Site: Break' o Other: GEI Consultants, Inc. · A Source Control (SC) Pilot-Scale Treatability Study will be performed by GEI Consultants, Inc. (OBI) at the O'Connor Superfund Site

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

SOURCE CONTROL

PILOT-SCALE PROJECT OPERATIONS PLAN

VOLUME I OF ffl

Site Management and Community Relations Support Plan O'Connor Site Augusta, Maine

Submitted by GEI Consultants, Inc.

f\j.—^ Joanne O. Morin Project Manager

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

Document SC Pilot-Scale POP, Vol. I Revision 1

Date June 19, 1992

EXECUTIVE SUMMARY

A Source Control (SC) Pilot-Scale Treatability Study will be performed by GEIConsultants, Inc. (OBI) at the O'Connor Superfund Site (Site) in Augusta, Maine for Central Maine Power Company (CMP) of Augusta, Maine. This work will be the second phase of the Source Control Pre-Design activities as described in the Site Statement of Work (SOW) for Remedial Design/Remedial Action (RD/RA). Pilot-Scale activities are described in the SC Pilot-Scale Treatability Study Work Plan, submitted as a separate document for the United States Environmental Protection Agency (EPA) review. The SOW was included as a provision of the Consent Decree between the United States of America and Central Maine Power Company (CMP), which was entered on September 3, 1991.

Prior to performing SC Pilot-Scale activities at the Site, the SOW requires that site-specific work plans be generated to establish procedures to be followed in performing the field, laboratory and analysis work, and community and agency liaison activities. These work plans are combined to form the Site Project Operations Plan (POP) and are provided in this document. The four components of the POP are:

Site Management Plan (SMP) Volume I Community Relations Support Plan (CRSP) Volume I Sampling and Analysis Plan (SAP) Volume II and III Health and Safety Plan (HSP) Appendix of Volume II

The POP is presented in three separate volumes. Volume I contains the SMP and CRSP. Volumes II and III contain the SAP. The SAP contains the Field Sampling Plan (Volume II), the HSP is included as an appendix of the Field Sampling Plan, and the Quality Assurance Project Plan (Volume III).

The purpose of the SMP is to describe how the various SC Pilot-Scale project aspects such as access, security, site control, management responsibilities, waste disposal, budgeting, and data handling will be managed. The SMP defines the hierarchy of communication and reporting between GEI field engineers and geologists, GEI project management, CMP project coordinator, CF Systems Corporation (CF Systems), and EPA and Maine Department of Environmental Protection (DEP) representatives, to ensure that information regarding on-site activities is effectively transmitted. The SMP also specifies an organized plan of site control/site access, and provides contingency planning.

The purpose of the CRSP is to ensure and specify adequate support for the community relations efforts of the EPA. The CRSP shall support the community relations plan (CRP) for the Site to be developed by the EPA.


Date June 19, 1992

The Field Sampling Plan describes the sampling and data gathering procedures for field activities. The Quality Assurance Project Plan describes the site-specificobjectives, policies, organizations, functional activities, and specific Quality Control/Quality Assurance procedures needed to achieve the data quality objectives of the SC Pilot-Scale studies. The HSP describes health and safety protocols that will be followed during Pilot-Scale field activities.

Document SC Pilot-Scale POP, Vol. I

TABLE OF CONTENTS

EXECUTIVE SUMMARY TABLE OF CONTENTS LIST OF TABLES LIST OF FIGURES

1. INTRODUCTION 1.1 Site Description and Background 1.2 Summary of EPA-Seleeted Remedy 1.3 Previous Pre-Design Investigations

2. SITE MANAGEMENT PLAN (SMP) 2.1 SC Pilot-Scale Activities 2.2 Communications and Key Personnel

2.2.1 Project Personnel 2.2.2 Endangerment and Response 2.2.3 Reporting

2.3 Site Control 2.3.1 Access 2.3.2 Site Management and Security 2.3.3 Air Monitoring 2.3.4 Waste Disposal 2.3.5 On-Site Waste Storage

2.4. Data Handling

3. COMMUNITY RELATIONS SUPPORT PLAN (CRSP) 3.1 Introduction 3.2 Previous Community Relations Activities 3.3 Community Relations Objectives 3.4 Anticipated Community Relations Support Activities

TABLES FIGURES

Revision 1 Date June 19, 1992

Page No.

1 1 2 3

6 6 7 7

11 12 13 13 13 16 17 18 19

20 20 20 21 22


Date June 19, 1992

LIST OF TABLES

1 - Waste Generation

LIST OF FIGURES

1 - Site Location 2 - Location of Transformer Work Areas and Swales 3 - Site Work Zones


Date June 19, 1992 Page 1

1. INTRODUCTION

1.1 Site Description and Background

The O'Connor Superfund Site (Site) is located along U.S. Route 17 near the eastern boundary of the city limits of Augusta, Maine (Figure 1). The Site covers approximately nine acres within a larger 65-acre parcel. The Site is currently surrounded by a chain-link fence, and is abutted by woodlands to the north and west, U.S. Route 17 to the south, and the west branch of Riggs Brook and its associated wetlands to the east. The Site is situated on the crest of a low ridge which is aligned northeasterly and parallel to Riggs Brook.

