part of the investigation is not to characterize

- 77 - AR300083

• buried waste, since waste disposal has not occurred near the

I northeastern corner of the building. Soil sampling will beconducted to determine the location of cubsurface non-aqueous

I phase TCE, which may have originated from a spill or leak.

| Nine additional soil borings will be drilled behind the

former NCR building. Six borings will be installed inside the

northeast paved area, two inside the southeast paved area, and

one to the northeast of the former LPG tanks. The locations ofi the borings will in part be conditioned on the results of the

soil vapor investigation.

i The depth of each boring will depend on the soil types

. encountered; however, at least two drilled within the northeast

paved area will extend to the base of the Columbia aquifer. In

i addition, the boring installed to the northeast of the former LPG

tank may extend to the base of the aquifer, if necessary. No

borings will be made through any clay lenses encountered. The

boring will stop at such points and a 6-inch soil sample will be

collected from the top of the lens. The sample will be analyzed

for TCE.

Soil samples will be taken with split spoon samplers.

Samples will be screened visually and with HNu/OVA headspace

analysis in the field. The two samples with the highest HNu/OVA

readings or visually observed contamination will be submitted for

laboratory analysis. If the HNu/OVA readings are at background

levels, with no visually observed contamination present, samples

from the 4 to 5-foot and 9 to 10-foot intervals will be submitted

, j for analyses. Analytical parameters for soil samples will depend

~ 7 8 ~ AR30008I*

on the results of groundwater priority pollutant scans. If non- /'"

I volatile compounds are found in groundwater, soil samples will be

analyzed for the appropriate parameter group. Otherwise, soil

1 samples will be analyzed for VOCs. In the event that high

concentrations of VOCs or other compounds are found, additional

soil sampling may be conducted to further define the subsurface

distribution of VOCs. The need to install additional groundwater

monitoring wells, at multiple levels, in areas of high

concentrations of VOCs will also be evaluated.

The borings extending to the base of the Columbia aquifer

will be retrofitted to serve as monitoring wells. Each will be

screened at shallow, intermediate, and deep intervals, with the

deepest being screened at the baco of: tha aquifer. These wells

will be monitored to determine the presence of non-aqueous phase

TCE at depth. Drilling and soil sampling methods are described

in the QA/QC Project Plan and will be detailed in the Project

Operations Plan.

To characterize fill or sediment adjacent to the wastewater

treatment plant basins (location IB on Figure 2-5), soils will

also be sampled for total chromium and hexavalent chromium on the

northeast and northwest sides of the basins, which are areas of

suspected sludge disposal. Samples will be taken at 37 points on

a 20-foot grid (Figure 5-5). Split-spoon samplers will be used

in borings drilled to the water table.

Samples will be screened visually and with HNu/OVA headspaceanalyses for volatile organics. Samples with observed organic icontamination will be submitted for VOC and total chromium and

- 7 9 - HR300085

WastewaterTreatmentBasins

Fwt.LEQEND

• loll tampllng LeMlton

48300086

NCR CORPORATIONFormer NCR Facility

Mllliboro. D«liwirt• RGURE 5-5

SOIL SAMPLING POINTSCHROMIUM SOURCE

AREA

hexavalent chromium analyses. If no contamination is observed

visually or with RNu/OVA headspace analysis, samples from the

4 to 5-foot and 9 to 10-foot intervals will be submitted for

analyses for VOC's and chromium. Additional soil sampling will

be conducted in areas of high concentrations of chromium if

determined necessary to further delineate the source(s) of

contamination.

5.2.8 Surface Water and Stream Sediment Quality Investigation

As discussed in Section 3.2.2, surface water samples taken

from Iron Branch in October 1983 and January 1984 revealed

elevated concentrations of TCE and trace amounts of PCE. Further

sampling is planned t.n determine the current extent of

contamination in surface water.

Surface water and stream sediment quality will be

investigated in the following study area drainage system

components: Iron Branch, Wharton's Branch, the effluent ditch,

and seep points.The objectives of this component of the Remedial Investigation

are to:

i Establish the chemistry of surface water leaving thestudy area and in nearby streams

• Determine whether war.tu constituents have accumulated instream sediment

• Obtain information to be used in the biologicalinvestigation and the Endangerment Asessment

- 81 - AR300087

Preliminary measurements have been taken to determine theextent of tidal influence in Iron Branch ("Groundwater QualityInvestigation," Hay 1985 BCM). To further define this influence,a series of staff gage measurements will be taken at locations

shown on Figure 5-6, At each of these points, stage measurementswill be taken at least once an hour for a period of not less than24 hours. Periodic, sinusoidal stage fluctuations will be

considered an indication of tidal influence, Tidal fluctuationswill be used to determine the location of surface water and

stream sediment sampling locations. If a tidal influence isshown to exist, an attempt will be made to obtain "low-flow"surface water samples at ebb tide when the samples arecollected.

Surface water samples will be obtained at eight samplingstations, which are shown on Figure 5-6 and described in Table

5-2. Samples will be taken at each location. These locationsmay be modified when the extent of tidal fluctuations is fullyevaluated. At the time of each sampling event, salinity,specific conductance, and stream stage will be recorded at each

station. Flow rates will be estimated at the time of eachsampling using channel dimensions and velocity measurements. Thebank of the stream will be observed for the presence of any seepor discolorations in general. Water samples will be collected inlaboratory-prepared containers, and will be preserved and chilled

for transportation under chain-of-custody documentation.Two sets of surface water samples will be token. If field

conditions permit, one set will be obtained during a period of

~82~ AR300088

FIGURE 5-6STREAM SAMPLING

LOCATIONSAR300089

- 83 - "SB. Milsboro, Deltwira

Table 5-2Surface Hater and Stream Sediment Sampling Locations

SampleName __________Location*____________S-l Iron Branch, upstream of site, between Route 113 and

Mitchell Street

S-2 Iron Branch, near railroad bridge

S-3 Iron Branch, near monitoring wells 24A, B & C

S-4 Iron Branch, about 1,000 feet downstream of S-3

S-5 Iron Branch, near confluence with Wharton's Branch

S-6 Wharton's Branch near confluence with Iron BranchS-7 Wharton's Branch, near railroad bridge

S-8 Indian River, near bridge on Route 20

* Locations may change once tidal fluctuations have beencharacterized

-84- AR300090

high flow and the other during a period of low flow. In the

I first set, one sample (S-5) will be analyzed for List A

parameters (Table 5-3). The remaining samples will be analyzed

I for List B parameters (Table 5-3). In the second set, samples

i from all stations will be analyzed for List B parameters, unlessthe results from the first set indicate that other parameters are

present. In this case, all second set samples will be analyzedfor those parameter groups that were found in the first set.

Sampling Program - Sediment

One set of sediment samples from surface water bodies will

be collected and analyzed to determine the existing accumulation

of waste constituents. Sampling locations are the same as those

described for surface water sampling (see Figure 5-6; Table

5-2). The surface sediments will be collected using a sediment

grab (Ekman, Peterson, Ponar, etc.). Sediment samples will be

visually inspected in the field for composition, and will be

preserved for transport under chain-of-custody to the

laboratory. One stream sediment sample (S-5) will be analyzed

for List A parameters (Table 5-3). The remaining samples will be

analyzed for List B parameters. In the event that non-volatile

organic compounds are found in the S-5 sample, all other stream

sediment samples will be analyzed for non-volatile compounds as

specified in List A, Table 5-3. Sufficient volumes of stream

sediment will be taken to allow for these additional analyses, 'if

necessary. In addition to the analysis for the List A and List

B parameters, a grain size analysis and measurement of percent s>r'

- s s - AR300091

TABLE 5-3

SURFACE HATER AND STREAM SEDIMENT PARAMETERS

List A, :

CERCLA CLP Organic Hazardous Substance List* Dissolved OxygenPriority Pollutant Metals CODTotal Chromium AlkalinityHexavalent Chromium Hardness

. pH SalinitySpecific ConductanceTotal Suspended Solids

List BVolatile Organic Compounds , Dissolved OxygenTotal Chromium CODHexavalent Chromium AlkalinitypH HardnessSpecific Conductance SalinityTotal Suspended Sol Ids

- B6 - HR300092

moisture content and total organic carbon will be conducted onselected sediment samples.

5.2.9 Air Investigation/MonitoringThe objectives of the air quality monitoring program are:

To establish baseline site conditions before workbegins, so proper safety precautions can be taken byonsite personnel

To monitor site conditions during ground disturbance(e.g., soil borings)If necessary, to assess potential offsite migration ofvolatile and particulate emissions. , Implementation ofthis program will be a function of activity-monitoringresults

To accomplish the stated goals, a two-phase monitoring program is

planned.

Phase I: Following establishment of appropriatebaseline conditions, onsite real-time monitoringequipment (HNu, OVA) will be used during fieldactivitiesPhase II: If, during ground disturbance operations, HNureadings are persistently >5 ppm above backgroundlevels, readings will be taken at the study areaboundary at points to be selected in the field. If HNureadings continue to be >5 ppm above background, theContingency Plan will be instituted to assess hazardousair constituents

Safety specialists and other authorized field personnel willobtain HNu or OVA measurements throughout the site and adjacent

areas prior to and during surface disturbance and samplingefforts to establish study area background concentration

- 87 - AR300093

levels. All real-time data will be recorded on air monitoringdata sheets.

An indication of organic levels >5 ppm above background will

be reported directly to the onsite safety officer and the site

manager so they can determine safety equipment requirements. If

HNu results remain >5 ppm above background, all work will stop in

that area and the area will be cleared until the source is deter-

mined. Appropriate respiratory protection will be implemented.During onsite operations, if HNu readings are persistently

>5 ppm above background readings after the above safety

precautions have been taken, additional monitoring at the First

Freedom Center and at the study area downwind boundary will be

conducted at points to be selected in the field. If readings at

the study area boundary are >5 ppm above background, theContingency Plan will be implemented.

If the results of the Phase II air monitoring program show

concentrations at the study area boundary of >5 ppm above

background, a program to assess levels of VOCs in the air will be

conducted. The air monitoring will be conducted using monitoring

stations that are to be established around the working area

perimeter. One station will be upwind of the working area, and

the remaining evenly spaced stations will be downwind. Actual

locations will be based on wind direction rose diagram informa-tion. One personnel pump will be set up at each station. These

pumps will be set up on tripods or other supports so that the

intake is at least 1 meter above ground. The sampler will be

protected from precipitation by a shelter (i.e., umbrella). Each

~88~ AR300091*

pump will be monitoring total VOCs using a Tenax tube system. ••'"''

I Samples will be collected for analysis for an 8-hour period, onceper day, for 3 consecutive days. This will provide 8-hour time-

I weighted average VOC concentration data.

The procedures to be followed when collecting VOCs using

sorbent tubes will be specified in detail in the Project

Operations Plan.

': 5.2.10 Biological/Ecological Investigations

The biological/ecological investigations have been designed

to address NCP criteria (40 CFR300.68) and also meets specific

I NEPA compliance items required by EPA (USEPA 1979, 1985; Council

on Environmental Quality 1970), The objectives of the biologi-I " 1cal/ecological investigation include:

Characterization of the existing biological community inthe vicinity of the study area

Establishment of ecological pathways by which contami-nants can be dispersed

Determination of degree of toxicity or bioaccumulationof TCE in the environment and potential chromium in theenvironment.

In accordance with the RI Guidance Document (USEPA 1975), a

thorough literature search will be performed to identify such

important environmental receptors as endangered species, critical

habitats, and receptors consumed by man. In addition, specific

field data will be collected to augment information gathered from

the literature search.

- 8 9 - AR300095

5.2.10.1 Characterization of the Biological CommunityTask 1 - Vegetation

A vegetation map of the site and immediate surroundings will

be produced based on aerial photography and confirmed by a field

study. The field survey will include a determination of the

types of vegetation, soil, and hydrology. A description of

natural habitat and wildlife usage areas of wetlands and unique

vegetation communities will be identified and discussed. A

deliniation of wetlands will also be included. The potential for

threatened and endangered plant species on the site will be

reviewed.

Task 2 - Aquatic Community

Iron Branch is the closest surface water body to the area of

contamination. In order to characterize the aquatic community of

the creek, a macroinvertebrate survey will be conducted to deter-

mine the extent, bioavailability and toxicity of any contamina-

tion present. As an alternative, an evaluation of whether a

sediment bioassay is more appropriate will be performed. Four to

five stations will be sampled with three to five replicates taken

at each. One sampling station will be at the site of maximum

contamination, one upstream and up to three or more downstream

(Figure 5-6). Organisms will be collected by sediment grab

sampler (Eckman dredge) and other scrapers due to the muck nature

of the substrate. The sediment will be sieved (maximum 1 mm) and

sorted. Organisms will be preserved and identified to at least

family level. Sampling will take place in the fall, if possible,

before operation of the recovery well and discharge to Iron

Branch.

- s o - AR300096

A discussion of the biological community of the Indian RiverI in the vicinity of Millsboro will be based on secondary data.

Sources include reports prepared by the Delaware DNREC, the U.S.

I Army Corps of Engineers, and Delmarva Power and Light Company.

An analysis of the aquatic community will include

discussions of habitat suitability, pollution sensitivity of

' organisms, presence of game species, use of the area for spawning

and nursery, and general health of the community. The generali

health of the aquatic communities at each station' will be

evaluated, as necessary, by analyzing the biological

I characteristics (e.g., species diversity, presence of indicator

l species) along with chemical and physical factors at each site.

Parameters will be quantified and analyzed statistically where

I appropriate. The impact of contaminants from the former NCR site

on the aquatic community of Iron Branch will be evaluated by

I comparing stations upstream of the affected area with downstreami stations.

Task 3 - Terrestrial Wildlife

Use of the site by terrestrial wildlife will be

documented. Potential for threatened and endangered species will

be based on the occurrence of critical habitat. Data sourcesinclude Delaware DNREC, Sussex County, and site observations. No

trapping will be conducted.

