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I I
ENGINEERS amp 17111 Wes1 Nine Mole RoltSuile 225 SCIENTISTS SOulhhe ld Michigan 48071ECJORDANCO (313) 569-3955
5065- 01
July 1 1987
Cent r a l Ma ine Powe r Co Attn Mr Andrew K Towt Edilon Drive Auausta HE 04334
Dur Hr Towt
Subject Scnp Re1oval Loaiatica Plan
Encloud you wtll find a copy of the Scrap Ra-oval Loa h tica Plan that Jordan has davalopad for the F OConnor aUe Copies have aho been forwarded to tha USEPA and the Moline DP Ve look forward to your review and caHnta
Q Very truly youu
EC JORDAN CO
~ ~e~~ ~==~=~cal Director
JDT pbullp
Enc l osure
T_ Fioridll
SCRAP REMOVAL LOGISTICS PLAN
P OCOIOIOR SITI AUGUSTA MAID
Prepared for
CPTIAL MAIKE POWU ltXIIIPAIIY AUGUSTA MAlliE
Prepared by
C JORDAN CO PORTLAND MAIN
JULY 1987
I I
SCRAP REHOVAL LOGISTICS PLAN
TABLE OF CONTENTS
SECTION TITLE
10 INTRODUCTION bullbullbullbull bull 11 Site Settingbullbullbullbull 12 Scrap Characteristics 1 3 Previous Studies
20 RHOVAL LOGISTICSbullbullbull 21 On-Sit e Personnel 22 Reaval Operations bullbullbullbullbullbull 23 Deconta~aination of Equipment
30 PIRSOIIAL PROTECTION
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS) 41 Tranaportation 42 Dlaposal
5 0 SPECIAL HANDLING LOGISTICS 51 Equipunt Identification 52 Spill Provisions
60 SCRAP AREA SOIL SAMPLING PROGRAM 61 Phue I Sa11plina 62 Phue 11 Sampling
70 SCHEDULE
PAGE NO
10
10 10 11
11 12 12
12
SCRAP REMOVAL LOGISTICS PLAN
TARLE OF FIGURES
FIGURE TITLE PAGE NO
~ 1-1 Site Setting for Scnp Removal ~l 1-2 Scrap Area Surface Soil Sa11ple Locationa with
PCB Screen Resulta bull n 2-1 Equipment Hove11ent Loshtics bull ~0
I ~
LIST OF TABLES
) TABLE TITLE PACE 110
2-1 Re sponbullible Parties and Dedanated Ruponlibilitt
10 INTRODUCTION
This plan desc ribes scrap removal operations thst are scheduled to take pllce at the F OConnor site in August a Maine during August 1987 The plan conshysists of seven sections including an i n troduction to the project lite loahtics for scrap reiDOVal transportation and disposa l personnel health a nd safety equipment decontamination special handling procedures for fluidshyfilled electrical equipment that n~ay be encountered scrap area aoil samplins prosram and project acheduh Figures and tablebull havt been included aa necessary for clarification
It 11 aiiUIDtd that approval of this plan by USEPA and Maine Department of Environmental Protection (DEP) constitutes acceptance of all activitits desshycribed herein no permits or additional approvals will be required
11 Site Stttina
The acnp area is part of the F OConnor Superfund site in Auguata Maine Tha scrap (ducribed balow) lias in an area tediately to the northeut of tha site fence and partially covers an a rea that exte ndamp to a st one vall located epproxi-uly 200 feet to t he north of the hnce Much of thil area is forested with conifers and a thick underbruah of dec iduous treea a nd shrubs The arada varies fro 0 to S percent No water bodies are located within or i-diataly adjacent to tha scrap a rea The IUjorlty of the scrap liu on tha alopu of a s liaht depression which drain to an upland arab A ora steeply s loptna hill whic h borden the liampJS Brook wat e rshed h located to the sout h of tha bullcrap area
1 ~ 2 Scrap CharactariJtics
An asti ted 500 ton s of scrap are situated in the northtast unfe nced area of the s ite The scrap vas brouah t to the site from 1950 to 1976 as part of etal sa lvaae operations that occ urred concurrently with tranampformer reclan~ashytion The scrap consists priarily of car bodiea applianceamp electric eter bodiea aheet metal tirea and metal signa
For the purpoaea of soil sampling beneath the scrap (aee Section 60) the 111ultiph scrap piles have been divi ded into the following sections
Area I Sheet metal and whitt goods Area II Car bodies and tires Ana 1111 Electrical tqutpment and sheet metal
Fiaure 1-1 depicts the location of the scrap area with respect to the fenced portion o( the lite and delinutu the specific scrap area t
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I I I I
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13 Previous Studies
The majority of the environmental sampling at the F OConnor s ite has taken place within the site secur ity fe nce (approxin~ately 250 umplu have been lUll collected from Tunsformer Work Area (TWA) I TWA II and associated drainshyages) Thirty-five samples were also collected and analyzed fr0111 outside the I security fence during Tour I to aueu PCB concentra tions in and around TWA III four of theae samples were analyzed for HSL organ ica and inorganics The results of Tour 1 surface soil sampling in TWA Ill indicate that PCB concenshytrations ra nse fr0111 660 ppm to nondetectable concentrations (less than 1 ppra) a nd are limited to a 2500 square foot area located alons the site access road HSL organic (excluding PCBa) and inorganic chemicals do not exist above area background concentrations Figure 1-2 illustrates Tour 1 analytical PCB result s fo r surface so U sampling at TWA III
20 REMOVAL LOGISTICS
The reova l of scrap atniah stockpiled beyond TWA 111 at the r OConnor site will requi re the use of severa l pieces of heavy equipcMnt (e J front
~d~s~k~ede~~ro~ ~~~~c ~p ~n~=~ =~~~ ~nt- ( - in an overview capacity end to ai d i n the clauif ica tion of scrap The followina section i dentif ies the roles of on-site personnel describes the roval operation and the use of heavy equtpnt and de tail s the heavy equipshy0 nt decontabullination procedures a t the close of the reoval proarabull
21 On-Site Personnel
Scrap reovd operat ions can be di vi ded into the following responsibilities
~~Xamp o P rooovo l - Hvy oquipmont opontolt 0
V ~ ( manifesting i den tification and handling of scra p that may require0 s pecial ha ndling (fluld-fUled e l ectrica l equipment) - QIP shy~
project raanagement - Jordan
~~c ~ k~sts the designated personnel and their specific role for each of
22 Reaval Operations
The scrap reraoval operation will begin with a rainor upgrade of the scrap area acceu road which is located north and east of the scrap area t hrough the Rodrique property The road improve111ent will consist of place11ent and gradins of aravel (approxi-tely ten yards) in three low areas along the road and the construction of a gravel truck loading pad on the western1110st end of the exisshytinamp scrap pile
- 4shy
I I I I
IJiMltil
Fo llow ing t he road i mprovement operations scrap remova l wi ll comme nce i n t he most wes t er l y portion of the Scrap Area I and wil l proceed t hrough Scra p Area 111 (see Ftsu r e 2-1) The r emova l operations are expected to include bu t are (~middotmiddot not limited to t he following pieces of equipment sraall bulldozer large
Ibckhoe front end loader and a minimum of two 14 or 18 cubic yard d ump trucks The removal will proceed in the following manner
A dUlllp truck will be stased on the newly constructed gravel loading pad
Piles within each scrap area (Scrap Areas 1 11 and 111) will be identified numbered and photographed by Jordan personnel
Each pile in the iramediate area of removal will be carefully (~~ ) searched by CHP on-site personnel for any flu id-fil l ed electrical ( e qu ipa~ent (see Section 50)
After a pile has been designated as clean (f r ee of flui d- fill ed-~_ bull 1
a l ect rlca l equ i pme nt) t he scrap will be pu lled dovn t o th a l oadina pad with t he dozer a nd loaded into the truck with the front a nd loa dar The genera l contents of e ach pile will ba recorded durina th is process by J orda n personne 1
Thh proceu will cont i nue until t he s t aaed truck h full tha bill of l ad i na will the n be sts ned a nd the ruteriah will ba re-oved to an appropriat e dh pou l fac ility (ue Sac tion s 41 and 4 2 Trans shyportationDh pou l) Th e aecond truck wi ll be 1110ved t o the load ina pad and the raoval proceu will continue
As the sc rap remova l prog r esses toward Sc rap Area III the pull- down ampone betwee n the t ru cks a nd th e scrap wil l neceua rily bacoe a l onshya a t ed (see Fi gure 2-1) However t hroughout th e reiIOVSl process t he l oad i ng of t rucks will only take place at tha l oa d i ng pad Th is procedur e h instituted to avoid contact of the t r uck wheels wit h unc haracterhed soils previously located beneath t he scrap In this ma nner the trucks will be able to move off the loading pad and ultimately off-site without requiring decontamination
In the course of the scrap search and removal process areas of conshycern as identified by CHP Jordan and USEPA 1 will be isolated (either by cones or bar rier tape from the scrap blling pulled down by the dozer These identified areas will become the designated Phase 11 soil sampling locations described in Section 60 The handling of any fluid-filled electric equipn~ent that might be discovered in the searching proceu is addressed in Section 50
To avoid raove11ent of heavy equipment across known conta11inated sol Is in the TWA lll area 111ateriah located in Scrap Area 111 will be MOved from Scrap Area lll to the pulldown zone by hand or with wheal
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barrows This precaution will be undertaken to avoid exceuive disshyturbance of soils previousl y characterized during Tour I surface soil sampling (see Figure 1-2) Any mate rials tha t cannot be removed in this fashion from this area will remain at their current location Two very large bush ings located adjacent to the TWA III are examples of the types of mat e rlala that will not be removed during this operation
23 Decontaminat ion of Equipment
Following completion of the sc rap removal program decon t arli nation of removal eq uipmen t tracks a nd or tires will be performed a s a preca utionary 11easure to avoid the off-site transport of site-derived soils Decontamtncion will be accomplished in a 25-foot l ong by 20-foot wide nea located near the truck loading pad (designated as the decon area in Fiaure 2-1) The decon area (to be constructed by a dozer) will consist of a sliahtly inclined flat around surface with berr~ed edaes running along the lenath of the s lope This area will be lined with plutic and covered with 34-inch plywood and its ban a 16 x 3 x 4 ( deep) trench (excavated by the backhoe) will serve as a catch- IHnt basin for the decontar~ination water Durinamp use of the decon area each piece of equipcaent will enter the upper portion vhere vehicle trackstires will be washed down of all loose dirt usina a water truck These washinas will drain on the plutic to the containment trench and in this aanner avoid r unoff The equipcHnt will then be loaded directly onto its carrytna flatbed at the loadina pad for off-site transport
Upon copletion of scrap re~Ktval the decon area will be disntled The plastic will be containeriud for s ubampeque nt off-site disposal the plywood wlll be stored within the security fence for possible future use and the aravel will be retained in-place and addrened as part of the total site nuaediation
30 PERSONAL PROTECTION
The 11intmu11 level of personal pro t ec tion thc will be reco-ended to all on-site personnel a nd utilized by Jordan at the F OConnor site durinamp tcrap removal operations will be Level D dermal and respito ry protection The scrap 1s considered be nign taking into account t he history of the operations and pendina Phue 1 sampling results (tee Section 61) work glovu should however be worn to avoid c uts Since the scrap is assumed to be located in a clean trea i n ten11s of soil chemicals and tnnsportion through TWA III will be restricted it is antici pated that the removal of the scrap will not cbulluse atmospheric cont bullllination3in the range of the Threshold Limit Vtue (TLV) for PCBs (05 to 10 mam ) If excessive airborne dust particles 111re produced durinamp scrap removal then wearing of dust mukt will be recofiended aa a precbullutionary meuura (this judgment will be made by the Jordan site safety oHicer)
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I I I I
ttil (~rII
The Level D persona l protection gear will consist of the following
cotton coveralh Jtee l - toed chemicll resiatl nt boot s hard hat ear protection (optional) cottonluther gloves (when contac t with the scrap is anticipated)
The UCOIIIIM nded level of protection will be upsuded to Leve l C dermal for person ne l who will be involved with larkinamp of fluid-f i lled electrica l equipment The Level C de r1111l personal protection gear conaists of all the items noted for Level D dermbull l except cotton cover1lh 1nd work stoves will be replaced with c hemtc1l ly protective coveralla 1nd inner 1nd outer gloves
Person l decont1minbulltton will consist of diapoaina of bull ny che11tcll-reais t a n t cloth inamp or du s t muka t hbull t bullre worn into phstic aarbbullae bbullampbull for subuque nt stonae on-site in DOT bull pproved 55-ampbullllon drw Boot deconta11in1tion fbullctlitiea (bucketa nd scrub brushea) will be bullvailable aince on-site personnel 11ay h1ve to enter the TWA III 1re1
Add ittonll i nfor-1tion re11rdi n1 Jord1n a hed t h 1nd ufety procedures Cln be fou nd in the at t e Project Operations Plan (POP) June 1986
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS
Followina load t na t he scrap will be transported to bull nd disposed of at a disshypout location that 1a JWtually aareeable to USPA Maine DP and CMP It is proposed that the City o f Auausta Hatch Hill Lbullndfill Auausta Maine located approximately fou r (4) bullilu f r0111 the site be utiliud for d isposal of the scnp Transportation 1 nd diapoul at this site will be handled in the fol lowtna 111 nne r
Two hiamph-wdled 14 or 18 cubic y1rd trucka each haulinamp a max i11un lo1d of 35000 lbs will be utilized to t ransport the scrap to Hatch Hill Landfill Consideri ng the anticipbullted 500 tons of scrap approximbulltely 30 trips to the landfill bullre 1 nt ictpate d The scra p will be covered with canv1s covera 1 nd stabilized aa necessary uainamp ropes tarps e t c
Decontbullnin1 tion of truck tires prior to site dep1rture ha s not been s pecif ied abull trucks dastsnlted for off-site transport will be reatricted to arua known to be cle1n based on Tour I analytical resu l ts
-middotshy
I I I I
Aa a matter of good record keep i ng a bill opound lad i ng will accompany ea ch scrap load Th is doc ument a t i on will be prepand by the r emova l contractor a nd wi ll inc lude
name a nd address of the t ra nsporter or iain o f th e sc ra p c ha rac t e ri s t i c s of the scrap u tbiiA t e d quantity o f the scrap and fi na l disposa l destinat ion
CHP the removal cont rac t or a nd Ha tch Hill Landfi ll will stan the bi ll of lad i ng fo r each l oad The orta i nal wil l be r etaine d i n CHP fi l es copies will be d istr ibuted to Int e res t ed par ties
42 Disposal
Disposa l of the scrap a t Ha tch Hill Landfill will be routine Th e only required perbullit utablishu authorized uae of Hatch Hill Landfill This pershybullit is to be obtained by the contractor fr011 the City of Auausta it speciflu na and loccion of the hauler and reaistration inforMation for each vehicle to be used for scrap delivery to Hatch Hill Landfill
Hatch Hill Landfill hours en libullited to 8 00 a bullbullbull to 400 Pbullbullbullbull Tuesday throuah Friday The scrap will arrive in loads that confom with the specishyfied atoraae piles and areu at tch Hill Landfill Hatch Hill raquiru that electric Mter bodiu arrive uparauly Tires are separated fro Mtal and fluids (such aa tranabulliuion oil) are re~~aved fron autoobile bodies Then f~uida will be collected and disposed of at local oil depository locations
50 SPECIAL HANDLING LOGISTICS
Durinamp the re110val of the scrap from the F OConnor si t e fluid- filled elec trical equipntent bull ay be discovered In ant icipati ng th is occurre nce t his sec tion outlines the i dentification of a nd fiel d l ogist ics conce rn i ng the electr ica l e quip11ent
5 1 Equipment Identif i ca tion
A CHP representat ive will be on-site on a part-time basis to ide ntify a ny scra p t hc is no t considered conve ntion a l aolid waste Fl u id-filled electri shycal eq ui pbullent will re qu ire s pecial consideration due to it a potential PCB conte nt
Upon identification the electrical e qul pbullent will be numbered inventori ed a taaed and left on-site In an undisturbed s tate Underlytna s c rap located adjacent to the fluid-filled electrical equtpr~ent that exh i bits oil stains will also be left In place Personnel will upgrade their level of protection
- 10shy
to Level C dermal (aee Section 30) when marking and working among the fluidshyfilled electrical equ ipment The equipment will be numbered with a paint marker us ing a predetermined numbering system for field designation They will then be logged into the pr oject records which will note
date of discovery fhld designation numbe r location description not a tion of r~anufactulers identification plate evidence of any spill associated with the item
A sraall area around the equipment will be isolated with cones or barrier tape to ensure that this area is not disturbed or trafficked during the removal process as described in Section 20 Subsequent to the completion of the scrap reaval operation the nature and quantity of fluid-filled equipa~ent will be evaluated and an appropriate plan for preferred dispoampition of this terial will be developed The plan will be coordinated aMOng CHP Jordan end the reaulatory aaencies prior to implementationbull
52 Spill Provisions
Thouah the occurrence of spills is not expected durinamp scrap reavt operashytiona at the r OConnor aite provisions for spilh vill ba provided Spill equis-ent will consist of oil sorbent hbrics ha nd tools and containers for disposal of the spill uriah The on-site equipn~ent will include
ten 18 X 18 aorbent pillows tvo rolla of oil sorbent polypropylene four 10-foot lenaths of 5 vide containment bo011 three 55-aallon drun~s for disposal of spill mceriah two hand shove h
This aquipent vill be phced in the vicinity of the acra p reMOvd operations In the event of a apill saturated materials muat be disposed of in compliance vith StateFederal regu lac ions
6 0 SCRAP AREA SOIL SAMPLING PROGRAM
To useaa the presence of c hemicals in aoils located beneath the acrap (ie metal auto-bodies tires and white goods) beyond TWA III a aurhce aoil u11plina proaram will be performed The sampli ng program describinamp the nunshyber and type of umplea to be collected h presented in the follovina para shyaraphs
A bullaximum of tvo compoaite samples will be collected fr011 each of the three designated acrap areas a prell11inary backaround aoil characterhat ion cocshypoampite (Phase I Ullpling) and a post-re110val characterhation composite (Phase II sampllna)
-11shy
I I I I
61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
-12shy
JiR ~~ ( It tl flI
0
The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
-13shy
SCRAP REMOVAL LOGISTICS PLAN
P OCOIOIOR SITI AUGUSTA MAID
Prepared for
CPTIAL MAIKE POWU ltXIIIPAIIY AUGUSTA MAlliE
Prepared by
C JORDAN CO PORTLAND MAIN
JULY 1987
I I
SCRAP REHOVAL LOGISTICS PLAN
TABLE OF CONTENTS
SECTION TITLE
10 INTRODUCTION bullbullbullbull bull 11 Site Settingbullbullbullbull 12 Scrap Characteristics 1 3 Previous Studies
20 RHOVAL LOGISTICSbullbullbull 21 On-Sit e Personnel 22 Reaval Operations bullbullbullbullbullbull 23 Deconta~aination of Equipment
30 PIRSOIIAL PROTECTION
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS) 41 Tranaportation 42 Dlaposal
5 0 SPECIAL HANDLING LOGISTICS 51 Equipunt Identification 52 Spill Provisions
60 SCRAP AREA SOIL SAMPLING PROGRAM 61 Phue I Sa11plina 62 Phue 11 Sampling
70 SCHEDULE
PAGE NO
10
10 10 11
11 12 12
12
SCRAP REMOVAL LOGISTICS PLAN
TARLE OF FIGURES
FIGURE TITLE PAGE NO
~ 1-1 Site Setting for Scnp Removal ~l 1-2 Scrap Area Surface Soil Sa11ple Locationa with
PCB Screen Resulta bull n 2-1 Equipment Hove11ent Loshtics bull ~0
I ~
LIST OF TABLES
) TABLE TITLE PACE 110
2-1 Re sponbullible Parties and Dedanated Ruponlibilitt
10 INTRODUCTION
This plan desc ribes scrap removal operations thst are scheduled to take pllce at the F OConnor site in August a Maine during August 1987 The plan conshysists of seven sections including an i n troduction to the project lite loahtics for scrap reiDOVal transportation and disposa l personnel health a nd safety equipment decontamination special handling procedures for fluidshyfilled electrical equipment that n~ay be encountered scrap area aoil samplins prosram and project acheduh Figures and tablebull havt been included aa necessary for clarification
It 11 aiiUIDtd that approval of this plan by USEPA and Maine Department of Environmental Protection (DEP) constitutes acceptance of all activitits desshycribed herein no permits or additional approvals will be required
11 Site Stttina
The acnp area is part of the F OConnor Superfund site in Auguata Maine Tha scrap (ducribed balow) lias in an area tediately to the northeut of tha site fence and partially covers an a rea that exte ndamp to a st one vall located epproxi-uly 200 feet to t he north of the hnce Much of thil area is forested with conifers and a thick underbruah of dec iduous treea a nd shrubs The arada varies fro 0 to S percent No water bodies are located within or i-diataly adjacent to tha scrap a rea The IUjorlty of the scrap liu on tha alopu of a s liaht depression which drain to an upland arab A ora steeply s loptna hill whic h borden the liampJS Brook wat e rshed h located to the sout h of tha bullcrap area
1 ~ 2 Scrap CharactariJtics
An asti ted 500 ton s of scrap are situated in the northtast unfe nced area of the s ite The scrap vas brouah t to the site from 1950 to 1976 as part of etal sa lvaae operations that occ urred concurrently with tranampformer reclan~ashytion The scrap consists priarily of car bodiea applianceamp electric eter bodiea aheet metal tirea and metal signa
For the purpoaea of soil sampling beneath the scrap (aee Section 60) the 111ultiph scrap piles have been divi ded into the following sections
Area I Sheet metal and whitt goods Area II Car bodies and tires Ana 1111 Electrical tqutpment and sheet metal
Fiaure 1-1 depicts the location of the scrap area with respect to the fenced portion o( the lite and delinutu the specific scrap area t
-1 shy
e
FIG
UR
E 1
-1
SE
TT
ING
FO
R S
CR
AP
RE
MO
VA
L
F
OC
ON
NO
R S
ITE
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ST
A
MA
INE
bull
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13 Previous Studies
The majority of the environmental sampling at the F OConnor s ite has taken place within the site secur ity fe nce (approxin~ately 250 umplu have been lUll collected from Tunsformer Work Area (TWA) I TWA II and associated drainshyages) Thirty-five samples were also collected and analyzed fr0111 outside the I security fence during Tour I to aueu PCB concentra tions in and around TWA III four of theae samples were analyzed for HSL organ ica and inorganics The results of Tour 1 surface soil sampling in TWA Ill indicate that PCB concenshytrations ra nse fr0111 660 ppm to nondetectable concentrations (less than 1 ppra) a nd are limited to a 2500 square foot area located alons the site access road HSL organic (excluding PCBa) and inorganic chemicals do not exist above area background concentrations Figure 1-2 illustrates Tour 1 analytical PCB result s fo r surface so U sampling at TWA III
20 REMOVAL LOGISTICS
The reova l of scrap atniah stockpiled beyond TWA 111 at the r OConnor site will requi re the use of severa l pieces of heavy equipcMnt (e J front
~d~s~k~ede~~ro~ ~~~~c ~p ~n~=~ =~~~ ~nt- ( - in an overview capacity end to ai d i n the clauif ica tion of scrap The followina section i dentif ies the roles of on-site personnel describes the roval operation and the use of heavy equtpnt and de tail s the heavy equipshy0 nt decontabullination procedures a t the close of the reoval proarabull
21 On-Site Personnel
Scrap reovd operat ions can be di vi ded into the following responsibilities
~~Xamp o P rooovo l - Hvy oquipmont opontolt 0
V ~ ( manifesting i den tification and handling of scra p that may require0 s pecial ha ndling (fluld-fUled e l ectrica l equipment) - QIP shy~
project raanagement - Jordan
~~c ~ k~sts the designated personnel and their specific role for each of
22 Reaval Operations