Principal features on the property include a large barn that formerly housed scrap operations, an Upland Marsh, an adjacent "low area" of fill, two surface water impoundments (Upper and Lower Lagoons), three former outdoor transformer work areas (TWAs) and a former scrap area (Figure 2). Site drainage is principally controlled by the slope extending eastward from the crest of the ridge toward Riggs Brook, and man-made drainage features connecting the Upland Marsh on the top of the ridge to Riggs Brook. Currently, the Upper and Lower Lagoons located on the slope leading down to Riggs Brook serve as detention basins for surface water flow from the Upland Marsh. The Upland Marsh drains to the Upper Lagoon via a subsurface drainage pipe. The Upper Lagoon drains to the Lower Lagoon via a drainage swale. The water that flows out of the Lower Lagoon follows a drainage swale to Riggs Brook.

The Site was primarily used as grazing land until the 1950s when the F.O'Connor Co.started a salvage and transformer recycling business. The salvage processes included stripping and recycling transformers that contained polychlorinated biphenyl (PCB)-laden oils. As a result of the uncontrolled releases of PCBs at the Site, the Site was placed on the National Priorities List. On March 23, 1985, the United States Environmental Protection Agency (EPA) and Maine Department of Environmental Protection (DEP) issued an Administrative Order to the O'Connor Company and Central Maine Power Company (CMP) (Docket No. 1-86-1031) identifying each as a Potentially Responsible Party.

Much of the large surface debris has been removed as a result of initial remedial measures. In 1986 and 1987, a remedial investigation was performed by E.C. Jordan Co. for CMP. These investigations included collecting over500 soil samples, installing 11monitoring wells, and performing analyses of surface water, ground water, sediment, and biota for PCBs, organic and inorganic chemicals. The primary contaminants detected in soil and sediments at the Site were PCBs, polynuclear aromatic hydrocarbons (PAHs), and lead. Chlorinated benzenes, PCBs, phthalates (plastizers) and to a lesser extent volatile organics and metals were detected in ground water, and PCBs and metals were detected in surface water.



1.2 Summary of EPA-Selected Remedy

The Record of Decision (ROD) developed by EPA for the Site includes a Source Control (SC) Remedy and a Management of Migration (MOM) Remedy. The SC Remedy involves treatment with solvent extraction technology of contaminated soil, debris, sediments and surface water to remove sources of PCBs, lead and cPAHs contamination. Additional information on level and extent of soil, water and sediment contamination is provided in the October 1991 SC Pre-Design Sampling Report.

EPA stated in the ROD that contaminated soil and sediment containing PCBs, cPAHs, and lead above cleanup standards are to be excavated and treated on-site using a solvent extraction technology. Cleanup standards for PCBs, cPAHs and lead in soil and sediment are identified in the ROD to be 1 parts per million (ppm), 1 ppm, and 248 ppm, respectively. Excavated material will need to be segregated and/or screened to separate cobbles and metal debris greater than 1-inch in diameter. The cobbles and debris may be crushed and treated with solvent extraction or may be decontaminated, if necessary, and disposed off-site. Dewatering will be necessary to excavate contaminated soil located below ground water.

Surface water from the Upland Marsh, Upper Lagoon and Lower Lagoon will be pumped as necessary to excavate contaminated sediments. Water contaminated with hazardous substances will be disposed off-site at a permitted facility unless otherwise instructed by EPA. Cleanup standards for surface water are 0.065 parts per billion (ppb) for PCBs, 87 ppb for aluminum, and 1.94 ppb for lead.

Contaminated liquids produced during solvent extraction treatment that contain extracted PCBs and cPAHs will be destroyed off-site at a licensed Toxic Substance Control Act (TSCA) incinerator. Soil treatment residues resulting from the solvent extraction process that contain lead concentrations above the 248 ppm cleanup standard will be transported off-site to a licensed landfill. If lead concentrations in soil exceeding the cleanup standard also exceed the toxicity characteristic concentration for lead resulting in classification as a hazardous waste (5 ppm), lead contaminated soil will undergo further treatment using a solidification/stabilization treatment technology.

The ROD specifies decontamination and demolition of the on-site barn. The barn would undergo decontamination procedures if contamination was present above cleanup standards (to be specified later by EPA) through collection of soil, dust and other loose material. These materials would be combined with the other contaminated soils and sediments for on-site solvent extraction treatment. Large scrap items in the barn would be removed for disposal off-site or decontamination and the barn structure would be sampled to detect the presence of contamination. Following sampling and analysis of the barn structure, the barn would be demolished and transported to an off-site facility for appropriate disposal.



13 Previous Pre-Design Investigations

Pre-Design SC sampling included:

• Collection of 122 soil samples from test pits and borings in June 1991.

• Collection of 15 sediment samples from the Upland Marsh and Upper and Lower Lagoons in June and July 1991.

• Collection of ten surface water samples from the Upland Marsh and Upper and Lower Lagoons in June 1991.

• Collection of 36 samples of soil, wood and concrete from the on-site barn floor and walls, and wipe samples from debris and equipment located within the barn in June 1991.

Based on Pre-Design sampling results, 17,500 cy of soil and sediments were estimated to contain greater than 1ppm PCBs. Using the assumption of 50 percent over-excavation and 20 percent for soil expansion, the total volume of soil and sediment requiring remediation is 31,500 cy compared to 23,500 cy calculated in the ROD.

