United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
(OS-240)
f PAb40 8-91
May 1991
Design And
Construction Issues
At Hazardous Waste Sites
Conference Proceedings
Part 1: Pages 1 thru 700
Hyatt Regency
at Reunion
Dallas, Texas
May 1-3,1991
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EPA/540/8-91/012
OSWER DIRECTIVE #9355.8-01
MAY 1991
Design And Construction Issues
At Hazardous Wastes Sites
CONFERENCE PROCEEDINGS
HYATT REGENCY AT REUNION, DALLAS, TEXAS
MAY 1-3, 1991
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Office of Emergency and Remedial Response
Harzardous Site Control Division
Washington, D.C. 20460
Printed on Recycled Paper
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NOTICE
Development of this document was funded, wholly or in part, by the United States Environmental
Protection Agency. This document has not undergone a formal USEPA peer review. Since this
document is essentially a collection of papers presenting ideas of individual authors, it has not been
reviewed subject to USEPA technical and policy review, and does not meet USEPA standards for
USEPA document publication. The views expressed by individual authors are their own and do not
necessarily reflect the views, policies, or ideas of USEPA. Any mention of trade names, products,
or services does not convey, and should not be interpreted as conveying, official USEPA approval,
endorsement or recommendation.
This document is not intended to and does not constitute any rulemaking, policy or guidance by the
Agency. It is not intended to and cannot be relied upon to create a substantive or procedural right
enforceable by any party. Neither the United States Government nor any of its employees,
contractors, subcontractors or their employees makes any warranty, expressed or implied, or assumes
any legal liability or responsibility for any third party's use of or the results of such use of any
information or procedure disclosed in this report, or represents that its use by such third party would
not infringe on privately owned rights.
ACKNOWLEDGEMENT
The U.S. Environmental Protection Agency (EPA) wishes to thank all of those who participated in
the development of the Agenda, Proceedings Manual, and attended the first "Conference on Design
and Construction Issues at Hazardous Waste Sites", held between May 1-3, 1991 at the Downtown
Hyatt Regency at Reunion in Dallas Texas. The feedback received during and after the conference
was extremely positive; it is EPA's plan to sponsor this conference on an annual or biennial basis over
the next several years until a 'steady-state' in design and construction at hazardous waste sites is
reached.
Several individuals played an important role in making the conference the success it was. In
particular, Kenneth Ayers, William Zobel, and Edward Hanlon of USEPA, and Michael Blackmon
and Chris Fafard of PEER Consultants, and the PEER Consultants Word Processing staff, should be
recognized. We thank these individuals, the Conference Abstract Review Committee, and the authors,
speakers, panel members, and conference participants for a job well done. Their efforts will help
insure that design and construction efforts during hazardous waste site remediation will continue to
see quality improvements in future years.
Paul F. Nadeau, Acting Director
Hazardous Site Control Division
U.S. Environmental Protection Agency
Conference Project Managers
Kenneth W. Ayers, USEPA Edward Hanlon, USEPA
CDR William R. Zobel, USEPA Michael Blackmon, PEER Consultants
Abstract Review Committee Plenary Session Speakers
Robin Anderson, USEPA, Washington, DC Paul F. Nadeau, USEPA, Washington, DC
William Bolen, USEPA, Chicago, IL Timothy Fields, Jr., USEPA,
Walter Graham, USEPA, Philadelphia, PA Washington, DC
Edward Hanlon, USEPA, Washington, DC Robert E. Layton, Jr., USEPA, Dallas, TX
Donald Lynch, USEPA, New York, NY Colonel Wayne J. Scholl, U.S. Army Corps
Brian Peckins, U.S. Army Corps of of Engineers, Washington, DC
Engineers, Washington, DC James W. Poirot, CH2M-HH1, International,
CDR William Zobel, USEPA, Denver, Colorado
Washington, DC
Luncheon Speaker
Donald Brown, Stubbs Overbeck & Associates, Inc., Houston, Texas
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PREFACE
CONFERENCE ON DESIGN AND CONSTRUCTION ISSUES
AT HAZARDOUS WASTE SITES
MAY 1-3, 1991, HYATT REGENCY AT REUNION, DALLAS
The first U.S. Environmental Protection Agency (EPA)-sponsored national conference on design and
construction issues at hazardous waste sites occurred between May 1-3, 1991 at the Downtown Hyatt
Regency at Reunion in Dallas Texas. Ninety-five presentations of technical papers with three panel
discussions on technical/policy issues and case studies were held.
Included in this publication are questions and answers from the panel discussions, as well as text of
the technical papers. In some cases, the authors' names and addresses are included at the end of their
respective papers. This 'Conference Proceedings' culminates and memorializes the significant efforts
made at and for this conference.
This national conference was warranted and timely due to the increased complexity of issues related
to this subject area and the growing number of hazardous waste sites entering design and construction.
The conference also had a different intent, agenda and format than other major hazardous waste
conferences. An open exchange of ideas to promote formal and informal discussion of design and
construction issues was planned, in order to encourage national consistency, help develop more
efficient and practical means to move design and construction projects through the pipeline, and
augment EPA's current efforts to revise its Superfund design and construction guidance and policies.
Topics covered a range of issues, including pre-design activities, construction administration and
claims, community relations, health and safety, and government policy. Participants include the U.S.
Department of Energy (DOE), Department of Defense (DOD), Bureau of Reclamation, and Army
Corps of Engineers, as well as EPA, numerous design and construction contractors and State agencies.
EPA wishes to thank all of those who participated in the first "Conference on Design and
Construction Issues at Hazardous Waste Sites". It is EPA's plan to sponsor this conference on a regular
basis over the next several years. The next conference is tentatively planned for early April, 1992 in
Chicago.
Future inquiries regarding this conference and next year's planned conference are encouraged to be
made in writing to the attention of: Kenneth Ayers, Chief, Design and Construction Management
Branch, U.S. Environmental Protection Agency, 401 M Street, SW, Mailcode OS-220W, Washington
DC 20460, or by contacting EPA's Design and Construction Management Branch at (703) 308-8393.
in
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SUMMARY OF QUESTIONS AND RESPONSES FROM THE PANEL SESSIONS
DESIGN AND CONSTRUCTION POLICY PANEL SESSION
Kenneth Ayers (Co-Chair)
Hazardous Site Control Division
Office of Emergency and Remedial Response
USEPA
Charles Schroer (Co-Chair)
Acting Chief, Construction Division
USAGE
James Feeley
Chief, Superfund and Emergency Response Section
Texas Water Commission
Doug Smith
U.S. Department of Energy
John J. Smith
Acting Branch Chief
Remedial Operations and Guidance Branch
USEPA
James Moore
Baltimore District, USAGE
1. QUESTION: What support is available through the Corps of
Engineers or the Bureau of Reclamation for RCRA-
lead actions?
RESPONSE: The Corps and Bureau of Reclamation are available
and have done support of RCRA actions.
2. QUESTION: How are lessons learned at remediation sites in
Texas shared?
RESPONSE: Papers are presented at Conferences such as this.
The State is open to provide any information they
have to interested parties.
3. QUESTION: With regard to Texas State Enforcement actions, how
do you view cost recovery and what documentation is
acceptable with the courts?
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RESPONSE:
QUESTION:
RESPONSE:
QUESTION:
RESPONSE:
QUESTION:
RESPONSE:
Cost recovery on non-NPL sites has been successful
on solid waste enforcement sites. On NPL sites the
recovery is conducted in conjunction with the EPA.
The State Superfund program has not proceeded far
enough to start recovery.
With the new shift to PRP lead RD/RAs, we need to
evaluate what the PRPs are like; some may be
trusted, some not. This may be determined in the
negotiation process. It should be considered that
the public does not trust the PRPs.
A draft PRP Oversight Guidance Document has been
prepared and distributed to RPMs. Current EPA
staffing and funding will not be able to handle
oversight of a large number of new sites. The
amount of liability that the EPA will assume in PRP
oversight must be evaluated. Possibly each
enforcement action needs to be evaluated, case by
case, and as little oversight as necessary be used.
Begin with high oversight and, if the PRP is
determined to be performing acceptably, reduce the
amount of oversight. This approach is presented in
the guidance which is still out in draft form,
awaiting feedback. The guidance is flexible, based
on the RPM's evaluation of the PRP performance.
Part of the guidance was to have the PRP provide an
Independent Quality Assurance Team provide QA data
to the RPM for review. This point is still in
contention.
When can we expect an agreement between EPA, Corps
and Bureau of Rec on data validation?
EPA Region 2 does have an agreement with the Corps,
and a national agreement has been proposed.
Current trends are shifting toward more autonomy to
the EPA Regions, and fewer national agreements are
being signed. EPA Regions and the respective Corps
and Bureau of Reclamation representatives need to
determine, on a Region-specific basis, whether such
agreements are necessary. If so, meetings should
be set, and decisions made, on this issue.
What is the status of "Lessons Learned"?
the direction for distribution?
What is
A computerized "Lessons Learned" system was
developed at the Corps which every field office
could input to and be read at headquarters. The
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current status of the system was not available. It
is not currently being used for the Superfund
Program, but it will be adopted.
QUESTION: One of the problems many RPMs run into is the
acquisition of property during a Remedial Action.
Many Remedial Actions have been halted to allow
time to acquire a piece of property, property
easement or long-term lease. Under SARA, the law
requires that any property acquisition during a
Remedial Action must be accepted by the State after
the action is complete.
In Pennsylvania, the Commonwealth has refused to
accept any of the acquired properties. Since an
agreement with the Commonwealth has to be in place
prior to the property acquisition, projects in
Pennsylvania are stifled at the time. Is anything
being done to deal with the States' concerns that
they will be liable for any contamination remaining
on the site after the Remedial Action?
RESPONSE: It is a requirement under the law; we can't get
around this. EPA's tentative understanding is that
states may not be considered liable for any
contamination remaining on the site after remedial
action. However, if only an easement is needed
which will expire at the end of the Remedial
Action, State approval is not required. If we are
buying property and the lease actually comes to the
EPA, an agreement for transfer to the State is
required. In regard to the liability issue, in the
Superfund contract the States have agreed to
operate and maintain long-term remediation after
the EPA completes its efforts. We don't understand
or know all the details of why Pennsylvania has
taken this stand at the this time.
QUESTION: The States are mainly fearful of "owner liability"
for property which they must take over after the
Remedial Actions. Is there any effort at
Headquarters to relieve the States of this
potential liability in the future?
RESPONSE: As discussed above, EPA's tentative understanding
is that states may not be considered liable for any
contamination remaining on the site after remedial
action. EPA is still investigating this issue.
However, it was never fully understood why
Pennsylvania was not willing to accept the property
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acquisitions. This can be discussed with
Headquarters Council to see if there is some
wording which may assist in the negotiations with
Pennsylvania.
9. QUESTION: Do you think the Federal Government could be a
central data-gathering point for "Lessons Learned"
within the Corps, and States as well, and could
there be a publication of this data for those who
need this information?
RESPONSE: This would be the optimum; however, resources are
not available at this time to facilitate this large
an effort. For a computer database of "Lessons
Learned", significant screening of the data to be
input must be done. "Lessons Learned" may become
purely emotional or personal, which are not the
intent of this type of database. Information which
is not clearly worded and analyzed could be
misinterpreted or lead to liability. This will
require mature screening.
RESPONSE: The EPA Design and Construction Management Branch
produces a bimonthly flyer, "RD/RA Update", which
provides current information and "lessons learned"
on RD/RAs.
In regard to setting design parameters, I
understand that there is a lack of data available
to make site decisions. When you get into the
construction phase, you need to take the
opportunity to seek the data to verify the design
parameters that you have designed with and make
necessary adjustments. Is the Corps of Engineers
putting into place any mechanism to keep the
Designer involved during construction to verify
design parameters?
RESPONSE: Absolutely. An agreement is made with the designer
for involvement throughout construction to discuss
problems, etc.
11. QUESTION: In regard to AE liability, could this point be
expanded on?
RESPONSE: In just the last few years the EPA has gotten
heavily involved in design, and we are now seeing
designs being implemented. EPA's REM contracts had
the standard AE liability clause, which states that
if there is an error or omission that the AE firm
10. QUESTION:
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12. QUESTION:
RESPONSE:
13. QUESTION:
RESPONSE:
14. QUESTION:
will go back and correct this error or omission at
no cost, and if the error or omission was caused by
negligence and the error caused significant
increased costs the AE firm will be liable for
these costs (rough interpretation). If the EPA
gives the designer definitive direction, more than
likely the EPA is assuming liability for the
affects of that direction.
The guidance given to the AE determines if the AE
is liable for errors. An AE liability clause is
being drafted specifically for the ARCs contracts.
However, the negligence standard, Section 119 set
up for indemnification, may conflict with the
liability clause; it is not a clear-cut issue.
What are the differences between the two liability
clauses?
Section 119 imdemnification addresses third party
liability associated with releases or threatened
releases. AE liability is two party, which focuses
on design errors or omissions. The clause being
drafted for the ARCs contracts is not substantially
different. It clarifies that for a cost
reimbursement contract, if an error or omission
occurs the EPA is only asking for the error or
omission to be corrected at no cost; EPA is not
asking for additional design work to be performed
gratis. Also, it clarifies negligence portions so
there is not a conflict with the negligence
standard, Section 119.
What efforts have been made by the Corps of
Engineers to involve small, disadvantaged or women-
owned business in your contracts?
Efforts are being made to track small and
disadvantaged business (SDB) contracts and insure
the set-aside levels are met. Future effort will
be made to track the amount of subcontracts which
are awarded to SDBs.
Should private industry be performing site clean-up
with the question of clean-up sufficiency? Could
other mechanisms be used to achieve clean-up?
Could the property be given to the AE firm in
return for the clean-up? The EPA providing funds
to the Corps who then pays an AE does not seem
efficient.
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RESPONSE: An "orphan" site is a site which does not have a
viable PRP. This does not necessarily mean there
is not an owner; it means that the PRP does not
have the funds or ability to do the remediation.
The EPA cannot just take possession of the
property. The legal ramifications would be
extensive.
In regard to efficiency, the decision was made to
get the most technically qualified people working
on Superfund site remediations due to the potential
risks posed at these sites. Costs were not the
central factor. The Corps was determined to have
the technically qualified personnel needed.
Efficiency, strictly in regard to profit margin, is
not the whole picture.
15. QUESTION: In Navy programs there is not enough contract
oversight available. The oversight official cannot
keep up with the amount of data and information
generated by several contractors at several sites.
The contractors then operate with minimal
oversight. I think the Government or the EPA's
time would be better spent on enforcement.
RESPONSE: That is one of the problems focused on by EPA
Administrator William Reilly — enforcement first;
however, resolving this problem will not occur
overnight.
The EPA has had a preponderance of excellent
contractors and encourages initiative by
contractors. It depends on your outlook and how
you want to use a contractor. Overall the products
received by the EPA have been excellent. However,
the EPA would prefer to have 100% enforcement
actions and not spend any of the Superfund.
16. QUESTION: Any lessons learned from Value Engineering Studies?
RESPONSE: We are very receptive to contractors proposals on
how to better clean up sites. At the Sikes
project, a major revision is underway. Under State
law, however, we cannot share the savings.
There is a Federal value engineering clause in
which savings achieved through a value engineering
study are shared with the contractor. The
Bridgeport, New Jersey site had a value engineering
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proposal which was accepted by the government
during construction.
17. QUESTION: I understand there is an interagency agreement
between the EPA and the Corps that states any
contract that is more than $5 million will go to
the Corps. I recommend that this limitation be
extended from $5 million to $10 million. There are
45 ARCs contractors, and you will achieve your
goals more quickly and efficiently.
RESPONSE: There is no dollar value specified in the
interagency agreement. It was strictly a policy
call on EPA's part. Any projected remedial action
of less than $5 million, the Regions have their
choice of using the Corps, bureau of Rec or an ARCs
contractor for either or both Design and
Construction. For contracts between $5 million and
$15 million, the Regions haves the choice of using
an ARCs contractor or Corps of Engineers for design
and implementing the construction through the Corps
or Bureau of Rec. Anything over $15 million is to
be designed and constructed by the Corps of
Engineers or Bureau of Rec.
A policy letter has been drafted to consider
exceptions to this policy on a case-by-case basis.
The Regions would have to make a strong argument to
waive this criteria.
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COMMUNITY RELATIONS PANEL SESSION
Melissa Shapiro (Chair)
Office of Emergency and Remedial Response
USEPA
Michael McGaugh
USEPA Region I
Betty Winter
USEPA, Region IV
Karen Martin
Superfund Community Relations Coordinator
USEPA Region V
Louis Barinka
Remedial Project Manager
USEPA Region VI
Betty Williamson
Community Relations Coordinator
USEPA, Region VI
George Hanley, USAGE
Pat Ferrebee
U.S. Navy
1. QUESTION: Regarding your comments about not responding
argument by argument in the Responsiveness Summary,
how do we have a complete Responsiveness Summary if
we have, say, forty arguments in the formal
comments and do not address them individually?
RESPONSE: There are situations where the arguments get so
outside of the reality of the project that they
start creating problems that do not exist, be it a
hypothetical question or whatever. Instead of
being in a response mode where we literally go
through the arguments and respond sentence by
sentence, we got back to the basics of "did we
consider reduction of volume, toxicity and
mobility". We focused on those issues that they
were trying to attack, rather than getting into a
point by point discussion in the response.
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QUESTION: My understanding of the Responsiveness Summary is
that you can take the comments and group them into
general points, as opposed to addressing specifics
to the letter.
ANSWER: Correct.
QUESTION: Concerning sending documents out to the TAG group
(Technical Assistant Grant group of the New Bedford
Community Environmental Awareness Group), they were
sent out as draft documents — were they EPA
internally reviewed, or what do you mean by
"draft"? Were they documents that actually came
from the RI consultant?
RESPONSE: The documents the TAG group received from their own
consultant were final documents; the group had
hired this consultant to generate their documents.
The TAG group received from EPA draft RI documents
prepared by EPA's RI consultant.
QUESTION: I assumed that EPA had a consultant doing the
RI/FS; did the TAG people see documents directly
from that consultant, or did EPA internally review
these documents, with their technical people,
before they went to the TAG group?
RESPONSE: EPA reviewed them first, they were draft final
versions.
QUESTION: Did you find, when you first started working with
the Community Group, that they were organized to
the point that they were ready to apply for the
Technical Assistance Grant, or anxious to do so, or
was it something that had to be Worked with?
RESPONSE: No, the group had to be formed. Going back to the
initial meeting they had, there was difficulty
because the area was settled with Portuguese with
little English speaking ability. EPA community
relations coordinators went out with bilingual
material trying to generate interest for the group.
At an early meeting with the City of New Bedford,
one woman requested to be the project manager. She
organized sign up sheets which were taken to the
community^
QUESTION: Did you provide assistance or background for the
incorporation process which the Community Group
went through?
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RESPONSE: They did that on their own. Problems developed
with attaining Non-Profit Organization status
through the IRS.
QUESTION: When initial newspaper articles (regarding a
hazardous waste site) came out, was there any sort
of direct response by the Navy, or did you just
kind of let them go and continue with your
community relations?
RESPONSE: We did a press release, and we also prepared
several fact sheets which we took to the community.
We put them in the post office, library, etc. We
had already set up an information repository — we
had done a few of the preliminary things we would
do for a CR. We did not respond directly to the
newspaper article because they had taken all our
words, distorted them, then devoted several pages
to the distorted version.
QUESTION: When your press officer experienced loss of
credibility, was there a communication strategy or
any kind of a CRP in place?
RESPONSE: We did not have a CRP in place. We figured out our
plan as events unfolded. We had never gone out and
done interviews, never prepared a formal CRP. I
can tell you now that the Navy does not like to be
in that kind of a situation. As soon as we realize
contamination on a site, we like to get started
[with community relations]. The sooner you get
started, the better off you are. We learned a
valuable lesson in Mechanicsburg, and if nothing
else, it was worth that experience.
QUESTION: Can you describe the situation in Mechanicsburg?
RESPONSE: We had PCBs in the drainage ditch, but that is not
what was described in the paper. Mechanicsburg is
a supply depot, where the U.S. keeps their
strategic supplies on a 700 acre paved site. We
keep strategic reserves of lead, chromium,
manganese, etc. Mechanicsburg is a ship's parts
control center. We have parts of ships in supply
there. It's one of those sites that, in time of
war, ships parts to whoever needs them. One of the
things that was a problem for us when the state
discovered the PCBs was that we could not identify
their source because we had no record of having
stored PCBs on that facility. We finally
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discovered that we had rebuilt transformers there,
and that was the source of PCB contamination. We
did an extensive storm sewer evaluation to try to
track down where the PCBs were coming from, and we
had to replace portions of that storm sewer.
We had talked to the newspaper about other sites,
though, including the site where we had buried
outdated medical supplies from World War II.
That's where the newspaper blew things out of
proportion.
QUESTION: Is this a base where Navy personnel live, and what
kind of Community Relations exist with the base
people?
RESPONSE: We informed them first, because people on the base
don't like hearing about a base problem from a
neighbor or friend. They want to know about it
first. They were kept informed through briefings.
11. QUESTION: On the Formerly Used Defense Sites, does the Corps
conduct the community relations plan or is there
some leftover military facility that handles it?
RESPONSE: If it's an active installation, the Corps provides
technical support; the installation prepares the
CRP. For remediation at active installations,
there is a book called The Commander' s Guide to
Installation Restoration — an Army publication
from USATHAMA — that says the responsibility of
the installation commander is to be the paragon of
environmental virtue. The cleanup of a site is his
responsibility, so even if the Corps may be running
everything else at a site, the chairman of the
technical review committee is invariably the
installation commander.
The CRP is usually prepared by active
installations. We do offer to them to do the CRP
and allow them to fine tune it, in which case we
would turn it over to a contractor. The decision
was made a long time ago that, with the number of
sites we have in the Kansas City district, we would
need an enormous number of people to prepare all
the CRPs or even to, manage that many contractors.
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HEALTH AND SAFETY PANEL SESSION
Joseph Cocalis (Chair)
Office of Emergency and Remedial Response
USEPA
John Moran
Health and Safety Director, LHSFNA
Sella Burchette
USEPA
Les Murphy
International Association of Fire Fighters
Denny Dobbin
NIEHS
Thomas Donaldson
Omaha Division, USAGE
Ira Nadelman
USAGE
Mary Ann Garrahan
OSHA
Diane Morrell
Ebasco
1. QUESTION: Is a hazardous waste site defined by OSHA?
Example: An office trailer in the support zone.
Do these workers need training?
RESPONSE: There is an internal inconsistency within the
standards. In Section E it is defined that if an
employee is on site regularly, and has no exposure
or potential for exposure, he still needs 24 hours
of training and one day of on-site training. This
includes everybody that enters the boundaries of
the site.
In Paragraph A of the standard: There must be an
exposure from a hazard on-site for 120 to apply.
The policy is, if there is a hazard the standard
applies, if there is no hazard from the site then
the standard will not apply.
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COMMENT: Section A states that where exposures are known or
potential then the standards apply if in one of 5
categories. The potential for exposure includes
accidental exposure.
QUESTION: Does 1910.120 have a requirement for one Health and
Safety Plan, rather than 50, one for each
contractor on site. Should there be just one plan
for the entire site?
RESPONSE: That is the way the standard is interpreted.
COMMENT: The contractor should approve the plans for the
subcontractors.
COMMENT: There is no rule saying there has to be just one
health and safety plan (HASP) , but any others
should be just as strict and specific as the prime
contractors, to make life easier. It is the Prime
Contractor's responsibility to oversee the
subcontractor's HASPs.
COMMENT: The contractors write the HASP and the
subcontractors must comply. It is not always the
case where it is one site, one HASP, especially for
very large sites where there are four or five major
contractors. A better way to work it is one
project, one HASP.
COMMENT: During contract solicitation, they normally require
a HASP. Exceptions are when contractors onsite
want a more restrictive plan. They may add to the
minimum OSHA and Corps requirements.
QUESTION: Should contractor's health and safety record be a
requirement for bid specs?
RESPONSE: For a request for proposals, the health and safety
record is a factor. For an IFB it is not a factor.
Contractors at this point should be aware of the
requirements. Some major contractors, for example,
the government, considered this a prequalification.
QUESTION: Congress passed a law about agencies assuming
responsibility for worker training. Of the
1.8 million workers that qualify for this, 53% are
firefighters, who have the highest risk, but are
not adequately trained. Thirty-one percent are law
enforcement agents, also high risk and one percent
are hazardous waste workers who have a lot of
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training. Doesn't the firefighter agency have a
direct responsibility to provide adequate funding,
as Congress had intended the money to be used, as
in the case of firefighters with high legitimate
claims to be trained rather than for EPA to assume
responsibility.
RESPONSE: The request for training is very competitive. Many
agencies apply, but only a few get it. This agency
has filled their obligation thus far with the money
that is available. If there is more money, there
will be more training. The Hazardous Materials
Transportation Act of 1990 is providing a grant
program at the local level through public sector
agencies. When this grant goes through, there will
be more training from the fire service.
QUESTION: If the funding is inadequate, why not go back to
Congress and say there is not enough money for
training, so these people can do their jobs
effectively. It seems as though the money is going
to the wrong people. Educational Institutions
should not be getting the funding because they do
not have the authority to help. People who do the
work should be getting the money.
RESPONSE: The President's budget cut the programs funding in
half. Appropriations are fighting it now.
QUESTION: What is to be done with utility companies wanting
to come on site for routine maintenance, main
breaks, etc. Should they have a trained contractor
on site with them? Is it okay to just have a site
safety person out there to make sure that the
utility company complies with the site HASP? How
does OSHA feel about this? Is this a violation to
have them on site?
RESPONSE: OSHA says there must be site representative who is
trained with a trained person monitoring. All
utilities should have properly trained people.
COMMENT: We must coordinate very early on. If you know
there are gas mains and underground utilities,
there is plenty of time before an investigation
begins to contact utilities and make them aware of
what is to come on this site. Be prepared because
there is no excuse to send untrained workers onto
the site to be exposed to what is there.
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COMMENT: These utility people won't be going onto the sites
very often.
RESPONSE: It is not okay to send untrained personnel on site.
COMMENT: There are contractors available to work for
utilities that have people that are properly
trained. There is no reason for utility companies
to put people's lives in jeopardy by sending
untrained workers onto a hazardous waste site. If
utilities don't have qualified people, there are
contractors who do.
7. QUESTION: What is going on around the country before we come
into town and say we have Superfund site? How are
the communities and responders, gas companies,
firefighters, etc., handled prior to the listing of
Superfund site? As far as training is concerned,
focusing only on Superfund is hitting only on a
limited portion of the market.
RESPONSE: Superfund is such a small portion of what trainers
have to deal with. Many fire chiefs, etc., are
stuck to tradition, not training. When dealing
with them (firefighters) on Superfund sites, you
get the same knee jerk reaction as with various
other kinds of exposures. It is very tough to get
the cooperation needed that you get from the Corps
of Engineers and the EPA.
COMMENT: Concerning the planning step of emergency response,
having this carried out at the remedial action
phase by the construction contractors will not only
entail the fire department but some of the issues
on utility services, etc. It is an issue that is
difficult with the Corps of Engineers in execution.
If it is difficult to affect the execution of the
emergency response plan because the service
providers are not trained or properly equipped to
perform the service. My recommendation for this
conference is that the support of a task force that
would look at the review process prior to design in
terms of the community service based around a
selected site and go through a thorough fact
finding process to delineate the best course of
emergency response that can get plugged into
design.
xviii
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COMMENT: There has to be cooperation from the government to
recognize that they must get out more information
and get it out in a more timely manner. Also, the
need is the same from emergency responders. In the
past, when looking at any federal documents with
requirements a contractor could assume that these
requirements were being met. So in a situation
dealing with a large union, such as the fire
fighters, you go into a town, coordinating with
town officials and a fire chief. If in fact that
is not the way this needs to proceed, then that
word has got to get out to the contracting and
government community because it is a fairly logical
assumption to make, that if the fire chief says he
can respond there will be a response and there
won't be any question as to whether his people are
trained. From both sides there has to be a clear
view of what all the issues are.
CONCLUSION: We are all now witnessing EPA, Corps of Engineers,
and experienced trainers all working together for
Health and Safety. One year ago you wouldn't have
seen this. Hopefully, there will be more progress
in the year ahead, especially with training in
emergency response.
xix
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TABLE OF CONTENTS
CONFERENCE PROCEEDINGS
Page No.
I. CASE STUDIES
Composite Concrete Liners for Radioactive Wastes
Thomas Ambalam, Kaiser Engineers 2
Fast Tracking Remedial Design at the Cape Fear Wood Preserving Site
Thomas Clark, CDM ,.. •••••• 7
Ambient Air Quality Management at French Limited Superfund Site
Bruce Dumdei, ARCO 23
Remedial Construction at the Industrial Waste Control Site, Fort Smith,
Arkansas
Santanu Ghose, USEPA 78
Bayou Bonfouca Superfund Site Case Study of Selected Issues
Robert Griswold, USEPA 108
Soil Remediation in the New Jersey Pinelands
Edward Hagarty, C.C. Johnson & Malhotra . 128
When is a Superfund Remedial Action "Complete"? A Case Study of the
Crystal City Airport RA Implementation and Transition to O&M
Bryon Heineman, USEPA 138
WEDZEB Enterprises Remedial Action: Planning for an Efficient
Remedial Action Completion
Tinka Hyde, USEPA . . . 161
The Landsdowne Radiation Site; Successful Cleanup In A Residential
Setting
Victor Janosik, USEPA 167
Remedial Design Approach and Design Investigations at the Bayou
Bonfouca Site
Kevin Klink, CH2M Hill . . 174
Value Engineering Studies of the Helen Kramer Landfill Superfund Site
Amy Monti, URS Consultants '. . . 202
Remedial Action In and Around Light Industrial Activity at the Denver
Radium Superfund Site
Timothy Rehder, USEPA 229
Streamlining Remedial Design Activities at the Department of Energy's
Monticello Mill Tailings NPL Site
Deborah Richardson, Chem Nuclear 238
xx
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TABLE OF CONTENTS
CONFERENCE PROCEEDINGS
Page No.
Construction of a Kaolin Clay Cap for Buried Nuclear Waste
C.J. Schexnayder, Nello L. Teer Co 249
Lessons Learned From Remedial Design of Helen Kramer Landfill
Superfund Site
Vern Singh, URS Consultants 277
Contract Security in Superfund: An Open Dialogue Between Government
and the Remedial Construction Industry
James Steed, Formerly of Texas Water Commission 286
Remedial Design and Construction at the Charles George Landfill
Superfund Site
Robert K. Zaruba, USAGE 292
II. COMMUNITY RELATIONS
Bells and Whistles: Community Relations During Remedial Design and
Remedial Action
Karen Martin, USEPA 308
Effects of Public Input and the Sampling Protocol on the Remedial Design
Process
Raymond Plieness, Bureau of Reclamation 328
III. CONSTRUCTION MANAGEMENT ISSUES
Remedial Design and Construction at the Picillo Farm Site
Mark Allen, Bechtel 335
Remedial and Post-Construction Activities at the Triangle Chemical
Company Site
Roger Brown, Weston 347
Concrete Cover Applications in Lined Drainage Ditch Construction
Camille Costa, Dynamac 358
A Case Study of Change Orders at a Supefund Site: Geneva Industries
Site—Houston Texas
Paul Cravens, Texas Water Commission 376
Transportation and Disposal of Denver Radium Superfund Site Waste
Richard Ehat, U.S. Bureau of Reclamation 390
Cost Estimating Systems for Remedial Action Projects
Gordon M. Evans, USEPA 399
xxi
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TABLE OF CONTENTS
CONFERENCE PROCEEDINGS
Page No.
HTW Construction Documentation Report: A Necessary Element in a
Successful Remediation
Heidi Facklam, USAGE 403
Change Orders Can Ruin Your Day: An Analysis of Construction Change
Orders in the Region 6 Superfund Program
Mark Fite, USEPA 409
Remedial Action Bids and Cost Estimates
Amy Halloran, CH2M Hill 420
RAC to PRP: The Thin Gray Line
Philip Kessack, ACRC 439
COS: An Expert System for the Analysis of Changes Claims
Moonja Park Kim, USACERL 472
The Tunnel Syndrome Solution: Can It Be Applies to Cleanup Projects?
Norman Lovejoy, Kellogg Corporation 487
The First Step for Strategic Environmental Project Management:
Environmental Cleanup Project Contract
James H. Pack, University of Nebraska 500
Permitting Superfund Remedial Actions or Nightmare on NW 57th Place
Lynna Phillips, EBASCO 518
State Oversight at Two Uranium Mill Superfund Sites in Colorado
Donald Simpson, Colorado Department of Health 528
Mobilizing for Remedial Construction Projects
Gary Stillman, Weston 550
Management of Change Order Conditions: A Superfund Case History
Myron Temchin, West HAZMAT, (303) 792-2535 ....... PreBented At Conference But Not Published
Construction Disputes on Hazardous Waste Projects
Theodore Trauner, TCS 558
Comparitive Roles of the EPA and the Bureau of Reclamation During the
Construction and Implementation of the Lidgerwood, North Dakota
Superfund Project
Laura Williams, USEPA 570
xxn
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TABLE OF CONTENTS
CONFERENCE PROCEEDINGS
Page No.
IV. GRQUNDWATER REMEDIATION
Pitfalls of Hydrogeologic Characterization
Steven Acree, USEPA Published, But Not Presented At Conference 589
Areawide Implementation of Groundwater Institutional Controls for
Superfund Sites
David Byro, USEPA 601
Verifying Design Assumptions During Groundwater Remediations
Michael Grain, USAGE 606
Hydrologic Risk Aspects of Hazardous Waste Site Remediations
William Doan, USAGE 622
Design and Construction of the Groundwater Treatment Plant at the
Conservation Chemical Company Site
Peter Harrod, ABB Environment Services 642
The Construction and Operation of the New Lyme Landfill Superfund Site
Groundwater Treatment Facility
Donna Hrko, USAGE 659
Arsenic Removal at the Lidgerwood Water Treatment Plant
Harry Jong, Bureau of Reclamation 668
Successful Program Management for Remedial Design/Remedial Action
James Kilby, Monsanto 673
Advances in Hazardous Waste Alluvial Sampling
Lowell Leach, USEPA 681
A Comprehensive Groundwater Quality Assessment and Corrective Action
Plan for a Single Hydrologic Unit with Multiple Contamination Sources
C.M. Lewis, USDOE 701
A Perspective for NAPL Assessment and Remediation
Mark Mercer, USEPA 735
Optimizing and Executing a Multi-Faceted Remedial Action Plan
Dennis Peek, Geraghty & Miller 748
V. HEALTH AND SAFETY
EPA/Labor Health and Safety Task Force
Joseph Cocalis, USEPA 760
xxin
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TABLE OF CONTENTS
CONFERENCE PROCEEDINGS
Page No.
Airborne Exposure at an Acid Sludge Remedial Site
Stephen Davis, IT Corporation 766
An Overview of the NIEHS Superfund Worker Education and Training Grant Program
Denny Dobbin, NIEHS 785
Hazardous Waste Sites: Worker Protection Perspectives
John Moran, LHSFNA 814
Crisis in the Fire Service
Les Murphy, IAFF 827
Worker Protection Standard
VlCki SantOrO, USEPA (201) 321-6740 Presented At Conference But Not Published
USEPA Generic HASP
Vicki SantOrO, USEPA (201) 321-6740 Presented At Conference But Not Published
USEPA Health & Safety Certification *
Vicki SantOrO, USEPA (201) 321-6740 Presented At Conference But Not Published
Overview of Hazard Waste Health and Safety Requirements
Rodney Turpin, USEPA (201) 321-6741 Presented At Conference But Not Published
VI. POLICY/MANAGEMENT ISSUES
Superfund — Program Standardization to Accelerate Remedial Design and
Remedial Action at NPL Sites
Shaheer Alvi, USEPA 838
Environmental Protection Agency Indemnification for Remedial Action
Contractors
Kenneth Ayers, USEPA 850
Innovative Design Review and Scheduling Tools: Potential Benefits to
HTW Remedial Projects
Gregg Bridgestock, USACERL 859
Basic Principles of Effective Quality Assurance
David E. Foxx, Foxx & Associates 885
Specifications for Hazardous and Toxic Waste Designs
Gregory Mellema, USAGE 889
Lessons Learned During Remedial Design and Remedial Action Activities
at Superfund Sites
Dev Sachdev, EBASCO 895
xxiv
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TABLE OF CONTENTS
CONFERENCE PROCEEDINGS
Page No.
Forecasting Staffing Requirements for Hazardous Waste Cleanup
Robert Salthouse, Logistics Management Institute 907
The Effects of the Davis-Bacon Act on the LaSalle Electrical Utilities
Phase I Remedial Action
David Seely, USEPA 919
Surety Bonds — Superfund Projects
August Spallo, USAGE 938
Remedial Design Schedule Management
Charles F. Wall, EBASCO 970
Remedial Management Strategy
Thomas Whalen, USEPA 1022
Acquisition Selection for Hazardous Waste Remediation
William Zobel, USEPA 1031
VII. PRE-DESIGN ISSUES
The Importance of Pre-Design Studies in Superfund Remediation
Jeffrey Bennett, Malcolm Pirnie, Inc 1042
RI/FS and ERA Impacts on RD/RA at Superfund Sites
William Bolen, USEPA 1060
Excavation/Off-Site Incineration RD/RA - Optimization of the
Planning/Investigation Process Based on the Two NPL Case Studies
John Gorgol, EBASCO 1087
Writing a Record of Decision to Expedite Remedial Action: Lessons from
the Delaware PVC Site
Stephen Johnson, DE DNR 1096
Site Characterization Data Needs for Effective RD and RA
John Moylan, USAGE 1103
New Bedford Harbor, Massachusetts Review of the Remedial
Investigation/Feasibility Study Process and Its Impact on Remedial
Design/Remedial Action
Mark Otis, USAGE 1110
The Pre-Design Technical Summary
Kenneth Skahn, USEPA 1118
XXV
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TABLE OF CONTENTS
CONFERENCE PROCEEDINGS
Page No.
VIII. DESIGN ISSUES
Accelerating the ROD to Remedial Action Process: Sand Creek Industrial
Superfund Site (OU1), Commerce City, Colorado
Brian Pinkowski, USEPA . . , 1125
Remedial Design of Superfund Projects -- What Can Be Done Better?
John Holm, USAGE . _.'.'. . 1141
Constructability Input to the HTRW Process
James Moore, USAGE 1148
Applications of a Design/Build Advisor Expert System to Environmental
Remediation Projects
Thomas Napier, USAGE 1162
"Conforming Storage Facilities" Remedial Construction Activities
D.M. Velazquez, DLA Published, But Not Presented At Conference 1 173
IX. TREATMENT TECHOLOGIES
A New Horizontal Wellbore System For Soil and Groundwater Remediation
Ronald BittO, Eastman Christensen Published, But Not Presented At Conference 1186
Soil Bentonite Backfill Mix Design/Compatability Testing: A Case History
Jane Bolton, USAGE 1203
Remedial Design for Solvent Extraction of PCB Contaminated Soils at
Pinette's Salvage Yard
Steven J. Graham, EBASCO (617) 451-1201 Presented But Not Published At Conference
United Creosoting Company Superfund Site, A Case Study
Deborah Griswold, USEPA 1219
Considerations for Procurement of Innovative Technologies at Superfund
Sites
Edward Hanlon, USEPA 1232
Trial Burn at MOTCO Site, LaMarque, Texas
MaryAnn LaBarre, USEPA 1256
Construction of Groundwater Trenches
Gary Lang, USAGE 1268
European Soil Washing for U.S. Applications
Michael Mann, Geraghty & Miller 1285
xxvi
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TABLE OF CONTENTS
CONFERENCE PROCEEDINGS
Page No.
Remedial Design Procedures for RCRA/CERCLA Final Covers
Donald Moses, USAGE 1300
The Challenge of Treating Superfund Soils: Recent Experiences
Carolyn Offutt, USEPA 1330
Tower Chemical: Remedial Design for a Small But Complex NPL Site
Victor Owens, EBASCO 1346
The Importance of Test Fills for the Construction of HTW Caps and Liners
David Ray, USACE 1360
Nuclear Waste Densification by Dynamic Compaction
Cliff Schexnayder, NellO L. Teer CO Published, But Not Presented At Conference 1 382
USEPA Region II Treatability Trailer for Onsite Testing of Soils and
Sludges
William Smith, CDM Published, But Not Presented At Conference 1409
Bioremediation of Toxic Characteristic Sludges with Biological
Liquids/Solids Slurry Treatment
Donald Sherman, RTI Presented At Conference But Not Published
Summary of Issues Affecting Remedial/Removal Incineration Projects
Laurel Staley, USEPA 1442
Remediating TCE Contaminated Soils: A Case Study of a Focused RI/FS
and Vacuum Extraction Treatability Study
Winslow Westervelt, Gannett-Flemming Inc 1458
xxvn
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I. CASE STUDIES
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Composite Concrete Liners for Radioactive Wastes
Tom Ambalam P.E., Principal Engineer,
Gary Koci, Principal Engineer
Kaiser Engineers
MSIN E6-66
Kaiser Engineers Hanford, Inc.
Post Office Box #888
Richland, WA 99352
INTRODUCTION
The requirements, under Minimum Technology Guidance by Environmental Protection Agency
(EPA), for hazardous waste landfills and surface impoundments were introduced by Hazardous and
Solid Waste Amendments of 1984. Double liners and leachate collection systems have been used
extensively for the disposal of hazardous wastes. Clay and high density polyethylene (HDPE) have
been the preferred choice for lining materials. However, for the disposal of radioactive wastes,
reinforced concrete liners with HDPE as a composite liner is considered to be an effective alternate.
This paper reports the details of concrete grout vaults and its features to meet the minimum
technology criteria and Department of Energy orders. The selection of liners, barriers and materials
for construction is also discussed. The use of concrete as a component of the composite liner system
is unique for the disposal of radioactive wastes and its applications for other wastes may be equally
appropriate.
OVERVIEW
Since 1943, the Department of Energy (DOE) has been receiving defense related radioactive wastes
at the Hanford Reservation (site), located in the southeast region of the State of Washington. The site
covers 560 square miles and is in an arid climate on the banks of the Columbia River. About 340,000
people reside within a 50-mile radius of the site. In the past, DOE's missions at the Hanford Site
included plutonium separation, energy technology development, and waste management. A variety
of low-level/high-level radioactive wastes (LLW/HLW), hazardous or plutonium contaminated wastes
in the form of "salt cake," sludge, and liquid are stored in underground storage tanks. LLWs are
generated by the medical, research facilities and the high level concentrations are the end products
of defense related projects and nuclear power plants. To comply with recent decisions within DOE,
the wastes have to be treated and disposed of in accordance with state and federal regulations.
Radioactive wastes consist of large volumes of material containing relatively low concentrations of
radioisotopes, as well as, smaller volumes of more highly concentrated materials. Depending on the
type of radiation, half-life and dose rate, the risk to human health and environment differ. Based
on these factors, radioactive wastes at the Hanford site are classified into low-level, high-level,
mixed, and transuranic wastes.
Radioactive wastes are stored in single shell tanks (SSTs) and double shell tanks (DSTs).
Approximately 37 million gallons of radioactive wastes are stored in 149 single shell tanks. Sixty-six
SSTs were confirmed or suspected to leak. Stabilization of SSTs is a top priority in the Tri-Party
Agreement, an inter-agency blueprint for corrective and remedial action at the Hanford Site between
EPA, DOE, and Washington Department of Ecology (WDOE). Stabilization will involve isolation of
the tanks and removal of pumpable liquid for disposal. Solidification, by mixing liquid radioactive
waste with cement grout, is identified as a permanent means of disposal for mixed wasted and LLW.
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SITE
The site for the vaults, located in the 200 Area of the Hanford Site, lies in the Central Plains of the
Columbia River Basin. The foundation soil for vaults consists of gravels and silty-fine sand. The
depth of the ground water table is approximately 260 feet. The storage and processing facilities for
DOE are located within the basin of the Columbia River, which is a major source of water for
municipal, industrial, recreation, and irrigation purposes for the States of Washington and Oregon.
GROUT TECHNOLOGY
Solidification of waste in a grout matrice appears to be a viable option for the long term disposal of
LLWs, HLWs and mixed wastes. Wastes removed from the tanks will be pre-treated to reduce the
volume prior to disposal. The high-level/transuranic wastes from the tanks will be targeted for
vitrification. Grout technology involves mixing waste slurries with cement, water, fly ash and
(sometimes) clay, and poured into concrete vaults to allow solidification such that the contaminants
are immobilized. Current methods of solidifying radioactive wastes are a slow process and migration
of leachate, during fixation and retention, should be prevented. Grout is a low-cost, low-energy
technology with wide applications for the Hanford Site. EPA's remedial investigations indicate that
the grout technology will likely be the leading candidate for immobilization of contaminated soils and
wastes stored in tanks. Because radioactive wastes emit heat energy over a long period, durability of
the waste form is questionable. In the 1990-95 five-year plan, DOE has scheduled to initiate a full-
scale demonstration and obtain data on durability by 1995 before implementation.
DESIGN CRITERIA
All radioactive wastes, except mixed wastes, are regulated under Atomic Energy Act and Nuclear
Waste Policy Act and their amendments. The Nuclear Regulatory Commission and the Department
of Energy are the regulatory agencies for the disposal of waste. Since 1984, the mixed wastes
processing and disposal were subjected to National Environmental Policy Act, Resource Conservation
and Recovery Act and Comprehensive, Environmental, Responsibility and Compensation Act. The
design and construction of the vaults are subject to the requirements of the Resource Conservation
and Recovery Act, Dangerous Wastes Regulations of the State of Washington, and the Department
of Energy Orders 5820.2A and 6430.1 A. ANSI/ASTM NQA-1 is the standard for the quality
assurance, in addition to Construction Quality Assurance requirements of EPA for hazardous waste
facilities. Radiation exposure, according to DOE orders, is that the effluent or air escaping from the
unit be limited to site standards - effective dose equivalent shall not exceed 25 mrem/year to any
member of the public.