The scrap reraoval operation will begin with a rainor upgrade of the scrap area acceu road which is located north and east of the scrap area t hrough the Rodrique property The road improve111ent will consist of place11ent and gradins of aravel (approxi-tely ten yards) in three low areas along the road and the construction of a gravel truck loading pad on the western1110st end of the exisshytinamp scrap pile
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Fo llow ing t he road i mprovement operations scrap remova l wi ll comme nce i n t he most wes t er l y portion of the Scrap Area I and wil l proceed t hrough Scra p Area 111 (see Ftsu r e 2-1) The r emova l operations are expected to include bu t are (~middotmiddot not limited to t he following pieces of equipment sraall bulldozer large
Ibckhoe front end loader and a minimum of two 14 or 18 cubic yard d ump trucks The removal will proceed in the following manner
A dUlllp truck will be stased on the newly constructed gravel loading pad
Piles within each scrap area (Scrap Areas 1 11 and 111) will be identified numbered and photographed by Jordan personnel
Each pile in the iramediate area of removal will be carefully (~~ ) searched by CHP on-site personnel for any flu id-fil l ed electrical ( e qu ipa~ent (see Section 50)
After a pile has been designated as clean (f r ee of flui d- fill ed-~_ bull 1
a l ect rlca l equ i pme nt) t he scrap will be pu lled dovn t o th a l oadina pad with t he dozer a nd loaded into the truck with the front a nd loa dar The genera l contents of e ach pile will ba recorded durina th is process by J orda n personne 1
Thh proceu will cont i nue until t he s t aaed truck h full tha bill of l ad i na will the n be sts ned a nd the ruteriah will ba re-oved to an appropriat e dh pou l fac ility (ue Sac tion s 41 and 4 2 Trans shyportationDh pou l) Th e aecond truck wi ll be 1110ved t o the load ina pad and the raoval proceu will continue
As the sc rap remova l prog r esses toward Sc rap Area III the pull- down ampone betwee n the t ru cks a nd th e scrap wil l neceua rily bacoe a l onshya a t ed (see Fi gure 2-1) However t hroughout th e reiIOVSl process t he l oad i ng of t rucks will only take place at tha l oa d i ng pad Th is procedur e h instituted to avoid contact of the t r uck wheels wit h unc haracterhed soils previously located beneath t he scrap In this ma nner the trucks will be able to move off the loading pad and ultimately off-site without requiring decontamination
In the course of the scrap search and removal process areas of conshycern as identified by CHP Jordan and USEPA 1 will be isolated (either by cones or bar rier tape from the scrap blling pulled down by the dozer These identified areas will become the designated Phase 11 soil sampling locations described in Section 60 The handling of any fluid-filled electric equipn~ent that might be discovered in the searching proceu is addressed in Section 50
To avoid raove11ent of heavy equipment across known conta11inated sol Is in the TWA lll area 111ateriah located in Scrap Area 111 will be MOved from Scrap Area lll to the pulldown zone by hand or with wheal
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barrows This precaution will be undertaken to avoid exceuive disshyturbance of soils previousl y characterized during Tour I surface soil sampling (see Figure 1-2) Any mate rials tha t cannot be removed in this fashion from this area will remain at their current location Two very large bush ings located adjacent to the TWA III are examples of the types of mat e rlala that will not be removed during this operation
23 Decontaminat ion of Equipment
Following completion of the sc rap removal program decon t arli nation of removal eq uipmen t tracks a nd or tires will be performed a s a preca utionary 11easure to avoid the off-site transport of site-derived soils Decontamtncion will be accomplished in a 25-foot l ong by 20-foot wide nea located near the truck loading pad (designated as the decon area in Fiaure 2-1) The decon area (to be constructed by a dozer) will consist of a sliahtly inclined flat around surface with berr~ed edaes running along the lenath of the s lope This area will be lined with plutic and covered with 34-inch plywood and its ban a 16 x 3 x 4 ( deep) trench (excavated by the backhoe) will serve as a catch- IHnt basin for the decontar~ination water Durinamp use of the decon area each piece of equipcaent will enter the upper portion vhere vehicle trackstires will be washed down of all loose dirt usina a water truck These washinas will drain on the plutic to the containment trench and in this aanner avoid r unoff The equipcHnt will then be loaded directly onto its carrytna flatbed at the loadina pad for off-site transport
Upon copletion of scrap re~Ktval the decon area will be disntled The plastic will be containeriud for s ubampeque nt off-site disposal the plywood wlll be stored within the security fence for possible future use and the aravel will be retained in-place and addrened as part of the total site nuaediation
30 PERSONAL PROTECTION
The 11intmu11 level of personal pro t ec tion thc will be reco-ended to all on-site personnel a nd utilized by Jordan at the F OConnor site durinamp tcrap removal operations will be Level D dermal and respito ry protection The scrap 1s considered be nign taking into account t he history of the operations and pendina Phue 1 sampling results (tee Section 61) work glovu should however be worn to avoid c uts Since the scrap is assumed to be located in a clean trea i n ten11s of soil chemicals and tnnsportion through TWA III will be restricted it is antici pated that the removal of the scrap will not cbulluse atmospheric cont bullllination3in the range of the Threshold Limit Vtue (TLV) for PCBs (05 to 10 mam ) If excessive airborne dust particles 111re produced durinamp scrap removal then wearing of dust mukt will be recofiended aa a precbullutionary meuura (this judgment will be made by the Jordan site safety oHicer)
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The Level D persona l protection gear will consist of the following
cotton coveralh Jtee l - toed chemicll resiatl nt boot s hard hat ear protection (optional) cottonluther gloves (when contac t with the scrap is anticipated)
The UCOIIIIM nded level of protection will be upsuded to Leve l C dermal for person ne l who will be involved with larkinamp of fluid-f i lled electrica l equipment The Level C de r1111l personal protection gear conaists of all the items noted for Level D dermbull l except cotton cover1lh 1nd work stoves will be replaced with c hemtc1l ly protective coveralla 1nd inner 1nd outer gloves
Person l decont1minbulltton will consist of diapoaina of bull ny che11tcll-reais t a n t cloth inamp or du s t muka t hbull t bullre worn into phstic aarbbullae bbullampbull for subuque nt stonae on-site in DOT bull pproved 55-ampbullllon drw Boot deconta11in1tion fbullctlitiea (bucketa nd scrub brushea) will be bullvailable aince on-site personnel 11ay h1ve to enter the TWA III 1re1
Add ittonll i nfor-1tion re11rdi n1 Jord1n a hed t h 1nd ufety procedures Cln be fou nd in the at t e Project Operations Plan (POP) June 1986
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS
Followina load t na t he scrap will be transported to bull nd disposed of at a disshypout location that 1a JWtually aareeable to USPA Maine DP and CMP It is proposed that the City o f Auausta Hatch Hill Lbullndfill Auausta Maine located approximately fou r (4) bullilu f r0111 the site be utiliud for d isposal of the scnp Transportation 1 nd diapoul at this site will be handled in the fol lowtna 111 nne r
Two hiamph-wdled 14 or 18 cubic y1rd trucka each haulinamp a max i11un lo1d of 35000 lbs will be utilized to t ransport the scrap to Hatch Hill Landfill Consideri ng the anticipbullted 500 tons of scrap approximbulltely 30 trips to the landfill bullre 1 nt ictpate d The scra p will be covered with canv1s covera 1 nd stabilized aa necessary uainamp ropes tarps e t c
Decontbullnin1 tion of truck tires prior to site dep1rture ha s not been s pecif ied abull trucks dastsnlted for off-site transport will be reatricted to arua known to be cle1n based on Tour I analytical resu l ts
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I I I I
Aa a matter of good record keep i ng a bill opound lad i ng will accompany ea ch scrap load Th is doc ument a t i on will be prepand by the r emova l contractor a nd wi ll inc lude
name a nd address of the t ra nsporter or iain o f th e sc ra p c ha rac t e ri s t i c s of the scrap u tbiiA t e d quantity o f the scrap and fi na l disposa l destinat ion
CHP the removal cont rac t or a nd Ha tch Hill Landfi ll will stan the bi ll of lad i ng fo r each l oad The orta i nal wil l be r etaine d i n CHP fi l es copies will be d istr ibuted to Int e res t ed par ties
42 Disposal
Disposa l of the scrap a t Ha tch Hill Landfill will be routine Th e only required perbullit utablishu authorized uae of Hatch Hill Landfill This pershybullit is to be obtained by the contractor fr011 the City of Auausta it speciflu na and loccion of the hauler and reaistration inforMation for each vehicle to be used for scrap delivery to Hatch Hill Landfill
Hatch Hill Landfill hours en libullited to 8 00 a bullbullbull to 400 Pbullbullbullbull Tuesday throuah Friday The scrap will arrive in loads that confom with the specishyfied atoraae piles and areu at tch Hill Landfill Hatch Hill raquiru that electric Mter bodiu arrive uparauly Tires are separated fro Mtal and fluids (such aa tranabulliuion oil) are re~~aved fron autoobile bodies Then f~uida will be collected and disposed of at local oil depository locations
50 SPECIAL HANDLING LOGISTICS
Durinamp the re110val of the scrap from the F OConnor si t e fluid- filled elec trical equipntent bull ay be discovered In ant icipati ng th is occurre nce t his sec tion outlines the i dentification of a nd fiel d l ogist ics conce rn i ng the electr ica l e quip11ent
5 1 Equipment Identif i ca tion
A CHP representat ive will be on-site on a part-time basis to ide ntify a ny scra p t hc is no t considered conve ntion a l aolid waste Fl u id-filled electri shycal eq ui pbullent will re qu ire s pecial consideration due to it a potential PCB conte nt
Upon identification the electrical e qul pbullent will be numbered inventori ed a taaed and left on-site In an undisturbed s tate Underlytna s c rap located adjacent to the fluid-filled electrical equtpr~ent that exh i bits oil stains will also be left In place Personnel will upgrade their level of protection
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to Level C dermal (aee Section 30) when marking and working among the fluidshyfilled electrical equ ipment The equipment will be numbered with a paint marker us ing a predetermined numbering system for field designation They will then be logged into the pr oject records which will note
date of discovery fhld designation numbe r location description not a tion of r~anufactulers identification plate evidence of any spill associated with the item
A sraall area around the equipment will be isolated with cones or barrier tape to ensure that this area is not disturbed or trafficked during the removal process as described in Section 20 Subsequent to the completion of the scrap reaval operation the nature and quantity of fluid-filled equipa~ent will be evaluated and an appropriate plan for preferred dispoampition of this terial will be developed The plan will be coordinated aMOng CHP Jordan end the reaulatory aaencies prior to implementationbull
52 Spill Provisions
Thouah the occurrence of spills is not expected durinamp scrap reavt operashytiona at the r OConnor aite provisions for spilh vill ba provided Spill equis-ent will consist of oil sorbent hbrics ha nd tools and containers for disposal of the spill uriah The on-site equipn~ent will include
ten 18 X 18 aorbent pillows tvo rolla of oil sorbent polypropylene four 10-foot lenaths of 5 vide containment bo011 three 55-aallon drun~s for disposal of spill mceriah two hand shove h
This aquipent vill be phced in the vicinity of the acra p reMOvd operations In the event of a apill saturated materials muat be disposed of in compliance vith StateFederal regu lac ions
6 0 SCRAP AREA SOIL SAMPLING PROGRAM
To useaa the presence of c hemicals in aoils located beneath the acrap (ie metal auto-bodies tires and white goods) beyond TWA III a aurhce aoil u11plina proaram will be performed The sampli ng program describinamp the nunshyber and type of umplea to be collected h presented in the follovina para shyaraphs
A bullaximum of tvo compoaite samples will be collected fr011 each of the three designated acrap areas a prell11inary backaround aoil characterhat ion cocshypoampite (Phase I Ullpling) and a post-re110val characterhation composite (Phase II sampllna)
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61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
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The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
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I I
SCRAP REHOVAL LOGISTICS PLAN
TABLE OF CONTENTS
SECTION TITLE
10 INTRODUCTION bullbullbullbull bull 11 Site Settingbullbullbullbull 12 Scrap Characteristics 1 3 Previous Studies
20 RHOVAL LOGISTICSbullbullbull 21 On-Sit e Personnel 22 Reaval Operations bullbullbullbullbullbull 23 Deconta~aination of Equipment
30 PIRSOIIAL PROTECTION
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS) 41 Tranaportation 42 Dlaposal
5 0 SPECIAL HANDLING LOGISTICS 51 Equipunt Identification 52 Spill Provisions
60 SCRAP AREA SOIL SAMPLING PROGRAM 61 Phue I Sa11plina 62 Phue 11 Sampling
70 SCHEDULE
PAGE NO
10
10 10 11
11 12 12
12
SCRAP REMOVAL LOGISTICS PLAN
TARLE OF FIGURES
FIGURE TITLE PAGE NO
~ 1-1 Site Setting for Scnp Removal ~l 1-2 Scrap Area Surface Soil Sa11ple Locationa with
PCB Screen Resulta bull n 2-1 Equipment Hove11ent Loshtics bull ~0
I ~
LIST OF TABLES
) TABLE TITLE PACE 110
2-1 Re sponbullible Parties and Dedanated Ruponlibilitt
10 INTRODUCTION
This plan desc ribes scrap removal operations thst are scheduled to take pllce at the F OConnor site in August a Maine during August 1987 The plan conshysists of seven sections including an i n troduction to the project lite loahtics for scrap reiDOVal transportation and disposa l personnel health a nd safety equipment decontamination special handling procedures for fluidshyfilled electrical equipment that n~ay be encountered scrap area aoil samplins prosram and project acheduh Figures and tablebull havt been included aa necessary for clarification
It 11 aiiUIDtd that approval of this plan by USEPA and Maine Department of Environmental Protection (DEP) constitutes acceptance of all activitits desshycribed herein no permits or additional approvals will be required
11 Site Stttina
The acnp area is part of the F OConnor Superfund site in Auguata Maine Tha scrap (ducribed balow) lias in an area tediately to the northeut of tha site fence and partially covers an a rea that exte ndamp to a st one vall located epproxi-uly 200 feet to t he north of the hnce Much of thil area is forested with conifers and a thick underbruah of dec iduous treea a nd shrubs The arada varies fro 0 to S percent No water bodies are located within or i-diataly adjacent to tha scrap a rea The IUjorlty of the scrap liu on tha alopu of a s liaht depression which drain to an upland arab A ora steeply s loptna hill whic h borden the liampJS Brook wat e rshed h located to the sout h of tha bullcrap area
1 ~ 2 Scrap CharactariJtics
An asti ted 500 ton s of scrap are situated in the northtast unfe nced area of the s ite The scrap vas brouah t to the site from 1950 to 1976 as part of etal sa lvaae operations that occ urred concurrently with tranampformer reclan~ashytion The scrap consists priarily of car bodiea applianceamp electric eter bodiea aheet metal tirea and metal signa
For the purpoaea of soil sampling beneath the scrap (aee Section 60) the 111ultiph scrap piles have been divi ded into the following sections
Area I Sheet metal and whitt goods Area II Car bodies and tires Ana 1111 Electrical tqutpment and sheet metal
Fiaure 1-1 depicts the location of the scrap area with respect to the fenced portion o( the lite and delinutu the specific scrap area t
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13 Previous Studies
The majority of the environmental sampling at the F OConnor s ite has taken place within the site secur ity fe nce (approxin~ately 250 umplu have been lUll collected from Tunsformer Work Area (TWA) I TWA II and associated drainshyages) Thirty-five samples were also collected and analyzed fr0111 outside the I security fence during Tour I to aueu PCB concentra tions in and around TWA III four of theae samples were analyzed for HSL organ ica and inorganics The results of Tour 1 surface soil sampling in TWA Ill indicate that PCB concenshytrations ra nse fr0111 660 ppm to nondetectable concentrations (less than 1 ppra) a nd are limited to a 2500 square foot area located alons the site access road HSL organic (excluding PCBa) and inorganic chemicals do not exist above area background concentrations Figure 1-2 illustrates Tour 1 analytical PCB result s fo r surface so U sampling at TWA III
20 REMOVAL LOGISTICS
The reova l of scrap atniah stockpiled beyond TWA 111 at the r OConnor site will requi re the use of severa l pieces of heavy equipcMnt (e J front
~d~s~k~ede~~ro~ ~~~~c ~p ~n~=~ =~~~ ~nt- ( - in an overview capacity end to ai d i n the clauif ica tion of scrap The followina section i dentif ies the roles of on-site personnel describes the roval operation and the use of heavy equtpnt and de tail s the heavy equipshy0 nt decontabullination procedures a t the close of the reoval proarabull
21 On-Site Personnel
Scrap reovd operat ions can be di vi ded into the following responsibilities
~~Xamp o P rooovo l - Hvy oquipmont opontolt 0
V ~ ( manifesting i den tification and handling of scra p that may require0 s pecial ha ndling (fluld-fUled e l ectrica l equipment) - QIP shy~
project raanagement - Jordan
~~c ~ k~sts the designated personnel and their specific role for each of
22 Reaval Operations
The scrap reraoval operation will begin with a rainor upgrade of the scrap area acceu road which is located north and east of the scrap area t hrough the Rodrique property The road improve111ent will consist of place11ent and gradins of aravel (approxi-tely ten yards) in three low areas along the road and the construction of a gravel truck loading pad on the western1110st end of the exisshytinamp scrap pile
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IJiMltil
Fo llow ing t he road i mprovement operations scrap remova l wi ll comme nce i n t he most wes t er l y portion of the Scrap Area I and wil l proceed t hrough Scra p Area 111 (see Ftsu r e 2-1) The r emova l operations are expected to include bu t are (~middotmiddot not limited to t he following pieces of equipment sraall bulldozer large
Ibckhoe front end loader and a minimum of two 14 or 18 cubic yard d ump trucks The removal will proceed in the following manner
A dUlllp truck will be stased on the newly constructed gravel loading pad
Piles within each scrap area (Scrap Areas 1 11 and 111) will be identified numbered and photographed by Jordan personnel
Each pile in the iramediate area of removal will be carefully (~~ ) searched by CHP on-site personnel for any flu id-fil l ed electrical ( e qu ipa~ent (see Section 50)
After a pile has been designated as clean (f r ee of flui d- fill ed-~_ bull 1
a l ect rlca l equ i pme nt) t he scrap will be pu lled dovn t o th a l oadina pad with t he dozer a nd loaded into the truck with the front a nd loa dar The genera l contents of e ach pile will ba recorded durina th is process by J orda n personne 1
Thh proceu will cont i nue until t he s t aaed truck h full tha bill of l ad i na will the n be sts ned a nd the ruteriah will ba re-oved to an appropriat e dh pou l fac ility (ue Sac tion s 41 and 4 2 Trans shyportationDh pou l) Th e aecond truck wi ll be 1110ved t o the load ina pad and the raoval proceu will continue
As the sc rap remova l prog r esses toward Sc rap Area III the pull- down ampone betwee n the t ru cks a nd th e scrap wil l neceua rily bacoe a l onshya a t ed (see Fi gure 2-1) However t hroughout th e reiIOVSl process t he l oad i ng of t rucks will only take place at tha l oa d i ng pad Th is procedur e h instituted to avoid contact of the t r uck wheels wit h unc haracterhed soils previously located beneath t he scrap In this ma nner the trucks will be able to move off the loading pad and ultimately off-site without requiring decontamination
In the course of the scrap search and removal process areas of conshycern as identified by CHP Jordan and USEPA 1 will be isolated (either by cones or bar rier tape from the scrap blling pulled down by the dozer These identified areas will become the designated Phase 11 soil sampling locations described in Section 60 The handling of any fluid-filled electric equipn~ent that might be discovered in the searching proceu is addressed in Section 50
To avoid raove11ent of heavy equipment across known conta11inated sol Is in the TWA lll area 111ateriah located in Scrap Area 111 will be MOved from Scrap Area lll to the pulldown zone by hand or with wheal
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barrows This precaution will be undertaken to avoid exceuive disshyturbance of soils previousl y characterized during Tour I surface soil sampling (see Figure 1-2) Any mate rials tha t cannot be removed in this fashion from this area will remain at their current location Two very large bush ings located adjacent to the TWA III are examples of the types of mat e rlala that will not be removed during this operation
23 Decontaminat ion of Equipment
Following completion of the sc rap removal program decon t arli nation of removal eq uipmen t tracks a nd or tires will be performed a s a preca utionary 11easure to avoid the off-site transport of site-derived soils Decontamtncion will be accomplished in a 25-foot l ong by 20-foot wide nea located near the truck loading pad (designated as the decon area in Fiaure 2-1) The decon area (to be constructed by a dozer) will consist of a sliahtly inclined flat around surface with berr~ed edaes running along the lenath of the s lope This area will be lined with plutic and covered with 34-inch plywood and its ban a 16 x 3 x 4 ( deep) trench (excavated by the backhoe) will serve as a catch- IHnt basin for the decontar~ination water Durinamp use of the decon area each piece of equipcaent will enter the upper portion vhere vehicle trackstires will be washed down of all loose dirt usina a water truck These washinas will drain on the plutic to the containment trench and in this aanner avoid r unoff The equipcHnt will then be loaded directly onto its carrytna flatbed at the loadina pad for off-site transport
Upon copletion of scrap re~Ktval the decon area will be disntled The plastic will be containeriud for s ubampeque nt off-site disposal the plywood wlll be stored within the security fence for possible future use and the aravel will be retained in-place and addrened as part of the total site nuaediation
30 PERSONAL PROTECTION
The 11intmu11 level of personal pro t ec tion thc will be reco-ended to all on-site personnel a nd utilized by Jordan at the F OConnor site durinamp tcrap removal operations will be Level D dermal and respito ry protection The scrap 1s considered be nign taking into account t he history of the operations and pendina Phue 1 sampling results (tee Section 61) work glovu should however be worn to avoid c uts Since the scrap is assumed to be located in a clean trea i n ten11s of soil chemicals and tnnsportion through TWA III will be restricted it is antici pated that the removal of the scrap will not cbulluse atmospheric cont bullllination3in the range of the Threshold Limit Vtue (TLV) for PCBs (05 to 10 mam ) If excessive airborne dust particles 111re produced durinamp scrap removal then wearing of dust mukt will be recofiended aa a precbullutionary meuura (this judgment will be made by the Jordan site safety oHicer)
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I I I I
ttil (~rII
The Level D persona l protection gear will consist of the following
cotton coveralh Jtee l - toed chemicll resiatl nt boot s hard hat ear protection (optional) cottonluther gloves (when contac t with the scrap is anticipated)