No additional data were collected that contradict the conclusions in the Remedial Investigation (RI) that the distribution of PAHs seemed to be limited to the TWAs and "low area." Based on the data collected during Pre-Design and RI studies, concentrations of cPAHs in soil predominantly ranged between 1and 10 ppm. However, one sample collected during Pre-Design studies contained 139 ppm cPAHs exceeding the maximum cPAH concentration of 30 ppm defected during the RI.

The data collected during Pre-Design Studies agreed well with the distribution of lead presented in the RI. Concentrations of lead exceeding cleanup standards were predominantly found in the top foot of soil in TWA I, TWA II, and the "low area."

Based on Pre-Design sampling results, 550 to 600 cy of sediments from the Upland Marsh, Upper Lagoon and Lower Lagoonwere estimated to contain concentrations of PCBs greater than 1 ppm, compared to 384 cy of sediments estimated in the FS. Approximately 85 percent of these sediments contained PCBs greater than 10 ppm. These sediments represent 3.4 percent of the 17,500 cy of soil and sediment containing PCBs greater than 1 ppm. Using the assumptions of 50 percent for over-excavation and 20 percent for expansion, the approximate volume of sediments with PCB concentrations exceeding 1 ppm is 1,000 cy.



The cleanup standard of 0.065 ppb for PCBs was exceeded in all three surface water bodies during Pre-Design Studies. The highest levels of PCB contamination in surface water were found in the Upper Lagoon, lower levels were present in the Lower Lagoon, and the lowest levels were found in the Upland Marsh. This pattern of distribution correlates with the distribution of contaminated sediments.

The cleanup standard of 87 ppb for aluminum was exceeded in all three surface water bodies during Pre-Design Studies. The cleanup standard of 1.94 ppb for lead was exceeded only in the Upland Marsh and Lower Lagoon during Pre-Design Studies, but was exceeded in all three surface water bodies during the RI.

Concentrations of PCBs in concrete* dust and wood samples from within the barn did not exceed the current Maine Department of Environmental Protection and TSCA regulatory limit of 50 ppm for disposal in non-hazardous/non-TSCA waste landfills. Only one wipe sample from the top of a stove contained concentrations of PCBs exceeding the cleanup levels of 10 Mg/100 square centimeter (cm2) for high contact solid surfaces established by the TSCA Maximum concentrations of lead in concrete, dust, and wood samples were 963 ppm, 43,400 ppm, and 90.5 ppm, respectively.

The following investigations were also performed to provide data for design of the components of the SC Remedy:

• Bench-scale treatability studies were performed with two solvent extraction technologies to examine whether solvent extraction can achieve the cleanup standards of 1 ppm for PCBs and cPAHs.

• The extent of wetlands on-site were delineated and assessed in terms of their current functional values.

° Elements of surface water control including diversion of surface runoff, pumping of surface water and surface water treatment were evaluated.

• Soil and sediment excavation and dewatering techniques were identified.

• Debris handling and screening techniques necessary to satisfy the solvent extraction 1-inch maximum size requirement was examined. Debris washing systems were also evaluated.

• A quantitative risk assessment was performed to examine short-term exposure risks to off-site receptors from remedial activities. The results of the risk assessment were used to develop an air monitoring program to protect on-site workers.



During Pre-Design Studies, bench-scale treatability testing of two solvent extraction technologies indicated difficulty in achieving cleanup standards in soil and sediment with PCB concentrations greater than 100 ppm. Testing also indicated difficulty in reducing cPAHs to below the cleanup standard. Since Pre-Design sampling encountered ePAH contamination exceeding the maximum concentration detected during the RJ, cPAH contamination may be more significant than previously indicated. Increased emphasis on evaluation of ePAH removal efficiency is needed during pilot-scale testing.

Based on data obtained from Pre-Design studies on the quantity of soil and sediment contaminated above the cleanup standard and the results of bench-scale testing, it was estimated that 11,000 cy of soil and sediment may fail to achieve a cleanup standard of 1 ppm.

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



2. SITE MANAGEMENT PLAN (SMP)

2.1 SC Pilot-Scale Activities

SC Pilot-Scale activities will be performed as part of the Pre-Design phase of studies at the Site. Pilot-Scale activities are designed to collect data that will be used to develop full-scale design and operational parameters for the materials pre-processing and solvent extraction treatment systems. SC Pilot-Scale studies will include: materials excavation and handling, soil and sediment treatability testing and debris washing operations. Specific field activities are described below.

Materials Excavation and Handling

Materials excavation and handling activities are designed to evaluate the ability of readily available equipment to excavate on-site materials and separate the debris and rocks greater than 1-inch diameter from the fine grained silts and clays. Major elements of this phase of work include:

• Excavating areas where desired concentration ranges of contaminants and geologic materials for pilot-scale treatability testing exist;

• Collecting samples from the excavated materials for analytical screening and laboratory analyses to verify that desired contaminant concentrations were obtained;

• Manually separating debris greater than 4-inch diameter from the excavated materials;

• Sieving the excavated materials through a vibrating screen to obtain uniform materials less than 1-inch in diameter; and,

• Storing sieved feedstock in labeled drums adjacent to the pilot testing solvent extraction treatment unit.