Further bioassessment activities will be conducted as

necessary. These additional investigations will be based on the

results of the initial sampling of the biological community.

91 - AR300097

5.2.10.2 Analysis of Bioaccumulation Potential

One of the major concerns in an endangerment assessment is

the potential for movement of the material away from the site and

into the food chain. If a pathway between the environment andhumans exists, an evaluation of the potential for bioaccumulation

will be conducted.

Literature on potential uptake in the terrestrial and

aquatic environments will also be collected as necessary. The

adjacent area is currently farmed. Potential uptake by grain

crops will be included, if a potential exposure is found to

exist. The literature will be reviewed and evaluated in light of

the data collected during the field investigations. If analyses

of the groundwater, surface water, and sediment show significant

levels of contamination and the literature shows significant

potential uptake, detailed body burden analyses will be conducted

on representative organisms from the affected area.

5.3 DATA VALIDATION AND ANALYSIS OF RI DATA

5.3.1 Data Validation

A number of technigues will be used to acquire data during

the Remedial Investigation process. These are summarized below:• Develop background data sources

• Compile and review existing data pertaining to the site• Conduct site visits

• Conduct field investigations

• Conduct bench and pilot studies

-92- AR300098

Samples will be analyzed as specified in the QA/QC Project

Plan. The methodology will be in accordance with EPA-approved

procedures Sample holding times, containers, preservatives (ifneeded), and chain-of-custody will all be in accordance with EPAprocedures.

The analytical results will be subjected to QA/QC review.The QA/QC review emphasizes accuracy, consistency, and represen-tativeness of data.

5.3.2 Data Analysis

The RI/FS will be conducted such that the data collected

will enable the development of an assessment of the risk posed to

human health and the environment of remediation methods, ifnecessary.

To accomplish these goals, the data assembled will be con-

tinuously assessed for quality and completeness. Detailed QA/QC

procedures are specified in the QAPjP to ensure quality of data,

and contingencies will be developed to address any discrepancies(e.g., re-sampling, re-analysis).

Data completeness will be addressed as the project develops

by assessing, during each successive task, the utility of data

previously collected. If there are insufficient data to allow

technically supportable progression to the next phase of investi-

gation (the endangerment assessment or the FS), additional sam-pling or re-analysis may be required.

-93- AR300099

5.3.3 Methodology

The data will be systematically evaluated as the project

develops, with each phase of the field investigation adding to

the data base and aiding in the project's focus and direction.

The planned methodology is as follows:

Data will be compiled on land use and demographics inthe vicinity of the site.

The study area will be mapped to provide an base uponwhich field data can be established.

Historical information will be reviewed includingphotographs, interviews with former plant personnel, andplant records.

Since volatile organic and chromium groundwatercontamination has been established, groundwater samplingand analysis will be conducted to determine whetherthere are any other contaminants of concern (Phase I).

Soil, sediments, surface water, and biotic samples willbe obtained at designated sampling locations. Analysesto be conducted will be determined by the results of thePhase I groundwater sampling analyses.

Further groundwater sampling and analysis will beconducted, if necessary, by data generated from Phase Igroundwater analyses.

Air monitoring, if necessary, will be conductedconcurrently with all phases of the field investigationas a method of establishing proper protection levels foronsite personnel. The air monitoring data will also beused to assess the air route as a migration pathway forcontaminants.

Existing data and results of groundwater sampling andsoil sampling will be used to determine the source ofTCE contamination.

A characterization and inventory of contaminantsrevealed will be conducted to determine quantities andtypes of contaminants onsite and for use in developmentof remediation alternatives.

Bench and pilot studies may be conducted to aid in theevaluation of remedial alternatives, and the design andconstruction of i;he selected alternatives.

- 94 - AR300IOO

Throughout the field investigation phase, information

collected will be continuously evaluated and the project approachfocused for the purpose for establishing sufficiency of data.

Once sufficient data have been collected and risks assessed, a

plan for remediation of these risks will be developed.

5.4 ENDANGERMENT ASSESSMENT

5.4.1 Introduction

As part of the Remedial Investigation, an assessment will be

made of the risks to public health and the environment posed by

current site conditions. The area within which endangerment is

to be addressed will be determined by Remedial Investigation

activities and may include the facili'ty currently in use at the

site. The potential health risks associated with the study area

are based on possible exposure of the public to contamination

migrating offsite either through direct exposure via air or

water, or through bioconcentration via the food chain. No

imminent threat to human health or the environment has been

established by sampling conducted to date (see Section 3.0). Any

potential risks presented by future site usage will be discussed

in the endangerment assessment of the remedial investigation.

The principal risk associated with the study area is the

possibility of long-term contaminant migration. The offsite

migrat'jn of contaminants to the north, via groundwater and

surface water, may present a potential risk to the floodplain

environment and the Indian River. Although no direct human ~

~95" A R 300IOI

health threat has been identified with this pathway, risk to

biological receptors and the potential for resultant bioaccumu-

lation in the food chain will be examined.It has already been established that the groundwater in the

study area is contaminated. Establishing a management programbased solely on the presence of contamination is insufficient to

evaluate risks to human health and the environment. A rational

approach depends on a determination of the level of risk with andwithout remediation and a scientific evaluation of the magnitude

of risk associated with various levels of contamination,

Evaluation of the effectiveness of various alternative remedial

action plans to reach an acceptable level of residual contamina-

tion will be accomplished in the Feasibility Study.

Potential exposures will be evaluated for a given residual

level of contamination, based on an evaluation of the pathways of

exposure and other factors. These exposures will be assessed in

terms of potential dose to the exposed population. Based onconsideration of potential dose, the nature of the exposed

population, and the toxicity of the chemicals of concern, an

assessment of the health risk posed by a given level of residual

contamination will be made. The various alternative remedial

action plans can then be evaluated in terms of the health risk.Adverse environmental impacts will be thoroughly investigated and

evaluated.An alternative concentration limit (ACL) will be proposed if

it can be shown that the constituent(s) will not pose a

substantial present or potential hazard to human health or the

- 96 - AR300I02

environment as long as the alternative concentration limit is notexceeded.

The following factors will be considered, in accordance with

40 CFR 264.93:

1. Potential adverse effects on groundwater quality,

considering:

a. The physical and chemical characteristics of thewaste, including its potential for migration

b. The hydrogeological characteristics of the facilityand surrounding land

c. The quantity of groundwater and the direction ofgroundwater flow

d. The proximity and withdrawal rates of groundwaterusers

e. The current and future uses of groundwater in thearea

f. The existing quality of groundwater, includingother sources of contamination and their cumulativeimpact on the groundwater quality

g. The potential for health risks caused by humanexposure to waste constituents

h. The potential damage to wildlife, crops,vegetation, and physical structures caused byexposure to waste constituents

i. The persistence and permanence of the potentialadverse effects

2. Potential adverse effects on hydraulically connected

surface water quality, considering:

a. The volume and physical and chemical character-istics of the waste

b. The hydrogeolgical characteristics of the facilityand surrounding land

- 97 - W300/03

/*"' 'c. The quantity and quality of groundwater, and thedirection of groundwater flow

d. The patterns of rainfall in the regione. The proximity of the regulated unit to surface

waters

f. The current and future uses of surface waters inthe area and any water quality standardsestablished for those surface waters

g. The potential for health risks caused by humanexposure to waste constituents

h. The potential damage to wildlife, crops,vegetation, and physical structures caused byexposure to waste constituents

i. The persistence and permanence of the potentialadverse effects

5.*.2 Information Regalrementa

| After the data have been collected, this information must be

organized to allow for the following: an assessment of the type

' and potential hazard of the waste; an assessment of the

I mechanisms and rates by which hazardous constituents may migrate

offsite; an identification of receptors that may be affected by

those constituents; and a determination of the severity of the

potential effects. The following discussion describesconsiderations within these categories.

1. Waste Characteristics - The waste characteristics

category contains considerations that examine the

waste's environmental mobility and persistence, and the

I adverse affects it can cause. These considerations are:

\I -"- HR300IOI)

• Toxicity

• Persistence

• Ignitability

• Reactivity

• Corrosivity

• Solubility

• Volatility

• Physical state

Solubility, volatility, and physical state measure the

extent to which mobile wastes can leave the study

area. Toxicity and persistence assess the study area's

potential to cause health-related injuries.

Ignitability, reactivity, and corrosivity evaluate the

possibility of fire, explosion, or similar emergencies.

2. Site Characteristics - The site characteristics category

considers the physical conditions of the site that may

contribute to the potential for offsite migration.These considerations are:

• Climate

• Past site uses

• Existing site uses

• Drainage characteristics

• Surficial soil characteristics• Slope

• Vegetative patterns

- 99 - AR300I05

Ecological systemHaste containment

These data are useful in assessing the potential for

contaminants to exit the site via available pathways.

3. Pathways - This category considers the potential for

migration and attenuation of contaminants. The itemsconsidered are:

• Levels of contamination

1 • Type.(s) of contaminationI • Distance to nearest surface water body

•> Depth to groundwater and vertical permeability

I • Net precipitation

• Groundwater flow rate

I i Food chain

I • Air quality

I Distance to the nearest surface water and depth to

groundwater measure the availability of pollutant

migration routes. Soil permeability, mineralogy,

thickness, etc., measure the potential for contaminantattenuation and ease of migration. Net precipitation

I uses annual precipitation and evapotranspiration to

estimate the amount of leachate a site produces.

I Evidence of contamination, type of contamination, and

• level of contamination evaluate pollution currentlyapparent at the site.

I "10°" AR300I06

4. Receptors - This category considers the proximity of

I human populations and critical environments, the types

of water uses within the area, and the potential for

' future growth. The considerations in this category are:

• Population within reasonable proximity of site

• Distance and direction to drinking water wells

• Distance to offsite buildings• Land uses

• Critical environments

Residential populations and distance to the nearest:

offsite building measure the potential for human

exposure. Distance to the nearest drinking water well

measures the potential for human ingestion of

contaminants should underlying aquifers be polluted.

Land use evaluates the current and anticipated uses of

the surrounding area. The critical environment

determines the potential for adversely affecting

important biological resources and fragile natural

settings.

Soils, surface water, groundwater, air, biota, and

demographic information to be used in the Endangerment Assessment

will be obtained in the Site Investigation described in Section

5.2. A principal objective of the investigation is to obtainsufficient primary data on which the Endangered Assessment will

• be based. Throughout the field (and laboratory) investigation,

- 101 - AR300I07

the data for each environmental medium will be reviewed todetermine whether suitable and sufficient data have beencollected to allow a thorough endangerment assessment.

5.4.3 Risk Assessment ProceduresAfter organization of the site data into manageable

environmental categories, a determination of the potentialenvironmental risks associated with the site will be made. Thisinvolves the application of certain techniques to estimate theleachate generation rate, the ability of the groundwater and

surface water to conduct contaminants, and the potential forexposure of humans or environmental resources to thecontaminants.

The hazard potential of the waste source is determined by

the toxicity associated with the chemicals and the potential forleachate generation and migration. The toxicity associated withthe contaminants will be assessed by sampling and comparing the

results to certain water quality and health criteria, including:

1. RCRA standards for hazardous waste facilities2. Clean Water Act priority pollutant standards3. Safe Drinking Water Act standards4. Applicable literature on toxicology and public health

data for specific chemicals5. Short and long-term toxicity data and bioaccumulation

data6. OSHA standards for concentrations of pollutants in the

workplace >

-102- AR300I08

7. Multimedia environmental goals (MEGs) as defined by theEPA for short-term exposure of human populations orbiota

8. Health Advisories - EPA guidelines on anticipated impactof some synthetic organic compounds

9. State of Delaware Water Quality Standards

10. U.S. EPA Ambient Water Quality Criteria (EPA 440/5-86-001)

Migration potential is determined by evaluating any

containment structures ' and the degree of contact between the

waste sources and the migration pathway. Containment structures

would prevent migration and therefore decrease environmental

risks. Leachate generation can be estimated through the use of a

water balance, which compares precipitation, runoff, and

evaporation to determine infiltration. By estimating leachate

generation, the amount of contaminants that have entered or are

entering the aquifer can be estimated.

5.5 REMEDIAL INVESTIGATION REPORT

5.5.1 General

A Draft Remedial Investigation Report and a Final Remedial

Investigation Report will be prepared at the end of the Remedial

Investigation. The reports will summarize the methods, findings,

and conclusions of the RI, as well as the objectives of the

Feasibility Study.

- 103 - AR300I09

r--5.5.2 Report Format ' i

Executive Summary1.0 Introduction

Site and Project BackgroundAssessment of Environmental ConditionsObjectives

2.0 Environmental Setting3.0 Hydrogeological Investigation and Review of Phase I

RI/FS Initial Response Action

4.0 Surface Water Investigation

5.0 Soils Investigation

6.0 Biological Investigation7.0 Air Investigation

8.0 Waste Characterization

9.0 Bench, and Pilot Studies

10.0 Endangerment Assessment

Potential ReceptorsHealth ImpactsEnvironmental Impacts

11.0 Summary of Findings

ConclusionRecommendation for FSRecommendations for additional studiesReferencesAppendices

Note: A feasibility Study (FS) Work Plan will bedeveloped along with the final RI Report.

-104- A R 3 0 0 I I O

5.6 FEASIBILITY STUDY

5.6.1 Purpose

The purpose of the Feasibility Study (FS) is to develop,

evaluate, and select remediation approaches for existing or

potential future impacts resulting from past or present waste

management activities. The Remedial Investigation (RI) will

serve as the basis for the FS. The FS will serve as preliminary

engineering study to evaluate and select the remedial

alternatives for individual sites as well as for the study area

as a whole.

