GEI Consultants, Inc · gei consultants, inc . v. source control draft final project operations plan . volume i of iv site management plan and community relations support plan . 60

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VGEI Consu l t an t s , Inc

SOURCE CONTROL DRAFT FINAL PROJECT OPERATIONS PLAN

VOLUME I OF IV SITE MANAGEMENT PLAN AND COMMUNITY RELATIONS SUPPORT PLAN

60 PERCENT REMEDIAL DESIGN O'CONNOR COMPANY SUPERFUND SITE AUGUSTA, MAINE

Supervising Contractor: Settling Defendant:

GEI Consultants, Inc. Central Maine Power Company Suffolk Building Technical Services Department 53 Regional Drive 41 Anthony Avenue Concord, New Hampshire 03301-8500 Augusta, Maine 04330 (603) 224-7979 (207) 626-9620

Charles R. Nickerson, PE Senior Project Manager Technical Coordinator

February 13, 1995

This document was prepared by afour-member multi-discipline designteam assembled by Central Maine Power Company to complete remedial design for the O'Connor Company Superftmd Site. The design team member companies and their primary project contacts were asfollows:

Company Responsibility Project Contact

GEI Consultants, Inc. * Geoenvironmental Consultant Joanne O. Morin, LSP (Note: Supervising Contractor) Senior Project Manager

Central Maine Power Company Electrical, Mechanical, and Daniel E. Spaulding, P.E. Technical Services Department Structural Engineering Civil Engineer

Sargent Diversified Services Remediation Contractor David C. Jones (H.E. Sargent, Inc.) Project Manager

Woodard & Curran, Inc. Environmental Engineering Henri J. Vincent, P.E. Designer Senior Project Manager

This document was submitted pursuant to the Consent Decree in United States of America vs. Central Maine Power Company. Civil No. 90-Q302B, entered on September 3, 1991, and the Explanation of Significant Differences, approved and issued by U.S. Environmental Protection Agency on July 11, 1994.

*Denotes principal author (s) of document.

SC POP Volume I of IV Site Management Plan and Community Relations Support Plan 60 Percent Remedial Design Revision 0

TABLE OF CONTENTS VOLUME I

TABLE OF CONTENTS LIST OF TABLES LIST OF FIGURES

PAGE NO.

1. INTRODUCTION 1 1..1 Purpose of Project Operations Plan 1 1.2 Site Description and Background 1 1.3 Overview of Remedial Action 3 1.4 SC Remedial Action Elements 4

2. SITE MANAGEMENT PLAN 7 2.1 Introduction 7 2.2 Site Security and Access 7

2.2.1 General 7 2.2.2 Responsibilities 8 2.2.3 Site Access Control 8 2.2.4 Access Authorization and Identification 9 2.2.5 Monitoring Systems 9

2.2.5.1 Cameras 9 2.2.5.2 Alarms 9 2.2.5.3 Reporting 9

2.2.6 Other Security Procedures 10 2.3 Communications and Key Personnel 10

2.3.1 Remedial Action Management 10 2.3.2 Principal Remedial Action Contractors 11 2.3.3 Health and Safety Contractor 14 2.3.4 Independent Quality Assurance Team 15 2.3.5 Communications 15 2.3.6 Emergency Response 16 2.3.7 Financial Reporting 16

2.4 Emergency Response and Contingency Plan 16 2.4.1 Overview 17 2.4.2 Personnel and Responsibilities 17 2.4.3 Incident Prevention Systems 19 2.4.4 Types of Emergencies 19 2.4.5 Contingency Plan for Site Water Treatment System 23 2.4.6 Communications 24 2.4.7 Emergency Equipment and Personal Protective Equipment 25


2.4.8 Evacuation Plan 25 2.4.9 Copies of the Emergency Response Plan 26 2.4.10 Arrangements with Local Authorities 26

2.5 Air Quality Monitoring 26 2.5.1 Purpose 26 2.5.2 Background 28 2.5.3 Feneeline Monitoring 29

2.5.3.1 General 29 2.5.3.2 PCB-Based Feneeline Monitoring Limits 29

2.5.4 Ambient Air Monitoring Locations 30 2.5.4.1 Overview 30 2.5.4.2 Fixed Feneeline Station 30 2.5.4.3 Upwind and Downwind Feneeline Locations 31 2.5.4.4 Soil Handling Area 32 2.5.4.5 Soil Treatment Unit Area 33

2.5.5 Ambient Air Monitoring Weather Station 33 2.5.6 Ambient Air FM^ and/or TSP Monitoring Equipment and Specifications 34

2.5.6.1 Fixed Monitoring Location 34 2.5.6.2 Portable PM10 and/or TSP Monitoring Equipment 34

2.5.7 PM10 and/or TSP Data Reduction, Review and Management 35 2.5.7.1 Fixed Location Continuous Record 36 2.5.7.2 Portable PM10 and/or TSP Monitors 36

2.5.8 Ambient Air Quality Personnel Responsibilities 37 2.6 Management of Remediation-Derived Wastes 37

2.6.1 Summary of Remediation-Derived Wastes 37 2.6.2 Management of Remediation-Derived Wastes 38

2.6.2.1 Waste Waters and Non-aqueous Liquids 38 2.6.2.2 Waste Solids 39

2.6.3 On-site Storage Requirements 40 2.6.4 Waste Manifesting and Disposal 41

2.7 Records and Data Management 42 2.7.1 Introduction 42 2.7.2 Central Project Files 43 2.7.3 Verification Testing and Analysis Contractor Files 43

2.7.3.1 Project Filing 43 2.7.3.2 Data Management 44

2.7.4 Data 44 2.7.5 Database Management 45

3. COMMUNITY RELATIONS SUPPORT PLAN 46

TABLES FIGURES


LIST OF TABLES

Waste Stream Management Anticipated Quantities of Waste Streams

LIST OF FIGURES

Site Location Site Layout Sketch Site Utilization Sketch Plan Remedial Action Project Organization Remedial Action Contracting

SC POP Volume 1 of IV Site Management Plan and Community Relations Support Plan 60 Percent Remedial Design Revision 0 Page 1

1. INTRODUCTION

1.1 Purpose of Project Operations Plan

The purpose of this Source Control Remedial Action Project Operations Plan (SC POP) is to describe measures to assure that the goals for the Remedial Action are achieved. The contents of the SC POP are included in four separate volumes for ease of reference. Volume I of the SC POP contains the Site Management Plan (SMP) and the Community Relations Support Plan (CRSP). The purpose of the SMP is to describe contingency planning measures, for on-site workers and the local affected population. The purpose of the CRSP is to support the U.S. Environmental Protection Agency (EPA) and the Maine Department of Environmental Protection (DEP) in their efforts to provide information to the general public about the Remedial Action, including an educational program on the status of contamination in Riggs Brook.

Volume II of the SC POP contains the Site-specific Health and Safety Plan (HSP). The primary goal of the HSP is to ensure the health and safety of on-site personnel during the SC Remedial Action. Volume HI of the SC POP contains the Field Sampling Plan (FSP). The purpose of the FSP is to provide methods and procedures for collection of the data required to assure that the target cleanup goals have been met. Volume IV of the SC POP is the Quality Assurance Project Plan (QAPP), which describes analytical methods and procedures required to meet the data quality objectives of the sampling program elements.

1.2 Site Description and Background

The O'Connor Company Superfund Site (Site) is located along U.S. Route 17 near the eastern boundary of the city limits of Augusta, Maine (Figure 1). Previous salvage and transformer recycling activities by the F. O'Connor Company at the Site lead to uncontrolled releases of oil containing polychlorinated biphenyls (PCBs). The area to be remediated covers approximately nine acres within the 23-acre Site and is situated on the crest of a low ridge aligned parallel to the west branch of Riggs Brook.

Principal features on the property include a large barn that formerly housed scrap operations, an Upland Marsh, an adjacent, filled "Low Area", two surface water impoundments (Upper and Lower Lagoons), three former outdoor Transformer Work Areas (TWAs) and a former scrap storage area (Figure 2). Site drainage is principally controlled by the natural slope extending eastward from the crest of the ridge towards Riggs Brook and by man-made drainage features connecting the Upland Marsh on the top of the ridge to Riggs Brook ("Central Drainage"). Wetlands contiguous with the Riggs Brook wetlands are located in the southeastern portion of the Site.

SC POP Volume I of IV Site Management Plan and Community Relations Support Plan 60 Percent Remedial Design Revision 0 Page 2

Soil materials on the Site include topsoil, fill, glacial marine silty clay, and glacial till overlying bedrock. Fill materials in the Low Area consist primarily of sediments dredged from the Lagoons. Fill also includes much of the materials located in the TWAs and consist of more granular sediments which also contain debris from the transformer salvaging operations. Fill thickness generally ranges from approximately 1 foot to 3 feet.

The silty clay underlies the fill and is generally continuous over the entire Site. Fissures and desiccation cracks in the clay create a soil structure consisting of blocks ranging from approximately 1 to 12 inches on a side. Yellow staining in some fissures appears to be associated with PCB oil migration.

Till ranges from a thin veneer of coarse granular material overlying bedrock in the northern portions of the Site, to thicker layers of dense, fine-grained sediments overlying the bedrock surface in the central and eastern portions of the Site. The change in the observed textures of till are inferred to result from enhanced weathering of till in the northern portion of the Site, due to a lower water table than is observed in the central and eastern portions of the Site. The bedrock consists of a hard, slightly weathered, slightly to moderately fractured quartz mnnmnitp (granitic) rock, with localized seams of extremely weathered rock.

Remedial Pre-Design field studies were conducted from June 1991 through January 1993, as required under the Consent Decree. The results of the Pre-Design studies indicated that there was a significant increase in contaminated soil and sediment volume over 1989 estimates. Pilot-scale treatability studies indicated that solvent extraction technology cannot achieve the 1989 Record of Decision (ROD) target cleanup goals for PCBs and carcinogenic polycyclic aromatic hydrocarbons (cPAHs) in a technically feasible and/or attainable cost effective manner Based on the implementability and the new information developed since the ROD, the EPA adjusted the target cleanup goals for all soils which are to be located more than 12 inches below grade within a three- to four-acre Designated Area (Figure 2). As described in the an Explanation of Significant Differences (ESD) signed by the EPA on July 14, 1994, soil and sediment above target cleanup goals will be excavated, treated with solvent extraction technology, and placed in die Designated Area.