Soil and Sediment Treatability Testing

Treatability testing will be performed to evaluate the ability of solvent extraction to treat contaminated soil and sediment to the cleanup standards. Testing will be performed by CF Systems in their mobile demonstration treatment unit (MDU). CF Systems will subcontract Chemfix Environmental Services, Inc. (Chemfix) to perform solidification/stabilization testing on-site in pilot-scale equipment. Major elements of this phase of work include:



• Homogenizing feedstock with a pug mill;

0 Sampling and analysis of homogenized feedstock to evaluate pretreatment contaminant concentrations;

• Treatment of homogenized feedstock with solvent extraction technology to remove organic contaminants;

• Stabilization of treated fill having lead concentrations above 1000 ppm; and

• Laboratory analyses to evaluate the removal efficiency of the treatment system.

Debris Washing

Debris washing is designed to reduce PCB contamination on large-diameter, uncrushable pieces of metal, wire cable and other non-porous materials to allow their disposal in a local landfill. Major elements of this phase of work include:

• Separating uncrushable debris from excavated fill soil both manually and with sieving;

• Washing the debris on a leachate collection pad using a high-pressure steam cleaner; and,

Collecting representative wipe samples of debris to evaluate the decontamination method.

Wipe samples will also be collected from debris located in areas outside the extent of contaminated soil and sediment to evaluate whether decontamination of this debris will be needed.

22 Communications and Key Personnel

2.2.1 Project Personnel

The following are key individuals and parties that will be involved in various roles during the Pilot-Scale studies:

• Ross Gilleland, United States Environmental Protection Agency Regional Project Manager (RPM)



Allen J. Bingham, Maine Department of Environmental Protection State Project Coordinator

Charles R. Nickerson, Central Maine Power Company Project Coordinator

Joanne O. Morin, GEI Consultants, Inc.

John Markiewicz (William McGovern, Alternate) CF Systems Corporation MDU Manager

Sam Pizzitola, Chemfix Environmental Services, Inc. Solidification/Stabilization Subcontractor

Wes Miller, NET Atlantic, Inc. Analytical Laboratory

Charles R. Weeks, Northland Management Services Excavation and Site Preparation Subcontractor

John Margian, Aptus Waste Disposal Subcontractor

As the Supervising Contractor, GEI will be responsible for management of the Pilot-Scale studies and performance of the field activities and analyses.

The following GEI personnel will be assigned to this project:

PERSONNEL RESPONSIBII ITTF.S

Joanne O. Morin Project Manager Richard F. Murdock Quality Assurance Officer Ian Phillips Fre-Design StadlesiManager Benjamin Y. Su Treatability Studies Manager Boyd P. Smith SC Pilot-Scale On-Site Project Coordinator Thomas S. Bobowski Field Personnel Christopher L. Covel Field Personnel William J. Haswell Field Personnel Robert Forsberg Field Personnel Joanne McLaughlin Field Personnel



Mike Yako Field Personnel Charles Blodgett Analytical Field Screening

The GEI On-Site Project Coordinator will coordinate and manage all field investigations, and will report progress on a daily basis to the Prqject Manager. GEI's Project Manager will regularly update the CMP Project Coordinator of the progress of work and will notify the Project Coordinator if special communications are needed with EPA and DEP. The Project Coordinator will communicate directly with the EPA RPM regarding site activities, unusual conditions, or unforeseen events.

The key individuals and their specific responsibilities in regard to SC Pilot-Scale activities are listed below:

Charles R. Nickerson Central Maine Power Company

Project Coordinator.

Key contact for communications with EPA and DEP.

Authorizes work to be performed by Supervising Contractor (GEI).

Review all work plans, memoranda and reports received from GEI for compliance with study objectives, clarity and completeness prior to submittal to the EPA Remedial Project Manager.

Ensure that requirements of Consent Decree are met.

loamte D> GEI Consultants, Inc.

Supervising Contractor key contact.

Overall technical responsibility for project; reports to Charles R. Nickerson, Project Coordinator.

Review all work plans, memoranda, and reports prepared by GEI and GEI's subcontractors for compliance with study objectives, technical adequacy, clarity, and completeness, prior to submittal to Project Coordinator.

Ensure that project budget and schedule are met.



Ensure that supervising contractor resources are available for project needs.

Monitor task activities to ensure compliance with study objectives and scope of work.

GEI Consultants, Inc.

• Prepare or review preparation of work plans, memoranda, and reports.

• Ensure that field personnel are adequately trained and understand work plan objectives.

• Ensure that work is carried out according to the provisions and methodologies in the Sampling and Analysis Plan.

• Ensure that ongoing quality control procedures are followed during performance of work.

• Supervise data reduction, validation, and reporting.

• Report to Joanne Q. Morin, Project Manager, on all technical and administrative aspects of project status.

Richard F. Murdock, Quality Assurance Officer GEI Consultants, Inc.

• Independent review of major deliverablesfor clarity, completeness, and conformance to project requirements.

• Training of Quality Assurance/Quality Control (QA/QC) inspection personnel on project Quality Assurance (QA) requirements and procedures.

• Scheduling, coordinating, and performance of QA inspections and audits to assess compliance with the project requirements and specifications.

• Verification that all activities are implemented in accordance with the Quality Assurance Project Plan (QAPP).