The UCOIIIIM nded level of protection will be upsuded to Leve l C dermal for person ne l who will be involved with larkinamp of fluid-f i lled electrica l equipment The Level C de r1111l personal protection gear conaists of all the items noted for Level D dermbull l except cotton cover1lh 1nd work stoves will be replaced with c hemtc1l ly protective coveralla 1nd inner 1nd outer gloves
Person l decont1minbulltton will consist of diapoaina of bull ny che11tcll-reais t a n t cloth inamp or du s t muka t hbull t bullre worn into phstic aarbbullae bbullampbull for subuque nt stonae on-site in DOT bull pproved 55-ampbullllon drw Boot deconta11in1tion fbullctlitiea (bucketa nd scrub brushea) will be bullvailable aince on-site personnel 11ay h1ve to enter the TWA III 1re1
Add ittonll i nfor-1tion re11rdi n1 Jord1n a hed t h 1nd ufety procedures Cln be fou nd in the at t e Project Operations Plan (POP) June 1986
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS
Followina load t na t he scrap will be transported to bull nd disposed of at a disshypout location that 1a JWtually aareeable to USPA Maine DP and CMP It is proposed that the City o f Auausta Hatch Hill Lbullndfill Auausta Maine located approximately fou r (4) bullilu f r0111 the site be utiliud for d isposal of the scnp Transportation 1 nd diapoul at this site will be handled in the fol lowtna 111 nne r
Two hiamph-wdled 14 or 18 cubic y1rd trucka each haulinamp a max i11un lo1d of 35000 lbs will be utilized to t ransport the scrap to Hatch Hill Landfill Consideri ng the anticipbullted 500 tons of scrap approximbulltely 30 trips to the landfill bullre 1 nt ictpate d The scra p will be covered with canv1s covera 1 nd stabilized aa necessary uainamp ropes tarps e t c
Decontbullnin1 tion of truck tires prior to site dep1rture ha s not been s pecif ied abull trucks dastsnlted for off-site transport will be reatricted to arua known to be cle1n based on Tour I analytical resu l ts
-middotshy
I I I I
Aa a matter of good record keep i ng a bill opound lad i ng will accompany ea ch scrap load Th is doc ument a t i on will be prepand by the r emova l contractor a nd wi ll inc lude
name a nd address of the t ra nsporter or iain o f th e sc ra p c ha rac t e ri s t i c s of the scrap u tbiiA t e d quantity o f the scrap and fi na l disposa l destinat ion
CHP the removal cont rac t or a nd Ha tch Hill Landfi ll will stan the bi ll of lad i ng fo r each l oad The orta i nal wil l be r etaine d i n CHP fi l es copies will be d istr ibuted to Int e res t ed par ties
42 Disposal
Disposa l of the scrap a t Ha tch Hill Landfill will be routine Th e only required perbullit utablishu authorized uae of Hatch Hill Landfill This pershybullit is to be obtained by the contractor fr011 the City of Auausta it speciflu na and loccion of the hauler and reaistration inforMation for each vehicle to be used for scrap delivery to Hatch Hill Landfill
Hatch Hill Landfill hours en libullited to 8 00 a bullbullbull to 400 Pbullbullbullbull Tuesday throuah Friday The scrap will arrive in loads that confom with the specishyfied atoraae piles and areu at tch Hill Landfill Hatch Hill raquiru that electric Mter bodiu arrive uparauly Tires are separated fro Mtal and fluids (such aa tranabulliuion oil) are re~~aved fron autoobile bodies Then f~uida will be collected and disposed of at local oil depository locations
50 SPECIAL HANDLING LOGISTICS
Durinamp the re110val of the scrap from the F OConnor si t e fluid- filled elec trical equipntent bull ay be discovered In ant icipati ng th is occurre nce t his sec tion outlines the i dentification of a nd fiel d l ogist ics conce rn i ng the electr ica l e quip11ent
5 1 Equipment Identif i ca tion
A CHP representat ive will be on-site on a part-time basis to ide ntify a ny scra p t hc is no t considered conve ntion a l aolid waste Fl u id-filled electri shycal eq ui pbullent will re qu ire s pecial consideration due to it a potential PCB conte nt
Upon identification the electrical e qul pbullent will be numbered inventori ed a taaed and left on-site In an undisturbed s tate Underlytna s c rap located adjacent to the fluid-filled electrical equtpr~ent that exh i bits oil stains will also be left In place Personnel will upgrade their level of protection
- 10shy
to Level C dermal (aee Section 30) when marking and working among the fluidshyfilled electrical equ ipment The equipment will be numbered with a paint marker us ing a predetermined numbering system for field designation They will then be logged into the pr oject records which will note
date of discovery fhld designation numbe r location description not a tion of r~anufactulers identification plate evidence of any spill associated with the item
A sraall area around the equipment will be isolated with cones or barrier tape to ensure that this area is not disturbed or trafficked during the removal process as described in Section 20 Subsequent to the completion of the scrap reaval operation the nature and quantity of fluid-filled equipa~ent will be evaluated and an appropriate plan for preferred dispoampition of this terial will be developed The plan will be coordinated aMOng CHP Jordan end the reaulatory aaencies prior to implementationbull
52 Spill Provisions
Thouah the occurrence of spills is not expected durinamp scrap reavt operashytiona at the r OConnor aite provisions for spilh vill ba provided Spill equis-ent will consist of oil sorbent hbrics ha nd tools and containers for disposal of the spill uriah The on-site equipn~ent will include
ten 18 X 18 aorbent pillows tvo rolla of oil sorbent polypropylene four 10-foot lenaths of 5 vide containment bo011 three 55-aallon drun~s for disposal of spill mceriah two hand shove h
This aquipent vill be phced in the vicinity of the acra p reMOvd operations In the event of a apill saturated materials muat be disposed of in compliance vith StateFederal regu lac ions
6 0 SCRAP AREA SOIL SAMPLING PROGRAM
To useaa the presence of c hemicals in aoils located beneath the acrap (ie metal auto-bodies tires and white goods) beyond TWA III a aurhce aoil u11plina proaram will be performed The sampli ng program describinamp the nunshyber and type of umplea to be collected h presented in the follovina para shyaraphs
A bullaximum of tvo compoaite samples will be collected fr011 each of the three designated acrap areas a prell11inary backaround aoil characterhat ion cocshypoampite (Phase I Ullpling) and a post-re110val characterhation composite (Phase II sampllna)
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I I I I
61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
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The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
-13shy
SCRAP REMOVAL LOGISTICS PLAN
TARLE OF FIGURES
FIGURE TITLE PAGE NO
~ 1-1 Site Setting for Scnp Removal ~l 1-2 Scrap Area Surface Soil Sa11ple Locationa with
PCB Screen Resulta bull n 2-1 Equipment Hove11ent Loshtics bull ~0
I ~
LIST OF TABLES
) TABLE TITLE PACE 110
2-1 Re sponbullible Parties and Dedanated Ruponlibilitt
10 INTRODUCTION
This plan desc ribes scrap removal operations thst are scheduled to take pllce at the F OConnor site in August a Maine during August 1987 The plan conshysists of seven sections including an i n troduction to the project lite loahtics for scrap reiDOVal transportation and disposa l personnel health a nd safety equipment decontamination special handling procedures for fluidshyfilled electrical equipment that n~ay be encountered scrap area aoil samplins prosram and project acheduh Figures and tablebull havt been included aa necessary for clarification
It 11 aiiUIDtd that approval of this plan by USEPA and Maine Department of Environmental Protection (DEP) constitutes acceptance of all activitits desshycribed herein no permits or additional approvals will be required
11 Site Stttina
The acnp area is part of the F OConnor Superfund site in Auguata Maine Tha scrap (ducribed balow) lias in an area tediately to the northeut of tha site fence and partially covers an a rea that exte ndamp to a st one vall located epproxi-uly 200 feet to t he north of the hnce Much of thil area is forested with conifers and a thick underbruah of dec iduous treea a nd shrubs The arada varies fro 0 to S percent No water bodies are located within or i-diataly adjacent to tha scrap a rea The IUjorlty of the scrap liu on tha alopu of a s liaht depression which drain to an upland arab A ora steeply s loptna hill whic h borden the liampJS Brook wat e rshed h located to the sout h of tha bullcrap area
1 ~ 2 Scrap CharactariJtics
An asti ted 500 ton s of scrap are situated in the northtast unfe nced area of the s ite The scrap vas brouah t to the site from 1950 to 1976 as part of etal sa lvaae operations that occ urred concurrently with tranampformer reclan~ashytion The scrap consists priarily of car bodiea applianceamp electric eter bodiea aheet metal tirea and metal signa
For the purpoaea of soil sampling beneath the scrap (aee Section 60) the 111ultiph scrap piles have been divi ded into the following sections
Area I Sheet metal and whitt goods Area II Car bodies and tires Ana 1111 Electrical tqutpment and sheet metal
Fiaure 1-1 depicts the location of the scrap area with respect to the fenced portion o( the lite and delinutu the specific scrap area t
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13 Previous Studies
The majority of the environmental sampling at the F OConnor s ite has taken place within the site secur ity fe nce (approxin~ately 250 umplu have been lUll collected from Tunsformer Work Area (TWA) I TWA II and associated drainshyages) Thirty-five samples were also collected and analyzed fr0111 outside the I security fence during Tour I to aueu PCB concentra tions in and around TWA III four of theae samples were analyzed for HSL organ ica and inorganics The results of Tour 1 surface soil sampling in TWA Ill indicate that PCB concenshytrations ra nse fr0111 660 ppm to nondetectable concentrations (less than 1 ppra) a nd are limited to a 2500 square foot area located alons the site access road HSL organic (excluding PCBa) and inorganic chemicals do not exist above area background concentrations Figure 1-2 illustrates Tour 1 analytical PCB result s fo r surface so U sampling at TWA III
20 REMOVAL LOGISTICS
The reova l of scrap atniah stockpiled beyond TWA 111 at the r OConnor site will requi re the use of severa l pieces of heavy equipcMnt (e J front
~d~s~k~ede~~ro~ ~~~~c ~p ~n~=~ =~~~ ~nt- ( - in an overview capacity end to ai d i n the clauif ica tion of scrap The followina section i dentif ies the roles of on-site personnel describes the roval operation and the use of heavy equtpnt and de tail s the heavy equipshy0 nt decontabullination procedures a t the close of the reoval proarabull
21 On-Site Personnel
Scrap reovd operat ions can be di vi ded into the following responsibilities
~~Xamp o P rooovo l - Hvy oquipmont opontolt 0
V ~ ( manifesting i den tification and handling of scra p that may require0 s pecial ha ndling (fluld-fUled e l ectrica l equipment) - QIP shy~
project raanagement - Jordan
~~c ~ k~sts the designated personnel and their specific role for each of
22 Reaval Operations
The scrap reraoval operation will begin with a rainor upgrade of the scrap area acceu road which is located north and east of the scrap area t hrough the Rodrique property The road improve111ent will consist of place11ent and gradins of aravel (approxi-tely ten yards) in three low areas along the road and the construction of a gravel truck loading pad on the western1110st end of the exisshytinamp scrap pile
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I I I I
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Fo llow ing t he road i mprovement operations scrap remova l wi ll comme nce i n t he most wes t er l y portion of the Scrap Area I and wil l proceed t hrough Scra p Area 111 (see Ftsu r e 2-1) The r emova l operations are expected to include bu t are (~middotmiddot not limited to t he following pieces of equipment sraall bulldozer large
Ibckhoe front end loader and a minimum of two 14 or 18 cubic yard d ump trucks The removal will proceed in the following manner
A dUlllp truck will be stased on the newly constructed gravel loading pad
Piles within each scrap area (Scrap Areas 1 11 and 111) will be identified numbered and photographed by Jordan personnel
Each pile in the iramediate area of removal will be carefully (~~ ) searched by CHP on-site personnel for any flu id-fil l ed electrical ( e qu ipa~ent (see Section 50)
After a pile has been designated as clean (f r ee of flui d- fill ed-~_ bull 1
a l ect rlca l equ i pme nt) t he scrap will be pu lled dovn t o th a l oadina pad with t he dozer a nd loaded into the truck with the front a nd loa dar The genera l contents of e ach pile will ba recorded durina th is process by J orda n personne 1
Thh proceu will cont i nue until t he s t aaed truck h full tha bill of l ad i na will the n be sts ned a nd the ruteriah will ba re-oved to an appropriat e dh pou l fac ility (ue Sac tion s 41 and 4 2 Trans shyportationDh pou l) Th e aecond truck wi ll be 1110ved t o the load ina pad and the raoval proceu will continue
As the sc rap remova l prog r esses toward Sc rap Area III the pull- down ampone betwee n the t ru cks a nd th e scrap wil l neceua rily bacoe a l onshya a t ed (see Fi gure 2-1) However t hroughout th e reiIOVSl process t he l oad i ng of t rucks will only take place at tha l oa d i ng pad Th is procedur e h instituted to avoid contact of the t r uck wheels wit h unc haracterhed soils previously located beneath t he scrap In this ma nner the trucks will be able to move off the loading pad and ultimately off-site without requiring decontamination
In the course of the scrap search and removal process areas of conshycern as identified by CHP Jordan and USEPA 1 will be isolated (either by cones or bar rier tape from the scrap blling pulled down by the dozer These identified areas will become the designated Phase 11 soil sampling locations described in Section 60 The handling of any fluid-filled electric equipn~ent that might be discovered in the searching proceu is addressed in Section 50
To avoid raove11ent of heavy equipment across known conta11inated sol Is in the TWA lll area 111ateriah located in Scrap Area 111 will be MOved from Scrap Area lll to the pulldown zone by hand or with wheal
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barrows This precaution will be undertaken to avoid exceuive disshyturbance of soils previousl y characterized during Tour I surface soil sampling (see Figure 1-2) Any mate rials tha t cannot be removed in this fashion from this area will remain at their current location Two very large bush ings located adjacent to the TWA III are examples of the types of mat e rlala that will not be removed during this operation
23 Decontaminat ion of Equipment
Following completion of the sc rap removal program decon t arli nation of removal eq uipmen t tracks a nd or tires will be performed a s a preca utionary 11easure to avoid the off-site transport of site-derived soils Decontamtncion will be accomplished in a 25-foot l ong by 20-foot wide nea located near the truck loading pad (designated as the decon area in Fiaure 2-1) The decon area (to be constructed by a dozer) will consist of a sliahtly inclined flat around surface with berr~ed edaes running along the lenath of the s lope This area will be lined with plutic and covered with 34-inch plywood and its ban a 16 x 3 x 4 ( deep) trench (excavated by the backhoe) will serve as a catch- IHnt basin for the decontar~ination water Durinamp use of the decon area each piece of equipcaent will enter the upper portion vhere vehicle trackstires will be washed down of all loose dirt usina a water truck These washinas will drain on the plutic to the containment trench and in this aanner avoid r unoff The equipcHnt will then be loaded directly onto its carrytna flatbed at the loadina pad for off-site transport
Upon copletion of scrap re~Ktval the decon area will be disntled The plastic will be containeriud for s ubampeque nt off-site disposal the plywood wlll be stored within the security fence for possible future use and the aravel will be retained in-place and addrened as part of the total site nuaediation
30 PERSONAL PROTECTION
The 11intmu11 level of personal pro t ec tion thc will be reco-ended to all on-site personnel a nd utilized by Jordan at the F OConnor site durinamp tcrap removal operations will be Level D dermal and respito ry protection The scrap 1s considered be nign taking into account t he history of the operations and pendina Phue 1 sampling results (tee Section 61) work glovu should however be worn to avoid c uts Since the scrap is assumed to be located in a clean trea i n ten11s of soil chemicals and tnnsportion through TWA III will be restricted it is antici pated that the removal of the scrap will not cbulluse atmospheric cont bullllination3in the range of the Threshold Limit Vtue (TLV) for PCBs (05 to 10 mam ) If excessive airborne dust particles 111re produced durinamp scrap removal then wearing of dust mukt will be recofiended aa a precbullutionary meuura (this judgment will be made by the Jordan site safety oHicer)
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The Level D persona l protection gear will consist of the following
cotton coveralh Jtee l - toed chemicll resiatl nt boot s hard hat ear protection (optional) cottonluther gloves (when contac t with the scrap is anticipated)
The UCOIIIIM nded level of protection will be upsuded to Leve l C dermal for person ne l who will be involved with larkinamp of fluid-f i lled electrica l equipment The Level C de r1111l personal protection gear conaists of all the items noted for Level D dermbull l except cotton cover1lh 1nd work stoves will be replaced with c hemtc1l ly protective coveralla 1nd inner 1nd outer gloves
Person l decont1minbulltton will consist of diapoaina of bull ny che11tcll-reais t a n t cloth inamp or du s t muka t hbull t bullre worn into phstic aarbbullae bbullampbull for subuque nt stonae on-site in DOT bull pproved 55-ampbullllon drw Boot deconta11in1tion fbullctlitiea (bucketa nd scrub brushea) will be bullvailable aince on-site personnel 11ay h1ve to enter the TWA III 1re1
Add ittonll i nfor-1tion re11rdi n1 Jord1n a hed t h 1nd ufety procedures Cln be fou nd in the at t e Project Operations Plan (POP) June 1986
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS
Followina load t na t he scrap will be transported to bull nd disposed of at a disshypout location that 1a JWtually aareeable to USPA Maine DP and CMP It is proposed that the City o f Auausta Hatch Hill Lbullndfill Auausta Maine located approximately fou r (4) bullilu f r0111 the site be utiliud for d isposal of the scnp Transportation 1 nd diapoul at this site will be handled in the fol lowtna 111 nne r
Two hiamph-wdled 14 or 18 cubic y1rd trucka each haulinamp a max i11un lo1d of 35000 lbs will be utilized to t ransport the scrap to Hatch Hill Landfill Consideri ng the anticipbullted 500 tons of scrap approximbulltely 30 trips to the landfill bullre 1 nt ictpate d The scra p will be covered with canv1s covera 1 nd stabilized aa necessary uainamp ropes tarps e t c
Decontbullnin1 tion of truck tires prior to site dep1rture ha s not been s pecif ied abull trucks dastsnlted for off-site transport will be reatricted to arua known to be cle1n based on Tour I analytical resu l ts
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I I I I
Aa a matter of good record keep i ng a bill opound lad i ng will accompany ea ch scrap load Th is doc ument a t i on will be prepand by the r emova l contractor a nd wi ll inc lude
name a nd address of the t ra nsporter or iain o f th e sc ra p c ha rac t e ri s t i c s of the scrap u tbiiA t e d quantity o f the scrap and fi na l disposa l destinat ion
CHP the removal cont rac t or a nd Ha tch Hill Landfi ll will stan the bi ll of lad i ng fo r each l oad The orta i nal wil l be r etaine d i n CHP fi l es copies will be d istr ibuted to Int e res t ed par ties
42 Disposal
Disposa l of the scrap a t Ha tch Hill Landfill will be routine Th e only required perbullit utablishu authorized uae of Hatch Hill Landfill This pershybullit is to be obtained by the contractor fr011 the City of Auausta it speciflu na and loccion of the hauler and reaistration inforMation for each vehicle to be used for scrap delivery to Hatch Hill Landfill
Hatch Hill Landfill hours en libullited to 8 00 a bullbullbull to 400 Pbullbullbullbull Tuesday throuah Friday The scrap will arrive in loads that confom with the specishyfied atoraae piles and areu at tch Hill Landfill Hatch Hill raquiru that electric Mter bodiu arrive uparauly Tires are separated fro Mtal and fluids (such aa tranabulliuion oil) are re~~aved fron autoobile bodies Then f~uida will be collected and disposed of at local oil depository locations
50 SPECIAL HANDLING LOGISTICS
Durinamp the re110val of the scrap from the F OConnor si t e fluid- filled elec trical equipntent bull ay be discovered In ant icipati ng th is occurre nce t his sec tion outlines the i dentification of a nd fiel d l ogist ics conce rn i ng the electr ica l e quip11ent
5 1 Equipment Identif i ca tion
A CHP representat ive will be on-site on a part-time basis to ide ntify a ny scra p t hc is no t considered conve ntion a l aolid waste Fl u id-filled electri shycal eq ui pbullent will re qu ire s pecial consideration due to it a potential PCB conte nt
Upon identification the electrical e qul pbullent will be numbered inventori ed a taaed and left on-site In an undisturbed s tate Underlytna s c rap located adjacent to the fluid-filled electrical equtpr~ent that exh i bits oil stains will also be left In place Personnel will upgrade their level of protection
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to Level C dermal (aee Section 30) when marking and working among the fluidshyfilled electrical equ ipment The equipment will be numbered with a paint marker us ing a predetermined numbering system for field designation They will then be logged into the pr oject records which will note
date of discovery fhld designation numbe r location description not a tion of r~anufactulers identification plate evidence of any spill associated with the item
A sraall area around the equipment will be isolated with cones or barrier tape to ensure that this area is not disturbed or trafficked during the removal process as described in Section 20 Subsequent to the completion of the scrap reaval operation the nature and quantity of fluid-filled equipa~ent will be evaluated and an appropriate plan for preferred dispoampition of this terial will be developed The plan will be coordinated aMOng CHP Jordan end the reaulatory aaencies prior to implementationbull
52 Spill Provisions
Thouah the occurrence of spills is not expected durinamp scrap reavt operashytiona at the r OConnor aite provisions for spilh vill ba provided Spill equis-ent will consist of oil sorbent hbrics ha nd tools and containers for disposal of the spill uriah The on-site equipn~ent will include
ten 18 X 18 aorbent pillows tvo rolla of oil sorbent polypropylene four 10-foot lenaths of 5 vide containment bo011 three 55-aallon drun~s for disposal of spill mceriah two hand shove h
This aquipent vill be phced in the vicinity of the acra p reMOvd operations In the event of a apill saturated materials muat be disposed of in compliance vith StateFederal regu lac ions
6 0 SCRAP AREA SOIL SAMPLING PROGRAM
To useaa the presence of c hemicals in aoils located beneath the acrap (ie metal auto-bodies tires and white goods) beyond TWA III a aurhce aoil u11plina proaram will be performed The sampli ng program describinamp the nunshyber and type of umplea to be collected h presented in the follovina para shyaraphs
A bullaximum of tvo compoaite samples will be collected fr011 each of the three designated acrap areas a prell11inary backaround aoil characterhat ion cocshypoampite (Phase I Ullpling) and a post-re110val characterhation composite (Phase II sampllna)
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I I I I
61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
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JiR ~~ ( It tl flI
0