The target cleanup goals for the Designated Area are:

total PCBs - less than or equal to 10 parts per million (ppm) total cPAHs - less than or equal to 10 ppm lead - less than or equal to 248 ppm (no change)


The target cleanup goals for all areas outside the Designated Area are:

PCBs - less than or equal to 1 ppm cPAHs - less than or equal to 1 ppm lead - less than or equal to 248 ppm

1.3 Overview of Remedial Action

Soils and sediment containing greater than 10 ppm PCBs and 10 ppm cPAHs will be excavated, treated to the target cleanup goals with solvent extraction, and placed in the Designated Area.

Soils and sediment containing between 1 and 10 ppm PCBs or cPAHs located outside the Designated Area will be excavated and placed within the Designated Area without treatment. Soils within the Designated Area containing less than 10 ppm PCBs or cPAHs and less than 248 ppm lead will not be excavated.

Contaminated liquids produced during solvent extraction treatment that contain extracted PCBs, cPAHs and potentially lead, will be destroyed off-site at a licensed Toxic Substances Control Act (TSCA)/Resource Conservation and Recovery Act (RCRA) incinerator. Exhaust gases from the solvent extraction process shall be treated by air pollution control devices, as necessary, to ensure that health and safety and air quality requirements are met.

The top 12 inches across the entire excavated area of the Site will be replaced with clean fill from off-site sources. The clean fill will be re-vegetated. The clean fill/topsoil shall contain less than or equal to 1 ppm PCBs and 1 ppm cPAHs, and 248 ppm lead. Areas of wetlands disturbed by the remediation will be backfilled with 24 inches of clean, off-site fill suitable for sustaining growth of the desired wetlands vegetation.

If during full-scale implementation of the remedy, EPA determines that solvent extraction treatment is not feasible, then soil and sediment containing PCBs and cPAHs above the target cleanup goals will be transported off-site to a TSCA/RCRA hazardous waste landfill(s) without treatment.

Soil residues, after solvent extraction treatment, that contain lead concentrations above the 248 ppm 1989 ROD target cleanup goals will be transported off-site for land disposal. If this lead-contaminated soil exceeds the Toxicity Characteristic concentration for lead (5 ppm), then the soil will undergo further treatment using a stabilization treatment technology prior to off-site disposal in a licensed landfill.

Site restoration will include restoration of on-site wetlands and/or establishing compensatory wetlands that achieve an equivalent functional value of the wetlands not restored. The ROD also specifies decontamination, demolition and off-site disposal of the barn.


1.4 SC Remedial Action Elements

The SC Remedial Action includes both SC and Management of Migration (MOM) components. The SC portion of the remedy established in the ROD and modified by the ESD will include the following:

Site preparation will include clearing of vegetation and installation of erosion control measures. Most of the areas to be excavated are currently either bare or covered with grass, and brush or small trees.

» Surface water from the Upland Marsh, Upper Lagoon and Lower Lagoon will be pumped as necessary to excavate contaminated sediments. Water contaminated with hazardous substances will be treated on the Site and discharged to Riggs Brook, or disposed of off-site at a licensed facility.

• Surface water flow will be diverted from upstream of the Site to discharge to Riggs Brook during SC.

• The on-site barn will be decontaminated and demolished. Disposal of the demolished structure will be in accordance with TSCA and RCRA requirements.

- Soil and sediment containing greater than 248 ppm lead, or greater than 10 ppm PCBs or cPAHs within the Designated Area, and greater than 1 ppm PCBs or cPAHs outside of the Designated Area will be excavated and stockpiled.

Excavated soil and sediment containing greater than 10 ppm PCBs or 10 ppm cPAHs will be treated on-site with solvent extraction and backfilled on-site in the Designated Area, if they meet the target cleanup goals. Approximately 12,300 cy of soil and sediment contain contaminants above the target cleanup goals. This volume estimate includes contingencies of 50 percent for overexcavation and 20 percent for ex situ soil expansion. All of the soil containing greater than 10 ppm cPAHs also contains greater than 10 ppm PCBs and must be treated for PCBs. Soil containing greater than 248 ppm lead will be excavated and disposed of at a licensed landfill.

Soils and sediment containing between 1 ppm and 10 ppm PCBs or cPAHs located outside the Designated Area will be excavated and placed in the Designated Area without treatment. Soil and sediment located within the Designated Area that contain less than 10 ppm PCBs or cPAHs will be left-inplace without treatment.


Soils located in wetlands contiguous to Riggs Brook which contain greater than 5 ppm PCBs will be excavated and stockpiled. Soils with greater than 10 ppm PCBs or cPAHs will be treated to less than 10 ppm PCBs and cPAHs and placed in the Designated Area.

Excavation dewatering will be necessary to excavate contaminated soil located below the ground water table. Excavations may extend to approximately 10 feet below ground water through predominantly clayey soil.

Soil and sediment treated to the target cleanup goals will be backfilled within the Designated Area. Regrading to establish pre-existing drainage patterns will be performed.

Treated soil and sediment exceeding the Designated Area target cleanup goals of 10 ppm for PCBs or cPAHs will be transported off-site for disposal at a licensed landfill.

PCB- and ePAH- contaminated oil recovered during treatment will be transported to an off-site TSCA incinerator for destruction.

Soil containing greater than 248 ppm lead and exceeding the Toxicity Characteristic Leaching Procedure (TCLP) concentration for lead will be stabilized to reduce the mobility of the lead. Most of the soil containing greater than 248 ppm lead also contains greater than 10 ppm PCBs, and must be treated for PCBs. Soil and sediment to be stabilized will be transported to a licensed, off-site TSCA/RCRA facility for stabilization and disposal. Soil containing greater than 248 ppm lead but not exceeding the TCLP concentration for lead will be disposed off-site at a licensed landfill without stabilization.

Site restoration will include replacement of the top 12 inches of the entire excavated area with clean Ell and topsoil which shall contain less than or equal to 1 ppm PCBs and cPAHs, and 248 ppm lead. Areas of on-site wetlands located within contaminated portions of the Site will be covered with 24 inches of clean fill suitable for wetlands restoration.

Wetlands disturbed by remedial activities will be restored in place to their current functional value. Compensatory wetlands will also be established.

A five-year review of Site conditions will be performed, as appropriate.

In addition to the SC portion of the remedy, MOM (ground water recovery, treatment with granular activated carbon, and on-site discharge) activities and Riggs Brook Wetlands monitoring


are included in the ROD. Procedures for performing MOM activities will be included in a separate MOM Remedial Action POP.

In addition to the above considerations, the Site is located adjacent to a heavily-travelled State road and several residential properties. Operational considerations will include dust control, noise levels, impacts to traffic, potential odors, and general public safety and perception issues. The area available for treatment operations is limited due to Site layout and the area requiring excavation. Space limitations will also restrict the ability to stockpile soil throughout the SC Remedial Action: before treatment; after treatment pending backfill (if meeting all target cleanup goals); and after treatment pending off-site disposal (if failing any target cleanup goals). Consequently, excavation, treatment, and backfill of treated material will need to be a continuous operation.


2. SITE MANAGEMENT PLAN

2.1 Introduction

The SMP addresses the need to control personnel and contaminants on the Site during Remedial Action in an orderly fashion so that the elements of the Remedial Action Work Plan can be completed in a timely, effective, organized, and safe manner. Specific components of the SMP are:

• Site Security and Access

• Communications and Key Personnel

Emergency Response and Contingency Plan

• Air Monitoring Plan

• Waste Disposal

° Records and Data Management

The purpose of the SMP is to provide clear procedures to control and manage-

project personnel or members of the public when they enter or leave the Site;

• contaminants when they leave the Site, either intentionally as approved wastes or unintentionally as fugitive emissions;

• emergency procedures;

communications (both on-site and off-site); and

• record keeping.

2.2 Site Security and Access

2.2.1 General

The purpose of Site security is to prevent the exposure of unauthorized, and unprotected people to the Site hazards; avoid the increased hazards from vandals; prevent theft; and avoid interference with safe working procedures.


2.2.2 Responsibilities

The Remedial Action Supervising Contractor shall have the overall responsibility for maintaining security on-site. Site security will be maintained 24 hours a day during Site operations by a Security Contractor. The Security Contractor will report directly to the Remedial Action Supervising Contractor.

The Security Contractor shall be responsible for:

maintaining security at the primary Site access control point;

monitoring alternate access control points, maintaining daily logs and records, and monitoring alarm systems;

• establishing a system to identify authorized personnel and ensure Site visitors are accompanied by authorized personnel;

coordinating Site communications with the Remedial Action Supervising Contractor, notifying local authorities of security problems; and

completing daily logs, incident reports, and weekly summary reports.

Responsibilities of contractors, Site personnel, and Site visitors include:

• signing in on the daily log,

• notifying security of the planned use of alternate access points, and

notifying security of any incident related to the security of the Site.

2.2.3 Site Access Control

Access to the Site will be controlled by a combination of three measures: access control points, fencing, and security personnel. One primary, and two alternate control points will be located along Route 17. Fencing will be erected that surrounds the working areas of the Site. A security station will be located at the primary access control point. All personnel and visitors will be required to log in at the security station. Figure 3 shows the locations of Site access control features. These locations may be revised during the 95 percent Remedial Design.

Access control points will remain locked when Site operations are not being performed. Each of the four Principal Contractors, the Remedial Action Supervising Contractor, and


Security personnel shall have keys to the access control points. Key personnel and Principal Contractors are described in Section 2.3.

2.2.4 Access Authorization and Identification

Each contractor and governmental agency shall provide a list of names of personnel authorized to work on the Site. Personnel entering the Site shall identify themselves to security personnel before access to the Site. Site visitors shall provide their name, who they are representing, positive identification, and be approved for access by the Remedial Action Supervising Contractor prior to accessing the Site. All persons entering the Site shall provide proper documentation of the appropriate health and safety training and medical monitoring.

2.2.5 Monitoring Systems

2.2.5.1 Cameras

The use of video camera monitor systems may be necessary to aid in the control of the Site. Two preliminary camera locations have been tentatively identified. One may be located in the northern corner of the fenced area, and the second located between the Lower and Upper Lagoons. If video camera systems are not necessary, then a routine program of inspection of the Site shall be established by the Remedial Action Supervising Contractor and security personnel.

2.2.5.2 Alarms

Alarms systems will be established based on the various operations on-site, including high water alarm for storm water treatment, and emergency system monitoring alarms for solvent extraction treatment. Alarm signals shall be relayed to the security station during Site operations. Other alarm systems may be established based on the emergency contingencies systems established in coordination with local emergency services during 95 percent Remedial Design.