5.6.2 Scope

The FS'will consist of seven tasks:

Task 1 - Description of the Proposed Responses

Task 2 - Preliminary Remedial Technologies

Task 3 - Development of Alternatives

Task 4 - Initial Screening of Alternatives

Task 5 - Evaluation of Alternatives

Task 6 - Feasibility of Study Report

Task 7 - Additional Requirements

An FS Work Plan detailing the technical approach, project

management, and schedule will be completed simultaneously with

the RI Report. <

- 105 - A R 3 0 0 I I I

Task 1 - Description of the Proposed Responses

Study area background information and a summary of the RI

findings and conclusions will be prepared. A statement of

purpose and objectives and a detailed FS scope of work will be

developed in response to the RI's findings and conclusions.

Task 2 - Preliminary Remedial TechnologiesBased on the RI findings and conclusions and the statement

of purpose established in Task 1, a master list of potentially

feasible remediation technologies will be prepared. The master

list will include both onsite and offsite technologies.

Interaction between different remedial action technologies will

be evaluated. The master list will then be screened to select

remedial 'technologies suitable for the study area.

Task 3 - Development of Alternatives

Preliminary alternatives for management of specific areas

within the site (including exposure rate, if necessary) will be

developed on the results of the remedial investigation and

consideration of the screened preliminary remedial

technologies. These alternatives will take into account the

remedial response objectives, including:

• Public health and environmental concerns

• Findings and conclusions of the RI Study

i Guidance and requirements of the National ContingencyPlan (NCP)

- 106 - A R 3 0 0 I I 2

• Applicable federal and state standards, guidance, andadvisories

Site-specific alternative selection will include, as appropriate:

• Offsite treatment and disposal

• Alternatives that meet or exceed applicable standards orcriteria

• Alternatives that do not achieve relevant standards orcriteria, but will provide suitable levels ofenvironmental protection

• No Action

Preliminary cleanup objectives will be developed in consultationwith EPA and the State.

Task 4 - Initial Screening of Alternatives

The alternatives developed in Task 3 will be screened to

eliminate those alternatives that are infeasible or inappropriate

based on six screening criteria. The criteria are:

• The long-term uncertainties associated with landdisposal

• The persistence, toxicity, mobility, and propensity tobioaccumulate hazardous substances and theirconstituents

• Short- and long-term potential for adverse healtheffects from human exposure

• Long-term maintenance costs

• The potential for future remedial action costs if thealternative remedial action were to fail

• The potential threat to human health and the environmentassociated with excavation, transportation, andredisposal or containment

-107- A R 3 0 0 I I 3

During the course of completing this task or at any point in /--the Feasability Study, should it become apparent that additional

site-specific data are required to screen or evaluate

alternatives (e.g., specific location foundationcharacteristics), that data will be obtained in the most rapid

and efficient manner possible. The goal will be to obtain this

information without delaying the progress of the FeasibilityStudy.

Bench' and pilot studies may be needed to obtain sufficient

data to evaluate remedial alternatives or provide information for

the design and construction of a selected alternative. If bench

and pilot studies are deemed necessary based on work activities,

a separate work plan and schedule will be developed for EPA

approval. This work plan will be submitted early enough to "'

maintain steady progress of the overall Feasibility Study,

Task 5 - Evaluation of Alternatives

A detailed analysis of the alternatives passing the Task 4

initial screening will be conducted. The detailed analysis will

further consider, at a minimum:

• Technical considerations (feasibility, safety, etc.)

• Protection of human health and the environment

• Institutional issues• Cost effectiveness

• Regulatory requirements and guidance

• Consistency with other site-specific remediationalternatives ,

- 108 - A R 3 0 0 I I 4

• Utilization of permanent solutions and alternative. treatment technologies or resource recovery technologies

l Upon completion of the detailed of each alternative, a final

comparison and evaluation of these alternatives and their compo-

nent technologies will be performed.

A summary of alternatives will be prepared highlighting

important differences among alternatives. The following informa-

tion will be included for each alternative:

• Public health information

• Environmental effects

• Technical aspects

• Compliance with applicable technical requirements andenvironmental regulations

• Community effects

• Offsite disposal information

• Institutional factors

• Present worth of total costs

Task 6 - Feasibility Study Report

A Feasibility Study Report will be prepared describing the

evaluation/recommendation process in detail and the results of

this process.

A management plan will be presented including a preliminary

engineering concept of all management program components.

- 109 - AR300M5

Task 7 - Additional RequirementsThe additional tasks required to implement the management

plan, such as post-closure plans, compliance schedules, and long-

term monitoring, will be provided.

A R 3 0 0 I I 6

6.0 REFERENCES

BCM Eastern, Inc. October 1981. Hazardous Waste Investigation,NCR, Millsboro, Delaware.

BCM Eastern Inc. April 1984. Excavated Sludge Disposal SitePost Closure Monitoring and Groundwater Quality Assessment forNCR Corporation.

BCM Eastern Inc. April 1984. Groundwater Quality Investigationand Groundwater Quality Management Plan, Interim Report for NCRCorporation.

BCM Eastern Inc. January 1985. Groundwater Management Programand Groundwater Quality Assessment.

BCM Eastern, Inc. March 1986. Magnetic Survey Report, NCRCorporation Former Facility, Millsboro, Delaware.

Council on Environmental Quality, Executive Office of thePresident. 1978. Regulations for Implementing the ProceduralProvisions of the National Environmental Policy Act 40 CFR Parts1500-1508. Reprint 43 FR 55978-56007.

Delaware Department of Natural Resources and EnvironmentalControl. 1985. Hater Quality Standards for Streams.

Delmarva Power and Light Company. 1977. Final EnvironmentalImpact Statement: Indian River Power Station, Unit 4, Millsboro,Sussex County, Delaware,

Documentation of the Threshold Limit Values, Fourth Edition.1980. American Conference of Governmental Industrial Hygienists,Inc.

Dyksen, V.E., Hess, A.F., Barnes, M.J., and Cline, G.C. 1982.The Use of Aeration to Remove Volatile Organics fromGroundwater. Presented at Annual Conference AHHA, Miami Beach,Florida.

Jordan, R.R. 1962. Stratigraphy of the Sedimentary Rocks ofDelaware. Delaware Geological Survey, Bulletin 9, p. 51.

Love, S.T., Jr., and Eilers, R.G. 1982. Treatment of DrinkingHater Containing Trichloroethylene and Related IndustrialSolvents. AWHA Journal, Vol. 74., No. 8.

Sax, I. 1984. Dangerous Properties of Industrial Materials.

Sax, I. 1975. Dangerous Properties of Industrial Materials.

Stover, E.L. 1982. Removal of Volatile Organics fromContaminated Groundwater. Groundwater Monitoring Review, Fall1 12.

~m~ AR300II7

Sundstrom, R.W., and Pickett, T.E. 1969. The Availability ofGroundwater in Eastern Sussex County, Delaware. Hater ResourcesCenter, University of Delaware.

Theis, C.V. 1935. The Relation between the Lowering of thePiezometric Surface and the Rate and Duration of Discharge of aWell using Groundwater Storage.

Todd, O.K. 1959. Groundwater Hydrology. John Wiley and Sons,Inc., New York.

Trans. Ameri. Geophysical Onion. V. 16 pp. 519-524.

U.S. Environmental Protection Agency. May 1985. Guidance onRemedial Investigation under CERCLA.

'U.S. Environmental Protection Agency. May 1985. Guidance ofFeasibility Studies under CERCLA.

U.S. Environmental Protection Agency. 1979. Implementation ofProcedures on the National Environmental Policy Act 40 CFR Part6. Federal Register 44:118.

Windholz, M., Ed. 1976. The Merck Index. Merck & Co., Inc.,Rahway, N.J.

- 112 -AR300II8

[r

Appendix A - Sampling Protocol

AR300II9

APPENDIX A

SAMPLING PROTOCOL

Samples were obtained from the monitoring well using thefollowing protocol:

1. Static water level in the well was measured using anelectric well probe and tape measure.

2. The volume of standing water contained in the well wascalculated.

3. If well yield permitted, five times the volume of watercontained in the well was pumped with a gasoline-poweredsuction pump. Otherwise, the well was pumped dry threetimes.

4. The bailer used for obtaining the sample was cleanedusing the following procedures:

a. Washed with soap and water and rinsed withdistilled deionized water

b» Washed with a 50 percent methanol, 50 percentdistilled, deionized water solution

c, Washed with distilled, deionized water

5. The first bail of sample retrieved from the well wasdiscarded.

6. The sample was bailed and then filtered using apressurized nitrogen gas filtering device utilizingfilter paper with a 0.45-micron pore size.

7. The sample was placed in an appropriate laboratory-prepared sample container.

8. The bailing and filtering process was continued untilthe required volume of sample was obtained. If thewater was turbid, the filter paper was changed asnecessary. Otherwise, it was changed between wells.

9. The sample containers were then rinsed, labeled, andplaced in a chilled environment for shipment to the BCMlaboratory.

This process was repeated for each well sample.

AR300I20

Appendix B - Groundwater .Quality Data

AR300I2I

IMU Msumui or QUMIHIT tiowoMTn KMITOI.IK w*tTi:/t O»TA /-••

riKST FMCOOH IK* fKUIIII 'HIUSKK),

imlitill Mill Milt Mill* Mil 4 Mill MH< Mil 7' 'III I 9 Nil U »tll U "III

ttMtt.iltr Clnnionl ll/n/ll 1,11 I.H 7,14 7.17 7,2) 1,00 7,77 • I,HIfnl Mn HI liYil) 01/11/92 — —06/30/92 IO.M io,n i.n i.it 7,n t,M I,M I.Moim/92 I,M i.u 7,t2 7,u MI I.M I,D '.'I12/11/12 10,J4 1,12 I.M I.II 7.21 «,12 I,M *.:003/23/n U,H 11,11 n,M 10,74 10,11 ii,M — io,raM/12/81 13.S 12.27 — 11.57 10,« ;|,J1 — II,7406/K/ll II,0» 10.41 — 1,20 «,10 i.M — 8,!'01/04/M II,to I0.2< — t.M S,!7 »,7S — !,««

ll.t) 11,21 — 10,11 10,)! I.S4 ... IO.U

|A" IttMM will) 01/ll/H i,2 1,4 I.I I,) !.l «• 1,1 f,)04/JO/K — 1,7/9,1) — l,t/l,31 (I.M i,7M,07 —OI/il/K — 1,2/1,4 — I.I/i.l <l,7/1,1 l,l/«,4 1,1/6.1 —li/li/lt — 4.7 — S.; ••• 1,201/H/ll ... S,2/4.1 ™ I.I/S.n 1.V1.0 1.1/4,» —M/li/11 »,S S.l ••• «,2 1,1Ot/M/11 — 1.1 — 9.1 !,! t.J01/01/11 ... 1,4 «• 1,0 I,' 9,601/07/M ~. 6.1 — 6,4 9,6 9,904/29/U 4,4 1,4 ... 1,7 9.9 9,6 — — !,3 Vi f.l

IPKiril CoMKIinci'* 01/11/12 U Si 17 161 -ISO ... 201 122i (will 06/.W12 — 107/90 — 177/200 /I90 94/901 04/21/12 — H/«3 ~ 190/161 121/101 IH/110 111/117

I 12/11/92 — H — 100 ... 122,1 01/71/93 — 107/120 — 192/176 Itl/IN 64/6i

01/17/91 N 111 — ID IMoa/io/ii ... M ... M MI 01/04/91 — 117 ••• 141 112 M

01/07/U ... U? ... |W M« M]( M/n/M /« » ... 2vn 121 w? ... — illI rim oi/n/92 \f l« M <4 tt ... u <4i Ok'KI/D! ... It ... 1 — I?I 09/21/H! ... t — I .» 131, 12/15/8! — — — «! ••• t

n),'23/li ~. ISO — 21 71 HOI n/U/Il — 17! ••• 11 M 61

ff/VJ/n ... I — 74 ••• 7141/DI/IM ••• <9 — 411 ... B

1 01/07/91 ••• C — 4 ... (I

01/11/92 17 110 7A 110 123 ••• !" 100Ct/lH/92 — 122 — 2~ — M0!/7|/g? — 100 — 130 — 4(0I:/H/I: — ii — 17; — ;oa43/.1/9) <•• Ill ~ 179 1-7 (3109/K/A1 42 M — Oi09/10/91 — 19) ••> n01/04/M ... 12! ~ II! ... 1201/07/94 ... 91 ••• III ••• H

01/11/9209/12/92

ChlDrimi OH/I) 01/11/9206/30/1?01/21/9212/19/9201/21/9109/li/9109/30/9101/04/9403/07/9401/01/9409/07/9403/K/9!04/21/9!Ot/09/9!11/11/9!01/07/9!

1,711,11

1,1_.

_.

...

...

™

...

3,22

4.11,04,13,19,11.4

_

0,17

1,1_.

_

_

_.

~

9,11 1,72.17

10,2 11,71.2

9,7 !.!

9,41

J,7

VII 4.44

11,0 1,7

•.A ".'. ".'. .".' i" ";!>,01,1

1,24

-«« .. ... "1 "•'. '.".".

AR300I22

II

IFemur Dill Mill Milt Mil f mil i Mil! Mil « mil 7* Mil S MUM Mil 99

Mumi B/I2/M (0,01 O.IH _ (0,09 —

CwilJl 09/11/91 (0,00! (0,009 — (0,009 — — . —

CmoilB, ttlMllnl 11/21/41 (0,0002 (0,0002 (0,0002 0,019 10,002 (0,0002 (0,002 (0.0002i««-ii ni/it/ii 10,001Q1/?l/92 — (0,039li/il/32 ~ (0,01003/2VU — (0,02••"••" (0,1)2

(0,01 <0,WI <0,l»l ','001!0.14J (0.0001 (O.W <H,00!0080 — (MIC(0.02 (U.O: (0,02(0,1)2 (Q.,12a/ro/91 ... (0,02 ••• n.oi <a,c; <o.w

1)1/04/91 ... 0.01 — 1.04) — 0.0103.T7/M — (0,02 — 0,0! — 'iO.C!