The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
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10 INTRODUCTION
This plan desc ribes scrap removal operations thst are scheduled to take pllce at the F OConnor site in August a Maine during August 1987 The plan conshysists of seven sections including an i n troduction to the project lite loahtics for scrap reiDOVal transportation and disposa l personnel health a nd safety equipment decontamination special handling procedures for fluidshyfilled electrical equipment that n~ay be encountered scrap area aoil samplins prosram and project acheduh Figures and tablebull havt been included aa necessary for clarification
It 11 aiiUIDtd that approval of this plan by USEPA and Maine Department of Environmental Protection (DEP) constitutes acceptance of all activitits desshycribed herein no permits or additional approvals will be required
11 Site Stttina
The acnp area is part of the F OConnor Superfund site in Auguata Maine Tha scrap (ducribed balow) lias in an area tediately to the northeut of tha site fence and partially covers an a rea that exte ndamp to a st one vall located epproxi-uly 200 feet to t he north of the hnce Much of thil area is forested with conifers and a thick underbruah of dec iduous treea a nd shrubs The arada varies fro 0 to S percent No water bodies are located within or i-diataly adjacent to tha scrap a rea The IUjorlty of the scrap liu on tha alopu of a s liaht depression which drain to an upland arab A ora steeply s loptna hill whic h borden the liampJS Brook wat e rshed h located to the sout h of tha bullcrap area
1 ~ 2 Scrap CharactariJtics
An asti ted 500 ton s of scrap are situated in the northtast unfe nced area of the s ite The scrap vas brouah t to the site from 1950 to 1976 as part of etal sa lvaae operations that occ urred concurrently with tranampformer reclan~ashytion The scrap consists priarily of car bodiea applianceamp electric eter bodiea aheet metal tirea and metal signa
For the purpoaea of soil sampling beneath the scrap (aee Section 60) the 111ultiph scrap piles have been divi ded into the following sections
Area I Sheet metal and whitt goods Area II Car bodies and tires Ana 1111 Electrical tqutpment and sheet metal
Fiaure 1-1 depicts the location of the scrap area with respect to the fenced portion o( the lite and delinutu the specific scrap area t
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13 Previous Studies
The majority of the environmental sampling at the F OConnor s ite has taken place within the site secur ity fe nce (approxin~ately 250 umplu have been lUll collected from Tunsformer Work Area (TWA) I TWA II and associated drainshyages) Thirty-five samples were also collected and analyzed fr0111 outside the I security fence during Tour I to aueu PCB concentra tions in and around TWA III four of theae samples were analyzed for HSL organ ica and inorganics The results of Tour 1 surface soil sampling in TWA Ill indicate that PCB concenshytrations ra nse fr0111 660 ppm to nondetectable concentrations (less than 1 ppra) a nd are limited to a 2500 square foot area located alons the site access road HSL organic (excluding PCBa) and inorganic chemicals do not exist above area background concentrations Figure 1-2 illustrates Tour 1 analytical PCB result s fo r surface so U sampling at TWA III
20 REMOVAL LOGISTICS
The reova l of scrap atniah stockpiled beyond TWA 111 at the r OConnor site will requi re the use of severa l pieces of heavy equipcMnt (e J front
~d~s~k~ede~~ro~ ~~~~c ~p ~n~=~ =~~~ ~nt- ( - in an overview capacity end to ai d i n the clauif ica tion of scrap The followina section i dentif ies the roles of on-site personnel describes the roval operation and the use of heavy equtpnt and de tail s the heavy equipshy0 nt decontabullination procedures a t the close of the reoval proarabull
21 On-Site Personnel
Scrap reovd operat ions can be di vi ded into the following responsibilities
~~Xamp o P rooovo l - Hvy oquipmont opontolt 0
V ~ ( manifesting i den tification and handling of scra p that may require0 s pecial ha ndling (fluld-fUled e l ectrica l equipment) - QIP shy~
project raanagement - Jordan
~~c ~ k~sts the designated personnel and their specific role for each of
22 Reaval Operations
The scrap reraoval operation will begin with a rainor upgrade of the scrap area acceu road which is located north and east of the scrap area t hrough the Rodrique property The road improve111ent will consist of place11ent and gradins of aravel (approxi-tely ten yards) in three low areas along the road and the construction of a gravel truck loading pad on the western1110st end of the exisshytinamp scrap pile
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I I I I
IJiMltil
Fo llow ing t he road i mprovement operations scrap remova l wi ll comme nce i n t he most wes t er l y portion of the Scrap Area I and wil l proceed t hrough Scra p Area 111 (see Ftsu r e 2-1) The r emova l operations are expected to include bu t are (~middotmiddot not limited to t he following pieces of equipment sraall bulldozer large
Ibckhoe front end loader and a minimum of two 14 or 18 cubic yard d ump trucks The removal will proceed in the following manner
A dUlllp truck will be stased on the newly constructed gravel loading pad
Piles within each scrap area (Scrap Areas 1 11 and 111) will be identified numbered and photographed by Jordan personnel
Each pile in the iramediate area of removal will be carefully (~~ ) searched by CHP on-site personnel for any flu id-fil l ed electrical ( e qu ipa~ent (see Section 50)
After a pile has been designated as clean (f r ee of flui d- fill ed-~_ bull 1
a l ect rlca l equ i pme nt) t he scrap will be pu lled dovn t o th a l oadina pad with t he dozer a nd loaded into the truck with the front a nd loa dar The genera l contents of e ach pile will ba recorded durina th is process by J orda n personne 1
Thh proceu will cont i nue until t he s t aaed truck h full tha bill of l ad i na will the n be sts ned a nd the ruteriah will ba re-oved to an appropriat e dh pou l fac ility (ue Sac tion s 41 and 4 2 Trans shyportationDh pou l) Th e aecond truck wi ll be 1110ved t o the load ina pad and the raoval proceu will continue
As the sc rap remova l prog r esses toward Sc rap Area III the pull- down ampone betwee n the t ru cks a nd th e scrap wil l neceua rily bacoe a l onshya a t ed (see Fi gure 2-1) However t hroughout th e reiIOVSl process t he l oad i ng of t rucks will only take place at tha l oa d i ng pad Th is procedur e h instituted to avoid contact of the t r uck wheels wit h unc haracterhed soils previously located beneath t he scrap In this ma nner the trucks will be able to move off the loading pad and ultimately off-site without requiring decontamination
In the course of the scrap search and removal process areas of conshycern as identified by CHP Jordan and USEPA 1 will be isolated (either by cones or bar rier tape from the scrap blling pulled down by the dozer These identified areas will become the designated Phase 11 soil sampling locations described in Section 60 The handling of any fluid-filled electric equipn~ent that might be discovered in the searching proceu is addressed in Section 50
To avoid raove11ent of heavy equipment across known conta11inated sol Is in the TWA lll area 111ateriah located in Scrap Area 111 will be MOved from Scrap Area lll to the pulldown zone by hand or with wheal
-5shy
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barrows This precaution will be undertaken to avoid exceuive disshyturbance of soils previousl y characterized during Tour I surface soil sampling (see Figure 1-2) Any mate rials tha t cannot be removed in this fashion from this area will remain at their current location Two very large bush ings located adjacent to the TWA III are examples of the types of mat e rlala that will not be removed during this operation
23 Decontaminat ion of Equipment
Following completion of the sc rap removal program decon t arli nation of removal eq uipmen t tracks a nd or tires will be performed a s a preca utionary 11easure to avoid the off-site transport of site-derived soils Decontamtncion will be accomplished in a 25-foot l ong by 20-foot wide nea located near the truck loading pad (designated as the decon area in Fiaure 2-1) The decon area (to be constructed by a dozer) will consist of a sliahtly inclined flat around surface with berr~ed edaes running along the lenath of the s lope This area will be lined with plutic and covered with 34-inch plywood and its ban a 16 x 3 x 4 ( deep) trench (excavated by the backhoe) will serve as a catch- IHnt basin for the decontar~ination water Durinamp use of the decon area each piece of equipcaent will enter the upper portion vhere vehicle trackstires will be washed down of all loose dirt usina a water truck These washinas will drain on the plutic to the containment trench and in this aanner avoid r unoff The equipcHnt will then be loaded directly onto its carrytna flatbed at the loadina pad for off-site transport
Upon copletion of scrap re~Ktval the decon area will be disntled The plastic will be containeriud for s ubampeque nt off-site disposal the plywood wlll be stored within the security fence for possible future use and the aravel will be retained in-place and addrened as part of the total site nuaediation
30 PERSONAL PROTECTION
The 11intmu11 level of personal pro t ec tion thc will be reco-ended to all on-site personnel a nd utilized by Jordan at the F OConnor site durinamp tcrap removal operations will be Level D dermal and respito ry protection The scrap 1s considered be nign taking into account t he history of the operations and pendina Phue 1 sampling results (tee Section 61) work glovu should however be worn to avoid c uts Since the scrap is assumed to be located in a clean trea i n ten11s of soil chemicals and tnnsportion through TWA III will be restricted it is antici pated that the removal of the scrap will not cbulluse atmospheric cont bullllination3in the range of the Threshold Limit Vtue (TLV) for PCBs (05 to 10 mam ) If excessive airborne dust particles 111re produced durinamp scrap removal then wearing of dust mukt will be recofiended aa a precbullutionary meuura (this judgment will be made by the Jordan site safety oHicer)
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I I I I
ttil (~rII
The Level D persona l protection gear will consist of the following
cotton coveralh Jtee l - toed chemicll resiatl nt boot s hard hat ear protection (optional) cottonluther gloves (when contac t with the scrap is anticipated)
The UCOIIIIM nded level of protection will be upsuded to Leve l C dermal for person ne l who will be involved with larkinamp of fluid-f i lled electrica l equipment The Level C de r1111l personal protection gear conaists of all the items noted for Level D dermbull l except cotton cover1lh 1nd work stoves will be replaced with c hemtc1l ly protective coveralla 1nd inner 1nd outer gloves
Person l decont1minbulltton will consist of diapoaina of bull ny che11tcll-reais t a n t cloth inamp or du s t muka t hbull t bullre worn into phstic aarbbullae bbullampbull for subuque nt stonae on-site in DOT bull pproved 55-ampbullllon drw Boot deconta11in1tion fbullctlitiea (bucketa nd scrub brushea) will be bullvailable aince on-site personnel 11ay h1ve to enter the TWA III 1re1
Add ittonll i nfor-1tion re11rdi n1 Jord1n a hed t h 1nd ufety procedures Cln be fou nd in the at t e Project Operations Plan (POP) June 1986
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS
Followina load t na t he scrap will be transported to bull nd disposed of at a disshypout location that 1a JWtually aareeable to USPA Maine DP and CMP It is proposed that the City o f Auausta Hatch Hill Lbullndfill Auausta Maine located approximately fou r (4) bullilu f r0111 the site be utiliud for d isposal of the scnp Transportation 1 nd diapoul at this site will be handled in the fol lowtna 111 nne r
Two hiamph-wdled 14 or 18 cubic y1rd trucka each haulinamp a max i11un lo1d of 35000 lbs will be utilized to t ransport the scrap to Hatch Hill Landfill Consideri ng the anticipbullted 500 tons of scrap approximbulltely 30 trips to the landfill bullre 1 nt ictpate d The scra p will be covered with canv1s covera 1 nd stabilized aa necessary uainamp ropes tarps e t c
Decontbullnin1 tion of truck tires prior to site dep1rture ha s not been s pecif ied abull trucks dastsnlted for off-site transport will be reatricted to arua known to be cle1n based on Tour I analytical resu l ts
-middotshy
I I I I
Aa a matter of good record keep i ng a bill opound lad i ng will accompany ea ch scrap load Th is doc ument a t i on will be prepand by the r emova l contractor a nd wi ll inc lude
name a nd address of the t ra nsporter or iain o f th e sc ra p c ha rac t e ri s t i c s of the scrap u tbiiA t e d quantity o f the scrap and fi na l disposa l destinat ion
CHP the removal cont rac t or a nd Ha tch Hill Landfi ll will stan the bi ll of lad i ng fo r each l oad The orta i nal wil l be r etaine d i n CHP fi l es copies will be d istr ibuted to Int e res t ed par ties
42 Disposal
Disposa l of the scrap a t Ha tch Hill Landfill will be routine Th e only required perbullit utablishu authorized uae of Hatch Hill Landfill This pershybullit is to be obtained by the contractor fr011 the City of Auausta it speciflu na and loccion of the hauler and reaistration inforMation for each vehicle to be used for scrap delivery to Hatch Hill Landfill
Hatch Hill Landfill hours en libullited to 8 00 a bullbullbull to 400 Pbullbullbullbull Tuesday throuah Friday The scrap will arrive in loads that confom with the specishyfied atoraae piles and areu at tch Hill Landfill Hatch Hill raquiru that electric Mter bodiu arrive uparauly Tires are separated fro Mtal and fluids (such aa tranabulliuion oil) are re~~aved fron autoobile bodies Then f~uida will be collected and disposed of at local oil depository locations
50 SPECIAL HANDLING LOGISTICS
Durinamp the re110val of the scrap from the F OConnor si t e fluid- filled elec trical equipntent bull ay be discovered In ant icipati ng th is occurre nce t his sec tion outlines the i dentification of a nd fiel d l ogist ics conce rn i ng the electr ica l e quip11ent
5 1 Equipment Identif i ca tion
A CHP representat ive will be on-site on a part-time basis to ide ntify a ny scra p t hc is no t considered conve ntion a l aolid waste Fl u id-filled electri shycal eq ui pbullent will re qu ire s pecial consideration due to it a potential PCB conte nt
Upon identification the electrical e qul pbullent will be numbered inventori ed a taaed and left on-site In an undisturbed s tate Underlytna s c rap located adjacent to the fluid-filled electrical equtpr~ent that exh i bits oil stains will also be left In place Personnel will upgrade their level of protection
- 10shy
to Level C dermal (aee Section 30) when marking and working among the fluidshyfilled electrical equ ipment The equipment will be numbered with a paint marker us ing a predetermined numbering system for field designation They will then be logged into the pr oject records which will note
date of discovery fhld designation numbe r location description not a tion of r~anufactulers identification plate evidence of any spill associated with the item
A sraall area around the equipment will be isolated with cones or barrier tape to ensure that this area is not disturbed or trafficked during the removal process as described in Section 20 Subsequent to the completion of the scrap reaval operation the nature and quantity of fluid-filled equipa~ent will be evaluated and an appropriate plan for preferred dispoampition of this terial will be developed The plan will be coordinated aMOng CHP Jordan end the reaulatory aaencies prior to implementationbull
52 Spill Provisions
Thouah the occurrence of spills is not expected durinamp scrap reavt operashytiona at the r OConnor aite provisions for spilh vill ba provided Spill equis-ent will consist of oil sorbent hbrics ha nd tools and containers for disposal of the spill uriah The on-site equipn~ent will include
ten 18 X 18 aorbent pillows tvo rolla of oil sorbent polypropylene four 10-foot lenaths of 5 vide containment bo011 three 55-aallon drun~s for disposal of spill mceriah two hand shove h
This aquipent vill be phced in the vicinity of the acra p reMOvd operations In the event of a apill saturated materials muat be disposed of in compliance vith StateFederal regu lac ions
6 0 SCRAP AREA SOIL SAMPLING PROGRAM
To useaa the presence of c hemicals in aoils located beneath the acrap (ie metal auto-bodies tires and white goods) beyond TWA III a aurhce aoil u11plina proaram will be performed The sampli ng program describinamp the nunshyber and type of umplea to be collected h presented in the follovina para shyaraphs
A bullaximum of tvo compoaite samples will be collected fr011 each of the three designated acrap areas a prell11inary backaround aoil characterhat ion cocshypoampite (Phase I Ullpling) and a post-re110val characterhation composite (Phase II sampllna)
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I I I I
61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
-12shy
JiR ~~ ( It tl flI
0
The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
-13shy
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13 Previous Studies
The majority of the environmental sampling at the F OConnor s ite has taken place within the site secur ity fe nce (approxin~ately 250 umplu have been lUll collected from Tunsformer Work Area (TWA) I TWA II and associated drainshyages) Thirty-five samples were also collected and analyzed fr0111 outside the I security fence during Tour I to aueu PCB concentra tions in and around TWA III four of theae samples were analyzed for HSL organ ica and inorganics The results of Tour 1 surface soil sampling in TWA Ill indicate that PCB concenshytrations ra nse fr0111 660 ppm to nondetectable concentrations (less than 1 ppra) a nd are limited to a 2500 square foot area located alons the site access road HSL organic (excluding PCBa) and inorganic chemicals do not exist above area background concentrations Figure 1-2 illustrates Tour 1 analytical PCB result s fo r surface so U sampling at TWA III
20 REMOVAL LOGISTICS
The reova l of scrap atniah stockpiled beyond TWA 111 at the r OConnor site will requi re the use of severa l pieces of heavy equipcMnt (e J front
~d~s~k~ede~~ro~ ~~~~c ~p ~n~=~ =~~~ ~nt- ( - in an overview capacity end to ai d i n the clauif ica tion of scrap The followina section i dentif ies the roles of on-site personnel describes the roval operation and the use of heavy equtpnt and de tail s the heavy equipshy0 nt decontabullination procedures a t the close of the reoval proarabull
21 On-Site Personnel
Scrap reovd operat ions can be di vi ded into the following responsibilities
~~Xamp o P rooovo l - Hvy oquipmont opontolt 0
V ~ ( manifesting i den tification and handling of scra p that may require0 s pecial ha ndling (fluld-fUled e l ectrica l equipment) - QIP shy~
project raanagement - Jordan
~~c ~ k~sts the designated personnel and their specific role for each of
22 Reaval Operations
The scrap reraoval operation will begin with a rainor upgrade of the scrap area acceu road which is located north and east of the scrap area t hrough the Rodrique property The road improve111ent will consist of place11ent and gradins of aravel (approxi-tely ten yards) in three low areas along the road and the construction of a gravel truck loading pad on the western1110st end of the exisshytinamp scrap pile
- 4shy
I I I I
IJiMltil
Fo llow ing t he road i mprovement operations scrap remova l wi ll comme nce i n t he most wes t er l y portion of the Scrap Area I and wil l proceed t hrough Scra p Area 111 (see Ftsu r e 2-1) The r emova l operations are expected to include bu t are (~middotmiddot not limited to t he following pieces of equipment sraall bulldozer large
Ibckhoe front end loader and a minimum of two 14 or 18 cubic yard d ump trucks The removal will proceed in the following manner
A dUlllp truck will be stased on the newly constructed gravel loading pad
Piles within each scrap area (Scrap Areas 1 11 and 111) will be identified numbered and photographed by Jordan personnel
Each pile in the iramediate area of removal will be carefully (~~ ) searched by CHP on-site personnel for any flu id-fil l ed electrical ( e qu ipa~ent (see Section 50)
After a pile has been designated as clean (f r ee of flui d- fill ed-~_ bull 1
a l ect rlca l equ i pme nt) t he scrap will be pu lled dovn t o th a l oadina pad with t he dozer a nd loaded into the truck with the front a nd loa dar The genera l contents of e ach pile will ba recorded durina th is process by J orda n personne 1
Thh proceu will cont i nue until t he s t aaed truck h full tha bill of l ad i na will the n be sts ned a nd the ruteriah will ba re-oved to an appropriat e dh pou l fac ility (ue Sac tion s 41 and 4 2 Trans shyportationDh pou l) Th e aecond truck wi ll be 1110ved t o the load ina pad and the raoval proceu will continue
As the sc rap remova l prog r esses toward Sc rap Area III the pull- down ampone betwee n the t ru cks a nd th e scrap wil l neceua rily bacoe a l onshya a t ed (see Fi gure 2-1) However t hroughout th e reiIOVSl process t he l oad i ng of t rucks will only take place at tha l oa d i ng pad Th is procedur e h instituted to avoid contact of the t r uck wheels wit h unc haracterhed soils previously located beneath t he scrap In this ma nner the trucks will be able to move off the loading pad and ultimately off-site without requiring decontamination
In the course of the scrap search and removal process areas of conshycern as identified by CHP Jordan and USEPA 1 will be isolated (either by cones or bar rier tape from the scrap blling pulled down by the dozer These identified areas will become the designated Phase 11 soil sampling locations described in Section 60 The handling of any fluid-filled electric equipn~ent that might be discovered in the searching proceu is addressed in Section 50
To avoid raove11ent of heavy equipment across known conta11inated sol Is in the TWA lll area 111ateriah located in Scrap Area 111 will be MOved from Scrap Area lll to the pulldown zone by hand or with wheal
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barrows This precaution will be undertaken to avoid exceuive disshyturbance of soils previousl y characterized during Tour I surface soil sampling (see Figure 1-2) Any mate rials tha t cannot be removed in this fashion from this area will remain at their current location Two very large bush ings located adjacent to the TWA III are examples of the types of mat e rlala that will not be removed during this operation
23 Decontaminat ion of Equipment
Following completion of the sc rap removal program decon t arli nation of removal eq uipmen t tracks a nd or tires will be performed a s a preca utionary 11easure to avoid the off-site transport of site-derived soils Decontamtncion will be accomplished in a 25-foot l ong by 20-foot wide nea located near the truck loading pad (designated as the decon area in Fiaure 2-1) The decon area (to be constructed by a dozer) will consist of a sliahtly inclined flat around surface with berr~ed edaes running along the lenath of the s lope This area will be lined with plutic and covered with 34-inch plywood and its ban a 16 x 3 x 4 ( deep) trench (excavated by the backhoe) will serve as a catch- IHnt basin for the decontar~ination water Durinamp use of the decon area each piece of equipcaent will enter the upper portion vhere vehicle trackstires will be washed down of all loose dirt usina a water truck These washinas will drain on the plutic to the containment trench and in this aanner avoid r unoff The equipcHnt will then be loaded directly onto its carrytna flatbed at the loadina pad for off-site transport
Upon copletion of scrap re~Ktval the decon area will be disntled The plastic will be containeriud for s ubampeque nt off-site disposal the plywood wlll be stored within the security fence for possible future use and the aravel will be retained in-place and addrened as part of the total site nuaediation
30 PERSONAL PROTECTION