2.2.5.3 Reporting

A daily sign-in log containing the signatures of personnel who have entered the Site shall be maintained at the security station. A Site control log consisting of a report on the condition of the Site during routine inspection shall be maintained daily. Incident reports shall be completed whenever an incident occurs and shall contain the nature and description of the incident, along with any control measures taken. A weekly summary of logs and incident reports shall be provided to CMP for review.


2.2.6 Other Security Procedures

Internal and external communication systems, such as two-way radios and telephone, shall be maintained at the security station and by the security personnel Routine procedures, other than those previously identified, shall be established in more detail by the Security Contractor in coordination with the Remedial Action Supervising Contractor.

Communications and Key Personnel

2.3.1 Remedial Action Management

CMP will use a "construction management" project delivery system to complete the Remedial Action work at the Site. The concept of construction management is defined as the coordinated effort of the owner, the Construction Manager, and the Principal Contractors working together to achieve a final product which is on schedule and within budget. The Remedial Action Supervising Contractor will act as the Construction Manager during the SC Remedial Action.

The Remedial Action Project Organization for the Site will be as shown on Figure 4. CMP intends to manage the Remedial Action by separating the project into three phases: 1) Source Control, 2) Management of Migration, and 3) Riggs Brook Monitoring.

CMP's Technical Services Department (TSD) will provide the construction management services for the Remedial Action in the role as the Remedial Action Supervising Contractor. The TSD has a staff of 60 people, including 25 professional engineers, 3 licensed surveyors, 23 technicians, and 10 clerical and support staff. TSD personnel have worked on a variety of projects ranging from research and development of innovative technologies, contaminated site remediation, to traditional civil, mechanical and electrical work. The TSD has extensive knowledge in the planning, design, project management, construction management and inspection of power plants, substations, transmission lines, and office facilities. The TSD currently has 8 people that are trained in Hazardous Waste Operations in accordance with 29 CFR §1910.120.

Since the early 1970's the TSD has utilized the construction management project dielivery system on its design and construction projects to control the cost, scheduling, quality, safety and environmental impacts. On each project, a qualified site manager, supported by a professional staff, is appointed to provide the construction management services. Professional support staff represent CMP's Purchasing, Environmental and Licensing, Legal, Safety, and Risk Management Departments. As the Construction Manager for the Site, TSD's responsibilities would include:


• Providing management expertise in monitoring performance of the principal contractors and subcontractors, controlling schedules, and overseeing financial accounts.

° Monitoring the performance of the sampling and analysis program and the quality assurance/quality control (QA/QC) program to ensure that they are being carried out as intended.

® Keeping the Project Coordinator informed of budget and schedule matters.

Monitoring of production rates towards established milestones for completion of all phases of the work to assure timely completion.

« Maintaining accurate logs and records of project activities.

• Establishing methods for resolving conflicts and taking the lead to see that conflicts are resolved as quickly and expeditiously as possible.

• Evaluating problems and processing change orders as appropriate.

• Approving bills and invoices in a timely manner and processing them for payment.

• On-site interaction with regulatory agencies.

• Preparation and execution of manifests for shipment of hazardous materials.

2.3.2 Principal Remedial Action Contractors

Management of the SC phase of the Remedial Action will require contractual agreements between the Project Coordinator and the following four Principal Contractors: Site Work Contractor; Solvent Extraction Contractor; Waste Disposal Contractor; and Verification Testing and Analysis Contractor. Figure 3 lists the areas of responsibility for each of the SC Principal Contractors.

Site Work Contractor

The Site Work Contractor for the SC Remedial Action will be responsible for numerous activities as shown on Figure 5. Although the successful completion of all these activities is very important to the Remedial Action, the crucial element in selecting the


Site Work Contractor will be the ability to conduct the required earth moving operations to support the Solvent Extraction Contractor. During the prequalification stage of contracting (performed concurrently with 60 percent Remedial Design), CMP evaluated each prospective Site Work Contractor to ensure that they have the required earthmoving experience, experienced and trained personnel with a proficiency in hazardous waste operations, and adequate resources to support the SC remediation. The Site Work Contractor will be the first contractor on-site to begin the Site preparation phase, and will remain on-site for the duration of the SC Remedial Action until Site restoration for SC is complete.

Solvent Extraction Contractor

The Solvent Extraction Contractor will be responsible for the soil treatment system. The contaminated soils and sediments which meet the specified pre-treatment performance criteria, will be prepared and furnished to the Solvent Extraction Contractor by the Site Work Contractor. After the soil treatment process is completed, the treated soils and sediments meeting the specified post treatment performance criteria will be returned to the Site Work Contractor. Materials which do not meet their respective target cleanup goals will require off-site disposal.

The Solvent Extraction Contractor will begin mobilization of their facility as early as practicable so as to be ready to start the soil treatment process early in the second construction season. The treatment process will then run 24 hours a day, 7 days a week until all contaminated soils and sediments have been treated.

SC Verification Testing and Analysis Contractor

Engineering and consulting members of the Remedial Design Team will be contracted to provide QC and QA oversight of the Remedial Action in the role of the Verification Testing and Analysis Contractor. A risk assessment consultant will also be added to the team to provide risk assessment services, if needed. The Verification Testing and Analysis Contractor will include:

• GEI Consultants, Inc. (Geoenvironmental Design Firm);

• Woodard & Curran Environmental Services (Environmental Design Firm);

The Smart Associates Environmental Consultants, Inc. (Wetlands Consultant); and

Alceon Corporation (Risk Assessment Consultant).


The Verification Testing and Analysis Contractor will be responsible to conduct all testing and analysis in accordance with the Remedial Action Sampling and Analysis Plan (SAP).

It is anticipated that the Verification Testing and Analysis Contractor will establish a chemical laboratory facility on-site to conduct the routine testing and analysis. Periodically, analytical results from the on-site laboratory will be correlated to an off-site laboratory. On-site laboratory facilities will be set up and staffed to provide adequate turn around times for all testing and analysis results.

Non-chemical (e.g., geotechnical) testing will be provided by the Verification Testing and Analysis Contractor. Outside laboratories will be subcontracted to provide additional testing and analysis, as needed.

Waste Disposal Contractor

The Waste Disposal Contractor will be responsible for the transportation and off-site disposal of waste(s) generated on the Site. Wastes generated on the Site may include but are not limited to:

• Debris (Barn decontamination and demolition materials, debris segregated from on-site soils, and miscellaneous debris);

» Debris decontamination residues;

» Soils containing greater than 248 ppm of lead;

Soils containing greater than 10 ppm PCBs or cPAHs;

• Extract generated by solvent extraction treatment;

° Discharge from storm water treatment system;

• Wastes generated by on-site treatment of storm water;

Wastes generated by closure of work areas constructed for the Remedial Action;

• Personal protective equipment and other disposable equipment;

Decontamination wastes;


• Waste generated by the on-site laboratory; and,

• Sanitary wastes.

Due to the different waste streams that will be generated, it is anticipated that more than one waste disposal facility will be contracted to meet the needs of the Site. Before a waste disposal facility is chosen an extensive audit of the contractor's facility and parent organization will be conducted, if necessary. The audit will review:

Waste Handling Systems/Operations;

• Facility Design, Safety and Security Systems;

• Location;

• Facility History;

Environmental Management;

Regulatory Compliance Record; and

a Financial Status.

2.3.3 Health and Safety Contractor

The Health and Safety Contractor will be a health and safety specialist responsible for:

• Updating the Site Health and Safety Plans as needed.

• Auditing Site activities to assess compliance with the Site Health and Safety Plans.

Monitoring Site environmental conditions and providing recommendations to the Remedial Action Supervising Contractor.

Reporting health and safety violations to the Remedial Action Supervising Contractor.


2.3.4 Independent Quality Assurance Team

The Independent Quality Assurance Team (IQAT) will be contracted directly by the Project Coordinator, and will provide independent review of all contractors and consultants involved in the remediation including the field personnel managing the remediation.

The IQAT has the following responsibilities during the Remedial Action:

• Monitor and audit Construction Quality Assurance (CQA) inspection personnel on project QA requirements and procedures.

Schedule and coordinate CQA inspections.

• Verify that the QC plan for construction activities is implemented in accordance with the Site-specific plan.

• Perform independent on-site inspections of the work to assess compliance with the approved design criteria plans and specifications.

• Report results of all inspections, including findings when the work is not of acceptable quality or fails to meet the specified design requirements, to CMP and EPA.

At this time, it is anticipated that IQAT personnel will:

• Make Site visits to observe representative portions of the Remedial Action for the duration of construction activities to confirm that work is being performed in accordance with plans, specifications, and applicable regulations.

o Review and comment on construction reports before the reports are sent to EPA.

• Spot check analytic data and resulting decisions made by Site personnel regarding limits of excavation and classification of waste.

• Perform QA field audits as identified in the QAPP.

2.3.5 Communications

As indicated on Figure 4, the Project Coordinator will be the point of contact for the EPA and DEP. The Remedial Action Supervising Contractor will be represented by the


Construction Manager, who will report to the Project Coordinator. All on-site communications between Principal Contractors will be coordinated by the on-site Construction Manager. Daily Site meetings will be used to review health and safety issues, work progress, and any other concerns. Key personnel for each Principal Contractor will be identified in the Remedial Action Work Plan. Overall work assignments will be given by the Remedial Action Supervising Contractor Construction Manager on a daily basis.

Communications between the Project Coordinator and the public, are addressed in Section 3 of the SMP.

Sampling and analysis data collected by the Verification Testing and Analysis Contractor directly affect the work performed by the Site Work Contractor and the Solvent Extraction Contractor. Therefore, the Verification Testing and Analysis Contractor will report to the Remedial Action Supervising Contractor.

• the required extent of excavations based on sampling and analysis data;

• the results of treated soil analyses and recommendations for further soil treatment, off-site disposal, or placement in the Designated Area;

• the results of all sampling of wastes to be disposed or treated off-site; and

• the status and results of the air monitoring program (see Section 2.5 of the SMP).

The IQAT and Health and Safety Contractor, while on-site, will report to the Remedial Action Supervising Contractor only. The Remedial Action Supervising Contractor will be responsible for communicating and implementing any recommendations with all contractors. The exception to this will be in the case of activities that the Health and Safety Contractor feels are an imminent threat to human health and safety. In addition, the IQAT will report all evaluations and recommendations to the Project Coordinator.

2.3.6 Emergency Response

Communications relative to emergency responses are detailed in Section 2.4.

2.3.7 Financial Reporting

This section will be developed during the 95 percent Remedial Design.