• Reporting results of all inspections to the Project Manager who will in turn report to the Project Coordinator. Reports will indicate if the work is of acceptable quality or fails to meet the specified project requirements.

Benjamin Y. Su, Treatability Studies Manager GEI Consultants, Inc.

• Review all treatability testing work plans, memoranda, and reports for compliance with study objectives, clarity and completeness.

0 Perform audits of subcontracted treatability study programs.

• Evaluate ground water treatability study results.

Boyd P. Smith, SC Pilot-Scale On-Site Project Coordinator GEI Consultants, Inc.

• Prepare portions of Pilot-Scale work plans, memoranda, and reports.

• Ensure field personnel understand all aspects of the SC Field Sampling Plan and Health and Safety Plan.

• Supervise all SC field activities including equipment preparation, sampling activities, documentation, and sample custody.

• Serve as Health and Safety Officer during all SC field activities.

• Maintain on-site communications between CF Systems and GEI personnel.

• Report to the Pre-Design Studies Manager daily during all field activities.

2.2.2 Endangerment and Response

If any field activity causes or threatens to cause a release of waste material at or from the Site, or presents an endangerment to public health or welfare or the environment, GEI shall promptly take all appropriate action to prevent, abate, or minimize such release or endangerment and shall immediately notify the CMP Project Coordinator. The CMP Project Coordinator shall immediately notify the EPA RPM, the EPA Emergency Response Unit - Region I, the State Project



Coordinator, and the local fire department. The GEI Oa-SIte Pfoject Coordinator shall take such action in accordance with all applicable provisions of the HSP. CMP, with assistance from GEI, shall develop and submit a response plan to EPA and the State within ten (10) days, or as soon thereafter as is practicable, in accordance with Section XVII, Paragraph 53 of the Consent Decree. If necessary, local residential notification of endangerment will be performed by the local fire and police departments. CMP will notify local residents of a potential problem by calling the Dispatch Center for the Department of Public Safety.

223 Reporting

CMP will submit to EPA a SC Pilot-Scale Treatability Study Report. This report will be submitted within one-hundred-eighty-niae <189) days of receiving notification of approval or EPA modification of the SC Pilot-Scale Treatability Study Work Plan. This report will include a description of methodologies, and analysis of results and conclusions developed from the materials excavation and handling, soil treatability testing and debris washing undertaken in accordance with the Work Plan. Nine unbound and one bound copy of the report will be submitted to EPA Four unbound and one bound copy will be submitted to the DEP.

CMP will submit to EPA ten copies of the written monthly progress reports which: (a) describe the actions which have been taken toward achieving compliance with the Consent Decree during the previous month; (b) include summary results of sampling and tests and all other data generated in the previous month; (c) include descriptions of all plans and procedures completed under the Pilot-Scale Work Plan during the previous month; (d) describe all actions, data gathering and plans which are scheduled for the next month and provide any other information relating to the progress of construction that is necessary to assess compliance under the Consent Decree; and (e) include information regarding percentage of completion, unresolved delays encountered or anticipated that may affect the future schedule for implementation of the SOW or any of the Work Plans, and a description of efforts made to mitigate those delays or anticipated delays. CMP will submit to DEP three copies of the written monthly progress reports. Monthly progress reports are to be submitted to EPA and the State by the fifteenth day of every month following the date of the lodging of the Consent Decree until EPA certifies Completion of the Work.

To the extent Section 103 of CERCLA, 42 U.S.C. §11004, requires reporting of emergency information or events to the National Response Center and as required in Section XI of the Consent Decree, the CMP Project Coordinator shall verbally notify the EPA RPM or the EPA Geographic Section Chief and the State project Coordinator of such information or events. If the EPA RPM and the EPA



Geographic Section Chief are not available, the Project Coordinator shall notify the EPA Emergency Response Unit - Region I, and the State Project Coordinator. These notifications will be made in addition to the reporting required by Section 103 of CERCLA and Section 304 of the Emergency Planning and Community Right-To-Know Act (EPCRA). Within twenty days of the onset of such an event, CMP shall furnish to the EPA a written report setting forth the events which occurred and the measures taken, and to be taken, in response thereto. Within thirty (30) days of the conclusion of such an event, CMP shall submit a report setting forth all actions taken to respond thereto.

CMP, with the assistance of GEI, will submit each year, within thirty (30) days of the anniversary of the entry of the Consent Decree, a report to the Court and the Parties setting forth the status of response actions at the Site, which shall, at a minimum, include a statement of major milestones accomplished in the preceding year, a statement of tasks remaining to be accomplished, and providing a schedule for implementation of the remaining work. The report will include a summary of CMP's financial expenditures on the RD/RA activities to date.

23 Site Control

23.1 Access

The SC Pilot-Scale field work will be performed on property owned by CMP. No private property access will be necessary during SC Pilot-Scale field activities.

232 Site Management and Security

Zones will be established on the Site to distinguish areas where potential exposure of personnel to hazardous materials will require personnel protective equipment. A pre-project briefing will be held with all personnel to review the SAP, HSP, and SMP requirements. Figure 3 shows the locations of the exclusion zones, contamination reduction zone (CRZ) with equipment and personnel decontamination stations, and the clean zone for on-site activities. A field office for secure storage of equipment and supplies will be mobilized to the Site during SC Pilot-Scale field activities.