In addition to standard design criteria for nuclear facilities, the vault
must be designed to withstand a maximum operating temperature of 90 degrees Centigrade and
prevent intrusion of or retention of water from rain, snow melt or other sources. Long term release
of radionuclides and chemical constituents shall be limited to IxlO'2 cm/sec and the vapor barrier
shall be designed to limit escape of vapors to IxlO'5 cm/sec.
VAULTS
Four concrete vaults are now under construction at the site. The vaults are constructed of reinforced
concrete with a catch basin to serve as leachate collection and removal system. The inside dimensions
of the vault are 123 feet long, 50 feet wide and 34 feet high and the capacity is 1,400,000 gallons (Fig.
1). The concrete mix consists of cement and aggregate mixed with 20 percent pozzolan to meet a
compressive strength of 4500 psi. The vault is isolated by a diffusion barrier at the base and sides
to prevent migration of leachate to the soil. Vaults are designed to receive the slurry above 150
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degrees Fahrenheit. The barriers, vertical leachate drains, and concrete HDPE composite liners are
some of the unique features of this project. With a .32 water-cement ratio, installation utilizes unique
curing and thermal controls for the mix to insure additional integrity for thermal cracking from the
grout mix.
LINER SYSTEMS
The vaults are designed with two component liner (composite) systems and a leachate collection
system. The primary composite liner system will be an elastomeric urethane asphalt coating applied
to interior vault wall concrete. The secondary composite shall be of HDPE liner attached to the
concrete of the catch basin.
The elastomeric asphalt coating was analyzed for its engineering properties and tested for capacity
to span shrinkage and thermal cracks in concrete. The coating is capable of counteracting shear stress
due to the grout and its in-place ability to bridge cracks in the concrete was tested in the laboratory.
The coating will consist of Lion Nokorode 705M and will be applied, at a rate of 2 gal/100 sqft, for
a total dry film thickness of 75 mil. Unlike coal-tar coatings, the elastomeric is compatible with a
radioactive waste and grout formulation. The secondary composite is HDPE laid over the concrete
basin and anchored by stainless steel batten strips.
In the primary and secondary composite liners, concrete serves as the backbone of the system.
Though vastly different from clay liners, a typical feature of most hazardous waste landfills, the
concrete plays a dual role in the concrete vaults. Concrete has a low permeability in the range of
IxlO'11 cm/sec, ten thousand times lower than clay. To achieve water tightness, impermeable
concretes with a low water-to-cement ratio and moist curing (7 days) are specified. Though
expensive, concrete liners are the preferred choice due to the structural, thermal, solidification, and
radioactive considerations.
DIFFUSION BARRIER
A diffusion barrier serves as a cocoon for the vault to prevent migration of vapor and infiltration of
moisture from the soil. The cocoon is designed to achieve a vapor diffusion IxlO"10 cm/sec and to
isolate the waste from the environment. The cocoon is 36 inches thick and, due to limiting water
vapor transmission the barrier is designed to be virtually watertight and prevent migration of leachate
to the soil column below. The diffusion barrier is made of graded gravel treated with an anti-
stripping additive to improve surface oil adhesion. The liquid asphalt AR-6000W is used at 7.0+
percent by weight of total mixture. Lime is used as an anti-stripping agent at 2.5 to 3 percent by
weight of mixture to pretreat the aggregate prior to mixing with asphalt.
LEACHATE COLLECTION SYSTEM
The vault is supported by a catch basin (pan) wherein the leachate collection system and pipes
transport the leachate to the sump. The secondary composite liner consists of the concrete floor of
the basin and the HDPE liner. The basin is lined with 60 mil HDPE and drain pipes transport
leachate to a sump with level sensors to activate the pump. The sump is a carbon steel collector
encased in concrete. A highly permeable diffusive layer of gravel (18 inches thick) separates the vault
from the basin and transmits dead loads in excess of 8000 pounds per square feet. The impact (creep)
due to gravel loads on the HDPE liner is mitigated with a layer of geotextile.
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DRAINAGE PATH
On the vertical sides, the vault is also provided with a drainage path to transmit the leachate to the
catch basin below. The drainage path consists of a layer of geotextile, geomembrane, and geonet laid
against the sides of the vault and separated from the asphalt by a thermal board. Due to the heat
generated by the asphalt during placing and solidification, the drain path needs to be separated by
thermal insulation to avoid damage to HDPE components.
SUMMARY
Cement concrete can be an effective alternate liner material for hazardous waste and radioactive waste
disposal sites. In locations, where native soil is a limiting factor for clay or soil/bentonite liners,
concrete as a component for composite lining should be explored. In desert climates, where
desiccation cracking may impact clay or soil/bentonite liners, concrete liners provide an alternative
choice. Due to rigidity of concrete, the designs should accommodate special coatings to span the
cracks to protect the integrity of the disposal sites.
The cost of concrete liners will be expensive compared to other admix liners and geosynthetic
materials. For equivalent thickness, concrete weighs more and the foundation costs will be
significant. However, if the integrity and compatibility can be achieved while reducing the
thicknesses, it is possible that concrete linings can be a viable alternative for hazardous waste sites too.
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GROUT WASTE DISPOSAL VAULT
STRUCTURAL BACKFILL
RCRA COVER
BENTONITE MIX
COMPACTED TOP SOIL
COATING a GROUT CAP EXTERIOR DRAINAGE PATH
GROUT WASTE
L,NEERR(CO!ISR|TTEE*COAT,NG)// / *- g*"°J"'[»*vg-
REINFORCED CONCRETE -—-// / LOWER CoipOSfTE L?NER
HOPE LINER (CONCRETE & HOPE) (60 ml)
SECTION A-A
3' MIN. GRAVEL
DIFFUSION BREAK
EXTERIOR DRAIN PATH
(GEOGRID, GEONET, HOPE
AND GEOTEXTILE)
REINFORCED CONCRETE VAULT
NATIVE SOIL
3' MIN. GRAVEL DIFFUSION BREAK
REINFORCED CONCRETE
LEACHATE SUMP
4' LEACHATE PIPING
SAND AND GRAVEL DRAINAGE MEDIA
PREPARED FOR THE US. DEPARTMENT OF ENERGY
OFFICE OF ENVRONMENTAL RESTORATION
AND WASTE MANAGEMENT
KAISER ENGMEERS HANFORD
NO SCALE 247190 5/4/88 KRUEGER
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Fast-Tracking Remedial Design at the
Cape Fear Wood Preserving Site
R. Tom Clark and Diane A. Gow
Camp Dresser & McKee Inc., Atlanta, Georgia
2100 RiverEdge Parkway, Suite 400
Atlanta, Georgia 30328
(404) 952-8643
Jon K. Bornholm
U.S. Environmental Protection Agency, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404)347-7791
INTRODUCTION
Fast-tracking, a method to accelerate remedial design and remedial action projects by eliminating
and/or rearranging various tasks, can be successfully applied to the remedial design and remedial
action work elements in the cleanup of hazardous waste sites. This paper presents a case history in
which innovative fast-tracking techniques were applied to a Superfund Site remedial design.
Although this project did not exhibit all the characteristics usually conducive to fast-tracking, it was
completed in an expeditious manner by omitting tangential design tasks, carefully scheduling select
tasks, and combining intermediate and prefinal design. Most importantly, a preliminary design
meeting was held with the U.S. Environmental Protection Agency (EPA) and representatives of the
U.S Army Corps of Engineers and the State of North Carolina during a critical phase of the project
to resolve key design issues and facilitate design completion.
In August 1989, EPA retained Camp Dresser & McKee Inc. (CDM), through its Federal Programs
Corporation subsidiary, to complete a remedial design of the Cape Fear Wood Preserving Site, an
abandoned wood treating facility located in Fayetteville, North Carolina. EPA's original Statement
of Work included twelve major design tasks, each typical of a remedial design work assignment for
a Superfund site. The original Statement of Work called for completion of the project by the end of
the 1990 calendar year. After the Final Work Plan was approved, EPA, in an effort to obligate funds
for the RA phase, directed CDM to finish the design by the end of EPA's fiscal year 1990. As a
result, five major changes were made to the original scope of work, three tasks were eliminated, and
the design schedule was ultimately shortened by approximately two months.
This paper presents a history and description of the Cape Fear Site and elements most suited to fast-
tracking, compares the original and final scope of work for the site, and presents specific techniques
used for fast-tracking the remedial design for this project.
BACKGROUND
Site Description
The Cape Fear Site is located in Cumberland County, North Carolina, on the western side of
Fayetteville near Highway 401 and along Reilly Road (Figure 1). The site includes approximately 9
acres of a 41-acre tract of land adjacent to other industrial/commercial establishments as well as
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private residences. Four homes are located near the site. In addition, a subdivision is located a
quarter of a mile south of the site and houses approximately 1,000 people.
The terrain of the Cape Fear Site is predominantly flat, with drainage provided by a swampy area on
the northeast side of the site and a man-made ditch to the southeast that extends southeastwardly
from the site. A variety of land uses exist around the Cape Fear Site. The properties to the north
include a pine forest, a concrete plant, and a few residential properties. To the east is a continuation
of the pine forest, and to the west is farmland used for growing crops and raising livestock. A second
concrete plant and the subdivision are located to the south.
Site History
History of Contamination. Operations at the Cape Fear Site commenced in 1953 and continued until
1983.1 The Cape Fear Wood Preserving facility produced creosote-treated wood from 1953 until 1978
when demand for creosote-treated products declined. Wood was also treated by a wolmanizing
process using salts containing sodium dichromate, copper sulfate, and arsenic pentoxide, known as
the copper-chromium-arsenic (CCA) process. The date the CCA process began at the site is not
available, nor is it known whether the creosote and CCA processes occurred simultaneously.
Both liquid and sludge wastes were generated by the treatment processes and pumped into a sump
north of the treatment area (Figure 2). As liquid separated from the sludge, it was pumped into a
drainage ditch that extends southeasterly behind the developed portion of the site and into a diked
pond. Stormwater runoff from the treatment yard also flowed into this drainage ditch. In addition,
waste from the CCA treatment process was pumped into an unlined lagoon north of the dry kiln.
In 1977, the site was determined to be contaminated with constituents of coal tar and coal tar creosote.
State authorities ordered the owner/operator to take measures to comply with North Carolina law.
As a result, operations at the facility were changed to limit further releases, a new water well was
installed for a resident living west of the site, and 900 cubic yards of contaminated soil were
transported for land-spreading to a leased property approximately 2.5 miles south of the site.
Sometime between 1979 and 1980, a new closed-circuit CCA system was installed and the old creosote
and CCA facilities were decommissioned. The new CCA plant was regulated under the Resource
Conservation and Recovery Act (RCRA) as a small quantity hazardous waste generator until 1983.
When the company went out of business, the site was subsequently abandoned.
Initial Investigation and Remedial Measures. EPA conducted a site reconnaissance and site
investigation in October 1984. As a result, emergency removal actions for sump sludge, lagoon
sludge, lagoon wastewater, and selected contaminated soils (ditch and northeast seasonal swamp) were
undertaken in 1985. Later in 1985 another investigation was undertaken, resulting in a second
emergency response being conducted in 1986 to remove contamination caused by a creosote spill.
Recent Investigations and Studies. A remedial investigation characterizing the nature and extent of
contamination was conducted under the REM II contract by CDM from April 1987 to October 1988.2
The feasibility study presenting cleanup goals for the contaminated media and evaluating possible
remedial action alternatives for the site was also developed by CDM and completed in December
1988.3 EPA signed the Record of Decision (ROD) on June 30, 1989, and in August 1989, EPA
contracted with CDM to begin a remedial design at the site.4 A Remedial Design Work Plan, prepared
by CDM, presented the scope of work, technical approach, management plan, schedule, and staffing
requirements to complete the remedial design.5 Additional project planning documents prepared by
CDM during the remedial design included a Field Operations Plan, Quality Assurance Project Plan,
Health and Safety Plan, and a Community Relations Plan. Design documents were also prepared
8
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between August and September 1990 that included a design report and plans and specifications for
site remediation.6
Summary of the Remedial Investigation. During the remedial investigation, CDM discovered that
records concerning the exact nature and quantity of wastes disposed onsite were not available.
Information obtained from representatives of the Cape Fear Wood Preserving Company, however,
indicated that the only chemicals used in the wood preserving processes were creosote and
wolmanizing salts containing a copper-chromium-arsenic mixture. The type of carrier oil was not
identified.
Past investigations indicated extensive site contamination with polycyclic aromatic hydrocarbons
(PAHs), and to a lesser extent, copper, chromium, and arsenic. The soil was contaminated in several
areas. In addition, volatile organic compounds (VOCs) resulting from a leaking underground storage
tank were observed at the site in a localized area. Even though most of the soil contaminants have
a low water solubility, the close proximity of the groundwater to land surface had apparently
facilitated the migration of contaminants into the groundwater system, as evidenced by contaminated
groundwater samples.
Summary of the Feasibility Study. As part of the feasibility study project, cleanup goals were
derived for chemicals of concern at the Cape Fear Site. Chemicals of concern and exposure pathways
had been detailed in a previously conducted risk assessment and were reviewed where pertinent to
the derivation of cleanup goals. Potential remedial technologies were also identified and screening
was conducted to eliminate treatment and containment options that were not feasible or were
impractical.
Summary of the Record of Decision. The ROD was issued by EPA in June 1989 and mandated
remediation of groundwater, soils, sediments, and surface water bodies. In addition, various waste
materials stored onsite were targeted for cleanup. EPA's preferred remedy for soils was either soil
washing or low temperature thermal desorption to remove organic contaminants followed by either
soil washing or solidification to address the inorganics. EPA desired to determine the most suitable
remedy for mitigation of soils based on results of treatability studies to be conducted during the RD.
Summary of the Remedial Design. A design was developed to incorporate EPA mandates identified
in the ROD. A flow diagram showing the various mitigation pathways is presented in Figure 3. This
flow schematic formed the basis of resulting design documents. In addition, CDM performed
treatability studies and conducted various field investigations at the site during the remedial design.
The resulting product of the RD included a design report and plans and technical specifications for
site remediation.
DISCUSSION
Fast-Tracking Remedial Design Projects
Fast-tracking is a technique used to optimize project schedules by manipulating the tasks required
to complete the overall project. Fast-tracking generally eliminates and/or rearranges the tasks
involved in a project. Because tasks are often interrelated, eliminating tasks must be done carefully
to avoid problems later in the project. Rearranging the order or timing in which the tasks are
performed can expedite the overall project schedule. The less complex a project, the more amenable
it is to fast-tracking. In addition, projects that display particular traits are more easily accelerated
using fast-tracking techniques. These characteristics and their application to the Cape Fear Site are
discussed below.
9
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The Proposed Remedy Utilizes a Proven Technology. Soil washing is a proven technology but
remains in the developmental stages for full-scale implementation. Low temperature thermal
desorption, although proven to be effective on certain organic contaminants, minimum temperatures
required to volatilize PAHs were unknown. In addition, because the ROD did not specify particular
technologies, additional evaluation was required before the design could begin. As a result, this trait
was not characteristic of the Cape Fear project.
Treatabilitv Studies Mav Not be Required. Alternately, they may have already been completed during
the remedial investigation or feasibility study, and only minimal additional field data are required.
Again, a treatability study was required by the ROD for the Cape Fear Site, so this trait was not
typical for this project.
A Value Engineering Study Mav Not be Required. A value engineering study was included in the
original Cape Fear Site scope of work but was eliminated as part of the fast-tracking process.
Although a value engineering study was not conducted, CDM reconciled this by conducting internal
formal technical reviews, which allowed CDM to expedite the schedule without sacrificing quality
of the design product.
Intermediate Design Tasks Mav Not be Required. The intermediate design task was included in the
original scope of work, but was eliminated to expedite the project schedule. Continual
communication between CDM and EPA was crucial during this phase of the project to avoid
additional design revisions.
The Site and Conditions Present no Unusual Property Access Problems or Permitting Requirements.
The Cape Fear Wood Preserving Company is no longer in operation and the owners have been
responsive to EPA's involvement in remediation of their property. In addition, environmental
permitting requirements are expected to be minimal (i.e. an NPDES permit for discharge of treated
water from the site will be required). Therefore, this characteristic applied to the Cape Fear project.
Evolution of the Scope of Work
The decision to fast-track the remedial design at the Cape Fear Site was not made during the initial
planning stages. In fact, it was decided after approval of the Work Plan and after an actual date had
been established by EPA for delivery of the final design. This section describes how the scope of
work evolved throughout the project. An overview of the project history is shown in timeline form
in Figure 4.
The original scope of work prepared by EPA consisted of twelve tasks. These tasks are presented in
Table 1. During the initial scoping meeting in October 1989 between CDM and EPA, it was decided
that the soil washing pilot study would be incorporated into the remedial action phase. A treatability
study originally proposed for treatment of contaminated aqueous streams, was eliminated during this
meeting since it was determined that standard technologies could be used to treat these streams based
on expected contaminant levels. It was further decided to postpone the bid evaluation process until
the remedial action phase.
By November 1989, CDM had completed draft versions of the Remedial Design Work Plan, the Field
Operations Plan, the Health and Safety Plan, and the Community Relations Plan. These plans were
reviewed by EPA and approved in January 1990 with an agreed upon completion date of September
28, 1990 for delivery of final design documents. CDM then began subcontractor procurement
activities; however, bid packages sent out for drilling services, geotechnical services and soil washing
treatability testing had unforseen complications which precluded subcontract award consistent with
the approved work plan project schedule. These complications included lack of bidder response and
10
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low bids exceeding the budgeted subcontract amount. Field activities were subsequently delayed.
In March 1990, an additional change in scope was made. In order to be eligible for remedial funds,
a design, complete with drawings and specifications, needed to be completed by the end of the third
quarter of the fiscal year. Therefore, to ensure funding; EPA divided the remedial design efforts into
two operable units. The first phase, which was not dependent on the results of field work and
treatability study, would be expedited and completed by June 30, 1990, and the design for the second
phase would be completed no later than October 31, 1990. CDM then prepared and submitted a
preliminary design report for the first phase of the design on April 16, 1990.
Shortly thereafter, EPA decided to combine the remedial design of both operable units, and sought
to have final design documents submitted to EPA by the end of September 1990. This gave CDM
approximately 5 months to complete the design. To expedite the schedule, it was necessary for CDM
to modify the critical path schedule and associated tasks. After careful evaluation of work assignment
tasks, CDM developed a fast-track schedule for implementing the remedial design. It was imperative
that no delays in the field work or the treatability study occur and that CDM receive concurrence
with EPA, the State of North Carolina, and the U.S. Army Corps of Engineers on critical design issues
at the 30% design phase. In addition, EPA and peer review would be reduced from four weeks to
three weeks. This latest change in scope required that all field work begin on April 30, 1990 and the
treatability study start on May 7, 1990. The final scope of work, dated April 1990 included the
results of fast-tracking and is presented in Table 2.
Techniques Used for Fast-Tracking
Virtually all remedial design projects can take advantage of fast-tracking techniques to expedite
schedules; however, certain fast-tracking techniques used on some projects may not be applicable to
others. EPA has identified the following techniques that can be used to fast-track remedial design
projects.7
Reduce the Detail Required in the Design Documents. This may include eliminating detailed design
drawings (plans) and specifications and instead preparing a site layout drawing and a basic description
of the work to be performed. This works best for simple remediation sites, such as pump and treat
systems or excavation and disposal of small quantities of contaminated soil. If the recommended
cleanup is more complex, the use of "performance" type specifications can be used. Performance
specifications are written to specify certain performance criteria that a contractor must meet, and do
not involve detailed equipment specifications that require more time to develop.
Use Standardized Sets of Specifications. Many engineering firms have developed standard "generic-
type" specifications that are used from one project to another. In addition, various equipment
manufacturers have prepared standard sets of specifications for specific treatment equipment.
Caution should be exercised in their use, however, since they are general in nature, and the proper
modifications should be made to incorporate site-specific conditions and issues.
Use Existing Plans. Where possible, information from existing plans previously prepared during the
remedial investigation and feasibility study stage should be used, such as a Health and Safety Plan,
Quality Assurance Project Plan, and Community Relations Plan. Although the actual plans may not
be reusable, information relating to site conditions and nature of contamination may be used to help
prepare the corresponding plans for the remedial design.
Provide Project Continuity. For an EPA-lead site, considerable time is saved in the transition from
the ROD to remedial design if the same EPA contractor performs the remedial investigation,
11
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feasibility study and the design. The benefits are that EPA already has a working relationship with
the firm and the firm has an established project file and is familiar with the site.
Expedite Access Agreements. Site access agreements during the remedial investigation and feasibility
study phase should be structured to also allow for site access during design activities. Access and real
estate concerns can be very time consuming and complicated. Considerable time is saved if these
concerns are addressed early in the project.
Conduct Parallel Design Reviews. Time is saved if design reviews are scheduled in parallel with
continuing design work so they are not on the critical path. In many cases, review of design
documents by state agencies and oversight firms can take place concurrently with EPA review.
Another time-saving technique is to invite agency personnel to in-house technical reviews conducted
by the engineering firm during early stages of the project. By doing this, EPA concerns are
incorporated concurrently with review comments identified by the engineering firm.
Schedule Value Engineering Studies Efficiently. If a value engineering study is required, it should
be scheduled separately from the design critical path. The results of the value engineering study
should be incorporated into final design documents.
Almost all of these fast-tracking techniques were used to some extent during the Cape Fear project
as depicted in Table 3.
The fast-tracking techniques discussed above can be applied to any remedial design project. Each
project, however, should be evaluated on a site-specific basis to determine the most appropriate
means to expedite the schedule. In other words, a strategy should be developed to expedite the
project that is best suited to meeting project-specific milestones and client objectives.
As the scope of work evolved for the Cape Fear project and the need to fast-track the design became
more evident, a logical plan was developed to meet the schedule objectives of EPA. This plan
contained four key components:
o Eliminating unnecessary design tasks
o Combining intermediate and prefinal/final design tasks
o Efficient planning of the treatability study
o Conducting a 30% design review meeting with EPA
Each of these techniques was used by CDM to fast-track the design and prepare a final project
schedule as shown in Figure 5.
Elimination of Unnecessary Design Tasks. In order to meet EPA's September 30th deadline, CDM
proposed to eliminate several design tasks (or subtasks) identified in the original work plan that were
not required to meet objectives of the final deliverable documents. The subtasks eliminated included
preparing a separate treatability study report, conducting a value engineering study, and preparing
a complete bid package. A separate treatability study report was not required since it was decided
to incorporate this report into the design report. A value engineering study was deleted due to time
requirements to conduct the study and the fact that extensive quality assurance measures allowed for
in-house reviews prior to document submittal. Finally, a decision was made by CDM and EPA to
limit design documents to technical specifications and drawings during the design phase. That is,
CDM prepared technical specifications and drawings without specific bidding instructions and
12
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contract terms and conditions. These "front-end" contractual documents would be incorporated as
a first task under the remedial action phase.
Two other subtasks were eliminated as a result of combining the intermediate and prefinal/final
design tasks (described in detail below). These included preparing a final design report and preparing
intermediate design plans and specifications representing 60% design completion.
Combining Intermediate and Prefinal/Final Design Tasks. A second component used in fast-tracking
at the Cape Fear Site involved combining the intermediate and prefinal/final design tasks into one
final design task. The original scope of work included the following three tasks for the design portion
of the project:
(1) Preliminary Design (comprised of four subtasks: performing a groundwater extraction
analysis, designing a water treatment system, designing a soil treatment system, and preparing
a preliminary design report)
(2) Intermediate Design (comprised of two subtasks: preparing a final design report and preparing
60% plans and specifications)
(3) Prefinal/Final Design (comprised of two subtasks: revising the 60% plans and specifications
for a 90% design submittal and revising the 90% plans and specifications for the 100% design
submittal)
The final scope of work for the design portion using fast-tracking included two tasks:
(1) Preliminary Design (comprised of five subtasks: performing a groundwater extraction analysis,
designing a water treatment system, designing a soil treatment system, preparing a single
design report, and preparing 90% plans and specifications)
(2) Final Design (comprised of one subtask: revising the 90% plans and specifications for the
100% design submittal)
The net result was the elimination of two subtasks. In addition, the design report and 90% plans and
specifications were prepared concurrently and submitted to EPA at the same time. This resulted in
only one design review prior to preparation of the final design documents. In order to overcome this
possible shortfall in quality assurance, a 30% design review meeting was added as a critical component
of the fast-tracking plan that occurred prior to beginning the design report and 90% design
documents.
Efficient Planning of the Treatabilitv Study. A third technique used to fast-track the remedial
design involved careful scheduling of the treatability study so that results of the study would be
available at the appropriate time. The treatability study was conducted in approximately 15 weeks
and involved bench-scale testing for soil washing, low temperature thermal desorption, and
solidification. Since the objective of the treatability study was to determine the most suitable
treatment technology for contaminated soils, it was critical that the final results be available prior to
the final design task. The treatability study was planned so that the results of soil washing and
thermal desorption would be available prior to beginning the design report and 90% plans and
specifications, and the results of the solidification test were available prior to beginning the final
design submittal.
Conducting a 30% Design Review Meeting With EPA. A final component of the fast-tracking
strategy, and perhaps the most important, was conducting a 30% design review meeting with EPA and
13
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peer review parties. The purpose of this meeting was to review all work performed by CDM to date
and resolve critical design issues to allow for project completion by the September 30th deadline. The
30% design review meeting was a working session conducted before starting work on the design report
and 90% plans and specifications. The meeting was attended by EPA, State representatives, the U.S.
Army Corps of Engineers, and CDM project staff. Key design factors were discussed and agreed
upon by all parties. These design factors included methods of water and soil remediation, methods
of hazardous materials remediation, preferred discharge alternative for treated water, and type and
format of the design documents. In order to proceed with subsequent design tasks and meet the
agency deadline, it was important to resolve these design factors early in the project.
Keys to Successful Fast-Tracking
Based on CDM's design experience at the Cape Fear Site, four key factors have been identified that
are critical to the success of fast-tracking a remedial design project.
Develop a Schedule and Abide by It. A schedule for fast-tracking should be developed as soon as
the need arises to expedite the project. Assumptions used to implement the schedule should be
written down and discussed with the client. Most importantly, the schedule should be rigorously
adhered to, and when deviations arise, necessary modifications should be made so that project
deadlines are maintained.
Maintain Communication With the Client. Constant communication with the client is a must when
implementing a fast-track design project. This can be accomplished through weekly status reporting
and/or conducting regular briefings to inform the client of the project status and any expected
deviations in the project schedule. It is important for the client to understand the complexity of each
task, how long it will take, and if the task is on the critical design path.
Resolve Critical Design Issues Early On. Immediate steps should be taken after conducting site
investigations and evaluating the data to define key design factors, determine or estimate these
factors, and obtain client "buy-off. Critical design factors may include treatment flow rates, volumes
of soil and groundwater targeted for cleanup, disposal alternatives, specific methods and technologies
for remediation (if not already defined in the ROD), preliminary equipment sizing, estimated
treatment duration, budgetary costs for site remediation, and type and format of the final design
documents. This was accomplished on the Cape Fear project by conducting a 30% design review
meeting with the client and review parties. The objective is to determine key design parameters early
in the project and obtain client concurrence so that subsequent tasks can be completed on time.
Plan and Implement Efficient Use of Staff Resources. Schedule compression due to fast-tracking
results in more staff resources being utilized over a shorter period of time. Before fast-tracking
commitments are made, adequate and qualified staff should be identified and assigned to the project.
The client should be aware of increased staffing requirements that results in additional coordination
efforts which may lead to increased project costs. These increased costs may, however, be offset by
cost savings related to shortening the project
schedule and eliminating certain tasks.
CONCLUSIONS
Fast-tracking the remedial design was used successfully at the Cape Fear Site to meet EPA-established
deadlines, and resulted in shortening the project duration by about two months. This is considered
exceptional due to the fact that the original project schedule was based on virtually no slack time and
assumed that procuring of subcontractors and conducting field work would take place without delay.
The results of fast-tracking also revealed that in a 5-month period the following tasks were
14
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successfully completed: an extensive site investigation lasting over one month that involved five
subcontractors, a 15-week long treatability study utilizing three subcontractors, and design of site
remediation resulting in a two-volume design report and complete technical specifications and
construction drawings to be used in selecting a contractor for cleanup.
It should also be noted that this project did not exemplify some of the characteristics of projects most
suitable for fast-tracking. This is demonstrated by the fact that the proposed treatment technologies
for soil remediation were either unproven technologies or in the early developmental stages. For
instance, soil washing has never been used on a full-scale basis at a Superfund site and solidification
of PAH compounds is relatively new. As a result, treatability studies were required for this project
to identify a suitable soils treatment scheme.
Fast-tracking techniques used at the Cape Fear Site included those identified in EPA guidance
documents and others implemented by CDM based on project-specific conditions, including:
elimination of unnecessary design tasks, combination of intermediate and prefinal/final design tasks,
proper scheduling of the treatability study, and conducting a 30% design review with EPA.
Keys to successful fast-tracking on remedial designs include dedication to a rigid project schedule,
maintaining constant communication with the client, identifying and resolving key design factors
early on, and making the most efficient use of staff resources.
REFERENCES
1. NUS Corporation, Geological and Sampling Investigation Report. Cape Fear Wood Preserving
Site. Favetteville. North Carolina. U.S. Environmental Protection Agency Superfund Division,
1986.
2. Camp Dresser & McKee Inc., Final Remedial Investigation Report for Cape Fear Wood
Preserving Site. Favetteville. North Carolina. 391-RR1-RT-GMRF, Prepared for U.S.
Environmental Protection Agency, 1988.
3. Camp Dresser & McKee Inc., Draft Final Feasibility Study Report for Cape Fear Wood
Preserving Site. Favetteville. North Carolina. 391-FS1-RT-GTAY, Prepared for
Environmental Protection Agency, 1988.
4. U.S. Environmental Protection Agency, Record of Decision for the Cape Fear Wood
Preserving Site. Favetteville. North Carolina. U.S. Environmental Protection Agency, Atlanta,
Georgia, 1989.
5. Camp Dresser & McKee Inc., Final Work Plan for the Cape Fear Wood Preserving Site.
Favetteville. North Carolina. 7740-002-WP-BBMR, Prepared for U.S. Environmental
Protection Agency, 1990.
6. Camp Dresser & McKee Inc., Remedial Design Report for the Cape Fear Wood Preserving
Site. Favetteville. North Carolina. 7740-002-DR-BBWH, Prepared for U.S. Environmental
Protection Agency, 1990.
7. Office of Emergency and Remedial Response, Guidance on Expediting Remedial Design and
Remedial Action. EPA/540/G-90/006, U.S. Environmental Protection Agency, Washington,
DC, 1990, pp 15-21.
15
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Figure 1 Site Location Map.
-------
FORMER CREOSOTE
UNIT SUMP
OLD CREOSOTE/
CCA UNIT
V SANDERS
ARESIDENCE
V
\
JACKSON
RESIDENCE
CCA RECOVERY
SUMP
FORMER CCA
UNIT
SEASONAL
-iinT
* SWAMP
STORAGE
TANKS
FORMER LAGOON
STORAGE TANKS
CLEARED AREA
— — SURFACE WATER DRAINAGE
100
100
SCALE IN FEET
CONCRETE PLANT
DISCHARGE POND
Figure 2 Site Features Map.
-------
00
CCA SALT CRYSTALS
PICKED UP
[SOLIDIFIED CREOSOTE)-
EXCAVATION
ASBESTOS INSULA
TTONJ-
| UNDERGROUND TANK^-
EXCAVATION
ABOVE GROUND
TANKS/PIPING
LIQUID CONTENTS
REMOVED
1
1
J
;KACED| —
~|
LIQUID CONTENTS
REMOVED
1 1 1
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TANK
» RCRA
• LANDFILL
CUMBERLAND
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IF CONTAMINATED
REMOVED
TANKS
DECONTAMINATION OF
TANKS AND PIPING
TANKS
TESTED
IF CLEAN
DECON. WASHWATER
LIQUID CONTENTS
METAL CUT AND SOLD FOR
SCRAP OR SENT TO CUMBERLAND
COUNTY SOLID WASTE FACILITY
SLUDGE
CONTAMINATED FINES
UOUB CONTENTS
RAW SOIL
OFFSITE METALS
TREATMENT FACILITY
CONTAMINATED GROUNDWATER
r-
1
ETC
EQU
, ,
ALIZ
WASHING
CLEAN SOIL
WASHWATER ,
ACTIVATED CARBON ADSORPT
BIOTI
SO
t
RETURNED TO
EXCAVATION
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REATMENT OR REMANING 1
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.
T f
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TREATED WATER f*
HOLDING TANK
EFFLUENT TRANSFER
PUMP
;RA FACILITY
ONE EXTRACTION
WELL * PUMP
(DEEP AQUIFER)
Figure 3 Remedial Design Process Flow Diagram.
-------
Conduct —
Field Work
1989
Signed
Original
Work
Asstgment
Form to
Begin
Work
Original
Scoping
Meeting
*
J
nt
*
cw
Sub
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Proj
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Pro
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Oct
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mits
Ft
led
is
L4
imits
y
lect
is
Nov
Dec
Jan | Fee
FPA
Changes to
Phase Site
Design
Approach
Mar
Apr My
Submits
Preliminary
Design Report
for Phased Site
Design Approach
1
1
Jun
Jul
1
*
Conduct 1 30% -J
Treatability Design
Study Meeting
COM
Submits
Preliminary
Design Repor
and Draft
Design
Documents
to EPA
1
t
Sept
1990
Changes to
Single Site
Design Approach
Submits
Final Design
Documents
to EPA
Figure 4 Project Timeline.
-------
1990 Apr
May
Jun
Jul
Aug
Sept
Oct
TASK NAME
Reissue Field Bid Packages
Bid Period-Field Subcontract
Eval/Awaid Field Subcontract
Field Contract Execution
Conduct Field Work
Analytical Testing-Field Data
Award Treat Study Subcontract
Treat Study Contract Execution
Conduct Treat Study
Conduct Endangered Species Suv
Evaluate Data & Dev 30% Design
Present 30% Design to EPA
Prepare Fact Sheet No. 1
Submit Fact Sheet No. 1
Perform GW Extraction Analysis
Design GW Treatment System
Design Sol Treatment System
Prepare Design Report
Submit Design Report
EPA Review Design Report
Prepare 90% Plans/Specs
Submit 90% Plans/Specs
EPA Review 90% Plans/Specs
Prepare Fact Sheet No. 2
Submit Fact Sheet No. 2
Prepare 100% Plans/Specs
submit 100% nans/specs
Project Completion and uoseout
4
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Figure 5 Final Project Schedule.
-------
Table 1 Tasks included in the orginal scope of work (January 1990).
Original Scope of Work
1. Project Planning
2. Field Data Acquisition/Sampling and Analysis
3 Treatability Study - Pilot/Bench Scale Tests
4. Data Evaluation
5. Preliminary Design
6. Intermediate Design
7. Prefinal/Final Design
8. Design Support Activities
9. Value Engineering
10. Community Relations Support
11. Bid Package Preparation
12. Project Completion and Closeout
Table 2 Tasks included in the final scope of work (April 1990).
Final Scope of Work
1. Project Planning
2. Field Data Acquisition/Sampling and Analysis
3. Treatability Study - Bench Scale Test
4. Data Evaluation
5. Preliminary Design - presented at 30% Design Meeting
6. Final Design
7. Design Support Activities
8. Community Relations Support
9. Project Completion and Closeout
21
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Table 3 Fast-Tracking Techniques Used at the Cape Fear Site
Technique
Party
Implemented
Applicability to the Cape Fear
Project
Reduce design
detail
Use standardized
specifications
Reuse existing
plans
Provide project
continuity
Expedite site
access
Conduct parallel
design reviews
Keep value
engineering study
off critical path
Engineer
Engineer
Engineer
EPA
EPA
EPA
None
Complex design required preparation of plans and
specifications. CDM used "performance" type
specifications extensively.
CDM used previously prepared in-house
specifications and modified them for site-specific
conditions.
CDM conducted the remedial investigation and
feasibility study and therefore was able to reuse the
Health and Safety Plan, Community Relations Plan,
and Quality Assurance Project Plan to expedite
remedial design planning.
CDM was selected for the remedial design
primarily because of its previous experience with the
remedial investigation and feasibility study. This
knowledge of the site helped expedite the remedial
design.
The site is abandoned and the current property
owner is cooperative in allowing site access to conduct
investigations during the remedial design.
EPA conducted concurrent design review with the
State of North Carolina and the U.S. Army Corps of
Engineers.
A value engineering study was eliminated in order
to expedite the remedial design.
2?
*• •—
-------
Ambient Air Quality Management
at French Limited Superfund Site
(Author(s) and Address(es) at end of paper)
INTRODUCTION
A subject often overlooked in the design of remediation
projects is ambient air impacts of the remediation process. It
was, however, recognized early in the remedial investigation
phase of the French Limited Superfund project that volatile
organic compounds could create ambient air concerns during
remediation. As a result, ambient air impacts issues have been
considered throughout the preliminary planning and conceptual and
final design phases of the French Limited remediation project.
This paper presents the sequence of steps that evolved into
the final Ambient Air Management Program at the French Limited
site. First, a description of the site and of the early phases
of the project are presented. The importance of the cooperative
effort between the responsible parties and the U.S. Environmental
Protection Agency (EPA) is also discussed. The paper then
presents a more detailed description of the in-situ
bioremediation demonstration phase of the project that drove the
final Ambient Air Management Program. A discussion of the role
of risk assessment is presented, followed by details of the air
management system to be used during the final remediation
activities at the site. It is hoped that the concepts outlined
here will serve as a future model for similar sites, enabling air
impacts to be more easily addressed at all sites.
BACKGROUND
The French Limited Superfund site located northeast of
Houston, Texas, is a former sand pit that is now a 7.3-acre
lagoon that contains a 4- to 12-foot layer of petrochemical
sludge residue under 12 to 20 feet of water. The sludges were
deposited between 1966 and 1972 by French Limited, Inc., a
contract waste disposal business permitted by the state of Texas.
During its brief operating period, numerous companies used the
disposal facility.
Initial remedial investigations were performed by EPA, who
placed the site on the Superfund National Priorities List in
1982. A coalition of about 80 companies who used the disposal
facilities and were identified by EPA as Potentially Responsible
Parties for site remediation formed the French Limited Task Group
in 1983. ENSR was contracted by the Task Group to provide a wide
range of environmental consulting and engineering services for
remediation of the site.
Initial Investigations
The Task Group voluntarily accepted responsibility for
proceeding with the site's remedial investigation and feasibility
study (RI/FS) under the supervision and oversight of EPA and the
Texas Water Commission (TWC). The investigations determined that
23
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the primary hazardous waste problem stemmed from the sludges on
the lagoon bottom. While not posing an immediate threat because
of the water cover, the site posed a long-term threat to public
health and the environment, and remediation was required.
Sampling and analysis of the sludges revealed a broad
mixture of petrochemical compounds including a number of EPA
priority pollutants. The RI also confirmed that the
contamination had migrated into the groundwater. Fortunately,
the lagoon is isolated, and adequate time is available for site
remediation before contaminant migration becomes a public health
threat.
In 1986, the Task Group faced new Superfund regulations
emphasizing waste destruction as a preferable remedial
alternative. EPA favored incineration as the remedy for the
French Limited site.
The chairman of the Task Group's Technical Committee,
Richard E. Sloan of ARCO Chemical Company, examined the basis for
EPA's incineration preference. He found that EPA had not given
serious consideration to biological remediation because no
technical database existed to show that the technology could be
successfully applied to the French Limited site. Recognizing the
potential for cost and time savings using bioremediation, the
Task Group obtained EPA approval to perform laboratory studies to
determine whether the technology was applicable. Based on
positive results from the laboratory studies, further EPA
approval was obtained for a large-scale biodegradation field
evaluation using 20,000-gallon treatment tanks on the shore of
the lagoon. The field evaluation performed in March 1987 again
strongly supported the feasibility of applying biological
technology at the site.
EPA and TWC held a public meeting to announce that, while
incineration was the preferred remediation alternative for the
site, based on a request and positive preliminary data from the
Task Group, they would authorize a 6-month in-situ biodegradation
demonstration before making a final remedial decision.
The in-situ demonstration was successfully completed and the
results reported in October 1987.
EPA then completed its review of the technical database and
process results achieved during the on-site demonstrations. In
a January 1988 public meeting, EPA and TWC reversed their
previously announced preference for on-site incineration, and
indicated that the biodegradation technology proposed by the
French Limited Task Group was the preferred site remedy. After
a public comment period, and evaluating all recommendations and
comments, EPA signed the Record of Decision for bioremediation at
the French Limited site in April 1988.
24
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Ambient air quality management issues are discussed in
greater detail for the in-situ bioremediation demonstration and
final design program in the remainder of this paper.
PROJECT MANAGEMENT
Special approaches requiring variations of standard
industrial wastewater biological treatment were needed due to the
characteristics of the sludges and contaminated subsoils.
Because the chosen remediation method was a new engineering
application that had to be completed within a short timeframe,
ENSR developed and established a project management system that
emphasized open communication among all parties.
From the beginning, the management approach emphasized open
communications regarding all aspects of the project. To ensure
that all parties would have adequate review time and to allow
opportunities for suggestions and redirection of the project
elements, Task Group Chairman Sloan insisted upon immediate data
availability to all involved parties, including EPA and TWC.
Daily status review meetings were conducted at the site
during the in-situ biodegradation demonstration, providing
coordination among Task Group, ENSR, and agency oversight
personnel. These meetings maintained daily understanding of
project status and progress, and allowed regular definition and
resolution of issues and problems as they arose.
The Task Group, ENSR, and EPA regional and oversight staff
held weekly meetings during the demonstration to review all
technical data obtained during the previous week, and discuss
project status. As the technical database and field evaluation
evolved, these meetings were used to adjust the direction and
details of project activities to ensure that a complete technical
database would be available upon completion of the demonstration.
Community Information Program
An important aspect of the immediate and open communication
program for the French Limited project was a community
information program. This proactive communications program gave
all residents in nearby areas the opportunity to hear regular
presentations describing the project approach, current status and
accomplishments, and final results. The Task Group retained the
public relations firm of Goldman & Co. of Houston to manage this
important communications link, and coordinate all other aspects
of media interest in the project.
Shortly after project initiation, slide presentations of the
process operations were presented on a regular basis to community
leaders and area groups, as well as to local, state, and federal
governmental representatives. Because of the unique nature of
25
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the project, media interest was high, and open communication of
the approach and results to the media became another critical
component of the program.
The project management and communications approaches were
integral to the success of the on-site biodegradation
demonstration and EPA's decision to allow bioremediation at the
site, and will contribute ultimately to the final cleanup of the
site. The approaches created an environment in which issues and
ideas, judgment concerns, redirections, and refinements were
sought from everyone associated with the project, from regulatory
agency and responsible industry parties to independent experts
and community residents. This resulted in a continually updated
understanding and refinement of project goals and achievements,
and allowed prompt and informed conclusions to be reached to the
benefit of all concerned (Sloan, 1987).
IN-SITU BIOREMEDIATION DEMONSTRATION
Air issues were considered during the earliest phases of the
project, including remedial investigations, laboratory studies,
and pilot bioremediation studies. It was during the in-situ
bioremediation demonstration that ambient air management became
a prominent feature of the overall remediation project. The
following discussion describes the monitoring program put in
place during this phase of the program.
Based on the preliminary studies at the site, several
naturally occurring aerobic bacteria were identified which were
thought to show promise as organic biodegraders if their activity
could be stimulated and enhanced through the addition of balanced
nutrients and oxygen to the system.
A 6-month air monitoring program was one part of the
comprehensive environmental monitoring plan associated with the
overall bioremediation demonstration project. The environmental
monitoring plan encompassed air, groundwater, and health and
safety issues. A more comprehensive description of the
bioremediation demonstration program can be found elsewhere
(Sloan, 1987). The remainder of the discussion will focus on the
air issues associated with the site.
The air monitoring program at the site was constructed to
respond to concerns of off-gassing of hazardous constituents in
the sludge during the addition of oxygen in the form of air
sparged into the sludge and lagoon water. The goals of the air
monitoring plan for the bioremediation demonstration at the
French Limited site were to:
• Measure on-site and site property line impacts of air
emissions from the bioremediation processes.
26
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• Protect the health and safety of both on-site personnel
and off-site general public.
The resulting data from this phase of the project were also
to be used to design the appropriate program for the final
remediation option.
Methods
The objectives of the air monitoring program were addressed
by monitoring the following five separate groups of variables.
1. Continuous measurement and recording of meteorological
data (wind speed, wind direction, temperature, relative
humidity, barometric pressure, and precipitation).
2. "Real-time" measurements of total ionizables using
photoionization detector (HNu) measurements.
3. "Real-time" syringe sampling for volatiles using on-
site gas chromatograph (GC) analysis.
4. "Real-time" sampling of the semi-volatile naphthalene
using charcoal absorbent with on-site GC analysis.
5. "Time-integrated" sampling for volatiles by collection
on Tenax solid absorbent followed by gas
chromatography/mass spectrometry (GC/MS) laboratory
analysis.