Emergency Response and Contingency Plan

2.4.1 Overview

The Emergency Response Plan is intended to provide a link between the activities at the project Site and the local emergency response organizations and to provide procedures for a coordinated response by Site personnel with local response organizations. A copy of the Site Emergency Response and Contingency Plan, and the Site-specific Health and Safety Plan, will be provided to appropriate local emergency response organizations. The emergency procedures within the Emergency Response Plan will minimize the impact of an emergency or unusual occurrence upon the health and safety of personnel at the Site. These emergency procedures also identify the work force and equipment resources available to cope with industrial and natural emergencies.

2.4.2 Personnel and Responsibilities

Emergency Coordinator

In the event of an emergency, the Remedial Action Supervising Contractor or designee will serve as the Emergency Coordinator and will be responsible for control of the Site. Alternate Emergency Coordinators will be identified in the event that the Primary Emergency Coordinator is unavailable. Emergency Coordinators must be available for rapid access by on-site personnel in the event of an emergency.

Whenever there is an imminent or actual emergency situation, the Emergency Coordinator shall immediately:

Control entry of personnel into the affected area.

• Activate internal Site alarms or communication systems, where applicable, to notify all Site personnel.

Identify the characteristics, source, amount, and extent of any released materials, if possible.

• Direct emergency response personnel.

• Ascertain who is on the Site.

• Notify appropriate state or local agencies with designated response roles if their assistance is needed.


The Emergency Coordinator shall take all reasonable measures necessary to ensure that fires, explosions, and releases do not occur.

The Emergency Coordinator shall:

• Be identifiable to local emergency response personnel.

• Be backed up with specified alternate.

° Have authority to resolve any emergency safety and health problems with the assistance of the Health and Safety Contractor.

• Be authorized to obtain emergency equipment and supplies, as needed.

• Have control of personnel entering that portion of the Site within the emergency area.

Project Coordinator

The Project Coordinator has the overall responsibility for the project. He shall ensure that adequate staff and resources are available to conduct an effective emergency response program.

Remedial Action Supervising Contractor

The Remedial Action Supervising Contractor is responsible for coordinating and implementing the Emergency Response Plan. The Remedial Action Supervising Contractor and the Emergency Coordinator shall be familiar with all aspects of the Emergency Response Plan, operations and activities of the Site, the location and characteristics of materials on-site, the location of all records, and the Site layout. He has the authority to commit resources needed to carry out the activities of the Emergency Response Plan.

Site Health and Safety Officer

The Site Health and Safety Officer will assist the Emergency Coordinator to identify the extent of the emergency situations that could arise at the Site, and to identify the primary personnel who will be prepared to immediately respond to Site emergencies.


Security Officer

The Security Officer shall be responsible for monitoring alarm systems, communications from on-site personnel, and notifying the local emergency response organization(s).

Emergency Contacts

Emergency contacts consisting of a responsible person, an alternate, and contact numbers shall be identified for on-site Emergency Coordinators, each local response organization, each on-site contractor, and appropriate governmental agency.

2.4.3 Incident Prevention Systems

Incident prevention systems shall be identified for handling hazardous materials on-site. Systems shall be dependent upon on-site operations and activities. Each contractor shall identify the incident prevention system appropriate for their hazardous and flammable materials.

2.4.4 Types of Emergencies

A variety of emergencies, including work-related emergencies, Site-related emergencies, and natural phenomena could occur at the Site, such as:

Occupational

• Personal injury or fatality;

• Property damage;

Environmental release; and

• Personnel exposure.

Site Related

• Fire;

• Unplanned water discharge;

Hazardous substance spill;

Explosion;


• Release of vapors/dust; and

• Chemical reactions.

Natural Phenomena

• Earthquake;

• Tornado/hurricane;

• Electric storms, winds;

Floods/high water; and

• Snow/blizzards.

Threats and Civil Disorders

• Bomb threats;

• Sabotage; and

Unauthorized entry, vandalism or theft.

Procedures for responding to some of these emergencies will need to be developed with assistance from local emergency response organizations and will be presented in the 95 percent submittal. In addition, coordination with the Solvent Extraction Contractor will be required.

Life Threatening Iniurv or Illness

For any life threatening injury or illness for any situation where immediate primary medical attention iis necessary, medical care will take precedence over decontamination. Decontamination shall only be performed if it does not delay medical care or adversely affect the injured person. Medical personnel will be advised of the possible contamination.

First aid assistance will be administered by individuals trained and certified. Each contractor on Site shall have a member of their project team who is first aid and CPR-trained and certified. A location shall be set aside in a clean and safe area, with appropriate first aid provisions for the care of personnel in the event of injury.


Serious Injuries

Serious or emergency injuries require that an individual be stabilized to reduce the risk of shock. An ambulance shall be summoned and the victim transported to the hospital.

Injuries with Contamination

Upon notification of an injury on-site, the Site Health and Safety Officer or designated representative shall he summoned to the injured individual to supervise the hazardous materials monitoring and decontamination.

Minor Injuries

Minor injuries to personnel may be treated using first aid kits located on-site

Fire Fighting

An attempt will be made to extinguish small fires with portable fire extinguishers. Personnel using these devices shall be trained in their use. Fires that cannot be readily controlled will be immediately reported to the local fife department. If a fire cannot be extinguished with a portable extinguisher, personnel shall immediately evacuate the area.

On-site fifes, no matter how seemingly insignificant, must be reported to the Emergency Coordinator. The Emergency Coordinator, or designee, shall be required to interface with the fire department as it arrives on-site.

Hazardous Materials Spill

Spills could occur during liquid transfer, including hazardous materials loading, equipment fueling operations, and vehicle accidents. A spill could contaminate receiving surface water, ground water or cause a release of vapors to the air. A fuel spill could ignite. A small spill which can be controllable immediately by routine methods should be cleaned up without the activation of this contingency plan, unless the odor level is significant in the area of the spill.

The Emergency Coordinator will direct emergency activities to contain the spill and ensure that all safety and health equipment and supplies needed for a spill are readily available and properly used. The Site Health and Safety Officer shall be responsible for providing the Emergency Coordinator with technical information.


During hazardous materials spill cleanups, the Site Health and Safety Officer shall:

• Monitor for exposures to chemical contamination.

• Determine the need for protective equipment and apparel.

• Identify the restricted work area and controlled access areas.

The Emergency Coordinator shall be responsible for directing subcontractor work crews. The Site Health and Safety Officer shall remain at the spill scene during target cleanup goals activities, until the scene is secured.

When the emergency response plan is activated, the spill area will be surrounded with absorbent material. If a flammable material is spilled, all nearby ignition sources will be shut down. The appropriate measures for the removal of the spilled material will be determined by the Emergency Coordinator and the Construction Manager

Personnel not involved in the target cleanup goals activities will be excluded from the immediate area. The Emergency Coordinator and Site Health and Safety Officer will make a determination as to whether additional personal protective equipment, fire fighting equipment or evacuation is required based upon direct-reading instrumentation air monitoring data.

The Emergency Coordinator will determine when outside assistance is required and make the necessary notifications. When the situation is under control, the Emergency Coordinator Will notify the Construction Manager that the contingency plan was implemented. When the spill has been completely cleaned up, an "All Clear" signal will be given. The "All Clear" signal may be communicated by radio, in person, or by air horn blast. All spill response supplies shall be replenished as soon as possible.

Flammable Gases

Flammable gasses will include solvent extraction chemicals, cleaning solvents, and fuels. Concentrations equal to or greater than 20 percent of the Lower Explosive Limit at the Site will result in the immediate evacuation of personnel from the affected area. The Site Health and Safety Officer will determine when personnel can safely return. Vapor release higher than background at the perimeter of the Site shall be reported to the Construction Manager.


Natural Phenomena

The Emergency Coordinator and the Site Health and Safety Officer are responsible for reacting and handling as much as possible, any potential emergency situation. These may include lightning storms, high winds, or extremes in temperature.

Additional details will be provided for other possible emergency situations during 95 percent Remedial Designing after consultation with local emergency organizations.

2.4.5 Contingency Plan for Site Water Treatment System

The proposed contingency plan includes both equipment and operation procedures. Backup equipment is needed to ensure the pump station and treatment system are fully operational and operating procedures are necessary to prepare for water flows greater than the design basis.

Equipment

The following equipment and structures are proposed as part of the contingency plan

• The main process and chemical feed pumps will have piped backups or shop spares. >

• The activated carbon system will have two columns piped in series with each column providing 100 percent of the required carbon and hydraulic retention time.

• A backup generator will provide power in the event of a line power failure.

• The lagoons will be designed with freeboard which may be used for additional storage if necessary.

The Lower Lagoon or associated pump station will have a controlled overflow that will measure and sample water that overflows the lagoon storage system.


Operation Procedures

The following operating procedures are recommended as part of the contingency plan.

Weather reports for the upcoming week would be monitored by the Remedial Action Supervising Contractor to provide enough time to prepare for unusually large storm events.

0 If the storage lagoon reaches the high level mark, plastic tarps will be used to cover bare ground so that runoff could be drained to a clean area. The Site Work Contractor will supply and store the tarps.

• Pumps supplied by the Site Work Contractor will be used to pump water from the storage lagoons to open excavations.

A contract with a trucking company will be developed to ensure tankers would be available for temporary storage of water. The Site Work Contractor will supply the pumps and piping to fill the trucks.

2.4.6 Communications

On-site Communications

An on-site communication system (e.g., radios, alarms, colored flags, hand signals) shall be established to alert workers to danger, convey safety information, and maintain Site control. Radio contact will be maintained between the Remedial Action Supervising Contractor, Security, the four Principal Contractors, and the Waste Disposal Contractor. All on-site personnel shall have air-horns available to signal other on-site personnel of an emergency or need for assistance. One long continuous blast will signal the need to evacuate the Site, and short repeated blasts will signal the need for assistance.

Off-site Communications

The Site Health and Safety Officer will ensure that all Site personnel are familiar with the procedure for contacting local emergency response organizations. When reporting an emergency situation, the following information will be provided:

Name or person making call;

° Telephone number and location of person making call;

• Nature of the emergency;


• Name(s) of person(s) exposed or injured (if any);

• Actions taken; and

• Name and location of Site contact for emergency, if other than caller.

2.4.7 Emergency Equipment and Personal Protective Equipment

The Remedial Action Supervising Contractor, with assistance from the Site Health and Safety Officer, shall ensure that basic emergency equipment and supplies are available and are in good condition at the work Site.

The following emergency equipment shall be available at the work Site:

• First aid kit (36 man, including chemical burn kit);

• Emergency oxygen kit;

Three Self-Contained Breathing Apparatus (SCBA) units;

Portable, pressurized eyewash with hand-held shower;

• Hand-held compressed air horns;

• Appropriate spill cleanup supplies and equipment, including absorbent materials, reclaim drums, and shovels; and

Fire extinguishers and stretcher.