The primary exclusion zone shown on Figure 3 includes the majority of the fenced area except for the small area that will be used for decontamination of equipment and personnel (CRZ). Activities to be performed in the primary exclusion zone include:

Excavation and screening of on-site materials



• Washing of debris

• Pilot-Scale testing of the solvent extraction and solidification/stabilization treatment equipment

The CF Systems mobile MDU and Chemfix solidification/stabilization equipment will be located in the western corner of the Site. A secondary 50 foot by 60 foot exclusion zone will be established within the primary exclusion zone around the treatment system work area (Figure 3). Access to this zone will be coordinated between the GEI On-Slte froject Coordinator and the CF Systems MDU Manager.

An approximately10-foot by 30-foot areawillbe preparedforstorageof solid waste remaining on the site until hill-scale remedial activities (Figure 3). This area is described inSection 2*3.5.

The outer boundary of the primary exclusion zone, called the hotline^ will be clearly marked by the existing fences or ropes with flagging. Two access points for personnel and equipment will be established through the hotline to control the flow of personnel and equipment into and out of the primary exclusion zone, and to verify that proper procedures for entering and exitingare followed. The temporary storage area for drummed wastes generated during field activities will be located in the drum storage area adjacent to the access gate for equipment.

The personnel working in the primary exclusion zone will include the Oa-Site Project Coordinator, the GEI sampling personnel, and contractor personnel such as heavy-equipment operators and laborers. All personnel within the primary exclusion zone will wear the level of protection required by the site-specific HSP. Personnel working in the secondary exclusion zone will include only CF Systems, Chemfix, and authorized personnel. All personnel within the secondary exclusion zone will wear at a minimum the level of protection required by the site-specific HSP.

The contamination reduction zone (CRZ) is the transition area between the contaminated area and the clean area. The CRZ is designed to reduce the potential that contamination will be transferred from the exclusion zones to the clean zone. The CRZwill contain equipment and personnel decontamination stations. The CRZ will be flagged in the field at the location shown on Figure 3.

Access to the CRZ from the clean zone is through two access control points, one each for personnel and equipment. Personnel entering the CRZ will be required to wear the personnel protection clothing and equipment described in the HSP. To reenter the clean zone, workers will remove all protective clothing and equipment worn in the CRZ and leave through the personnel access control point.



Decontamination will take place within the CRZ in the personnel decontamination corridor and the equipment decontamination corridor. The decontamination corridors begin at the hotline.

The CRZ will be designed to accommodate the following:

• Decontamination of equipment, personnel, and samples;

• Emergency response; transport for injured personnel and first aid equipment;

• Equipment resupply; personnel protective clothing and equipment, sampling equipment and supplies;

• Sample packaging and preparation for on-site or off-site laboratories;

• Worker's temporary rest area; bench, chair, refreshments, and shelter.

Personnel within the CRZ will be required to maintain site security and internal communications.

The field office will be established in the clean zone and will be the location of all administrative and support functions required for the on-site investigations. This would include Level I analytical analyses performed by a GEI chemist. Support personnel will wear normal work clothes within the clean zone and field offices. The support zone personnel will be responsible for performing the proper communication in the event of an emergency. All emergency telephone numbers, vehicle keys, monitoring well keys and project documents will be kept in the field office. Wireless communication devices will be kept in the field office to communicate with field personnel in the exclusion zone. Wireless communication will also be maintained between the CF Systems MDU Manager and the GEI On-Site Project Coordinator. A log will be maintained in the GEI personnel field books of all personnel on-site and their times of entry and exit onto and off of the Site.

The clean zone will coincide with the fence line that encompasses the Site as shown in Figure 3. The access control points into the Site will be locked at all times except during periods of personnel or equipment mobilization into and out of the fenced area. This will prevent unauthorized entry into the Site which might result in exposure of persons to potential hazardous conditions. The keys to the gates will be retained by CMP. The GEI On-Site Project Coordinator will obtain the keys from CMP at the beginning of field activities and return the keys to CMP upon completion of field activities. The locks for the equipment and personnel access control points will be keyed alike. A different key and lock will be used for the access point into the field office area. As this is within the clean zone, this key may be controlled by



other field personnel, whereas the key for the other gates will be controlled only by the GEI On-Site Project Coordinator. All visitors to the Site will be processed through the field office. Only properly trained and authorized personnel will be permitted to enter the contaminant reduction and exclusion zones. The field office located outside the main fence line in the clean zone will also be used to store equipment and supplies. The field office will be kept locked during periods of inactivity. In addition, the small fenced area surrounding the field office will also be kept locked.

The propane storage tanks used by the treatment system will be located in the clean zone adjacent to the primary exclusion zone (Figure 3). These tanks will be accessed by local contractors to resupply propane to the treatment system. Access to the propane tanks will be monitored and controlled in accordance with applicable OSHA regulations (29 CFR 1910.120). Potable water tanks for the treatment systems will be filled by the excavation contractor.

233 Air Monitoring

Air monitoring will be performed continually during the Pre-Design field investigations. The monitoring equipment will include a photoionization detector (PID) manufactured by HNu systems (HNu PI-101) for the monitoring of VOC levels, and a MIE MINIRAM hand-held aerosol monitor (HAM) for the monitoring of airborne particulates. The need for respiratory protection and the level of protection for field personnel will be determined based upon data collected with the PIDand HAM, asspecified in theHSP. The Pilot-ScaleOn-Site ProjectCoordinator will be responsible for ensuring that personnel comply with applicable Health and Safety requirements.