Three different monitoring levels were used during the
course of the project. The most intensive phase (Phase I) was
used during the first 3 days of each different operational stage
in the bioremediation program (i.e., air sparging, air sparging
with sludge pump mixing, and subsoil dredging). A second,
slightly lower-intensity phase of monitoring (Phase II) was used
after the initial impact of air emissions had been assessed from
"real-time" measurements taken during Phase I monitoring. The
Phase II level monitoring was better suited to daily routine
monitoring throughout lengthy operational stages of the
demonstration project. A third, lower-intensity level (Phase
III) was begun after Phase II monitoring showed only low levels
of air emissions associated with the demonstration project. The
Phase II results indicated that air monitoring goals could be
accomplished using a lower monitoring intensity.
The sampling frequency and the technical methods employed in
each of the three phases of air monitoring are described in the
following paragraphs. The use of the term "lagoonside" refers to
a sampling location at the edge of the lagoon bank, approximately
5 to 7 feet from the water's edge. The term "fenceline" refers
27
-------
to a sampling location at the French Limited site property
boundary.
Phase I monitoring consisted of:
• Eight-hour, "time-integrated" Tenax samples taken at
five locations (one upwind, two downwind lagoonside,
two downwind fenceline) each shift, three shifts per
day (day, evening, night).
• "Real-time" syringe sampling at three locations (one
upwind, one downwind lagoonside, one downwind
fenceline) each hour for 8 hours per day.
• "Real-time" naphthalene monitoring each hour at one
location (downwind lagoonside) for 8 hours per day.
• "Real-time" total ionizables (e.g., HNu) measurements
hourly at the same time and location as each "real-
time" syringe sample.
Phase II monitoring consisted of:
• Eight-hour, "time integrated" Tenax samples taken at
three locations (one upwind, one downwind lagoonside,
one downwind fenceline) once per day.
• "Real-time" syringe sampling taken at three locations
(one upwind, one downwind lagoonside, one downwind
fenceline) four times per day.
• "Real-time" naphthalene monitoring four times per day
at one location (downwind lagoonside).
• Total ionizables (e.g., HNu) measurements at least four
times per day at the same time as each "real-time"
syringe sample.
Phase III monitoring consisted of:
• Eight-hour, time-weighted-average Tenax samples taken
at two locations (upwind and downwind fenceline) each
day.
• Total ionizables (e.g., HNu) measurements taken hourly.
Meteorological Measurements
A free-standing 10-meter tower was constructed at the site
and used to determine the following meteorological parameters:
wind direction, wind speed, temperature, relative humidity,
barometric pressure, precipitation, and sigma theta.
28
-------
Meteorological data from the on-site station were used to locate
sampling variations and to correlate air impact data collected
with relevant wind conditions.
"Real-Time" Measurements
Three "real-time" measurements were conducted at the site
during the demonstration project as a means for daily checks on
air impacts within a timeframe to allow for mitigating actions to
take place if necessary. These measurements were designed to
address air program goals relating to the protection of health
and safety of both on-site and off-site personnel, and to develop
a database defining instantaneous contaminant concentration
levels. The real-time analyses were used by site operations
managers in controlling the level of air impacts by reducing and,
if necessary, shutting down operations if pre-assigned "action
level" concentrations were reached. The real-time measurements
included: total ionizables (e.g., HNu) measurements, on-site
determination of target volatile organics, and on-site
determination of the semi-volatile naphthalene.
Throughout the in-situ biodegradation demonstration, air
concentrations were monitored and compared with preset
concentration limits. In the real-time impact monitoring
program, the concentration levels of seven compounds were
monitored, four and eight times per day, in Phase II and Phase I
schedules, respectively. These compounds are shown in Table 1
with their 1987 OSHA 8-hour threshold limit values (TLVs) and the
action levels that would require reduced intensity of aeration
and/or sludge mixing.
Detection of any one of the compounds during the lagoonside
sampling at the following concentrations, for the indicated
number of samples, required the indicated operating response.
Number of collected
Samples Concentration Operating Response
1 TLV Immediate resample
and, if verified,
system shutdown.
2 Action Level Reduced aeration or
mixing operation.
4 Action Level System shutdown.
Target compounds were selected to be representative of
expected emissions based on pilot-scale experiments conducted
prior to the demonstration project.
29
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TABLE 1
Target Compounds Action Levels
Lagoons ide
Action Level
Compound TLV (ppm)
Benzene 10.0 5.0
Toluene 200.0 100.0
Ethylbenzene 100.0 50.0
Trichloroethene 100.0 50.0
Tetrachloroethene 100.0 50.0
Chloroform 50.0 25.0
Naphthalene 10.0 5.0
30
-------
A second curtailment criterion was based upon HNu readings
taken at the fenceline sampling locations. A reading in excess
of 1.0 ppm above background required immediate reduction in
aeration/mixing operations, and, if the 1.0-ppm reading continued
for 30 minutes, system shutdown was required.
Volatile Target Compound Monitoring. Real-time volatile target
compound monitoring consisted of determination of six organic
compounds: chloroform, benzene, trichloroethene, toluene,
tetrachloroethene, and ethylbenzene. These compounds were
selected based on emissions characterized from laboratory and
pilot studies on the lagoon sludge. Two GCs equipped with
photoionization detectors (Photovac 10S50) were used for the
target compound determinations. These chromatographs were
located in the field laboratory, where the samples were analyzed
and data reduced on-site. Grab samples were collected manually
using 1.0-ml gas-tight syringes. Samples were taken directly to
the field laboratory for analysis.
The specific sampling locations (upwind and downwind)
selected for each sampling event were based upon the
meteorological conditions existing at the time. Each sample was
collected from one of 36 pre-selected sampling stations shown in
Figure 1. The specific sampling location was selected to be
nearest to the then-current wind direction.
All GC data were reduced on-site and the results were posted
on a central data board located in the field operations office.
Quality assurance procedures included collection of blanks and
collocated samples. Calibrations for the six target compounds
were conducted at least twice daily from a certified gas mixture
of each component.
Naphthalene Monitoring. Naphthalene is the most volatile of the
polynuclear aromatic (PNA) compounds and was known to be present
in the lagoon sludge. As such, naphthalene was identified as the
PNA most likely to be released during the demonstration project.
NIOSH analysis Method 1501 for aromatic hydrocarbons, used
for determination of naphthalene analysis, was performed in the
field laboratory using a GC (Hewlett Packard 5990) equipped with
a flame ionization detector. Charcoal absorbent tubes were used
for absorption of naphthalene from air sampled by a calibrated
battery-operated air sampling pump. The time period for sampling
was generally 1 hour.
The specific sampling locations were selected based upon the
meteorological conditions at the time of sampling. Each sample
was collected from whichever of the 36 pre-selected stations was
closest to the predicted one-hour wind direction. All
naphthalene data were reduced on-site and results posted on the
31
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2752103A
CO
IN SITU BIODEGRADATION
DEMONSTRATION AREA
unr*
200
200
LEGEND
• - AW SAMPLING LOCATION
SCALE IN FEET
FIGURE 1
ENSR CONSULTING AND ENGINEERING
FRENCH LIMITED
BIODEGRADATION DEMONSTRATION
AIR SAMPLING LOCATIONS
JOG
APPVD:
DATE:
3/14/91
REVISED:
PROJECT
NUMBER:
2870-014
-------
central data board, located in the field operations office.
Calibrations using prepared solutions of naphthalene were
conducted at least daily. Quality assurance procedures included
field and laboratory blanks, spikes, and collocated samples.
Total lonizables Measurements. A total ionizables measurement
using an HNu photoionization detector was made and recorded at
the same time and at the same location at which each syringe
sample was taken. The HNu was calibrated with a certified
standard of isobutylene at least daily.
Time-Integrated Sampling For H8L Volatiles
The time-integrated monitoring was conducted at the site during
the demonstration to document the average daily impact on
downwind areas on-site and at fenceline locations.
Time-integrated impact measurement samples were collected by
drawing the air sample through a cartridge of pre-cleaned Tenax
solid sorbent material. The sample was drawn through the Tenax
tube at a measured flow rate using a battery-operated air
sampling pump. The time period of sampling was generally 8
hours. Samples were packaged in accordance with EPA-approved
QA/QC procedures and forwarded to an off-site laboratory for
analysis. There, the samples were thermally desorbed from a
heated chamber onto a GC column for GC/MS analysis.
The GC/MS analysis of the sample determined the
concentration levels of the 35 volatile organic compounds from
the EPA Hazardous Substance List (HSL) . The HSL was used because
it represented those constituents that might be expected to
evolve from the process operations based on air contaminant
measurements from the earlier-conducted pilot-scale experiments.
In addition to the routine analysis for the HSL, 12 selected
ambient air Tenax samples were analyzed qualitatively to identify
the predominant compounds collected, without regard to a specific
target list.
The specific locations of upwind and downwind sampling were
based on the meteorological conditions existing at the time.
Each sample was collected from whichever of the 36 pre-selected
sampling stations was nearest to the 8-hour predicted downwind
(or upwind) direction.
Quality assurance procedures included daily field and
laboratory blanks, spikes, and collocated sampling. GC/MS
analytical procedures followed EPA Methods (TO-1).
33
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Results
The monitoring programs described above were carried out
according to Phase I, II, and III schedules on the following
dates in 1987:
Phase I 4/21 to 4/23
Phase II 4/24 to 5/11
Phase I 5/12 to 5/14
Phase II 5/15 to 8/25
Phase I 8/25 to 8/28
Phase II 8/29 to 9/2
Phase I 9/3 to 9/4
Phase III 9/5 to 10/9
The dates identified are helpful in understanding the results
described below.
Total lonizables Results
More than 1,800 individual total ionizables measurements
were made throughout the air program scheduled readings. In
addition, HNu measurements were made continuously at downwind
fenceline locations during actual sludge mixing or soil dredging
to monitor for action level concentrations. The highest HNu
measurement recorded was 9.5 ppm at lagoonside and 1.8 ppm at
fenceline.
On two occasions, operations were curtailed due to HNu
readings exceeding the action limit of 1.0 ppm above background.
In both cases, sludge aeration and mixing activities were
curtailed and the fenceline readings returned to below the action
limit within 20 minutes, and did not exceed the limit during the
rest of the day. Sludge mixing was started again the next day
without HNu readings exceeding action limits.
Procedures required on-site personnel to wear organic vapor
cartridge-type respirators when HNu readings exceeded 1.0 ppm
above background. The occasions when this was needed were few
and generally of short duration.
"Real-Time" Target Volatiles Results
Over 1,800 syringe-collected samples were analyzed for the
six target volatile compounds. Table 2 presents the summary
results of the monitoring. The concentrations of all target
compounds remained well below their action limits for the entire
demonstration project. The single highest percent of an action
limit was for benzene, and was only 3% of the limit at the
fenceline. There was never a need to curtail operations due to
target compound concentrations levels.
34
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TABLE 2,
FRENCH LIMITED BIODCGRADATION DEMONSTRATION
REALTIME TARGET VOLATILES RESULTS SUPtWRY
Concentration in Parts Per Billion (ppb)
00
Cl
Target
Compound TLV
diloroCorH 50 000
Benzene 10 , 000
Trichloroethene 100,000
Toluene 200,000
Tetrachloro-
ethene 100,000
Etliylbenzene 100,000
Action
Limit
25 000
5,000
50,000
100,000
50,000
50,000
Det action
Li»it
350
10
10
25
30
50
Lagoons id*
Concentration
Rang*
BDL
BDL-1160
BDL-675
BDL-1494
BDL-650
BDL-610
La goons id* Fenceline
Maxiaua r*nc*lin* Naxiaua
Concentration Concentration Concentration
I of Action Li Bit Range % of Action Limit
- - -• HnT
•^——— DL>L> ™~ ~~ •^-^—
23 BDL- 150 3.0
1 . 4 BDL-520 1 . 0
1 . 5 BDL-590 0 . 6
1.7 BDL- 156 0.3
1.6 BDL-420 0.9
BOL - Below Detection Limit
-------
Naphthalene Results
Over 600 on-site determinations for naphthalene were made
during the monitoring program. No naphthalene was detected
during the ambient monitoring above the method detection limit of
150 ppb. Therefore, throughout the program, all samples
contained less than 3% of the naphthalene action limit of 5 ppm.
Time-Integrated Sampling Results
Qualitative Time-Integrated Results. Twelve Tenax samples
analyzed during the program were selected for qualitative
identification of all major compounds present. Figure 2 presents
a typical total ion chromatogram from the GC/MS analysis. Each
of the major peaks in the chromatogram is identified. The
compounds identified were either simple hydrocarbons or compounds
on the HSL list.
These qualitative results indicate that the HSL target
compounds provide a good characterization of the potentially
hazardous constituents present in the air emissions.
Quantitative Time-Integrated Results. Over 1,500 Tenax samples
were analyzed during the program period. Table 3 summarizes the
results for quantitative time-integrated determinations. As can
be seen from Table 3, trans-1,2-dichloroethene had the highest
lagoonside 8-hour average concentrations of any of the HSL
compounds. However, this concentration represented only 0.2% of
its TLV.
Concentrations determined for fenceline locations were even
lower, with 30 of the 35 compounds determined to be normally
below detection limits.
Comparison of Results
The air program had to be comprehensive in the variety of
compounds it tested for, yet responsive enough to feed back
information quickly, in order to meet project objectives.
Real-time or continuous measurements (using equipment such
as photoionization or flame ionization detectors) for organic air
pollutants, give immediate results, but are not compound-specific
and generally have relatively high detection limits (in the
parts-per-million range). Detection limits, more applicable to
ambient measurements in the parts-per-billion or even sub-ppb
range, can be achieved through concentrating a large volume of
air contaminants on sorbents. These samples can also be sent to
laboratories for sophisticated analyses such as GC/MS. These
results are, by nature, historical; by the time the analysis is
complete, the composition of the ambient air may be much
different.
36
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CO
ioe.
R1C
FIGURE 2
FRENCH LIMITED BIODEGRADATION DEMONSTRATION
FLUX CHAMBER RESULTS GC/MS DATA
HL
07'30/87 14:I?:00
i'luMS I TO 8WU
262M30.
17:05
i'l'i'i iCnll
-------
TABLE 3
FRENCH LIMITED BIODEGRADKTION DEMONSTRATION
TIME-INTEGRATED IMPACT NONITORINT, RLbULTS SUWtARY
Concentration ii. facts Per Billion (ppb)
CO
GO
Coapound TLV Li ait
CholoroMthane 50,000 0.6
BroaoMthane 5,000 0.3
Vinyl Chloride 5,000 0.4
Chloroethane 1,000,000 0.4
Hethylene Chloride 50,000 0.3
Acetone 750,000 0.5
Carbon Disulfide 10,000 0.4
1,1-Dichloroethene 5,000 0.3
1,1-Dichloroethane 200,000 0.3
Trans-l,2-Dichloro- 200,000 0.3
ethene
Chlorofora 10,000 0.2
1,2-Dichloroethane 10,000 0.3
2-Butanone 200,000 0.4
1,1,1-Trichloroethane 350,000 0.2
Carbon Tetrachloride 5,000 0.2
Vinyl Acetate 10,000 0.3
Broaodichloroethane 0.2
1,2-Dichloropropane 75,000 0.2
Trana-l,3-Dichloro- 1,000 0.3
propene
Trichloroethene 50,000 0.2
DibroBOchloroMthane 0.1
Lagoons id*
Actual
Concentration
2
BDL-2 . 4
BDL
BDL-132
BDL
BDL-7 . 7
BDL-46
BDL-134
BDL-3.5
BDL-225
BDL-483
BDL-9 . 4
BDL-214
BDL-122
BDL-1 . 4
BDL-1 . 1
BDL-9 . 1
BDL
BDL-110
BDL
BDL-88
BDL
Highest
Concentration
% of TLV
0.005
-
3
-
0.015
0.006
1
0.7
0.1
0.24
0.009
2
0.06
0.0004
0.02
0.1
-
0.15
-
0.18
-
Most Frequent
Concentration
Range
BDL
BDL
BDL
BDL
BDL
BDL- 10
BDL
BDL
BDL-1 0
10-50
BDL- 10
BDL- 10
BDL- 10
BDL
BDL
BDL
BDL
BDL-10
BDL
BDL-10
BDL
Fenceline
Actual
Concentration
Range
BDL
BDL
BDL-1 . 8
BDL
BDL- 3. 9
BDL-31.1
BDL-56
BDL
BDL-5.9
BDL-1 6
BDL- 3 . 4
BDL-9 . 6
BDL-61.4
BDL-0.5
BDL-1 . 1
BDL-1. 0
BDL
BDL-2. 0
BDL
BDL-1 .2
BDL
Host Frequent
Concent rat ion
3
BDL
BDL
BDL
BDL
BDL
BDL-10
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
Rotes:
1. Based on normal 20-liter air volu»e.
2. BDL entries indicate levels were below detection liaiits.
3. Concentration level ranges used: BDL, BDL-10 ppb, 10-50 ppb, >50 ppb.
-------
TABLE 3 -(continued)
FRENCH LIMITED BIODEGRADATIOR DEMONSTRATION
TIME-INTEGRATED IMPACT HDWITORIHG RESULTS SUWIART
Concentration in Parts Per Billion (ppb)
CO
CO
Compound TLV
1,1,2-Trichloroethane 10,000
Bensene 10,000
Cis-1,3-Dichloro- 1,000
propene
2-Chloroethyl Vinyl
Ether
Bromoform 500
2-Hexanone 5,000
4-Methyl-2-Pentanone 50,000
Tetrachloroethene 50,000
1,1,2,2-Tetrachloro- 1,000
ethane
Toluene 100,000
Chlorobeniene 75,000
EthyIbenzene 100,000
Styrene 50,000
Total lylene 100,000
Detection
Limit1
0.2
0.4
0.3
0.3
0.1
0.3
0.3
0.2
0.2
0.3
0.2
0.3
0.3
0.3
Actual
Concentration
Rang*2
BDL-11.2
BDL-255
BDL
BDL-3 . 6
BDL
BDL-1 . 3
BDL-3. 7
BDL-6.1
BDL
BDL-1 21
BDL-19.8
BDL-152
BDL-52.9
BDL-112
Lagoons id*
Highest
Concentration
* of TLV
0.11
3
-
-
_
0.02
0.007
0.01
-
0.1
0.025
0.1
0.1
0.1
Most Frequent
Concentration
3
Range
BDL
BDL-10
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL-10
BDL
BDL-10
BDL
BDL-10
Fenceline
Actual
Concentration
Range
BDL-1.1
BDL-11
BDL
BDL
BDL
BDL
BDL
BDL-0.2
BDL
BDL-2 4
BDL-1.0
BDL-5.8
BDL-1.1
BDL-7.0
Most Frequent
Concentration
3
BDL
BDL-10
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL-10
BDL
BDL-10
BDL
BDL-10
Motes:
1. Based on normal 20-liter air volume.
2. BDL entries indicate levels were b«low detection limits.
3. Concentration level ranges used: BDL, BDL-10 ppb, 10-50 ppb, >50 ppb.
-------
The air monitoring project developed for the French Limited
project incorporated the real-time measurements, qualitative and
quantitative time-integrated measurements, and intermediate
"grab" samples analyzed on-site with minimal turnaround time.
Which method was best for the study? All the applied
methods had their place in accomplishing the goals of the
project.
Table 4 presents the applications, benefits, and limitations
of the three air monitoring approaches used.
Based on these results and the comparison of techniques
described above, air monitoring successfully accomplished its
goals of protecting the health and safety of on-site and off-site
personnel and documenting the contaminants released by the
bioremediation demonstration.
Results
Air impacts during the in-situ bioremediation demonstration
were minimal and placed few limitations on day-to-day operations
because the air monitoring program allowed answers to air impact
questions to be available in time to ensure proper and safe site
operations. When impacts did occur, they were found to be
readily controllable, decreasing immediately upon reducing the
intensity of sludge aeration or mixing.
EQUIPMENT DEVELOPMENT
Upon completion of the in-situ bioremediation demonstration
phase of the project, an equipment development phase was begun.
During this phase, various pieces of equipment, including
aerators, mixers, pumping systems, etc., were tested for
applicability for use in the final remediations. A new cell of
the lagoon was walled off next to the in-situ demonstration cell.
An additional cell was also walled off at the east end of the
lagoon for testing during this phase as well. The testing of
equipment proceeded during the next approximately 1-1/2 years.
Because this testing of mixing and aeration activities had
the potential for ambient air impacts, air monitoring efforts
were continued during this phase of the program. Time-weighted-
average Tenax measurements were taken on a daily to weekly basis
depending on the level of activity at the site. All measurement
results were compiled and reported with the monthly progress
reports describing the operational activities at the site.
Results during this phase of the operation showed no
significant ambient air impacts resulting from equipment
development. These results, in combination with the results
40
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TABLE 4
Approach
Real-
time
HNU/OVA
Syringe
Grab
Samples
Application
Short-term impact
monitoring for
health & safety.
Short-term impact
monitoring for
health & safety.
Time-
Inte-
grated
Tenax
Samples
8-hour time-
integrated
impacts for
volatiles
Benefit
Most sensitive
action limit
trigger for pro-
ject.
Limited compound-
specific
information
possible. Peak
values measured.
Qualitative
results available
immediately.
Compound-specific
for large variety
of contaminants.
Good qualitative
and quantitative
results.
Limitation
No compound-
specific
information
possible.
Only semi-
quantitative
Only six
compounds
measured.
Labor
intensive.
Long-term-
average
impacts only.
Longest
turnaround
time for
results.
41
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from the in-situ bioremediation demonstration phase, represent
one of, if not the most, comprehensive long-term ambient air
databases developed for any Superfund site.
REMEDIAL ACTION PLAN
Ambient air management was a key element in the development
of the Remedial Action Plan (RAP) for the French Limited site.
It was decided by the management team that the best strategy for
accomplishing the goals of the remediation while minimizing air
impacts was to base the air management program on a risk
assessment evaluation. A risk assessment was conducted for the
bioremediation demonstration project to determine whether the
emissions anticipated during the full-scale final bioremediation
effort would be acceptable. Air monitoring techniques were
established in the RAP that would produce the data necessary for
ongoing evaluation of risk during the final remediation. The
monitoring techniques have been more fully developed and
presented in the final air monitoring program design, and are
discussed in detail following a description of the risk
assessment procedures used.
Risk Assessment On Bioremediation Demonstration Project
CERCLA Section 121 requires that the clean-up remedies
applied in the remediation of a Superfund site must be protective
of human health and the environment. Using the measurements
collected in the air monitoring program (described above), a
human health risk assessment was conducted to assess the
potential health risks to nearby residents from exposure to
lagoon emissions during bioremediation activities. The following
discussion describes the procedures and results of the risk
assessment evaluation on the bioremediation demonstration
project.
Hazard Identification
The data produced by the air monitoring program indicated
that the majority of the lagoon emissions during the
bioremediation demonstration project were relatively non-toxic
chemicals, such as aliphatic hydrocarbons. However, 33 of the 35
volatile organic compounds (VOCs) on the HSL were also identified
in small quantities. Due to their potential toxicities, these 35
compounds were evaluated in the human health risk assessment.
The air monitoring data were examined for compound concentration,
trends in distribution, and consistency of detection for these 35
VOCs. The VOC releases were found to be discontinuous and
variable over the course of the demonstration project, due to the
uneven distribution of the chemicals in the lagoon and variations
in the bioremediation operations. It was concluded that the
particular chemicals that may be released and the concentrations
42
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of those chemicals will vary throughout the full-scale
bioremediation project.
Exposure Assessment
The potential exposure pathway evaluated in the risk
assessment was the inhalation of gaseous compounds emitted from
the lagoon during the bioremediation demonstration. Other
exposure pathways were considered to be not applicable because
access to the site is prevented and the groundwater is not
utilized as a drinking water source. Exposure point
concentrations in the ambient air were modeled for the nearest
receptors, i.e., the closest residents downwind of the lagoon
site. The modeled receptor locations were located in the
Riverdale subdivision approximately 675 feet to the west-
southwest of the lagoon (identified as receptor #1), and in the
Dreamland subdivision approximately 2,900 feet to the east-
southeast of the lagoon (identified as receptor #2). Receptors
#1 and #2 represented the people located nearest the lagoon, who
have the highest potential exposure and any associated health
risk. People living farther away from the site and people
occasionally passing through the area would have lower exposures
and, thus, fewer risks.
Potential chronic inhalation exposure was estimated for
these receptors using a standard risk assessment equation for
average daily dose.
Average Daily Dose (mg/kg/day) = Air concentration (mg/m3) x
Inhalation rate (m3/person/day) x
I/body weight (person/kg)
To estimate the average daily dose, the concentration of
each compound in the air at the point of exposure was modeled
using the long-term average concentration measured by the Tenax
monitoring technique. The inhalation rate and body weight were
assumed to be 20 iir/day and 70 kg, respectively, as is typically
assumed by the EPA (EPA, 1989).
The potential for long-term adverse health effects at
receptors #1 and #2 was evaluated by estimating the average daily
doses and any associated chronic carcinogenic and noncarcinogenic
risks. The potential for short-term adverse health effects at
receptors #1 and #2 was evaluated by comparing the modeled
maximum 8-hour average air concentration to an allowable air
concentration for each chemical.
Dose-Response Assessment
The toxicity of each of the 35 HSL compounds was reviewed
with regard to both acute (short-term) and chronic (long-term)
health effects. An acute effect occurs in response to a brief
43
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exposure usually to a higher concentration of a compound than
might result in chronic effects. A chronic effect occurs in
response to extended exposure to a relatively low concentration
of a compound. Chronic health effects may be manifested as the
development of cancer or the development of noncarcinogenic
effects such as the impairment of liver or lung function. The
toxicity literature and EPA dose-response databases were reviewed
to obtain quantifiable estimates of acute and chronic health
effects.
Acute Health Effects. The severity of acute effects depends on
the exposure concentration; that is, higher concentrations may
produce severe, irreversible effects, while lower concentrations
may cause limited, reversible effects. In general, the focus of
health-protective guidelines is the prevention of relatively low-
level, readily reversible effects, such as coughing or eye
irritation.
In this risk assessment, the "allowable air concentration"
was designated as the threshold limit value — time-weighted
average (TLV-TWA) divided by an uncertainty factor. The TLV-TWA
values are listed by the American Conference of Governmental
Industrial Hygienists (ACGIH) and represent the TWA concentration
for an 8-hour workday and 40-hour work week to which workers may
be repeatedly exposed without experiencing adverse health
effects. The allowable air concentrations were derived by
dividing the TLV-TWA by an uncertainty factor of 42. This
uncertainty factor was derived by multiplying a factor of 4.2 (to
adjust the 8-hour, 5-day TLV-TWA to an allowable concentration
appropriate for the 24-hour, 7-day exposure anticipated in this
risk assessment) by factor of 10 (to account for possible
sensitive individuals in the exposed population).
Chronic Noncarcinogenic Health Effects. Acceptable exposure
levels for noncarcinogenic health effects are based on the
existence of no-effect thresholds, i.e., levels below which
exposures are unlikely to cause adverse effects. When exposed to
levels below the threshold, the human body is able to detoxify
the chemical or otherwise adjust to compensate for any potential
adverse physiological effects. Exposure limits for chemicals
with no-effect thresholds are called reference doses (RfDs) or
inhalation reference concentrations (RfCs). RfDs and RfCs are
dose-response values based on the assumed no-effect threshold,
derived from either human or animal data, combined with
appropriate uncertainty factors. RfDs are expressed as doses in
milligrams chemical per kilogram body weight per day (mg/kg/day).
RfCs are similar to RfDs, but are expressed as concentrations in
units of milligrams chemical per cubic meter of air (mg/m3) . A
person exposed to a dose (concentration) which is less than the
RfD (RfC) is assumed to experience no adverse health effects from
the exposure.
44
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The RfDs and RfCs used in this risk assessment were obtained
from the EPA Integrated Risk Information System (IRIS) database
(EPA, 1990a) and the Health Effects Assessment Summary Tables
(HEAST) (EPA, 1990b).
Chronic Carcinogenic Health Effects. It is assumed, for
regulatory purposes, that the development of cancer does not
exhibit a no-effect threshold, meaning that every exposure to a
potentially carcinogenic chemical is assumed to pose some risk.
However, there is increasing recognition that thresholds exist
below which some chemicals do not cause cancer. This is
especially true for several of the chlorinated hydrocarbons
listed on the HSL. Nonetheless, the assumption of no-threshold
is conservatively applied in this project. The no-threshold
approach for assessing cancer risk implies that the cumulative
exposure up to any given point of time determines the cancer risk
at that time, regardless of any variability in exposure
concentrations over shorter time periods.
EPA quantifies cancer risk by applying a linearized
multistage model to available data, obtained either from humans
or experimental animals, to derive a cancer slope factor (CSF).
The CSF derived from animal studies reflects a nearly uniform
dosing regimen administered throughout an animal's lifetime. The
CSF is expressed in units of (mg/kg/day) "1. The CSF values used
in this risk assessment were obtained from the IRIS database
(EPA, 1990a) and HEAST (EPA, 1990b).
Risk Characterization
Risk characterization is the process in which the dose-
response information is combined with the estimated exposure data
for the chemicals identified as being potentially hazardous. The
result is an estimate of the likelihood that people exposed to
the chemicals will experience acute or chronic health effects,
given the assumptions used in the risk assessment.
Acute Health Risks. The acute health risks from exposure to
compounds emitted from the lagoon during the demonstration
project were assessed by calculating a short-term effect ratio.
This ratio compared the modeled maximum 8-hour average air
concentrations at receptors #1 and #2 with the adjusted TLVs,
which were considered to be "allowable air concentrations," as
shown below.
Short-Term Maximum Air
Short-Term Effect Ratio _ Concentration (ppb)
(unitless) Adjusted TLV (ppb)
45
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If the short-term effect ratio is less than 1, the allowable
short-term air concentration is not exceeded and no short-term
health effects would be expected to occur. If the short-term
effect ratio is greater than 1, then the allowable short-term air
concentration is exceeded, and a potential for adverse short-term
health effects may exist. The potential for short-term health
effects from inhalation exposure was evaluated for receptor
locations #1 and #2 for the 32 HSL compounds for which TLV data
exist.
At both receptor locations #1 and #2 for all 32 compounds,
the short-term effect ratio was less than 1 by one to six orders
of magnitude. Thus, it was concluded that no adverse short-term
health effects occurred at the nearest residential receptor
locations during the bioremediation demonstration project.
Chronic Noncarcinogenic Risks. To estimate potential
noncarcinogenic risks associated with a given level of chemical
exposure, a hazard index was calculated. The equation for
computing the hazard index is shown below.
Hazard Index (unit less) = Av^a^e Daily Dose (mg/ kg/ day)
RfD (mg/kg/day)
If the hazard index is less than 1, the RfD is not exceeded
and no adverse noncarcinogenic health effects would be expected
to occur. If the hazard index is greater than 1, the RfD is
exceeded and a potential for adverse noncarcinogenic health
effects may exist.
Noncarcinogenic health effects from inhalation exposure were
evaluated at receptor locations #1 and #2 for the 16 HSL
compounds for which RfDs were available. For each of the 16
compounds, the hazard index was less than 1 by two to five orders
of magnitude. The total hazard index was also less than 1.0 at
both receptor locations.
Chronic Carcinogenic Risks. To estimate potential carcinogenic
risks associated with a given level of chemical exposure, an
excess lifetime cancer risk was calculated. The computed excess
lifetime cancer risk is an estimate of the upper 95% confidence
level on the increased chance of contracting cancer, above
background cancer rates. The equation for computing the excess
lifetime cancer risk is shown below.
46
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Excess Lifetime Cancer *™rf*e,?^ ?°f 1 (mg/kg/day] X
Risk (unitlpiq) = CSF (mg/kg/day) 1 x
Risx (unitless) Lifetime Averaging Factor (year/year)
Standard risk assessment practice specifies that a less-
than-lifetime exposure must be averaged over a 70-year lifetime
in the calculation of carcinogenic effects (EPA, 1989). The
lifetime averaging factor for calculating carcinogenic effects
equals the elapsed exposure period divided by the assumed 70-year
lifetime. Because the bioremediation demonstration project
lasted approximately 2 years, the lifetime averaging factor for
estimating carcinogenic effects in this risk assessment was 2
years divided by 70 years.
The excess lifetime cancer risk is typically compared with
levels of cancer risk that are considered allowable or
acceptable. EPA defines the acceptable range in excess lifetime
cancer risk to be between 1 x 10"* and 1 x 10"6 (EPA, 1990c) .
Carcinogenic health effects from inhalation exposure were
evaluated at both receptor locations #1 and #2 for the 15 HSL
compounds for which CSFs are available. For each of the 15
compounds, the excess lifetime cancer risks were 2 x 10"6 (2 in 1
million) or lower. The total carcinogenic risk was 6 x 10"6 (6 in
a million) at receptor #1 and 8 x 10"7 (8 in 10 million) at
receptor #2. These levels are within the limits defined as
acceptable by EPA. These levels are so low that they would not
be detectable given an average background rate of about one in
three for contracting cancer.
Results
The results of the risk assessment on the bioremediation
demonstration project showed that the lagoon emissions during
remediation were well below levels likely to cause acute or
chronic adverse health effects. On the basis of this risk
assessment it was concluded that it would be possible to conduct
the full-scale bioremediation effort within the constraints of
emission limitations that would protect human health.
AMBIENT AIR QUALITY MANAGEMENT PROGRAM FINAL DESIGN
Development of Health-Protective Emission Limits
Because of the variable nature of the lagoon emissions
during the remediation process and the potential toxicity of some
of the VOCs emitted from the lagoon, it was recognized that the
potential risks to human health would be a major controlling
factor over the full-scale bioremediation project. The
bioremediation operation would have to be managed to limit
47
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potential risks to human health by limiting air emissions. For
this purpose, emission limitations were established based on
health risk criteria, which were approved by EPA. By setting
emission limits that would be protective of the most exposed
nearby residents, these limits would also protect people with
lower exposures; for example, people living farther away or
people who occasionally pass through the area. The air emission
limits were determined for the full-scale bioremediation effort
by back-calculating from the adopted health risk criteria using
risk assessment techniques. The following discussion presents
the derivation of the short-term and long-term health protective
emission limits which will be applied during the full-scale
bioremediation of the French Limited site.
Short-Term Emission Limits Protecting Against Acute Health
Effects
Because TLV-TWAs are not strictly based on acute effects,
other literature sources describing acute adverse health effects
were reviewed to determine other chemical concentrations at which
acute effects might be manifested. Information reviewed included
primary literature, supporting documentation for the TLVs,
National Institute for Occupational Safety and Health (NIOSH)
documents, and EPA documents. This review focused on identifying
the lowest observed adverse effects levels (LOAELs) and no
observed adverse effects levels (NOAELs) for acute effects.
The majority of the chemicals released during the
bioremediation demonstration were hydrocarbons such as hexane,
cyclohexane, heptane, or pentane. The concentrations of these
hydrocarbons that might result in acute effects (within hours)
start just below 100 ppm and range as high as thousands of parts
per million, depending on the chemical. For the HSL compounds,
however, concentrations ranging between tens and hundreds of
parts per million could result in acute effects. The acute
toxicology literature indicates that a total VOC concentration
below 15 ppm would be expected to be protective against acute
effects for the nearest residents, even when the total
concentration monitored was assumed to be the most toxic HSL
compound.
Long-Term Emission Limits Protecting Against Chronic Health
Effects
Air criteria concentrations (ACCs) were established to
protect against chronic adverse health effects. Because the ACC
levels are much lower than the concentrations that could cause
acute effects, by meeting the ACCs, it is also unlikely that
acute health effects would occur.
The ACCs were derived for both carcinogenic and
noncarcinogenic health effects by back-calculating from
48
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acceptable exposure levels using risk assessment equations. The
acceptable exposure levels were derived from acceptable health
risk criteria approved by EPA. The acceptable health risk
criteria were established as follows: the allowable potential
increase in a person's excess lifetime cancer risk would be
limited to 1 in 1 million per chemical, and the allowable
potential noncarcinogenic risk would be limited to a hazard index
of 1 per chemical. The ACCs required to achieve these health
protection objectives were calculated for each of the HSL
compounds as described below.
In order to derive the ACCs, the hazard index and excess
lifetime cancer risk equations were rearranged to solve for the
air concentration variable that will become the ACC. To
accomplish this, all the variables in the equation, except for
the air concentration, were assigned values.
Exposure assumptions were made for the nearest residents who
are located in the Rogge, Dreamland, and Riverdale subdivisions.
These potentially exposed residents were assumed to weigh 70 kg,
breathe 20 m3 of air per day, and have a 70-year lifetime. They
were assumed to be at their residences, and therefore potentially
exposed to lagoon emissions, every minute of every day for the
entire 2 years of the full-scale bioremediation effort.
Bioavailability factors (BAFs) were incorporated into the
derivation of the ACCs. These factors had not been previously
used in the risk assessment on the bioremediation demonstration
project because that assessment preceded EPA's published guidance
on the use of BAFs (EPA, 1989) . The BAF accounts for any
potential differences between the absorption efficiency and
biological effectiveness of the route and medium of inhalation
exposure and the absorption efficiency and biological
effectiveness of the route and medium of the experimental study
from which the dose-response value (RfD or CSF) was derived.
When the RfD or CSF is based on exposure dose, the BAF is a
relative adjustment factor defined as the ratio of the estimated
absorption factor for the site-specific medium and route of
exposure (air) to the known or estimated absorption factor for
the laboratory study from which the RfD or CSF was derived. Use
of this factor permits appropriate adjustment if the efficiency
of absorption is known or expected to differ because of
physiological effects and/or matrix or vehicle effects. When the
RfD or CSF is based on absorbed or metabolized dose, the BAF is
not a relative factor; rather it is an absolute factor expressing
the expected bioavailability in humans. If the RfD and CSF are
based on studies involving different exposure routes or matrices,
then the BAF for evaluating noncarcinogenic effects may be
different than the BAF for evaluating carcinogenic effects.
49
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Compound-specific, effect-specific BAFs were determined for
the HSL compounds based on reviews of available scientific
literature. For chemicals with little information, availability
of the dose to humans through inhalation exposure was assumed to
be the same as that of the test species and the route and medium
used in the experimental study.
As previously discussed, the health protection objectives of
1 in 1 million (1 x 10"6) excess lifetime cancer risk for each
potentially carcinogenic compound and a hazard index of 1.0 for
each potentially noncarcinogenic compound were the established
goals for the bioremediation of the French Limited site. Using
these assigned values, the equations were solved and an ACC was
derived for each of the HSL compounds. Table 5 presents the ACCs
derived for the HSL compounds.
For potentially noncarcinogenic compounds:
Inhalation Rate x BAF]
ACC= 1. 0 T
Body Weight x RfD
For potentially carcinogenic compounds:
ACC= (IxlCT6) 7
Inhalation Rate x Lifetime Averaging
Factor x BAF x CSF
Body Weight
Because the BAFs, RfDs, and CSFs are chemical-specific, the
ACCs will differ for each chemical. For chemicals potentially
exhibiting both carcinogenic and noncarcinogenic effects, ACCs
were derived for both health effects and the lowest ACC was
selected for that chemical.
Managing Operations to Achieve Health Protective Emission Limits
Operating procedures during the bioremediation will be
managed on the basis of air emission limits set as total VOC
response action limits and chemical-specific ACCs. The total VOC
limits are short-term emission limits designed to protect nearby
residents from exposure to chemical concentrations that might
result in short-term or acute adverse health effects. The ACCs
are long-term emission limits designed to protect the public
health from long-term or chronic carcinogenic or noncarcinogenic
health effects.
To protect against potential acute health effects,
continuous monitoring of total VOCs will be conducted at the top
of the flood wall. Five monitoring stations will be positioned
50
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TABLE 5
Air Criteria Concentrations (ACCs)
Compound
Acetone
Benzene
Bromodichloromethane
Bromoform
Bromomethane
2-Butanone
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chloroform
Chloromethane
Dibromochloromethane
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethene
trans-1,2-Dichloroethene
1,2-Dichloropropane
cis-1,3-Dichloropropene
trans-1,3-Dichloropropene
Ethylbenzene
Methylene chloride
4-Methyl-2-pentanone
Styrene
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
Vinyl Chloride
Xylenes
(ppb)
220
1.3
14.5
8.1
1.5
107
3.2
0.4
3.7
6.1
12.1
8.6
119
3.0
7.9
17.6
0.4
0.2
0.2
103
22.5
19.6
245
1.0
5.4
521
190
2.5
3.8
0.4
68.3
(Mg/m3
530
4.2
98.6
83.3
6.0
315
10.2
2.4
17.5
30.4
25.2
74.5
490
13.5
31.5
70.0
1.8
0.9
0.9
449
79.5
80.5
1060
7-0
37.1
2,000
1050
14.0
20.6
1.0
301
51
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in the direction of the three nearest residential areas (Rogge,
Dreamland and Riverdale subdivisions) and in the direction of two
neighboring roads. The allowable short-term total VOC
concentration of 5 ppm has been incorporated into the short-term
response action limits. The total VOC concentration will be
continuously monitored and bioremediation operations will be
managed so as to avoid the attainment of acute VOC
concentrations. In the unlikely event of an exceedance of the
maximum short-term total VOC concentration (see discussion to
follow), evacuation procedures will be conducted in order to
prevent the occurrence of acute exposures to neighboring
residents.
To protect against potential chronic health effects and to
achieve the health protection objectives of 1 in 1 million (1 x
10"6) excess lifetime cancer risk for carcinogenic effects and a
hazard index of 1.0 for noncarcinogenic effects, long-term VOC
concentrations will be monitored for each of the HSL compounds to
ensure that they do not, on average, exceed the ACCs. A
computerized system has been designed to continuously compare the
chemical-specific ACCs with the cumulative average concentration
modeled for that chemical at each of three residential locations
(i.e., for the nearest resident in the Rogge, Dreamland, and
Riverdale subdivisions). The ratio of the ACC to the cumulative
average concentration is called the air criteria concentration
ratio (ACCR) . An ACCR will be derived for each chemical on a
weekly basis throughout the 2-year period of the full-scale
bioremediation project. The long-term VOC emissions during
bioremediation will be managed such that the final ACCR will be
equal to or less than 1.0 for each chemical, thereby protecting
the public from adverse chronic exposures.
Measurement and Modeling Techniques
The remainder of this paper describes the sampling,
analytical data management, and modeling techniques used to
generate data for the risk assessment procedures described above.
The program presented is the result of a cooperative effort
between all participants in the project, the Task Group, ENSR,
and EPA.
The Ambient Air Monitoring Program for potential releases of
VOCs from the French Limited Bioremediation Process Operations
includes two types of monitoring action: short-term monitoring
and long-term, time-integrated monitoring.
Short-Term Monitoring. The short-term monitoring program provides
a continuous, instantaneous reading of total VOC concentrations
in ambient air. Five separate continuous measurements are taken
at strategic locations around the operating bioremediation
treatment cell, at the top of the French Limited lagoon flood
wall, to determine whether control adjustments are necessary in
52
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the bioremediation process to maintain total VOC concentrations
within pre-approved limits established by EPA. Additionally,
these measurements will be continuously recorded for historical
purposes, and each measurement will trigger a process control
alarm signal should it exceed a pre-set reading. The alarm point
is selected to ensure that control action is taken before the
pre-approved EPA limits are reached.
Long-Term Monitoring. The long-term monitoring program provides
a 24-hour/day, 7 day/week continuous sampling of organic
compounds in the ambient air at three French Limited site
property line locations. These locations are directly between
the bioremediation cell that is in operation and the three
nearest potential receptors (the Riverdale, Rogge, and Dreamland
subdivisions).
The air samples are analyzed daily to provide a time-
integrated measurement of the 35 VOCs on the HSL. The
concentrations determined in these measurements are then
processed mathematically to identify the dispersion that will
occur between the French Limited site property line and the three
potential receptor locations. The potential receptor
concentrations will be compared with the acceptable concentration
criteria approved by EPA for the 2-year bioremediation operating
period.
These daily long-term measurements will be continuously
accumulated and averaged to derive a cumulative average for each
compound on a weekly basis. The ongoing calculation of these
ACCRs will be used to determine whether adjustments in the
bioremediation operation are necessary in order to attain the
project-specific health protection criteria. This chemical-
specific average will be compared against the acceptable 2-year
ambient air criteria approved by EPA.
Total Volatile Organics Short-Term Measurements
Results of short-term VOC measurement will be used to
determine whether control action is needed to protect potential
receptors from short-term exposures, to ascertain the effects of
short-term concentrations on long-term health risk, and to ensure
these effects are maintained within EPA-approved operational
limits.
Organic vapor monitors (OVMs) will be permanently placed at
five locations at the flood wall relative to the future operating
bioremediation treatment cells. Figure 3 shows the placement of
the analyzers for cell E and cell F. As can be seen from the
figure, some monitoring locations will serve both cells but will
represent a different relative position for each.
53
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en
MONITORING LOCATIONS
CELL F
FLOOD WALL
FENCEUNE
1
2
3
6
7
A
B
C
C_ELL_£
1
3
4
5
6
A
B
C
t
11
200
iMw OAK-
FIGURE 3
400
SCALE IN FEET
ENSR CONSULTING AND ENGINEERING
AMBIENT AIR MONITORING LOCATIONS
FRENCH LIMITED
UKAWM:
EDH
APPVD:
BO
OMt 8/22/90
REVISED:
WTOJECT
NUU6ER:
NEV
-------
Measurements will be recorded as total VOCs, and calibrated
as a relative response to benzene as iso-butene. A certified
standard of approximately 8 ppm iso-butene will be used at all
OVM stations.
VOC release response procedures have been developed and are
presented in the French Limited Project RAP- VOC concentrations
to be considered response action points are described later in
this paper.