Cnruin, lolll mill II/2S'HI 'O.OOiJ (0,0002 (0,0002 9.|2! 0,002 '0,0002 0,031 (0,110021)1/11/92M/10/92M//I/9212/i.wc;1)1/21/91U9/1WI100/JO/S)OI/04/D401/07/31

09/07/Mni/lli/99M/.'s/;9IK/uK/8!ll/il/.ii,11/07/F'

I run l|,;n/9lO.'/II/V

.l r.miKI II/15/B?; 03,'M/Bl

M/\WIK1,'30/91

I C1/3I/BI! 01/0//IU

rtmairnt 03/11/1?, Wtu'r 09/12/13

"l»f OJ/12/A3 .

!'i: 01/12/13. oi,'04/9<

' ur'l miHM by cwiitnict'on n*ilcl>" ifi/dlld Mllylll

— Hot IBllyitt)«.'i • Oiti rijKtM An to iqilp*«tt Nltunetinlourti: KX (Him lie,

—

ill 0!

...'• •

0.023

(0,004

0,001O.OOT(1.U20

(0,01(0,02

'n,n.'

(I.H5?0,9100,009

0,005

(0,002<n,is0,00)0,110

0,0001

0,0)0

(0.005

C.07I0,260.109

•0.02

n.oi

0.079

(0,001

0,002(0.10(O.W

0,001

0,02! 0.0(7)

(11,001

0.0090.010

.-n.o?

n,Mi...

O.C70

...

.(0,011 0012U,00! 0.0070.02<

(0,02

(0,02 ••• ••• ''d I?

(1,001

U.C02

(0.002

0,012 0.024

(0.00!

;;: E

• no; (Do:

...

...

...

...

AR300I23

•All! M (Continue!]

S4"Vl« Inlirln Hitlonil Prlilr; \I >rmirr Oitr Mill Mil 10 Mil 11 Kill 11A HI) 1119 Mil 12 MUD Orintlng mitr Stmdirm f \

I Srouncvur tltvitlani II/2P/8I 7,20((HI Ko<l ill ll»:l) 01/11/91

I 0«/:0/92 7.74 7,79 ... 7,74 ... 6,90 1,4109/21/62 7,10 7,06 ... 7,0912/11/82 7.93 7,62 ... 7,9903'23/fl3 10,01 10,00 — 9,62OS/12/11 11.09 10,97 ... 10,97oe/io/i: 1,99 1,44 ... e.it

6.19 7.716,99 1.13I.M 10,54«.M 11,507,40 1.91

01/04'94 9,29 1.04 ... 1,8! 1,05 1.07 9,5401/07/94 10,22 1,92 — 1,79 1.97 1.91 10,52

ptf" litxwira mini OlVll/ii 6.7 S.i — !,; ' ... 5,1 6.109/M/12 1,1/9.6 5.4/7,3 — 5.5/6,0 — /1.75M/il/4? 5.9/5,6 4.0/5,2 — 5.1/5,9 — 5.7/5,5 —11/15/12 5,5 5,2 — 4,9 — 4.901/M/M 5.4/4.9 5,1/4.8 — 5,2/4,1 ... 5,2/4,75 -•OS/i:/13 5.9 5,5 — 5,3 — 9,909/30/93 5,4 9,4 — 5,2 5,9 5,401/04/94 5.2 9,6 — 5,2 — 5,501/07/94 5,6 5,7 — 5.4 ... 5,406/06/04 5.4 9,7 5,4Oe/07/9< 5,3 5,5 5,103/16/95 6,2 5,5 — 5.3G4/25/96 5.2 5,4 ... 5.1 5,4 6.4 5,5oe/oB/65 5,4 5,6 ... 5,111/11/9! 5,!9 5.69 — 5,5!03/07/K6 4,9 4.9 — 5.4

Specific ComliKtlnci" 01/11/92 229 109 — 159 ••• 97 104lutmei) 06/30/92 213/260 149/140 — 177/200 ... /|00

09/21/12 190/174 121/101 ... 194/170 — 93/9112/15/87 199 120 ... 151 ... |0701/23/31 211/221 121/11! — 141/1)6 ... 112/14701/12/91 1)9 114 — 111 ... |66UB/.'Otoj M Hi — M — KA01/D4/VI IM 9! — 95 — 102OJ/O'/B! IS) 97 — 41,4 ... »,5OC/Oo/94 111 BS 104«/07'M «4 7t Ml);./lu'6j 144,9 10?,C ... 111,1iN/Z'i/tt 1)7,11 109,1) — ll/.ll HI 91 M(ll/da/05 101 n 152.11 ••• 166.0li/U'flS IJV.O 196 — 174lil'flW. 111? 97 — 11

01/1 1/112 12 1216,'Hi/r2 20 4OM/rl/fl? Jfl I!I2/I5/C2 M 1601/23/61 5C (4OVI3/0] It I!OU/30'3! 12 21Ol/OJ/8; 16 UQJ/H7/J4 12 (4

TO 06/30/U 136 122C9/21/92 1/1 n12/15/92 206 10701/23/11 »3 216P5/l7f91 90 71ce/io/ei 99 TO01/04/84 117 5!03/1)7/04 115 60

1241216IB100964012

125134inin118t7H — 9247H

6032

116

dltrltlrt W/ll/6! 5,«l 2.80 — 4,2 — 3,74 J,51OS/K/82 2,04 1,78 — 2,94 — 7.35

ChlorUii ta/l) 01/11/8! 15,0 7,0 ... 10,1 — 9,4 1,106/10/32 !2,Z 8,3 — 11,0K/21/B? 11,1 6,6 — 10,612,'15/K 11.0 5,0 ... 7.3a:/23/63 11,1 9,6 ... 7,2M/I2/M 1.5 6,1 — 7,006(30/13 7,0 4,9 — 7,2 — 5,201/01/84 8,83 4.57 — 5.4601/07/8) 9.1 6,4 ... t,4C6/06H4 6,1 4.7 5,6Oe,'0!'B4 5,5 5,7 5.90!/16'« D * 8.7 ••• 6.5 '04/2S/B! 13.6 • 22.1 ... 1,508/05(1! 7.04 11.1 ... 8.0511/13/85 5,69 11.4 ... 5,2203/07/86 7,9! 12.91 ... 7,4!

B-3 AR300I21*

MILE C'l (Cwillnwd)

Saolt IntlMi Hitloml frliirjrDm WHS Kill 10 Hill h Mil 11* Kill 111 Mil 12 Will) Drlniilni ««ir SurxJtroi

Mionll 05/12/81 (0.03 <0.05 ~ <0,05 — (O.OiC«»M M/I2/U (0.005 (0,005 ~. (0,005 ... (0.005Ckrali*, Winllnt 11/23/81 0.054 -. ~ _. — ... ... 0,05(•9/1) 01/11/92 — 0,049 — 0,133 ~ (0.0002 (0.032

01/30/82 0.1M C.OM — 0,915 ~ (0,00101/21/92 0.131 0,12} ~ 0,64 — (0,00!12/19/82 0,107 0,075 — 0.482/ — (0.010 -.

0.414/0,658 •*•

03/21/tl 0,43 0,12 ••• 0,15a/12/81 0.19 0,02 ~- 0,44 — (0,02oe/:o/« 0,2: 0,07 — 0,21 <o,02 <o,0201/04/85 3,M 0,043 — 0,14 — 0,0]O.V07/M 0,34 0,04 — 0,12 — (0,02

Clralw, Totil fig/1) 11/12/91 0,111 ~ — — — -. ••• 0,0503/11/83 — 0,094 •• 0,130 ... 0,001 0,00206/30/82 0,372 0.1!7 — 0.58!, 000 0,01V09/21/82 0,49 0.1? ... 0,64 — 0,01912/15/92 0,125 0,075 — 0.5M/ -•- 0.02P

0.452/0.780*"

03/23/83 0.4} 0.13 ... 0,3505/S2/83 0,192 0.02 — 0,437 — <0.0206/30/8] 0,24 0,07 — 0,32 (0.02 (0,0201/04/84 0,34 ' 0.043 ••• 0.14 -. <0.0:03/07/84 0,34 9.04 — 0,12 ••• (0.0206/06/84 0,19 0,04 0,2308/07/84 0,21 0.08 0,1503/16/85 0,470 0.167 ••• 0,4t704/25/85 0,2b 0,10 — 0,<1 (0.02 <0.0 (0.0!IW/IU/B5 0,389 0,100 — 0,!!211/13/89 0,2'2 0,055 — 0,42403/07/96 0,421 .1.100 — 0,150

|ror. . 11/28/8103/11/82 0,009 0.017 — 0,003 — 0.006 0,079

lid 03/11/92 — (0.002 — (0,002 — (0.00; (0 002 0,0506/30/92 0,302 0,034 — 0,00409/21/82 0,002 (0.002 — 0,00212/15/82 <0,002 (0,002 — (0,002

• 03/21/83 0,002 0,00305/12/83 (0,10 (0,10 — (0,10 ~ (0,1000/30/93 <0.002 (0,002 — (0,00201/04/84 <0,15 (0.15 — <0,1! ~. (0,1503/07/84 0,004 0,004 — 0,004 ... 0,004

Nffgmte 03/11/92 0,032 0,022 — 0.0!4 ... 0,023 0.12<SMfrcury 05/12/93 0,0007 0,0009 — 0,0012 — 0,0006Nlcktl 05/12/83 — — — — —line OS/12/93 ••• — — — — — . ...Cjnnldt 01/04/94 ~ ~

• fell ftMftd b; COTitrxtlOfl vtfilclt" L*/flllO

M • DHI r»]KtM out tJ NJlniWlt illfunctlonSourti: lot Cntirn Inc.

AR300I25

l!

I I I I I I I I I I I I I I I I (I I I I I I I I I I 1 1 ( 1 1 1 1

I I I I I I I I I I (I I I I I I I I I I (I I I I I I I I ( ( ,

1 ( 1 1 ( 1 1 1 1 1 I I ( I ( ( ( ( ( I II I I t ( I ( I I I I I ( I ( ( ( ( I I It I I I I I ( I I I 1 1 ( 1 1 ( 1 ( 1 1

( 1 1 1 1 1 ( 1 1 1 ( 1 ( 1 1 1 1 1 1( I I I I I ( I I I ( 1 ( 1 1 1 1 ( 1I I I I ( I ( ( ( I I I ( I ( I ( ( |

( I ( I I ( ( I ( I ( I I ( ( ( ( ( I I

I I I ( ( ( 1 1 ( 1

1 ( 1 1 ( 1 1 1 1 1 I I ( I I I I I ( I NI I I I I I I I I I I I ( I I I I ( I I O ,MI I I I I I I I I I I I ( I I I I I I I • i

i i i i i i i i ( i i i ( ( i i <i i i i i i i i ( i i i ( i i ti i i i > i (( < l i ( ( i i i

i i i i i

i i i i i i ii i i i i i i

1 1 1 1 1 ( 1 i (

i i i i i i -.

SSSSS3S3SS 3SSSS3SS3S3 ffi SoRMQMinfntMQxr^ ai-iQMtnmNQvrxtn ui v

53SS28SS83 =SSS2!ScSSSSSs z u

i s * -2 SS Ba I ES I *t ll

i- I ~ SB•5, S S pS a Si

5S Ri!<- n

J S?T. 4 «0 «f

AR300I26

GROUIMTER AMLVTICAL DATAVOLATILE ORGANICS

FIRST FREEDOM CENTER (FORMER NCR FACILITY)MILLSBORO, DELAWARE

Pirmter Units

BCM Lltontory Hunter:

Methyltnt Chlorldi ug/1

l,l-D1cl)1oroetl)we ug/1

Trjni-l,2-0tcfiloroethene ug/1

Chloroform ug/1

11,2-Dlchloroethine ug/1

1,1,1-Trlchloroetruoe ug/1

Cirtjon Tetrichlorlde ug/1

Tdchloroettiyleni ug/1

Dlbronochtoroettiine +/or ug/1I,l,2-Tr1cl>loroeth4ne »/orc1i.l,3-D1chloropropen«

1,1,2,2-Tetrachloroethine ug/V+/or Tetrachloroethene

DiteSmpled

5/13/839/06/831/04/848/07/842/04/854/25/85

5/13/839/06/831/04/848/07/844/25/855/13/839/06/831/04/848/07/844/25/85

5/13/839/06/831/04/848/07/844/25/85

5/13/839/06/831/04/848/07/844/25/85

5/13/839/06/831/04/848/07/844/25/85

5/13/839/06/831/04/848/07/844/25/35

5/13/839/06/831/04/848/07/844/25/85

5/13/839/06/831/04/848/07/842/04/854/25/855/13/839/06/831/04/848/07/844/25/85

5/13/839/06/831/04/848/07/842/04/854/25/85

Hell 1 Hell 2

1004748 N304749

-• (1400231— M13036

(1508101 (1506102

mmm mmm

mmm mrnrn

21. 9

<1.0 O.O... mmm

... ...

mwm <0.1mmm <J,0

O.O O.O... ...

3,2

0,0 0,0... ...

1.0... 0,00,0 o!o

— 2,2

O.O <1,0... ...

0,76,7

(0,1(1,0

O.O O,0<0,1 95,0... ...

— 11,626,3

O.O 0,0... ...... ...— (0.1... 0,00,0 <i,o<01l... <0.1

(1,0

O.O (1,0

Hell 4 Nell '.

0304750 •»... 11310244... 0400233— (141X37

0508097 0501103

... ...

IM. mmm

23.13.0

O.O 0(1)... —.mmm mmm

mmm <(),'••• o.oo.o o.o

1.3H. <1 0

10,4 1.2

2.0... 0,0O.O (1,0

1.3

O,0 O.O

... <o,i•*• 0,0o.o o.o

(0.10.9

O.O 0.077,7 -.-••• (C,immm ?'*sin43,2 l.i... ...

••• mmm

mmm t f

mmm t J

o.o <:',.•(0.1 ...