The 11intmu11 level of personal pro t ec tion thc will be reco-ended to all on-site personnel a nd utilized by Jordan at the F OConnor site durinamp tcrap removal operations will be Level D dermal and respito ry protection The scrap 1s considered be nign taking into account t he history of the operations and pendina Phue 1 sampling results (tee Section 61) work glovu should however be worn to avoid c uts Since the scrap is assumed to be located in a clean trea i n ten11s of soil chemicals and tnnsportion through TWA III will be restricted it is antici pated that the removal of the scrap will not cbulluse atmospheric cont bullllination3in the range of the Threshold Limit Vtue (TLV) for PCBs (05 to 10 mam ) If excessive airborne dust particles 111re produced durinamp scrap removal then wearing of dust mukt will be recofiended aa a precbullutionary meuura (this judgment will be made by the Jordan site safety oHicer)
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The Level D persona l protection gear will consist of the following
cotton coveralh Jtee l - toed chemicll resiatl nt boot s hard hat ear protection (optional) cottonluther gloves (when contac t with the scrap is anticipated)
The UCOIIIIM nded level of protection will be upsuded to Leve l C dermal for person ne l who will be involved with larkinamp of fluid-f i lled electrica l equipment The Level C de r1111l personal protection gear conaists of all the items noted for Level D dermbull l except cotton cover1lh 1nd work stoves will be replaced with c hemtc1l ly protective coveralla 1nd inner 1nd outer gloves
Person l decont1minbulltton will consist of diapoaina of bull ny che11tcll-reais t a n t cloth inamp or du s t muka t hbull t bullre worn into phstic aarbbullae bbullampbull for subuque nt stonae on-site in DOT bull pproved 55-ampbullllon drw Boot deconta11in1tion fbullctlitiea (bucketa nd scrub brushea) will be bullvailable aince on-site personnel 11ay h1ve to enter the TWA III 1re1
Add ittonll i nfor-1tion re11rdi n1 Jord1n a hed t h 1nd ufety procedures Cln be fou nd in the at t e Project Operations Plan (POP) June 1986
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS
Followina load t na t he scrap will be transported to bull nd disposed of at a disshypout location that 1a JWtually aareeable to USPA Maine DP and CMP It is proposed that the City o f Auausta Hatch Hill Lbullndfill Auausta Maine located approximately fou r (4) bullilu f r0111 the site be utiliud for d isposal of the scnp Transportation 1 nd diapoul at this site will be handled in the fol lowtna 111 nne r
Two hiamph-wdled 14 or 18 cubic y1rd trucka each haulinamp a max i11un lo1d of 35000 lbs will be utilized to t ransport the scrap to Hatch Hill Landfill Consideri ng the anticipbullted 500 tons of scrap approximbulltely 30 trips to the landfill bullre 1 nt ictpate d The scra p will be covered with canv1s covera 1 nd stabilized aa necessary uainamp ropes tarps e t c
Decontbullnin1 tion of truck tires prior to site dep1rture ha s not been s pecif ied abull trucks dastsnlted for off-site transport will be reatricted to arua known to be cle1n based on Tour I analytical resu l ts
-middotshy
I I I I
Aa a matter of good record keep i ng a bill opound lad i ng will accompany ea ch scrap load Th is doc ument a t i on will be prepand by the r emova l contractor a nd wi ll inc lude
name a nd address of the t ra nsporter or iain o f th e sc ra p c ha rac t e ri s t i c s of the scrap u tbiiA t e d quantity o f the scrap and fi na l disposa l destinat ion
CHP the removal cont rac t or a nd Ha tch Hill Landfi ll will stan the bi ll of lad i ng fo r each l oad The orta i nal wil l be r etaine d i n CHP fi l es copies will be d istr ibuted to Int e res t ed par ties
42 Disposal
Disposa l of the scrap a t Ha tch Hill Landfill will be routine Th e only required perbullit utablishu authorized uae of Hatch Hill Landfill This pershybullit is to be obtained by the contractor fr011 the City of Auausta it speciflu na and loccion of the hauler and reaistration inforMation for each vehicle to be used for scrap delivery to Hatch Hill Landfill
Hatch Hill Landfill hours en libullited to 8 00 a bullbullbull to 400 Pbullbullbullbull Tuesday throuah Friday The scrap will arrive in loads that confom with the specishyfied atoraae piles and areu at tch Hill Landfill Hatch Hill raquiru that electric Mter bodiu arrive uparauly Tires are separated fro Mtal and fluids (such aa tranabulliuion oil) are re~~aved fron autoobile bodies Then f~uida will be collected and disposed of at local oil depository locations
50 SPECIAL HANDLING LOGISTICS
Durinamp the re110val of the scrap from the F OConnor si t e fluid- filled elec trical equipntent bull ay be discovered In ant icipati ng th is occurre nce t his sec tion outlines the i dentification of a nd fiel d l ogist ics conce rn i ng the electr ica l e quip11ent
5 1 Equipment Identif i ca tion
A CHP representat ive will be on-site on a part-time basis to ide ntify a ny scra p t hc is no t considered conve ntion a l aolid waste Fl u id-filled electri shycal eq ui pbullent will re qu ire s pecial consideration due to it a potential PCB conte nt
Upon identification the electrical e qul pbullent will be numbered inventori ed a taaed and left on-site In an undisturbed s tate Underlytna s c rap located adjacent to the fluid-filled electrical equtpr~ent that exh i bits oil stains will also be left In place Personnel will upgrade their level of protection
- 10shy
to Level C dermal (aee Section 30) when marking and working among the fluidshyfilled electrical equ ipment The equipment will be numbered with a paint marker us ing a predetermined numbering system for field designation They will then be logged into the pr oject records which will note
date of discovery fhld designation numbe r location description not a tion of r~anufactulers identification plate evidence of any spill associated with the item
A sraall area around the equipment will be isolated with cones or barrier tape to ensure that this area is not disturbed or trafficked during the removal process as described in Section 20 Subsequent to the completion of the scrap reaval operation the nature and quantity of fluid-filled equipa~ent will be evaluated and an appropriate plan for preferred dispoampition of this terial will be developed The plan will be coordinated aMOng CHP Jordan end the reaulatory aaencies prior to implementationbull
52 Spill Provisions
Thouah the occurrence of spills is not expected durinamp scrap reavt operashytiona at the r OConnor aite provisions for spilh vill ba provided Spill equis-ent will consist of oil sorbent hbrics ha nd tools and containers for disposal of the spill uriah The on-site equipn~ent will include
ten 18 X 18 aorbent pillows tvo rolla of oil sorbent polypropylene four 10-foot lenaths of 5 vide containment bo011 three 55-aallon drun~s for disposal of spill mceriah two hand shove h
This aquipent vill be phced in the vicinity of the acra p reMOvd operations In the event of a apill saturated materials muat be disposed of in compliance vith StateFederal regu lac ions
6 0 SCRAP AREA SOIL SAMPLING PROGRAM
To useaa the presence of c hemicals in aoils located beneath the acrap (ie metal auto-bodies tires and white goods) beyond TWA III a aurhce aoil u11plina proaram will be performed The sampli ng program describinamp the nunshyber and type of umplea to be collected h presented in the follovina para shyaraphs
A bullaximum of tvo compoaite samples will be collected fr011 each of the three designated acrap areas a prell11inary backaround aoil characterhat ion cocshypoampite (Phase I Ullpling) and a post-re110val characterhation composite (Phase II sampllna)
-11shy
I I I I
61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
-12shy
JiR ~~ ( It tl flI
0
The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
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13 Previous Studies
The majority of the environmental sampling at the F OConnor s ite has taken place within the site secur ity fe nce (approxin~ately 250 umplu have been lUll collected from Tunsformer Work Area (TWA) I TWA II and associated drainshyages) Thirty-five samples were also collected and analyzed fr0111 outside the I security fence during Tour I to aueu PCB concentra tions in and around TWA III four of theae samples were analyzed for HSL organ ica and inorganics The results of Tour 1 surface soil sampling in TWA Ill indicate that PCB concenshytrations ra nse fr0111 660 ppm to nondetectable concentrations (less than 1 ppra) a nd are limited to a 2500 square foot area located alons the site access road HSL organic (excluding PCBa) and inorganic chemicals do not exist above area background concentrations Figure 1-2 illustrates Tour 1 analytical PCB result s fo r surface so U sampling at TWA III
20 REMOVAL LOGISTICS
The reova l of scrap atniah stockpiled beyond TWA 111 at the r OConnor site will requi re the use of severa l pieces of heavy equipcMnt (e J front
~d~s~k~ede~~ro~ ~~~~c ~p ~n~=~ =~~~ ~nt- ( - in an overview capacity end to ai d i n the clauif ica tion of scrap The followina section i dentif ies the roles of on-site personnel describes the roval operation and the use of heavy equtpnt and de tail s the heavy equipshy0 nt decontabullination procedures a t the close of the reoval proarabull
21 On-Site Personnel
Scrap reovd operat ions can be di vi ded into the following responsibilities
~~Xamp o P rooovo l - Hvy oquipmont opontolt 0
V ~ ( manifesting i den tification and handling of scra p that may require0 s pecial ha ndling (fluld-fUled e l ectrica l equipment) - QIP shy~
project raanagement - Jordan
~~c ~ k~sts the designated personnel and their specific role for each of
22 Reaval Operations
The scrap reraoval operation will begin with a rainor upgrade of the scrap area acceu road which is located north and east of the scrap area t hrough the Rodrique property The road improve111ent will consist of place11ent and gradins of aravel (approxi-tely ten yards) in three low areas along the road and the construction of a gravel truck loading pad on the western1110st end of the exisshytinamp scrap pile
- 4shy
I I I I
IJiMltil
Fo llow ing t he road i mprovement operations scrap remova l wi ll comme nce i n t he most wes t er l y portion of the Scrap Area I and wil l proceed t hrough Scra p Area 111 (see Ftsu r e 2-1) The r emova l operations are expected to include bu t are (~middotmiddot not limited to t he following pieces of equipment sraall bulldozer large
Ibckhoe front end loader and a minimum of two 14 or 18 cubic yard d ump trucks The removal will proceed in the following manner
A dUlllp truck will be stased on the newly constructed gravel loading pad
Piles within each scrap area (Scrap Areas 1 11 and 111) will be identified numbered and photographed by Jordan personnel
Each pile in the iramediate area of removal will be carefully (~~ ) searched by CHP on-site personnel for any flu id-fil l ed electrical ( e qu ipa~ent (see Section 50)
After a pile has been designated as clean (f r ee of flui d- fill ed-~_ bull 1
a l ect rlca l equ i pme nt) t he scrap will be pu lled dovn t o th a l oadina pad with t he dozer a nd loaded into the truck with the front a nd loa dar The genera l contents of e ach pile will ba recorded durina th is process by J orda n personne 1
Thh proceu will cont i nue until t he s t aaed truck h full tha bill of l ad i na will the n be sts ned a nd the ruteriah will ba re-oved to an appropriat e dh pou l fac ility (ue Sac tion s 41 and 4 2 Trans shyportationDh pou l) Th e aecond truck wi ll be 1110ved t o the load ina pad and the raoval proceu will continue
As the sc rap remova l prog r esses toward Sc rap Area III the pull- down ampone betwee n the t ru cks a nd th e scrap wil l neceua rily bacoe a l onshya a t ed (see Fi gure 2-1) However t hroughout th e reiIOVSl process t he l oad i ng of t rucks will only take place at tha l oa d i ng pad Th is procedur e h instituted to avoid contact of the t r uck wheels wit h unc haracterhed soils previously located beneath t he scrap In this ma nner the trucks will be able to move off the loading pad and ultimately off-site without requiring decontamination
In the course of the scrap search and removal process areas of conshycern as identified by CHP Jordan and USEPA 1 will be isolated (either by cones or bar rier tape from the scrap blling pulled down by the dozer These identified areas will become the designated Phase 11 soil sampling locations described in Section 60 The handling of any fluid-filled electric equipn~ent that might be discovered in the searching proceu is addressed in Section 50
To avoid raove11ent of heavy equipment across known conta11inated sol Is in the TWA lll area 111ateriah located in Scrap Area 111 will be MOved from Scrap Area lll to the pulldown zone by hand or with wheal
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barrows This precaution will be undertaken to avoid exceuive disshyturbance of soils previousl y characterized during Tour I surface soil sampling (see Figure 1-2) Any mate rials tha t cannot be removed in this fashion from this area will remain at their current location Two very large bush ings located adjacent to the TWA III are examples of the types of mat e rlala that will not be removed during this operation
23 Decontaminat ion of Equipment
Following completion of the sc rap removal program decon t arli nation of removal eq uipmen t tracks a nd or tires will be performed a s a preca utionary 11easure to avoid the off-site transport of site-derived soils Decontamtncion will be accomplished in a 25-foot l ong by 20-foot wide nea located near the truck loading pad (designated as the decon area in Fiaure 2-1) The decon area (to be constructed by a dozer) will consist of a sliahtly inclined flat around surface with berr~ed edaes running along the lenath of the s lope This area will be lined with plutic and covered with 34-inch plywood and its ban a 16 x 3 x 4 ( deep) trench (excavated by the backhoe) will serve as a catch- IHnt basin for the decontar~ination water Durinamp use of the decon area each piece of equipcaent will enter the upper portion vhere vehicle trackstires will be washed down of all loose dirt usina a water truck These washinas will drain on the plutic to the containment trench and in this aanner avoid r unoff The equipcHnt will then be loaded directly onto its carrytna flatbed at the loadina pad for off-site transport
Upon copletion of scrap re~Ktval the decon area will be disntled The plastic will be containeriud for s ubampeque nt off-site disposal the plywood wlll be stored within the security fence for possible future use and the aravel will be retained in-place and addrened as part of the total site nuaediation
30 PERSONAL PROTECTION
The 11intmu11 level of personal pro t ec tion thc will be reco-ended to all on-site personnel a nd utilized by Jordan at the F OConnor site durinamp tcrap removal operations will be Level D dermal and respito ry protection The scrap 1s considered be nign taking into account t he history of the operations and pendina Phue 1 sampling results (tee Section 61) work glovu should however be worn to avoid c uts Since the scrap is assumed to be located in a clean trea i n ten11s of soil chemicals and tnnsportion through TWA III will be restricted it is antici pated that the removal of the scrap will not cbulluse atmospheric cont bullllination3in the range of the Threshold Limit Vtue (TLV) for PCBs (05 to 10 mam ) If excessive airborne dust particles 111re produced durinamp scrap removal then wearing of dust mukt will be recofiended aa a precbullutionary meuura (this judgment will be made by the Jordan site safety oHicer)
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I I I I
ttil (~rII
The Level D persona l protection gear will consist of the following
cotton coveralh Jtee l - toed chemicll resiatl nt boot s hard hat ear protection (optional) cottonluther gloves (when contac t with the scrap is anticipated)
The UCOIIIIM nded level of protection will be upsuded to Leve l C dermal for person ne l who will be involved with larkinamp of fluid-f i lled electrica l equipment The Level C de r1111l personal protection gear conaists of all the items noted for Level D dermbull l except cotton cover1lh 1nd work stoves will be replaced with c hemtc1l ly protective coveralla 1nd inner 1nd outer gloves
Person l decont1minbulltton will consist of diapoaina of bull ny che11tcll-reais t a n t cloth inamp or du s t muka t hbull t bullre worn into phstic aarbbullae bbullampbull for subuque nt stonae on-site in DOT bull pproved 55-ampbullllon drw Boot deconta11in1tion fbullctlitiea (bucketa nd scrub brushea) will be bullvailable aince on-site personnel 11ay h1ve to enter the TWA III 1re1
Add ittonll i nfor-1tion re11rdi n1 Jord1n a hed t h 1nd ufety procedures Cln be fou nd in the at t e Project Operations Plan (POP) June 1986
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS
Followina load t na t he scrap will be transported to bull nd disposed of at a disshypout location that 1a JWtually aareeable to USPA Maine DP and CMP It is proposed that the City o f Auausta Hatch Hill Lbullndfill Auausta Maine located approximately fou r (4) bullilu f r0111 the site be utiliud for d isposal of the scnp Transportation 1 nd diapoul at this site will be handled in the fol lowtna 111 nne r
Two hiamph-wdled 14 or 18 cubic y1rd trucka each haulinamp a max i11un lo1d of 35000 lbs will be utilized to t ransport the scrap to Hatch Hill Landfill Consideri ng the anticipbullted 500 tons of scrap approximbulltely 30 trips to the landfill bullre 1 nt ictpate d The scra p will be covered with canv1s covera 1 nd stabilized aa necessary uainamp ropes tarps e t c
Decontbullnin1 tion of truck tires prior to site dep1rture ha s not been s pecif ied abull trucks dastsnlted for off-site transport will be reatricted to arua known to be cle1n based on Tour I analytical resu l ts
-middotshy
I I I I
Aa a matter of good record keep i ng a bill opound lad i ng will accompany ea ch scrap load Th is doc ument a t i on will be prepand by the r emova l contractor a nd wi ll inc lude
name a nd address of the t ra nsporter or iain o f th e sc ra p c ha rac t e ri s t i c s of the scrap u tbiiA t e d quantity o f the scrap and fi na l disposa l destinat ion
CHP the removal cont rac t or a nd Ha tch Hill Landfi ll will stan the bi ll of lad i ng fo r each l oad The orta i nal wil l be r etaine d i n CHP fi l es copies will be d istr ibuted to Int e res t ed par ties
42 Disposal
Disposa l of the scrap a t Ha tch Hill Landfill will be routine Th e only required perbullit utablishu authorized uae of Hatch Hill Landfill This pershybullit is to be obtained by the contractor fr011 the City of Auausta it speciflu na and loccion of the hauler and reaistration inforMation for each vehicle to be used for scrap delivery to Hatch Hill Landfill
Hatch Hill Landfill hours en libullited to 8 00 a bullbullbull to 400 Pbullbullbullbull Tuesday throuah Friday The scrap will arrive in loads that confom with the specishyfied atoraae piles and areu at tch Hill Landfill Hatch Hill raquiru that electric Mter bodiu arrive uparauly Tires are separated fro Mtal and fluids (such aa tranabulliuion oil) are re~~aved fron autoobile bodies Then f~uida will be collected and disposed of at local oil depository locations
50 SPECIAL HANDLING LOGISTICS
Durinamp the re110val of the scrap from the F OConnor si t e fluid- filled elec trical equipntent bull ay be discovered In ant icipati ng th is occurre nce t his sec tion outlines the i dentification of a nd fiel d l ogist ics conce rn i ng the electr ica l e quip11ent
5 1 Equipment Identif i ca tion
A CHP representat ive will be on-site on a part-time basis to ide ntify a ny scra p t hc is no t considered conve ntion a l aolid waste Fl u id-filled electri shycal eq ui pbullent will re qu ire s pecial consideration due to it a potential PCB conte nt
Upon identification the electrical e qul pbullent will be numbered inventori ed a taaed and left on-site In an undisturbed s tate Underlytna s c rap located adjacent to the fluid-filled electrical equtpr~ent that exh i bits oil stains will also be left In place Personnel will upgrade their level of protection
- 10shy
to Level C dermal (aee Section 30) when marking and working among the fluidshyfilled electrical equ ipment The equipment will be numbered with a paint marker us ing a predetermined numbering system for field designation They will then be logged into the pr oject records which will note
date of discovery fhld designation numbe r location description not a tion of r~anufactulers identification plate evidence of any spill associated with the item
A sraall area around the equipment will be isolated with cones or barrier tape to ensure that this area is not disturbed or trafficked during the removal process as described in Section 20 Subsequent to the completion of the scrap reaval operation the nature and quantity of fluid-filled equipa~ent will be evaluated and an appropriate plan for preferred dispoampition of this terial will be developed The plan will be coordinated aMOng CHP Jordan end the reaulatory aaencies prior to implementationbull
52 Spill Provisions
Thouah the occurrence of spills is not expected durinamp scrap reavt operashytiona at the r OConnor aite provisions for spilh vill ba provided Spill equis-ent will consist of oil sorbent hbrics ha nd tools and containers for disposal of the spill uriah The on-site equipn~ent will include
ten 18 X 18 aorbent pillows tvo rolla of oil sorbent polypropylene four 10-foot lenaths of 5 vide containment bo011 three 55-aallon drun~s for disposal of spill mceriah two hand shove h
This aquipent vill be phced in the vicinity of the acra p reMOvd operations In the event of a apill saturated materials muat be disposed of in compliance vith StateFederal regu lac ions
6 0 SCRAP AREA SOIL SAMPLING PROGRAM
To useaa the presence of c hemicals in aoils located beneath the acrap (ie metal auto-bodies tires and white goods) beyond TWA III a aurhce aoil u11plina proaram will be performed The sampli ng program describinamp the nunshyber and type of umplea to be collected h presented in the follovina para shyaraphs
A bullaximum of tvo compoaite samples will be collected fr011 each of the three designated acrap areas a prell11inary backaround aoil characterhat ion cocshypoampite (Phase I Ullpling) and a post-re110val characterhation composite (Phase II sampllna)
-11shy
I I I I
61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
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The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
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13 Previous Studies
The majority of the environmental sampling at the F OConnor s ite has taken place within the site secur ity fe nce (approxin~ately 250 umplu have been lUll collected from Tunsformer Work Area (TWA) I TWA II and associated drainshyages) Thirty-five samples were also collected and analyzed fr0111 outside the I security fence during Tour I to aueu PCB concentra tions in and around TWA III four of theae samples were analyzed for HSL organ ica and inorganics The results of Tour 1 surface soil sampling in TWA Ill indicate that PCB concenshytrations ra nse fr0111 660 ppm to nondetectable concentrations (less than 1 ppra) a nd are limited to a 2500 square foot area located alons the site access road HSL organic (excluding PCBa) and inorganic chemicals do not exist above area background concentrations Figure 1-2 illustrates Tour 1 analytical PCB result s fo r surface so U sampling at TWA III
20 REMOVAL LOGISTICS
The reova l of scrap atniah stockpiled beyond TWA 111 at the r OConnor site will requi re the use of severa l pieces of heavy equipcMnt (e J front
~d~s~k~ede~~ro~ ~~~~c ~p ~n~=~ =~~~ ~nt- ( - in an overview capacity end to ai d i n the clauif ica tion of scrap The followina section i dentif ies the roles of on-site personnel describes the roval operation and the use of heavy equtpnt and de tail s the heavy equipshy0 nt decontabullination procedures a t the close of the reoval proarabull
21 On-Site Personnel
Scrap reovd operat ions can be di vi ded into the following responsibilities
~~Xamp o P rooovo l - Hvy oquipmont opontolt 0
V ~ ( manifesting i den tification and handling of scra p that may require0 s pecial ha ndling (fluld-fUled e l ectrica l equipment) - QIP shy~
project raanagement - Jordan
~~c ~ k~sts the designated personnel and their specific role for each of
22 Reaval Operations