The short-term measurement system incorporates five Thermo
Electron (TECO) 910A® OVMs at the flood wall, and an Odessa DSM
3260 Data Collector*, 386 computer, and custom-built alarm relay
panel at the operations room. A functional block diagram of the
approach is presented in Figure 4. This approach centralizes all
monitoring data at one on-site location and provides the means
for remote locations to connect to the system via telephone modem
for transmitting current and historical data.
Each monitoring location will be equipped with one analyzer
and zero and span gases. All analyzers will be connected to a
central signal/data processing system in the operations computer
room. The analyzers will be positioned, as shown in Figure 3, to
represent monitoring the following general directions:
• Toward Rogge subdivision to the northeast.
• Toward Dreamland subdivision to the southeast.
• Toward Riverdale subdivision to the southwest.
• Downwind of the predominant wind direction to the
northwest.
• Due south of the center of the then-active cell of the
lagoon.
Specific locations will depend on which bioremediation cell
is active, as specified in Figure 3. When bioremediation is
complete in cell F, monitors 2 and 7 will be moved to locations
4 and 5, respectively. Shelters will be placed outside the flood
wall and will be elevated against it to prevent possible damage
caused by cranes and other vehicles inside the wall, or by flood
events. The sample intake line will be a 1/4-inch Teflon tube
with a sleeve of 1/2-inch conduit. Sampling points will be ap-
proximately 1 meter above and 1 meter inside the flood wall at
each of the five locations. These are installed in accordance
with the specifications of 40 CFR Part 58, Appendix E.
55
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SAMPLE
INPUT
UNIT 1 OF 5
01
en
TECO
910 A
OVM
S
P
A
N
Z
E
R
0
STATUS LINE
4-20 MA
ODESSA
3260
386
20 MHZ
COMPUTER
DIAL
PHONE
LINE
FIGURE 4
ENSR CONSULTING AND ENGINEERING
FUNCTIONAL 6LOCK DIAGRAM
TOTAL VOLATILE ANALYSIS
FRENCH LIMITED
JOG
APPVO:
°*Tt: 8/20/90
REVISED:
PROJECT
NUMBER:
2870-01-1
REV
o
-------
TECO Analyzer
The TECO 910A* OVM, designed to be used on a continuous
basis, uses a photoionization detector (PID) with a heated
sampling flow path and a microprocessor to control calibrations
and output. The detection limit of the method is 0.5 ppm as
benzene.
Data Collector
The Odessa DSM 3260 Data Collector will convert the 4- to
20-mA signal from the remote analyzers into meaningful units in
ppm. The DSM 3260 will be configured to provide interim averages
of 5 minutes and final averages of 1 hour. The interim averages
will be used for both alarm control and graphic presentation on
the local computer screen. Each of the five OVMs will have a
data collector channel recording its output and an associated
alarm control set at 5 ppm. If the site experiences a 5-ppm-
level alarm at one analyzer, it will also sound an alarm as more
analyzers exceed 5 ppm; in addition, a calibration failure will
trigger an alarm.
Software will be used to generate monthly summary reports of
data collected. The reports will be included in the monthly
project progress reports submitted to EPA. Data can also be
accessed in real-time at the site or through a remote terminal
via modem.
The OVM instrumentation and time-integrated sampling
equipment will be installed, calibrated, operated, and audited,
consistent with Standard Operating Procedures (SOPs).
The TECO 910* OVM is a self-calibrating instrument. A zero
and span calibration check will be performed each hour. Each of
these events will be 2.5 minutes in length. Zero and span
calibration events will be staggered for the five sites so that
only one analyzer at a time will be in calibration mode. The
analyzer self-corrects to the span value.
As is normal with PID instruments, the analysis will be
calibrated relative to a benzene standard. However, iso-butene
is used as a surrogate standard to benzene to avoid potential
exposure to benzene during calibrations. The instrument is
calibrated to iso-butene's corrected response relative to benzene
(iso-butene is generally provided by the supplier as a benzene
equivalent concentration). The analyzer, therefore, will be
calibrated in parts-per-million as benzene even though an iso-
butene standard will actually be used. An approximately 8 ppm
certified standard of benzene equivalent to iso-butene will be
used at each OVM station.
57
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At installation and quarterly thereafter, a multi-point
calibration will be conducted to verify the daily calibrations.
This audit calibration check will be conducted with calibration
gases different from those used for the daily calibration.
Audit of calibration data control charts, field repair
forms, and other associated recordkeeping will also be conducted
quarterly in conjunction with the multipoint calibration
performance audit.
Results of the total volatile organics
measurements will be reported in three ways:
short-term
• Results will be tracked in real-time on the monitor
screen at the site computer system. These results as
they are updated can also be accrued from remote
computer terminals via modem.
• A field log will be kept at the site which will include
a summary of dates, results to-date which have been
quality assurance checked, and notations of any events
where action events have been exceeded.
• Quality assured data summaries will also be included in
the monthly project progress reports submitted to EPA.
Any time total VOC concentrations exceed predetermined
action limits at a monitoring location at the top of the
floodwall, response actions will be implemented in accordance
with the following plan.
Site
Operational
Condition
Green
Yellow
Red
Total VOC
Concentration
0-5 ppm
5-11 ppm
5-11 ppm
White
ppm
The site alarms
operational condition.
Duration
Indefinite
More than
5 minutes
More than
30 minutes
More than
30 minutes
Response Action
Normal operation
Reduce aeration and
mixing intensity.
Shut down aeration
and mixing; conduct
specific target
volatile sampling
at top of flood
wall.
Evacuate on-site
personnel.
sound upon reaching the yellow site
58
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All concentrations specified are pending confirmation from
long-term risk assessment results. Levels will be adjusted, if
necessary, to aid in the maintenance of long-term average levels.
This monitoring is intended to identify the types of compounds
present during these elevated concentration periods.
If white concentrations persist after mixing and aeration
operations have been shut down, meteorological conditions will be
analyzed and the downwind property line total VOC concentration
determined by use of portable OVM instrumentation similar in
response to the fixed flood wall monitors. The portable OVM will
be used routinely for on-site health and safety monitoring. If
this concentration is less than 2.0 units, the downwind property
line monitoring will continue until on-site readings return to
normal. If this reading exceeds 2.0 units and continues at that
level for more than 15 minutes, an evacuation notice will be
issued. If closure of a public road is warranted, the road will
be blockaded with traffic flares until the Sheriff's Department
arrives on the scene. The French Limited Task Group Project
Coordinator, EPA Project Manager, TWC Project Manager, Texas Air
Control Board, and Harris County Pollution Control Department
will be notified of the situation.
Emergency controls will remain in effect until it has been
determined, to the satisfaction of the Sheriff's Department, that
conditions have returned to normal and blockades or evacuations
can be withdrawn.
As soon as emergency controls are removed, the Task Group
will establish communications with nearby residents and community
leaders to describe the situation that occurred, the actions
taken to control it, and the actions being taken to prevent
reoccurrence. Any contact with the public will be made in
person. The public will not be expected to hear or respond to
site alarms which trigger during the yellow operational
condition.
This emergency plan will be reviewed with the Harris County
Emergency Coordinator prior to startup of the bioremediation
program.
After emergency controls have been removed, site personnel
will establish communications with the Task Group Project
Coordinator. The situation that occurred will be described (with
the ambient air total VOC concentrations), and plans to prevent
reoccurrence established. The Task Group Project Coordinator
will review the situation with the EPA Project Coordinator within
24 hours of the occurrence. They will follow the procedures
outlined in the approved Contingency Plan. Upon EPA and Task
Group concurrence, bioremediation operations will be resumed.
The re-startup will follow the normal process (with any
modification resulting from the incident) of startup of aeration
59
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followed by startup of mixing activity, with continuous
monitoring of ambient air total VOC concentrations throughout the
sequence.
Within 60 days of the incident, the Task Group Project
Coordinator will submit a detailed report to EPA giving:
• Date/time of incident.
• Description of incident.
• The complete total VOC concentration database during
the incident.
• The complete meteorological database during the
incident.
• Description of notifications given.
• Description of agency and public communications
initiated.
• Re-startup date/time and special procedures followed.
• Description of actions taken to prevent reoccurrence.
The report to EPA will serve as an historical record of the
incident. It will be a document of reference for further
discussion, if any, concerning the events that took place during
and immediately following the incident.
Time-Integrated VOC Measurements
Routine time-integrated VOC measurements will be taken at
the property line to provide data for determining possible long-
term health risk from air emissions from the site. Ambient air
will be sampled by Tenax® and carbon molecular sieve (CMS)
absorbent tubes and analyzed for the 35 HSL target VOCs by GC/MS.
A 2-year health risk will be calculated weekly using the
total project analytical database available each week. Each
week's results will be added to the project-to-date database
prior to the week's health risk calculations. Operations will be
controlled to ensure that, by the end of the remedial action
project, the long-term health risk at each of the three nearest
receptor locations (Riverdale, Rogge, and Dreamland) has been
maintained within EPA-approved health risk criteria. Results of
health risk calculations will be recorded in the log at the site,
where they will be available for inspection and use by operations
personnel and review by regulatory agencies. Results will also.
be included in the monthly project progress reports to be
submitted to EPA.
60
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Time-integrated sampling will be conducted at three
fenceline locations on a line between the subdivisions of
interest and the operational cell of the lagoon. Approximate
locations of the sampling, corresponding to the Rogge, Dreamland,
and Riverdale subdivisions, are shown in Figure 3. Final
locations will depend on physical limitations of the site.
Efforts will be made to locate the sites on as direct a line as
possible. The same type of shelter will be used as for the total
organics measurement equipment.
Throughout the remediation period, 24-hour integrated
samples will be collected daily, 7 days per week. Sampling will
only be suspended due to severe weather conditions at the site.
Time-integrated measurement samples will be collected on Tenax*
solid sorbent cartridges and collocated CMS cartridges, and
analyzed by thermal desorption GC/MS. Air samples will be
collected by drawing the sampled air through the cartridges of
precleaned Tenax* and CMS sorbent at a measured flow rate, using
an electrically operated sampling pump. A second cartridge will
be placed downstream of the first cartridge to facilitate
detection of any breakthrough. One pump will be used for each
cartridge set.
The sampling flow rate will be controlled using a Mass Flow
Controller. Each cartridge set (Tenax* and CMS) will be
controlled by an individual mass flow controller. Nominal
sampling volumes of 20 liters for Tenax* and 30 liters for CMS
will be used. Mass flow controller accuracy will be checked at
least quarterly, according to EPA protocols. Battery-operated
Alpha personnel sampling pumps will serve as backup in case of an
individual station power failure. Samples will be properly
packaged and forwarded to the off-site laboratory for GC/MS
analysis. Samples will be thermally desorbed in a heated chamber
onto a GC column for GC/MS analysis. GC/MS analysis will be used
to determine the presence and levels of the 35 VOCs.
Of the 35 HSL target compounds, five compounds will be
determined using CMS and the remaining 30 using Tenax*. Table 6
presents the five compounds to be determined by CMS, with the
expected detection limits for each. The detection limit assume
a nominal 30-liter sampling volume and a 25-ng GC/MS detection
limit per compound. Table 7 presents the same information for
the Tenax*-sampled compounds. These limits for Tenax*-sampled
compounds assume a nominal 20-liter sampling volume.
The sampling program will include the preparation of one
field blank for each day of sampling. One duplicate run will be
made per week of sampling.
Laboratory results reports will be compiled by the French
Limited Task Group Data Manager. Laboratory determinations will
be combined with field log data on sample flow and sampling time
61
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TABLE 6
Compounds Determined by CMS
compound Method Detection Limit*
Chloromethane 0.4 ppb
Bromomethane 0.2 ppb
Vinyl chloride 0.3 ppb
Chloroethane 0.3 ppb
Methylene chloride 0.2 ppb
*Based on 30-L sampling volume and 25-
ng/compound GC/MS detection limit
62
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TABLE 7
Compounds Determined by Tenax
Compound
Acetone
Carbon disulfide
1,1-Dichloroethene
1,1-Dichloroethane
trans-1,2-
Dichloroethene
Chloroform
1,2-Dichloroethane
2-Butanone
1,1,1-
Trichloroethane
Carbon
tetrachloride
Vinyl acetate
Bromodichloro-
methane
1,2-
Dichloropropane
cis-1,3-
Dichloropropene
Trichloroethene
Method
Detection
_ . ,. *
Limit
0.5 ppb
0.4 ppb
0.3 ppb
0.3 ppb
0.3 ppb
0.2 ppb
0.3 ppb
0.4 ppb
0.2 ppb
0.2 ppb
0.3 ppb
0.2 ppb
compound
Dibromochloromethane
1,1,2-
Trichloroethane
Benzene
trans-1,3-
Dichloropropene
2-Chloroethyl-
vinylether
Bromoform
4-Methy1-2-pentanone
2-Hexanone
Tetrachloroethene
1,1,2,2-
Tetrachloroethane
Toluene
Chlorobenzene
0.2 ppb Ethylbenzene
0.3 ppb Styrene
0.2 ppb Total Xylenes
Method
Detection
Limit*
0.1 ppb
0.2 ppb
0.4 ppb
0.3 ppb
0.3 ppb
0.1 ppb
0.3 ppb
0.3 ppb
0.2 ppb
0.2 ppb
0.3 ppb
0.2 ppb
0.3 ppb
0.3 ppb
0.3 ppb
Based on 20-k sampling volume and 25-ng/compound GC/MS
detection limit*
63
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to calculate the 24-hour average concentration of each of the
target compounds. These data will be compiled in Lotus
spreadsheet form suitable for input to fenceline impact
calculations.
Time-integrated sampling will be conducted at the initiation
of remedial activities in each of the operational cells of the
lagoon, as well as at the three fenceline locations. This
sampling will be conducted at a downwind floodwall short-term
monitoring location for five consecutive days during the first
week of operation of the first cell. Flood wall sampling will be
repeated during the first week of the second cell operation and
at significant changes in aeration or mixing activities. The
downwind location will be selected on the basis of the predicted
24-hour wind direction. Samples will be taken over a 24-hour
period with all sampling and analysis procedures the same as for
the fenceline locations. Samples most likely to have the highest
concentrations from 2 of the 5 days of sampling will be selected
to be analyzed. These samples will be quantitatively analyzed
for the same compounds as those collected at the fenceline
locations. In addition, the analytical results data will be
qualitatively reviewed to identify major compounds present. The
purpose of these qualitative determinations is to identify
compounds that might be present which were not included in the
target list quantitative determinations, and to investigate
whether qualitative compositional changes have occurred in the
air emissions.
Sampling for specific target volatiles will also be
conducted at the onset of a red site operational condition. The
purpose of this sampling is to qualitatively identify the
compounds which constitute the total VOC concentrations measured.
Samples will be taken at the flood wall at the short-term monitor
that triggered the red condition. If more than one monitor is at
the red range, samples will be taken from the site of the monitor
reporting the highest value. As soon as possible after the red
site operational condition has been reached, a sample will be
collected. An air volume of at least 10 liters will be collected
for both the Tenax* and CMS sampling techniques. A sampling time
of 30 minutes will be used to minimize the averaging period. If
the site operational condition decreases to a yellow or green
level during sampling, sampling will be completed, but a notation
made of the time when the level dropped below the red level. At
least one 30-minute sample will be analyzed for each day that
operational response condition sampling is conducted. Samples
which are most likely to have the highest concentration will be
selected for analysis. Samples taken will be immediately sent to
the laboratory and given priority for analysis. Analysis
procedures will be the same as other time-integrated measure-
ments. Results of the analysis will be reported immediately upon
completion to the French Limited Task Group Project Coordinator.
64
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The results will also be included in documentation describing the
total VOC short-term measurement results for this time period.
Modeling Air Impacts
The overall purpose of the Ambient Air Monitoring and
Control Program (AAMCP) modeling phase is to ensure that the
ambient impacts due to the bioremediation of the French Limited
site at the three closest residential subdivisions are within
acceptable limits. This will be accomplished by estimating
average weekly and project-to-date ambient impacts at these
residential subdivisions and comparing these impacts with health-
protective criteria.
Ambient impacts due to the bioremediation of the French
Limited site will be estimated on a weekly basis for each of the
35 compounds measured at the fenceline sampling locations in the
time-integrated sampling phase. The time-integrated sampling
data gathered at the fenceline sampling locations, together with
an EPA guideline dispersion model and on-site meteorological
data, will be used to calculate the ambient impacts from the
French Limited remediation operations at the closest three
residential subdivisions.
The system, in large part, will be computerized, with only
minimal manual requirements. The structure of the modeling
system can be divided into three major sections:
1. Calculation of average weekly and project-to-date
French Limited impacts at the fenceline sampling
locations.
2. Calculation of dilution factors to estimate the average
weekly and project-to-date French Limited impacts at
the residential subdivisions.
3. Calculation of ACCRs.
A flow chart of this process is shown in Figure 5. Each of
these steps is discussed in detail below.
The time-integrated fenceline sampling program discussed
previously will measure the ambient concentrations of 35
compounds. The data will be collected over a 24-hour time period
and will therefore represent 24-hour average concentrations.
These data, in conjunction with the individual compound detection
limits and ambient background concentrations, will be used to
calculate the weekly and project-to-date fenceline impacts due to
the bioremediation of the French Limited site.
65
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o:
2B70\28704-1
INDIVIDUAL
24-HOUR
ucAciiBrn
FENCEUNE
CONCENTRATIONS
AVERAGE
WEEKLY
MEASURED
FENCEUNE
CONCENTRATIONS
SUBTRACT
BACKGROUND
CONCENTRATIONS
AVERAGE WEEKLY
AND PTD
MEASURED
FRENCH LIMITED
IMPACT
CONCENTRATIONS
WEEKLY
MET DATA
SOURCE DATA
COMPUTER
DISPERSION
MODEL
AVERAGE WEEKLY
CALCULATED
CONCENTRATIONS
AT FENCEUNE
AND RESIDENCES
WEEKLY DILUTION
FACTOR BETWEEN
FENCEUNE AND
RESIDENCE
1
WEEKLY AND PTD
FRENCH UMITED
CONCENTRATIONS
AT RESIDENCE
I
AIR
CRITERIA
CONCENTRATION
RATIO
AIR
CRITERIA
CONCENTRATION
FIGURE 5
PTD - PROJECT TO DATE
ENSR CONSULTING AND ENGINEERING
FLOWCHART FOR
AIR MODEUNG
FRENCH LIMITED
JOG
APPVth
12/18/90
REUSED:
PROJECT
NUMBER:
REV
9H7O— (HA
-------
The compound detection limits come directly from the
fenceline measurements program. It was previously determined
that ambient background concentrations of benzene, toluene, and
xylene occur due to Houston regional area sources (vehicles,
industrial, commercial uses, etc.)- These background levels are
estimated to be 1.7, 1.6, and 1.5 ppm for benzene, toluene, and
xylene, respectively.
The weekly and project-to-date French Limited fenceline
impacts will be calculated by first averaging the individual,
measured 24-hour compound concentrations to develop total impact
concentrations (i.e., French Limited plus background).
Individual measured concentrations, which were determined to be
below detection limits, will be set to one-half their respective
limits. The final step in developing French Limited fenceline
impacts is to subtract the background concentrations from these
values.
The individual 24-hour compound concentrations will be
manually loaded into a computerized database on a weekly basis.
That is, each week a full set of compound concentrations for each
of the three fenceline locations will be entered into the
database. A program will then be executed each week to determine
average weekly and project-to-date ambient concentrations and
French Limited impacts at the fenceline locations. Figure 6 is
a flow chart of this process.
These calculations will be performed with a computerized
dispersion model developed for EPA. In many applications,
compound emission rates would be directly placed into an
atmospheric dispersion model, and the model would then calculate
the impact of those emissions at specific receptor locations.
Because reliable compound emission rates are not available for
the remediation process, however, another method must be used.
A dispersion model will be used to calculate impacts at the
fenceline sampling and residential receptor locations using a
generic (i.e., normalized) emission rate. A dilution factor (DF)
will be calculated for each receptor pair. This dilution factor
will then be applied to the French Limited fenceline impacts to
determine the receptor-residence ambient impacts.
The dispersion model will be used as the computational core
for this process, and other computerized software will be placed
around it to automate the procedure. Dispersion model
calculations will be performed on a weekly basis using weekly
meteorological STAR frequency distributions. Project-to-date
impacts will be calculated from the weekly results. Figures 7
and 8 are flow charts of this process.
67
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cn
ex
2870\2fl704-2
NEW WEEKS//
-V 24-HOURV/
//FENCEUNE /,
, CONCENTRATIONS
WEEKLY
AVERAGE
FENCEUNE
CONCENTRATIONS
COMPOUND
DETECTION
LIMITS
PTO
AVERAGE
FENCEUNE
CONCENTRATIONS
WEEKLY
FRENCH LIMITED
FENCELINE
IMPACTS
PREVIOUS
WEEKLY
AVERAGE
CONCENTRATIONS
PTD
FRENCH LIMITED
FENCELINE
IMPACTS
COMPOUND
BACKGROUND
LEVELS
FIGURE 6
1M
ENSR CONSULTING AND ENGINEERING
DATA FLOWCHART FOR CALCULATION
OF FRENCH LIMITED FENCEUNE IMPACTS
FRENCH LIMITED
JOG
APPVO:
OATC- 12/18/90
REVISED:
PROJECT
NUMBER:
2870-014
REV
-------
O3
CO
2870\28704-3
*»?
/sssss
METEOROLOGICAL
DATA
PROCESS
SOFTWARE
SOURCE
DATA
CELL E
SOURCE
DATA
CELL F
WEEKLY
STAR
DISTRIBUTION
DILUTION
FACTORS
FIGURE 7
ENSR CONSULTING AND ENGINEERING
DATA FLOWCHART FOR CALCULATION
OF DILUTION FACTORS
FRENCH LIMITED
DRAWN:
JOG
APPVD:
DATE:
REVISED:
I NUMBER:
12870-014
RCV
-------
2870\287
-------
In addition to the atmospheric dispersion model, the
specific data necessary for these calculations are:
meteorological data, source parameters (location, emission rates,
and release parameters), and location of receptors (i.e., points
for which concentrations are to be calculated). Each of these is
discussed in detail below.
A meteorological station will be operated continuously
during the remediation activity. The station will consist of:
• A free-standing 10-meter tower.
• A wind speed and direction sensor at the 10-meter level
on the tower.
• A temperature and relative humidity sensor (with
radiation shield) at the 2-meter level on the tower.
• A barometric pressure sensor located inside a shelter
adjacent to the tower.
• A tipping-bucket rain gauge (with wind screen) located
at ground level near the tower.
• A data acquisition hardware and software system to
record digital data from analog signals produced by the
meteorological sensors. This data acquisition system
will be located in the field laboratory near the tower.
In addition to recording average values for each of the
parameters monitored (totals for rainfall), the data acquisition
system will calculate and record averages of standard deviation
of wind direction, commonly called sigma theta. The sigma theta
variable is a measure of atmospheric turbulence, a parameter
important in determining atmospheric dispersion characteristics.
The data acquisition system will calculate 5-minute and
hourly averages. Hourly averages will be recorded and used for
impact calculations for the time-integrated concentration
measurements.
The hourly averages will be summarized into the various
reports as follows.
Hourly data recovery (monthly)
Mean wind speed (monthly)
Vector wind direction (monthly)
Temperature (monthly)
Barometric pressure (monthly)
Precipitation (monthly)
Percent frequency-wind rose (monthly)
Hourly observations (daily)
71
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The equipment specified to be used meets or exceeds EPA-
recommended specifications (EPA, 1987).
The quality control procedures for the meteorological
measurements are designed to maintain equipment accuracy and
acceptability within the tolerance limits given in Table 8.
Criteria for the validation of collected data are shown in Table
9.
Weekly and project-to-date STAR frequency distribution will
be developed each week after the new week's meteorological data
have been manually verified according to established data
validation procedures. The data will then be inserted into the
permanent hourly database. The STAR data represent frequency
distribution of wind speed, wind direction, and atmospheric
stability. This weekly STAR frequency is the meteorological data
that will be used in the dispersion model analysis.
EPA's Industrial Source Complex (ISC) dispersion model will
be used to simulate ambient impacts from the lagoon at the three
fenceline sampling location receptors and three residential
receptors. The ISC model is an EPA guideline model capable of
simulating dispersion from point, volume, and area sources in
both urban and rural dispersion environments. The long-term
version of ISC (ISCLT) will be used to calculate normalized
project impacts at the fenceline and residence receptor
locations. ISCLT uses a meteorological joint frequency distribu-
tion of wind speed, wind direction, and atmospheric stability
class (STAR distribution) to estimate long-term average ambient
impacts.
The basic concept of the dispersion modeling will be to
calculate the average weekly impacts at both the fenceline and
residential receptors using a generic emission rate. By dividing
the normalized residence-receptor impact by the fenceline-
receptor impact, a normalized dilution factor for the
fenceline/residence receptor pair is obtained. This dilution
factor can then be applied to the weekly average French Limited
impact at the fenceline to estimate the weekly average French
Limited impact at the residence receptor location. Average
project-to-date French Limited impacts will then be calculated by
averaging the weekly impacts.
Model calculations will be performed at six receptor
locations: the three fenceline sampling locations and the three
closest residential subdivisions. The three subdivisions, Rogge,
Dreamland, and Riverdale, are located to the northeast, south-
southeast, and south-southwest of the French Limited site,
respectively.
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TABLE 8
Recommended Meteorological Tolerance
Limits
for Audit Results
Parameter Limits1
Wind Speed ±1.12 mph
Wind Direction ±5°
Temperature + 0 . 5 ° C
Relative Humidity ±1.5% RH
Precipitation ±10%
Assurance Handbook for Air
Pollution Measurement Systems: Volume
IV, Meteorological Measurements EPA
600/1-82-060, February 1983.
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TABLE 9
SuBBary of Meteorological Data Performance Goals
Data
Recovery
validation Rate
Parameter Limit {% of
Units (% of true) possible)
Wind speed mph ±5 mph 90%
Wind direction Degrees ±20" 90%
compass
Temperature Degrees ±3°C 90%
celsius
Barometric Inches of ±2 in. of 90%
pressure mercury mercury
Precipitation Inches ±0.01 inch 90%
Relative % ±5% 90%
humidity
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The average compound concentrations produced by the French
Limited operations that are acceptable at any residence, assuming
a full 2 years of remediation, have been calculated. These
acceptable average compound concentrations are referred to as the
Air Criteria Concentrations (ACC) and are shown on Table 5 in
both ppb and /zg/m3. The ratio of the ACC to the calculated French
Limited impact at receptor-residences is referred to as the ACC
Ratio (ACCR). This ratio should be below 1.0 for each compound
at the end of the 2-year remediation program.
As an operational tool to ensure that the final ACCRs will
not exceed 1.0, they will be tracked on a weekly basis. If one
or more of the compound-specific ACCRs is above 1.0 during the
program, necessary operational changes can be made to reduce the
emissions and atmospheric impact of the process.
The overall purpose of the modeling phase is to produce a
simple measure of the remediation operation's impact on
acceptable ambient air concentrations levels at the nearest
residences. This will be accomplished with the calculation of
ACCRs for the 35 HSL compounds measured by the fenceline air
sampling program.
The final product of the modeling phase will be three
tabular reports, one for each sampling location/residence pair,
which will be produced weekly, listing the following information
for each chemical:
• Current weekly average French Limited impact at monitor
sampling location.
• Project-to-date average French Limited impact at
monitor sampling location.
• Current weekly average French Limited impact at
residence receptor location.
• Project-to-date average French Limited impact at
residence receptor location.
• Number of valid samples incorporated into weekly and
project-to-date average.
• Weekly ACCRs.
• Project-to-date ACCRs.
A copy of these reports will be kept on-site for review by
operations personnel for their use in decisions on future
operations at the site and for review by regulatory agencies.
The report will also be included in the monthly project progress
reports.
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CONCLUSIONS
The evolution of the Ambient Air Management Program for the
French Limited site was the result of a conscious effort
throughout the project to consider air impacts. The database
developed thus far is one of, if not the most, comprehensive for
a Superfund site. Evaluation of the data and the risk-based
monitoring programs developed establish a high level of
confidence that the final remedial effort will accomplish its
ambient air quality management goals. The program developed for
this site can serve as a model for similar remediation efforts
where there is concern over air impacts. Possibly more
importantly, this program has shown that ambient air quality
management should not be thought of as a hinderance to remedial
activities, but as an integral part of the overall process.
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REFERENCES
Sloan, R. "Bioremediation Demonstration at Hazardous Waste
Site," Gas and Oil Journal. September 14, 1987, pp 61-66.
U.S. EPA. 1987. Ambient Monitoring Guidelines for Prevention of
Significant Deterioration TPSD] EPA 450/4-87-007.
U.S. EPA. 1989. Risk Assessment Guidance for Superfund: Vol 1
- Human Health Evaluation Manual (Part A) Interim Final.
Office of Emergency and Remedial Response, Washington, D.C.
EPA/540/1-89/002.
U.S. EPA. 1990a. Integrated Risk Information System (IRIS).
Environmental Criteria and Assessment Office, Cincinnati, OH.
U.S. EPA. 1990b. Health Effects Assessment Summary Tables
(HEAST); First/Second Quarters vFY-1990. U.S. EPA,
Washington, D.C. PB90-921102.
U.S. EPA. 1990c. National Oil and Hazardous Substances
Pollution Contingency Plan. 40 CFR Part 300. Final Rule.
Effective March 9.. 1990.
Author(s) and Address(es)
Bruce E. Dumdei, Ph.D.
Nancy Bryant
ENSR Consulting and Engineering
740 Pasquinelli Drive
Westmont, IL 60559
(708) 887-1700
Ted Davis
French Limited Task Group, Inc.
15010 FM2100
Suite 200
Crosby, TX 77532
(713) 328-3541
Judith Black
U.S. Environmental Protection Agency, Region VI
1445 Ross Avenue
Dallas, TX
(214) 655-6735
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Remedial Construction at the
Industrial Waste Control Site,
Fort Smith, Arkansas
Santanu Ghose
and
Garret Bondy P.E.
U.S. Environmental Protection Agency
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
INTRODUCTION
The Industrial Waste Control (IWC) site is a closed and covered industrial landfill built in an
abandoned surface coal mine. The site was closed in 1978 by the Arkansas Department of Pollution
Control and Ecology (ADPC&E) after contaminants migrated off-site. In 1982, the IWC site was
added to the National Priorities List of hazardous waste sites. In June 1988 a remedy was selected for
the site and in October 1989 remedial construction began. Construction was completed in December
1990, ahead of schedule and for a cost less than that originally estimated.
The purpose of this paper is twofold: First, to describe the most significant portion of the remedial
construction activities that were performed by the Potentially Responsible Party Steering Committee
(referred to as the IWC Steering Committee) with oversight by the U.S. Environmental Protection
Agency (EPA). These activities included excavation of buried drums, stabilization/solidification of
contaminated soils, and construction of a slurry wall and French drain system. Second, to present the
lessons that were learned in completing this many-faceted remediation project.
Because very few remediation projects have actually been completed nationwide, it is important that
those projects that have been completed, serve as learning tools for future projects. In this paper, the
lessons learned at the IWC site are presented for consideration in conducting future remediation
projects.
SITE BACKGROUND
The IWC site covers 8 acres and is located about 7 miles southeast of Fort Smith, Arkansas. The site
was built on an abandoned surface coal mine. Coal mining occurred in the area from the 1800s to the
1940s. Around the site, several undergrond mines operated until 1935. Surface strip mining took
place onsite during the 1940s. Disposal of construction debris and industrial wastes began sometime
in the late 1960s. In 1974, the IWC owner/operator obtained a state permit for an industrial landfill.
Until mid-1978 a wide variety of liquid and solid wastes, including painting wastes, solvents,
industrial process wastes, and metals were disposed at the site.
During its operation as a landfill, the site consisted of a number of large trash and industrial waste
disposal areas and 2 liquid waste surface impoundments. In the spring of 1977 a heavy rain caused
one or more of the impoundments to overflow. This overflow contaminated surrounding livestock
pastures and a pond on a nearby farm. As a result, the ADPC&E closed the site in 1978 by covering
it with soil. After the closing, ADPC&E and EPA conducted field surveys and found contaminated
soils and leachate on the site. EPA conducted preliminary assessments in 1980 and in 1981. In 1982,
EPA placed the IWC site on the National Priorities List (NPL) of hazardous waste sites. EPA
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conducted a phased Remedial Investigation (RI) during the summers of 1984 and 1985 and a
Feasibility Study (FS) in early 1986.
In mid-1986, the IWC Steering Committee requested permission to conduct additional studies to
further define the locations of buried drums and the extent of contamination. The study, which
included trenching and visual inspection for the locations of buried drums, and soil sampling and
analyses, to quantify the extent of contamination, was approved by EPA and was conducted by the
Steering Committee in 1986-87.
Results of the EPA and IWC Steering Committee investigations indicated that there were five areas
of concern at the site (See Figures 1, 2 and 3):
• Area A is an old surface mine used as a landfill. It contained wood products and some solid
industrial wastes.
• Area B received secondary contamination from subsurface leaks from area D and overspills
from area C.
• Area C contained abandoned surface ponds used during landfill operations for evaporation
of organic-rich liquids, solvents, paint thinners, etc. This area contained significant volumes
of contaminated soils and waste sludges.
• Area D contained buried drums filled with organic liquids and contaminated solids. This area
was a major source of contamination for areas A and B.
• Area 09B (See Figure 3) was where ground water samples showed contamination in the
perched zone.
Based upon the results of both the initial RI by EPA and the supplemental investigation by the
Steering Committee, the following conclusions were reached:
• The primary contaminants of concern are methylene chloride, ethylbenzene, toluene, xylene,
trichloroethane, chromium, and lead.
• Up to 3000 liquid filled buried drums may exist in Area D.
• Up to 5800 solid filled buried drums may exist in Areas A and C.
• Contaminated soils exist in Areas A and C and possibly near well 09B.
• Very little ground water contamination has occurred. The most contaminated ground water
is in a perched zone, near well 09B. This zone has a very low yield.
In 1988, EPA selected the following site remedy (See Figure 3):
• Buried drums are to. be excavated from Area D. Liquids from the drums are to be disposed
off-site at an approved RCRA facility.
• Contaminated soils from Areas C and D and around ground water monitoring well 09B are
to be excavated, stabilized onsite, and returned to Area C. The stabilized matrix must pass
the Toxicity Characteristic Leaching Procedure (TCLP) test, as well as the ASTM strength
test.
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• A slurry wall is to be installed around the stabilized soils.
• A French drain system is to be installed along the south, west, and east sides of the site to
intercept and divert shallow ground water around the site. An impermeable barrier, such as
a slurry wall, is to be installed on the site side of the French drain to prevent onsite ground
water from entering the French drain.
• A multilayer RCRA cap is to be constructed to cover the area bounded by the French drain
system and the northern site boundary.
• Monitor onsite and adjacent ground water and impose land use restrictions.
DISCUSSION
After US EPA approved the remediation design documents, construction started on October 16, 1989.
The following discussion describes the excavation of buried drums, the construction of the slurry wall
and French drain, the stabilization of onsite soils, and the capping operations. The lessons learned
during these remedial activities are also described.
Drum Excavation
In accordance with the approved plans, the upgradient and downgradient sides of the Area D
excavation were bordered by clay berms to prevent run-on and run-off during excavation. An area
100 feet by 75 feet with a depth ranging from 6 to 12 feet eventually was excavated. It was planned
that soil and drum excavation be accomplished primarily using backhoe equipment with a drum
grappler to lift drums out of the excavation, even though some manual excavation may be required.
Potentially contaminated soils were also removed during the drum excavation process. This soil was
staged for later screening to determine which soil required stabilization. (This paper does not describe
the screening process.)
A 1:5 entrance ramp was first excavated down into the east side of Area D. A single drum was found
during the ramp excavation. After removing 1.5 feet of soil from the entire area, excavation
proceeded, using a backhoe, moving out from the ramp from east to west. Drum excavation proved
very difficult since the drums were corroded and in various states of disintegration. When a liquid-
containing drum was unearthed and it was leaking or it was too deteriorated to withstand the stress
of removal, it was tapped and its contents were pumped to a new drum (See photo 2 showing a drum
in backhoe bucket being pumped empty). Excavated drums were removed from the area and staged
in a drum staging area for final disposal. Even though great care was used in trying to minimize the
tearing of drums or spilling of drum contents during excavation, spillage did occur. When spillage
occurred, the spilled drum liquids were mixed with clean soil and Class C Flyash (CFA) and moved
to the Soil Staging Facility (SSF), where it was stored for solidification later, with other contaminated
soils.
On January 23, 1990, during excavation on the south wall of Area D, several full drums were
discovered. One drum was 4 ft below grade and partially embedded in soil. The drum was leaking
an orange material. Water was continually seeping from the face of the excavation near the drum.
The contractor attempted to control water around the drum by pumping and adding flyash.
Simultaneously, the contents of the deteriorating drum were pumped to a new drum. A cap was put
on the new drum after it was filled to the desired level. As the drum was being hoisted out of the
excavation, it was noticed that the drum was becoming warm. As the drum was placed on the ground
outside of the excavtion area, workers noticed that the drum was expanding. The contractor tried to
remove the bung cap, but only succeeded in loosening it before the pressure caused foam to spew
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from the drum. The contractor immediately evacuated personnel from the drum area and closed the
perimeter road. The drum was observed from upwind, across the excavation area, using binoculars.
After approximately 15 minutes, the drum swelling caused the drum to tilt 20 degrees from the
vertical (photo 3) and the bottom seam opened up about 6 inches. Soon afterwards, the seam burst and
the drum was propelled into the air. The drum rose approximately 200 feet up in the air (photo 4)
and landed 260 ft away from it's original location. The contractor arrived at the impact point and
measured 3 parts per million total volatile organics with an Hnu meter. Scattered pieces of foam were
found at the impact area. The foam was collected, and soil in a 4 foot by 4 foot area, and 2 inches
deep, around the impact point was removed and brought back to the site. A sample was taken from
this soil for analysis. The analysis showed no site-related contaminants above background levels.
EPA then ordered all drum excavation activities halted until the incident was thoroughly investigated
and corrective measures were taken to avoid additional incidents. EPA, the EPA oversight contractor,
the IWC Steering Committee construction contractor, and personnel from the PRP companies,
participated in the investigation.
During the investigation, personnel from one of the PRP companies identified the foam found around
the drum impact point as a resin that was used by their company to manufacture refrigerators. It is
known that the foam is formed when this resin is combined with water. Based upon this finding, it
was concluded that water seeping from the side of the excavation entered the partially buried drum,
which contained the resin used in the manufacturing process. The water and resin were then pumped
to the new drum, where the water caused the resin to polymerize and become foam. The pressure
created within the drum when the resin, transformed into foam, caused the drum explosion.
On February 20, 1990, EPA issued its approval for the PRP contractor to resume drum excavation,
with a number of modifications to the drum excavation procedures. Some of the more important
modifications were:
• Drums are to be located using techniques which will not disturb, puncture, or crush drums.
These techniques will include probing with a rod and geophysical methods.
• When located, drums should be hand-excavated (See photo 1).
• Liquid from any source, including ground water seepage, should not be allowed to combine
with liquid material contained in any excavated drum.
• Pumps used to pump liquids from a buried drum to a new drum must be purged between
pumping from different drums.
• Drums that are to receive liquids pumped from buried drums are to be inspected before
receiving waste, to ensure that no liquids are already in drum.
On February 24, 1990, drum excavation in Area D was completed. A total of 102 liquid filled drums
were excavated from Area D. These drums were staged onsite and eventually incinerated at an off-
site facility. Many solid filled or crushed drums were excavated, and approximately 2600 yd3 of soil
were excavated from area D. Backfilling of the area was completed between March 1 and March 3,
1990. Empty drums were crushed and covered in the excavation.
On June 25, 1990, excavation of potentially contaminated soils began in Area C. An area 125 eet by
75 feet with a depth ranging from 19 feet to 26 feet was eventually excavated.
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During Area C excavation two large areas of buried drums were unexpectedly encountered on the
southern edge of the area. Between July 20 and August 9, 1990, a total of 142 liquid filled drums
were excavated without incident, using the modified methods used for drum excavation in Area D.
The liquid-filled drums were staged onsite and eventually incinerated off-site. Empty and solid filled
drums were re-buried in the excavation.
Slurry Wall Construction
Two slurry walls were constructed. One wall, referred to as the site slurry wall, was constructed to
serve as an impermeable barrier between the site and the French drain (See Figures 1 and 3). The site
slurry wall has three legs, which parallel the French drain and surround the site from the south, east,
and west.
The other slurry wall, referred to as the Area C slurry wall, was constructed around Area C (See
Figures 1 and 3) to contain the stabilized soils from Areas C and D. It has three sides, with the fourth
side being the site slurry wall.
Prior to construction of the slurry walls, the ability of the slurry wall material to act as a barrier to
site-related contaminants was tested. It was required that the wall have a permeability of less than
1 x 10~7 cm/sec for site-related contaminants. The test required that the water/bentonite/soil mixture
be tested for permeability using a leachate solution representative of the site. Five pore volumes of
the leachate solution containing a total contaminant concentration of 1000 ppm (containing equal
proportions of toluene, xylene, methylene chloride and trichloroethylene) were passed through a
sample of the slurry mixture. This procedure, which required approximately 2 months to complete,
confirmed that the wall had an average permeability of 4.6 x 10"8 cm/sec.
Both slurry walls had the same specifications. These specifications were, in general, standard
specifications for slurry walls. In order to ensure compliance with the specifications, tests were
performed on the slurry wall materials, on a regular basis. Some of the specifications are described
below:
• The slurry walls were built to have a minimum vertical wall thickness of 30 inches (See Figure
4).
• The slurry wall trenches were dug to a depth of backhoe refusal, rather than 3 ft into the
weathered shale as originally planned. The original procedure was felt to be imprecise as the
shale weathers completely. Excavating to backhoe refusal ensured that the bedrock was
reached. While this required additional excavation, it was believed to result in a superior
slurry wall.
• The water/bentonite mix had to meet the following specifications prior to mixing with soil:
- Density = 64 to 85 lb/ft3
- Marsh Viscosity * 40 seconds
- Max Filtrate loss = 30 cm3/30 minutes @ 100 lb/in2
• The water/bentonite/soil mixture that was placed into the trench to form the slurry wall must
have a final permeability of no more than 1 x 10"7 cm/sec.
Construction of the site slurry wall began on March 13, 1990. The first slurry was mixed using water
from an existing onsite well. However, slurry mixing was delayed due to low flow from the well.
To correct this problem, a frac tank was placed next to the slurry mixing pits. The tank was used to
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store water, and it was filled at night and during slack periods from the same onsite well. Water from
the tank was then drained directly into mixing pits, as needed.
The site slurry wall was installed in three separate segments. The first leg of the site slurry wall was
started at Pt. 5 (See Figures 3 and 4). A starter trench with a 1 in 4 slope began this leg, and the
slurry wall was installed, moving towards Pts. 3 and 4. A small pocket of drums was unexpectedly
discovered near Pts. 3 and 4. The drums were removed and the excavation was backfilled with clean
compacted soil. The slurry wall was then completed to the site's southwestern corner, at Pt. 3.
The second leg of the site slurry wall was started on the northwestern extremity of the site, at Pt. 2,
and progressed towards Pt. 3. The slurry wall had been installed only a short distance when the
trenching unexpectedly encountered a part of the abandoned landfill. The work was halted and a
decision was made to excavate the landfill debris and bury it under the cap within the site slurry wall.
This excavation was then backfilled with clean, compacted material.
In order to minimize the delay in completing the site slurry wall, construction of the third leg began
while the landfill debris along the second leg, was being excavated. Construction of the third leg
began at Pt. 6 and was completed upon reaching Pt. 5. Construction was then resumed on the second
leg. The entire site slurry wall was completed on March 11, 1990, when the second leg was completed
at Pt. 3.
In total, the site slurry wall had an approximate length of 1400 feet and required approximately 1741
yd3 of the water/bentonite slurry.
Construction of the Area C slurry wall commenced on September 18, 1990, and was completed
without unexpected events on September 20, 1990. The Area C slurry wall was approximately 465
feet long and required approximately 726 yd3 of the water/bentonite slurry (See Figures 3, 6, and 7).
French Drain
The French drain was constructed 10 to 20 ft upgradient from and parallel to the site slurry wall (See
Figures 3, 5, and 5b). The purpose of this drain is to intercept upgradient, clean, ground water and
detour it around the site. The French drain consists of a highly permeable, gravel filled trench with
a perforated collection pipe installed along the bottom. The perforated collection pipe was connected
to non-perforated pipe on the east and west ends of the system. These pipes carry the collected
ground water into two recharge wells. The recharge wells were completed into two empty coal mine
voids located immediately north of the site (denoted as Pts. 1 and 6 on Figure 3).
The French drain trenches were dug down into the shale layer so that the drain bottom was keyed into
the shale, in accordance with the construction plans. A four-inch perforated pipe was placed in the
bottom of the trench and covered with filter sand to within 2 feet from the ground surface. The
remaining 2 feet of trench were then filled with compacted backfill.
Just south of Pt. 6, along the eastern side of the site, it was known that the French drain would cross
the abandoned landfill (See figure 5). To avoid settling of the landfil beneath the French drain, and
subsequent damage to the system, a gravel bridge was planned and constructed across the landfill.
This bridge was constructed before installation of the French drain began. In constructing the bridge,
the landfill debris was removed down to bedrock. The excavation was partially filled with gravel and
then filled with compacted backsoil up to the elevation of the perforated piping.
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In order to avoid contaminating the clean ground water that is being diverted around the site, with
leachate from the landfill, the perforated pipe was enclosed in a solid pipe as it crossed the landfill.