(0 .... , < • t0,0 <!,,;

Nell 6 fell 8A Hell 38

11310245 0310246— 0400275— 0413038 MIJC39

0508104 ftSOfllOS 0508106

... ... »•

... ... ...I/. 8

••• OiO O»0O.9 O.O O.O

.-,... ... ...— '0,1 •«*-• <1,0 <I,0<1.0 <1,0 O.O

125... 7,6 O,00.0 88,3 O.O

6.1O.J O,0

1,1 4,5 2,0

0.9O,0 '1.00,0 o.n 0,0

1,11.7 0,0

0.0 0.0 0,0

10,1... <l,o .,'1,0O.O (1.0 '1,0... ... ...«U 1,500... 1,400

J38 1,2... 1,1?6 8,40.0 305 '.1,0... ... ' ...... ... „•••— (0,1 —— (1,0 O.U<1,0 <1,0 <1,0

0,50,0 O,077,5 <0,1

0.0 0,0 O,0

AR300I27

Ntll 8C

...

mmm

M13040

1506107

mmm

mmm

<1,0<i.O—.......0:0o.o......o.oo.omm.

...

o.o<:.0

...<1,0<1,0

._

...<' Q<i,o

...o.oo.o...mmm

mmm

1.13,4O.O......

...

',1.0

...o.oo!o

B-6

TABLE C-2 (Continued)

Pir meter

flCM litontory Oirter:

Hethylene Chloride

1,1-Dlchloroethine

Tr«ns-l,2-0kh1oroethene

Ci'ilCli'0'Giill

1,2-Dichloroethane

1,1,1-Trlchloroethaie

Cirbon Tetrichlorlde

Trlchtoroethylene

Dlbronothloroethsne */or1,1,2-Trlchloroettune */ords-l,3-D1chloropropene

I,l,2,2-Tetr:ch1oroettunt+/or Tetrjchloroettiene

OiteUnits Smpljd

5/13/839/06/831/04/848/07/842/04/85,4/25/BS

ug/1 5/13/839/06/831/01/848/07/844/25/85

ug/1 5/13/839/06/831/04/848/07/844/25/85

ug/1 5/13/839/06/831/04/848/07/844/25/85

ug/1 5/13/529/06/831/04/848/07/844/2:/a5

ug/1 5/13/839/06/831/04/848/07/844/25/85

ug/1 5/13/83o/nfi/Ri7/UD/DJ1/04/848/07/844/25/85

ug/1 5/13/83nintiQ')vfUO/uJi/04/d48/07/844/25/85

ug/1 5/13/839/06/831/04/848/07/842/04/854/25/85

ug/1 5/13/839/06/831/04/848/07/844/25/85

ug/1 5/13/839/06/831/04/848/07/842/04/854/25/85

Hell 9

0304751

04002360413041

0508098

...

"7.4o.oo.o

<0 l0.0o.o

542.5

30.4

4,7q.oi .3

1.6O.O(1,0

0,8O.OO.O

tO.l(1.0O.O

500...

48145,1...

51.9

<i!oo.o<0,1<p l0.0o.o

Nell 10

0304752

040C2370413042

0508099

"io.iO.O0.0

(0,1O.OO.O

1,10,01,2

2,1O.O0.0

1,20,00.0

0,7O.OO.O

<0 1<i!o0.0

68.7...

30.59,3

...

23,9

o!o0.0

<0,1

(0 1<i!o"o.o

Nell 11A

0304753N31024904002380413043

0508100

9,3<i!o

<0,1O,00,0

8.83,4

17,7

3.70.01,2

1,40,00,0

1.01.10.0

<0 1o!oO.O4704087.971.643.0125

<i!oo.o(0,1

18,90,02,40,0

Nell 118

031025104002390413044

0508108

1340.0O.O

<0,10.0o.o

<Q 10.0o.o

0,80.0l.S

2.00,0O.O

<0.10.00,0

<0 1o!o0,0...<2,5»jOtl11,84.71.3

(0.1(1,00.0...

<Q,1o.o1,80,0

HellU-12

0304754031025804002400413045

0508109

8,0O.O0.0

<0.1O,0O.O

54,369,610,354,3

1.70.0J.I

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2,4002,0001,400

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1,190

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AR300I28B-7

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... • dot mil,viid!our>;i: BCH Entirn Inc.

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5/13/631/06/631/04/M1/07/142/04/154/25/K

5/13/131/06/131/04/M1/07/844/25/15

5/13/131/06/631/04/84t/07/M4/25/15

5/13/139/06/131/04/MB/07/644/15/15

4/13/839/06/331/M/B4A/07/644/zs/K5/13/639/06/831/04/818/07/844/25/W

5/I3/B39/06/831/04/B4(1/07/644/25/655/13/839/06/831/04/648/07/644/25/65

5/13/839/06/831/04/648/07/942/04/B54/25/B5

5/I3/B39/06/B31/04/648/07/844/25/B5

S/13/B31/04/831/04/B48/07/542/04/854/25/85

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[i. 'r:u

I

, , .Appendix C - 1985 Correspondence Regarding Hell PoiritB.: ;

if ' •• •'.'.' ' '• ' .- '•

AR300I30

LBCMJ BCM Eastern Inc.Engineer], Planners and Scientists

' One Plymouth Meeting • Plymouth Meeting, PA 19462 • Phone: (215) 825-3800

September 24, 1985

Dr. William S. Brewer, ManagerCorporate Safety and Industrial HygieneCorporate Personnel ResourcesNCR CorporationWorld HeadquartersDayton, OH 45479

Subject: TCE Source DeterminationMillsboro, Delaware ProjectBCM Project No. 00-4529-10

Dear Bill:

As part of the Investigation of groundwater quality at and hear NCR'sformer Millsboro plant, BCM has attempted to locate the source of dissol-ved TCE Identified In the site's groundwater. The source Is suspected tobe non-aqueous phase. TCE which is retained in soil near the northeasterncorner of the main building,

BCM drilled soM borings In the suspected source area, but soil samplesfailed to locate any non-aqueous phase TCE in the soil. BCM has also ob-served the excavation of several pits at the suspected location of a bur-ied TCE storage tank. No such tank was found, and soil in the excavationsdid not contain significant TCE levels.

In continuing the search for the TCE source, BCM intends to focus on TCEconcentrations in groundwater, rather than In soil. We believe that thiswill enable us to close in on the source, but not require that we find aneedle in a haystack.

Therefore, It is proposed that five to ten well points be installed In thesuspected source area. HNu measurements will be made In each well pointsoon after Installation and development, to guide the location of subse-quent points. An attempt will be made to locate the points In such amanner as to close in on the area with maximum TCE levels. Groundwatersamples will be taken after all well points are installed.Hell points will be constructed with 2-inch galvanized screen and casing.Since they are only to be sampled once, for source delineation, the,v willnot be packed or grouted. Soil samples will not be taken during instal-lation.

• A Member Firm olBetz»Converse»MLirdoch«lno, ———————KM /IR300I3I

NCR Corporation - 2 - September 24, 1985

Depending on the results of this effort, subsequent action Is expected toInclude one or more of the following:

A. Install additional well points, as required to further closeIn on the TCE source.

B. If certainty 1s achieved regarding the TCE source, drilltest borings and sample soil to confirm the presence of non-aqueous phase TCE, and to assist planning of appropriateremedial measures. Also install permanent monitoring wells,1f necessary.

C. If certainty is achieved regarding the TCE source, Implementa source elimination program. Details of such a programwill depend on the nature of the source. Major optionsunder consideration now include soil excavation and a soilflushing system.

Well point installation is expected to be completed by September 27, 1985.Groundwater and analytical results are expected by October IB, 1985. Wewill contact you next week to describe preliminary results from the wellpoints. Please feel free to call if you have any questions.

Very truly yours,

Robert C. BrodSenior Hydrogeologist

RCB/pdcc: A. M. Robinson, BCM

R.'E. Sacks, BCM

c_2 BR300I32

I •BCM BCM Eastern Inc.

Engineers, Planners and ScientistsOne Plymouth Meeting • Plymouth Meeting, PA 19462 • Phone; (215) 825-3800

November 14, 1985

Dr. Mil Ham S. Brewer, ManagerCorporate Safety and Industrial HygieneCorporate Personnel ResourcesNCR CorporationWorld HeadquartersDayton, OH 45479

Subject: TCE Source DeterminationMillsboro, Delaware ProjectBCM Project No. 00-4529-10

Dear Bill:BCM has completed the installation of ten well points at the former Mills-boro plant as part of the effort to locate the source of dissolved TCE Inthe groundwater at the site. This letter describes the results from thesewell points, and recommendations for appropriate follow-up activities.Well point locations are shown on the attached Figure 1. Two sets ofgroundwater samules were obtained from each of these well points and fromwell W-20. All of these samples were analyzed for TCE. The groundwate:samples collected on September 23-24, 1985 were split and analyzed byBCM's laboratory and by Wastex Industries, Inc.'s laboratory for qualityassurance/auallty control purposes. The second set of samples taken onOctober 9., 1985 was analyzed by BCM's laboratory. Results of the analysesare presented in Table 1.The highest TCE concentrations were found In WP-6 and WP-9. Average TCEconcentrations for the analyses at these two locations were 317,000 ug/1and 122,000 ug/1, respectively. Groundwater samples from the other wellpoints had an average TCE concentration of about 17,000 ug/1. Monitoringwell H-20, which in the past had TCE concentrations consistently greaterthan 100,000 ug/1, had an average concentration of 8,700 ug/1.These results have not provided a clear understanding of the source ofTCE. Relatively high concentrations from well points WP-7, WP-8, andWP-9 suggest that the source Is either close to or upgradlent from thosepoints. However, the highest concentrations were observed In samples fromWP-6, which Is located in an area not previously suspected as being nearthe source.

• A Membe:' Firm of Betz«Converse«Murdoch«lnc, •AR30UI3JC-3

Dr. HllliamS. Brewer -2- November 14. 1985NCR Corporation

Based upon these results, Me ore currently preparing to remove five wellpoints and reinstall them, along with seven additional well points, at thelocations shown In Figure 2.- The new locations are concentrated aroundthose areas where high concentrations were observed In previous samples.Hell points HP-4, WP-6, HP-7, WP-8, and WP-9 will be sealed so that theycan be used for future groundwater sampling.The second group of well points will be Installed during the week ofNovember 25, 1985. Should you have any questions or wish to discuss theresults or plans, please feel free to call.

Very truly yours,

Robert C. BrodSenior Hydrogeologist

RCB/rkhEnclosurescc: A. M. Robinson, BCM

R. E. Sacks, BCM

c-4 AR300I3I4

TABLE 1

TRICHLOROETHYLENE CONCENTRATIONS IN GROUNDWATERFIRST FREEDOM CENTER (FORMER NCR FACILITY), MILLSBORO, DELAWARE

•SAMPLING DATA/LABORATORY•• • 9/23-24/85 •••• 10/9/85

Well No. BCM WASTEX BCM

W-20 4,130 12,540 9,500HP-1 11,900 12,700 7,660HP-2 15,000 18,490 12,000WP-3 2,500 4,570 227HP-4 13,800 16,400 229HP-5 6,230 16,160 16,900WP-6 440,000 194,000 317,200HP-7 69,900 73,000 64,000WP-8 31,700 15,437 32,100HP-9 114,000 68,000 183,000HP-10 120 304 210Field Blank 34 <1 3.0Trip Blank - - <1.0

Source: .BCM Eastern Inc. and Wastex Industries, Inc.All trichloroethylene concentrations in ug/1.

/IR300I35

Appendix D - The Drawdown Calculationsi c --., • • • • • • • . . -

HR300I37

THEIS DRAWDOWN CALCULATIONS

Predictions of water table drawdown and resultant water table elevationwere made by applying the Thels Equation and theory of superposition tothe static Mater table configuration as determined from monitoring wellsat the site.The Thels Equation 1s expressed as:

Where s • water table drawdown, ftW(u) • well function of u, where

y. r?S4Tt

Q • rate of well discharge, ft /day (negative for recharge)T » transmlsslvlty, ft2/dV • distance from pumping well, ftS • storage coefficient, fractiont * time, days

Based1 on BCM's understanding of local hydrogeology, as described in Sec-tion 5,1 of this report, the method was applied using the following •assumptions:

a. T • 14,000 ft2/dayb. S • 0.031c. t • 30 daysd. There are no hydraulic boundaries within the radius of

influence.

IH RR300I38

Appendix E - Air Stripper Influent Concentration/Calculations •'

flR300!39

.1

AIR STRIPPER INFLUENT CONCENTRATION CALCULATIONS

I The concentration of TCE pumped from the recovery well, and thus goingI Into the air stripper, 1s estimated based on the assumption that the rate

of TCE generation equals the rate of TCE withdrawal, as shown by the fol-lowing miss balance equation:

I QS cs • Qw CwWhere: Q$ • Existing rate of groundwater flow through cross

I section of aquifer at the suspected source, under\ non-pumping conditions.I ' Qw " Recovery well pumping rate

Cs • TCE concentration at sourceCM » TCE concentration in well effluent

,' Qs Is defined by Darcy's Law:

| Qs • K1A

I Where: K • hydraulic conductivity - 140 ft/dayI 1 • hydraulic gradient • 0.003 ft/ftj A « width of aquifer (normal to flow) from which TCE contaml-f ' nated water 1s being drawn x saturated thickness ofI aquifer • 200 feet x 100 feet

Qs • (140 ft/day) x (0.003 ft/ft) x (200 ft x 100 ft)• 8,400 ft3/day • 237,888 I/day

I ' Cs « 1s based on (1) TCE concentrations measured near suspectedsource on November 26, 1985 (Figure 3-6)

(2) the assumption that TCE concentration decreasesi linearly to zero from the top to the bottom of

the aquifer.( • 1/2 [(206,000 ug/1 + 24,000 ug/1 + 132,000 ug/1 + 463,000 ug/1) * 4]

- 103,125 ug/1

I Qw • 200 gpm • 288,000 gpd • 1,090,080 I/day

' r - 237.888 I/day x 103.125 uq/1I t>* l,09U,UBu i/day

> 22,000 ug/1 • air stripper Influent concentration

AR300UOE-l

Appendix F - Health and Safety Flan

AR300UI

HEALTH AND SAFETY PLAN FORNCR MILLSBORO, DELAWARE

PROPOSED NPL SITE

AR300U2

introductionThis health and safety plan provides an overview of condi-

tions at the facility and describes the safety procedures to be

employed and the rationale for their selection. Based on the

known hazards onsite, it is not anticipated that any specializedpersonnel protection is needed. This health and safety plan has

been prepared in order to address any potentially health

threatening contingencies. All personnel working at the site

will be briefed by the site safety officer and will be required

to become familiar with the following sections of this plan:

• Safety Rules and Personal Hygiene• Field Standard Operating Procedures• Heat Stress and Heat Stress Monitoring• Emergency Procedures

ESC personnel are included in a Medical Monitoring Program

which is described in the plan,

Exposure to Toxic Substances

This health and safety plan relates to potential remediation

activities and the collection of soil samples using manually

operated sampling equipment, an auger sampler rig or a standard

backhoe, It is known that priority pollutants may be present in

soils onsite. The primary constituents of concern are trichloro-

ethylene and chromium. A brief toxicological profile of the

major constituents of concern are included in a following section

of this report.