The scrap reraoval operation will begin with a rainor upgrade of the scrap area acceu road which is located north and east of the scrap area t hrough the Rodrique property The road improve111ent will consist of place11ent and gradins of aravel (approxi-tely ten yards) in three low areas along the road and the construction of a gravel truck loading pad on the western1110st end of the exisshytinamp scrap pile
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Fo llow ing t he road i mprovement operations scrap remova l wi ll comme nce i n t he most wes t er l y portion of the Scrap Area I and wil l proceed t hrough Scra p Area 111 (see Ftsu r e 2-1) The r emova l operations are expected to include bu t are (~middotmiddot not limited to t he following pieces of equipment sraall bulldozer large
Ibckhoe front end loader and a minimum of two 14 or 18 cubic yard d ump trucks The removal will proceed in the following manner
A dUlllp truck will be stased on the newly constructed gravel loading pad
Piles within each scrap area (Scrap Areas 1 11 and 111) will be identified numbered and photographed by Jordan personnel
Each pile in the iramediate area of removal will be carefully (~~ ) searched by CHP on-site personnel for any flu id-fil l ed electrical ( e qu ipa~ent (see Section 50)
After a pile has been designated as clean (f r ee of flui d- fill ed-~_ bull 1
a l ect rlca l equ i pme nt) t he scrap will be pu lled dovn t o th a l oadina pad with t he dozer a nd loaded into the truck with the front a nd loa dar The genera l contents of e ach pile will ba recorded durina th is process by J orda n personne 1
Thh proceu will cont i nue until t he s t aaed truck h full tha bill of l ad i na will the n be sts ned a nd the ruteriah will ba re-oved to an appropriat e dh pou l fac ility (ue Sac tion s 41 and 4 2 Trans shyportationDh pou l) Th e aecond truck wi ll be 1110ved t o the load ina pad and the raoval proceu will continue
As the sc rap remova l prog r esses toward Sc rap Area III the pull- down ampone betwee n the t ru cks a nd th e scrap wil l neceua rily bacoe a l onshya a t ed (see Fi gure 2-1) However t hroughout th e reiIOVSl process t he l oad i ng of t rucks will only take place at tha l oa d i ng pad Th is procedur e h instituted to avoid contact of the t r uck wheels wit h unc haracterhed soils previously located beneath t he scrap In this ma nner the trucks will be able to move off the loading pad and ultimately off-site without requiring decontamination
In the course of the scrap search and removal process areas of conshycern as identified by CHP Jordan and USEPA 1 will be isolated (either by cones or bar rier tape from the scrap blling pulled down by the dozer These identified areas will become the designated Phase 11 soil sampling locations described in Section 60 The handling of any fluid-filled electric equipn~ent that might be discovered in the searching proceu is addressed in Section 50
To avoid raove11ent of heavy equipment across known conta11inated sol Is in the TWA lll area 111ateriah located in Scrap Area 111 will be MOved from Scrap Area lll to the pulldown zone by hand or with wheal
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barrows This precaution will be undertaken to avoid exceuive disshyturbance of soils previousl y characterized during Tour I surface soil sampling (see Figure 1-2) Any mate rials tha t cannot be removed in this fashion from this area will remain at their current location Two very large bush ings located adjacent to the TWA III are examples of the types of mat e rlala that will not be removed during this operation
23 Decontaminat ion of Equipment
Following completion of the sc rap removal program decon t arli nation of removal eq uipmen t tracks a nd or tires will be performed a s a preca utionary 11easure to avoid the off-site transport of site-derived soils Decontamtncion will be accomplished in a 25-foot l ong by 20-foot wide nea located near the truck loading pad (designated as the decon area in Fiaure 2-1) The decon area (to be constructed by a dozer) will consist of a sliahtly inclined flat around surface with berr~ed edaes running along the lenath of the s lope This area will be lined with plutic and covered with 34-inch plywood and its ban a 16 x 3 x 4 ( deep) trench (excavated by the backhoe) will serve as a catch- IHnt basin for the decontar~ination water Durinamp use of the decon area each piece of equipcaent will enter the upper portion vhere vehicle trackstires will be washed down of all loose dirt usina a water truck These washinas will drain on the plutic to the containment trench and in this aanner avoid r unoff The equipcHnt will then be loaded directly onto its carrytna flatbed at the loadina pad for off-site transport
Upon copletion of scrap re~Ktval the decon area will be disntled The plastic will be containeriud for s ubampeque nt off-site disposal the plywood wlll be stored within the security fence for possible future use and the aravel will be retained in-place and addrened as part of the total site nuaediation
30 PERSONAL PROTECTION
The 11intmu11 level of personal pro t ec tion thc will be reco-ended to all on-site personnel a nd utilized by Jordan at the F OConnor site durinamp tcrap removal operations will be Level D dermal and respito ry protection The scrap 1s considered be nign taking into account t he history of the operations and pendina Phue 1 sampling results (tee Section 61) work glovu should however be worn to avoid c uts Since the scrap is assumed to be located in a clean trea i n ten11s of soil chemicals and tnnsportion through TWA III will be restricted it is antici pated that the removal of the scrap will not cbulluse atmospheric cont bullllination3in the range of the Threshold Limit Vtue (TLV) for PCBs (05 to 10 mam ) If excessive airborne dust particles 111re produced durinamp scrap removal then wearing of dust mukt will be recofiended aa a precbullutionary meuura (this judgment will be made by the Jordan site safety oHicer)
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The Level D persona l protection gear will consist of the following
cotton coveralh Jtee l - toed chemicll resiatl nt boot s hard hat ear protection (optional) cottonluther gloves (when contac t with the scrap is anticipated)
The UCOIIIIM nded level of protection will be upsuded to Leve l C dermal for person ne l who will be involved with larkinamp of fluid-f i lled electrica l equipment The Level C de r1111l personal protection gear conaists of all the items noted for Level D dermbull l except cotton cover1lh 1nd work stoves will be replaced with c hemtc1l ly protective coveralla 1nd inner 1nd outer gloves
Person l decont1minbulltton will consist of diapoaina of bull ny che11tcll-reais t a n t cloth inamp or du s t muka t hbull t bullre worn into phstic aarbbullae bbullampbull for subuque nt stonae on-site in DOT bull pproved 55-ampbullllon drw Boot deconta11in1tion fbullctlitiea (bucketa nd scrub brushea) will be bullvailable aince on-site personnel 11ay h1ve to enter the TWA III 1re1
Add ittonll i nfor-1tion re11rdi n1 Jord1n a hed t h 1nd ufety procedures Cln be fou nd in the at t e Project Operations Plan (POP) June 1986
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS
Followina load t na t he scrap will be transported to bull nd disposed of at a disshypout location that 1a JWtually aareeable to USPA Maine DP and CMP It is proposed that the City o f Auausta Hatch Hill Lbullndfill Auausta Maine located approximately fou r (4) bullilu f r0111 the site be utiliud for d isposal of the scnp Transportation 1 nd diapoul at this site will be handled in the fol lowtna 111 nne r
Two hiamph-wdled 14 or 18 cubic y1rd trucka each haulinamp a max i11un lo1d of 35000 lbs will be utilized to t ransport the scrap to Hatch Hill Landfill Consideri ng the anticipbullted 500 tons of scrap approximbulltely 30 trips to the landfill bullre 1 nt ictpate d The scra p will be covered with canv1s covera 1 nd stabilized aa necessary uainamp ropes tarps e t c
Decontbullnin1 tion of truck tires prior to site dep1rture ha s not been s pecif ied abull trucks dastsnlted for off-site transport will be reatricted to arua known to be cle1n based on Tour I analytical resu l ts
-middotshy
I I I I
Aa a matter of good record keep i ng a bill opound lad i ng will accompany ea ch scrap load Th is doc ument a t i on will be prepand by the r emova l contractor a nd wi ll inc lude
name a nd address of the t ra nsporter or iain o f th e sc ra p c ha rac t e ri s t i c s of the scrap u tbiiA t e d quantity o f the scrap and fi na l disposa l destinat ion
CHP the removal cont rac t or a nd Ha tch Hill Landfi ll will stan the bi ll of lad i ng fo r each l oad The orta i nal wil l be r etaine d i n CHP fi l es copies will be d istr ibuted to Int e res t ed par ties
42 Disposal
Disposa l of the scrap a t Ha tch Hill Landfill will be routine Th e only required perbullit utablishu authorized uae of Hatch Hill Landfill This pershybullit is to be obtained by the contractor fr011 the City of Auausta it speciflu na and loccion of the hauler and reaistration inforMation for each vehicle to be used for scrap delivery to Hatch Hill Landfill
Hatch Hill Landfill hours en libullited to 8 00 a bullbullbull to 400 Pbullbullbullbull Tuesday throuah Friday The scrap will arrive in loads that confom with the specishyfied atoraae piles and areu at tch Hill Landfill Hatch Hill raquiru that electric Mter bodiu arrive uparauly Tires are separated fro Mtal and fluids (such aa tranabulliuion oil) are re~~aved fron autoobile bodies Then f~uida will be collected and disposed of at local oil depository locations
50 SPECIAL HANDLING LOGISTICS
Durinamp the re110val of the scrap from the F OConnor si t e fluid- filled elec trical equipntent bull ay be discovered In ant icipati ng th is occurre nce t his sec tion outlines the i dentification of a nd fiel d l ogist ics conce rn i ng the electr ica l e quip11ent
5 1 Equipment Identif i ca tion
A CHP representat ive will be on-site on a part-time basis to ide ntify a ny scra p t hc is no t considered conve ntion a l aolid waste Fl u id-filled electri shycal eq ui pbullent will re qu ire s pecial consideration due to it a potential PCB conte nt
Upon identification the electrical e qul pbullent will be numbered inventori ed a taaed and left on-site In an undisturbed s tate Underlytna s c rap located adjacent to the fluid-filled electrical equtpr~ent that exh i bits oil stains will also be left In place Personnel will upgrade their level of protection
- 10shy
to Level C dermal (aee Section 30) when marking and working among the fluidshyfilled electrical equ ipment The equipment will be numbered with a paint marker us ing a predetermined numbering system for field designation They will then be logged into the pr oject records which will note
date of discovery fhld designation numbe r location description not a tion of r~anufactulers identification plate evidence of any spill associated with the item
A sraall area around the equipment will be isolated with cones or barrier tape to ensure that this area is not disturbed or trafficked during the removal process as described in Section 20 Subsequent to the completion of the scrap reaval operation the nature and quantity of fluid-filled equipa~ent will be evaluated and an appropriate plan for preferred dispoampition of this terial will be developed The plan will be coordinated aMOng CHP Jordan end the reaulatory aaencies prior to implementationbull
52 Spill Provisions
Thouah the occurrence of spills is not expected durinamp scrap reavt operashytiona at the r OConnor aite provisions for spilh vill ba provided Spill equis-ent will consist of oil sorbent hbrics ha nd tools and containers for disposal of the spill uriah The on-site equipn~ent will include
ten 18 X 18 aorbent pillows tvo rolla of oil sorbent polypropylene four 10-foot lenaths of 5 vide containment bo011 three 55-aallon drun~s for disposal of spill mceriah two hand shove h
This aquipent vill be phced in the vicinity of the acra p reMOvd operations In the event of a apill saturated materials muat be disposed of in compliance vith StateFederal regu lac ions
6 0 SCRAP AREA SOIL SAMPLING PROGRAM
To useaa the presence of c hemicals in aoils located beneath the acrap (ie metal auto-bodies tires and white goods) beyond TWA III a aurhce aoil u11plina proaram will be performed The sampli ng program describinamp the nunshyber and type of umplea to be collected h presented in the follovina para shyaraphs
A bullaximum of tvo compoaite samples will be collected fr011 each of the three designated acrap areas a prell11inary backaround aoil characterhat ion cocshypoampite (Phase I Ullpling) and a post-re110val characterhation composite (Phase II sampllna)
-11shy
I I I I
61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
-12shy
JiR ~~ ( It tl flI
0
The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
-13shy
I I I I
IJiMltil
Fo llow ing t he road i mprovement operations scrap remova l wi ll comme nce i n t he most wes t er l y portion of the Scrap Area I and wil l proceed t hrough Scra p Area 111 (see Ftsu r e 2-1) The r emova l operations are expected to include bu t are (~middotmiddot not limited to t he following pieces of equipment sraall bulldozer large
Ibckhoe front end loader and a minimum of two 14 or 18 cubic yard d ump trucks The removal will proceed in the following manner
A dUlllp truck will be stased on the newly constructed gravel loading pad
Piles within each scrap area (Scrap Areas 1 11 and 111) will be identified numbered and photographed by Jordan personnel
Each pile in the iramediate area of removal will be carefully (~~ ) searched by CHP on-site personnel for any flu id-fil l ed electrical ( e qu ipa~ent (see Section 50)
After a pile has been designated as clean (f r ee of flui d- fill ed-~_ bull 1
a l ect rlca l equ i pme nt) t he scrap will be pu lled dovn t o th a l oadina pad with t he dozer a nd loaded into the truck with the front a nd loa dar The genera l contents of e ach pile will ba recorded durina th is process by J orda n personne 1
Thh proceu will cont i nue until t he s t aaed truck h full tha bill of l ad i na will the n be sts ned a nd the ruteriah will ba re-oved to an appropriat e dh pou l fac ility (ue Sac tion s 41 and 4 2 Trans shyportationDh pou l) Th e aecond truck wi ll be 1110ved t o the load ina pad and the raoval proceu will continue
As the sc rap remova l prog r esses toward Sc rap Area III the pull- down ampone betwee n the t ru cks a nd th e scrap wil l neceua rily bacoe a l onshya a t ed (see Fi gure 2-1) However t hroughout th e reiIOVSl process t he l oad i ng of t rucks will only take place at tha l oa d i ng pad Th is procedur e h instituted to avoid contact of the t r uck wheels wit h unc haracterhed soils previously located beneath t he scrap In this ma nner the trucks will be able to move off the loading pad and ultimately off-site without requiring decontamination
In the course of the scrap search and removal process areas of conshycern as identified by CHP Jordan and USEPA 1 will be isolated (either by cones or bar rier tape from the scrap blling pulled down by the dozer These identified areas will become the designated Phase 11 soil sampling locations described in Section 60 The handling of any fluid-filled electric equipn~ent that might be discovered in the searching proceu is addressed in Section 50
To avoid raove11ent of heavy equipment across known conta11inated sol Is in the TWA lll area 111ateriah located in Scrap Area 111 will be MOved from Scrap Area lll to the pulldown zone by hand or with wheal
-5shy
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at
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att
31ll
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11
11
_
_
__
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barrows This precaution will be undertaken to avoid exceuive disshyturbance of soils previousl y characterized during Tour I surface soil sampling (see Figure 1-2) Any mate rials tha t cannot be removed in this fashion from this area will remain at their current location Two very large bush ings located adjacent to the TWA III are examples of the types of mat e rlala that will not be removed during this operation
23 Decontaminat ion of Equipment
Following completion of the sc rap removal program decon t arli nation of removal eq uipmen t tracks a nd or tires will be performed a s a preca utionary 11easure to avoid the off-site transport of site-derived soils Decontamtncion will be accomplished in a 25-foot l ong by 20-foot wide nea located near the truck loading pad (designated as the decon area in Fiaure 2-1) The decon area (to be constructed by a dozer) will consist of a sliahtly inclined flat around surface with berr~ed edaes running along the lenath of the s lope This area will be lined with plutic and covered with 34-inch plywood and its ban a 16 x 3 x 4 ( deep) trench (excavated by the backhoe) will serve as a catch- IHnt basin for the decontar~ination water Durinamp use of the decon area each piece of equipcaent will enter the upper portion vhere vehicle trackstires will be washed down of all loose dirt usina a water truck These washinas will drain on the plutic to the containment trench and in this aanner avoid r unoff The equipcHnt will then be loaded directly onto its carrytna flatbed at the loadina pad for off-site transport
Upon copletion of scrap re~Ktval the decon area will be disntled The plastic will be containeriud for s ubampeque nt off-site disposal the plywood wlll be stored within the security fence for possible future use and the aravel will be retained in-place and addrened as part of the total site nuaediation
30 PERSONAL PROTECTION
The 11intmu11 level of personal pro t ec tion thc will be reco-ended to all on-site personnel a nd utilized by Jordan at the F OConnor site durinamp tcrap removal operations will be Level D dermal and respito ry protection The scrap 1s considered be nign taking into account t he history of the operations and pendina Phue 1 sampling results (tee Section 61) work glovu should however be worn to avoid c uts Since the scrap is assumed to be located in a clean trea i n ten11s of soil chemicals and tnnsportion through TWA III will be restricted it is antici pated that the removal of the scrap will not cbulluse atmospheric cont bullllination3in the range of the Threshold Limit Vtue (TLV) for PCBs (05 to 10 mam ) If excessive airborne dust particles 111re produced durinamp scrap removal then wearing of dust mukt will be recofiended aa a precbullutionary meuura (this judgment will be made by the Jordan site safety oHicer)
-8shy
I I I I
ttil (~rII
The Level D persona l protection gear will consist of the following
cotton coveralh Jtee l - toed chemicll resiatl nt boot s hard hat ear protection (optional) cottonluther gloves (when contac t with the scrap is anticipated)
The UCOIIIIM nded level of protection will be upsuded to Leve l C dermal for person ne l who will be involved with larkinamp of fluid-f i lled electrica l equipment The Level C de r1111l personal protection gear conaists of all the items noted for Level D dermbull l except cotton cover1lh 1nd work stoves will be replaced with c hemtc1l ly protective coveralla 1nd inner 1nd outer gloves
Person l decont1minbulltton will consist of diapoaina of bull ny che11tcll-reais t a n t cloth inamp or du s t muka t hbull t bullre worn into phstic aarbbullae bbullampbull for subuque nt stonae on-site in DOT bull pproved 55-ampbullllon drw Boot deconta11in1tion fbullctlitiea (bucketa nd scrub brushea) will be bullvailable aince on-site personnel 11ay h1ve to enter the TWA III 1re1
Add ittonll i nfor-1tion re11rdi n1 Jord1n a hed t h 1nd ufety procedures Cln be fou nd in the at t e Project Operations Plan (POP) June 1986
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS
Followina load t na t he scrap will be transported to bull nd disposed of at a disshypout location that 1a JWtually aareeable to USPA Maine DP and CMP It is proposed that the City o f Auausta Hatch Hill Lbullndfill Auausta Maine located approximately fou r (4) bullilu f r0111 the site be utiliud for d isposal of the scnp Transportation 1 nd diapoul at this site will be handled in the fol lowtna 111 nne r
Two hiamph-wdled 14 or 18 cubic y1rd trucka each haulinamp a max i11un lo1d of 35000 lbs will be utilized to t ransport the scrap to Hatch Hill Landfill Consideri ng the anticipbullted 500 tons of scrap approximbulltely 30 trips to the landfill bullre 1 nt ictpate d The scra p will be covered with canv1s covera 1 nd stabilized aa necessary uainamp ropes tarps e t c
Decontbullnin1 tion of truck tires prior to site dep1rture ha s not been s pecif ied abull trucks dastsnlted for off-site transport will be reatricted to arua known to be cle1n based on Tour I analytical resu l ts
-middotshy
I I I I
Aa a matter of good record keep i ng a bill opound lad i ng will accompany ea ch scrap load Th is doc ument a t i on will be prepand by the r emova l contractor a nd wi ll inc lude
name a nd address of the t ra nsporter or iain o f th e sc ra p c ha rac t e ri s t i c s of the scrap u tbiiA t e d quantity o f the scrap and fi na l disposa l destinat ion
CHP the removal cont rac t or a nd Ha tch Hill Landfi ll will stan the bi ll of lad i ng fo r each l oad The orta i nal wil l be r etaine d i n CHP fi l es copies will be d istr ibuted to Int e res t ed par ties
42 Disposal
Disposa l of the scrap a t Ha tch Hill Landfill will be routine Th e only required perbullit utablishu authorized uae of Hatch Hill Landfill This pershybullit is to be obtained by the contractor fr011 the City of Auausta it speciflu na and loccion of the hauler and reaistration inforMation for each vehicle to be used for scrap delivery to Hatch Hill Landfill
Hatch Hill Landfill hours en libullited to 8 00 a bullbullbull to 400 Pbullbullbullbull Tuesday throuah Friday The scrap will arrive in loads that confom with the specishyfied atoraae piles and areu at tch Hill Landfill Hatch Hill raquiru that electric Mter bodiu arrive uparauly Tires are separated fro Mtal and fluids (such aa tranabulliuion oil) are re~~aved fron autoobile bodies Then f~uida will be collected and disposed of at local oil depository locations
50 SPECIAL HANDLING LOGISTICS
Durinamp the re110val of the scrap from the F OConnor si t e fluid- filled elec trical equipntent bull ay be discovered In ant icipati ng th is occurre nce t his sec tion outlines the i dentification of a nd fiel d l ogist ics conce rn i ng the electr ica l e quip11ent
5 1 Equipment Identif i ca tion
A CHP representat ive will be on-site on a part-time basis to ide ntify a ny scra p t hc is no t considered conve ntion a l aolid waste Fl u id-filled electri shycal eq ui pbullent will re qu ire s pecial consideration due to it a potential PCB conte nt
Upon identification the electrical e qul pbullent will be numbered inventori ed a taaed and left on-site In an undisturbed s tate Underlytna s c rap located adjacent to the fluid-filled electrical equtpr~ent that exh i bits oil stains will also be left In place Personnel will upgrade their level of protection
- 10shy
to Level C dermal (aee Section 30) when marking and working among the fluidshyfilled electrical equ ipment The equipment will be numbered with a paint marker us ing a predetermined numbering system for field designation They will then be logged into the pr oject records which will note
date of discovery fhld designation numbe r location description not a tion of r~anufactulers identification plate evidence of any spill associated with the item
A sraall area around the equipment will be isolated with cones or barrier tape to ensure that this area is not disturbed or trafficked during the removal process as described in Section 20 Subsequent to the completion of the scrap reaval operation the nature and quantity of fluid-filled equipa~ent will be evaluated and an appropriate plan for preferred dispoampition of this terial will be developed The plan will be coordinated aMOng CHP Jordan end the reaulatory aaencies prior to implementationbull
52 Spill Provisions
Thouah the occurrence of spills is not expected durinamp scrap reavt operashytiona at the r OConnor aite provisions for spilh vill ba provided Spill equis-ent will consist of oil sorbent hbrics ha nd tools and containers for disposal of the spill uriah The on-site equipn~ent will include