In addition, the standard personal protective equipment for the Site will be available for use in the event of an emergency. This equipment includes:

• Chemical cartridge respirators; and

• Chemical resistant coveralls, gloves, and boots.

2.4.8 Evacuation Plan

The Site Health and Safety Officer shall make Site personnel aware of evacuation routes (primary and alternates) and take a head count should evacuation be necessary. In the event of the need for community evacuation, the Emergency Coordinator will inform the local police and other local authorities of the emergency. Information provided will


include information about the release or spill such as the type of material, quantity, Site wind direction, and any other useful information that will assist with the evacuation. The Emergency Coordinator must be available to help local and other agency officials decide what areas should be evacuated.

2.4.9 Copies of the Emergency Response Plan

A copy of the Emergency Response Plan and any revisions to the Emergency Response Plan shall be:

• Maintained on-site; and

• Submitted, as appropriate, to all local police departments, fire departments, hospitals, and state and local emergency response teams that may be called upon to provide emergency services.

2.4.10 Arrangements with Local Authorities

Arrangements will be made to coordinate with and familiarize the police, fire department, and emergency response teams with the layout of the Site, properties of hazardous waste handled and associated hazards, places where on-site personnel would normally be working, entrances to roads inside the facility and possible evacuation routes.

The local hospital will be made familiar with the properties of the hazardous materials handled at the Site and the types of injuries or illness that could result from fire, explosion or releases. Copies of Material Safety Data Sheets shall be provided to hospital and other local emergency response entities.

Air Quality Monitoring

2.5.1 Purpose

The air quality monitoring program is established in accordance with the requirements set forth in the ROD and the Revised Statement of Work (RSOW) to monitor levels of airborne contaminants released during Site SC remedial activities. The purposes of the air quality monitoring program are to alert remedial personnel to the potential of adversely affecting off-site abutters and to document compliance with risk-based monitoring limits established for the Remedial Action.


The air quality monitoring program:

• Establishes measurable, threshold monitoring limits for airborne contaminants acceptable in air at the fenceline boundary of the Site which are protective of human health in off-site air pathway receptor populations;

Identifies the air monitoring instrumentation capable of real-time measurements to verify attainment of the fenceline monitoring limits;

• Establishes a monitoring protocol logic to determine appropriate sampling locations, frequency and mode of air monitoring, contingent on daily Site remedial activities and meteorological conditions;

» Establishes an air monitoring data reduction, review, and management system to providie on-site management personnel with timely access to the air monitoring results; and

» Establishes a clear chain-of-communication and chain-of-responsibility to react to the air monitoring results.

The ambient air quality monitoring program for SC Remedial Action at the Site is based on the following documents:

EPA guidance set forth in Guidance On Applying the Data Quality Objective Process For Ambient Air Monitoring Around Superfund Sites: Stages I & n, EPA-450/4-89-015, August 1989; and Stage m, EPA450/4-90-005, March 1990;

Focused Public Health Risk Assessment for Soil and Sediment Remediation of the F. O'Connor Superfund Site, by Alceon Corporation (Alceon) of Cambridge, Massachusetts, dated January 2, 1992;

• A draft letter by Alceon summarizing development of Site-specific, risk-based air monitoring limits for dust bearing PCBs (1995 Risk Assessment), to be finalized and included in the 95 percent submittal as an appendix;

State of Maine's Guidance Manual for Human Health Risk Assessments at Hazardous Waste Sites. June 1994; and


State of Maine's Interim Ambient Air Guidelines February 1991 and January 1993.

2.5.2 Background

The 1992 Focused Public Health Risk Assessment for Soil and Sediment Remediation of the F. O'Connor Sunerfiind Site (1992 Risk Assessment) evaluated potential health risks to abutters from the principal Site contaminants lead, PCBs, and cPAHs. Because these chemicals have low or very low vapor pressures, they are most readily transported in absorbed to particulate matter (measured either as respirable particulate matter, which is defined as particles with an aerodynamic diameter of less than 10 microns, abbreviated as PM10; or as total suspended particulates, defined as all particles suspended in ab, abbreviated as TSP). Consequently, the 1992 Risk Assessment focused on potential risks to off-site receptors exposed to Site chemicals sorbed to fugitive dust emissions as a result of proposed remedial activities.

As part of the 1992 Risk Assessment, Alceon performed ab dispersion modeling based on EPA guidance and meteorologic data from Augusta to identify the off-site receptor which would potentially receive the greatest exposure to fugitive dust from the Site. The results of the ab dispersion model indicated that residents living approximately 0.2 km west of the Site would have the highest exposure. The Ab Quality Monitoring Program presented in this SMP, therefore, focuses on protecting the residents living approximately 0.2 km west of the Site from Site chemicals sorbed to fugitive dust.

The 1992 Risk Assessment concluded that the most important Site contaminant

contributing to the total Incremental Lifetime Cancer Risk from fugitive dust during the SC Remedial Action at the Site is PCBs. The 1992 Risk Assessment also concluded that

none of the non-cancer health hazard indices exceeded a value of 1.0, the Superfund guideline.

The 1992 Risk Assessment derived fenceline action levels for SC remedial activities using modeled estimates for dust generation during typical earth-moving activities. Action levels based on State of Maine Interim Ambient Ab Guidelines were developed for particulates and for fugitive dust bearing cPAHs and lead, but not for PCBs. Because the State of Maine has not published an ambient ab guideline for PCBs and because the 1992 Risk Assessment concluded that the largest potential risk to off-site abutters during remediation was from exposure to PCBs, Alceon in 1995 derived risk-based monitoring limits for PCBs in fugitive dust using available State of Maine and EPA guidance. The 1995 Risk Assessment relied on modeled data and meteorotogical information developed as part of the 1992 Risk Assessment.


Chemical-specific Federal or State of Maine Applicable or Relevant and Appropriate Requirements (ARARs) for ambient air pathway exposures to concentrations of PCBs have not been established.

The Site-specific fenceline monitoring limits for fugitive dust bearing PCBs are discussed in Section 2.5.3. Although the 1992 Risk Assessment derived action levels for cPAHs and lead, the monitoring limits for fugitive dust bearing PCBs are more protective (i.e., are lower in concentration) than the levels for cPAHs and lead. Consequently, only the monitoring limits for PCBs are addressed in Section 2.5.3.

2.5.3 Fenceline Monitoring Limits

2.5.3.1 General

Alceon developed PCB-specific fenceline air monitoring limits based on estimated concentrations of PCBs in fugitive dust. The estimated concentrations rely on the extensive data set compiled during Remedial Investigation and Pre-Design phases. This approach allowed calculation of fenceline air monitoring limits for PCBs expressed and measured as equivalent concentrations of either PM10 (i.e., respirable dust) or TSP (total suspended particulates).

2.5.3.2 PCB-Based Fenceline Monitoring Limits

Alceon determined that two different exposure pathways could present risks to off-site abutters from fugitive dust: inhalation of dust and ingestion of vegetables grown in topsoil on which fugitive dust may be deposited. The two pathways have the following monitoring limits:

° Inhalation Pathway = 1,175 Mg/m3 PM10

Ingestion Pathway = 2,126 ^g/m3 TSP

Because these monitoring limits are risk-based, they represent a weighted average concentration for the duration of the entire project. The actual monitoring period over which a time-weighted average will be measured for use in Site management decisions will be determined during 95 percent design, but will likely be 24 horns.

In order to facilitate field implementation of measuring ambient fugitive dust concentrations, an evaluation will be performed during 95 percent design to determine whether the PM10 or the TSP monitoring limit can be clearly shown to be the more protective level. If that determination can be made, then the more


conservative parameter will be monitored in the field and will form the basis of all time-weighted average fenceline air quality measurements.

.4 Ambient Air Monitoring Locations

2.5.4.1 Overview

Ambient air monitoring for fugitive dust will be performed at the following five locations:

a permanent fenceline station adjacent to the residence just west of the Site, as discussed in Section 2.5.2 above;

a fenceline station selected daily to be located upwind of SC activities most likely to be generating fugitive dust from contaminated areas;

a fenceline station selected daily to be located downwind of SC activities most likely to be generating fugitive dust from contaminated areas;

• optional monitoring at auxiliary stations located within and around the various soil handling areas to help Site managers evaluate, anticipate* and control the release of fugitive dust to meet fenceline monitoring limits; and

• optional monitoring adjacent to the soil treatment unit, depending upon emissions encountered during remedial activities from the treatment unit.

Each of these locations is discussed in detail in the sections following

2.5.4.2 Fixed Fenceline Station

A continuously reading air monitor will be permanently stationed at the fixed fenceline location determined by Alceon's air dispersion modeling as being adjacent to the off-site receptor with the greatest potential exposure. As discussed in Section 2.5.7.1, this station will be used to evaluate air quality relative to the monitoring limits established for fenceline air quality.


The fixed fencelihe air monitoring station will be housed on an accessible, open-sided, covered platform approximately 10 feet off the ground just inside the Site fenceline at the location shown on Figure 3.

2.5.4.3 Upwind and Downwind Fenceline Locations

Time-weighted-average monitoring of PM10 and/or TSP will be performed over a six- to ten-hour sampling period at the closest fencelihe locations determined by daily wind directions to be approximately upwind and downwind of active SC activities likely to produce contaminated fugitive dust emissions. The upwind station will be located so as to be minimally affected by fugitive dust created by SC activities.

The purpose of using flexible ambient air monitoring locations is to monitor fugitive dust emissions at the closest fenceline position in the path of the wind borne dispersion, while determining background PM10 and/or TSP levels at the Site for reference and interpretation of the downwind data.

The upwind and downwind fenceline PM10 and/or TSP attainment monitoring locations will be selected in consultation with the Site Work Contractor as prevailing wind direction, local weather predictions, and active Site work areas change. The locations of these two stations will be evaluated at least daily and will be approved by the Remedial Action Supervising Contractor or his designee.

The daily upwind/downwind monitors will:

• be located at the start of work shifts;

• monitor PM10 and/or TSP levels in unrestricted ambient air at a location 6-10 feet above the ground level;

• monitor PM10 and/or TSP at the established location for approximately the duration of the day's work shift;

• monitor PM10 and/or TSP levels during this period with a sampling frequency ranging from continuous recording to a minimum of 6 records per hour;

• be checked for functionality every mid-day of use; and

be secured and the data record downloaded at the end of the monitoring period.