Personnel operating sampling and excavation equipment will

be handling augers and other equipment that contain soil and

liquid residue from the contaminated soil and that may give off

volatile organic fumes from these materials. These workers may

Health and Safety Plan - Page 1 flR300 | l<3

also be exposed to airborne dust that may contain some waste

materials and to the solvents that will be used to decontaminatethe drilling equipment. To protect these workers from skin

contact and respiration of fumes and dust, they may be required

to use Level C protection as described in the following sections

of this plan.Properties of MaterialsTr ichloroethylene

Trichloroethylene (TCE) is a widely used industrial

solvent. It can be a severe irritant of the skin and eyes; skin

contact can result in blistering. Also, TCE is absorbed readilyfthrough the skin. Ingestion and inhalation are also potential

routes of exposure to TCE. It is distributed in the body to

fatty tissues,

In acute exposures, the compound is a depressant of the

central nervous system. It can cause visual disturbances,

confusion, fatigue, nausea, and vomiting. Heart arrythmias and

necrosis of ' the liver and kidneys also can result from acute

exposures, as can respiratory failure and cardiac arrest when TCE

is ingested. TCE in not highly toxic in acute exposures,

however. The LD50 for oral administration to rats was 4,920

rag/kg while for mice it was 2,402 mg/kg. The ACGIH has proposeda TLV for TCE of SO ppm (270 ing/m3), while the OSBA TWA has been

set at 100 ppm.Chronic exposures to TCE can also result in kidney and liver

damage. The compound has been found to be carcinogenic in some

laboratory animals when administered by ingestion or inhalation,

Health and Safety Plan - Page 2 AR3QOIM

I TCE can cross the placenta. Inhalation exposures have resulted

I in developmental abnormalities in rats. TCE has not been shown

to be mutagenic, however. The EPA has proposed a Recommended

Maximum Contaminant Level in drinking water of zero ppm TCE.

TCE will not be persistent in many environmental situations.

It is fairly volatile, the evaporative half-life is about 20

minutes, and it readily photooxidizes. Also, it can undergosignificant biodegradation. Nevertheless, it remains a signi-

ficant contaminant of deeper soils and groundwater. While it has

been found to be toxic to aquatic life in bioassays, its poor

water solubility will frequently preclude such concentrations

being reached in natural aquatic systems.

Chromium

Chromium exists in compounds mostly in the trivalent or

hexavalent states. Trivalent chromium compounds are more common

and less toxic than the hexavalent forms. It is mainly the

hexavalent compounds that are irritants and corrosives. Acute

exposures to dusts or mists of chromium compounds can result in

coughing, headache, dyspnea, loss of weight, and pain on respira-

tion. Industrial exposures to hexavalent chromic acid mists have

resulted in ulcers of the skin and nasal septa. Hexavalent

chromium compounds can cause severe contact dermatitis. Absorp-

tion through the skin can result in kidney damage. Although

chromates are poorly absorbed after ingestion, hexavalent com-

pounds can cause gastrointestinal hemorrhaging. Large oral doses

can also cause kidney damage. The LD5Qs for oral administration

j of hexavalent compounds to laboratory animals have been found to

Health and Safety Plan - Page 3 flRQflDI I R

I nrange from around 300-500 mg/kg. The OSHA THA is 0.5 mg/nr for

I soluble chromium compounds, and 1.0 mg/m3 for insoluble ones.

Some hexavalent chromium compounds are carcinogenic at the

site of exposure. Lung cancers have been found to result from

inhalation exposures in the workplace. While hexavalent com-

pounds have been found to be mutagenic in bacterial and other

test systems, the trivalent compounds have not shown mutagenicactivity. Some hexavalent compounds also appear to be terato-

genic and embryotoxic. The EPA primary drinking water standard

for chromium is 0.05 mg/1.

i Trivalent chromium compounds tend to be insoluble in water

i except at a very low pH. Hexavalent compounds are moderately

soluble. In the environment, hexavalent chromium, being a strong

i oxidizer, readily reacts with reducing agents to form trivalent

compounds, which are far more stable. Trivalent chromium com-

| pounds readily precipitate except in highly acid solutions. Both

types of compounds only adsorb weakly to sediments. The EPA

standard for chromium to protect freshwater aquatic life varies

with the hardness of the water body, but generally ranges from

2.2-9.9 mg/1. For hexavalent chromium, the standard is 21 ug/1.

Nature of HazardsESC has consulted various references to evaluate the nature

of potential site hazards and desirable personal protective

equipment (PPE) including: NIOSH/OSHA/USCG/EPA Occupationali

Safety Health Guidance Manual for Hazardous Waste Site

I' Activities, Pattys Industrial Hygiene, ACGIH Threshold Limit

Values and NIOSH Pocket Guide to Chemical Hazards. The rationale

Health and Safety Plan - Page 4 AR300U6

employed for the selection of the PPE is discussed at the end ofthis document.

The nature of the hazard posed by the materials at the site

is chronic rather than acute. Short term exposures to the mate-

rials will not be immediately toxic or debilitating. Level D

protection for all onsite workers is being specified. This willinclude splash suits, gloves, and boots in order to prevent

direct contact with potentially contaminated soils. ESC will

require the use of chemically resistant coveralls, gloves, and

boots, and require a daily change of coveralls.

Level C protection is fully encapsulating and mandates the

use of air purifying respirators. Level C protection will be

required if there is evidence of potentially debilitating organic

vapors or of dusts in the breathing space in the work area. An

HNU meter will be employed to detect organic vapors. As a rule

of thumb, concentrations from background to 5 ppm will require

the use of Level C protection, including respirators with

appropriate cartridges. This "trigger limit" may be based upon

our knowledge of the contaminants at the site and relevant ACGIH

TLV. Rotary mud drilling should not generate dust. If visibledust is produced in the work area, Level C protective equipment

may be required.

The design of drilling rigs creates the potential for

contact with overhead electric lines and underground utility

lines. The rig will not be operated within 15 feet of overhead

lines. Underground lines will be located and will be avoided.

In the event of an accident the nearest medical assistance

Health and Safety Plan - Page 5 AR300U7

will be sought as specified in the section entitled Emergency

Procedures.

Site ControlsReal estate in the vicinity of the plant is undeveloped. If

necessary, during sampling activities, an "Exclusion Area" will

be delineated as each phase of the sampling and or excavation

effort proceeds using caution tape or other equivalent physical

barrier. The exclusion area will be made subject to strictaccess controls. Absolutely no access to or traffic through the

exclusion area by personnel or equipment shall be permitted

unless they are directly involved in the remedial program. Per-

sonnel working within these areas shall be required to wear

appropriate protective clothing and safety equipment,

A contamination reduction area (CRA) will be located adjacent

to each sampling phase. The boundary between the Exclusion Area

and the CRA will be posted. The CRA will be separated from the

rest of the facility by caution tape or equivalent physical

barrier. Decontamination will be performed within the CRA. Per-

sonnel entering the CRA will be required to wear protective

equipment.Site Health and Safety Officer

A Health and Safety Officer and alternate will be specified.

The responsibilities of the site health and safety officer will

include the following:• Briefing personnel on the hazards at the site, the

standard operating procedures to be employed, andemergency procedures

• Conducting onsite health monitoring

Health and Safety Plan - Page 6

,J

Coordinating access control and site security

Monitoring work practices and decontamination to insurethat required procedures are being followed

Being available to document and respond to any concernsor complaints made by personnel onsite

Evaluating the effectiveness of the personal protectiveequipment.

Documenting unsafe work practices or conditions.

Documenting any accidents or incidents that result inillness or injury to personnel

Daily evaluation and amendment of the Health & SafetyPlan to remedy deficiencies and post entry briefings

Health and Safety Plan - Page 7 |,g

Level of Protection '

Staff members and/or contractors of ESC responsible for the

project have received training in CPR, basic first aid, site

safety, and personal protection for hazardous materials handling,

and relevant staff members have undergone a respirator fit test.

Level C protection may be specified for personnel operating

sampling equipment and collecting and packaging samples. In this

case, level C requires use of a full-face air-purifying maskequipped with organic vapor/particulate canisters. This type of

equipment provides protection against concentrations of most com-

mon organic vapors and potentially significant airborne parti-

culates.

A rang? of background to 5 ppir, above ambient background

concentrations of vapors/gases in the atmosphere has been

established as guidance for selecting Level C protection (U.S.

EPA 1984). An HNU meter will be used to determine whether

organic vapors are above background and consequently, whether

upgrading personnel protection to Level C will be required,

Readings from 5 to 500 ppm above background dictate that Level B

will be required. Level B requires the use of SCBA.

The HNU meter will be calibrated at least once during the

start of each operating day or when the instrument supplies

erratic readings.The calibration of the analyzer can be readily checked by

the use of an HNU small disposable cylinder containing isobutyl-

ene (HNU pn 101-350) with a regulator (HNU pn 101-351). At the

factory, the analyzer is first calibrated on the desired gas -•••'

Health and Safety Plan - Page B (\R300150

standard at the specified concentration. Then a measurement ismade with isobutylene. The ppm reading along with the span

setting using isobutylene is recorded in the calibration report.In service, the i< nlyzer calibration can be checked and read-justed if necessary by using this cylinder and regulator as

follows:a. Connect the analyzer to the regulator and cylinder with a

short piece (butt connection) of tubing. The calibration gasin the cylinder consists of a mixture of isobutylene and zeroair. Isobutylene is nontoxic and safe to use in confinedareas. There are no listed exposure levels at any concentra-tion.

The regulator sets and controls the flow rate of gas at avalue preset at the factory. This will be about 250 cc/min.

It is important that the tubing be clean since contaminatedtubing will effect the calibration reading. Do not use thecylinder below about 30 psig as readings below that levelcan deviate up to 10% from the rated value.

b. With the SPAN setting at 9.8 and the function switch at 0-200open the valve on the cylinder until a steady reading isobtained.

c. If the reading is the same as the recorded data, the analyzercalibration for the original species of interest is stillcorrect.

d. If the reading has changed, adjust the SPAN setting until thereading is the same.

e. Shut off the cylinder as soon as the reading is established,

f. Record and maintain this new SPAN, setting. Then recalibratethe analyzer on the species of interest as soon as possible.

g. Whenever, the analyzer is recalibrated, it is to be immedi-ately checked with the small cylinder and the readingrecorded. This can then be used for later checking in thefield.

Health and Safety Plan - Page 9AR300I5I

Personnel Protective Equipment (PPE)

Level C personnel protective kite will consists of the fol-

lowing equipment to be worn if necessary within the exclusionarea at all times:

• Full-face dual canister air purifying respirator (NIOSHapproved)

• Organics and dust respirator cartridges

• Tyvek coveralls or Saranex coated Tyvek coveralls withelastic waists, booties, and hoods

• Steel-toed work booto

• Outer booties

• Gloves - inner surgical, cloth outer• Hardhats

Level D personnel protective kits will consist of the same

items as for Level C, except the plain Tyvek coveralls may be

substituted for Saranex coated Tyvek. Respirators will be

available but not worn unless organic vapors exceed ambient

concentrations. Contractors will provide their own personalprotective equipment.

The fit of the facepiece-to-face seal of the respirator

affects its performance. The Site Safety Officer will be

responsible for insuring that a good seal is maintained. After

each day's use the respirator will be inspected, cleaned andstored,

Personnel protective equipment that is damaged will be

immediately replaced. Back-up equipment will be kept onsite forreplacement as necessary.

Health and Safety Plan - Page 10 AR300I52

The following protective equipment will be discarded andreplaced daily:

• respirator cartridges• Tyvek coveralls• outer booties• inner surgical gloves

Onsite Safety Equipment

Several pieces of safety equipment will be provided within

the immediate vicinity of the work area. An HNU meter will beused to detect organic vapors. A first aid kit will also be kept

at the command post.

Water hoses will be located on site to allow rapid wash down

of personnel either to remove contaminants or to cool protectiveclothing and reduce body temperature.

Safety Rules and Personal Hygiene . i

1. Do not eat, drink, smoke, chew gum or tobacco or engage in

any other practice in the exclusion area that increases the

probability of hand-to-mouth transfer or ingestion of

material.

2. Wash hands and face throughly upon leaving the work area and

before eating, drinking, or any other activities.

3. Throughly wash entire body an soon as passible after removingLevel C protective garments.

4. Remove all facial hair which interferes with a satisfactoryfit of respiratory protective equipment.

5. Do not wear contact lenses while wearing full facedrespirators.

6. Whenever possible avoid contact with contaminated or ; /suspected contaminated surfaces.

Health and Safety Plan - Page 11 AR300I53

7. Prescribed drugs should not be taken unless specificallyapproved by a qualified physician,

Field Standard Operating Procedures

1. Park vehicles outside the site boundaries.

2. This section of the Health and Safety Plan and the sections

entitled Safety Rules and Personal Hygiene, Heat Stress and

Heat Stress Monitoring, and Emergency Procedures will beprovided to you. Become familiar with them.