ten 18 X 18 aorbent pillows tvo rolla of oil sorbent polypropylene four 10-foot lenaths of 5 vide containment bo011 three 55-aallon drun~s for disposal of spill mceriah two hand shove h
This aquipent vill be phced in the vicinity of the acra p reMOvd operations In the event of a apill saturated materials muat be disposed of in compliance vith StateFederal regu lac ions
6 0 SCRAP AREA SOIL SAMPLING PROGRAM
To useaa the presence of c hemicals in aoils located beneath the acrap (ie metal auto-bodies tires and white goods) beyond TWA III a aurhce aoil u11plina proaram will be performed The sampli ng program describinamp the nunshyber and type of umplea to be collected h presented in the follovina para shyaraphs
A bullaximum of tvo compoaite samples will be collected fr011 each of the three designated acrap areas a prell11inary backaround aoil characterhat ion cocshypoampite (Phase I Ullpling) and a post-re110val characterhation composite (Phase II sampllna)
-11shy
I I I I
61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
-12shy
JiR ~~ ( It tl flI
0
The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
-13shy
I ~ I
~
~ ] [
il u bullbull gt
~~ ~ ~
~ gt u 0 c u u~ 0~ ~
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l c
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~
~ bull ~~E~E=
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middot middot-middot
_
EQ
UIP
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NT -middotT
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r F
IGU
RE
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S
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ET
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UIP
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S
~
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A
UG
US
TA
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AIN
E
L-------------~~---------------------------------~00
at
el
att
31ll
W~lSINIWOW
AW
dW
Ogt
~gt0
11
11
_
_
__
___
_ --
--
barrows This precaution will be undertaken to avoid exceuive disshyturbance of soils previousl y characterized during Tour I surface soil sampling (see Figure 1-2) Any mate rials tha t cannot be removed in this fashion from this area will remain at their current location Two very large bush ings located adjacent to the TWA III are examples of the types of mat e rlala that will not be removed during this operation
23 Decontaminat ion of Equipment
Following completion of the sc rap removal program decon t arli nation of removal eq uipmen t tracks a nd or tires will be performed a s a preca utionary 11easure to avoid the off-site transport of site-derived soils Decontamtncion will be accomplished in a 25-foot l ong by 20-foot wide nea located near the truck loading pad (designated as the decon area in Fiaure 2-1) The decon area (to be constructed by a dozer) will consist of a sliahtly inclined flat around surface with berr~ed edaes running along the lenath of the s lope This area will be lined with plutic and covered with 34-inch plywood and its ban a 16 x 3 x 4 ( deep) trench (excavated by the backhoe) will serve as a catch- IHnt basin for the decontar~ination water Durinamp use of the decon area each piece of equipcaent will enter the upper portion vhere vehicle trackstires will be washed down of all loose dirt usina a water truck These washinas will drain on the plutic to the containment trench and in this aanner avoid r unoff The equipcHnt will then be loaded directly onto its carrytna flatbed at the loadina pad for off-site transport
Upon copletion of scrap re~Ktval the decon area will be disntled The plastic will be containeriud for s ubampeque nt off-site disposal the plywood wlll be stored within the security fence for possible future use and the aravel will be retained in-place and addrened as part of the total site nuaediation
30 PERSONAL PROTECTION
The 11intmu11 level of personal pro t ec tion thc will be reco-ended to all on-site personnel a nd utilized by Jordan at the F OConnor site durinamp tcrap removal operations will be Level D dermal and respito ry protection The scrap 1s considered be nign taking into account t he history of the operations and pendina Phue 1 sampling results (tee Section 61) work glovu should however be worn to avoid c uts Since the scrap is assumed to be located in a clean trea i n ten11s of soil chemicals and tnnsportion through TWA III will be restricted it is antici pated that the removal of the scrap will not cbulluse atmospheric cont bullllination3in the range of the Threshold Limit Vtue (TLV) for PCBs (05 to 10 mam ) If excessive airborne dust particles 111re produced durinamp scrap removal then wearing of dust mukt will be recofiended aa a precbullutionary meuura (this judgment will be made by the Jordan site safety oHicer)
-8shy
I I I I
ttil (~rII
The Level D persona l protection gear will consist of the following
cotton coveralh Jtee l - toed chemicll resiatl nt boot s hard hat ear protection (optional) cottonluther gloves (when contac t with the scrap is anticipated)
The UCOIIIIM nded level of protection will be upsuded to Leve l C dermal for person ne l who will be involved with larkinamp of fluid-f i lled electrica l equipment The Level C de r1111l personal protection gear conaists of all the items noted for Level D dermbull l except cotton cover1lh 1nd work stoves will be replaced with c hemtc1l ly protective coveralla 1nd inner 1nd outer gloves
Person l decont1minbulltton will consist of diapoaina of bull ny che11tcll-reais t a n t cloth inamp or du s t muka t hbull t bullre worn into phstic aarbbullae bbullampbull for subuque nt stonae on-site in DOT bull pproved 55-ampbullllon drw Boot deconta11in1tion fbullctlitiea (bucketa nd scrub brushea) will be bullvailable aince on-site personnel 11ay h1ve to enter the TWA III 1re1
Add ittonll i nfor-1tion re11rdi n1 Jord1n a hed t h 1nd ufety procedures Cln be fou nd in the at t e Project Operations Plan (POP) June 1986
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS
Followina load t na t he scrap will be transported to bull nd disposed of at a disshypout location that 1a JWtually aareeable to USPA Maine DP and CMP It is proposed that the City o f Auausta Hatch Hill Lbullndfill Auausta Maine located approximately fou r (4) bullilu f r0111 the site be utiliud for d isposal of the scnp Transportation 1 nd diapoul at this site will be handled in the fol lowtna 111 nne r
Two hiamph-wdled 14 or 18 cubic y1rd trucka each haulinamp a max i11un lo1d of 35000 lbs will be utilized to t ransport the scrap to Hatch Hill Landfill Consideri ng the anticipbullted 500 tons of scrap approximbulltely 30 trips to the landfill bullre 1 nt ictpate d The scra p will be covered with canv1s covera 1 nd stabilized aa necessary uainamp ropes tarps e t c
Decontbullnin1 tion of truck tires prior to site dep1rture ha s not been s pecif ied abull trucks dastsnlted for off-site transport will be reatricted to arua known to be cle1n based on Tour I analytical resu l ts
-middotshy
I I I I
Aa a matter of good record keep i ng a bill opound lad i ng will accompany ea ch scrap load Th is doc ument a t i on will be prepand by the r emova l contractor a nd wi ll inc lude
name a nd address of the t ra nsporter or iain o f th e sc ra p c ha rac t e ri s t i c s of the scrap u tbiiA t e d quantity o f the scrap and fi na l disposa l destinat ion
CHP the removal cont rac t or a nd Ha tch Hill Landfi ll will stan the bi ll of lad i ng fo r each l oad The orta i nal wil l be r etaine d i n CHP fi l es copies will be d istr ibuted to Int e res t ed par ties
42 Disposal
Disposa l of the scrap a t Ha tch Hill Landfill will be routine Th e only required perbullit utablishu authorized uae of Hatch Hill Landfill This pershybullit is to be obtained by the contractor fr011 the City of Auausta it speciflu na and loccion of the hauler and reaistration inforMation for each vehicle to be used for scrap delivery to Hatch Hill Landfill
Hatch Hill Landfill hours en libullited to 8 00 a bullbullbull to 400 Pbullbullbullbull Tuesday throuah Friday The scrap will arrive in loads that confom with the specishyfied atoraae piles and areu at tch Hill Landfill Hatch Hill raquiru that electric Mter bodiu arrive uparauly Tires are separated fro Mtal and fluids (such aa tranabulliuion oil) are re~~aved fron autoobile bodies Then f~uida will be collected and disposed of at local oil depository locations
50 SPECIAL HANDLING LOGISTICS
Durinamp the re110val of the scrap from the F OConnor si t e fluid- filled elec trical equipntent bull ay be discovered In ant icipati ng th is occurre nce t his sec tion outlines the i dentification of a nd fiel d l ogist ics conce rn i ng the electr ica l e quip11ent
5 1 Equipment Identif i ca tion
A CHP representat ive will be on-site on a part-time basis to ide ntify a ny scra p t hc is no t considered conve ntion a l aolid waste Fl u id-filled electri shycal eq ui pbullent will re qu ire s pecial consideration due to it a potential PCB conte nt
Upon identification the electrical e qul pbullent will be numbered inventori ed a taaed and left on-site In an undisturbed s tate Underlytna s c rap located adjacent to the fluid-filled electrical equtpr~ent that exh i bits oil stains will also be left In place Personnel will upgrade their level of protection
- 10shy
to Level C dermal (aee Section 30) when marking and working among the fluidshyfilled electrical equ ipment The equipment will be numbered with a paint marker us ing a predetermined numbering system for field designation They will then be logged into the pr oject records which will note
date of discovery fhld designation numbe r location description not a tion of r~anufactulers identification plate evidence of any spill associated with the item
A sraall area around the equipment will be isolated with cones or barrier tape to ensure that this area is not disturbed or trafficked during the removal process as described in Section 20 Subsequent to the completion of the scrap reaval operation the nature and quantity of fluid-filled equipa~ent will be evaluated and an appropriate plan for preferred dispoampition of this terial will be developed The plan will be coordinated aMOng CHP Jordan end the reaulatory aaencies prior to implementationbull
52 Spill Provisions
Thouah the occurrence of spills is not expected durinamp scrap reavt operashytiona at the r OConnor aite provisions for spilh vill ba provided Spill equis-ent will consist of oil sorbent hbrics ha nd tools and containers for disposal of the spill uriah The on-site equipn~ent will include
ten 18 X 18 aorbent pillows tvo rolla of oil sorbent polypropylene four 10-foot lenaths of 5 vide containment bo011 three 55-aallon drun~s for disposal of spill mceriah two hand shove h
This aquipent vill be phced in the vicinity of the acra p reMOvd operations In the event of a apill saturated materials muat be disposed of in compliance vith StateFederal regu lac ions
6 0 SCRAP AREA SOIL SAMPLING PROGRAM
To useaa the presence of c hemicals in aoils located beneath the acrap (ie metal auto-bodies tires and white goods) beyond TWA III a aurhce aoil u11plina proaram will be performed The sampli ng program describinamp the nunshyber and type of umplea to be collected h presented in the follovina para shyaraphs
A bullaximum of tvo compoaite samples will be collected fr011 each of the three designated acrap areas a prell11inary backaround aoil characterhat ion cocshypoampite (Phase I Ullpling) and a post-re110val characterhation composite (Phase II sampllna)
-11shy
I I I I
61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
-12shy
JiR ~~ ( It tl flI
0
The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
-13shy
~ bull ~~E~E=
s~ -~
middot middot-middot
_
EQ
UIP
ME
NT -middotT
-
r F
IGU
RE
2-1
S
CA
LE
FE
ET
EQ
UIP
ME
NT
MO
VE
ME
NT
LO
GIS
TIC
S
~
F
OC
ON
NO
R S
ITE
A
UG
US
TA
M
AIN
E
L-------------~~---------------------------------~00
at
el
att
31ll
W~lSINIWOW
AW
dW
Ogt
~gt0
11
11
_
_
__
___
_ --
--
barrows This precaution will be undertaken to avoid exceuive disshyturbance of soils previousl y characterized during Tour I surface soil sampling (see Figure 1-2) Any mate rials tha t cannot be removed in this fashion from this area will remain at their current location Two very large bush ings located adjacent to the TWA III are examples of the types of mat e rlala that will not be removed during this operation
23 Decontaminat ion of Equipment
Following completion of the sc rap removal program decon t arli nation of removal eq uipmen t tracks a nd or tires will be performed a s a preca utionary 11easure to avoid the off-site transport of site-derived soils Decontamtncion will be accomplished in a 25-foot l ong by 20-foot wide nea located near the truck loading pad (designated as the decon area in Fiaure 2-1) The decon area (to be constructed by a dozer) will consist of a sliahtly inclined flat around surface with berr~ed edaes running along the lenath of the s lope This area will be lined with plutic and covered with 34-inch plywood and its ban a 16 x 3 x 4 ( deep) trench (excavated by the backhoe) will serve as a catch- IHnt basin for the decontar~ination water Durinamp use of the decon area each piece of equipcaent will enter the upper portion vhere vehicle trackstires will be washed down of all loose dirt usina a water truck These washinas will drain on the plutic to the containment trench and in this aanner avoid r unoff The equipcHnt will then be loaded directly onto its carrytna flatbed at the loadina pad for off-site transport
Upon copletion of scrap re~Ktval the decon area will be disntled The plastic will be containeriud for s ubampeque nt off-site disposal the plywood wlll be stored within the security fence for possible future use and the aravel will be retained in-place and addrened as part of the total site nuaediation
30 PERSONAL PROTECTION
The 11intmu11 level of personal pro t ec tion thc will be reco-ended to all on-site personnel a nd utilized by Jordan at the F OConnor site durinamp tcrap removal operations will be Level D dermal and respito ry protection The scrap 1s considered be nign taking into account t he history of the operations and pendina Phue 1 sampling results (tee Section 61) work glovu should however be worn to avoid c uts Since the scrap is assumed to be located in a clean trea i n ten11s of soil chemicals and tnnsportion through TWA III will be restricted it is antici pated that the removal of the scrap will not cbulluse atmospheric cont bullllination3in the range of the Threshold Limit Vtue (TLV) for PCBs (05 to 10 mam ) If excessive airborne dust particles 111re produced durinamp scrap removal then wearing of dust mukt will be recofiended aa a precbullutionary meuura (this judgment will be made by the Jordan site safety oHicer)
-8shy
I I I I
ttil (~rII
The Level D persona l protection gear will consist of the following
cotton coveralh Jtee l - toed chemicll resiatl nt boot s hard hat ear protection (optional) cottonluther gloves (when contac t with the scrap is anticipated)
The UCOIIIIM nded level of protection will be upsuded to Leve l C dermal for person ne l who will be involved with larkinamp of fluid-f i lled electrica l equipment The Level C de r1111l personal protection gear conaists of all the items noted for Level D dermbull l except cotton cover1lh 1nd work stoves will be replaced with c hemtc1l ly protective coveralla 1nd inner 1nd outer gloves
Person l decont1minbulltton will consist of diapoaina of bull ny che11tcll-reais t a n t cloth inamp or du s t muka t hbull t bullre worn into phstic aarbbullae bbullampbull for subuque nt stonae on-site in DOT bull pproved 55-ampbullllon drw Boot deconta11in1tion fbullctlitiea (bucketa nd scrub brushea) will be bullvailable aince on-site personnel 11ay h1ve to enter the TWA III 1re1
Add ittonll i nfor-1tion re11rdi n1 Jord1n a hed t h 1nd ufety procedures Cln be fou nd in the at t e Project Operations Plan (POP) June 1986
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS
Followina load t na t he scrap will be transported to bull nd disposed of at a disshypout location that 1a JWtually aareeable to USPA Maine DP and CMP It is proposed that the City o f Auausta Hatch Hill Lbullndfill Auausta Maine located approximately fou r (4) bullilu f r0111 the site be utiliud for d isposal of the scnp Transportation 1 nd diapoul at this site will be handled in the fol lowtna 111 nne r
Two hiamph-wdled 14 or 18 cubic y1rd trucka each haulinamp a max i11un lo1d of 35000 lbs will be utilized to t ransport the scrap to Hatch Hill Landfill Consideri ng the anticipbullted 500 tons of scrap approximbulltely 30 trips to the landfill bullre 1 nt ictpate d The scra p will be covered with canv1s covera 1 nd stabilized aa necessary uainamp ropes tarps e t c
Decontbullnin1 tion of truck tires prior to site dep1rture ha s not been s pecif ied abull trucks dastsnlted for off-site transport will be reatricted to arua known to be cle1n based on Tour I analytical resu l ts
-middotshy
I I I I
Aa a matter of good record keep i ng a bill opound lad i ng will accompany ea ch scrap load Th is doc ument a t i on will be prepand by the r emova l contractor a nd wi ll inc lude
name a nd address of the t ra nsporter or iain o f th e sc ra p c ha rac t e ri s t i c s of the scrap u tbiiA t e d quantity o f the scrap and fi na l disposa l destinat ion
CHP the removal cont rac t or a nd Ha tch Hill Landfi ll will stan the bi ll of lad i ng fo r each l oad The orta i nal wil l be r etaine d i n CHP fi l es copies will be d istr ibuted to Int e res t ed par ties
42 Disposal
Disposa l of the scrap a t Ha tch Hill Landfill will be routine Th e only required perbullit utablishu authorized uae of Hatch Hill Landfill This pershybullit is to be obtained by the contractor fr011 the City of Auausta it speciflu na and loccion of the hauler and reaistration inforMation for each vehicle to be used for scrap delivery to Hatch Hill Landfill
Hatch Hill Landfill hours en libullited to 8 00 a bullbullbull to 400 Pbullbullbullbull Tuesday throuah Friday The scrap will arrive in loads that confom with the specishyfied atoraae piles and areu at tch Hill Landfill Hatch Hill raquiru that electric Mter bodiu arrive uparauly Tires are separated fro Mtal and fluids (such aa tranabulliuion oil) are re~~aved fron autoobile bodies Then f~uida will be collected and disposed of at local oil depository locations
50 SPECIAL HANDLING LOGISTICS
Durinamp the re110val of the scrap from the F OConnor si t e fluid- filled elec trical equipntent bull ay be discovered In ant icipati ng th is occurre nce t his sec tion outlines the i dentification of a nd fiel d l ogist ics conce rn i ng the electr ica l e quip11ent
5 1 Equipment Identif i ca tion
A CHP representat ive will be on-site on a part-time basis to ide ntify a ny scra p t hc is no t considered conve ntion a l aolid waste Fl u id-filled electri shycal eq ui pbullent will re qu ire s pecial consideration due to it a potential PCB conte nt
Upon identification the electrical e qul pbullent will be numbered inventori ed a taaed and left on-site In an undisturbed s tate Underlytna s c rap located adjacent to the fluid-filled electrical equtpr~ent that exh i bits oil stains will also be left In place Personnel will upgrade their level of protection
- 10shy
to Level C dermal (aee Section 30) when marking and working among the fluidshyfilled electrical equ ipment The equipment will be numbered with a paint marker us ing a predetermined numbering system for field designation They will then be logged into the pr oject records which will note
date of discovery fhld designation numbe r location description not a tion of r~anufactulers identification plate evidence of any spill associated with the item
A sraall area around the equipment will be isolated with cones or barrier tape to ensure that this area is not disturbed or trafficked during the removal process as described in Section 20 Subsequent to the completion of the scrap reaval operation the nature and quantity of fluid-filled equipa~ent will be evaluated and an appropriate plan for preferred dispoampition of this terial will be developed The plan will be coordinated aMOng CHP Jordan end the reaulatory aaencies prior to implementationbull
52 Spill Provisions
Thouah the occurrence of spills is not expected durinamp scrap reavt operashytiona at the r OConnor aite provisions for spilh vill ba provided Spill equis-ent will consist of oil sorbent hbrics ha nd tools and containers for disposal of the spill uriah The on-site equipn~ent will include
ten 18 X 18 aorbent pillows tvo rolla of oil sorbent polypropylene four 10-foot lenaths of 5 vide containment bo011 three 55-aallon drun~s for disposal of spill mceriah two hand shove h
This aquipent vill be phced in the vicinity of the acra p reMOvd operations In the event of a apill saturated materials muat be disposed of in compliance vith StateFederal regu lac ions
6 0 SCRAP AREA SOIL SAMPLING PROGRAM
To useaa the presence of c hemicals in aoils located beneath the acrap (ie metal auto-bodies tires and white goods) beyond TWA III a aurhce aoil u11plina proaram will be performed The sampli ng program describinamp the nunshyber and type of umplea to be collected h presented in the follovina para shyaraphs
A bullaximum of tvo compoaite samples will be collected fr011 each of the three designated acrap areas a prell11inary backaround aoil characterhat ion cocshypoampite (Phase I Ullpling) and a post-re110val characterhation composite (Phase II sampllna)
-11shy
I I I I
61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
-12shy
JiR ~~ ( It tl flI
0
The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
-13shy
barrows This precaution will be undertaken to avoid exceuive disshyturbance of soils previousl y characterized during Tour I surface soil sampling (see Figure 1-2) Any mate rials tha t cannot be removed in this fashion from this area will remain at their current location Two very large bush ings located adjacent to the TWA III are examples of the types of mat e rlala that will not be removed during this operation
23 Decontaminat ion of Equipment
Following completion of the sc rap removal program decon t arli nation of removal eq uipmen t tracks a nd or tires will be performed a s a preca utionary 11easure to avoid the off-site transport of site-derived soils Decontamtncion will be accomplished in a 25-foot l ong by 20-foot wide nea located near the truck loading pad (designated as the decon area in Fiaure 2-1) The decon area (to be constructed by a dozer) will consist of a sliahtly inclined flat around surface with berr~ed edaes running along the lenath of the s lope This area will be lined with plutic and covered with 34-inch plywood and its ban a 16 x 3 x 4 ( deep) trench (excavated by the backhoe) will serve as a catch- IHnt basin for the decontar~ination water Durinamp use of the decon area each piece of equipcaent will enter the upper portion vhere vehicle trackstires will be washed down of all loose dirt usina a water truck These washinas will drain on the plutic to the containment trench and in this aanner avoid r unoff The equipcHnt will then be loaded directly onto its carrytna flatbed at the loadina pad for off-site transport
Upon copletion of scrap re~Ktval the decon area will be disntled The plastic will be containeriud for s ubampeque nt off-site disposal the plywood wlll be stored within the security fence for possible future use and the aravel will be retained in-place and addrened as part of the total site nuaediation
30 PERSONAL PROTECTION
The 11intmu11 level of personal pro t ec tion thc will be reco-ended to all on-site personnel a nd utilized by Jordan at the F OConnor site durinamp tcrap removal operations will be Level D dermal and respito ry protection The scrap 1s considered be nign taking into account t he history of the operations and pendina Phue 1 sampling results (tee Section 61) work glovu should however be worn to avoid c uts Since the scrap is assumed to be located in a clean trea i n ten11s of soil chemicals and tnnsportion through TWA III will be restricted it is antici pated that the removal of the scrap will not cbulluse atmospheric cont bullllination3in the range of the Threshold Limit Vtue (TLV) for PCBs (05 to 10 mam ) If excessive airborne dust particles 111re produced durinamp scrap removal then wearing of dust mukt will be recofiended aa a precbullutionary meuura (this judgment will be made by the Jordan site safety oHicer)