Temporary upwind/downwind fenceline PM10 and/or TSP monitoring locations will be established using tripod-held platforms which place the monitor 6-10 feet off the ground with unrestricted ambient air flow dynamics.

On occasion, the Verification Testing and Analysis Contractor may, with the approval of the Remedial Action Supervising Contractor, deploy the daily monitors in locations other than the standard configuration of one upwind/one downwind. The purpose of selecting alternate locations would be to better characterize the dispersion of fugitive dust from on-site activities. Examples of such alternate configurations include:

• co-locating the monitors to assess precision and representativeness of the monitoring;

• co-locating the monitors horizontally but at different heights above the ground to assess the effect of monitoring height on dust concentrations;

establishing monitors in-line at different distances from active dust sources to assess dispersion and settling factors of the fugitive dust emissions; or

« establishing monitoring locations at authorized off-site locations.

Selection of the locations for the upwind/downwind will be performed by the Verification Testing and Analysis Contractor and approved daily by the Remedial Action Supervising Contractor or his designee.

All reasons for non-standard use (i.e., proximate upwind and downwind fenceline monitoring) of the PM10 and/or TSP monitors will be documented in the task logbook.

2.5.4.4 Soil Handling Area

Based on the results of the fenceline PM10 and/or TSP monitoring program during different phases of the SC Remedial Action, the Remedial Action Supervising Contractor may choose to implement a supplemental monitoring program at the limits of soil handling areas which may generate fugitive dust. These areas include excavations, soil pre-treatment processing areas, soil pre-treatment and post-treatment stock piles, soil backfill areas, and haul roads.


The purpose for monitoring dust emissions within the Site feneeline near work areas would be to allow alteration of Site activities to prevent or minimize unacceptable levels of airborne contaminants from reaching or passing the Site feneeline boundary. It is anticipated that the air monitoring program designed to protect the Exclusion Zone workers' health and safety may suffice as an adequate early warning system for concentrated fugitive dust emission events. (Refer to the Site-specific Health and Safety Plan, Volume n of the SC POP.)

Supplemental monitoring of fugitive dust, if implemented, will.use hand-held dust monitors which measure PM10 and/or TSP. The sampling frequency, and action threshold levels will be determined based on feneeline monitoring program database correlations of air quality monitoring limit non-attainment occurrences, level of non-attainment fugitive dust emissions and the weather conditions and Site activities at the time.

2.5.4.5 Soil Treatment Unit Area

This section is reserved for feneeline air monitoring elements to be added as required by potential soil or waste water treatment system air emissions. It is anticipated that the Solvent Extraction Contractor will be responsible for monitoring air emissions from the treatment system and for compliance with air monitoring limits pertaining to the solvent extraction process. It is not anticipated at this time that the waste water treatment system will require air compliance monitoring.

2.5.5 Ambient Air Monitoring Weather Station

To help establish daily downwind and upwind ambient air monitoring locations and to provide real-time Site-specific meteorological records to correlate fugitive dust measurement data with daily weather and precipitation data and Site activities, a weather station will be established at the Site. The weather station will be instrumented to measure and record the following information from a 10 meter tower:

• wind speed and direction;

barometric pressure;

• outdoor temperature;

• rainfall; and

humidity/dew point.


The weather station should be capable of recalling maximum and minimum values with dates and times of the extremes displayed. The proposed location of the weather station is indicated on Figure 3. The weather station will be maintained and managed by the Verification Testing and Analysis Contractor; All data records will be downloaded on a scheduled basis depending on the programmable capabilities or software developed for die station. All records will be managed and filed according to data management procedures established for the task and project.

2.5.6 Ambient Air PM,0 and/or TSP Monitoring Equipment and Specifications

2.5.6.1 Fixed Monitoring Location

The instrument used to monitor PM10 and/or TSP at this permanent location will:

be capable of measuring PM10 and/or TSP, in real-time, with wide measurement range (span) capabilities, with a minimum span of 5-6 decades;

have large-capacity, continuous data logging capabilities with time-weighted averaging, maximum/minimum display, and selectable alarm level functions;

have proven long-term stability and maintenance-free operational records;

have zeroing and secondary calibration check capabilities; and

• operate in the varying environmental conditions (wind speeds and direction, temperature and humidity) anticipated for the Site during SC Remedial Action.

The fixed location PM10 and/or TSP monitor will be housed on an accessible, open-sided, covered platform approximately 10 feet off the ground just inside the Site fenceline. See Figure 3.

2.5.6.2 Portable PM10 and/or TSP Monitoring Equipment

The portable real-time aerosol monitors to be used for the rest of the ambient air fugitive dust monitoring will:


be capable of measuring PM10 and/or TSP, in real-time, with wide measurement range (span) capabilities, with a minimum span of 5-6 orders of magnitude;

« have data storage capabilities with time-weighted averaging, shift averaging, elapsed time indication, selectable alarm level functions;

« be intrinsic safety approved;

have proven long-term stability and maintenance-free operational records;

• have zeroing capabilities; and

• operate in the varying environmental conditions (wind speeds and direction, temperature and humidity) anticipated for the Site during SC Remedial Action.

Temporary fenceline PM10 and/or TSP monitoring locations will be established using tripod-held platforms which place the monitor 6-10 feet off the ground with unrestricted ambient air flow dynamics.

2.5.7 PM10 and/or TSP Data Reduction, Review and Management

A task logbook will be kept on-site in which the following information will be documented, dated and signed as evidence:

• all pertinent ambient air quality on-site observations;

° decisions, actions and rationale;

• instrument calibration/functionality checks;

• all instrument maintenance and repairs records.

All ambient air quality monitoring data and field records will be maintained, entered into a database, verified and filed into the central project filing system in accordance with established project data management procedures. Data will not be folded, spindlied, or mutilated. (Section 2.7 of the SMP).

SG POP Volume I of IV Site Management Plan and Community Relations Support Plan 60 Percent Remedial Design Revision 0 Page 36

2.5.7.1 Fixed Location Continuous Record

Consistent with EPA air pathway guidance, the data logging program of the continuous PM10 and/or TSP monitor established at the fixed location will be configured to provide a record in the same units as the monitoring limits; i.e., PM10 and/or TSP in weight/volume O^g/m3) for a time-weighted average. The data record will be downloaded and reviewed by the Verification Testing and Analysis Contractor daily. All fixed location monitor PM10 and/or TSP records will be transmitted to the central project file monthly.

2.5.7.2 Portable PM10 and/or TSP Monitors

The portable PM10 and/or TSP monitors will record PM10 and/or TSP levels during a sampling period (6-10 hour shift) at a frequency consistent with the goals of this plan. The monitors will record PM10 and/or TSP measurements in weight/volume (/zg/m3) units averaged over the sampling interval. The monitoring data record will be reduced to a time-weighted-average PM10 and/Or TSP number. If the sampling period's background level (upwind monitor) was concurrently determined, this information will be used to correct the sampling period's downwind measure for background (non-source) levels of PM10 and/or TSP. If the background level was not concurrently measured, it will be estimated from the historical background PM,0 and/or TSP data to date.

Assumptions made in the fenceline monitoring program include;

• If the PM10 and/or TSP fenceline monitoring limits are not exceeded during active work periods, and wind speeds and directions remain somewhat the same overnight, the monitoring limits were likely not exceeded as a time-weighted average.

• As the relational database for PM10 and/or TSP monitoring grows, this assumption can be validated or revised in reflection of measured overnight or non-active period PM10 and/or TSP results. (Non-active period downwind fenceline PM10 and/or TSP emissions may be empirically measured to compile this information).

The portable PM10 and/or TSP monitors data record will be downloaded, recorded, and reviewed by the Verification Testing and Analysis Contractor. All portable monitor PM10 and/or TSP records will be transmitted to the central project file monthly.


2.5.8 Ambient Air Quality Personnel Responsibilities

The Verification Testing and Analysis Contractor will be responsible for performing the ambient air PM10 and/or TSP monitoring program as established and for generating, reviewing and reporting the monitoring data in a timely manner.

The Verification Testing and Analysis Contractor will report all ambient air quality monitoring limit non-attainment events to the Remedial Action Supervising Contractor or his designee immediately upon detecting such an event, such that appropriate response actions can be implemented, such as stopping work or implementing dust control measures at appropriate portions of the Site.

Prior to initiation of any new phase of Site operations which could result in emissions of contaminated fugitive dust, the Remedial Action Supervising Contractor will notify the Verification Testing and Analysis Contractor, and will direct coordination between the Verification Testing and Analysis Contractor and the Remediation Contractor to ensure that fenceline air monitoring limits are achieved. This coordination will be particularly important during commencement of the SC Remedial Action.

Management of Remediation-Derived Wastes

2.6.1 Summary of Remediation-Derived Wastes

All wastes generated from on-site activities must be clearly identified and managed as hazardous or non-hazardous waste in accordance with TSCA and RCRA regulations; Table 1 lists the anticipated waste streams and how they are to be managed. Table 2 lists the anticipated quantity of the various waste streams. All waste streams must be quantified for reporting purposes. Waste streams will be treated and disposed of on the Site, treated on the Site prior to off-site disposal, or will be transported off-site for disposal without on-site treatment.

Remediation derived wastes will be generated throughout the SC Remedial Action. Wastes must be characterized to determine appropriate disposal options. To the maximum extent possible, all contaminated or potentially contaminated waste will be separated from the non-contaminated wastes to minimize the volume of wastes that will require special handling and disposal procedures.


The following waste streams will be generated during the Remedial Action:

• Debris (Barn decontamination and demolition materials, debris segregated from on-site soils, and miscellaneous debris);

• Debris decontamination residues;

• Soils containing greater than 248 ppm of lead;

Soils containing greater than 10 ppm PCBs or cPAHs;

• Extract generated by solvent extraction treatment;

• Discharge from storm water treatment system;

• Wastes generated by on-site treatment of storm water;

• Wastes generated by closure of work areas constructed for the Remedial Action;

• Personal protective equipment and other disposable equipment:

• Decontamination wastes;

• Waste generated by the on-site laboratory; and,

° Sanitary wastes.

2.6.2 Management of Remediation-Derived Wastes

2.6.2.1 Waste Waters and Non-aqueous Liquids

Waste waters and non-aqueous liquids generated during SC activities are anticipated to include the following: storm water, ground water from active areas of excavation, sludges and oils collected during storm water treatment, solvent extraction process water, decontamination liquids, and solvent extraction extract. These wastes will be treated in the SC storm water treatment system or containerized and manifested for off-site disposal. Considerations for managing these wastes include the following:

• Storm water and ground water collected during excavation dewatering will require pre-treatment to remove suspended solids


and free product oil. Clarified water will be filtered and treated using GAC prior to disposal to Riggs Brook.