3. During the pre-work safety meeting the project manager will

provide the following information:

• a description of the site and known problem areas

• the level of protection required

• emergency medical information

• the locations of the first aid kit, showers, telephones,nearest water supply, ice, and lavatory

4. Visit the nearest lavatory.

5. Lay out and check safety gear. This gear must be worn at all

times within the exclusion area.

6. Don safety gear in order:

Saran Tyvek coverallsSteel toed work bootsConnect suit and boots with tapeOuter bootiesAir purifying respirators (if required)

A. Inspection

1. Inspect before each use to be sure they havebeen adequately cleaned.

2. Check material conditions for signs ofpliability, deterioration or distortion

3. Examine cartridges and be sure they are theproper type for the intended use, that theexpiration date has not passed, and that theyhave not been opened or used previously.

Health and Safety Plan - Page 12 AR300I51*

4. Check face shields for cracks, or fogginess.

B. Loosen all harness strap adjustments.C. Place chin in chin cup and draw evenly back on

strap adjustments. Bottom two (2) straps first,then two (2) top straps, and center top strap last.

D. Check to determine that the respirator is centered

evenly on the face and that the straps are not

uncomfortably tight.

E. Check for leaks or proper facial seals.To conduct a negative-pressure test, close the

inlet part with the palm of the hand or squeeze the

breathing tube so it does not pass air, and gently

inhale for about in seconds. Any tnward rushing of

air indicates a poor fit. Note that a leaking

facepiece may be drawn tightly to the face to form

a good seal, giving a false indication of adequate

fit.To conduct a positive-pressure test, gently exhale

while covering the exhalation valve to ensure that

a positive pressure can be built up. Failure to

build a positive pressure indicates a poor fit.Raise hoodHardhatSurgical GlovesCloth GlovesNitrile Gloves (if applicable)Connect gloves and suit with tape

7. Select a buddy to act as a safety backup.

8. Check your buddy's equipment and have him check yours for

rips/tears/malfunctions. Pay special attention to

Health and Safety Plan - Page 13 AR300I55

respirators making sure that seals are good and thatcartridges are securely in place.

9. If any equipment or gear gets damaged or if your suit tearsbadly - GO BACK.

10. If you experience physical discomfort, breathing

difficulties, light-headedness, dizziness, or otherabnormalities - GO BACK.

11. On return have buddy check for external accumulation ofcontamination and remove it. Also check gear for damage. '

12. Decontamination will be performed at stations as follows:

Station 1—Segregated Equipment Drop; Deposit equipment used

onsite (tools, sampling devices and containers, monitoring

instruments, clipboards, etc.) in different containers with

plastic liners. Each may be contaminated to a different

degree. Segregation at the drop reduces the probability of

cross-contamination. This equipment may be reused ifsubsequent sampling is required on successive days.

Equipment: various size containersplastic drop cloths

Station 2—Tape Removal: Remove tape around boots and glovesand deposit in container with plastic liner.

Equipment: container (20-30 gallons)plastic liners

Station 3--Boot Cover Removal: Remove boot covers anddeposit in container with plastic liner.

Equipment: container (30-50 gallons)plastic linersbench or stool

Health and Safety Plan - Page 14AR300I56

rStation 4— Outer Glove Removal; Remove outer gloves and

deposit in container with plastic liner. These gloves may be

reused if subsequent sampling is required on successive days.

Equipment: container (20-30 gallons)plastic liners

Station 5—Safety Boot Removal; Remove safety boots and

suspend away from all surfaces or deposit in container withplastic liner. These boots may be reused if subsequent

sampling is required on successive days.

Equipment: container (30-50 gallons)plastic linersbench or stool

Station 6—Protective Coverall Removal; With assistance of

helper, remove protective coverall. Deposit in containerwith plastic liner.

Equipment: container (30-50 gallons)bench or stoolplastic liners

Station 7—Respirator Removal: Remove face piece. Avoid

touching face with gloves. Hang respirator away from

potentially contaminated surfaces or deposit in container

with plastic liner. Respirators may be reused if subsequent

sampling is required on successive days.

Equipment: container (30-50 gallons)plastic liners

Station 8~Inner Glove Removal; Remove inner gloves and

deposit in container with plastic liner.

Equipment: container (20-30 gallons)plastic liners

Station 9—Field Wash: i

Equipment: water

Health and Safety Plan - Page 15 AR300I57

soapwash basin/buckets

Station 10—Redress: Put on clean clothes.

13. Respirators will be cleaned daily by hand washing with a mild

disinfectant solution followed by a thorough rinse and air

drying. NEVER ALLOW A RESPIRATOR TO DRY WITH THE STRAPS

PLACED FORWARD ACROSS THE FACESHIELD AS THIS MAY CAUSE

CHANGES IN THE FACE TO RESPIRATOR SEAL SURFACE. The specific

procedures to be employed are as follows:

A. Remove all cartridges (canisters) and filters plusgaskets and seals not permanently affixed to their

seats.

B. Loosen harness adjustment straps.

C. Remove exhalation valve cover.

D. Remove inhalation and exhalation valves.

E, Remove protective faceshield cover.

F. Wash facepiece either in a cleaner/sanitizer powder

mixed with warm water or a mild soap/disinfectant

solution, preferably in a water temperature of 120 to

140 degrees fahrenheit. Wash components separately from

facepiece. Heavy soil may be removed from the facepiece

surface using a medium-soft handbrush.

G. Remove all parts from the wash solution and rinse twice

in clean, warm water.

H. Air dry all parts in a designated clean area.

I. Pat facepieces, valves, and seats to remove any

remaining soap residue, water, or other foreign material

with a clean, damp, lint free cloth.

Health and Safety Plan - Page 16 AR300I58

J. Reassemble respirator

K. Place respirator in a plastic bag and the respirator box

and or otherwise store the respirators to prevent

malfunction due to exposure to dust, moisture, sunlight,damaging chemicals, extreme temperatures, and impact.

Decontamination of Equipment

A decontamination pad sufficient in size to allow

decontamination of all major pieces of equipment will beconstructed on site prior to the initiation of sampling effort ifnecessary.

Heat Stress and Heat Stress Monitoring

Heat is one of the most common (and potentially serious)

illnesses at hazardous waste sites where PP.5 .is worn; therefore,

regular monitoring and other preventive precautions are vital.

Shelter from the sun will be provided during rest periods. If

necessary, work will be performed during the cooler night

hours. Table 1 lists the signs and symptoms of heat stress.

Initial work schedules will be approximately 90 minutes of work

followed by 15 minutes of rest. These schedules will be modified

based on the following monitoring stated in NIOSH, et al. (1985).• Heart rate will be measured during a 30 second period as

early as possible in the rest period. If the heart rate

exceeds 110 beats per minute at the beginning of the

rest period, the next work cycle will be shortened by

one-third without changing the rest period. If the

heart rate still exceeds 110 beats per minute at the

next rest period, the following work cycle will be

shortened by one-third-.

Health and Safety Plan - Page 17 fl [7 ? D fl I '•i Q

Table 1

Heat rash may result from continuous exposure to heat orhumid air.Heat cramps are caused by heavy sweating with inadequateelectrolyte replacement. Signs and symptoms include.

Muscle spasmsPain in the hands, feet and abdomen

Heat exhaustion occurs from increased stress on variousbody organs including inadequate blood circulation dueto cardiovascular insufficiency or dehydration. Signsand symptoms Include:

Pale, cool, moist skinHeavy sweatingDizzinessNauseaFainting

Heat Stroke is the most serious form of heat stress,Temperature regulation fails and the body temperaturerises to critical levels. Immediate action must betaken to cool the body before serious injury and deathoccur. Competent medical help must .be obtained. Signsand symptoms are:

Red, hot, usually dry skinLack of or reduced perspirationNauseaDizziness and confusionStrong, rapid pulseComa

Source: EPA 1965

Health and Safety Plan - Page 18 AR300I60

r1 • Oral temperature. A clinical thermometer (three minutes

I under the tongue) or similar device will be used to

measure the oral temperature at the end of the work

period (before drinking). If oral temperature exceeds99.6° F (37.6° C), the next work cycle will be reduced

by one-third without changing the rest period. If oral

I temperature still exceeds 99.6° F (37.36° C) at the

beginning of the next rest period, the following workcycle will be shortened by one-third. A'worker will not

be permitted to wear a semipermeable or impermeable

I garment when his/her oral temperature exceeds 100.6° Fi (38.1° C).

• Body water loss, if possible. Height will be measured

I on a scale accurate to ±0.25 Ib at' the beginning and end

of each work day to see if enough fluids are being taken

I to prevent dehydration. The body water loss should not

i exceed 1.5 percent total body weight loss in a work day.

Contingency Plan and Emergency Procedures

If HNU readings indicate a sudden increase of constituents

in the breathing zone to levels exceeding IDLH or if other

threatening hazards are noted,, ESC and its contractors will

evacuate the area. No personnel will return unless

instrumentation, engineering judgment or an emergency response

official indicates it is safe and proper to do so.

Emergency showers and first aid equipment will be available

onsite. In order to obtain medical assistance as soon as

. possible, the phone numbers, addresses, and directions for the s~

' nearest medical treatment facilities will be posted at the site.

Health and Safety Plan - Page 19 AR300 I fi I

In an emergency, the primary concern is to prevent the loss

of life or severe injury to site personnel. If immediate medical

treatment is required, decontamination will be delayed until the

victim has stabilized. If decontamination can be performed

without interfering with first aid, or if a worker has been

contaminated with an extremely toxic or corrosive material that

could cause severe injury, decontamination will be performedimmediately. If an emergency due to a heat-related illness

develops, protective clothing will be removed from the victim assoon as possible to reduce heat stress.

Medical Monitoring

The workers most exposed to contaminated soils at the site

are sampling personnel. These personnel are included in a

medical monitoring program established by ESC.

The purpose of the Medical Monitoring Program is to identify

any illness or problem that would put an employee at an unusual

risk from exposures; to assure that each employee can safely

utilize negative pressure respirators and withstand heat stress;

to establish and maintain a medical data base for employees in

order to monitor any abnormalities which may be related to work

exposure and could portentiate injury risk for the employee or

others in the performance of job functions. The MedicalMonitoring Program includes:

• a baseline physical examination

• medical determination of fitness of duty including workrestrictions after any job related injury or illness or non-job related absence lasting more than three (3) working days

• the review of each Site Specific Health and Safety Plan andpotential exposure list to determine the need for specificbiological and medical monitoring

Health and Safety Plan - Page 20 AR300I62

• annual and exit physical examinations with attention given tospecific exposures or symptoms

Baseline Physical Examination

A baseline physical examination will be performed on each

employee engaged in hazardous waste activities. The purpose of

this examination in the identification of any illness or problem

that would put an employee at unusual risk from certain

exposures; to certify the safe utilization of negative pressure

respirators (OSHA Safety and Health Standard 29 CFR 1910. 134);and the development of a data base for the assessment of exposure

related events detected through periodic medical monitoring.

Variable data such as age, sex, race, smoking, prior employment

and exposure history, etc., which may have a bearing upon the

occurrence of subsequent events once, employment begins, will begathered.

The content of the Baseline Physical Examination will include:

• medical, occupational and fertility history

• physical examination stressing neurological, cardiopulmonary,musculo-skeletal, and skin systems

• electrocardiogram

• PA and lateral chest x-ray• pulmonary function test (FJSV1, FVC, FF.V 25-75)

• audiogramt a multi-chemistry blood panel including kidney and liver

function tests, CBC with differential, and urinalysis

• tests deemed necessary by symptoms or exposure history

• red blood cell cholinesterase

• physical parameters including blood pressure and visualacuity testing

Health and Safety Plan - Page 21 , , „AR300I63

..„,'

Annual Physical Examination

An examination and updated occupational history will be

performed on an annual basis during the anniversary month of the

baseline physical examination. This examination serves to

identify and prevent illness caused by cumulative exposure to

toxic substances.

The Annual Physical Examination will include:

• personal work history (based on specific project histories)

• physical examination stressing neurological, cardiopulmonary,musculoskeletal, and skin systems

• pulmonary function test (FEV1,FVC,FEV 25-75)

• a multi-chemistry blood panel including kidney and liverfunction test

• audiogram

• tests deemed necessary by symptoms or exposure

• optional wellness profile

Return to Work Examination

Any job-related illness or injury will be followed by a

medical examination to determine fitness for duty or possible job

restrictions based upon the physical findings of the medical

examiner. A similar examination will be performed following

three (3) missed workdays due to a non-job-related illness or

injury requiring medical intervention.

Health and Safety Plan - Page 22AR300I61*

Exit Physical ExaminationThe content of the Exit Physical Examination will include:

• personal work history (based on specific project histories),

t medical, exposure and fertility history,

• physical examination stressing neurological, cardiopulmonary,musculoskeletal, and skin systems.

• pulmonary function test (FEV1,FVC,FEV 25-75).

• electrocardiogram• PA and lateral chest x-ray.

• audiogram• multi-chemistry blood panel including kidney and liver

function tests, CBC with differential, and urinalysis

• tests deemed necessary by symptoms and/or exposure history

• red blood oell cholinesterase

• physical parameters including blood-pressure and visualacuity testing

Health and Safety Plan - Page 23 .nonnircbb

References

NIOSH/OSHA/USCG/EPA. October, 1985. Occupational Safety andHealth Guidance Manual for Hazardous Waste Site Activities,

U.S. EPA. 1984. Standard Operating Guides. Office of Emergencyand Remedial Response Support Division, Edison, NJ.November, 1984.

AR300J66

Appendix P-II- Selection of Personnel Protective Equipment (

AR300I67

Stltetlon ef Nraonnel Prettetitt Eoulpatpt •

A, .Introduction.