-8shy
I I I I
ttil (~rII
The Level D persona l protection gear will consist of the following
cotton coveralh Jtee l - toed chemicll resiatl nt boot s hard hat ear protection (optional) cottonluther gloves (when contac t with the scrap is anticipated)
The UCOIIIIM nded level of protection will be upsuded to Leve l C dermal for person ne l who will be involved with larkinamp of fluid-f i lled electrica l equipment The Level C de r1111l personal protection gear conaists of all the items noted for Level D dermbull l except cotton cover1lh 1nd work stoves will be replaced with c hemtc1l ly protective coveralla 1nd inner 1nd outer gloves
Person l decont1minbulltton will consist of diapoaina of bull ny che11tcll-reais t a n t cloth inamp or du s t muka t hbull t bullre worn into phstic aarbbullae bbullampbull for subuque nt stonae on-site in DOT bull pproved 55-ampbullllon drw Boot deconta11in1tion fbullctlitiea (bucketa nd scrub brushea) will be bullvailable aince on-site personnel 11ay h1ve to enter the TWA III 1re1
Add ittonll i nfor-1tion re11rdi n1 Jord1n a hed t h 1nd ufety procedures Cln be fou nd in the at t e Project Operations Plan (POP) June 1986
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS
Followina load t na t he scrap will be transported to bull nd disposed of at a disshypout location that 1a JWtually aareeable to USPA Maine DP and CMP It is proposed that the City o f Auausta Hatch Hill Lbullndfill Auausta Maine located approximately fou r (4) bullilu f r0111 the site be utiliud for d isposal of the scnp Transportation 1 nd diapoul at this site will be handled in the fol lowtna 111 nne r
Two hiamph-wdled 14 or 18 cubic y1rd trucka each haulinamp a max i11un lo1d of 35000 lbs will be utilized to t ransport the scrap to Hatch Hill Landfill Consideri ng the anticipbullted 500 tons of scrap approximbulltely 30 trips to the landfill bullre 1 nt ictpate d The scra p will be covered with canv1s covera 1 nd stabilized aa necessary uainamp ropes tarps e t c
Decontbullnin1 tion of truck tires prior to site dep1rture ha s not been s pecif ied abull trucks dastsnlted for off-site transport will be reatricted to arua known to be cle1n based on Tour I analytical resu l ts
-middotshy
I I I I
Aa a matter of good record keep i ng a bill opound lad i ng will accompany ea ch scrap load Th is doc ument a t i on will be prepand by the r emova l contractor a nd wi ll inc lude
name a nd address of the t ra nsporter or iain o f th e sc ra p c ha rac t e ri s t i c s of the scrap u tbiiA t e d quantity o f the scrap and fi na l disposa l destinat ion
CHP the removal cont rac t or a nd Ha tch Hill Landfi ll will stan the bi ll of lad i ng fo r each l oad The orta i nal wil l be r etaine d i n CHP fi l es copies will be d istr ibuted to Int e res t ed par ties
42 Disposal
Disposa l of the scrap a t Ha tch Hill Landfill will be routine Th e only required perbullit utablishu authorized uae of Hatch Hill Landfill This pershybullit is to be obtained by the contractor fr011 the City of Auausta it speciflu na and loccion of the hauler and reaistration inforMation for each vehicle to be used for scrap delivery to Hatch Hill Landfill
Hatch Hill Landfill hours en libullited to 8 00 a bullbullbull to 400 Pbullbullbullbull Tuesday throuah Friday The scrap will arrive in loads that confom with the specishyfied atoraae piles and areu at tch Hill Landfill Hatch Hill raquiru that electric Mter bodiu arrive uparauly Tires are separated fro Mtal and fluids (such aa tranabulliuion oil) are re~~aved fron autoobile bodies Then f~uida will be collected and disposed of at local oil depository locations
50 SPECIAL HANDLING LOGISTICS
Durinamp the re110val of the scrap from the F OConnor si t e fluid- filled elec trical equipntent bull ay be discovered In ant icipati ng th is occurre nce t his sec tion outlines the i dentification of a nd fiel d l ogist ics conce rn i ng the electr ica l e quip11ent
5 1 Equipment Identif i ca tion
A CHP representat ive will be on-site on a part-time basis to ide ntify a ny scra p t hc is no t considered conve ntion a l aolid waste Fl u id-filled electri shycal eq ui pbullent will re qu ire s pecial consideration due to it a potential PCB conte nt
Upon identification the electrical e qul pbullent will be numbered inventori ed a taaed and left on-site In an undisturbed s tate Underlytna s c rap located adjacent to the fluid-filled electrical equtpr~ent that exh i bits oil stains will also be left In place Personnel will upgrade their level of protection
- 10shy
to Level C dermal (aee Section 30) when marking and working among the fluidshyfilled electrical equ ipment The equipment will be numbered with a paint marker us ing a predetermined numbering system for field designation They will then be logged into the pr oject records which will note
date of discovery fhld designation numbe r location description not a tion of r~anufactulers identification plate evidence of any spill associated with the item
A sraall area around the equipment will be isolated with cones or barrier tape to ensure that this area is not disturbed or trafficked during the removal process as described in Section 20 Subsequent to the completion of the scrap reaval operation the nature and quantity of fluid-filled equipa~ent will be evaluated and an appropriate plan for preferred dispoampition of this terial will be developed The plan will be coordinated aMOng CHP Jordan end the reaulatory aaencies prior to implementationbull
52 Spill Provisions
Thouah the occurrence of spills is not expected durinamp scrap reavt operashytiona at the r OConnor aite provisions for spilh vill ba provided Spill equis-ent will consist of oil sorbent hbrics ha nd tools and containers for disposal of the spill uriah The on-site equipn~ent will include
ten 18 X 18 aorbent pillows tvo rolla of oil sorbent polypropylene four 10-foot lenaths of 5 vide containment bo011 three 55-aallon drun~s for disposal of spill mceriah two hand shove h
This aquipent vill be phced in the vicinity of the acra p reMOvd operations In the event of a apill saturated materials muat be disposed of in compliance vith StateFederal regu lac ions
6 0 SCRAP AREA SOIL SAMPLING PROGRAM
To useaa the presence of c hemicals in aoils located beneath the acrap (ie metal auto-bodies tires and white goods) beyond TWA III a aurhce aoil u11plina proaram will be performed The sampli ng program describinamp the nunshyber and type of umplea to be collected h presented in the follovina para shyaraphs
A bullaximum of tvo compoaite samples will be collected fr011 each of the three designated acrap areas a prell11inary backaround aoil characterhat ion cocshypoampite (Phase I Ullpling) and a post-re110val characterhation composite (Phase II sampllna)
-11shy
I I I I
61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
-12shy
JiR ~~ ( It tl flI
0
The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
-13shy
I I I I
ttil (~rII
The Level D persona l protection gear will consist of the following
cotton coveralh Jtee l - toed chemicll resiatl nt boot s hard hat ear protection (optional) cottonluther gloves (when contac t with the scrap is anticipated)
The UCOIIIIM nded level of protection will be upsuded to Leve l C dermal for person ne l who will be involved with larkinamp of fluid-f i lled electrica l equipment The Level C de r1111l personal protection gear conaists of all the items noted for Level D dermbull l except cotton cover1lh 1nd work stoves will be replaced with c hemtc1l ly protective coveralla 1nd inner 1nd outer gloves
Person l decont1minbulltton will consist of diapoaina of bull ny che11tcll-reais t a n t cloth inamp or du s t muka t hbull t bullre worn into phstic aarbbullae bbullampbull for subuque nt stonae on-site in DOT bull pproved 55-ampbullllon drw Boot deconta11in1tion fbullctlitiea (bucketa nd scrub brushea) will be bullvailable aince on-site personnel 11ay h1ve to enter the TWA III 1re1
Add ittonll i nfor-1tion re11rdi n1 Jord1n a hed t h 1nd ufety procedures Cln be fou nd in the at t e Project Operations Plan (POP) June 1986
40 SCRAP TRANSPORTATIONDISPOSAL LOGISTICS
Followina load t na t he scrap will be transported to bull nd disposed of at a disshypout location that 1a JWtually aareeable to USPA Maine DP and CMP It is proposed that the City o f Auausta Hatch Hill Lbullndfill Auausta Maine located approximately fou r (4) bullilu f r0111 the site be utiliud for d isposal of the scnp Transportation 1 nd diapoul at this site will be handled in the fol lowtna 111 nne r
Two hiamph-wdled 14 or 18 cubic y1rd trucka each haulinamp a max i11un lo1d of 35000 lbs will be utilized to t ransport the scrap to Hatch Hill Landfill Consideri ng the anticipbullted 500 tons of scrap approximbulltely 30 trips to the landfill bullre 1 nt ictpate d The scra p will be covered with canv1s covera 1 nd stabilized aa necessary uainamp ropes tarps e t c
Decontbullnin1 tion of truck tires prior to site dep1rture ha s not been s pecif ied abull trucks dastsnlted for off-site transport will be reatricted to arua known to be cle1n based on Tour I analytical resu l ts
-middotshy
I I I I
Aa a matter of good record keep i ng a bill opound lad i ng will accompany ea ch scrap load Th is doc ument a t i on will be prepand by the r emova l contractor a nd wi ll inc lude
name a nd address of the t ra nsporter or iain o f th e sc ra p c ha rac t e ri s t i c s of the scrap u tbiiA t e d quantity o f the scrap and fi na l disposa l destinat ion
CHP the removal cont rac t or a nd Ha tch Hill Landfi ll will stan the bi ll of lad i ng fo r each l oad The orta i nal wil l be r etaine d i n CHP fi l es copies will be d istr ibuted to Int e res t ed par ties
42 Disposal
Disposa l of the scrap a t Ha tch Hill Landfill will be routine Th e only required perbullit utablishu authorized uae of Hatch Hill Landfill This pershybullit is to be obtained by the contractor fr011 the City of Auausta it speciflu na and loccion of the hauler and reaistration inforMation for each vehicle to be used for scrap delivery to Hatch Hill Landfill
Hatch Hill Landfill hours en libullited to 8 00 a bullbullbull to 400 Pbullbullbullbull Tuesday throuah Friday The scrap will arrive in loads that confom with the specishyfied atoraae piles and areu at tch Hill Landfill Hatch Hill raquiru that electric Mter bodiu arrive uparauly Tires are separated fro Mtal and fluids (such aa tranabulliuion oil) are re~~aved fron autoobile bodies Then f~uida will be collected and disposed of at local oil depository locations
50 SPECIAL HANDLING LOGISTICS
Durinamp the re110val of the scrap from the F OConnor si t e fluid- filled elec trical equipntent bull ay be discovered In ant icipati ng th is occurre nce t his sec tion outlines the i dentification of a nd fiel d l ogist ics conce rn i ng the electr ica l e quip11ent
5 1 Equipment Identif i ca tion
A CHP representat ive will be on-site on a part-time basis to ide ntify a ny scra p t hc is no t considered conve ntion a l aolid waste Fl u id-filled electri shycal eq ui pbullent will re qu ire s pecial consideration due to it a potential PCB conte nt
Upon identification the electrical e qul pbullent will be numbered inventori ed a taaed and left on-site In an undisturbed s tate Underlytna s c rap located adjacent to the fluid-filled electrical equtpr~ent that exh i bits oil stains will also be left In place Personnel will upgrade their level of protection
- 10shy
to Level C dermal (aee Section 30) when marking and working among the fluidshyfilled electrical equ ipment The equipment will be numbered with a paint marker us ing a predetermined numbering system for field designation They will then be logged into the pr oject records which will note
date of discovery fhld designation numbe r location description not a tion of r~anufactulers identification plate evidence of any spill associated with the item
A sraall area around the equipment will be isolated with cones or barrier tape to ensure that this area is not disturbed or trafficked during the removal process as described in Section 20 Subsequent to the completion of the scrap reaval operation the nature and quantity of fluid-filled equipa~ent will be evaluated and an appropriate plan for preferred dispoampition of this terial will be developed The plan will be coordinated aMOng CHP Jordan end the reaulatory aaencies prior to implementationbull
52 Spill Provisions
Thouah the occurrence of spills is not expected durinamp scrap reavt operashytiona at the r OConnor aite provisions for spilh vill ba provided Spill equis-ent will consist of oil sorbent hbrics ha nd tools and containers for disposal of the spill uriah The on-site equipn~ent will include
ten 18 X 18 aorbent pillows tvo rolla of oil sorbent polypropylene four 10-foot lenaths of 5 vide containment bo011 three 55-aallon drun~s for disposal of spill mceriah two hand shove h
This aquipent vill be phced in the vicinity of the acra p reMOvd operations In the event of a apill saturated materials muat be disposed of in compliance vith StateFederal regu lac ions
6 0 SCRAP AREA SOIL SAMPLING PROGRAM
To useaa the presence of c hemicals in aoils located beneath the acrap (ie metal auto-bodies tires and white goods) beyond TWA III a aurhce aoil u11plina proaram will be performed The sampli ng program describinamp the nunshyber and type of umplea to be collected h presented in the follovina para shyaraphs
A bullaximum of tvo compoaite samples will be collected fr011 each of the three designated acrap areas a prell11inary backaround aoil characterhat ion cocshypoampite (Phase I Ullpling) and a post-re110val characterhation composite (Phase II sampllna)
-11shy
I I I I
61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
-12shy
JiR ~~ ( It tl flI
0
The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
-13shy
I I I I
Aa a matter of good record keep i ng a bill opound lad i ng will accompany ea ch scrap load Th is doc ument a t i on will be prepand by the r emova l contractor a nd wi ll inc lude
name a nd address of the t ra nsporter or iain o f th e sc ra p c ha rac t e ri s t i c s of the scrap u tbiiA t e d quantity o f the scrap and fi na l disposa l destinat ion
CHP the removal cont rac t or a nd Ha tch Hill Landfi ll will stan the bi ll of lad i ng fo r each l oad The orta i nal wil l be r etaine d i n CHP fi l es copies will be d istr ibuted to Int e res t ed par ties
42 Disposal
Disposa l of the scrap a t Ha tch Hill Landfill will be routine Th e only required perbullit utablishu authorized uae of Hatch Hill Landfill This pershybullit is to be obtained by the contractor fr011 the City of Auausta it speciflu na and loccion of the hauler and reaistration inforMation for each vehicle to be used for scrap delivery to Hatch Hill Landfill
Hatch Hill Landfill hours en libullited to 8 00 a bullbullbull to 400 Pbullbullbullbull Tuesday throuah Friday The scrap will arrive in loads that confom with the specishyfied atoraae piles and areu at tch Hill Landfill Hatch Hill raquiru that electric Mter bodiu arrive uparauly Tires are separated fro Mtal and fluids (such aa tranabulliuion oil) are re~~aved fron autoobile bodies Then f~uida will be collected and disposed of at local oil depository locations
50 SPECIAL HANDLING LOGISTICS
Durinamp the re110val of the scrap from the F OConnor si t e fluid- filled elec trical equipntent bull ay be discovered In ant icipati ng th is occurre nce t his sec tion outlines the i dentification of a nd fiel d l ogist ics conce rn i ng the electr ica l e quip11ent
5 1 Equipment Identif i ca tion
A CHP representat ive will be on-site on a part-time basis to ide ntify a ny scra p t hc is no t considered conve ntion a l aolid waste Fl u id-filled electri shycal eq ui pbullent will re qu ire s pecial consideration due to it a potential PCB conte nt
Upon identification the electrical e qul pbullent will be numbered inventori ed a taaed and left on-site In an undisturbed s tate Underlytna s c rap located adjacent to the fluid-filled electrical equtpr~ent that exh i bits oil stains will also be left In place Personnel will upgrade their level of protection
- 10shy
to Level C dermal (aee Section 30) when marking and working among the fluidshyfilled electrical equ ipment The equipment will be numbered with a paint marker us ing a predetermined numbering system for field designation They will then be logged into the pr oject records which will note
date of discovery fhld designation numbe r location description not a tion of r~anufactulers identification plate evidence of any spill associated with the item
A sraall area around the equipment will be isolated with cones or barrier tape to ensure that this area is not disturbed or trafficked during the removal process as described in Section 20 Subsequent to the completion of the scrap reaval operation the nature and quantity of fluid-filled equipa~ent will be evaluated and an appropriate plan for preferred dispoampition of this terial will be developed The plan will be coordinated aMOng CHP Jordan end the reaulatory aaencies prior to implementationbull
52 Spill Provisions
Thouah the occurrence of spills is not expected durinamp scrap reavt operashytiona at the r OConnor aite provisions for spilh vill ba provided Spill equis-ent will consist of oil sorbent hbrics ha nd tools and containers for disposal of the spill uriah The on-site equipn~ent will include
ten 18 X 18 aorbent pillows tvo rolla of oil sorbent polypropylene four 10-foot lenaths of 5 vide containment bo011 three 55-aallon drun~s for disposal of spill mceriah two hand shove h
This aquipent vill be phced in the vicinity of the acra p reMOvd operations In the event of a apill saturated materials muat be disposed of in compliance vith StateFederal regu lac ions
6 0 SCRAP AREA SOIL SAMPLING PROGRAM
To useaa the presence of c hemicals in aoils located beneath the acrap (ie metal auto-bodies tires and white goods) beyond TWA III a aurhce aoil u11plina proaram will be performed The sampli ng program describinamp the nunshyber and type of umplea to be collected h presented in the follovina para shyaraphs
A bullaximum of tvo compoaite samples will be collected fr011 each of the three designated acrap areas a prell11inary backaround aoil characterhat ion cocshypoampite (Phase I Ullpling) and a post-re110val characterhation composite (Phase II sampllna)
-11shy
I I I I
61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
-12shy
JiR ~~ ( It tl flI
0
The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
-13shy
to Level C dermal (aee Section 30) when marking and working among the fluidshyfilled electrical equ ipment The equipment will be numbered with a paint marker us ing a predetermined numbering system for field designation They will then be logged into the pr oject records which will note
date of discovery fhld designation numbe r location description not a tion of r~anufactulers identification plate evidence of any spill associated with the item
A sraall area around the equipment will be isolated with cones or barrier tape to ensure that this area is not disturbed or trafficked during the removal process as described in Section 20 Subsequent to the completion of the scrap reaval operation the nature and quantity of fluid-filled equipa~ent will be evaluated and an appropriate plan for preferred dispoampition of this terial will be developed The plan will be coordinated aMOng CHP Jordan end the reaulatory aaencies prior to implementationbull
52 Spill Provisions
Thouah the occurrence of spills is not expected durinamp scrap reavt operashytiona at the r OConnor aite provisions for spilh vill ba provided Spill equis-ent will consist of oil sorbent hbrics ha nd tools and containers for disposal of the spill uriah The on-site equipn~ent will include
ten 18 X 18 aorbent pillows tvo rolla of oil sorbent polypropylene four 10-foot lenaths of 5 vide containment bo011 three 55-aallon drun~s for disposal of spill mceriah two hand shove h
This aquipent vill be phced in the vicinity of the acra p reMOvd operations In the event of a apill saturated materials muat be disposed of in compliance vith StateFederal regu lac ions
6 0 SCRAP AREA SOIL SAMPLING PROGRAM
To useaa the presence of c hemicals in aoils located beneath the acrap (ie metal auto-bodies tires and white goods) beyond TWA III a aurhce aoil u11plina proaram will be performed The sampli ng program describinamp the nunshyber and type of umplea to be collected h presented in the follovina para shyaraphs
A bullaximum of tvo compoaite samples will be collected fr011 each of the three designated acrap areas a prell11inary backaround aoil characterhat ion cocshypoampite (Phase I Ullpling) and a post-re110val characterhation composite (Phase II sampllna)
-11shy
I I I I
61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
-12shy
JiR ~~ ( It tl flI
0
The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
-13shy
I I I I
61 Phase 1 Ssmp lina
The ba ckground sot 1 composite aample will be comprised of natural-appearing soih (ie no stdns or oils) collected poundrom the sample points shown on figure 1-2 Th e purpose of these samples is to ensure that the scrap areas do not exhibit evidence of transformer recycling operations Each background composite sample will be analyzed by the CLP for HSL andytes (organiesinorshyganics including PCBs) to fully characterize the soih tn these areas If leampUlts of Phase 1 sampling indicate significant concentrations of PCBs andor other chemicals scrap removal logistics may have to ba modified
62 Phue 11 Samplinamp
The post-nmoval composite sample will consist of discrete samples of oilshystained soils that may be associated with fluid-filled e l ectrical equipment that are identified during the leraoval proce1s These corapositu s hould detect point sources of contamination within eac h scrap area and will be collected following movement of the equipn~ent upon storaae or disposal In the event that electric equipment and related stained soils are not observed in a desianated area this second cocaposite uaple will not be collected Should a coaposite UIIIJ) l e be collected in an area it will be analyzed for HSL oraanics only as the primary chemicals of concern are the PCBs PAHs and c hlorinated benzenes
7 0 SCHEDULE
The collection and analysis of soil naples and scrap r-oval operations bullbull~ampp lu are the primary event s requlrina schedulina durina the scrap ren10val proarabull lackaround samples from the three de s ianated 1crap areu (Phase 1 uaplina) were collected and submitted for anllylis on June 19 1987 Pendina receipt a nd results of these analyses (estimated turnaround time 4 to 5 weeks) scrap nmoval operations will commence at the site as described in the previous sections
Tentative start date for the removal progra111 is Monday Auaust 3 1987 On that dce all interested parties will convene at the site for a kick-off meetins to review operation loshtics and health and safety p-otocoh followins the meetins the heavy equipment contractor will begin field work by completing the access road upgrade and constructi ns the loadins pbulld Actual scrap removbulll operations will corm~ence on Tuesday Auaust 4 1987 at 700 a111 and will continue through to the completion of the project A typical workday will be 730 an to 430pm Tuesday through friday coinciding with Hatch Hill Landfills operatina hours Estimated completion time is two weeks
Followins scrbullp removal the post-rentOval characterization composite samples (Phue 11 samplina) will be collected as necessary and submitted for analyshysts The results of these analyses will be included in the Tour II data packshyage to be submitted to the USEPA and the Hdne OEP
-12shy
JiR ~~ ( It tl flI
0
The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
-13shy
0
The tentative schedule is iterlized below
June 19 1987 Phase 1 Samplina backaround conpoaites July 1 1987 De l ivery of Scrap Area Loahtlca Plan to
USEPAHaine DEP July 17 1987 Raceipt of Phue 1 uaplins results (nust be
nondetect for PCBa) August 3 1987 Kick-off uet ing and acrap area acceu road
upsrade August 4 1987 Scrap re1110val operationbull COIdence August 15 1987 Scrap re1110val operation complete
-13shy