Once the piping was laid, compacted backfill was placed over the piping.
Construction of the French drain system began with the installation of the mine void recharge
manway at the northeast end of the site (Pt. 6). This recharge well was completed on April 30, 1990.
A French drain trencher was then used to lay the French drain piping and filter sand. Installation
began at the northeast corner of the site and progressed around the site towards Pt. 5. In the middle
of the southeast side of the site, the rock became too shallow for the trencher to operate. The
remainder of the southeast side of the drain to the highest point was installed using a sewer box and
backhoe method.
A small pocket of drums was unexpectedly encountered where the drain turns northwest on the
southern perimeter (See Figure 3). A clay plug was installed on the French drain pipe to prevent
contamination of the pipe, while the drums were removed. Once the drums were removed,
installation of the drain proceeded. Drain construction was completed on June 15, 1990.
Soils Stabilization/Solidification Pilot Study
The selected remedy required that the contaminants in soils be immobilized through a stabilization
process.
Stabilization is a widely accepted practice for immobilizing metals in soils and sludges. Recently,
interest has grown in stabilizing organics. Soundararajan, Earth and Gibbons (1990) experimented
with the use of organophilic clay to stabilize waste containing organic compounds. Waste samples
from a recycling facility in northern Florida containing naphthalene, phenanthrene, and benzo-a-
anthracene were stabilized using synthetic organic clay. Using several sophisticated analytical
techniques, it was shown that chemical bonding, not mere absorption, occurred between the clay and
the organic contaminants.
Caldwell, Cote and Chao (1990) experimented with different cement-based additives to stabilize
wastes with organic contaminants. Included in their study were monocyclic aromatic compounds
including benzene, toluene, and orthoxylene (all were priority pollutants at the IWC site). Caldwell,
et al concluded that chemical containment of organic compounds is possible, but is highly contaminant
dependent.
Bench scale studies conducted for the IWC Steering Committee indicated that Class C flyash (CFA)
would be an effective stabilizing agent at the IWC site. However, it was unknown how much CFA
should be used, or the curing time that would be required. In order to delineate these important
parameters, a pilot study was performed.
A 12 foot by 12 foot area was excavated from Area C to obtain samples for the pilot. Previous
sampling from the area had indicated that the northwest corner of area C was most likely to yield the
most highly-contaminated soils. Prior to the excavation, the area was preconditioned with CFA to
minimize volatile emissions and to ease materials handling of the soils, which oftentimes had a sludge-
like consistency. The preconditioned material was stockpiled for the pilot.
Figure 15 shows the test plot for the pilot study. The test plot was 50 feet (E-W) x 80 feet (N-S),
subdivided into 5 sections each 16 feet wide. The preconditioned soils (20% CFA was added prior
to excavation), which had a total volume of approximately 73 yd3, were spread over the test plot to
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a depth of 6 inches. After removal of debris (small rocks, concrete chunks), the particle size of the
soil was reduced by having a Cat SS-250 soil stabilizer make six passes over the test plot.
A front end loader then evenly distributed CFA in measured quantities into the five subsections.
CFA was added to each subsection in 20% increments. The first subsection received an additional
20% from that already received prior to excavation (for a total of 40% CFA added), and the last
subsection received an additional 100% (for a total of 120% CFA added). After adding a requisite
amount of water, each of the five subsections received three passes by the Cat SS-250 for final
blending. Following the final blending, a CT-433 sheep's foot compactor was used to compact the
material.
After the test plots had cured for 26 days, samples of the stabilized material were taken with a hand-
operated coring tool and sent to laboratories for TCLP testing. The tests were conducted after 28 days
of curing. The only sample to pass the TCLP test (See Figures 9, 10, 11) for all of the target
chemicals (ethylbenzene, toluene, xylene plus metals barium and total chromium) was that sample
where a total of 120% CFA had been added.
Samples for the ASTM-2166 Unconfined Compressive Strength Test (UCS) were taken between 2 and
7 days of curing. All samples except one, with 80% CFA (a total of 100% CFA added), failed to pass
the 50 psi UCS after 7-day curing (See Figures 12 and 13). However, subsequent bench scale testing
indicated that solidification with the addition of 4% Portland cement achieved 90 psi UCS after 7-day
curing. Blends with 8 and 12% cement attained higher compressive strengths (See Figure 14).
Based upon the results of this study, it was concluded that in order to meet both the TCLP and
compressive strength requirements, a total of 120% CFA should be used in conjunction with 4%
Portland cement. It was further concluded that the curing time was somewhere between 0 and 28
days.
Soils Stabilization/Solidification
Prior to beginning the full-scale stabilization process, a one-foot thick clay liner was added to the
floor of Area C excavation, to serve as a leachate barrier. Mixing pads were also constructed near
Area C, east of the Soil Staging Facility.
On June 25, 1990, the full-scale soil stabilization/solidification phase began. A total of seven lifts
were each treated with 120% CFA and mixed on the pads near Area C. An adequate amount of water
was mixed in, and each lift was allowed to cure.
While the first pad was curing, daily samples were taken to test for the TCLP target compounds,
benzene, ethylbenzene, toluene, xylene, using a field GC/MS. Samples were also sent off-site every
few days to a laboratory for TCLP analysis. From the results, a correlation between the target
compounds, as analyzed using the field GC/MS, and the laboratory TCLP results, was developed.
This correlation was then used to predict when to perform the required TCLP analyses, based upon
the less expensive field GC/MS results.
The first stabilized pad passed the TCLP test in 17 days. For subsequent pads, the curing time
required to pass the TCLP test varied from 11 days to 17 days.
When the first lift passed the TCLP test it was taken into Area C for in-situ solidification, using 4%
Portland cement. On August 23, 1990, this first lift of stabilized/solidified material unexpectedly
failed the 7-day 50 psi UCS criterion. The lift was broken up using a disc and bulldozer and
85
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repulverized using an SS 250 mixer. An additional 8% cement was added to the lift. On August 27
the re-cemented lift attained a compressive strength of 125 psi in 3 days and passed the UCS criteria.
Subsequent lifts passing the TCLP criteria on the mixing pads were brought to Area C and spread
over the previously solidified material. These lifts were solidified in-situ by mixing 8% cement, and
all passed the UCS criteria in less than 7 days.
Soil stabilization/solidification was successfully completed on September 10, 1990. Approximately
12,800 yd3 of soil was excavated, of which 1800 yd3 was found to be contaminated, and this was
stabilized/solidified.
RCRA Cap & Cover
The RCRA cap and cover was installed to prevent surface infiltration, which could cause leaching
of the buried waste. The cap and cover was installed over the majority of the site including Areas
B, C and D (See Figures 1 and 3).
The cover system consists of a 2-foot clay layer overlaid by a high density plastic liner (HOPE liner).
A one-foot sand drainage layer covers the HDPE liner. This layer is covered with geotextile filter
fabric. The geotextile fabric is covered with 1.5 feet of compacted backfill. Six inches of top soil
is spread over the entire cap. Along the toe of the cap, a geogrid and gravel drain wedge is installed.
(See Figures 8 and 8b).
During the cap construction, two small areas of landfill trash were discovered on the north edge of
the cap outside the boundaries of the original cap. The first area in the northeast was discovered early
during installation of utilities. The second area of trash was found while digging the anchor trench.
Specifications of the cap were changed to enclose this area under the cap boundary.
Preliminary work on cover installation started before Area C solidification was complete. The
contractor started to move, compact and grade the general site backfill on August 23, 1990.
The installation of the 2-foot clay layer started on the east end of the site on September 17, 1990. The
clay was compacted in four lifts, each about six inches thick. Moisture and density tests were
conducted to ensure proper compaction. The cap was maintained prior to the installation of the liner
by scarifying and wetting, as necessary, and by rerolling and fine grading. The clay cap was
completed by October 17, 1990.
Installation of the 60 mil HDPE liner started on October 11, 1990, while the clay layer was still being
completed. Before laying each piece of the liner, the portion of the clay cap to be covered, was
inspected to ensure that the liner would not be damaged by underlying material. Panels of the HDPE
were unrolled and cut to the approximate length and shape. The panels were fitted and welded. The
panel welds were vacuumed and pressure tested. HDPE boots were fitted over the piezometers and
wells and welded to the liner (See Figure 8). The HDPE liner was installed over the entire site by
October 30, 1990.
Construction of the geogrid and gravel toe drain was started on October 22, 1990. A 2 inch by 12
inch form was placed between the toe drain and the sand drainage layer. This form was removed
after sand and gravel were installed (See Figure 8b). Geogrid installation was complete by November
3, 1990.
The sand drainage layer was started on October 18, 1990. Sand was delivered to the east end of the
site and pushed over the HDPE liner using a low ground pressure dozer. As the front of the sand
86
-------
progressed across the site crane mats were used to support dump trucks delivering sand. The sand
drainage layer was completed on November 9, 1990.
The geotextile filter fabric was then installed over the sand drainage layer to prevent fines from the
overlying soil backfill from permeating into the sand layer.
The first backfill layer was placed and compacted on October 31, 1990. The first lift of the backfill
was one-foot thick before being compacted. The second lift brought the backfill to the required
compacted thickness of one-and-a-half feet. The last of the backfill was placed on November 29,
1990.
Following completion of the backfill, a topsoil layer was lightly compacted over the entire cap to a
minimum depth of six inches. Placing of the top soil started on November 19,1990. The surface was
hydromulched between December 12 and 14, 1990 to start the vegetative cover. Erosion control
fabric was placed on the side slopes of the cap to prevent excessive water flowing off the cap. The
cap and cover installation was complete on December 14, 1990.
CONCLUSIONS
Remedial construction at the IWC site involved a wide range of activities. Contaminated soils, trash,
and buried drums containing liquid hazardous wastes, were excavated from landfill areas. Two slurry
walls were constructed, as was a French drain that included two recharge wells. Contaminated soils
were stabilized and solidified following a pilot study. A RCRA cap was also constructed. All of these
tasks were successfully completed. Overall, the remedial construction was completed ahead of
schedule and well within the estimated costs.
Because very few remedial construction projects have been completed nationwide, it is important that
those projects that have been completed, serve as learning tools for future projects. While this project
was successfully completed, some important lessons were learned.
The following is a summary of the lessons learned at the IWC site:
• It is extremely difficult, but very important, to accurately define the locations of landfill
debris, as well as the locations and number of buried drums. This is difficult because,
usually, very few landfill operating records are available, and because investigations using
boring techniques oftentimes miss large areas of buried debris or drums. It is recommended
that remedial investigations at landfill sites include the use of ground-penetrating radar which
is capable of locating 55-gallon drums at depths of 6 to 9 feet, as well as investigative
trenching techniques.
Throughout the IWC construction phase, the importance of accurately defining the locations
and number of buried debris and drums was illustrated. Landfill debris was unexpectedly
encountered during construction of both the site slurry wall and the RCRA cap. While this
only resulted in minor delays and minor modifications to the construction plans, more
significant delays could result at different projects.
In addition, far fewer buried drums were found in Area D, than had been estimated, and
buried drums were unexpectedly encountered while excavating contaminated soil in Area C.
It had been estimated that as many as 3000 liquid-filled buried drums may exist in Area D,
but only 102 were found. Conversely, buried drums were not expected in Area C, and 142
liquid-filled drums were found. While finding far fewer drums in Area D did not disrupt the
87
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project, unexpectedly finding drums in Area C did. Installation of the French drain system
was also disrupted when buried drums were unexpectedly discovered.
• Excavation of buried drums is both difficult and dangerous. Buried drums tend to be in
various stages of disintegration and can spill their contents with the slightest disturbance.
Oftentimes, in order to minimize the release of a drum's contents, it is necessary to either
hand-excavate the drum and/or pump its contents to a new drum. The drum explosion
demonstrated how dangerous drum removal can be. Great care must be taken to minimize the
commingling of different materials within an excavtion. This obviously includes minimizing
the flow of ground water into an excavation. In addition, it is imperative that the excavation
crew constantly watch for signs of an unexpected reaction.
• Construction plans must ensure that enough water is always available. Onsite wells may not
be capable of continually supplying enough water as it is needed, particularly during peak
construction periods. It may be necessary, especially in rural settings, to store water onsite
to ensure its availability.
• It is very important that bench scale and pilot studies be conducted to estimate the amount of
stabilization and solidification agents needed, as well as the necessary curing times. These
tests should attempt to simulate fullscale field implementation as closely as possible. During
the IWC pilot, the addition of cement to attain the UCS criteria should have been performed
on the mixing pad instead of in a bench scale test in the laboratory. This would have
indicated before full scale work began the optimum amount of cement necessary to attain the
UCS criteria and avoided having to re-pulverize the first lift.
ACKNOWLEDGEMENTS
We extend our thanks to the IWC Steering Committee for providing relevant information to prepare
this paper. Special thanks are due to Mr. William Bowen and Ms. Sherry Spencer of the U.S. Army
Corps of Engineers who provided oversight on behalf of U.S. EPA to assure construction quality. Mr.
M. S. Ramesh deserves thanks for guiding the IWC project through remedy selection and remedial
design.
REFERENCES
1. Caldwell R.T., Cote P.L., Chao C.C., Investigation of solidification for the immobilization of
trace organic contaminants. Hazardous Wastes & Hazardous Materials, Volume 7 No. 3, 1990
2. Soundararajan R, Barth E.F., Gibbons J.J., Use of an Organophilic clay to chemically stabilize
waste containing organic compounds. Hazardous Materials Control January/February 1990.
-------
SURFACE DRAINAGE DITCH - DinECTS FLOW AROUND SITE BOUNDARIES
FRGNCH DRAIN
SLURRY WALL
AREA 0
CAP 1 COVER - MINIMIZE INFILTRATION
4 PROMOTE RAPID RUNOFF
CONTAINMENT WALL
fflCtOW CAP AND COVCHI
flLLCO DRUMS
INTERCEPTOR
TRENCH- COLltCT AND OIVCRT/
sues '
suesuRfAct FLOW
^iU^XiXXliV HA*T$MO«NC/ATO»tA REGIONAL GROUND W A T E R F L 6 W " UUXUUXUt^S^
XXXXXXXXXXXXXXXVXXX XX XXXX^X XXXXXXXXXXXXXX
vvvxxXXXXXXXXXXXXXXXXXXXVXXXXXXXXXXXXXXXXXXXXXxXXXXX*
^XxxXXXXXXXXXXXXXXXXXXVXNSXXX^XxXXXXXXXXXXXxXXXXXXXX'
AN^ xxx\xxx*x\xvxx*xxxxxxxxxxxxx"xxxxxxxxxxxxxxx
XX^XXXXXNSXVXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXV\XXXXXXXXXXXXXXXXXXXXXXNXXXXX
XXXxXxXXXNXXXXXXX XXXX\X XN XXXX^
FIGURE 1 - THE REMEDY SELECTED FOR THE IWC SUPERFUND SITE
-------
CD
O
rREMNANT
STRIP MINF
EStr^
M/f
••%:•!>--.f ) Y/-J /•/ -r^Vi. MJ ^r^-^.^v^ VC"-- Nb -W^- -^>
- ^^N/AV-^^-<> "\^ ^-^!7,>- V*:0 - 4?l f Q
EGEND" /''» 1 I i -'.._: i; ;r:":0 y '> •' ,;; 1 i-:y ' V-P r,\ xX
V N' •'' ' " * ' '' '"'
LEGEND ,. i i • , ...-:>..<
AREA A STRIP MlhjE/ _ | V - V> A/\
AREA B" DISPOSAl/'AREf FOR )A I \\
•«!'_,. - VARIETY OF.WASTES \\\ \\\ < \
AREA C TWO FORMER LIQUID WASTE
SURFACE IMPOUNDMENTS
AREA D LIQUID FILLED AND CRUSHED
DRUM DISPOSAL AREA
Figure 2
IWC SITE BOUNDARY
PREPARED FOR
IWC SETTLING DEFENDANTS
FORT SMITH. ARKANSAS
-------
~l
CD
10--201
SEPARATION
AREA C SLURRY WALL/SITE SLURRY
WALL KEY
NOTE:
SLURRY WALL AND FRENCH DRAIN
BELOW CAP AND COVER
NOT TO SCALE
LEGEND
It I \ 1 I < I |
EXISTING FENCE
RCRA CAP AND COVER
PROPOSED EXTENDED BOUNDARY
AND NEW FENCE
AREA C SLURRY WALL
FRENCH DRAIN
SITE SLURRY WALL
-=• DISCHARGE PIPE
CLEAN BACKFILL
FIXATED WASTE
MANHOLE/PIPE DISCHARGE
POINT TO MINE
Figure 3
SLURRY WALL,
FRENCH DRAIN.
AND CAP AND COVER
PREPARED FOR
IWC SETTLING DEFENDANTS
FORT SMITH. ARKANSAS
NOTE: MONITOR WELL LOCATION HAS BEEN
PLOTTED FROM EXISTING LOG.
-------
TYPICAL CROSS-SECTION
OF SITE SLURRY WALL
NORTH
RCRA CAP 6 COVER
CAP PERIMETER
DRAINAGE CHANNEL-
FRENCH DRAIN
SITE SLURRY WALL-
SOUTH
FILLED IMPOUNDMENT
10'-20' SEPARATION
DETAIL
RCRA CAP AND COVER
Y////////////,
CLAY PLUG— tZJ
SHALE
TO
10'-20' SEPARATION
SITE
SLURRY WALL
-THICKNESS DETERMINED
DURING THE REMEDIAL
DESIGN PHASE
-KEY
SITE SLURRY WALL
DETAIL
/^-FRENCH DRAIN
Figure 4
SITE SLURRY
WALL CROSS-SECTION
AND DETAILS
PREPARED FOR
IWC SETTLING DEFENDANTS
FORT SMITH, ARKANSAS
NOTE: THIS FIGURE IS NOT TO SCALE.
92
-------
TYPICAL CROSS-SECTION
OF FRENCH DRAIN
NORTH
CAP PERIMETER
DRAINAGE DITCH-
FRENCH DRAIN-
SOUTH
DETAIL
CAP PERIMETER
DRAINAGE DITCH
RCRA CAP AND COVER
SHALE
• A
•». r
•a .<•
A -
:c
NATURAL GROUND SURFACE
-GRAVEL
THICKNESS DETERMINED
DURING THE REMEDIAL
DESIGN PHASE
4 0 PERFORATED
DRAINAGE PIPE
KEY
TYPICAL FR NCH DRAIN
DETAIL
NOTE: THIS FIGUF IS NOT TO SCALE.
Figure 5
FRENCH DRAIN
CROSS-SECTION
AND DETAILS
PREPARED FOR
IWC SETTLING DEFENDANTS
FORT SMITH, ARKANSAS
93
-------
48' DIA. PRECAST CONCRETE
MANHOLE W/BOLTED DO
BACKFILL
MATERIAL
DIA. PVC
PERFORATED
DRAIN PIPE
W/FILTER SOCK
CONCRETE PAD
LEVELING
LAYER
6' MIN.
EXISTING LANDFILL MATERIAL
4' DIA. PVC
NON-PERFO
DISCHARGE PIPI
CENTRALIZERS
(AS NECESSARY
4" TO 6" DIA. PVC
VERTICAL
DISCHARGE PIPE
EXISTING MINE VOID
FRENCH
DRAIN
•* "MATERIAL
NOTES:
1) THE WEST SIDE CROSS-SECTION WILL BE SIMILAR
BUT SHOULD NOT INCLUDE A LANDFILL CROSSING.
2) THIS FIGURE IS NOT TO SCALE.
Figure 5b
CROSS-SECTION OF FRENCH
DRAIN DISCHARGE SYSTEM
(EAST SIDE)
PREPARED FOR
IWC SETTLING DEFENDANTS
FORT SMITH, ARKANSAS
-------
TYPICAL CROSS-SECTION OF
AREAC SLURRY WALL
NORTH
SOUTH
AREAC SLURRY WALL
RCRA CAP AND COVER -, ^.-^.f/.
F|1 . X LANDFILL
AREA
CLAY PLUG
SHALE
MINIMUM
FIXED WASTE
AREA C
SLURRY WALL
THICKNESS DETERMINED
DURING THE REMEDIAL
DESIGN PHASE
Figure 6
-KEY
DETAIL
AREA C SLURRY WALL
DETAIL
AREA C SLURRY WALL
CROSS-SECTION AND DETAILS
porp*ofn COP
IWC SETTLING DEFENDANTS
FORT SMITH, ARKANSAS
NOTE: THIS FIGURE IS NOT TO SCALE.
95
-------
TYPICAL CROSS-SECTION OF
AREA C SLURRY WALL/SITE SLURRY WALL KEY
AREA C SLURRY WALL/SITE SLURRY WALL-
NORTH
SOUTH
RCRA CAP AND COVER - 7 -»-3-
AREACSLURRY WALL
DETAIL
THICKNESS
DETERMINED
DURING
REMEDIAL
DESIGN
PHASE
AREA C
SLURRY WALL
SITE SLURRY WALL
THICKNESS DETERMINED DURING
REMEDIAL DESIGN PHASE
Figure 7
PLAN VIEW OF
AREA C SLURRY WALL/
SITE SLURRY WALL
KEY DETAIL
AREA c SLURRY WALL/
SITE SLURRY WALL KEY
CROSS-SECTION AND DETAILS
PREPARED FOR
IWC SETTLING DEFENDANTS
FORT SMITH. ARKANSAS
NOTE: THIS FIGURE IS NOT TO SCALE.
Do Not Si ale Tnis
96
-------
NORTH
TYPICAL CROSS-SECTION
RCRA CAP AND COVFR
AND MONITOR WELL
DETAIL
PIKIMETCM
DftAINAQE CHANNEL
FRENCH DRAIN .
SITE tLUHMY WALL
SOUTH
FILL MATERIAL
1.5'
OEOTEXTILE
STAINLESS STEEL
BAND WITH
NEOPRENE GASKET
X
SAND DRAINAGE LAYER
-•VNTMETIC MEMBRANE
COMPACTED CLAY
FIXED WASTE/
LANDFILL MATERIAL
—=///=\\\=/// =///=
BEDROCK
RCRA CAP AND COVER
AND MONITOR WELL
DETAIL
MONITOR
WELL
CASING -
CASING
"SLEEVE
FLANGE/
LINER
WELD
-SCREENED
INTERVAL
Figure 8
NOTE: THIS FIGURE IS NOT TO SCALE.
RCRA CAP AND COVER
ANDTYPICAL MONITOR WELL
CROSS-SECTION AND DETAILS
PREPARED FOR
IWC SETTLING DEFEDANTS
FORT SMITH. ARKANSAS
Nol S-He
97
-------
Vegetated Surface Cover
Erosion Control Fabric
^/rriyf^^^y^W'^yy^'yf^^ ; ^ryr " " . ^ •. ^,: .^
/ /, //,'* /ss •'* -^^^ 1^*1 1 *'Pi 1-1 4rfl'l 1't < iX'l'l^T'l f¥ f l^^l I 'T\ A I \_l'J*r !•! 1A J I't^L-L I V^ 1 I'I*'T L^'Vfl*!^^ / 1 I T I*I^T*
Geotextile -
Filter Fabric
^pntf.S.i^.u.i.i.n.r
ntrol -fabric
CD
00
Geomembranc
Anchor Trench
Slurry Wall
Figure 8b
RCRA Cap & Cover
Cross-section details
-------
Leachate concentration Vs Percent CFA
Ethylbenzene
0.12
40 60
Percent GFA
80 100
WC Pilot 28 day cure
Series 1
TCLP
Fig 9
99
-------
Leachate Concentration Vs Percent CFA
Toluene
1.4
1.2
P
?
M
0.8
T
O
L
U 0.6
E
N
E
0.4
0.2
20
40 60
Percent CFA
80
100
Series 1
Fig 10
IWC Pilot 28 day cure
TCLP Crttorta
100
-------
Leachate Concentration Vs Percent CFA
Xylene
0.5
0.4
P
M 0-3
X
Y
L
E 0.2
N
E
0.1
20
40 60
Percent CFA
80
100
Series 1
Fig 11
IWC Site 28 Day cure
TCLP Criteria
101
-------
Percent CFA Vs UCS
1 day increment cure
40 60
Percent CFA
80
2 day cure
4 day cure
3 day cure
6 day cure
100
Fig 12
IWC Pilot
102
-------
Percent CFA Vs UCS
1 day increment cure
u
c
s
p
•
i
20
6 day cure
40 60
P«rcnt CFA
•+- 7 day cure
80
100
IWC Pilot
7 d Shelby
Fig 13
103
-------
Percent Cement Vs UCS
7 day cure
u
c
p
•
i
160
140
120
100
80
60
40
20
4 8
Percent Cement
12
2 hrs after Blending
iwc Pilot
4 hrs after Blending
Fig 14
104
-------
LOCATION OF TEST !>IL.OT
•Ol II
•--1
BXCAVATIOV
LOCATION
Figure 15
105
-------
Photo 1 : Drum being dug out by hand, area D
Photo 2 : Pumping liquid from deteriorated drum
in backhoe, area D
106
-------
Photo 3 : Drum incident, notice tilted drum
left of 18. Also notice warped top
of the tilted drum
Photo 4 : Tilted drum propelled into air.
Notice drum in the horizon above pickup
truck.
107
-------
BAYOU BONFOUCA SUPERFUND SITE
CASE STUDY OF SELECTED ISSUES
Slidell, Louisiana
(Author(s) and Address(es) at end of paper)
I) INTRODUCTION
The Bayou Bonfouca Superfund Site is one of the largest, most
complex hazardous waste problems in the country. Cleanup of this
site, which will cost in excess of $100 million, is now
successfully being implemented after resolution of numerous
technical and policy issues. The purpose of this paper is to
summarize resolutions to five critical issues which developed
during the design. Each of these items threatened to cancel any
active remedial response or to render its cost prohibitive. They
include:
1) discovery of a threefold volume increase in waste, potentially
invalidating the selected remedy;
2) development of a construction management system to prevent
fugitive air emissions from threatening residents around
the site;
3) adoption of a dry weight payment criteria for the incineration
process that potentially affects future incineration projects;
4) funding of such a large project; and
5) bonding requirements to ensure competitive bids.
The authors from the Environmental Protection Agency (EPA) have
chosen to provide a relatively brief review of these pertinent
issues, thereby giving a broad perspective of the complex
challenges involved in large Superfund projects. In addition, this
paper allows reviewers to identify possible areas in which they may
want to contact the authors for additional information and valuable
lessons learned.
II) SITE HISTORY - RECORD OF DECISION
The Bayou Bonfouca Superfund site is located within the city of
Slidell, St. Tammany Parish, Louisiana. The site consists of an
abandoned creosoting facility on 52 acres of land and an adjacent
contaminated bayou for which it is named. The community of Slidell
has a population of approximately 26,000 and serves primarily as
a bedroom community for New Orleans, which is about 25 miles away.
The land use adjacent to the bayou ranges from a industrial complex
that manufactures concrete piles to an apartment complex,
condominiums, and residential homes within 25 feet of the bayou.
The project was placed on the original National Priorities List in
1983 and included consideration of second degree burns being
received by Coast Guard divers during bayou sampling.
108
-------
Creosote operations began in 1892 and continued until 1970 when a
fire destroyed the plant. Remedial Investigations (RIs) and
Feasibility Studies were completed in 1987, and a Record of
Decision (ROD) was signed in March 1987. The results of these
investigations indicated concentrations of up to 12% polynuclear
aromatic hydrocarbons (PNAs) in surface waste piles, several
percent PNAs concentrations in the bayou sediments, and pure
product creosote within the ground water. The remedial action
ultimately selected included the following:
a) onsite incineration of 46,500 cubic yards of contaminated
sediments and 5,000 cubic yards of waste pile materials;
b) placement of an engineered cap over the ash from the
incinerator and the residual surface soils greater than 100
ppm total PNAs;
c) pump/treatment/reinjection of contaminated ground water; and
d) the estimated total construction cost was $55 million.
The RI characterized the general subsurface (Figure 1) at the
abandoned facility as being a few feet of sandy fill material
(surficial aquifer), overlaying about 20 feet of clay, which
covered approximately 12 feet of silty sand (shallow artesian
aquifer). Below the silty sand is another clay layer 10 to 20 feet
thick which rests on top of a sand layer (deep artesian aquifer).
The surficial aquifer results from recent rainfall events and does
not yield significant quantities of water; but it has been shown
to contain dissolved PNAs whenever water is able to be recovered.
The shallow artesian aquifer is known to contain free product
creosote, while the deep aquifer is uncontaminated.
The Agency in conjunction with the State of Louisiana indicated to
the local community, during the ROD public meeting, that the
selected remedy was "conceptual" in nature and that additional
studies were necessary during the Remedial Design (RD) phase.
These studies were to be conducted to gain more refined information
so as to develop detailed plans and specifications.
In 1988 RD field investigations were started to support the
preparation of detailed plans and specifications. This work was
conducted by CH2M HILL under contract to EPA with the Army Corps
of Engineers providing technical assistance. The primary emphasis
of this phase was to: 1) further delineate boundaries of
contaminated ground water and to evaluate the ability to pump and
treat; 2) better determine the extent of contaminated sediments
and related engineering properties; 3) evaluate the air emissions
during dredging and materials handling; and 4) evaluate the ability
to dewater the sediments. As a result of these investigations the
project was divided into two operable units as detailed below.
109
-------
Creosote Plant Site
GENERAL CROSS-SECTION
( not to scale )
Bulkhead
Resldental Area
O
Fill Material
Surface Soil
Previously assumed//
depth of Ii
contamination/ /
Upper Cohesive Layer
Upper Cohesive Layer
Actual depth/
nt I
contamination
Shallow Artesian Aquifer
Shallow Artesian Aquifer
Lower Cohesive Layer
Deep Artesian Aquifer
BAYOU BONFOUCA
Figure 1
-------
Ill) GROUND WATER OPERABLE UNIT
The delineation of the ground water contaminant plume and the pilot
treatment operations were conducted in the summer and winter of
1988. A total of 38 permanent and temporary wells were installed
on the plant site and along the edge of the bayou. As a result of
this work, free product creosote was discovered in three discreet
plumes rather than one continuous one as presented in the ROD.
Figure 2 reveals the approximate shape of these plumes. This
figure also shows that two of the plumes are on the plant property
while the other is adjacent to the bayou and appears to be
influenced by contamination within bayou sediments. A cross
section of where this aquifer is located is illustrated in Figure
1. The free product is located in about a 12 foot zone at a depth
of approximately 20 feet below the surface. The creosote tends to
be in separate seams throughout the aquifer rather than in one
layer at the bottom of the formation.
A ground water pilot study was conducted to evaluate the
capabilities to extract and treat these contaminants. Two
different types of extraction well configurations were evaluated.
A separate phase extraction system as shown in Figure 3 was used
to assess the ability to extract the creosote oil separately from
the water in the aquifer. This system consisted of oil extraction
wells in an equilateral triangle with wells at 2.5 foot spacings,
and a water extraction well within the center of the triangle. The
principle behind this array was to create a hydraulic gradient in
the water recovery well which would also induce the flow of pure
product creosote toward the oil recovery wells. The other system
consists of a conventional multi-phase pump system as shown in
Figure 4. This type of system removes both oil and water from the
formation at once rather than trying to extract them as different
phase liquids. It was found that the creosote could best be
removed through multi-phase pumps instead of separate pumps for oil
and water phases. This study also revealed that reinjection of the
treated water, as anticipated in the ROD, was not viable because
of the physical properties of the aquifer. The aquifer does not
readily allow the reinjection of water and as such it was believed
this would potentially be a costly ineffective action.
A second aspect of this pilot study was an evaluation of the most
effective form of treatment of the extracted groundwater prior to
discharge. The RD pilot study showed that the most effective
treatment train was oil-water separation; followed by sand,
oleophilic and carbon filtration; and then aeration before
discharge to the bayou. This system proved to be effective in
meeting the discharge criteria of the State of Louisiana and the
National Pollutant Discharge Elimination System.
Ill
-------
PROPERTY
BOUNDA
BAYOU BONFOUCA
ST. TAMMANY PARISH LOUISIANA
Contaminated shallow artesian aquifer
(depth 20') containing free product
creosote as defined through design
investigations.
Original limits of contaminated water
within the shallow artesian aquifer
as presented in the ROD.
BAYOU BONFOUCA SITE
BAYOU BONFOUCA. SLIDELL. LOUISIANA
Figure 2
-------
DEPTH BELOW GROUND SURFACE
(FT)
ui o t* o w c
1 1 1 1 1 1
30-
35-
_ DISCHARGE
CASINO -^^
BENTONITE/
CEMENT GROUT .
STATIC WATER LEVEL
SCREEN
•SAND
FILTERPACK ^^
CREOSOTE
RECOVERY
FAMP PUMP
i
.
/
• •" *
*." •"»
>*
%•
_•.'•;•;.
^
,e
^ Vi
JONTROLLER
•
10-
f
?
\
IsXXXV
/,
" •* *"•
•* • •*
' •* •*•
*•* •*•
• ' * •"
• •*,• •
AIR |-
±2 FEET
PUMPING (
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ORMAL
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1
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- WATER /CREOSOTE
RECOVERY
EJECTOR PUMP
A PUMP ON
A PUMP OFF
(DENSITY SENSOR)
Figure 3
GENERALIZED SCHEMATIC FOR
SEPARATE PHASE EXTRACTION
WELL SYSTEM (SYSTEM "A")
Bayou Borrfouca
SlkJell, Louisiana
113
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DEPTH BELOW GROUND SURFACE
(FT)
u 10 to -» -*
o m o tn o CM c
1 1 1 II 1 1
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f
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Flfliira &
GENERALIZED SCHEMATIC FOR
TOTAL FLUIDS EXTRACTION
WELL SYSTEM (SYSTEM "B")
Bayou Bonfouca
Slidell, Louisiana
114
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CONCLUSIONS
This pilot study proved quite useful in developing detailed plans
and specifications for full scale operations. During the course
of this pilot study, EPA and the State of Louisiana decided that
the site cleanup could be expedited by separating the ground water
out as an operable unit. This action was taken so that work could
be conducted on this phase while further evaluation was made on the
sediments as detailed below. The Ground Water Operable unit RA
contract was awarded in October 1989 to Chemical Waste Management
for $4.7 million and is currently under construction with planned
startup of the treatment plant in June 1991. Thirty-nine
extraction wells have been installed at the site and the plant is
designed for a maximum flow rate of 50 gallons per minute with an
operational flow rate of approximately 20 gallons per minute.
IV) SOURCE CONTROL OPERABLE UNIT
A) SEDIMENT INVESTIGATIONS/EXPLANATION OF SIGNIFICANT DIFFERENCES
During the sediment investigations it was discovered that the
horizontal and vertical extent of contamination were greater than
assumed from previous investigations. A total of 55 borings were
made in the bayou to evaluate the physical properties of the
sediments and to establish cutlines for dredging.
The bayou borings near the creosote plant revealed that the upper
cohesive (clay) layer, as shown in Figure 1, was not continuous
across the bayou as previous studies had indicated. The reasons for
this error lie in the incorrect interpretation of previous boring
logs and sub-bottom geophysical profiles. In addition, previous
sampling was limited in depth because of concerns with penetrating
the presumed upper clay layer, thereby possibly further spreading
contamination. Due to the non-continuity of this upper clay layer,
creosote was found at a maximum depth of about 17 feet below the
mudline, rather than at 5 feet as previously assumed. These
borings also showed that the horizontal extent of contamination was
approximately 4,000 feet, almost twice that presented in the ROD.
As a result of these investigations it was determined the volume
of contaminated sediments was approximately 170,000 cubic yards,
rather than the 46,500 cubic yards presented in the ROD. An
example of one of the cross-sections within the bayou is shown in
Figure 5. This figure provides PNA concentrations for grab and
composite samples, and the classification of the sediments
according to the unified soil classification system.
This volume increase caused the selected remedy to be re-evaluated
and the work associated with this phase of the project was
identified as the Source Control Operable Unit. Camp Dresser &
McKee (CDM) was contracted by EPA to re-evaluate the alternatives
presented in the ROD and consider the applicability of any new
115
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-r '0
- - -10
MUDUNC BASED
ON COt BA1HYMCTR1C
SURVEY
- • -13
- - -20
- - -23
CROSS SECTION FOR SECTION 3
Bayou Bontouca
SlideH. Louisiana
-------
innovations since the ROD was signed. The conclusions of these
studies showed that the selection of on-site incineration was still
the most appropriate method to remediate this site. Other methods
such as inplace solidification, partial sediment removal, or on-
site placement within a RCRA vault were found not to adequately
address the goals of EPA or the State of Louisiana to reduce the
toxicity or mobility of the contaminants. The study indicated that
bioremediation (in a slurry reactor) might be effective in reducing
the concentration of contamination, however, further review showed
that it would most likely not achieve the same percentage reduction
as incineration. In addition, it was found that the cost of
bioremediation would be slightly more than incineration. This was
due in part to the fact that the final material would have to be
dewatered prior to landfilling.
The CDM study did recommend two areas for consideration during
incineration which were further evaluated in the RD; using a
centrifuge during dewatering and utilizing waste heat from the
incinerator for additional drying of the sediments. Since EPA
decided a request for proposal (RFP) would be used for the RA
contract, both these options could be considered by the perspective
bidders. This study proved valuable by confirming that the
correct remedy was chosen in light of the significant change in
volume. As a result of this activity and other considerations, EPA
and the State of Louisiana issued the first Explanation of
Significant Differences within EPA, Region 6. The community was
in agreement with this proposal and this document serves as an
amendment to the ROD rather than requiring further delays
associated with submitting a new ROD.
It was decided early in RD process that the most appropriate means
to address these sediments was through use of predetermined
outlines. Given such a complicated project, specific cutlines are
anticipated to provide a much more controlled cleanup resulting in
a significantly reduced contractual risk to the State and EPA. The
cleanup standard was established as 1300 ppm PNAs based on waste
mobility and on a risk assessment assuming children wading in the
bayou and the cleanup goals previously established by EPA.
Consideration was also given to environmental concerns in that the
bayou currently has no biota in the sediments because of elevated
concentrations of PNAs. Therefore, plans were made to backfill the
bayou offering a clean environment for the restoration of biota and
a barrier against direct contact with any residual contamination
in the sediments.
An additional concern with bayou restoration is with shore
stabilization. The bayou, in the area of concern, abuts either
residential, commercial properties or wetlands. These
considerations serve to highlight the need to progress thoroughly
and with discretion. During the dredging operations sheetpiles or
similar slope support are necessary to protect the bayou bank and
associated wetlands.
117
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CONCLUSIONS
EPA was faced with a difficult situation when the volume of
contaminated materials more than tripled that presented in the ROD.
This dilemma was addressed by conducting a thorough evaluation of
possible alternatives and close coordination with the State and
community, allowing the project to continue without major delays.
The issuance of an Explanation of Significant Differences document
rather than reopening the ROD also saved significant time which
potentially could have required an additional two year delay. This
situation also emphasizes the need for adequate investigations
during the RI stage of any site.
B) AIR PILOT STUDY
Pilot studies were also conducted during the Remedial Design of
the Source Control Operable Unit to simulate actual air emissions
during construction. This action was necessary because previous
data indicated that the potential existed for large nuisance and
possibly toxic emissions. The pilot activities consisted of
dredging 12 cubic yards of sediments, separation of different size
materials on a vibrating screen and conducting 23 air test runs.
(Air monitoring took place at the point of operation and at
specified distances downwind). The air emissions tests were
conducted in test chambers as shown in Figure 6 and included
agitation and raked capabilities. Agitation was through a variable
speed mixer to simulate dilute and pumpable material, while the
raked chambers allowed disturbance of higher solid materials which
is reflective of stockpiled sediments. The results indicated
possible emissions of benzene, naphthalene, toluene, ethyl benzene,
and trimethyl benzene. Volatilization of these compounds was
modeled using the Industrial Source Complex Short Term Dispersion
model and showed no significant releases, however, it did indicate
the benefits of a properly detailed air emissions control strategy-
The results of these studies was presented in the RD package to
allow bidders to estimate air emissions. This data, and associated
transport modelling, was also used to select compounds for
establishing fenceline and dredge air action limits (contractor
control levels) for protecting off-site residents. The final
specification for these air emissions was as follows:
Monitoring at the Dredge
Monitoring Period Compound Action Limit (mg/m3)
5-min reading Benzene 9
Ethyl Benzene 1635
Naphthalene 225
Toluene 1680
Trimethyl Benzene 1125
118
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Monitoring on the Bavou Banks
Monitoring Period
15-min average
1-hour average
28-day and annual
averages
(annual averages
are cumulative)
Compound
Benzene
Ethyl Benzene
Naphthalene
Toluene
Trimethyl Benzene
Benzene
Ethyl Benzene
Naphthalene
Toluene
Trimethyl Benzene
Benzene
Ethyl Benzene
Naphthalene
Toluene
Trimethyl Benzene
Action Limit (mq/m3)
3
545
75
560
375
3
435
50
375
125
0.008
0.4
0.14
2.0
0.050
The Air Action Levels are based on an analysis and consideration
of EPA's Health risk numbers and OSHA standards. A case in point
is that the 1 hr. average at the Bayou Bank for Benzene is 3 mg/m3.
If this limit is reached the contractor would be required to
institute emission mitigation controls. This number also
corresponds to OSHA's numerical standard for the TLV. It is
important to note that the EPA criteria are far more protective of
human health than the OSHA standard even though similar
concentrations are employed. An important difference is that EPA's
action level kicks in after 1 hr. as opposed to being an acceptable
concentration for an 8 hour period, 5 days a week for forty years.
These levels were also established at the fenceline of the facility
where the incinerator will be located. However, the fenceline
limits also include action criteria for particulates which will
result from ash handling. The basis for these action levels is a
consideration of short and long term health data and that
specifications emphasize contractor controls.
CONCLUSIONS
The benefits of this air emissions pilot study were greatly
realized during the development of this design package and the cost
for it was more than adequately justified through reducing unknowns
to the bidders. The emissions criteria developed for this contract
also shows a logical approach to handling this important issue in
which many Superfund sites are just now beginning to realize the
potential effect.
119
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3-WAY TEFLON
SAMPLING VALVE
34" COPPER
TUBING v
SUPPLY
AGITATED
CHAMBER
AGITATED
CHAMBER
AGITATOR MOTOR,
LIGHTNIN 3 HP
0-200 SCFH
ROTAMETER
WITH FLOW
CONTROL VALVE
WOOD MIXER
SUPPORT
Xt" TEFLON
TUBING
AGITATED
CHAMBER
RAKED
CHAMBER
SKID- WOOD
CONSTRUCTION
DIAGONAL MEMBER
FOR MOTOR SUPPORT
AND TANK STABILIZATION
CARBON
TREATMENT
NTS
120
Rgure 6
SCHEMATIC OF AIR
TEST CHAMBERS
Bayou Bonfouca
Slidell, Louisiana
-------
C) DEWATERING PILOT STUDY/PAYMENT FOR INCINERATION
At the same time as the Air Pilot Study a dewatering study was also
conducted. Dewatering activities during these pilot studies
included polymer testing, vacuum assisted drying beds, gravity
settling, filter press, centrifuges, and belt filter presses.
Figure 7 presents a table of the results of these tests which was
provided to the bidders as part of the RD package. This data
indicates that when additional moisture is added to the sediments
it can be difficult to remove it prior to incineration. It also
shows that the moisture content of the incinerator feed would be
greatly affected by the dredging and dewatering process train
rather than the insitu moisture content of the sediments.
This data indicated that the most reasonable contractual approach
for handling the dredging, incineration and dewatering aspects of
this project was through paying for the ash on a dry weight basis
as it leaves the incinerator. This is completely different than
the typical incineration contract where measurement is based on the
wet material entering the incinerator. This approach places the
responsibility on the contractor to optimize his process train to
reduce the amount of water in the feed material to the incinerator.
Although several bidders disagreed with this approach, they were
unable to provide a more suitable method to handle this situation.
Associated with this issue was the realization that to pay for the
ash material on a dry weight basis the contract documents would
require a flexible performance strategy. Therefore, EPA and the
State of Louisiana decided to use a performance based specification
rather than a detailed design approach that specified specific
treatment trains (i.e., centrifuge followed by infrared
incineration, filter press followed by rotary kiln, etc.). The
contract was advertised for construction as a request for proposal
(performance based) rather than an invitation for bids (detailed
design).
CONCLUSIONS
In consideration of these studies and a detailed review of the
different possible process trains, it was decided that the most
effective way to advertise this RA was through a request for
proposals (RFP). It was recognized, that given such a complex
project, there could be a number of different approaches. EPA's
intent was to encourage competition, innovation and cost savings
for the Government. The RD for this construction was completed in
September 1990 and award of the RFP is expected in May 1991. The
issue of paying for incineration was addressed through weighing the
material as it exits the incinerator rather than weighing the feed
material. This assures the Government that the contractor
optimizes the process train to ensure that unnecessary moisture is
minimized.