1. frottetlYi equlpient fcta been dlrlded into four eattiorlea •eoordlafto tnt dairee ef protection afforded:

ij a&ould N mm tftin tht Blfbeit lore! of roapiratorj,akin tad fji protection la needed or wntn ooneintntleu ud•tarUlj oeaoeno an unknown.UT«! Bi Should be atltettd Mbta tnt nlftcit 1ml ofrtiplntory pretietloa 1« Mtdid, but • limr lird of akinprotictlon. UT«! J prottctlon ii tn« tinlnuc ItvtlrteoBDtadid for laltUl wtrlu. Ccee tni buarflg navi btcoditiralnid, piraonntl protietlon csrrtipoodlnf wltfi Unit

117 p* utllliid.o. ttrtl C; Should bi tilicttd w&ui tht type of alrbore*

•ubiUfict la knew, Use ccoeentrttion Ii Mtaurtd, and tfiterltirl* for uilag tlr-purlfyug rtaplritora art act.

t. Uvel P; Sbeuld not b« tnre it iE? ipUl MIDI withrwplntorr er ilcin butnla. la prlaarlljr • work uniformproridlni ilnlml prottetloc,

2. In fiptrtl, tbi Initial OD*aetoi aunrtj ia to onanetirlxi tfit1Intdiata btiirts ud, btaid on tatat flsdlrna, MMbllaaprt.Uitlnary ufity nqulrtainta. A* tbla data ia obttlatd ud•ntlTZtd, tt)« Itral of protietioo ud otbar atfttj proeidurta tratbaa Kdlfltd u approprlati. Do auadtrd aiuiod eu bt uatd toMltet • 1ml of protaetioB for all locldtntj. Each altuatlon auatbt (zaolned lodlTlduilly. AKI itneral (uiowea can bt (irta,bowirip, for judflni tbt aituation and datarmlnlng tnc Itral ofprotietlon rtqulnd. Tnt foUoxlAf atetlena daacriba erltarla to ba. oouldirtd Hnm ftltctlni toi laril of protection ipproprlatt for tpanicular altuatlon. In addition, ttblia II. 1 ud .11.2 prorlde •bulc dtclaion logic* for reapirator ud pretectlre •olotnlngaaleetlon.

I. eltetiat ItTili ef Frettttlen.

1. jUttl I EreUetlon

a. Seleetion Criterit - KMtiaf j£Z of tba followlnj erltarlaMUTUU tba ua of Ural I protection;

* (1) Tbt onemleal tubitanot nu been Identified ud rtqulrtatbt nlfbtat level of protection for tfit ikln, eyti ud tbtrtsplntory lyatea baaed on:

U-1 .,flR30QI68

Tiblt 11.1 .frottctlvt ClctftlM Deeialon Loalc

Aiaeablt lexicological data

Deterainn pbraleal atata(t) .Of

Enluatt all axpoaure patnvara

4Conduct eoMimtlYt ^ H° js tdequatt cbe&lealreaponat until a*tlsf»ctory cospiUblllty diU arallablt?auit aattrial laidentifltd .

Evaluate tfi* infomatlonto dettnlDe respiratory protection

requlreaenta (Stt Table 11.2}

iDee eneapaulattd / "S Voaaiblt injury erauit (LtYtl A) de«tb fron akin abacrptlon

t i of cnenlcala?NO |NO

• •»• — . v 'Severe akin ' y» Feasibility of atYtreIrritation U froa 4 akin Irritation free•olid er liquid . akin contact?contact only ' I

I I110 '.1" iUtilise celled JoaalbilitT of TO • . Oat proper•platn milt (U»el I) «7« IrrtUtlon? r aye protectlonIf appropriate for I >Q "•ntry Uak

Otillxa dlapoiabltcoYtnlla (LeYtl 9)

Q-2/1R300I69

Tafalt II. ?Jlcarlntpr Ptenien logic8CSA ?a Air-Purifyins

1. Za thtrt u oxygen deficiency? (leti than 19. St)If yea - Dee SCSA

2. laYt anllable peraonnel been aucoetafully flt-ttitid?If DO • Do not uae respirator • Dee SCBA

3. Za (bare any ohuoe of eye Irritation fro> tin ooottolnant?If yea • Oce only full-ftctpltot reap Ira tor

». Ia tbe contaminant at I.C.L.H. concentrations?

If yta - Only uae SCBAS. If tht.eontaainant la a paniculate, ia the 7LV (nitir than or liaa than

.OS BfV?If grtattr than,, uat a dust, aust, or fume filterIf leas than, uat a * f efficiency filter

t. If til ooataalnut ia pitoui, ia thi oonctntration gretttr tnan tailrecoostoded by. tbe aanufacturer of toe aelected caniatcr?

If yts • Dee SCBA

7. I* tbt eont-'nalnaiit conctntration greater tnan Uii aaxlaua uat liolt (MUL)for tbt Mlacttd reaplntor? (MUL i F.F. x TLV)

If yea • Oat SCBA

8. Dots tbe oontanlntnt nave adequatt mrning proptrtlea?

. If DO - Dee SCBA

t. Hill the wnterlvit generate a blgh beat of reaction with the eorttntualdt tit ouiater?

If yea . On SCBA10. Ia tbe oontaoinant one that tbe •mnufaoturtr. reooBenda that tbeir

ruplrttor not be need for?If yet . DM SCBA

"11. It tbi oontealnut a known or aueptoted oarclnogen?

j If 7U - Dee SCBA only12. Kill the oanliter Nltbaund breakthrough long enough to pewit aufflclent

entry tlai?

AR300I70

l-l-a-O)-(a) Measured or pottntlal for nlgb conctntratlon of 'ataosphtrle Tapora, gases or partlculatta (lie. vaporclouds, visible eolaslona, BLH livils, etc.); or

(b) On-acent operatloni and job functions inYolving nighpotential for aplaan, laatralon, or exposure tosuespestad liquids, nyora, fatt er partleulttea.

(2) Extremely hazardous aubatucta (e.g. dioxln, oyuldecompounds, oonctntrated ptitlcldts, Departaient ofTransportation Folson A aattriala, auapected oaroinogana,and Inftetloua aubsuneis) are known or auapected to bepreaent and akin contact la poaalble.

(3) Potential exists for contact with ikin-dtatnictlveaubatancta. , .

d) Optratlona oust be eonducttd in oonfintd or poorlyftntllated areas, until tht abatnct of hazards requiringlevel A protietlon la dtoonstrated. These areas areconducive to accuoulatlng high conccntratiou ofaubstancea.

*

(5) The type of cbeftie*!, eonetntrition, or cxpoaure potentialla unknown or uncertain. In tfila altuition, the highestlevtl of protection would be appropriate until tbe bturdacu be better, characterized.

b. Additional Guidance on Selection Criteria

(1) Tbe fully-tneapsulating ault provides tht blghtat degreeof protection to akin, eyea, ud reapiratory ayaten if theault uterial la resistant to tbe cbeBlcal(s) ef concernat the aeaaured or utlclptttd eoncentratlona. WhileLevel A provides auuclsna prottction, clotbing uterUl uybe rapidly ptratattd or penttrattd by certain cbtmleala.'Tntse limitations abould be recognised wben atlecting thetype or ehtucU-realatant atraent. Vhenever poaalblt,tht ault Hterlal abould bt aatcbed with tbe aubitueebeing protected against. Appendix XT provides data onooapaUDillty of ault uterlala and chtmioala. Onlta art ,tncounged to oonault with u Induatrlal bygenlat or othtrqualified peraon Htau eaklng tbla eelectlon.

'(2) Tbe uae of level A protection requlrea that tbe problemsof physical atreac, In particular beat atreas aaaoclattdwith the veering of iBpeneable protective clothing, beevaluated. Reaponae pertonnel auat be carefully Mnitoredfor physical tolerance ud recovery.

(3) tnctpaulated aulta, being heavy ud ousbereoat, decreaaedextarlty/agllity, vlautl acuity, etc., 'ud Increaae tnepol«ni,Ui tat accidinli. Toi» pottntitJ. decreaata u leasproti,,",lYi equlpatnt la required.

/1R300I7Izm

[Appendix G - Hazardous Substance List ,..-..'

J1R300I72'

CERCLA-CLP ORGANIC HAZARDOUS SUBSTANCE LIST

Quantltatlon LimitsH a t e r L o w Soil/Sediment(ug/1) (ma/kg)

EPA CONTRACT LABORATORY (CLP) VOLATILE ORGANICSContract Required Quantitatlon Limits (Detection Limits)Chloromethane 10 10Bromometnane 10 ' 10Vinyl Chloride 10 10Chloroethane 10 10Methylene Chlorlae 5 5Acetone 10 10CarDon Dlsulfloe 5 51,1-Olchloroethene 5 5l,l-D1ch)oroethane 5 5trans-l,2-D1chloroethene 5 5Chloroform 5 51,2-DI ch'loroethane 5 52-Butanone 10 101,1,1-Trlchloroetnane 5 5Caroon Tetracnlorlae 5 5Vinyl Acetate 10 10Bromodlchloromethane 5 51,1,2,2-Tetrachloroethane 5 5l,2-D1chloropropane 5 5trans-l,3-D1chloropropene 5 5Trlchloroethene 5 5Dlbromodlchloromethane 5 51,1,2-Trlchloroethane 5 5Benzene . 5 5ds-l,3-D1chloropropene 5 5Bromoform • 5 5

G-l 1R300I73

I

APPENDIX I (Continued)

Quantltatlon LimitsHater Low Sol I/Sediment(ug/1) (mo/kg)

EPA CONTRACT LABORATORY (CLP) VOLATILE ORGANICS (Continued)

1 2-Hexanone 10 104-Methyl-2-pentanone 10 10

I Tetrachloroethene 5 5Toluene . 5 5

I Chlorobenzene 5 5Etnyl Benzene 5 5Styrene 5 5Total Xylenes 5 5

1 CLP BASE/NEUTRALSb1s(2-Chloroethyl)ether 10 330

l 1,3-Dichlorobenzene 10 3301,4-Dkhlorobenzene 10 330

I Benzyl Alcohol 10 330l,2-D1chlorobenzene 10 330

I b1s(2-Ch!oro1sopropyl)ether 10 330N-N1troso-D1propylam1ne 10 330Hexachloroethane 10 330Nitrobenzene 10 , 330Isophorone . 10 330

' bis(2-Chloroethoxy(methane 10 3301,2,4-Trlchlorobenzene 10 330

i Naphthalene 10 3304-Chloroan111ne • 10 330

I Hexachlorobutafllene 10 330 '2-Hethylnaphthalene 10 330

, . Hexachlorocyclopentadlene 10 3302-Chloronaphthalene 10 3302-N1troan1l1ne 50 1,600

1 Dimethyl Phthalate 10' Sfl'R 3 0 0 I 7 bAcenaphthylene 10 330

G-2

APPENDIX I (Continued)

Quantltatlon LimitsH a t e r L o w Soil/Sediment(uq/l) (mq/kg)

CLP BASE/NEUTRALS (Continued)

3-N1troanU1ne SO 1,600Acenaphthene 10 330Olbenzofuran 10 3302,4-D1n1trotoluene 10 3302,6-D1n1trotoluene 10 330Dlethylphtnalate . 10 3304-Chlorophenyl Phenyl ether 10 330Fluorene 10 3304-N1troan1Hne 50 1,600N-n1trosod1pnenylam1ne 10 3304-Bromophenyl Phenyl ether 10 330Hexachlorobenzene 10 330Pnenanthrene 10 330Anthracene 10 330D1-n-butylphthalate 10 330Fluoranthene 10 330Pyrene 10 330Butyl Benzyl Phthalate 10 3303,3'-D1chlorobenz1d1ne 20 660Benzo(a)anthracene 10 330b1s(2-ethylhexyl)phthalate 10 330Chrysene 10 3300,1-n-octyl Phthalate 10 330Benzo(b) fluoranthene 10 330Benzo(k)f1uoranthene 10 330Benzo(a)pyrene 10 330Inoeno(l,2,3-cd)pyrene 10 330D1benz(a,h)anthracene 10 3308enzo(g,h,1)perylene 10 .330

6-3 AR300I75

APPENDIX I (Continued)

Quantltatlon LimitsHater Low Sol.1/Sediment(ug/1) (mg/kq)

CLP ACID EXTRACTABLES

Phenol 10 3302-Chlorophenol 10 3302-Methylphenol 10 3304-Methylphenol 10 3302-N1trophenol 10 3302,4-D1methylphenol 10 330Benzole Add 50 1,6002,4-Dlchlorophenol 10 3304-Chloro-3-methylphenol 10 3302,4,6-Trlchlorophenol 10 3302,4,5-Trlchlorophenol 50 1,6002,4-D1n1trophenol 50 1,6004-N1trophenol 50 1,6004,6-D1n1tro-2-methy)phenol 50 1,600Pentachloropnenol 50 1,600

CLP PESTICIDES/PCBs

alpha-BHC 0.05 8.0beta-BHC 0.05 8.0delta-BHC 0.05 8.0gamma-BHC (Llndane) 0.05 ,8.0Heptachlof 0.05 8.0Aldrln 0.05 8.0Heptachlor Epoxlde 0.05 8.0Endosulfan I 0.05 8.0Dleldrln 0.10 16.04,4'-DOE 0.10 • 16.0Endrln ' . 0.10 16.0Endi.t.ulfan II 0.10 16.0

fl_4 AR300I76

APPENDIX I (Continued)

Quantltatlon Limits

CLP PESTICIDES/PCBs (Continued)

4,4 '-ODDEndosulfan Sulfate4, 4 '-DOTEndrln KetoneMethoxychlorAlpna-chloroaneGama-chlordaneToxapheneAROCLOR-1016AROCLOR-1221AROCLOR-1232AROCLOR-1242AROCLOR-1248AROCLOR-1254AROCLOR-1260

Hater(ug/1)

0.100.100.100.100.50.50.51.00.50.50,50.50.51.01.0

Low Soil /Sealment(mg/kg)

16.016.016.016.080.080.080.0160.080.080.080.060.080.0160.0160.0

G"5 /IR300I77

BR300I78