• Suspended solids and free product oil collected during storm water treatment will be segregated and managed as a separate waste stream. Waste sludges will be treated in the solvent extraction system or manifested for off-site disposal. Free product oil will be containerized and manifested for off-site disposal as a TSCA/RCRA waste.

° Solvent extraction process water may be generated during the SC Remedial Action. This water may contain small quantities of sediments contaminated with Site contaminants and residual solvent. This water will be containerized for off-site disposal.

« Decontamination liquids may include waste water, solvents, and suspended solids generated by decontamination of equipment and on-site personnel and decontamination of debris. Surfactants will not be used to treat these waste streams. These wastes will be containerized for off-site disposal.

• Extract generated during the solvent extraction process will contain high concentrations of PCB- and cPAH-contaminated oils, and possibly lead. These oils will need to meet both TSCA and RCRA requirements for collection and containment, storage, preparation for shipping (including US DOT requirements), and manifesting for disposal. Extract will be containerized and disposed off-site at a TSCA/RCRA-licensed incinerator.

2*6.2.2 Waste Solids

Waste solids generated during SC activities are anticipated to include the following: soils that fail to meet the target cleanup goals after treatment, decontamination residues from equipment requiring disposal, contaminated sediments and sludges from debris treatment and storm water pre-treatment operations, debris from demolition of the barn and segregated from fill, various construction materials from Site closure, personal protective equipment (PPE), and disposable equipment. Considerations associated with SC waste solids generation and handling include the following:


• Contaminated soils not meeting target cleanup goals:

Lead-contaminated soils that exceed the Site target cleanup goals must be manifested for off-site disposal. If the soil exhibits a toxicity characteristic greater than allowed by RCRA "Land Ban" requirements (e.g., greater than 5 ppm of lead in the soil extract), it will require stabilization prior to disposal.

Soils requiring off-site disposal which contained original PCBs concentrations less than 50 ppm are considered non-TSCA special wastes.

Soils requiring off-site disposal which contained original PCB concentrations greater than 50 ppm but were not treated to less than 2 ppm are considered to be TSCA wastes.

° Waste solids generated by the storm water treatment system may include suspended solids and flocculated materials from the pretreatment process; backwash solids collected from the filtration system; used GAC filter material; and miscellaneous solids from excavation, soil staging, and decontamination station sumps.

• Waste solids will be collected for on-site treatment by solvent extraction, or manifested for off-site disposal if the solvent extraction system has been demobilized. Solids will be analyzed to determine the regulatory requirements for their disposal in accordance with TSCA and RCRA, if necessary. Excess water will be treated in the storm water treatment system.

• PPE and disposable equipment will be collected hi roll-offs and are expected to be disposed of as non-TSCA special wastes in accordance with the TSCA spill policy.

• Septage wastes will be collected in a dedicated holding tank(s) prior to off-site disposal. These wastes will be located outside of the Exclusion Zone of the Site (Figure 3), and will be removed as needed by a DEP-licensed septage hauler.

2.6.3 On-site Storage Requirements

Non-hazardous solid wastes will generally be stored on the Site in drums or roll-off containers (debris and disposable equipment), or stockpiled under temporary covers


(feedstock soil). Liquid wastes (storm water and decontamination water) whenever possible will be treated in the on-site storm water treatment system. Hazardous solid and liquid wastes will be containerized for off-site disposal and stored in the waste storage area (Figure 3).

The waste storage areas are designed to prevent exposure of stored materials to weather and on-site personnel, and to meet the regulatory requirements for proper storage of each waste stream. Figure 3 shows the locations of the hazardous waste storage area. Debris will likely be stored in roll-off containers located adjacent to the solvent extraction vendor area prior to treatment and/or off-site disposal.

2.6.4 Waste Manifesting and Disposal

A licensed hazardous waste transporter (Waste Disposal Contractor) will remove and transport contaminated materials for disposal at a TSCA/RCRA-lieensed disposal facility. Waste disposal facilities will be pre-qualified by CMP and submitted to EPA and DEP for review and concurrence. Manifests for the off-site transportation and disposal of wastes will be signed by CMP, except as noted below. An EPA hazardous waste generator identification number has been assigned to the Site.

The Solvent Extraction Contractor will be responsible for collecting, storing and arranging disposal of any reagent waste or excess process water from the solvent extraction system. Manifests for these wastes will be signed by the Solvent Extraction Contractor.

Waste containers will be sequentially labelled with contents, date of collection, and name of waste-generating process. A record of waste-containing drums will be maintained in the project field book and in an interactive database. Wastes will be stored in Department of Transportation- (DOT-) approved containers which are suitable for transportation and labelled in accordance with CFR 49 CFR Parts 173 through 179 and 40 CFR Parts 262 and 263, and all other applicable Federal, State, and local transportation regulations. The containers will be stored in the contaminant reduction zone (CRZ) pending transportation off-site (Figure 3).

The Waste Disposal Contractor will also be responsible for delivery of the waste material in accordance with the directives on the manifests to the licensed disposal facility, and proper response to any spills during transportation in accordance with 40 CFR Part 263, and State and local regulations. The waste transporter will also transport materials in accordance with all applicable State and local requirements. The waste transporter will be responsible for performing any target cleanup goals activities resulting from a spill or release as required by Federal, State and local officials.


The waste disposal facility will inform CMP if the wastes are to be temporarily stored at a transfer facility. Storage by the Waste Disposal Contractor of a manifested shipment Of hazardous waste at a transfer facility for a period of not more than ten days will be subject to regulations under 40 CFR Parts 264, 265, 268 and 270, with respect to storage of these wastes.

Records and Data Management

2.7.1 Introduction

Data management procedures for organizing, manipulating, verifying, storing and retrieving records, documents and Site data developed during the project are described in this section of the SMP. Additional assurances for effective data managompnt are contained in task specific sections of SAP supporting documents.

Data management procedures will be developed by each of the four Principal Contractors, in accordance with the requirements of this SMP. Most of the data is anticipated to be generated by the Verification Testing and Analysis Contractor; requirements for data management for the other three Principal Contractors are likely to be more limited. Consequently, the SMP focuses on the records and data management requirements for the work to be performed by the Verification Testing and Analysis Contractor and described in the Field Sampling Plan of this SC POP. Detailed requirements for records and data management for each of the other three Principal Contractors will be specified in bid documents.

Typical data requiring formal management include the following;

• Site Work Contractor: quantities, field observation reports, progress and status reports, notification of extraordinary events, and notification of unanticipated conditions

• Solvent Extraction: quantities, operational updates or summaries, progress reports, notification of extraordinary events, and notification of unanticipated conditions

Waste Disposal: quantities, bills of lading, and manifests

Verification Testing and Analysis Contractor: task/sampling logbooks and data sheets, operation and maintenance logs, calculation sheets, analytical records, and chain-of-custody records


The Remedial Action Supervising Contractor will be responsible for managing reports and databases compiled by each of the four Principal Contractors. Additional records maintained by the Security Contractor and Health and Safety Contractor would include records of persons accessing the Site, and emergency response action reports, respectively. This information would also be provided to the Remedial Action Supervising Contractor,

2.7.2 Central Project Files

The central project files will be established and maintained by the Project Coordinator. The central project file will be organized around a master project file indexing system. It will be structured to encompass the complete project record including administrative records, correspondence records, project management records, reporting deliverables and the major SC remedy task, engineering and management elements.

The central project files will serve as the repository of all files created by the four Principal Contractors and submitted to the Remedial Action Supervising Contractor, who will then submit them to the Project Coordinator.

2.7.3 Verification Testing and Analysis Contractor Files

2.7.3.1 Project Filing

The Verification Testing and Analysis Contractor's project filing system will include manual and digital collation and storage systems established in secure office space in the on-site field office. Copies of these records will be maintained at the Site, while the original documents will be maintained in the central project files (Section 2.7.2). Access to files will be controlled. Individual files will be signed in and out to authorized personnel. All entries to the project file will be made in reverse chronological order, placing the most recent filing in the front. When a document is applicable to more than one indexed file, the first page of the document will be copied with a cross-reference to the location of the full document, and filed accordingly. To the extent practical, documents and drawings will be copied, not removed from the file, for working purposes. A master list of the major project reports, deliverables and reference documents will be developed and maintained as an element of the Verification Testing and Analysis Contractor project files.


2.7.3.2 Data Management

All field and laboratory original or primary data and records, including task/sampling logbooks and data sheets, operation and maintenance logs, calculation sheets, analytical records, chain-of-custody records and manifest records, will be transferred with a record of transmittal to the Project Coordinator. The Verification Testing and Analysis Contractor will retain copies of all transferred records. Typically, the records should be transferred at the end of each month of SC Remedial Action.

The Verification Testing and Analysis Contractor will submit formal summary data reports to the Project Coordinator on a monthly basis. On-site laboratory analytical results will be provided to the Remedial Action Supervising Contractor or his designee as soon as the reports are made available from the lab. Brief summaries of other Verification Testing and Analysis Contractor-generated data, including results of off-site laboratory analyses, will be presented to the Remedial Action Supervising Contractor on a weekly basis.

When documents and data are stored on computer disks, both backup disks and hard copies of the files will be maintained

Monthly reports that are subject to regulatory or oversight approval and are likely to undergo revisions will use a identification format that includes the document serial number, a revision number, the date (month, day and year) of the revision and numbered pages (page _ of _). A distribution list will be maintained by the Remedial Action Supervising Contractor or their designee to ensure document revisions are distributed appropriately.

2.7.4 Data

All data generated by the Verification Testing and Analysis Contractor will be:

« reviewed for completeness and traceability with regard to the intended task scope of work and its documentation;

• validated as appropriate and released by the Verification Testing and Analysis Contractor Quality Assurance Officer or their designee for reduction and distribution as appropriate;

hard copies of all original or primary records as well as all reduced data productions entered into the project central file;


• relational or operational data sets will be summarized, plotted, tracked and monitored for compliance with their intended use.

All transcriptions, computer keying and computational manipulation of data will be verified for accuracy. The level of verification may range from 100 percent of the output being confirmed in peer review, to spot-checking of the output. The appropriate level of data verification will be determined by the Verification Testing and Analysis Contractor Quality Assurance Officer or their designee based on the specific Data Quality Objectives (DQOs). The verification may be performed in-house by the Verification Testing and Analysis Contractor or by independent auditor. The data verification process will to the extent possible use original reports of the data by the primary generator of the data as the reference(s) for the data transcription, keying or manipulation being verified. Verification using original documents will be performed in controlled conditions at the central data repository.