121
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Comparison of Dewatering Results from Design Investigation,
Field Study, and Offsite Laboratory Activities
Polymer Jar Test
Batch Flux Curve Test
Gravity Settling Test
Buchner Funnel Test
(Vacuum Filtration)
Filter Leaf Test
Sludge Drainage Test
(Preliminary Thickening
Test)
Belt Filter Pressure Test
Bench-Scale Vacuum-
Assisted Dewatering Test
Pilot Scale Plate and Frame
Filter Press Test
Vacuum-Assisted Sludge
Dewatering Bed Testing
Basket Centrifugation Test
Solid Bow Centrifugation Test
Continuous Solid Bowl
Centrifuge Test
Pressure Filtration
Trommel Screen
Dewatering Simulation
Test
Ranges of Solids Contents Achieved by Various Dewatering
Methods for Each Investigation
Design
Investigation
172-22.0
(4.6-10)
14.7-22.6
(4.6-10.7)
16.7-19.3
(14.2-22.6)
46.4-53.2
43-47%
(17.5)
42J-50.7
•
NP
NP
NP
NP
NP
NP
NP
NP
Field Study
NP
NP
(4.7-15.2)
14.4-26.2
NP
(5-20)
332-417
(16.9)
31.0-492
NP
(18-22)
37.1-415
(8.2-22)
22.6-30.0
(8-22)
22-38
NP
NP
NP
NP
NP
Offsite Laboratory
NP
NP
(2&5)
37-39
NP
(10-30)
23-30
NP
NP
NP
NP
a.(43.l)
b.46.7-50.4
(25.0-36J
40.0-47.8
(35.0)
25.2-51.2
(36J)
45-46
(30.0)
32.6
Upper entry ( ) indicates the initial toUda coocentntioo*.
Lover entry indicate* the final dewitered sludge toUd* concentration*.
All cooceotratioaa presented at percent local totidt by weight.
N? - Ten not performed.
•Tea did DOC produce reportaWe retulta.
122
Figure 7
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D) Value Engineering
A Value Engineering (VE) study was prepared by the Corps' Kansas
City District during the preparation of plans and specifications.
As previously noted, the RA contract was an RFP rather than a
detailed design. This approach allows the bidders more flexibility
in implementing the selected remedy and at the same time allows a
more competitive bid by not specifying a certain type of
incinerator or dewatering train.
Although, the Corps' study generated some very good suggestions,
some of which were included in preparing the specifications, the
cost effectiveness of a VE study for an RFP remains questionable.
A VE study is more appropriate when you have detailed plans,
wherein you have specific process trains and are able to optimize
the approach. In an RFP it is expected that the bidders will
include VE considerations in putting together their proposal and
as such it may not be as effective for the Government to do this
during the design. Furthermore, it remains questionable in an RFP
if bidders should be allowed to present a VE proposal as currently
allowed in some contract clauses. The very nature of an RFP should
be that the contractor has selected the most cost effective
approach; therefore, allowing the contractor to gain additional
monies from use of a VE contract clause is unreasonable. If a
bidder knew in advance that only one or two proposals were
expected, then the proposal might not be optimized knowing that if
the contract was won then additional funds could be made through
a VE.
E) FUNDING
Because of the high cost of this project, in excess of $100
million, the EPA was concerned about RA funding for the Bayou
Bonfouca Source Control Operable Unit. This money is to be
provided by the State of Louisiana and EPA, which pay 10 percent
and 90 percent, respectively. Typically on Fund lead projects,
for which the Corps administers the contract, the Agency is
responsible for providing, up front, 100 percent of these funds
through an Interagency Agreement (IAG) prior to advertisement.
Funding for this work was proving to be a big issue since this was
a significant portion of the overall yearly RA budget for Superfund
projects. Because of this, Region 6 approached the Corps during
the initiation of the RD to reduce the funding impact by conducting
the work in two phases or to see if the Corps could use their
continuing contracting authority. Continuing contract authority
allows the Government to fund multi-year contracts on a yearly
basis; i.e., not providing all the monies up front.
123
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It was subsequently discovered that the Army Corps of Engineers has
not been granted continuing contract authority on Superfund
construction contracts although it has been for Civil works. After
attempts failed in trying to get the Corps to obtain such authority
for this project, EPA decided that the contract should be divided
into two phases based on site activities as discussed below. The
first phase was classified as the base portion, and the second was
the option phase.
The base consists of mobilization of the incinerator and water
treatment facilities, preparation of plans (i.e. Health and Safety,
Air Monitoring and Action Plan, etc.), preparation of the initial
landfill, the incinerator trial burn and incineration of
approximately 15 percent of the material. The reason for the
selection of these items was that EPA wanted to ensure adequate
funding was available for all work related to preparing the
landfill, and the incineration of the waste piles. This also
allowed a logical break point between work on the contamination at
the abandoned plant and those activities with bayou sediments.
The option phase includes mobilization of the dredge equipment,
stabilization of the bayou slopes (i.e. sheetpiles, etc.), dredging
and backfilling of the bayou, incineration of the contaminated
sediments, construction of the landfill cap, demobilization of the
incinerator and other related facilities and one year of post
closure operation and maintenance.
CONCLUSIONS
Phased funding for dividing large scale projects is recommended
whenever the contract is anticipated to take several years and
funds are not readily available. This approach allows EPA to
address several sites at one time rather than tying funds up on
only one large project. However, it is also highly recommended
that the Corps pursue the authority to advertise these large
Superfund projects under continuing contract authority.
F) BONDING
Bonding remains one of the most important issues related to
advertising large (> $20 million) Superfund RA projects in this
country. The size of the Bayou Bonfouca contract concerned EPA,
Region 6, in that without proper consideration to bonding it was
felt this item could severely restrict competition. Previous
experience within the Region, coupled with discussions with the
sureties industry, had indicated that bonding was hard to obtain
on projects larger than $20 million. The primary reason for this
dealt with liability concerns. Above this value, the number of
bidders able to obtain bonding is reduced and, therefore,
competition is severely limited. This issue was brought to the
attention of the Army Corps of Engineers especially in light of
124
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their conventional approaches in requiring performance bonds of
100 percent of the contract amount or advertising projects entirely
as a service contract. In a service contract the contractor is not
required to submit any performance bonds and the Government is at
significant risk if the contractor defaults. Alternately, in 100
percent bonding the Government is fully protected and as is the
case on large scale projects, the Government may be overly
protected.
EPA approached the Corps' Kansas City District and requested a
reduced bonding that would both protect the Government and allow
competition. Region 6 decided not to arbitrarily use the $20
million value which most sureties would provide, but to actually
estimate the cost to the Government to readvertise and mobilize a
new contractor if the existing contractor defaulted. This process
involved a thorough review of the bid items and an evaluation of
the potential impacts (contractual and environmental) if the
contractor defaulted at different points during the anticipated
schedule. Through this effort the final total performance bonding
requirements developed by the Corps were completed and they are as
detailed below.
(1) If the bidder provides a total performance bond for
both the base and option contracts, the total amount
shall not exceed 12 percent of the total cost.
(2) The bidder could choose to provide an initial bond
for the base contract only, and then increase it at
time of award of the option contract. If this
alternative was selected the requirements are for
20 percent bonding on the base and then additional
bonding of up to 12 percent of the total cost at
award of the option.
(3) It was also required if the contractor decided to
separate bonding by alternative 2 above that the same
surety or sureties were utilized. This requirement
aides in ensuring that the Government does not
accept the risk of improper sureties after the base
is awarded.
IV) SUMMARY
This paper has presented a wide spectrum of issues that were
addressed during the development of the Remedial Design for the
Bayou Bonfouca Superfund site. In particular, it covers the issues
of pilot studies, payment for incineration on an ash weight basis,
Value Engineering, funding and bonding on large scale projects.
It also provides brief discussions on other key design issues that
may be relevant for scoping future work on other similar Superfund
sites.
125
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Pilot studies have shown to be helpful in developing plans and
specifications, in addition to ensuring cleanup goals can be
achieved. This site has also shown that it's very important to
address these issues during the RI stage rather than during the RD.
If these studies were conducted prior to the ROD, the actual volume
of contamination would have been discovered greatly simplifying the
overall process.
This project has presented an innovative approach for paying
incineration quantities. Rather than utilizing the weight of the
feed material, EPA choose to pay on the dry weight basis of the
ash. This protects the Government against the payment for
incinerating unnecessary moisture and places the responsibility on
the contractor to optimize the process train. This approach should
be considered on future Superfund sites.
It was found that Value Engineering studies related to projects
that are scheduled for procurement as a Request For Proposals may
not be as effective as they are with Invitations For Bids. In fact
the nature of RFPs is such that a Value Engineering process should
be conducted by the perspective bidders during the preparation of
their proposal and not after award of the contract. If a
contractor does not optimize his approach through use of VE
principles he risks not winning the contract.
Up front bonding on large scale projects (>$20 million) is often
difficult to obtain, especially when the costs are expected to be
around $100 million. By dividing the work into 2 separate phases,
the EPA was able to prioritize Agency-wide remedial needs of
available dollars for numerous other sites. As a related point,
it is suggested that both EPA and the Army Corps of Engineers
pursue the authority for awarding continuing contracts.
Performance bonding has been found to be a critical item related
to the ability to obtain competitive bids and to protect the
Government against contractor default. Although service contracts
have been used, since there is no bonding required in this type of
contract, the EPA could be left with at least the cost for
procuring a new contract if the existing contractor fails to
perform adequately. The possibility exists that additional costs
exist due to uncompleted work such as environmental releases, etc.
At the same time it is unreasonable to automatically require 100
percent bonding without a consideration of the actual costs
associated with default and reprocurement. On the Bayou Bonfouca
site it was found that approximately 12 percent of the total
construction amount would be sufficient as a performance bond.
This type of approach is recommended for other large remedial
projects.
126
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V) REFERENCES
- CH2M HILL, July 16, 1991, Bayou Bonfouca Source Control Operable
Unit Design Investigation Report, Volumes 1-3
- CH2M HILL, July 16, 1991, Bayou Bonfouca Source Control Operable
Unit Pilot Study Report
- United States Army Corps of Engineers, November 1990, Bayou
Bonfouca Source Control Operable Unit - Contract Documents
- United States Environmental Protection Agency, Region 6, February
5, 1990, Bayou Bonfouca Explanation of Significant Differences
- United States Environmental Protection Agency, Region 6, March
31, 1987, Record of Decision
Author(s) and Address(es)
Robert M. Griswold, P.E.
U.S. Environmental Protection Agency
Region 6 (6H-SA)
1445 Ross Avenue Dallas, Texas 75202
(214) 655-2198
Stephen A. Gilrein, P.E.
U.S. Environmental Protection Agency
Region 6 (6H-SA)
1445 Ross Avenue Dallas, Texas 75202
(214) 655-6710
127
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Soil Remediation in the New Jersey Pinelands
Edward Patrick Hagarty, P.E.
C.C. Johnson & Malhotra, P.C.
601 Wheaton Plaza South
Silver Spring, Maryland 20902
(301) 942-5600
Dev R. Sachdev, P.E., Ph.D.
Ebasco Services, Inc.
160 Chubb Avenue
Lyndhurst, New Jersey 07071
(201) 460-6434
Lorraine Frigerio
U.S. Environmental Protection Agency
Region II
26 Federal Plaza
New York, New York 10278
(212) 264-7022
INTRODUCTION
The Lang Property Superfund Site located in the environmentally sensitive New Jersey Pinelands was
a former cranberry and blueberry farm where 1,200 to 1,500 drums of hazardous waste were
indiscriminently stored. The hazardous waste in the drums included a variety of volatile organic as
well as some inorganic contaminants. In December 1978 the State of New Jersey ordered that these
drums be removed. The drums were removed, but somehow their contents were emptied on-site,
resulting in the contamination of the sandy surface soil and underlying Cohansey Aquifer. The site
was listed on the National Priority List (NPL) in December 1982, and a remedial
investigation/feasibility study (RI/FS) was initiated in May 1985. A record of decision was issued
in September 1986 and by November 28, 1988, the remedial design (RD) was completed and the soil
was remediated. Completion of the RI/FS, RD and the remedial action (RA) was ahead of schedule
and within budget.
Several items contributed to the successful completion of this remediation in a relatively short time
frame. These included: 1) the use of the results of the RI/FS to separate the soil and groundwater
contamination into two separate operable units; 2) the use of the geophysical investigation and
subsequent test pits to identify potential excavation problems; 3) the cooperation among the U.S.
Environmental Protection Agency Region II, (EPA) the U.S. Army Corps of Engineers (COE), the
New Jersey Department of Environmental Protection, (NJDEP) and the consultants; and 4) the
dedication of the team to completing the remediation prior to enactment of certain Land Ban
provisions. This deadline was imposed since the Record of Decision (ROD) did not call for
pretreatment of the soils prior to disposal at an approved landfill. One of the highlights of the
remedial design was a three day meeting with the representatives from the COE, EPA and the
consultants who had conducted both the RI/FS and the RD for soil remediation. Questions that were
raised by the approving and implementing agencies were satisfactorily and quickly answered by the
RD consultant. Additionally, consultation was available from the RI/FS team regarding details of the
site conditions. Another time saving item was the elimination of the 60% design submittal from the
usual submittals of 30%, 60%, 90% and 100% complete. The
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purpose of this paper is to present a case study emphasizing that collection of the information during
the RI/FS phase needed to complete the RD not only accelerated the RD schedule but also resulted
in substantial savings. It will also compare the cost estimates from the FS, the RD, and that of the
selected contractor. This paper will also address the benefits of contractor continuity, a key element
of EPA's 10-year Alternative Remedial Contracting Strategy (ARCS).
BACKGROUND
The Lang Property is a 40-acre area in a rural portion of Pemberton Township, Burlington County,
New Jersey (see Figure 1). Cranberries and blueberries were once cultivated on most of the property,
however, at the time of the RD, only a few small blueberry fields were active. In 1975, 1,200 to
1,500 drums of unidentified chemical waste were discovered in a four acre clearing on the property.
The State of New Jersey filed a suit against the Langs and an order was issued by the Superior Court
of New Jersey directing the Langs to remove the waste from their property. The Langs subsequently
hired a local contractor to remove the waste. This contractor removed the drums from the site,
however, prior to their removal, the drums were apparently punctured and the chemical waste was
spilled onto the ground.
Several factors related to the site area combine to magnify the severity of the problem at Lang
Property. First, the site is located within the Pineland National Reserve, a large and unique forest
expanse located within the highly populated Northeast United States. This area has been recognized
as an important and environmentally sensitive natural resource. The site and adjacent areas, including
the down gradient wetlands, are part of the Pinelands Preservation Area District and are regulated
through the New Jersey Pinelands Protection Act which has been adopted by the Pinelands
Commission. Second, the site overlies the Cohansey Sand Formation, a largely undeveloped aquifer
under water table conditions which has tremendous potential for future water supply development.
Third, groundwater is typically present from one to three feet below ground surface and recharge to
the groundwater occurs rapidly by infiltration through the coarse sandy soil. Consequently, chemical
contamination spilled onto the ground surface at the site would have easy access to the groundwater.
Finally, the nature of the soil and groundwater in the site area tend to make the contamination
problem more severe. Sandy soils typical of the Pinelands, particularly the coarse sands found near
the ground surface, tend to be relatively inert with very little organic matter. Such soils have little
capacity for adsorption of organic contaminants from the groundwater. In addition, the groundwater
itself tends to have a low chemical buffering capacity. Consequently, contamination in the
groundwater in this area has very little potential for adsorption by soil particles or chemical
neutralization by natural constituents of the groundwater.
CC Johnson & Malhotra, P.C. (CCJM) has been actively involved in a variety of work assignments
at this Superfund site. As a member of the Zone 1 REM/FIT Contract under prime contractor NUS
Corporation, CCJM completed the Remedial Action Master Plan (RAMP) in 1983. In 1984 CCJM
began work on the Remedial Investigation/Feasibility Study (RI/FS) under a subcontract to Camp
Dresser & McKee Federal Programs Corporation as a team member of the REM II Contract. Under
this contract CCJM was responsible for all aspects of the RI/FS even though parts of the project were
conducted by other team firms. CCJM provided the Site Manager, the primary contact between the
REM II Team and EPA, and coordinated all subcontractors including those on the team and those in
the subpool (drillers, laboratory, test pit excavators, and treatability study laboratories). A ROD was
signed in 1986 for both groundwater and soils. CCJM was also responsible for conducting the
Remedial Design (RD) and participating in the Remedial Construction Management (CM) for the soils
portion of the selected remedy. The RD and CM were conducted as part of the REM III Contract
under which Ebasco Services Inc. was the prime contractor. Again, CCJM was given the primary
responsibility for conducting the site management aspects of the work assignment including
interaction with EPA and COE. Through three different contracts, CCJM was able to maintain
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FORT DIX MILITARY RESERVATION
LANG
PROPERTY
SITE
\Y y FOREST
VICINITY MAP
LANG
PROPERTY
SITE
SCALE
NONE
LOCATION OF LANG PROPERTY SITE
DATE
APRIL 1991
C.C. JOHNSON & MALHOTRA, P.C.
130
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contractor continuity and provide EPA with a series of documents that successfully allowed them to
remediate contaminated soils at the site and to determine the proper course of action for the
groundwater remediation.
Remedial Action Master Plan
The first document prepared after the site was listed on the NPL was the Remedial Action Master
Plan (RAMP), which included a data and records search from the file materials at EPA and NJDEP.
Based on this information, an assessment of the site was made. The results of the site assessment
included a recommendation that a full RI/FS be conducted. Within the RAMP, a preliminary scope
of work, schedule and cost estimate to complete the RI/FS were also made.
Remedial Investigation
The scope of the RI/FS was determined after detailed discussions with EPA. The purpose of the RI
was identified as determining the nature and extent of contamination. An approach which used
screening techniques (such as geophysics and head space analysis of soil samples) was followed. The
screening techniques were followed by more detailed soil sampling at the surface and at various
depths as part of the boring, well drilling and groundwater sampling activities. After a scoping
meeting with EPA and NJDEP, a Work Plan was prepared which detailed the scope of the RI and FS
as well as estimated the total cost and the schedule to complete the RI/FS.
As a result of the work done during the RAMP, it was determined that the source of contamination
at the site was the shallow soils and groundwater. Since all of the drums were removed from the area,
no other source existed. Based on file data, the nature of the contamination included, at a minimum,
volatile organics as well as heavy metals. The first phase of the RI, therefore, focused on soils and
shallow groundwater in the cleared area at the end of the access road. A site map showing various
features is shown in Figure 2. The RI included the following investigations:
o Site Survey
o Geophysical Survey
o Test Pit Excavation
o Soil Screening
o Soil Sampling
o Surface Water and Sediment Sampling
o Wellpoint Installation and Sampling
o Monitoring Well Installation and Sampling
o Vegetative Investigation
o Air Monitoring
Several conclusions were made using the RI data regarding chemical contamination at the Lang
Property. Surficial soils in a two-acre portion of the four acre clearing where disposal took place
were contaminated with volatile organic compounds and metals. Low levels of PCBs were also present
in the surficial soil in at least two locations. Vertical contamination of soils in portions of the site
known to contain chemical pollutants was limited to a maximum depth of 20 feet. Surface water and
sediment samples collected from areas of ponded water within the on-site disposal area were also
contaminated with volatile organics as were samples collected from a location along the ditch draining
the site. This location is in position to receive surface water draining from the on-site disposal
area (see Figure 2). It is believed that this ditch may have intercepted contaminated shallow
groundwater as it traveled from the on-site disposal area. Shallow groundwater beneath the on-site
disposal area is contaminated by volatile organic compounds and metals. Although this contaminated
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MAN MADE
DITCHES (TYP.)
LIMITS OF
CONTAMINATED
SOILS
PROPERTY//
APPROX. LOCATION
TREE LINE
•V--C-">-^-ACCESS --
x^x"/xM; ROAD iC?-
SCALE
I" =270'
DATE
APRIL 1991
LANG PROPERTY SITE
FIGURE
2
C.C.JOHNSON & MALHOTRA.P.C.
-------
groundwater plume could have limited concentric migration, its migration is principally in a
northwesterly direction.
This first phase RI answered most of the questions necessary to prepare a Feasibility Study, although
there were still some unanswered questions. For example, locations for the northwestern most point
of groundwater contamination and the northern most point of soils contamination could not be
established. Since most of the questions were answered, it was decided that instead of going through
an entire second phase of an RI, the FS should be completed and the remaining sampling would be
completed as part of the RD. This decision by EPA allowed the ROD to be signed in a much more
timely fashion.
Based on the results of the RI, the contaminated groundwater had not migrated far from the area of
disposal. This was attributed to the very slow ground water flow rate resulting from the minor
northwest gradient. The ditch which drains the site may have acted to intercept some of the shallow
groundwater from which volatilization of contaminants may have occurred. Groundwater below a
depth of 30 feet showed no evidence of contamination. This is because soil permeability in the site
area decreases with depth below ground surface. In addition, the groundwater exhibits slight upward
and downward vertical gradients that vary with the season. In the long term, this resulted in no net
downward movement of contaminated groundwater through the subsurface zone detected during the
RI.
An RI Report was prepared describing the results of the field investigations. The report presented
the data collected and evaluated the results with respect to applicable or relevant and appropriate
requirements (ARAR's). ARARs included state and federal criteria along with those from the
Pinelands Commission.
A risk Assessment was conducted which identified chemicals of concern, exposure pathways and
populations at risk.
Feasibility Study
A Feasibility Study (FS) was conducted for the site which screened technology types, developed
alternatives and provided a detailed evaluation of remedial alternatives in order to assist EPA in
selection of the Remedial Action which was included in the ROD. Alternatives considered included
excavation and either off-site disposal or incineration of contaminated soils. Groundwater alternatives
included pumping and either disposal in a local wastewater treatment facility (after pretreatment),
on-site treatment with disposal by injecting the treated groundwater into the aquifer from which it
came, or off-site treatment and disposal. All alternatives were evaluated in terms of costs, reliability,
implementation, safety, public health and welfare, environmental impacts, regulatory requirements,
and community acceptance. CCJM also provided support to EPA during preparation of the ROD.
Record of Decision
As described in the ROD, the selected remedy includes the following:
o Enclosure of the disposal area by a perimeter fence.
o Excavation of contaminated on-site soils to a depth of two feet (totaling
approximately 6,500 cubic yards), removal of these soils to an approved off-site
landfill disposal facility, and backfilling the excavated area with clean fill. (Note that
the actual quantity of soils was closer to 8,000 cubic yards.)
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o Extraction of approximately 30 million gallons of groundwater, with treatment and
on-site injection.
o Removal of on-site debris (tires, abandoned vehicles) and vegetation tofsfacilitate
filling and grading the site in the future.
o Post-construction operation and maintenance to verify the effectiveness of this
remedy.
The disposal of contaminated soils by landfilling was chosen instead of incineration due to the
excessive costs associated with incineration. Surficial soil samples (0-2 feet deep) were analyzed for
hazardous substances, and total volatile organic (TVO) concentrations were plotted on the site map
for each sample location. Limits of excavation were established by defining the area of soil
contamination greater than 1 mg/kg TVO concentration as required by NJDEP clean up criteria.
DISCUSSION
Remedial Design Description
As a subcontractor to Ebasco Services, Inc. under the REM III contract, CCJM was given full
responsibility for conducting the Remedial Design for the soils remedy at the Lang Property Site.
Under this REM III work assignment, CCJM prepared construction drawings and specifications,
following COE guidelines. The drawings and specifications were completed under a tight schedule
and included construction of road improvements, a contractor support area, a contamination reduction
area, and removal and hauling of approximately 8,000 cubic yards of contaminated soil to an
approved off-site disposal area. Provisions were made to dewater any soils that contained too much
water for off-site disposal. CCJM interacted effectively with EPA, COE, NJDEP, and Ebasco to
complete this project in a timely and cost effective manner.
The ROD addressed both the groundwater and the soils contamination at the site; however, it was
decided by EPA that the two contaminated media would be handled through two separate operable
units. This was done since additional data collection for the groundwater was more extensive than
that required for the soils. Additionally, by separating the two media, remediation of the soils could
proceed much quicker, thereby reducing the source of contamination. Also, there was no technical
basis to wait for the groundwater cleanup to be accomplished prior to cleaning up the soils. Since the
ROD did not include provisions for pretreatment of the contaminated soil prior to off-site disposal
at an approved hazardous waste landfill, the soil clean up had to be implemented prior to the 1988
Land Ban restrictions which would have required such treatment.
Use of RI/FS Data in Remedial Design
The RI/FS had determined that the type of contamination in the top two feet of soil at the site
included compounds which had not leached out by rain into the subsurface soils. These compounds
were generally not very soluble in water and had high carbon partition coefficients (indicative of
immobile compounds). This was the main finding of the RI/FS that aided in the selection of the
remedy which required excavation of the top two feet and flushing of all contaminated soils deeper
than two feet as part of the groundwater remedial action. This information was very important and
was used during the RD to determine the depth of excavation of most of the contaminated areas of
the site.
In other areas of the site, the question of excavating buried drums created some concern during the
design. The geophysical survey results indicated that there were drum-like signatures in certain areas
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of the site. This information necessitated greater caution during the design of the excavation and
during the excavation itself. Since this information was available, test pits were excavated (using
Level B Personnel Protective Equipment) to determine the presence of buried drums prior to
completion of the design. The test pits revealed that hundreds of buried tire rims, car seats and other
metal objects were present, but no drums. The results of the geophysical survey were used to identify
the location of the buried metal objects and were used in the drawings and specifications for the
excavation in these areas.
Cost estimates in FS were used to determine the relative costs among the alternatives. Cost estimates
completed during the RD were more refined and were used to determine as close as possible the actual
costs from the contractors who would bid on the contract. Cost estimates, for the selected remedy
estimated as part of the FS and the RD are compared to the bid from the selected contractor below:
FS RD Selected
Estimate Estimate Contractor Bid
$1,739,240 $4,125,450 $3,606,550
Problems Encountered
During design, there were several problems that were anticipated for this project including, control
of high concentrations of volatile emissions during construction; soil excavation in areas of shallow
ground water; adequate dewatering of the contaminated soil for transportation and disposal; and
disposal of decontamination water.
The concern for exposure to high concentrations of volatile organics resulted from the experiences
on site during soil sampling and drilling activities. During any intrusive activities, chemical odors
were prominent and photoionization detector readings were elevated. Several options were considered
for designing a system to alleviate this concern. One option included using spray foam to cover
excavated areas until new fill material could be brought in to cover the area. Another option
considered was to direct the contractor, through the specifications, to excavate and backfill
simultaneously or in such a manner that open areas were not left exposed for extended periods of
time. Requiring the use of personnel protective equipment to protect the workers and monitoring
down wind was also considered. The final specifications alerted the contractor to the potential
emissions problem but did not specify a method (other than monitoring) for dealing with it. The
contractor was to monitor and, if required, take appropriate measures to minimize these effects.
During construction, monitoring was conducted which indicated that the problem was not as serious
as anticipated. The contractor was able to complete the majority of the excavation first and backfill
later which helped keep the project on schedule. Personnel protective equipment was used on an as-
needed basis.
Excavation in an area where the groundwater is only two to three feet below the ground surface
presented two concerns. One concern was for the type of equipment necessary to perform the
excavation without getting stuck. The other concern was that the soil had to pass the Paint filter test
prior to hauling and acceptance at the approved landfill. Again, no specific requirements were made
in the specifications for the type of equipment to be used and the contractor was able to supply drag
lines as well as conventional earth moving equipment (pans, front end loaders, backhoes, etc.). Based
on the description of the site provided, the contractor was able to complete the work satisfactorily.
The drawings and specifications required a dewatering pad for soil that did not pass the Paint filter
test due to high moisture content. Due to the time of year that the excavation occurred and the
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method employed by the contractor during the excavation, the dewatering pad was not needed very
frequently.
Disposal of contaminated water from dewatered soils or from decontamination of equipment was
another concern. On-site disposal of the drainage from dewatered soils would have been the easiest
but was not allowed by the regulatory agencies. Therefore, provisions for collecting this water along
with the decontamination water, storing it on site and then hauling it off site for final treatment and
disposal were made in the specifications. There were no major problems encountered during the
construction. The contractor, however, built a different type of dewatering pad at no additional cost
to the project which performed adequately, especially considering that very little dewatering was
necessary. All contaminated water was collected and hauled off site as required in the specifications.
Another change to the design made by the contractor, at no additional cost to the client, included
constructing a weigh station on site instead of using a "nearby" existing station to determine the
quantity of soil hauled off site. This made the work much more efficient and more manageable.
One of the largest components of the RD work assignment was the design of the access road. Due
to the remote location of the site, the access road, although not directly part of the hazardous waste
handling, provided an essential link in the successful completion of the project. The existing road
was a four mile long rural road constructed of sand and pea gravel. The remedial design required that
the road be improved to allow heavy truck traffic to pass. Geotechnical samples were collected and
analyzed in order to determine the necessary improvements including the amount and size of gravel
required. One problem with the access road that occurred during construction was that the quantity
of gravel used significantly exceeded that estimated. However, the problem was not serious enough
to impact the schedule.
Schedule Boosters
The RD and subsequent construction followed an ambitious schedule. Several items contributed to
maintaining this schedule. Close coordination among the many parties involved was an important part
of the success of the project. The EPA Regional Project Manager was at the center of the
communications network. Communications were maintained almost daily among EPA, COE, NJDEP,
Ebasco Services Inc., and C.C. Johnson & Malhotra, P.C. This close contact kept all parties
knowledgeable about their specific roles and allowed problems to be solved as soon as they were
identified.
An additional help to the schedule was simultaneous distribution of the draft documents to all
individuals within the review agencies who were responsible for providing comments. This process
avoided double mailings and lost time. EPA made this project a high priority so that the soils remedy
called for in the ROD could be implemented prior to enactment of the Land Ban restrictions which
would have required that the soil be treated prior to off- site disposal. If the schedule were not
followed, the ROD would have to be revisited, and the RD would have to be redone. It was in the
government's best interest economically to complete the project on time. The COE in Kansas City
understood this and joined in with NJDEP to dedicate the necessary resources to the project in order
to provide expedited reviews. This dedication to the project was key in completing the project on
schedule.
Another boost to the schedule was provided by conducting all field work under the existing REM II
contract. Approved field operations plans and health and safety plans were in place which avoided
generation of new plans under the REM III contract. This saved time and money. Coordination
between the two contracts was made easy since the lead firm, CCJM was maintained throughout the
project. Contractor continuity is an important aspect of Superfund projects. Knowledge of the site
and easy access to background documents as well as knowing the local contacts provides a much more
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efficient method of operating these long term RI/FS/RD/RA projects. This is one reason that EPA
has established the ARCS contracts. These contracts are set up for 10 year periods and allow
contractor continuity without the administrative details of issuing new contracts for each phase of the
project.
An efficient method of incorporating agency comments on the RD occurred during a three-day
meeting held at the COE's offices in Kansas City. At this meeting representatives from the various
divisions within the COE, EPA, Ebasco, and CCJM were present to discuss the specifics of the RD.
When questions came up about why the design was done in a specific manner, the people who knew
the answers were present to respond. Regulatory decisions were made at the meeting and after the
meeting was completed, there was a clear understanding about the direction that the project was
moving. Everyone present knew how their comments would be incorporated. This meeting provided
an effective means to resolve conflicting comments. It also provided the reviewers with a better
understanding of the project and made subsequent reviews easier and quicker.
The last item which had a beneficial effect on the schedule was omitting the 60% design submittal
from the usual submittals of 30%, 60%, 90% and 100%. For this specific project this omission was
appropriate since the close coordination that was necessary in order to meet the schedule resulted in
the reviewing agencies being very familiar with the project drawings and specifications. By omitting
this review, many days were saved that would have been required to prepare, to review, and to revise
the 60% submittal. The final product did not suffer from lack of this submittal.
The result of completing this project in such a timely fashion was a savings of costs budgeted for the
soils RD. Actual costs of the work assignment were approximately 75% of those budgeted.
Maintaining the schedule was a primary factor in these savings.
CONCLUSIONS
Several items contributed to the successful completion of the design and implementation of the
selected remedy in a relatively short time frame. These included: 1) the use of the results of the
RI/FS to separate the soil and groundwater contamination into two separate operable units; 2) the
use of the geophysical investigation and subsequent test pits to identify potential excavation problems;
3) the cooperation among EPA, COE, NJDEP and the consultants; and 4) the dedication of the team
to completing the remediation prior to enactment of certain Land Ban provisions since the ROD did
not provide for treatment of the soils prior to disposal in an approved landfill. One of the highlights
of the remedial design was a three day meeting with representatives from COE, EPA, Ebasco and
CCJM. CCJM conducted the RI/FS for the entire site and the RD for soil remediation. Questions
that were raised by the approving and implementing agencies were answered by the design engineer
immediately. Additionally, consultation regarding the details of the site conditions were made with
the individual that was responsible for the RI/FS. Another time saving item was omitting the 60%
design submittal from the usual submittals of 30%, 60%, 90% and 100% complete. The success of this
project is a tribute to the team work and dedication of the individuals and the agencies involved.
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When Is a Superfund Remedial Action "Complete"? A Case
Study of the Crystal City Airport RA Implementation and
Transition to O&M
Bryon Heineman
U.S. Environmental Protection Agency, Region 6
1445 Ross Avenue
Mailcode 6H-SC
Dallas, Texas 75202
(214)-655-6715
INTRODUCTION
The Crystal City Airport, Crystal City, Texas, located 120 miles south of San Antonio was listed on
the National Priorities List (NPL) in 1986. The Record of Decision (ROD) for the first and only
operable unit was signed in September of 1987 and selected onsite consolidation under a RCRA cap
as the Agency's remedy. Primary contaminants included toxaphene, arsenic and DDT. Construction
activities began on February 5, 1990 and were completed on September 25, 1990. This project has
been a state-lead site funded by federal Superfund monies through the Texas Water Commission
(TWC). Community and Congressional interest has been high throughout the Superfund process at
this site.
Although the project was not technically complex, an unsupportive local community made the
implementation of the Remedial Action (RA) at this site particularly challenging. A brief overview
of the site's remedial history developed from the draft Closeout Report will be presented as
background information. A description of how the state of Texas and the region are implementing
the post-construction transition period into the Operations and Maintenance (O&M) phase will be
discussed relative to Superfund Comprehensive Accomplishments Plan (SCAP) milestones.
There are varying degrees of RA "completion" that will differ on a site specific basis. The current
agency trend is toward defining these degrees in an increasingly rigorous manner with revised SCAP
items such as "RA Award" and "O&F" (Operational and Functional) now being tracked. As more sites
move toward the RA phase, uniform Agency-wide interpretation of these definitions will be
necessary. The RA and post-RA SCAP definitions will be discussed and compared with the actual
dates realized at Crystal City.
BACKGROUND
The Crystal City Airport Superfund site is located within the city limits of Crystal City, Zavala
County, Texas, in the South-Central portion of Texas commonly referred to as the Winter Garden
District as depicted in Figure 1. The area is a region of low population where the economy is
dominated by agriculture and oil and gas production. Crystal City is the county seat of Zavala County
with approximately 8,000 residents from a total county population of 11,500. The nearest large
population center is San Antonio, located roughly 100 miles northeast1.
The Crystal City Airport is owned by the City of Crystal City. The site covers an area of
approximately 120 acres. Airport related facilities include a 3550-foot asphalt runway, a rotating
beacon on an elevated tower, a windsock, paved taxiways, and several buildings and foundations. The
land surrounding the airport property has a variety of uses. A closed municipal landfill, also owned
by the City of Crystal City, is located directly adjacent to the airport to the northeast. To the north,
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CO
CD
LOCATION OF CRYSTAL CITY
AIRPORT SUPERFUND SITE
KILOMETERS
EBASCO
EBASCO SERVICES INCORPORATED
MAP OF WINTER GARDEN DISTRICT
AND LOCATION OF CRYSTAL CITY
AIRPORT SUPERFUND SITE
FIGURE NO.
1
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the land is used as pasture land. Directly west of the site is a private residential area and a public
housing project. Southwest of the site is an elementary school, a high school, and associated athletic
fields. South of the site is a second residential area. Southeast of the site is more agricultural grazing
land1.
During World War II, the airport site was owned and operated by the U.S. military. It was used
primarily for housing persons detained during the war. In 1949, the U.S. Government deeded the
property to the city. The City of Crystal City has operated the facility as a municipal airport since
that time. Under lease arrangements with the City, several private companies operated aerial pesticide
applicating businesses at the Crystal City Airport beginning in the early 1950's. By 1982, all aerial
applicators were bankrupt and pesticide application operations were discontinued at the airport.
Upon declaring bankruptcy, the former operators abandoned various equipment and numerous
deteriorated drums on site1.
Remedial Planning Activities. A complete timetable of the Crystal City Superfund site can be found
as Attachment A to this report. The Texas Department of Water Resources (TDWR), the predecessor
agency to the TWC, initiated a preliminary site investigation on April 25, 1983 at the request of local
officials acting on behalf of concerned citizens. On June 13 and 23, 1983, additional reconnaissance
investigations were conducted to characterize the type and extent of the contamination. At least 50
drums of various agricultural pesticides and herbicides were observed, as well as extensive soil
staining apparently indicative of historically poor handling practices. Samples of the drinking water
and air did not contain any detectable contamination. An Immediate Removal Action was initiated
by the EPA on October 31, 1983, to remove the most highly contaminated materials. During this
action, approximately 40 cubic yards of waste and between 50-70 drums of material were placed in
two temporary disposal cells onsite, mixed with lime and capped with clay2. The temporary cell
locations were documented for the future permanent remedial action. The removal actions taken were
consistent with the permanent remedy.
After followup investigations on December 15, 1983, February 14, 1984, and March 29, 1984 by the
TWDR, EPA, and the Texas Air Control Board (TACB), an additional removal action was determined
to be warranted to further reduce short-term risks posed by the site. In May, 1984, an additional 19
drums were transported offsite to a permitted treatment, storage and disposal facility for disposal.
A fence with a locked gate was constructed around the site to limit public access, and warning signs
were posted2.
A Hazard Ranking System (HRS) package for the Crystal City Airport was finalized in June of 1984.
The overall site score was 32.26. The HRS package identified direct contact and air inhalation as the
exposure routes of primary concern, with HRS route scores of 50.0 and 43.0 respectively. The
toxicity and concentrations of the compounds at the site in addition to the close proximity of target
receptors were noted in the HRS3. The Crystal City Airport was proposed for inclusion during the
second update of the NPL on October 5, 1984. NPL listing was finalized on May 20, 19864.
The TWC and the EPA entered into a Cooperative Agreement on September 28, 1985 for a state-lead
Remedial Investigation and Feasibility Study (RI/FS). In June of 1986, the TWC contracted Ebasco
Services Incorporated to perform the RI/FS. Phase I of the RI fieldwork lasted from September
through October, 1986, and Phase II fieldwork was conducted during January and February of 1987.
Ebasco submitted a draft RI report for EPA and TWC review in April of 1987. A draft FS followed
in May, 1987. The RI and FS reports were finalized in June and July of 1987 respectively.
Extent of Contamination. The RI results indicated the contamination on-site consisted of numerous
organochlorine pesticides and herbicides, arsenic, and minor amounts of other semi-volatiles. DDT,
toxaphene, endrin, and dieldrin were chosen as indicator chemicals for each class of organochlorine
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compounds, arsenic for inorganics, and benzo(a)pyrene for the semi-volatiles and acid/base neutrals.
Because concentrations of DDT, toxaphene, and arsenic predominated throughout the airport, these
compounds were chosen as action level indicators1.
The two fieldwork phases of the Remedial Investigation included 314 surface and subsurface soil
samples. Off site samples of surface water and sediments were obtained from seven stream stations.
Forty five separate soil borings were drilled including a dry 180 foot hydrogeologic test hole. Air
sampling at both upwind and downwind locations was conducted during each phase. The three
municipal water supply wells were tested on multiple occasions, and onsite structures were wipe
sampled1.
The contamination was found to be limited to the upper surficial soils onsite. Significant
concentrations of contaminants were not found in the subsurface below a one foot depth except in
area S-7 where contamination above health based levels extended to an 18 inch depth1.
Groundwater was not found in any of the soil borings drilled at the site. The stratigraphy underlying
the surficial soil consists of two lithologic units of the El Pico Clay with permeabilities of 4 x 10~8
cm/sec and 1.5 x 10~8 to 3 x 10~9 cm/sec respectively.
The depth to the confined Carrizo Aquifer, the local source of municipal water, is approximately 700
feet in the vicinity of Crystal City. All samples collected from the three municipal wells completed
in the Carrizo Aquifer at depths of 800 to 1000 feet did not indicate the presence of contaminants.
The low permeability of the soils, the relative immobility of the contaminants, the lack of
groundwater recharge areas, and the depth to groundwater effectively isolated the site contamination
from the municipal water supply4'5.
Offsite stream water, sediment, and surface samples were at or below background levels. However,
offsite migration after a heavy rainfall event through surface water pathways was determined to be
possible. Air sampling results did not indicate the presence of airborne contamination. Building
structure wipe tests did not indicate significant contamination1.
Extensive surficial soil contamination was identified in the vicinity of hangar buildings that had been
occupied by aerial spraying operators. Maximum contaminations of indicator compounds measured
in these areas were: 1,100 ppm toxaphene, 2,300 ppm DDT, and 1,450 ppm arsenic. The approximate
volume of contaminated soils above 100 ppm combined contaminants was estimated to be 12,000 cubic
yards4.
Pre-ROD Community Relations Activities. Public notice of the August 20, 1987 ROD public meeting
and comment period was announced via a news release on July 24, 1987, and published by the local
county newspaper. A fact sheet describing the history of the site, the RI/FS results and the
alternatives under consideration was issued to the public on August 10, 1987. The public meeting on
August 20 was attended by approximately 45 citizens. At the request of concerned citizens the public
comment period was extended to September 14, 19874.
Record of Decision. The ROD was signed on September 28, 1987 by the Regional Administrator.
The state of Texas concurred with the selected remedy. The selected remedy consisted of onsite
consolidation of all soils exceeding 100 ppm total pesticides under a RCRA cap. Public access to the
consolidation cell would be restricted with protective fencing. Deep-well injection of
decontamination liquids, a thirty year monitoring period and a five year review were also specified.
The selected remedy was found to be fully protective of human health and the environment4.
Toxaphene, Arsenic, and DDT were the contaminants of primary concern due to their widespread
distribution, toxicity, and high concentrations relative to other compounds detected. The risk
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assessment utilizing these three compounds resulted in a health based action level of 100 ppm total
pesticides. Target receptors were identified as airport workers, travellers, and nearby residents.
Exposure pathways were determined to be direct contact with contaminated soils through dermal
contact, ingestion or airborne dust inhalation. Future land use was projected to continue as a
municipal airport. This action level approaches a 1.0 x 10"6 risk level for onsite exposure through the
identified pathways and was approved by the Agency for Toxic Substances and Disease Registry5'6.
Remedial Design Activities. The funds to conduct the Remedial Design (RD) were awarded to the
state of Texas on March 31, 1988 through a Cooperative Agreement with the TWC. On June 14,1988,
the TWC entered into a contract with Ebasco Services, the engineering firm that had conducted the
RI/FS, to perform the RD work. In addition to preparing detailed technical plans and specifications
for bid, Ebasco's scope of work included the following RD phase engineering tasks7:
Perform rigorous bid quantity calculations,
Generate an engineering cost estimate,
Conduct geotechnical analyses of remedy components,
Perform pavement design calculations,
Determine onsite building decontamination methods,
Develop action level verification protocol,
Design materials handling and excavation procedures,
Compile detailed health and safety and QA/QC requirements,
Develop runoff control measures,
Design air monitoring protocol,
Generate construction sequence and schedule estimate.
Supplemental field data collected during the RD phase consisted of7:
Additional site surveying for horizontal and vertical control,
Defining subsurface conditions in the area of the consolidation cell,
Geotechnical tests of soils representing cell contents and cap material.
The design phase was placed on an expedited timeframe due to high public interest and was
completed in January of 1989. The TWC entered into a Construction Management contract with
Ebasco for oversight services during the RA on March 7, 1989.
Remedial Construction Activities. The TWC published an Invitation for Bids (IFB) on January 31,
19898. Eleven qualified bids were received with bid totals ranging from S1.091M to $2.241M, and
averaging S1.696M. The contract was awarded to the lowest qualified bidder, Qualtec, Inc, and was
executed by the TWC on April 21, 1989. Qualtec's submittals were finalized by June of 1989 and the
contractor attempted to mobilize onsite but was denied entry by local officials. After repeated
requests for access on behalf of Qualtec by both the EPA and TWC, a 104 Unilateral Administrative
Order (UAO) was issued to Crystal City by the EPA for unconditional site access. The city complied
in November 1989 and the TWC issued a Notice to Proceed to Qualtec on January 5, 1990. Qualtec
began onsite mobilization on February 5, 1990.
During the 120 day construction activity period, the following remedial activities were conducted9:
construction of the consolidation cell,
excavation and consolidation of contaminated material in the cell,
verification monitoring,
placement, compaction, and grading of clean backfill,
stormwater control,
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building decontamination, and asphalt floor removal,
demolition of building B-3,
reconstruction of airport facilities to approximate existing conditions,
construction of the RCRA cap over the consolidation cell per the specifications and consisting
of:
1 foot depth of clean clay temporary cover,
2 foot depth of compacted, highly impermeable clay,
30 mil thick HDPE impermeable liner, with pressure tested hot wedge welds,
1 foot depth of granular drainage material,
1 layer of geotextile,
2 foot depth of compacted soil with native vegetation topcover,
continuous air monitoring and dust control,
continuous health and safety and QA/QC operations.
construction of a security fence around the consolidation cell.
The analyses performed during the RA phase verifying the ROD specified action levels for soils and
demonstrating protectiveness in other media can be divided into five areas: air, water, soils,
structures, and other issues.
1. Air. Air monitoring was conducted during onsite activities with fixed PM10 stations at the
site boundaries employing 10 micron impaction filters. Background air monitoring was
conducted prior to the initiation of site work. The paniculate filters were analyzed for the
contaminants of concern on a regular basis according to EPA established procedures and the
results were compared to background levels. At no point in the project was the particulate
action level of 1.0 mg/m3 exceeded at the perimeter devices. Air quality was also verified
periodically and during key remedial activities with hand held real time instrumentation
including a handheld aerosol monitor (HAM) for particulate measurements, and a combustible
gas indicator (CGI) for combustion hazards. Airborne hydrocarbon monitoring was conducted
with both a photoionization detector (PID) and an organic vapor analyzer (OVA). Personnel
exposure monitoring was conducted with mobile personal impaction filter devices. All
personnel monitoring results were below the permissible exposure limits (PEL) as set by the
Occupational Safety and Health Administration (OSHA) for the primary contaminants9.