It is anticipated that air purifying respirators will be worn during material excavation and handling within the exclusion zone. The need for respiratory protection during the on-site activities will be determined by air monitoring for organic vapors and airborne particulates. If readings on the HAM of 1.0 mg/m3 particulate concentrations or greater are detected, or during activities when sporadic exposure of on-site workers to airborne particulates is likely, air purifying respirators will be worn. Also, if ambient VOC levels of 5 to 10 ppm in the breathing space are detected with the PID, air purifying respirators will be worn. Levels of organic vapors greater than 10 ppm will necessitate utilization of self-contained breathing apparatus (Level B). Based on data collected during the RI and Pre-Design SC studies, the need for Level B equipment protection is not anticipated.



23.4 Waste Disposal

After completion of SC field activities, a permitted hazardous waste transporter will remove and transportall contaminated materials (tyveksuits, gloves, boots, respirator cartridges, extracted PCBs, contaminated process waters, and methanol rinse waters) for disposal at a RCRA- and TSCA-permitted disposal facility. Prior to waste disposal, the hazardous waste transporter will provide to CMP the names of three potential locations/facilities for off-site hazardous waste disposal. CMP will provide these names to EPA for approval. Manifests for the off-site transportation and disposal of wastes will be signed by CMP. Table 1summarizes waste generation quantities and disposal options. On-site storage of wastes is described in Sectta?233iii

Waste drums will be sequentially labelled with contents, date of collection, and location of origin from Site. A record of waste-containing drums will be maintained in the project field book. Wastes will be stored in DOT-approved containers and labelled in accordance with 49 CFR Parts 173 through 179 and 40 CFR Parts 262 and 263, and all other applicable Federal, State, and local transportation regulations.

The waste disposal contractor will also be responsible for the following:

1. Manifest Form completion,

2. Compliance with manifest signature requirements,

3. Delivery of the waste material in accordance with the directives on the manifests to the permitted disposal facility,

4. All record keeping and reporting requirements,

5. Proper response to any spills during transportation in accordance with 40 CFR Part 263, and State and local regulations. The waste disposal contractor will also transport materials in accordance with all applicable State and local requirements. The waste disposal contractor will be responsible for performing any cleanup activities resulting from a spill or release as required by Federal, State and local officials.

The waste disposal contractor will inform CMP and GEI if the wastes are to be temporarily stored at a transfer facility. Storage by the contractor of a manifested shipment of hazardous waste at a transfer facility for a period of not more than 10 days are subject to regulations under 40 CFR 264, 265, 268 and 270.



233 Ot̂ Sit© Waste Storage

Wastes generated during Pilot-Scale activities will include wastes which will be manifested for off-site disposal at completion of Pilot-Scale activities and wastes which will remain on-site pending full-scale remedial action. Wastes staged prior to off-site disposal will be stored in die existing Drum Storage Area (Figure 3), These materials will include both liquid and solid wastes identified in Table 1. Wastes staged forlater treatment/disposal during full-scale remedial actions will consist only of solid materials (treated soilsand sediments) identifiedin Table 1. These materials will be stored adjacent to the on-site barn in the solid waste storage area shown on Figurei3i

The existing Drum Storage Area will be refurbished prior to Pilot-Scale activities. The following actions will be performed;

1 A sheet of 20-mii plastic will be placed on the ground to underlie the drums;

2. Drums will be placed ou wooden pallets over the plastic to allow visual inspection of the bottoms for leakage;

3. Drums will be covered with a plastic tarpaulin to prevent contact with precipitation;

4. labels will be covered with clear tape or plastic for protection from theelemeni&

The proposed Solid Waste Storage Area will be located on the northeast side of the on-site barn. Approximately forty 55-gallon drums will be stored in this area. The storage area will consist of an area approximately 30 feet long and 10 feet wide that will be cleared of brush and levelled. Drums of solid wastes will be placed on wooden pallets in rows of two with at least a3-foot space between rows. The upper one-third of the staged drums will be covered with plastic tarpaulins secured to the wooden pallets* Drum labels will be affixed below the tarpaulin and covered with clear tape or plastic for protection from the elements. Asecond plastic tarpaulin will be placed over the drums and labeis and secured in such a fashion to readily allow visible inspection of the lower portions of the drums and their labeis*



2.4. Data Handling

The analytical laboratory data collected during the SC Pilot-Scale studies will be stored in a LOTUS®-compatible computer database filing system. IBM personal computer compatible hardware will be used for the data processing. The data input fields for each sample collected will include the following:

Site Name Project Number Sample media Sample date Sample identification Parameters analyzed Concentrations of parameters detected

All data loaded into the computer database will pass through a 100 percent accuracy check as part of GEI's quality control program for analytical data. The quality control will consist of the GEI On-Site Project Coordinator checking the actual laboratory reports with the data on the spread sheets, if applicable, statistical manipulations of the analytical data will be performed by GEI using the computer software spread sheet program QUATTRO®. QUATTRO® accepts LOTUS® compatible data input files.