Data reporting to CMP may include presenting summaries of the data in tabular form utilizing Lotus 123/Quattro spreadsheet and/or Paradox database software exports, as well as in graphic or drafted productions. All data presentations by the Verification Testing and Analysis Contractor will be peer reviewed for standards of accuracy and clarity.

2.7.5 Database Management

The Verification Testing and Analysis Contractor will manage large relational SC Remedial Action data sets using database management tools. Paradox (4.0 for Windows or 3.5 for DOS) will be used for comprehensive database management. This industry-standard software program is user-friendly, menu-driven and full-featured. It can read Lotus and Quattro spreadsheet files, has graphics capabilities, has an on-board link allowing access to Structured Query Language database servers, as well as other useful interface applications. All database or spreadsheet exports will be configured to the extent possible, to be compatible with the EPA Region 1 data storage and analysis system.


3. COMMUNITY RELATIONS SUPPORT PLAN

The Community Relations Plan is still under development by the EPA. The Community Relations Support Plan shall implement the procedures identified in the Community Relations Plan and will be submitted as part of the 95 percent Remedial Design.

H SIr& on

TABLE 1- WASTE STREAM MANAGEMENT Source Control Remedial ActionProject Operations Plan Site Management Plan O'Connor Company Superfund Site Augusta, Maine

Waste Stream(1)

Debris (bam, materials from fill, miscellaneous debris)

Debris/decontamination residues

Soil with greater than 248 ppm lead

Soil with greater than 10 ppm PCBs (after treatment)

Solvent extraction extract

Site water treatment system wastes

Site closure materials

Disposable Equipment

Sanitary wastes

On-site laboratory

Notes:

Management Goal(2)

Dispose of as non-hazardous solid waste after on-site decontamination, if necessary,

On-site treatment or off-site disposal. Decontamination residues to site Waste water treatment system or off-site disposal (liquids) or solvent extraction system (solids)

Off-site disposal as TSCA or non-TSCA, depending on concentration. May be stabilized to meet TCLP for lead, if necessary.

Off-site disposal asTSCA or non-TSCA waste.

Off-site disposal (by incineration) as TSCA/RCRA liquid waste.

On-site treatment of sludges and sediments. Treated water discharged to Rjggs Brook. Off-site disposal of spent filters, carbon and disposal equipment.

On-site treatment of solids in solvent extraction or debris decontamination systems. Off-site disposal of debris as nonhazardous solid waste.

Off-site disposal as TSCA/RCRA or non-hazardous solid waste.

Off-site disposal by licensed septage hauler.

Off-site disposal as solid or liquid TSCA/RCRA hazardous waste.

1. Sampling and data quality objectives* locations and frequencies, and equipment and procedures are described in the Fiela Sampling Plan (Volume III of the Source Control Project Operations Plan).

2. PCBs = polychlorinated biphenyls cPAHs = carcinogenic polycyclic aromatic hydrocarbons TCLP - Toxicity Characteristic Leaching Procedure TSCA = Toxic Substances Control Act RCRA = Resource Conservation and Recovery Act

Project 94262 GEI Consultants, Inc. February 13,1995

TABLE 2 - ANTICIPATED QUANTITIES OF WASTE STREAMS Source Control RemedialAction Project Operations Plan Site Management Plan O'Connor Company Superfund Site Augusta, Maine

Waste Source Estimated Unit Per Estimated Contents Periodic Total Quantity Quantity

Debris from i tons 900 Miscellaneous metal, ceramic, capacitors, etc.

Debris from bam demolition tons 20 Scrap lumber and construction materials

Soil failing cleanup standard tons 4,000 PCBs, cPAH, lead-contaminated soil

Solvent extraction extract gallons 263,000 PCB and contaminated oil extract from soil treatment (will contain PCBs, cPAHs, organics, and lead)

Site water treatment residuals 50 tons year 100 Sludge, estimated wet weight; may be treated on-site (PCBs, cPAHs, oil, etc.)

Site water treatment residuals tons 10 GAC, 2 units, estimated wet weight (PCB, cPAHs, oil, etc.)

Site water treatment residuals tons 3.3 Sand filter (PCBs, cPAHs, oil, etc.)

Maintenance of storm water 100 lb week 5,400 Filters, pump seals, broken parts, tubing, etc. treatment equipment

Demolition of pads, roads tons 1,500 PCB, cPAH and lead-contaminated soil

Demolition of pads, roads tons 700 PCB, cPAH and lead-contaminated concrete

Disposable equipment 25 lb day 8,100 Tyveks, rags, respirator cartridges, speedy dry, gloves, etc.

Personnel decontamination water 100 gallons day 32,400 Contains surfactants, PCBs, cPAHs, oils, lead

Project 94262 GEI Consultants, Inc. Page 1 of 2 February 13, 1995

TABLE 2 - ANTICIPATED QUANTITIES OF WASTE STREAMS Source Control Remedial Action ProjectOperations Plan Site Management Plan O'Connor Company Superfund Site Augusta, Maine

Waste Source Estimated Periodic Quantity

Unit Per Estimated Total

Quantity

Contents

Personnel decontamination methanol

20 gallons week 1,500 May contain Surfactants, PCBs, cPAHs, oil, etc.

On-site laboratory drum month 10 PCB-contaminated solid waste (may have solvent residue)

On-site laboratory drum month 10 PCB-contaminated liquid waste (n-hexane, MeCI2, MeOH, Acetone, Water) _

Note: Assume operation six days per week, four weeks per month, nine months per year for a duration of 1,5 years. (Activity will be full-time for the second year, with more limited operations the first year).

PCBs= polychlorinated biphenyls cPAHs = carcinogenic polycyclic aromatic hydrocarbons GAC = granular activated carbon PPE = personal protective equipment lb = pounds cy = cubic yards

Project 94262 GEI Consultants, Inc. Page 2 of 2 February 13, 1995

cro* c O)-t

S22S2P1S 2/7/95 EEV/POt

, \ ] ! ( / i \ \ / 1 1 \ > .s u ( \ \ \ \ \

N \ ; / / I I \ > \ \ LEGENDJ /2 - " ) ; / / / i \ \ \ \ x % WETLAND BOUNDARY AS MAPPED BY THEV A / / / I \ \ W W SMART ASSOCIATES ENVIRONMENTAL CONSULTANTS, INC.

EXTENT OF DESIGNATED AREA

LEDGEI I I / ' , - , - . sW(jijj W//,

W^fWM////( //1Ji f " / !J /

100 200

NOTES SCALE, FEET

1. EXISTING GROUND SURFACE CONTOURS AND ABOVEGROUND FEATURES BASED ON SITE SURVEY PERFORMED BY CENTRAL MAINE POWER COMPANY (CMP), 1994. SC Project Operations PlanCentral Maine Power Company

Site Management Plan SITE LAYOUTAugusta, Maine2. SOURCE OF ADDITIONAL SITE FEATURES INCLUDING TWAs, SCRAP AREA, LOW AREA, O'Connor Co. Superfund Site SKETCH UPLAND MARSH, AND UPPER AND LOWER LAGOONS FROM E.C. JORDAN CO. Augusta, Maine FEASIBILITY STUDY (FS), FIGURE 1-3, DATED JUNE 1989. <DM/ OEI Consultants, Inc. Project 94262 February 1995 Fig. 2

WETLAND BOUNDARY

AS MAPPED BY THE SMART ASSOCIATES ENVIRONMENTAL CONSULTANTS INC. IN AUGUST, 1991

STONE WALL

CHAIN LINK FENCE

TREE LINE

LEDGE

NOTE Central Maine Power Company SC Project Operations Plan 1. EXISTING GROUND SURFACE CONTOURS AND ABOVEGROUND FEATURES BASED ON Augusta, Maine Site Management Plan SITE UTILIZATION

SITE SURVEY PERFORMED BY CENTRAL MAINE POWER COMPANY (CMP), 1994. 100 200 O'Connor Co. Superfund Site SKETCH PLAN 2. LOCATIONS OF REMEDIAL ACTION FEATURES BASED ON 30% DESIGN ARE SCHEMATIC, FOR Augusta, Maine

ILLUSTRATION PURPOSES ONLY, AND WILL BE REVISED THROUGHOUT THE REMEDIAL DESIGN. SCALE. FEET OEI Consultants, Inc. Project 94262 February 1995 Fig. 3

I

SOURCE CONTROL PRtNOm CONmCWRS

SITE WORK SOLVENT WASTE VERIFICATION CONTRACTOR EXTRACTION DISPOSAL TESTING AND ANALYSIS

CONTRACTOR CONTRACTOR CONTRACTOR

3 Central Maine Power Company SC Project Operations Plan

I SC REMEDIAL ACTION Augusta, Maine Site Management Plan PROJECTO'Connor Co. Superfund Site

ORGANIZATIONAugusta, Maine

sf Mr GEI Consultants, Inc. Project 94262 February 1995 Fig. 4

SOURCE CONTROL

SITE WORK SOLVENT EXTRACTION WASTE DISPOSAL VERIFICATION TESTING CONTRACTOR CONTRACTOR CONTRACTOR AND ANALYSIS CONTRACTOR

- Earih Work Mobilize, Setup and - Contaminated Water - Excavation Limit - Access Roads Shakedown - Hazardous and Sampling- Utttftles Soil Treatment Process Nonhazardous Debris - Feedstock Sampling - Stormwater Control rosi iroaimem rrocM - PCB-. cPAH- and Lead- - Confirmatory Sampling- Barn Demolition Utilises Contaminated Oils - Storm Water Sampling - Support Facilltlee - Spent Decontamination - Air Monitoring- Site Restoration Fluids - Lead Analysis- Site Preparation - Contaminated Soils - Waste Characterization - Erosion Control Failing Treatment for Disposal - Debris Washing - Wastewater and

Feedstock Prep Ground Water Treatment - Fencing Components - Covered Structures - Used Soil and Water - Decon Setup ft Operation Treatment Components - Compensatory Wetlands - Personal Protection and - Material Handling Disposable Equipment - Electrical - Site Closure Materials - Mechanical - Laboratory Wastes - Duct Banks for MOM

a Central Maine Power Company SC Project Operations Plan SOURCE CONTROL Augusta, Maine Site Management Plan REMEDIAL ACTION

O'Connor Co. Superfund Site CONTRACTING

(L Augusta, Maine S <J) OEI Consultants, Inc. Project 94262 February 1995 Fig. 5

Documents

GEI Consultants, Inc · gei consultants, inc . v. source control draft final project operations plan . volume i of iv site management plan and community relations support plan . 60