2. Water. A carbon adsorbtion water treatment unit was mobilized to the site by Qualtec as
described in their approved Contaminated Runoff Control Plan. During construction, all
surface water and decontamination liquids were carefully controlled onsite in a series of berms
per the design specifications. Contaminated water was allowed to evaporate from the
stormwater control berms. Evaporation residues were excavated and placed in the cell.
Because of adequate onsite water control, no water was transported off-site for deep-well
injection, and no water was discharged off-site to surface bodies. Sanitary sewage waste was
handled separately and disposed in accordance with all proper state and local regulations9.
3. Soils. A total of 104 soil verification samples and 8 soil composites were taken in accordance
with the design specifications. Each area of the site defined on the construction plans was
separately verified immediately after excavation under the close supervision of the TWC
and/or the TWC's representative. Areas S-9 and S-10 were sampled before excavation per
the specifications and were determined to be below the action level. Samples were taken in
the center of each excavated area on approximately a 150' X 150' grid. Samples were also
taken at the perimeter face of each excavation at approximately 200' intervals. Sample
locations were surveyed before backfilling. All sample results were below the ROD specified
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action levels at the verification depth as specified in the design. The verification depth was
12 inches throughout the site except in area S-7, which, due to slightly deeper contamination
identified during the remedial investigation, required an 18 inch verification depth9.
4. Structures. All structures in the contamination zones were steam cleaned in accordance with
the design specifications and EPA's guidance for building decontamination at Superfund sites.
Surface trash was removed before steam cleaning. Asphaltic floor slabs were removed and
replaced with concrete. Wipe samples taken in each decontaminated structure verified the
building decontamination action level had been met9.
5. Other Issues. Special verification monitoring was conducted immediately after the transfer
of the buried material in the temporary removal action pits into the consolidation cell. On
March 14,1990, immediately after the transfer, real time portable instrumentation and carbon
tubes samplers were utilized downwind to verify air quality. On April 19, 1990,
approximately 15 to 20 empty five gallon containers were found buried in a shallow pit
behind Frank's hangar. The soil in a 12.5 foot radius around the containers to a 2 foot depth
was excavated and placed in the consolidation cell. The verification soil samples of this pit
were additionally tested for the label contents of the drums. The verification results were
below the total pesticide action level specified in the ROD9.
QA/QC of Construction Activities. All project submittals from the Oversight Engineer, Ebasco, and
the Construction Contractor, Qualtec, were carefully reviewed by the TWC and EPA for
completeness, accuracy and compliance with all TWC and EPA quality assurance and quality control
protocol. Qualtec's submittals were also reviewed in this manner by Ebasco as part of Ebasco's
oversight responsibilities9.
Qualtec's QA/QC activities during construction conformed with their approved pre-construction
submittals including:
Laboratory Quality Management Plan,
Quality Control Management Plan.
All delivered construction materials used during the remediation were subject to strict quality
documentation. Photodocumentation was used during the RA phase as an additional quality
indicator9.
Ebasco's site activities throughout their association with the project conformed to their Quality
Assurance and Quality Control Plan for the Crystal City Airport Superf und Site. During the Remedial
Action phase, Ebasco provided construction oversight services on behalf of the TWC. Ebasco
maintained a continual presence at the site to monitor the compliance and QA/QC activities of the
construction contractor, Qualtec. Daily work progress and QA/QC meetings were held between
Ebasco and Qualtec representatives at the site. In addition, weekly meetings were held with Qualtec,
Ebasco, and TWC representatives. Minutes of these meetings can be found in the appendices to the
RA Report9.
Ebasco split approximately 10% of the critical verification samples as a quality assurance check.
Qualtec also split verification samples with a separate lab to provide an internal quality assurance
check on its prime lab subcontractor.
Pre-final inspections were held on May 31, 1990 and June 6, 1990 to close out site work. The
Certificate of Substantial Completion was issued July 3, 1990, signifying the completion of all work
except the vegetative topcover growth required by the contract specifications. The final work product
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acceptance occurred on September 25, 1990 after a joint EPA and State inspection indicated the
vegetative requirements had been met. After a number of revisions, the RA Report is projected to
be finalized and approved by the regional administrator by the third quarter of fiscal year 1991.
Post-ROD Community Relations Activities. Public fact sheets were published after significant RD
milestones and during each month of the RA phase. The RA phase fact sheets described the site work
completed to date and the upcoming construction activities planned for the following month. Separate
monthly progress reports were provided to local city officials also detailing RA activities. Various
briefings were held with the city manager throughout the RA phase. Additional briefings of the
Crystal City council were conducted periodically at its request by the TWC and EPA. City officials
were hosted on a site tour during a pre-final inspection. A public open house was held onsite in the
clean zone every Wednesday during construction by either TWC and/or EPA representatives to allow
public access to the responsible government officials. A toll free 1-800 line to the EPA offices was
also provided and advertised to the local public. A viewing platform was built in the clean zone for
interested residents to view site activities from a safe distance. The viewing platform was later
donated to the city. The EPA project manager attended a local Lions Club meeting and presented a
brief history of the remedial efforts conducted at the site.
Operational and Functional Period. The first year of the thirty year Operation and Maintenance
period was defined as the Operational and Functional (O&F) period by the state and the region. A
cooperative agreement for the first year of O&M was executed in June of 1990 to provide 90% federal
and 10% state funding to ensure the remedy proved to be O&F through four quarterly inspection
events. The scope of work for the O&F period included sampling of the city water for primary
contaminants, maintenance of the cell vegetative topcover, inspection of the cell fence and air
monitoring during the first and fourth quarters10. The TWC amended their oversight contract with
Ebasco Services in September, 1990 to include the O&F work. The TWC issued Ebasco a Notice to
Proceed in October, 1990. The O&F visits will be conducted on the following dates:
1) November 8, 1990
2) February 6, 1991
3) May 7, 1991
4) August 5, 1991
The TWC and the EPA have discussed the criteria that will prove the remedy is operational and
functional. Contaminants of concern should not be detected above health based limits in any city
water samples nor in any air monitoring samples taken during the O&F period. The cap should
remain intact, undisturbed, and operational. Vegetative topcover over the cell should be controlled
and healthy. Security fencing surrounding the cell should be performing as designed to restrict access
to the cell.
Operations and Maintenance. Following the demonstration of O&F, the TWC will continue to
monitor the site during the thirty year O&M phase to ensure the remedy continues to be protective
of human health and the environment.
Five year review. Since restricted areas where waste is controlled remain onsite, a five year review
will be conducted by the TWC and EPA. The five year review will be conducted to ensure the
remedy continues to be operational and functional and protective of human health and the
environment. The five year review of the selected remedy will be conducted after July 1995, five
years after the Substantial Completion of the Remedial Action for the single and final operable unit
at this site on July 3, 1990.
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DISCUSSION
A recent Agency initiative has been to more accurately define the status of projects that are moving
through and past the RA phase. This is in response to public frustration over the seeming lack of
progress in the Superfund program as gauged by the number of sites that have been removed from
the NPL since the program began. Depending on the site, the NPL delisting process may not begin
until a five year review has been conducted11. The relatively limited Agency experience in
completing RAs has led to somewhat of a vacuum in precedence. The combination of these items has
led to many post-RA sites staying on the NPL well after onsite activities are complete for various
regulatory reasons, hence contributing to the apparent lack of progress. Many more sites will be
proceeding into this post-RA stage in the next few years. Some guidance is currently available11.
The delisting stage could arguably be the most important phase in the Superfund process as the
Agency presents the public resolution to all site issues developed throughout the site's history. The
Agency's explanation of remedial progress could perhaps be better expressed to the public with more
effective milestone tracking of sites proceeding to delisting. Useful milestone definitions would both
contribute to the program's uniformity and aid in progress tracking. For this reason, the current 1991
SCAP milestone definitions12 will be compared to actual dates achieved and projected at the Crystal
City Airport site. Although the definitions presented below specifically apply to a fund-financed
state-lead site, and may be interpreted slightly differently on a regional basis, the issues raised may
be of general programmatic interest.
RA Award. This activity is defined as the award of the contract for remedial construction services12.
Currently, only the completion date is tracked. Often, the time period between the publication of the
request for bids and the award date may extend over a few months, particularly if a two-step
qualifications based procurement is utilized for a complex project. A more effective use of this SCAP
line item might be to define the RA Award start as the date of publication of the request for bids,
and RA Award complete as the date of an executed contract. At the Crystal City Airport site, a one-
step procurement of a non-complex remedial construction, bids were solicited on January 31, 1989,
and the contract was executed April 21, 1989.
RA On-Site Construction. This activity is also a single date event, currently defined as the initiation
of onsite mobilization by the RA construction contractor12. However, a significant project milestone,
the demobilization of the construction contractor from the site (i.e. the completion of onsite
construction activities) is currently not tracked by the SCAP. Both of these dates could easily be
tracked by this SCAP line item as RA On-Site Construction start and RA On-Site Construction
complete respectively.
At the Crystal City, contractor mobilization occurred on February 5, 1990, and contractor
demobilization occurred on July 9, 1990.
Operational and Functional. This is a new SCAP milestone for FY 1991. The definition for this
period parallels the definition found in Section 300.435(f)(2) of the NCP which states:
A remedy becomes "operational and functional" either one year after construction is
complete, or when the remedy is determined concurrently by EPA and the state to be
functioning properly and is performing as designed, whichever is earlier. EPA may
grant extensions to the one-year period as appropriate.
One issue that has recently been raised in Region 6 is whether the term "remedy" in the above
definition applies to the completion of each operable unit at a site, or strictly to the completion of the
final operable unit. The definition of accomplishment for this period is the Regional approval of
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either the Operable Unit RA Report or the Closeout Report, whichever is appropriate12. The O&F
period is therefore a discrete part of the Remedial Action phase by definition and occurs post-
construction. As mentioned above, contractor demobilization from the Crystal City Airport site
occurred on July 9, 1990. A joint state and federal inspection of the site and acceptance of the
constructed remedy occurred on September 25, 1990. The O&F period for the Crystal City site has
been defined by both the state and the region to extend for up to one year after this date. By
September of 1991, the state and the EPA will have conducted four quarterly site inspections to
monitor the air and groundwater quality at the site to determine the remedy's operationality and
functionality. The Closeout Report is currently projected for completion in the 1st quarter of fiscal
year 1992, with regional approval by the 2nd quarter of 1992.
One suggestion for applying the current definitions of O&F on Superfund projects is to incorporate
the language and terminology of the Agency's O&F period into the contracting agency's agreement
with the contractor. For example, the TWC's Superfund construction contracts include standard
boilerplate requirements based on Construction Specifications Institute (CSI) language for a one-year
post-construction warranty period and the final inspection/work acceptance protocol. If the work
is partially funded through an EPA grant, the federal project manager would be well served by
ensuring that the non-federal lead contract contains job completion verbiage and milestone definitions
parallel to those of the federal Superfund program. Generally, while the EPA is not a formal party
to such agreements, they are reviewed and approved by the Agency. Foresight for post-construction
issues during the approval process could be invaluable at a future date.
RA Completion, First, Subsequent, and Final. This milestone event is currently defined as the
approval by the Regional Administrator of the Operable Unit Remedial Action Report for a non-final
operable unit at a given site, or the approval of the Closeout Report for a final operable unit at a
given site12.
A brief explanation of the region's differentiation in practice between a Remedial Action Report (RA
Report) and a Closeout Report is relevant. The RA Report is generated by the Construction
Oversight entity11, which is generally the engineering firm that performed the RI/FS, and RD for the
site. At the Crystal City Airport, the Oversight Engineer maintained a continual presence at the site
throughout all RA activities to ensure the work was performed by the Construction Contractor as
specified. The Construction Contractor was responsible for all required project documentation. The
Oversight Engineer provided a second party verification of the documentation and compiled it into
the RA Report. The RA Report summarizes the RA activities and demonstrates that the remedy was
implemented in accordance with the ROD. This document also contains written certification from
both the Oversight Engineer and the Construction Contractor that the work was completed according
to the specifications. In general, an RA Report is generated for each operable unit at a site11. An
RA Report may or may not include a determination that a remedy has been demonstrated as O&F
depending how the O&F period is defined. Since the O&F period was defined by the state and the
region to extend up to one year at Crystal City, the Crystal City Airport RA Report does not make
a representation of O&F9. The determination of O&F will be jointly made by the state and the region
upon completion of the O&F period and will be based on recommendations of the Oversight Engineer
made during the O&F period. The table of contents for the Crystal City Airport RA Report can be
found as an attachment.
A site Closeout Report is an inherently governmental task, and may be written by either the EPA or
the lead agency, but should be approved by both. Only one Closeout Report is generated per NPL
site—after the completion of the final operable unit RA11. The Closeout Report is the Agency's
public representation that all actions necessary to protect human health and the environment have
been completed. Since only one operable unit exists at the Crystal City Airport a Closeout Report will
be generated at the completion of the (only) Remedial Action, which in this case will occur
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concurrently on the completion date of the O&F period. The O&F period will be documented in the
Closeout Report for the Crystal City Airport.
The definition of Remedial Action completion specifies that the remedial action is operational and
functional (O&F) at this milestone11'12. As defined above, the O&F period may extend up to one year
after contractor demobilization. Additionally, the generation of the Closeout Report and joint state
and federal concurrence on the status of the site may delay regional approval of the Closeout Report
for a period of time after the O&F period. Thus, at Crystal City, the strict SCAP definition of RA
completion is projected to occur up to approximately 20 months after the contractor demobilized and
actual site work was completed.
Operations and Maintenance. The O&M phase is defined to begin upon completion of the Remedial
Action12. According to this definition, the O&M start date should coincide with the RA completion
date.
Long Term Remedial Action (LTRA). An LTRA is defined as a response action taken for the
purpose of restoring ground or surface water quality12. The current definition is somewhat
ambiguous, but it has been implemented as follows for a fund-financed, state-lead, groundwater
treatment remedy in Region 6: The "RA" portion of the project will be defined as the construction
of the surface facilities, well network, and other equipment necessary to conduct the pump and treat
remedy. The "RA" has been placed in quotations due to somewhat confusing terminology of LTRA
sites. The start and complete dates of this portion of the project have been defined to be the date of
RA funding and the date of demonstrated O&F respectively. The O&F period will initiate upon the
final acceptance of the constructed equipment and consist of a verification period that proves the
performance specifications of the equipment have been met. At that point an Interim LTRA Report
will be prepared much like an RA Report that documents the completion of the "RA" portion. The
actual period of groundwater treatment that may take up to 10 years will occur during the "LTRA"
portion of the project. A Final LTRA Report will be generated at the completion of the LTRA and
will include the Interim LTRA Report as an appendix. The completion of the LTRA operable unit
will be achieved with regional and state approval of the Final LTRA Report. O&M activities for this
operable unit will then commence upon the approval of the Final LTRA Report. The guidance
suggests that the combined Interim and Final LTRA Reports may constitute the Closeout Report for
the site11. Example formats for a Region 6 Interim LTRA Report and a Final LTRA Report can be
found as attachments.
Initiation of NPL Deletion. This is the only other delisting milestone that is currently tracked for
fund-lead sites. The start of this task is credited upon the publication of the Notice of Intent to
Delete in the Federal Register12. If wastes are left in restricted areas onsite as in the case of Crystal
City, current policy requires a five year review before initiating the delisting process11. If a site is
an LTRA site, delisting would currently be initiated after the long-term treatment has been
concluded11.
CONCLUSIONS
The fund-financed state-lead construction activities at the Crystal City Airport site in Crystal City,
Texas have been completed. Pesticide contaminated soils above health based action levels have been
excavated and consolidated onsite beneath a RCRA cap. The threat to human health and the
environment has been effectively mitigated. Beyond the restricted area of the consolidation cell,
unrestricted use of the airport facilities has been returned to the local city government. O&F
activities for the single operable unit at the site are underway and will continue until the late summer
of 1991. A determination of the site's O&F status and continued protectiveness will be made at that
time by both the state and the region. The RA Report has been submitted by the Oversight Engineer
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and is currently under review by both the state and the region. A Closeout Report will be drafted
by the EPA after the completion of the O&F period.
The answer to the question, "When will the Crystal City Remedial Action be complete?" depends on
the degree of detail required by the questioner. The answer that follows invites the questioner to
choose his/her preference:
On-site construction: complete 7/9/90
Substantial final completion: complete 7/9/90
Contractor demobilization: complete 7/9/90
Growth of vegetative topcover: complete 9/25/90
Final state/regional inspection: complete 9/25/90
State/regional approval of RA Report: projected complete 5/1/91
O&F activities: projected complete 11/1/91
State/regional apprvl of Closeout Rep: projected complete 3/30/92
SCAP definition of O&F period: projected complete 3/30/92
SCAP definition of RA phase: projected complete 3/30/92
Initiation of O&M phase: projected start 3/30/92
One aspect of the post-RA process that should not be underestimated is the importance of obtaining
the consensus and input of all parties involved with the site. If care is not taken to continue to
promote consensus during the post-ROD period, a site may face the undesirable prospect of indefinite
listing. The decision to delist is a "meeting of the minds" between the state and federal governments
that includes public input. The delisting process may be as involved or as complex as the selection
of the remedy, particularly if a high profile or complex site is at issue. The complexity of the
delisting is in part caused by the addition of all the post-ROD documentation involved in the RD and
RA phases. One way in which consensus can be promoted is through documented joint state and
federal determinations at each post-RA milestone. For example, the following questions should be
defined in advance of the O&F period:
What are the goals of the O&F period?
Exactly what site conditions will determine when and if O&F has been achieved?
Exactly what site conditions will prove O&F has not been achieved?
What possible failure scenarios could occur and what are appropriate contingency plans?
Similar questions should be defined in advance of the five-year review even though Agency policy
may evolve significantly:
What level of five year review complexity is necessary?
What is the scope of the five year review?
When will the five year review occur?
How will the five year review be funded?
Who will conduct the five year review?
The Office of Emergency and Remedial Response is currently considering many of these five year
review issues.
DISCLAIMER
This paper was prepared by the author for presentation at the May, 1991 Conference on Design and
Construction Issues at Hazardous Waste Sites sponsored by the USEPA's Office of Emergency and
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Remedial Response. This paper reflects the opinions of the author only. This paper does not contain
either regional or national policy and should not be construed as such.
REFERENCES
1. Remedial Investigation. Final Report. Crystal City Airport Site, prepared by Ebasco Services
Incorporated for the Texas Water Commission in cooperation with the Environmental
Protection Agency, June, 1987.
2. After Action Report. Crystal City Airport Site. Environmental Protection Agency, Region VI
Emergency Response Branch, June, 1984.
3. Hazard Ranking System Package for the Crystal City Airport Site. Environmental Protection
Agency, Region VI, April, 1984.
4. Record of Decision. Crystal City Airport Site. Environmental Protection Agency, Region VI,
September 28, 1987.
5. Feasibility Study. Final Report. Crystal City Airport Site, prepared by Ebasco Services
Incorporated for the Texas Water Commission in cooperation with the Environmental
Protection Agency, July, 1987.
6. Health Assessment for the Crystal City Airport Site. Agency for Toxic Substances and Disease
Registry, May, 1988.
7. Remedial Design. Final Report. Crystal City Airport Site, prepared by Ebasco Services
Incorporated for the Texas Water Commission in cooperation with the Environmental
Protection Agency, December, 1988.
8. Remedial Design. Bid Specifications. Crystal City Airport Site, prepared by Ebasco Services
Incorporated for the Texas Water Commission in cooperation with the Environmental
Protection Agency, December, 1988.
9. Remedial Action Report. Crystal Citv Airport Site, prepared by Ebasco Services Incorporated
for the Texas Water Commission in cooperation with the Environmental Protection Agency,
December, 1990.
10. Operations and Maintenance Plan. Crystal Citv Airport Site, prepared by Ebasco Services
Incorporated for the Texas Water Commission in cooperation with the Environmental
Protection Agency, December, 1988.
11. Procedures for Completion and Deletion of National Priorities List Sites. United States
Environmental Protection Agency, Office of Emergency and Remedial Response, OSWER
Directive 9320.2-3A, April 1989, as revised by OSWER Directive 9320.2-3B, December, 1989.
12. Superfund Program Management Manual. United States Environmental Protection Agency,
Office of Solid Waste and Emergency Response, OSWER Directive 9200.3-0ID, June 1990.
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Schedule Name
Responsible
As-of Date
Crystal City Airport
Bryon Heineman
27-Mar-91
Task Name
+ Pre-Listing Activities
+ NPL Listing
+ RI/FS
+ RX Process
Record of Decision Signed
•» Remedial Design
+ Remedial Action
Regional Appvl of Closeout
+ Operations and Maintenance
+ Site Deletion
™"™ Detai I Task =====
• ••• (Progress) =====
Progress shows Percent Achie
Rep
Summary Task
(Progress)
(Slack)
ved on Actual
weeks per cha
Start
Date
1-Mar-83
5-Oct-84
19-Aug-85
24-Jul-87
28-Sep-87
31-Mar-88
29- Dec -88
27-Mar-92
27-Mar-92
3-Jul-95
O » O O B
Duratn End
(Days) Date
292 24 -Apr -84
406 19-May-86
475 10-Jul-87
36 14-Sep-87
0 28-Sep-87
201 18-Jan-89
832 26-Mar-92
0 27-Mar-92
5,657 9-Oct-14
485 6-Jun-97
Baseline
Conflict
Resource delay
Milestone
83 84 85 86 87 88 89 90 91 92
Start Apr
Status 1 211 11 32 11
Done . . =================
Done ... . ===
Done . . . . A .
Future ... . .
Future ... . . .
Future ... . . .
•
;=«_
TIME LINE Gantt Chart Report. Strip 1
ATTACHMENT A
Crystal City Airport Project
Schedule
-------
Schedule Name
Responsible
As-of Date
Crystal City Airport
Bryon Heineman
27-Mar-91
Task Name
Pre-Listing Activities
Site Abandonment by Operators
Local Identification
Initial TWDR Investigation
TWOR Site Visit
TWDR/EPA Prelim Sampling
EPA Soil Sampling
Initial Removal Action
Verification Sampling
Verfication Sampling
Verification Sampling
Subsequent Removal Action
NPL Listing
Site Proposed for NPL
Site Promulgated on NPL
RI/FS
Project Planning
Scoping Site Visit
RI/FS Funds Awarded to TUC
TWC Issues RFP
RFPs Due at TWC
TWC Awards Ri/FS Contract
Ebasco Drafts WP, QAPP, HSP
EPA/TWC Review Workplans
Ebasco Revisions
EPA/TWC Approval
RI Fieldwork
Onsite Mobilization
Phase I Fieldwork
Phase II Fieldwork
RI Report
Draft RI Report
EPA/TWC Review RI Report
Ebasco Revises RI Report
Final RI Report
FS Report
FS Authorized
FS Objectives Approved
Ebasco Drafts FS Report
EPA/TWC Review FS Report
Ebasco Revises FS Report
Final FS Report
ROD Process
Public Notice
Extended Comment Period
Public Meeting
Record of Decision Signed
Remedial Design
Project Planning
Start
Date
1-Har-83
21-Apr-83
25-Apr-83
5-Hay-83
13-Jun-83
25-Jul-83
31-Oct-83
15-Dec-83
14-Feb-84
29-Har-84
23-Apr-84
5-Oct-84
5-Oct-84
20-Hay-86
19-Aug-85
19-Aug-85
19-Aug-85
25-Sep-85
25-Feb-86
28-Har-86
31-Har-86
1-Jul-86
31-Jul-86
25-Aug-86
19-Sep-86
29-Sep-86
29-Sep-86
30-Sep-86
28- Jan- 87
17-Feb-87
17-Feb-87
8-Apr-87
7- Hay- 87
2-Jun-87
25-Sep-86
25-Sep-86
27-Feb-87
25-Sep-86
18-May-87
15-Jun-87
13-Jul-87
24-Jul-87
24-Jul-87
27-Jul-87
20-Aug-87
?8-Sep-87
31-Mar-88
31-Mar-88
Duratn
(Days)
7O9
eye.
0
0
0
0
0
0
3
0
0
0
2
406
0
0
475
273
0
0
0
0
65
21
18
18
0
94
0
23
13
74
36
21
17
0
198
0
0
160
19
19
0
36
0
35
0
0
201
52
End
Date
Jt *—— »OA
c*>-Apl OH
1-Har-83
21-Apr-83
25-Apr-83
5-Hay-83
13-Jun-83
25-Jul-83
2-NOV-83
15-Dec-83
14-Feb-84
29-Mar-84
24-Apr-84
19-May-86
5-Oct-84
20 -Hay- 86
10-Jul-87
18-Sep-86
19-Aug-85
25-Sep-85
25-Feb-86
28-Har-86
30-Jun-86
30-Jul-86
25-Aug-86
18-Sep-86
19-Sep-86
13-Feb-87
29-Sep-86
31-Oct-86
13-Feb-87
1-Jun-87
7-Apr-87
6 -Hay- 87
1 -Jun-87
2-Jun-87
10-Jul-87
25-Sep-86
27-Feb-87
15-May-87
12-Jun-87
10-Jul-87
13-Jul-87
14-Sep-87
24-Jul-87
14-Sep-87
20-Aug-87
28-Sep-87
18-Jan-89
13:Jun-88
83
Start Apr
Status 1
Done A
Done A
Done A
Done A
Done A
Done A
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Dpne
84
2
.
.
.
m
.
•
A
A.
A
•
.
f
,
.
.
.
.
m
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
,
.
.
85
1
86
1
87
1
88
1
89
3
90
2
91
1
92
1
-------
RO CA Signed w/TWC
TUC Receives RO SOW
Ebasco/TUC Revise SOU
EPA Reviews SOW
Ebasco Revises SOW
TWC/Ebasco Execute Contract
30X Design Effort
Ebasco Generates 30X RD
EPA/TWC 30X Review
30X RD Meeting
60X Design Effort
Ebasco Generates 60X RD
EPA/TWC 60X Review
60X RD Meeting
95X Design Effort
Ebasco Generates 95X RD
EPA/TWC 95X Review
100X Design Effort
Ebasco Generates 100X RD
EPA/TWC Review
100X RD Revisions
EPA Concurs W/100X RD
Post-RD Open House
Remedial Action
Project Planning
RA CA Signed u/TWC
TWC Issues IFB
Pre-Bid Conference
I™1* Bid Period
CJ! TWC Opens Bids
{jj- TWC Signs A&E Contract
TWC Signs Const. Contract
Qua I tec Drafts Submittals
Submittals Finalized
Pre-Construction Conf.
Aquisition of Site Access
TWC Denied Access
TWC Requests EPA Assist
EPA Drafts 104 UAO
City Receives UAO
EPA/City UAO Meeting
Effective Date of UAO
TWC Issues NTP
Field Work
Mobilization
Construction Activities
Pre-Final Inspection
Final Inspection
Substantial Completion
Vegetative Topcover Growth
Final Completion
RA Report
Prep of Draft RA Report
- Ebasco Submits Draft to TWC
TWC Review of Draft RA Rep.
EPA Receipt of Draft RA Rep.
EPA Review of Draft RA Rep.
Revision of RA Rep. by Ebasco
TWC Review of Revised RA Rep.
EPA Receipt of Revised RA Rep
31-Mar-88
1-Apr-88
1-Apr-88
26-May-88
27-May-88
14-Jun-88
15-Jun-88
15-Jun-88
9-Aug-88
15-Aug-88
16-Aug-88
16-Aug-88
13-Sep-88
19-Sep-88
20-Sep-88
20-Sep-88
26-Oct-88
1-Mov-SS
l-Nov-88
21-NOV-88
23-Dec-88
18-Jan-89
19-Jan-89
29-Dec-88
29-Dec-88
29-Dec-88
31-Jan-89
16-Feb-89
31-Jan-89
13-Mar-89
7-Mar-89
21-Apr-89
21-Apr-89
16-May-89
8-Jun-89
K-Jun-89
14-Jun-89
13-Jul-89
23-Aug-89
6-Nov-89
17-Nov-89
23-NOV-89
29- Dec -89
5-Feb-90
5-Feb-90
5-Feb-90
6-Jun-90
9-Jul-90
3-Jul-90
28-Jun-90
25-Sep-90
3-Jul-90
3-Jul-90
30-Aug-90
31-Aug-90
7-Sep-90
10-Sep-90
5-Oct-90
10-Dec-90
18-Dec-90
0
0
39
1
6
0
42
38
4
0
23
19
4
0
29
25
4
51
13
23
15
0
0
832
111
0
0
0
29
0
0
0
17
14
0
116
0
0
52
0
0
0
0
167
0
104
0
0
0
64
0
213
48
0
26
0
19
46
35
0
31-Mar-88 Done
1-Apr-88 Done
25-May-88 Done
26- May- 88 Done
6-Jun-88 Done
14-Jun-88 Done
12-Aug-88 Done
8-Aug-88 Done
12-Aug-88 Done
15-Aug-88 Done
16-Sep-88 Done
12-Sep-88 Done
16-Sep-88 Done
19-Sep-88 Done
31-Oct-88 Done
25-Oct-88 Done
31-Oct-88 Done
17- Jan- 89 Done
18-NOV-88 Done
22-Dec-88 Done
17- Jan- 89 Done
18- Jan- 89 Done
19-Jan-89 Done
26-Mar-92 Started
7-Jun-89 Done
29-Dec-88 Done
31-Jan-89 Done
16-Feb-89 Done
13-Mar-89 Done
13-Mar-89 Done
7-Mar-89 Done
21-Apr-89 Done
15-May-89 Done
5-Jun-89 Done
8-Jun-89 Done
22-Mov-89 Done
14-Jun-89 Done
13-Jul-89 Done
2-Nov-89 Done
6-Nov-89 Done
17-Mov-89 Done
23-NOV-89 Done
29-Dec-89 Done
25-Sep-90 Done
5-Feb-90 Done
28-Jun-90 Done
6-Jun-90 Done
9-Jul-90 Done
3-Jul-90 Done
25-Sep-90 Done
25-Sep-90 Done
26-Apr-91 Started
6-Sep-90 Done
30-Aug-90 Done
5-Oct-90 Done
7-Sep-90 Done
4-Oct-90 Done
7-Dec-90 Done
25-Jan-91 Done
18-Dec-90 Done
A .
4 .
A.
A.
A
.A
.A
. A
-------
1 ._i
H^
EPA Review of Revised RA Rep.
EPA Receipt of As-Built^
Final Qua I tec Documentation
TWC Approval of RA Report
Regional Approval of RA Rep.
First Yr O&M = RA O&F Period
Planning
1st Yr O&M CA Signed (O&F)
EPA Concurs w/O&M/O&F SOW
TWC Signs O&M/O&F Contract
TWC Issues NTP to Ebasco
Monitoring Activities
1st Quarter O&M/O&F
Beginning of Quarter
Site Visit
Trip Report
TWC/EPA Review
End of Quarter
Public Update
2nd Quarter O&M/O&F
Beginning of Quarter
Site Visit
Trip Report
TWC/EPA Review
End of Quarter
3rd Quarter O&M/O&F
Beginning of Quarter
L Site Visit
CJt Trip Report
4^a
§•
..
•i
. TWC/EPA Review
End of Quarter
4th Quarter O&M/O&F
Beginning of Quarter
Site Visit
Trip Report
TWC/EPA Review
End of Quarter
Closeout Report
TWC Submits Project Document.
Draft Closeout Report
TWC Review of Closeout Rep.
Closeout Report Revisions
TWC Concurrence
Regional Appvl of Closeout Rep
Regional Appvl of Closeout Rep
Operations and Maintenance
State Begins O&M
End of Thirty Year Period
Site Deletion
Five Year Review
Administrative Requirements
^m Detail Task ===== Summary Task
•• (Progress) ===== (Progress)
•— (Slack) 33= — (Slack)
IS-Dec-90
25-Jan-91
1-Apr-91
1-Apr-91
29-Apr-91
6-Jun-90
6-Jun-90
6-Jun-90
1-Aug-90
17-Sep-90
8-Oct-90
1-0ct-90
1-0ct-90
1-0ct-90
S-Nov-90
12-Nov-90
2-Jan-91
31-Dec-90
23-Jan-91
1-Jan-91
1-Jan-91
6-Feb-91
27-Mar-91
15-May-91
29-Mar-91
1-Apr-91
1-Apr-91
7-May-91
9-May-91
28-Jun-91
28-Jun-91
1-Jul-91
1-Jul-91
5-Aug-91
7-Aug-91
26-Sep-91
30-Sep-91
1-May-91
1-May-91
10-0ct-91
7-Nov-91
8-Jan-92
13-Feb-92
27-Mar-92
27-Mar-92
27-Mar-92
27-Mar-92
10-0ct-14
3-JUI-95
3-Jul-95
26-Dec-95
10
0
0
0
0
347
88
0
0
0
0
264
70
0
2
36
3
0
0
105
0
2
35
10
0
73
0
2
35
10
0
71
0
2
35
10
0
228
0
20
40
25
10
0
0
5,657
0
0
485
120
365
31-Dec-90
25-Jan-91
1-Apr-91
1-Apr-91
29-Apr-91
9-Oct-91
5-Oct-90
6-Jun-90
1-Aug-90
17-Sep-90
8-Oct-90
9-Oct-91
" 7-Jan-91
1-0ct-90
9-Nov-90
31-Dec-90
7-Jan-91
31-Dec-90
23-Jan-91
29-May-91
1-Jan-91
7-Feb-91
14-May-91
29-May-91
29-Mar-91
1Z-Jul-91
1-Apr-91
8-May-91
27-Jun-91
12-Jul-91
28-Jun-91
9-Oct-91
1-Jul-91
6-Aug-91
25-Sep-91
9-Oct-91
30-Sep-91
26-Mar-92
1-May-91
6-Nov-91
7-Jan-92
12-Feb-92
27-Feb-92
27-Mar-92
27-Mar-92
9-Oct-14
27-Mar-92
10-0ct-14
6-Jun-97
22 -Dec -95
6-Jun-97
Done . . . . . . ••
Done ... . . . . A
Future ... . . . . * .
Future ... . . . A
Future ... . . A
Started ... . . . -
Done ... . . . . ====
Done . . . . . . .A
Done ... . . . A
Done ... . . . . A
Done ... . . . . A
f
.
.
.
Started ... . . . • '
Done ... . . . ===
Done ... . . A
Done ... . •
Done . . . . . . . ••
Done ... . . . . •
Done ... . . . . A
Done ... . . . . A
.
.
e
.
.
.
Started ... . . . . ====
Done . . . . . . . A 1
Done ... . . . . «|
Future ... . . . . *•
Future ... . . . .
•
Future ... . . . . A
Future ... . . . . ===
Future ... . . . . A
Future ... . .
Future ... . . . .
Future ... . . .
Future ... . . .
Future ... . . .
Future ... . . . .
Future ... . . . .
Future ... . . .
Future ... . . . .
Future ... . . .
Future ... . . . .
Future ... . . .
Future ... . . .
Future ... . . .
Future ... . . . .
Future ... . . .
Future ... . . .
Future ... . . . .
Future ... . . . .
Future ... . .
Future ... . . . .
Future ' ... . . .
Future ... . . . .
Future ... . . . .
•
•
•
A .
3E=
A
•
•
•
A
-m i II II
A
•• .
•• .
•.
• .
A
A
5 • - .. .
A
.
.
.
•
«•«•• Baseline
»•»•>• Conflict
..•^ Resource delay
Progress shows Bercent Achieved on Actual A
Miles
tone
Scale- 6 weeks Der character --
TIME LINE Gantt Chart Report, Strip 1
-------
TABLE OF CONTENTS
SECTION TITLE PAGE
1.0 EXECUTIVE SUMMARY 1
2.0 PROJECT SUMMARY 3
2.1 Site Location and Description 3
2.2 Site History 3
2.3 General Geology/Hydrogeology 6
2.4 Extent of Contamination 7
2.5 Assessment of Risks 8
2.6 Record of Decision 9
2.7 Remediation Criteria 9
2.8 Waste Excavation Criteria 11
2.9 Original RA Scope of Work 12
2.10 Field Orders 13
2.11 Change Orders 16
2.12 Nonconformance Reports 18
2.13 Filial Certificate of Substantial
Completion 19
2.14 Construction Cost Summary 20
3.0 REMEDIAL ACTIVITIES 22
3.1 Manor Construction Activities 23
3.2 Health and Safety Activities 30
3.3 Quality Control Activities 30
3.4 Non-construction Issues 31
3.5 Construction Oversight Activities 32
3.6 Construction Oversight Cost Summary 33
4.0 PREFINAL INSPECTION RESULTS 34
4.1 Narrative Summary 34
4.2 Items Inspected 34
4.3 Punchlist and Corrective Action 35
5.0 POST-CONSTRUCTION OPERATION AND 37
MAINTENANCE
6.0 PROJECT FILES 38
ATTACHMENT B
Crystal City Airport RA Report Contents
155
-------
FIGURES
NUMBER DESCRIPTION
1 Site Location Map
2 Construction Cost Summary
3 Schedule of Construction Activities
4
21
29
APPENDICES
APPENDIX DESCRIPTION
A As-Built Drawings
B Field Orders
C Change Orders
D Nonconformance Reports
E Substantial Completion Documentation
F Construction Cost Documentation
G Health and Safety Summary Report
H Chemical Quality Control Project Summary Report
I Engineer's Weekly Progress Reports
J Construction Quality Control Daily Reports
K Weekly Progress Meeting Minutes
L Non-Construction Issues
M Operations and Maintenance Plan
N Record of Decision (ROD)
156
-------
ATTACHMENT c
ODESSA I REMEDIAL ACTION
INTERIM REPORT
TABLE OF CONTENTS
1.0 INTRODUCTION
2.0 SYNOPSIS OF SCOPE OF WORK, AND COMPLETION CERTIFICATION
2.1 Record of Decision
2.2 Description of the Original Construction Scope of Work
2.3 Changes to the Original Scope of Work (Change Orders)
2.4 Changes to the Project Technical Specifications (Field Orders)
2.5 Certification that the Work Was Done
3.0 DESCRIPTION OF REMEDIAL ACTIVITIES DURING CONSTRUCTION PHASE
3.1 Chronology of Major Construction Activities
3.2 Health and Safety (H&S) Activities
3.3 Contractor Quality Control (CQC) Activities
3.4 Resident Engineer Quality Assurance (QA) Activities
3.5 Construction Cost Summary
3.6 Non-construction Activities
4.0 PREFINAL INSPECTION
4.1 Narrative Summary
4.2 Items Inspected
4.3 Summary of Punchlist and corrective Action
5.0 PROCESS STARTUP AND OPERATION VERIFICATION
5.1 Startup Chronology and Narrative Summary
5.2 Operational Problems Encountered and Corrective Action
5.3 Verification of Process Performance
5.4 Optimum Operating Parameters, Recommended Maintenance Schedule, Average
Utility Consumption
5.5 Determination of Sludge Characteristics
5.6 Certification that Performance Based Criteria had Been Met
6.0 DESCRIPTION OF PROPOSED TREATMENT AND CLOSURE PHASE ACTIVITIES
157
-------
ATTACHMENT C
TABLE OF CONTENTS
(Continued)
7.0 LIST OF APPENDICES
APPENDIX
A
B
C
D
E
DESCRIPTION
G
H
El
E2
E3
Fl
F2
F3
F4
F5
F6
Certification of Completion
Prefmal Inspection Report
Change Orders
Field Orders
Progress Reports
Operations Management Monthly Progress Reports
Resident Engineer's Progress Reports
Monthly Progress Meeting Minutes
Quality Control/Quality Assurance
Daily Operations Reports
Contractor's Daily Quality Control Reports
Contractor's Chemical Testing Reports
Contractor's Sludge Testing Reports
Resident Engineer's Chemical Testing Reports
Resident Engineer's Non-Chemical Testing Reports
Contractor's Requests for Payment
As-Built Drawings
Operation and Maintenance Plan
F:\CL\ODA\TOC
158
-------
ATTACHMENT C
ODESSA I REMEDIAL ACTION
FINAL REPORT
TABLE OF CONTENTS
1.0 INTRODUCTION
2.0 INTERIM REPORT
3.0 DESCRIPTION OF REMEDIAL ACTIVITIES DURING TREATMENT AND
CLOSURE PHASES
3.1 Chronology of Major Activities
3.2 Health and Safety (H&S) Activities
3.3 Contractor Quality Control (CQC) Activities
3.4 Resident Engineer Quality Assurance (QA) Activities
3.5 Cost Summary
3.6 Other Remedial Activities
4.0 WASTE DISPOSAL SUMMARY
5.0 PREFINAL INSPECTION
5.1 Narrative Summary
5.2 Items Inspected
5.3 Summary of Punchlist and Corrective Action
6.0 PROPOSED POST TREATMENT OPERATION AND MAINTENANCE
7.0 DESCRIPTION OF PROJECT FILES
8.0 LIST OF APPENDICES
159
-------
TABLE OF CONTENTS
(Continued)
APPENDIX DESCRIPTION
A Certification of Completion
B Prefinal Inspection Report
C Change Orders
D Field Orders
E Progress Reports
El Operations Management Monthly Progress Reports
E2 Resident Engineer's Progress Reports
E3 Monthly Progress Meeting Minutes
E4 Monthly Well Reports
F Quality Control/Quality Assurance
Fl Daily Operations Reports
F2 Contractor's Daily Quality Control Reports
F3 Contractor's Chemical Testing Reports
F4 Contractor's Sludge Testing Reports
F5 Resident Engineer's Chemical Testing Reports
F6 Resident Engineer's Non-Chemical Testing Reports
G Contractor's Requests for Payment
H As-Built Drawings
I Operation and Maintenance Plan
160
-------
WEDZEB ENTERPRISES REMEDIAL ACTION:
PLANNING FOR AN EFFICIENT
REMEDIAL ACTION COMPLETION
(Auihor(s) and Address(es) at end of paper)
INTRODUCTION
The Superfund program was initiated with the promulgation of
the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) in 1980. Through the early stages of
the Superfund program, the primary focus of the program was
completing remedial investigations(RI)/feasibility studies
(FS). Near the end of the 1980s and in the early 1990s, the
Superfund program shifted emphasis from RI/FS activities to
remedial design/remedial action (RD/RA) activities. As the
Superfund program shifted its emphasis to the RD/RA phase,
effective planning and implementing of remedial construction
activities utilizing a phased approach was imperative.
This was especially true for complex sites requiring multi-
media remedial actions of several contaminated media.
Utilizing a phased approach to RD/RA projects is essential
for the following reasons:
It ensures that Statements of Work for both fund-
financed and potentially responsible party (PRP)-
lead are drafted to allow for flexibility in the
project implementation schedule during the RD/RA
phase.
It demonstrates to the public that the U.S.
Environmental Protection Agency (USEPA) is
progressing with remedial actions at National
Priority List (NPL) superfund sites.
It provides the EPA with a mechanism to demonstrate
to the public that narrowly defined objectives of
the Superfund Program, namely RA start and RA
completion, are being attained.
This paper will demonstrate how a cost-effective phased
approach to an NPL Superfund site RA was implemented at the
Wedzeb Enterprises site in Lebanon, Indiana.
BACKGROUND
At the Wedzeb Enterprises site, a fire which completely
destroyed a warehouse containing numerous capacitors and
transformers containing PCBs. Although a removal action was
completed to remove the debris generated by the fire, the
Phase I RI analytical results (USEPA, 1989a) indicated that
additional surface soil and sediment remediation was
necessary- The Record of Decision (ROD) and the associated
Explanation of Significant Differences (ESD) specified that
the RA must involve cleaning and testing approximately six
hundred feet of sewer line, excavating approximately fifteen
cubic yards of low-level PCB-contaminated surface soil, and
offsite disposal of sewer sediment, excavated soil, and RI-
derived waste (USEPA, 1989b). A phased approach to the RA
was chosen. -t o-t
lol
-------
Sanitary Sewer Activities
An RA contractor cleaned approximately six hundred feet of
sanitary sewer pipe over a three-day period in April 1990
(USEPA, 1990). The cleaning was accomplished by
hydraulically jetting the pipe, then suctioning the liquid
and sediment with a vacuum pump from a manhole to a
temporary reservoir tank. From the temporary reservoir
tank, the liquid containing the sediment was pumped through
a bag filter and a carbon adsorption unit to remove organic
contaminants. The liquid was finally metered to a carbon-
steel holding tank, where samples were collected to
determine contaminant concentrations.
The hydraulic jetting consisted of running a hose with a jet
nozzle attachment through the 600-foot segment of sanitary
sewer pipe, scouring the pipe walls with high-pressure
water. Standard sewer plugs were used at both manholes to
block the flow of jetted water downstream and to temporarily
prevent the flow of wastewater into the adjacent segment
which did not require cleaning. Once the plugs were
installed, the pipe line was jetted using a variety of
nozzles that spray along the pipe walls at various angles.
The sediment and grit deposited in and on the pipe was
flushed to the downstream manhole. Once the jetted water
and loosened sediment were collected in the downstream
manhole, a vacuum truck with a submersible hose pumped out
the manhole. The fluids from the manhole were then pumped
to a temporary reservoir for storage and settling of solids
from the fluids. From the temporary reservoir, the fluids
were sent through the bag filter to separate the solids from
the liquids, retaining the solids within the unit.