Document SG Pilot-Scale POP, Vol. I Revision 1


3. COMMUNITY RELATIONS SUPPORT PLAN (CRSP)

3.1 Introduction

This Community RelationsSupport Plan (CRSP) has been developed to support community relation efforts of the EPA during RD/RA activities at the O'Connor Site in Augusta, Maine. This CRSP shall specifically be in support of the Community Relations Plan for the Site to be developed by the EPA.

3.2 Previous Community Relations Activities

Previous community relations activities conducted by EPA at the Site were summarized in the ROD, as follows:

• October 27, 1984 - EPA issued a press release stating that EPA ordered the F.O'Connor Company to fence and post its property on Route 17 and to sample and analyze the contents of drums and storage tanks on-site.

• September 1985 - EPA released a community relations plan describing citizen concerns about the Site, outlining a program to address these concerns, and discussing how EPA intends to keep citizens informed about and involved in Site activities.

• May 13, 1986 - EPA issued a press release announcing that CMP and the F. O'Connor Company entered into a consent agreement with EPA to study hazardous waste contamination at the Site.

• June 11, 1986 - EPA held an informational meeting to describe the plans for the Remedial Investigation and Feasibility Study (RI/FS).

• March 25, 1987 - EPA issued a press release announcing that the Central Maine Power Company and the F.O'Connor Company entered into a modified consent agreement with EPA and the Maine DEP to investigate waste contamination at the Site.

• July 1989 - EPA mailed the proposed plan announcing EPA's preferred alternative for addressing contamination at the Site to all those on the Site mailing list.



• July 12, 1989 - EPA issued a public notice in the Kennebec Journal to announce the time and place of the public informational meeting for the Site, provide a brief analysis of the proposed plan, and invite public comment on the FS and the proposed plan.

• July 13, 1989 - EPA made the Administrative Record available for public review at EPA's offices in Boston and at the Lithgow Public Library in Augusta.

• July 19,1989 - EPA held a public informational meeting to discuss the results of the RI/FS and EPA's proposed plan.

• July 20 through August 19, 1989 - EPA held a public comment period on the proposed plan.

• August 10, 1989 - EPA held an informal public hearing to accept comments on the remedial alternatives evaluated in the FS and on the proposed plan.

EPA prepared a responsiveness summary for the RI/FS comment period July 20, 1989 to August 19, 1989. EPA's responses to two formal sets of written comments received during the public comment period and oral comments received at an informal public hearing on August 10, 1989. The responsiveness summary was included as part of the ROD for the Site.

33 Community Relations Objectives

As presented in the EPA Community Relations Plan for the Site (September 1985), the following objectives were identified to facilitate the flow of information between concerned citizens, local officials, and the agencies involved with remedial activities.

® Provide the community with accurate and complete information on the nature and schedule of all planned site activities and encourage citizen input.

• Provide residents and officials with results of the remedial activities.

• Maintain communications with State and localgovernment officialsconcerning site activities and the results of such activities.

8 Ensure that the media is provided with accurate information in a timely manner.

Periodically reassess the community's concerns.



3.4 Anticipated Community Relations Support Activities

CMP will provide community relations support at the request of EPA. CMP anticipates the following support activities:

• Assistance in preparing fact sheets or updates concerning RD/RA activities at the Site including publication and copying.

• Participation in public informational or technical meetings including preparation of fact sheets and provision of visual aids and equipment.

• Assistance in preparing a responsiveness summary of the public RD/RA comment period.

TABLE 1 - WASTE GENERATION SC Pilot-Scale Studies O'Connor Site Augusta, Maine

Type Source Estimated Quantity

Testing Disposal

Dry solid waste Tyvek, paper products, plastics, gloves, etc.

1 5 - 3 0 d r u m s Aptus(1) Off-site at an EPA-approved facility

Methanol waste

PCB oily-extracts

Rinse water from decontamination

From soil treatment

5 drums

1 drum

Aptus(1)

Aptus0)

Off-site at an EPA-approved facility

Off-site at an EPA-approved facility

Toluene Decontamination of soil treatment unit

1 drum Aptus(1) Off-site at an EPA-approved facility

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

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

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

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

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

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

Note:

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

off-site by the waste disposal subcontractor.

Project 90393 GEI Consultants, Inc. June 18, 1992

Approximate Scale (ft) 0 2,500 5,000

Source:

Scale:

USGS Topographic Sheets Togus Pond (1982) and Augusta (1980), Maine

1:30,000 (reduced 20% from original); Contour nterval « 10 feet

Central Maine Power Company Augusta, Maine

Pre-Design Studies O'Connor Site Augusta, Maine

SITE LOCATION

MAP

GEI Consultants, Inc. Project 90393 Jan. 31, 1992 "fl-1 I

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Central Maine Pre-Design Studies LOCATION OFPower Company

O'Connor Site TRANSFORMER WORK AREASAugusta, MaineSCALE: 1" = 140* Augusta, Maine AND SWALES

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Power Company Site Management Plan . Augusta, .Maine O'Connor Site SITE WORK· ZONES40 80 ___ , Augusta, Maine

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G EI Consultants,_ Inc. "

Projeqt 90393 Januar 31, 1992

Documents

Site: Break' o Other: GEI Consultants, Inc. · A Source Control (SC) Pilot-Scale Treatability Study will be performed by GEI Consultants, Inc. (OBI) at the O'Connor Superfund Site