After passing through the bag filter, the liquid was then
sent through carbon adsorption units to remove the volatile
organic compounds and PCBs. The carbon adsorption units
removed the organic contaminants in the water, including
PCBs that the bag filter had not removed. After filtration
was complete, the carbon was containerized and later
composited with existing Rl-derived waste during the RI-
derived waste disposal activities, which were completed in
August 1990.
A tanker truck was used to contain the water as it was
discharged from the carbon adsorption units. The tank's
5,000-gallon capacity was sufficient to contain the liquid
generated from the jetting and pumping operations.
Disposal of the generated wastewater from the tanker and
sewer sediment was the final procedure in the remediation
process. A liquid sample collected from the 5,000-gallon
tanker and a sediment sample collected from the bag filter
162
-------
were analyzed to determine the magnitude of PCB
contamination. The analytical results from the liquid and
sediment samples indicated no PCB contamination. Therefore,
the wastewater was discharged to the sanitary sewer. The
sediment was containerized and later composited with
existing Rl-derived waste during RI-derived waste disposal
activities.
After the sanitary sewer had been cleaned and the wastewater
had been removed, the pipe was inspected. This television
inspection consisted of a skid-mounted, closed-circuit
camera that sent signals to an aboveground monitor. The
camera was guided through the pipe by a winch and pulley
system, and the monitor was located in an onsite vehicle.
Operation of this apparatus consisted of pulling the camera
skid between two manholes. A tag line attached to the rear
of the camera allowed the operator to back up the camera. A
footage meter kept track of the distance traveled so that
any problem could be readily located. The inspection was
videotaped to provide a permanent record of the inspection.
The results of the television inspection indicated that the
sewer was structurally sound and clean from contamination.
A videotape of the inspection was recorded and put in the
project file.
Soil Excavation and Disposal Activities
An RA contractor excavated and removed approximately
fifteen yards of surface soil to a depth of 3 to 6 inches
along the southern and eastern part of the site. The
location and depth of removed soils were based on the August
and December 1989 Indiana Department of Environmental
Management (IDEM) analytical sampling results.
During the soil excavation, 30 drums containing wastes
generated during the RI and the sanitary sewer RA were
composited with the excavated soils. These composited soils
were sampled and analyzed in May 1990 to determine their PCB
concentrations. The sample analytical results indicated
less than 15 ppm PCBs. Based on these analytical results,
the excavated soil was composited with the Rl-derived waste,
and a total of 20 yards of material was transported to the
Prairie View sanitary landfill, for more cost-effective
disposal. This excavation and disposal was completed in
three days.
In addition, 30 drums were emptied and crushed onsite.
Because they had not been used to containerize any wastes,
these nonhazardous crushed drums were sold to a scrap-metal
distributor.
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DISCUSSION
Based on the relatively low cost of the remediation
($75,000) and the fact that two different contractors could
perform the RA, the implementation of the RA was conducted
using the following phased approach:
The contractor was asked to utilize the small-
purchase procedures established in Part 13 of the
Federal Acquisition Regulations (FAR).
• The RA was conducted in two stages: sanitary sewer
cleaning and soil excavation and disposal.
• The RA Report was structured similarly to the
close-out report.
Generally, Superfund RA contracts require use of the sealed
bidding solicitation process for contracts greater than
$25,000 established in Part 14 of the FAR. Sealed bid
solicitation is a lengthy process that usually requires a
minimum of 15 months. Initially, invitations to bid are
prepared. The bid package and bid review period are
published in the local newspapers and trade journals. After
bids have been received, the bids are tabulated, evaluated,
and awarded to the lowest bidder. The award of the RA
contract is also published.
For the Wedzeb Enterprise site, the USEPA realized that the
proposed RA described in the ROD and BSD could be divided
into separate tasks and completed separately. The RA was
separated into the cleaning of the sanitary sewer and the
soil excavation and disposal. By separating the RA into two
tasks, the cost of the RA could also be separated. The cost
of cleaning the sanitary sewer and the soil excavation and
disposal were estimated to be less than $25,000 each.
Therefore, the small-purchase procedures established in Part
13 of the FAR could be utilized.
The small-purchase procedures in Part 13 of the FARs enable
the USEPA to acquire a minimum of three bids directly from
RA contractors. Using the small-purchase procedures enabled
the RA to be completed under budget and only 15 months after
signature of the ROD. The RA tasks also could be scheduled
more efficiently and the contractor was able to mobilize
quickly to the site, which helped to demonstrate to the
public that the USEPA was progressing with the RA.
The RA was conducted in two stages including sanitary sewer
cleaning and soil excavation and disposal. It was realized
that by separating the RA, each task could be scheduled more
efficiently. By scheduling more efficiently, the contractor
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was able to commence work in the field more quickly. At the
beginning of each phase of work, a public meeting was held
to inform the community of the commencement of the RA. By
holding these public meetings, the USEPA was able to
demonstrate quite effectively to the public that the RA at
Wedzeb Enterprises site was timely and appropriate. At the
end of the second phase, the USEPA was easily able to
demonstrate to the community that the narrowly defined
goals, RA start and RA completion, were attained.
By structuring the remedial action report to be similar to
the close-out report, each report could be prepared
simultaneously, and the deletion process could begin
immediately- The early start on the close-out report
allowed the Wedzeb Enterprises site to be deleted from the
NPL more quickly. This timely deletion also helped
demonstrate to the public that the USEPA was accomplishing
the RA start and RA completion.
CONCLUSIONS
By implementing a phased approach at the Wedzeb Enterprises,
the RA was completed under budget and only 15 months after
signature of the ROD. If the contracts had been obtained
through the bidding process, it is unlikely that the
project could have been completed in 15 months. The phased
approach also provided for the proper scheduling of
activities for the RA to be efficiently completed. Finally,
the similarity between the remedial action report and the
close-out report allowed both reports to be completed
simultaneously. The result was RA completion and initiation
of the deletion process in a short time.
Although the Wedzeb Enterprises site was relatively small,
this approach would apply to larger, more complex sites.
This would be true particularly if the RA had multiple
components. Many times, these components are totally
independent of one another. The more straightforward
components can and should move forward while the
treatability study stage is underway for other areas of the
site.
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REFERENCES
USEPA, 1989a. U.S. Environmental Protection Agency (USEPA)
Final Phase IRemedial Invesgation, Wedzeb
Enterprises Site, Lebanon, Indiana. Prepared by
REM IV team. January 13, 1989.
USEPA, 1989b. USEPA. Design Report, Wedzeb Enterprises
Site, Lebanon, Indiana. Prepared by the REM IV
team. August 25, 1989-
USEPA, 1990. USEPA. Final Remedial Action Report, Wedzeb
Enterprises Site, Lebanon, Indiana. Prepared by
the REM IV team. September 25, 1990.
Author(s) and Address(es)
TinJca 6. Hyde
U.S. Environmental Protection Agency, Region V
230 S. Dearborn Street
Mail Code: 5HS-11
Chicago, Illinois 60660
(312) 886-9296
William T. Dudley
B&V Waste Science and Technology Corp.
4717 Grand Avenue, Suite 500
P.O. Box 30240
Kansas City, Missouri 64112
(913) 338-6665
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The Lansdowne Radiation Site;
Successful Cleanup In A Residential Setting
Victor J. Janosik
U.S. Environmental Protection Agency
841 Chestnut Building
Mailcode 3HW22
Philadelphia, PA 19107
(215)597-8996
INTRODUCTION
During the early 1900s, the radionuclide Radium 226 was utilized in medicine and for industrial
purposes with few or no precautions taken in regard to radiological health. Production,
purification and packaging of this radionuclide was conducted at small industrial sites,
laboratories, and even private homes.
In 1910, Dr. Dicran Kabakjian, a professor of physics at the University of Pennsylvania,
developed a process for the purification of radium. This process was used by a local company
that employed Dr. Kabakjian as a consultant from 1913 to 1922 when the company closed down.
Two years later, the professor opened what was essentially a family-run business in his house at
105 east Stratford Avenue in Lansdowne, Pennsylvania. He continued to produce and repair
radium implant needles used by physicians in the treatment of cancer, and to work with other
medical devices for twenty years. Dr. Kabakjian died at the age of 70 in 1945. He had suffered
from emphysema and a fibrous tissue buildup in his lungs, possibly due to his breathing of acid
fumes from his radium extraction process.
In 1949, 105 E. Stratford Avenue (the Kabakjian side of the twin house) was sold to the Tallant
family, who, in turn, sold it to the Kizirian family in 1961.
In 1963, based on information gathered from private individuals, the Pennsylvania Department of
Health inspected the house and found extremely high levels of radiation which prompted state
officials to begin to look for a way to clean up the property. Unable to address the problem and
cleanup through state or federal regulations, the Department of Health ordered the Kizirians to
decontaminate their home. The Kizirian family enlisted the assistance of a local congressman and
eventually the U.S. Public Health Service and the Pennsylvania Department of Health
decontaminated the 105 E. Stratford portion of the twin house as a "demonstration" project in
1964. The U.S. Air Force also contributed to the decontamination effort by supplying a mobile
radiation laboratory to monitor the cleanup.
The 1964 decontamination effort consisted of removing as much radium as practical by sanding,
scraping, vacuuming, and washing the house walls, floors and ceilings. Some wooden floorboards
and portions of the concrete basement floor were also removed. It is postulated that the acid
fumes from the radium- purification procedure which Dr. Kabakjian used, as well as spills,
burning of contaminated newspapers, and "tracking" of the radium on the bottoms of the
residents' shoes carried the radium throughout the home and resulted in its penetration deep into
the wood and plaster of the house. After the cleanup, the house received epoxy-based paint
coatings to limit the outward migration of the remaining radium. It is estimated that
approximately 90% of the radium in the house was removed in the 1964 cleanup action.
In the summer of 1964, the Kizirian family was allowed to move back into 105 E. Stratford. The
U.S. Public Health Service estimated that, based on a 16 hour-per-day exposure, the radiation
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dose rate received by the occupants was just above the then existing guideline of 0.5 rem/yr, and
that further decontamination of the house would be impractical; The Kizirian family continued to
live in the house.
Just on the other side of the common wall of the twin house, at 107 E. Stratford Avenue, the
Bashore family lived in the home that they had occupied since 1919, the same year that the
Kabakjians had moved into 105. No action was taken at 107 in 1964 when the contamination in
105 was addressed.
DISCUSSION
In 1983, EPA was requesting information from all states concerning radioactive sites that might be
eligible for Superfund cleanup monies. The Pennsylvania Department of Environmental
Resources (PADER) notified EPA of the Lansdowne site and its previous contamination. In early
1984, EPA and PADER sampling and monitoring of the structure showed high radon and gamma
radiation levels in 105 (the Kizirians) and high radon levels but with lower gamma levels in 107 ;
(the Bashores). Additionally, very high levels of radiation were measured in the soil around the
properties. In March, 1984, the Chronic Disease Division of the Centers for Disease Control
(CDC) wrote that based on the measured levels, "...the entire duplex structure should be
considered to pose a significant health risk to longterm occupants." Gamma radiation levels were
found to be about 100 micro-Roentgens per hour (uR/hr) throughout most of 105 E. Stratford^
and ranged to 300 uR/hr in the dining room. Radon daughters were measured using an EPA
RPISU and found to be about 0.3 Working Levels (WL). (It should be noted that this was before
the discovery of the infamous Watras House in the Reading Prong area of Pennsylvania and that
the radon levels in the Lansdowne home were thought to be very high at the time.)
A simplified gamma dose calculation for 100 uR/hr yields in excess of 800 mrem per year, so,
assuming average exposures, the residents were exceeding acceptable gamma exposure limits for
the general public. An exact dose prediction accounting for gamma energies, etc. was not
performed because the actual exposures of the residents was also dependent on the time spent in
various places in the house. This could not be determined with any accuracy. It was also clear
that the radon decay product exposure would be about 15 Working Level Months (WLM) per year.
This computation was based on a 50 WLM per WL exposure, and is reasonably accurate assuming
occupancy by pre-school children who would spend the majority of their time in the house. This
exceeds the 4 WLM per year occupational standard for uranium miners. In September, 1984,
EPA, in coordination with the Federal Emergency Management Agency (FEMA) began a
temporary relocation effort for the residents of the twin house. These actions were taken as part
of a larger effort to determine and to minimize the threat to the local community and the
environment. Mrs. Kizirian (105 E. Stratford) was moved to an apartment in the area. Mrs.
Bashore (107 E. Stratford) declined the relocation. She was remarried in November, 1984, and
moved to the home of her new husband.
EPA's emergency response action in 1984 included the installation of burglar alarm and fire alarm
systems, and a full sprinkler system throughout the structure. A 1000-gallon water bladder was
installed in the basement of each house as a back-up for the municipal water supply. The insides
of all windows were sealed with plastic to minimize radon and radon daughter dispersion, and
security arrangements were made with the Lansdowne Police Department.
Some of the furniture in the homes was found to be free of contamination and was removed for
the residents' use. Contaminated furniture and other household belongings were left in the houses
pending the remedial action. The owner of 107 E. Stratford expressed her desire to save a number
of pieces of heirloom mahogany furniture which were found to be contaminated with radium.
Initial efforts during the emergency response action failed to satisfactorily decontaminate most gf
the items.
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After the EPA involvement in the site became known, the fears of the site neighbors with regard
to the possible contamination of their respective homes had to be addressed. EPA handled this by
offering to survey the house of anyone in the neighborhood who asked. The various news media
were contacted to help extend this offer to those people who possessed articles which were taken
from 105 or 107 E. Stratford Avenue in years past and which might be contaminated with radium.
Because of the number of houses involved, the home surveys were conducted using a micro-R
meter. This search found that none of the nearby houses had been contaminated. However, the
survey showed elevated gamma levels in the back yards of the six adjoining properties. It was not
clear at the time whether this was due to shine from the 105/107 property or to contamination
which had migrated off the property.
As a result of news media attention, a few contaminated items were found which had previously
been removed from the house. The most important of these proved to be three metal cabinets
which had been removed from the basement of 105 E. Stratford by Dr. Kabakjian's son, and
which had been placed in the basement of that son's home, also in Lansdowne, not far from the E.
Stratford Avenue site. These cabinets had resulted in the contamination of the son's home, and
required a subsequent emergency response action (called "Son of Lansdowne") by EPA.
As part of the emergency removal action at the 105/107 E. Stratford Avenue site, the sewer lateral
from 105, and the street sewer were surveyed. Using a 2 X 2 sodium iodide detector, gamma
levels up to about 190 micro-R per hour were detected. The survey process was somewhat
complicated by the natural thorium content of the clay used to make the original sewer pipe.
Records of Decision
Following EPA's initial emergency response actions at the site, a Record of Decision (ROD) was
signed on August 2, 1985 by the EPA Region III Regional Administrator based on the studies
which had been performed on the site by Argonne National Laboratories. This first ROD
provided for the permanent relocation of the site residents. However, this matter became a non-
issue when the owner of 107 E. Stratford remarried and moved to her husband's home as noted
earlier, and the owner of 105 E. Stratford died in early 1986 while occupying the apartment which
had been provided under the temporary relocation during the emergency response action. The
selected Remedial Alternative, designated in a second ROD dated September 22, 1986, called for
the removal of the contaminated structures and the contaminated soil to an approved offsite
disposal facility. The ROD also called for the removal and replacement of the contaminated sewer
line on E. Stratford Avenue. The ROD provided that, after removal of the contaminated
structures and soil, the site would be backfilled with clean soil and revegetated. At the time, the
project was expected to cost approximately $4,500,000.
Remedial Design
EPA Region III developed an Interagency Agreement (LAG) with the U.S. Army Corps of
Engineers (USAGE), Omaha District, to develop specifications for the cleanup and to select a
remedial action contractor through a process of evaluating contractor- submitted proposals. Of
major concern in the development of the specifications were the protection of area residents from
radioactive aerosols, and the level to which contaminated soil would be cleaned up. It was decided
that the specifications would only generally require the protection of the residents from
radioactive dusts, and that the proposals from the contractors would be evaluated with particular
attention to the method that each contractor proposed for providing that protection. EPA also
decided, after consultation with USAGE and Argonne National Laboratory personnel, that the
UMTRACA standard of 5 pico-Curies per gram (pCi/g) above background for surface soil at
uranium mill tailing sites was an appropriate cleanup criterion for the soil in this densely-
populated area.
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It was conservatively estimated at that time of the design process that approximately 1000 tons of
contaminated soil would have to be excavated. It was also assumed, for the purposes of the
proposals, that the house was of frame and stucco construction, and that approximately one-half
of the rubble from the house would be disposed of as contaminated waste while the other half
would become ordinary demolition debris. After checking on the potential disposal costs for the
weights and volumes of the estimated amounts of contaminated wastes, USAGE requested that an
additional $1.5 million be added to the project budget. That brought the remedial action budget
to $6 million.
On April 26, 1988, USAGE, Omaha District awarded the construction contract to Chem-Nuclear
Systems, Inc., of Columbia, South Carolina. Oversight of the project was transferred to the
USAGE Baltimore District Office in May, 1988.
Site Access
It was, of course, necessary to gain access to the several properties which would be involved in the
remedial action. To prevent the loss of valuable personal property belonging to the Owners of 105
and 107 E. Stratford Avenue, the Commonwealth of Pennsylvania legislated money to pay those
owners the values of their properties. Two independent assessments were performed for each ,
residence and by way of contracts among the property owners, EPA, and the Commonwealth of
Pennsylvania, the owners were paid the full values of their respective properties. Under the
agreements, they would also retain the ownership of the building lots and would take possession of
those lots following the remedial action.
Written access statements were obtained from the six property owners surrounding the 105/107 E.
Stratford Avenue property because it was suspected that the soil of the back yards of those
residences would be contaminated with radium and would require excavation. One home owner
was in the process of attempting to sell his house during this process and resisted allowing EPA
access to his property. After lengthy and unsuccessful negotiations, EPA requested the assistance
of the Department of Justice whose attorney convinced the homeowner that it was in his best
interest to grant EPA the necessary access. The other five home owners were more easily
persuaded to grant access due in large part to a clause which EPA had incorporated into the
USAGE Request For Proposal. That clause called for the remedial contractor who would perform
the cleanup to replace all fencing, walkways, buildings, trees, shrubbery, etc., damaged or
destroyed as part of the cleanup of any "offsite" properties. Access was also gained from a
property owner whose driveway was to be blocked during the remediation. That access was for
the purpose of constructing a temporary driveway on another portion of her property for her use
during the remedial activities.
The Remedial Action
USAGE issued a Notice to Proceed to Chem-Nuclear Systems, Inc., on June 1, 1988. After a
number of meetings and various preparations, Chem-Nuclear began activities onsite at the
beginning of August. These onsite activities included the complete fencing of the 105/107
property, the installation of electric and telephone service, the construction of a small building to
separate contaminated from uncontaminated wastes, the placement of 4 trailers to house the site
management, the crew, the USAGE Project Engineer, and Argonne National Laboratories
personnel. The trailers and the building were placed on E. Stratford Avenue thereby blocking the
street for nearly one block and preventing the passage of any traffic.
Removal of the structure was accomplished from the inside out. The shell of the house was used
as a containment to prevent migration of the radium off the site. The structure was kept at a
negative pressure with a fan and HEPA filter to prevent leakage. Material removed from the .
house was classified as either "rad waste" or as demolition waste. This process required some
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simplifying assumptions otherwise the process of separation of the waste would have been
prohibitively costly. All materials with inaccessible interior surfaces, porous surfaces, or painted
surfaces were classified as rad waste. Materials noticeably above background on a G-M survey
meter received similar treatment. Because the background was somewhat elevated, three
background counts were used to estimate a standard deviation of the background at the place the
meter was to be used. If the reading obtained from an object was more than two sigma above
background, it was classified as rad waste. In the end, only two items from the structure, a half
brick and three quarters of a brick, were classified as uncontaminated waste. Whereas it had been
originally assumed that the houses were of frame and stucco construction, it was discovered
during the dismantlement that the exterior walls were of solid stone, ranging from 24 inches thick
at the foundation to 18 inches thick at the roofline.
Worker protection on the site consisted of cotton coveralls, booties, and respiratory protection.
Two forms of respiratory protection were used: negative pressure HEPA filter respirators and
Racal AH-3 Air Stream helmets. The latter devices incorporate helmet protection, eye protection
and respiratory protection in a single unit. In these units, a battery powered fan mounted on the
wearer's belt blows filtered air across the face. The protection factor is about 30. These devices
were recommended by Argonne National Labs personnel because of their favorable experience
with the units. The units were considered equivalent to level C pro-
tection and were used interchangeably with filter respirators. Higher levels of protection were not
used because the site had previously been cleaned of most of the original contamination and
because truly dangerous atmospheres could not reasonably be anticipated based on the extensive
site survey performed prior to the remedial action.
The site Health Physicist expressed concern about the Racal units because of their need for
frequent repairs and their bulkiness, especially when used in close quarters. The advantages of
these units include the lack of the need for a tight facial air seal and ease in breathing. Choice of
level C protection was judged to be appropriate upon evaluation of the air measurements taken
during the interior work. The cumulative average airborne contamination for the entire job was
1.2 Maximum Permissible Concentrations per hour (MPC-hr). This is far below the MPC for
radium. The maximum level measured during the remedial action was 7.5 MPC-hr for one two-
hour period at one location.
The yard around the house had shown obvious signs of contamination on the initial surveys done
during the 1984 emergency response action. Samples taken from "hot spots" showed high radium
concentrations in the soil. That initial survey strategy was influenced somewhat by statements
made by a next door neighbor that she remembered truckloads of "ore" being dumped in the side
yard of the house. The initial survey, however, indicated that the soil contamination was more or
less uniformly distributed and had been washed into the soil by rainfall. Soil core samples
appeared to confirm this assumption. However, upon excavation during the remedial action, the
pattern of contamination was found to be quite different. The hottest spots (1-2 mR/hr gamma)
were associated with broken test tubes apparently buried six inches to one foot below the ground.
A hot spot was discovered immediately to the right of the front porch door. It appears that the
professor occasionally discarded solutions by dumping them on the ground beside the door and
even had buried some materials in his yard. Most of the liquid waste from the radium-refining
process was probably disposed of in the sewer.
Several areas which, during the emergency response action, had appeared to be contaminated,
were found to be free of contamination during the remedial action. Elevated gamma readings in
those areas were apparently due to radon decay products which had migrated underground. Since
radium itself is only a weak gamma emitter and the 214-Pb and 214-Bi radon decay products are
the principle gamma emitters, the gamma surveys showed the location of the radon daughters, not
the radium. Radon transport underground was shown to be an important process which will
affect the ability of a survey to locate the source of contamination in future radium sites.
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Rotted tree roots were uncovered which had apparently acted as conduits for the radium. It is not
known whether the trees were alive when this process occurred, or whether the radium followed
the channels formed by the rotting roots. Radium levels in the soil near these roots was 14-50
pCi/g.
Soil contamination found during the remedial action was more extensive than had previously been
estimated. Radium contamination to a depth of 9 feet was found in the 105/107 E. Stratford
backyards and to 11 feet on two adjoining properties. The contamination had migrated onto all
six of the adjoining properties and required excavation. Trees, fences, shrubs, and lawns were
destroyed in the cleanup process. The sewer on East Stratford Avenue was excavated for disposal.
Garages on two of the adjacent properties were dismantled so that contaminated soil around them
could be excavated. Because of the extensive overrun for the soil excavations, an additional $4
million was added to the project in January 1989 bringing the budget to $10 million. The project,
primarily because of the extensive soil excavations, was costing up to $300,000 per day. By the
middle of April 1989, the project funds were nearly depleted and $1.6 million was added to bring
the budget to $11.6 million where it currently stands.
CONCLUSION
In all, 1,430 tons of radioactive rubble (46,698 cu. ft.) and 4,109 tons (83,226 cu ft.) of radium
contaminated soil were generated. Prior to remediation of the site, radium levels in the soil
ranged as high as 700 pCi/g. Following remediation, radium levels in the soil had been reduced to
no greater than 5 pCi/g above the local background of 1.5-2.1 pCi/g. An activity of no greater
than 5 pCi/g above the local background qualifies the site by EPA standards to be released for
unrestricted use. The total annual radiation effective dose equivalent received by a member of the
population in the United States from various sources of natural radiation exposure is estimated to
be 300 milli-rems (mrem). The Argonne National Laboratory has calculated the annual dose
equivalent on the site after backfilling to be about 75 mrem.
At the end of the cleanup, the site was brought to near- original grades and restored as a grassed
lot. A new sewer line was constructed to replace the 243 feet of contaminated line that was
removed. Trees on properties adjacent to the 105-107 lot that had to be removed during soil
excavation were replaced with nursery stock. A contaminated garage that was removed on the 112
East Stewart Avenue property (at the rear of the 105/107 E. Stratford property) was replaced in
kind, as was another non-contaminated garage at 110 E. Stewart that had to be demolished
because it was built over contaminated soil.
The project was brought to a successful conclusion without project personnel receiving any
radiation dose above the allowable limit and without the release of any radioactive contamination
into the environment. EPA is currently pursuing the process which will result in deletion of the
site from the National Priorities List.
REFERENCES
1. Remedial Action Plans and Procedures for the Lansdowne Property; Argonne National
Laboratory; June 1985.
2. Radiological Assessment Report for the Lansdowne Property; Argonne National
Laboratory; October 1985.
3. Record of Decision; U.S. Environmental Protection Agency; August 2, 1985.
4. Record of Decision; U.S. Environmental Protection Agency; September 22, 1986.
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5. Immediate Removal Request for the Lansdowne Site, U.S. Environmental Protection
Agency; September 7, 1984.
6. Post Remedial Action Report, Volumes I, II, HI and IV; U.S. Army Corps of Engineers;
June 1990.
7. "The Lansdowne Radiation Site, The Only Private Residence On The NPL"; William
Belanger and Victor Janosik; May, 1989.
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Remedial Design Approach and Design
Investigations at the Bayou Bonfouca
Superfund Site
(Author(s) and Address(es) at end of paper)
INTRODUCTION
This paper provides an overview of remedial design approaches and
design investigations for the Bayou Bonfouca Source Control oper-
able unit (OU). General topic areas include:
• Background site history and remedial investigations
• General remedial design approach and design investiga-
tions
• Pilot Study dredging and material handling
• Bayou sediment dewatering
• Air emission flux testing
• Air emission dispersion modeling
BACKGROUND
The Bayou Bonfouca site (Figure 1) is located in Slidell,
Louisiana, in St. Tammany Parish. The site is approximately
25 miles north and east of New Orleans. The site's name is a ref-
erence to Bayou Bonfouca, which forms the southern boundary of the
site. Bayou Bonfouca is a tributary of Lake Pontchartrain,
approximately 7 miles to the south of the site. The site encom-
passes approximately 55 acres.
Land east of the site is primarily used for commercial purposes.
Land north and west is generally residential, and land to the
southwest across Bayou Bonfouca is a residential subdivision.
About 750 people live within 1 mile of the site. Bayou Bonfouca
is used for industrial activities downstream of the site, and
recreational boating upstream and downstream. The majority of the
site lies within the 100-year flood plain of the bayou.
The bayou has been dredged downstream of the site. In addition, a
turning basin has been dredged adjacent to the site that is used
for barge operations. It appears that the turning basin was con-
structed by excavating into the bayou bank at the southern bound-
ary of the site and erecting a bulkhead along a 250-foot length of
this boundary- The turning basin is approximately 250 feet wide
and 10 feet deep. Upstream, the bayou is considerably shallower
and narrower.
SITE CONTAMINATION HISTORY
The earliest records of the Bayou Bonfouca site date back to 1892
when a creosote wood-treating facility was reportedly developed
onsite. The creosote plant treated pilings for use in the con-
struction of a railway across Lake Pontchartrain. Over the years,
the plant operated under che ownership of various creosote com-
panies. During the operating history of the plant, there were
apparently numerous releases of creosote onto the site and even-
tually into the bayou. In 1970, the plant burned and, reportedly,
a large amount of creosote was released from storage tanks onto
the site and into Bayou Bonfouca.
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ST. TAMMANY PARISH, LOUISIANA
Figure 1
Bayou Bonfouca Site
Slidell, Louisiana
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Available records indicate that creosote was the only preservative
used at the site. Creosote, distilled from bituminous coal, is a
complex mixture of over 400 individual components. Polynuclear
aromatic hydrocarbons (PNAs or PAHs) comprise over 90 percent of
the creosote components. Based on previous investigation data,
PNAs have been chosen as the indicator parameter(s) for Bayou
Bonfouca site contamination.
REMEDIAL INVESTIGATION ACTIVITIES
In April 1976, the U.S. Coast Guard began investigating the pollu-
tion of Bayou Bonfouca. The investigation revealed that creosote
was discharging overland via runoff into the bayou and that boats
had been damaged from contact with oily substances in the bayou.
A followup sampling program conducted by the U.S. Environmental
Protection Agency (EPA), the U.S. Coast Guard, and the National
Oceanic and Atmospheric Administration (NOAA) in 1978 charac-
terized the contaminants as containing numerous aromatic com-
pounds. The heavier fractions of these compounds were reported to
be in sediments within 400 to 500 yards of the plant site.
From 1979 to 1980, the regional response team began evaluating
alternate methods to address site problems. Several options were
evaluated; however, no action was taken because it was felt that
removal of the contaminated bayou sediments required further
study.
From 1980 through 1982, several investigations were performed
onsite for the U.S. Coast Guard and the NOAA. These studies
included qualitative evaluations of the components of the contami-
nated sediments, analysis of organisms from the bayou, and esti-
mates for surface waste volumes.
In December 1982, EPA included the Bayou Bonfouca site on the
National Priorities List (NPL) for Superfund sites. Remedial
investigations (RIs) were performed by EPA from late 1983 through
early 1986. The RIs investigated the extent of creosote waste and
contamination in onsite waste piles, onsite soils, onsite and
offsite groundwater, and bayou sediments.
FEASIBILITY STUDY/RECORD OF DECISION
A feasibility study (FS) for the Bayou Bonfouca site was completed
in 1986. The FS presented and evaluated a range of alternatives
for remediating the threats posed by site contaminants.
In March 1987, the EPA selected a remedial alternative to mitigate
the threats posed by hazardous waste at the Bayou Bonfouca site.
The selected remedy was presented in the Bayou Bonfouca Record of
Decision (ROD) under the authority of the Comprehensive Environ-
mental Response, Compensation, and Liability Act of 1980 (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA). In 1989, EPA decided to separate the remedial action
and associated design activities into two operable units (OU), the
176
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Groundwater OU and the Source Control OU. The original ROD was
amended in February 1990 in a document entitled Explanation of
Significant Differences to reflect changes to the remedy based on
the more than threefold increase in the estimated volume of con-
taminated bayou sediments that resulted from the 1988 sediment
investigation data.
As defined by the amended ROD, the scope of remedial activities to
be performed under the Source Control OU includes the following:
• Contaminated sediment in Bayou Bonfouca, the eastern
drainage channel, the western creek, and contaminated
waste piles will be incinerated onsite.
• Dredging will be conducted to "safe slopes," which will
result in minor amounts of contamination being left in
place in some areas. In areas where dredging to achieve
stable slopes would result in leaving significant vol-
umes of contaminants, bulkheads will be placed and the
material removed.
• During dredging operations, turbidity or silt curtains
and absorbent booms will be placed along the bayou, at
the ends of the bayou, and surrounding the operations,
to aid in controlling the release of contaminants during
dredging.
• Dredged areas will be backfilled with clean material to
provide a barrier against contact.
• Residual ash and contaminated soils to be consolidated
will be disposed in the onsite landfill. The landfill
will be covered with a RCRA-compliant cap.
• Contaminated onsite soils outside of the landfill area
between 100 and 1,000 ppm total PNAs will be consoli-
dated within the landfill. Contaminated soils greater
than 1,000 ppm total PNAs will be incinerated.
DESIGN ACTIVITIES
Design of the remedial action was initiated in June 1987. One of
the first activities was to develop the design basis for the
project. Design basis development included the collection and
evaluation of data to provide the technical input for the remedial
design activities. The previous site data base, compiled during
remedial investigations, identified the nature and extent of con-
tamination and provided a foundation for the FS. This site data
base needed to be expanded to provide remedy-specific data neces-
sary for design and subsequent remedial construction. To obtain
this data, design investigations were performed as part of the
Bayou Bonfouca remedial design.
177
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Design investigations were conducted from May 1988 through June
1990. Investigations were performed for the following purposes:
• To better determine the degree of sediment contamination
in the bayou
• To investigate the extent of groundwater contamination
beneath and adjacent to the site
• To assess the geotechnical characteristics of subsurface
materials at the site for design of the onsite landfill
and related facilities
• To provide a general characterization of wastes at the
site
• To assess dewaterability and material handling proper-
ties of contaminated bayou sediment
• To investigate air contaminant emission rates from
potential waste handling and process operations
• To determine slope conditions along the bayou banks that
may be affected by dredging
The design of the Groundwater OU was completed in June 1989 and
construction was awarded in October 1989.
The Source Control OU design was completed in September 1990. A
solicitation for Source Control OU remedial action proposals was
conducted and contractor proposals were received through March 4,
1991. The proposals are currently under evaluation by the U.S.
Army Corps of Engineers (USCOE). A remedial contractor selection
is anticipated in summer 1991.
DISCUSSION
DESIGN APPROACH
The Bayou Bonfouca Source Control OU final design documents con-
sist of primarily performance-type specifications. This specific
design approach was initially developed in mid-1988 under a pre-
liminary design concepts task. The main reasons for selecting the
primarily performance-specified design approach were:
• Multiple technologies and approaches are available for
use in the site remediation. Performance specifications
allow for contractor flexibility in using familiar tech-
nologies and methods. This allows for maximum remedial
action bid competition.
178
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• The majority of the remedial action work is service-
oriented and involves the use of temporary facilities
for which EPA and Louisiana Department of Environmental
Quality (LDEQ) would not assume long-term responsi-
bility.
The Bayou Bonfouca design investigations were conducted to support
the design effort. The investigation costs were considered versus
potential benefits of additional site-specific information. The
primary benefits identified for additional site information
included:
• Significantly improved data for developing representa-
tive site remediation design scenarios and costs
• Additional basis for development of specifications
• Significantly improved data to represent the site for
vendor bidding considerations
Table 1 lists major remedial action components for the Bayou
Bonfouca Source Control OU, and describes corresponding general
remedial design approaches and key design investigation input.
The Bayou Bonfouca design investigations encompassed dozens of
physical characterization, chemical characterization, and treat-
ability testing programs for various waste areas at the site. The
following subsections provide a general perspective on the Bayou
Bonfouca remedial design investigations and on use of the result-
ing data in the design. Focused discussions are also included
for the following specific design investigation areas:
• Field dredging and material handling
• Bayou sediment dewatering
• Air emission flux testing
• Air dispersion modelling
PILOT STUDY DREDGING AND MATERIAL HANDLING
Pilot Study dredging and material handling studies were performed
to obtain information on oversize material in the bayou, to
characterize sediments removed by full-scale dredging techniques,
and to provide sufficient sediment quantities for the Pilot Study
testing.
During the November/December 1989 Pilot Study conducted at the
Bayou Bonfouca site, bayou sediments were dredged, handled in
bulk, size classified, and placed into drums. The drummed sedi-
ments were used in a range of characterization and treatability
tests performed in the field and in subsequent laboratory tests.
Figure 2 shows a schematic layout for the actual. Pilot Study
operations. The following items highlight the dredging and mate-
rial handling operations:
179
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CO
o
Table 1
Summary of Remedial Design Approach /Design Investigation Input
Remedial Action Component
Dredging
Material handling
Sediment dewatering
Incineration
Water treatment
Air emissions monitoring and
controls
Site civil activities
• Site preparation (waste
consolidation, waste
excavation, site grading,
initial landfill
construction)
• Landfill operation
• Landfill closure
• Temporary site facilities
Remedial Design Approach
Performance specification with section
specific dredge lines.
Performance specification.
No specific performance requirements;
contractor systems must conform with
applicable regulations .
Performance specification. Sediment
incineration payment approach is based on
tons of dry ash.
Performance specification with a prescribed
minimum unit process train: flow
equalization, clarification, multimedia
filtration, oleophilic media filtration,
granular activated carbon, and post -aeration.
Performance specification. Remedial
contractor required to identify air emission
sources and fluxes and to perform dispersion
modelling.
Detailed design.
Detailed design.
Detailed design.
Performance specification.
Key Design Investigation Input
Sediment investigation provided data to
define dredge sections for inclusion in
construction drawings.
Pilot Study dredging with crane-mounted
clamshell revealed numerous logs and poles
near the bulkhead. Pilot Study dredged
materials were processed, using a double
deck power screen, into three size
fractions.
Lab scale and small field scale dewatering
tests provided an idea of probable range for
mechanical dewatering of bayou sediments.
Sediment cores were tested for Btu, ash, and
moisture content. This data helped define
inputs for incinerator throughput modelling.
Wastewater samples were synthesized using
sediments from sediment investigation, and
characterized. A 50-gpm pilot wastewater
treatment system was operated for the
Groundwater OU. This system included oil/
water separation, oleophilic media
filtration, sand filtration, and granular
activated carbon.
Pilot Study air contaminant flux testing
provided a range of organic fluxes to use as
inputs for individual source and combined
source dispersion modelling.
Geotechnical explorations provided
information for evaluating soil load bearing
of various site areas for anticipated
remedial construction.
CVOR185/059.51
-------
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VACUUM-ASSISTED
DEWATERING
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-7
CO
TURBIDITY
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Figure 2
1989 PILOT STUDY LAYOUT
Bayou Bonfouca
Slidell, Louisiana
-------
• Dredging was performed in the turning basin immediately
offshore from the bulkhead. The dredging operation was
performed within a 350-foot semicircular arc formed by a
solid vertical PVC turbidity curtain and bordered by the
bulkhead and nearby shorelines.
• Approximately 12 cubic yards of bayou sediments were
dredged with a 2-cubic-yard clamshell bucket. Samples
of the dredged sediments typically contained 32 to
37 percent solids.
• Dredged sediments were placed in rolloff containers,
removed by a backhoe, and fed to a double deck vibrating
screen. The sediments were discharged to drums after
separation into three size classifications.
• Large tree limbs or logs were encountered in each of the
eight clamshell bites. Many oversized objects were
"felt" by the crane operator. Several large logs and
limbs were pulled up above the water surface during the
dredging operations. Some of these were removed and
placed onshore, and some fell back into the Bayou. The
retrieved oversized tree limbs and logs were cut using a
chainsaw and placed into drums.
Figure 3 provides a schematic for the double deck vibrating screen
and shows the size cuts for the classified dredge materials.
Table 2 summarizes the field measured mass and volume distribu-
tions for the three dredged material size classifications.
Table 2
Material Size Classification
Less than 1/2 inch
Between 1/2 inch and 2 inches
Over 2 inches*
Mass %
70
20
10
Volume %
61
23
15
*Does not include trees and poles.
BAYOU SEDIMENT DEWATERING
The Bayou Bonfouca remedial action is centered around incinera-
tion. There is significant cost associated with the energy
requirements for vaporizing water in the incinerator. Water is
contained as an integral part of the as-dredged bayou sediment.
The design investigation data showed that the in-place sediments
average 51 percent water content on a mass basis. This sediment
makes up the majority of the material to be fed to the incinera-
tor. Therefore, the balance between dewatering and incineration,
costs is an important consideration for the remedial design.
182
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28-9! J: \QiS\i.MOUSr\MGvFO^O\3YLNPS4 DWG
SCREEN FEED
HOPPER ---•—
DREDGED BAYOU
SEDIMENTS
LOW SPEED
CONVEYOR
CONVEYOR TO
V/BRA TING
SCREEN
< 14"
MATERIAL
DOUBLE DECK
VIBRA TING SCREEN
ASSEMBLY
< 2"
MATERIAL
> 2"
MATERIAL
CLASSIFIED
DREDGED SEDIMENTS
TO DRUMS
Figure 3
VIBRATING SCREEN SCHEMATIC
Bayou Bonfouca
Slidell, Louisiana
-------
Equipment and Procedures
Dewatering studies have been performed to indicate viable dewater-
ing methods for reducing the water content of the dredged sedi-
ment. This experimentation has been performed in three phases:
during the initial design investigation, during the pilot study,
and following the pilot study at an offsite testing laboratory.
During the design investigation of 1988, dredged sediment was not
available, so drainage channel sediment, vibracore samples, and
bayou water were used to prepare a synthesized sediment sample for
settling and dewatering tests. Portions of the synthesized sample
were tested using the following methods over a range of dilutions:
• Polymer jar tests (using vendor-supplied products and
technical assistance)
• Batch flux curve settling tests (using graduated cylin-
ders)
• Gravity settling tests (using 6-inch-diameter by 8-foot-
tall column)
Capillary suction time tests
Buchner funnel tests (lab-scale vacuum filtration)
Sludge drainage tests (bench-scale sand bed simulation)
Pressure filter tests (using bench-scale device)
Filter leaf tests (using lab-scale apparatus)
Pilot study testing was performed in 1989 on sludge dredged from
near the bulkhead on the southern border of the site, using a
clamshell dredge. It was believed that these dredged samples were
more representative than synthesized samples tested in the 1988
Design Investigations, yet not necessarily representative of the
entire area to be dredged during remediation. The following tests
were performed on the dredged samples over a range of dilutions:
• Gravity settling tests (using 6-inch-diameter by 8-foot-
tall column)
Capillary suction time tests
Filter-leaf tests (using lab-scale apparatus)
Sludge drainage test (bench-scale sand bed simulation)
Filter press tests (1 ft3 pilot unit)
Lab-scale vacuum-assisted sludge dewatering bed polymer
dose testing
• Pilot-scale (8 ft3) vacuum-assisted sludge dewatering
bed tests
• Lab-scale (400-ml) vacuum-assisted sludge dewatering bed
tests
A portion of dredged sample was transported offsite to a testing
laboratory. Shortly after the pilot study, the laboratory per-
formed the following lab-scale tests:
• Basket centrifugation
• Solid-bowl centrifugation
• Vacuum filtration
184
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Pressure filtration
Simulated trommel screen dewatering
Results
Table 3 presents the results of the settling and dewatering test-
ing performed.
The pilot study as-dredged material was typically from 32 to
37 percent solids. The range of dewatering processes tested indi-
cated that solids concentrations of up to 50 percent were possible
using sludge drainage, vacuum filtration, and centrifugation tech-
niques. Many of these techniques employed polymers or other addi-
tives to reach the higher solids concentrations.
This dewatering testing has provided information that can be
applied to numerous remedial design scenarios for the Bayou
Bonfouca site. Testing dilute sludges has provided information on
the dewaterability of hydraulically dredged sediment, while the
more concentrated samples have provided results that describe the
dewaterability of the mechanically dredged sediment or thickened
hydraulically dredged sediment streams. Information on polymer
and additive dosing has also been collected for certain process
options over a range of feed concentrations.
AIR CONTAMINANT EMISSION FLUX TESTING
Preliminary flux values were calculated for air contaminant dis-
persion modelling efforts in the 1988 design investigation phase.
These values had been calculated using TSDF, based on the simpli-
fying assumption that the composition of the emission from contam-
inated soils and other material was 100 percent naphthalene.
Since air emissions resulting from the remediation efforts are a
major concern at the Bayou Bonfouca site, it was recognized during
the planning of the Pilot Study phase of predesign work that more
accurate measurements of the magnitude and estimates of the compo-
sition of air emissions resulting from anticipated remedial opera-
tions were necessary.
Equipment and Procedures
To define a list of target compounds in bayou sediment emissions,
a sample of sediment was obtained prior to air emissions field
work and was sent to an off site laboratory for gas chromatography/
mass spectroscopy (GC/MS) analysis. The results of this charac-
terization were used to identify target compounds and plan appro-
priate analytical techniques for use in the field pilot testing
effort.
Early in the Pilot Study planning activities, plans were made to
fabricate air contaminant flux chambers to obtain contaminant flux
185
-------
Table 3
Comparison of Dewatering Results from 1988 Design Investigation, Pilot Study,
and Offsite Laboratory Activities
Polymer Jar Test
Batch Flux Settling Test
Gravity Settling Test
Buchner Funnel Test (vacuum
filtration)
Filter Leaf Test
Sludge Drainage Test (sand
bed simulation)
Pressure Filter Test
Bench-Scale Vacuum-Assisted
Dewatering Test
Pilot-Scale Vacuum-Assisted
Sludge Dewatering Bed
Testing
Pilot-Scale Plate and Frame
Filter Press Test
Basket Centrifugation Test
Solid Bowl Centrifugation
Test
Continuous Solid Bowl
Centrifuge Test
Pressure Filtration
Trommel Screen Dewatering
Simulation Test
Ranges of Solids Concentration Achieved by Various
Dewatering Methods for Each Investigation
(percent by weight)
1988 Design
Investigations
17.2-22.0
(4.6-10)
14.7-22.6
(4.6-10.7)
16.7-19.3
(14.2-22.6)
46.4-53.2
43-47
(17.5)
42.3-50.7
*
NP
NP
NP
NP
NP
NP
NP
NP
Pilot Study
NP
NP
(4.7-15.2)
14.4-26.2
NP
(5-20)
33.2-42.7
(16.9)
31.0-49.2
NP
(18-22)
37.1-42.5
(8-22)
22-38
(8.2-22)
22.6-30.0
NP
NP
NP
NP
NP
Offsite Laboratory
NP
NP
(26.5)
37-39
NP
(10-30)
23-30
NP
NP
NP
NP
(43.1)
46.7-50.4
(25.0-36.5)
40.0-47.8
(35.0)
25.2-51.2
(36.5)
45-46
(30.0)
32.6
Upper entry ( ) indicates the initial solids concentrations.
Lower entry indicates the final dewatered sludge solids concentrations.
All concentrations presented as percent total solids by weight.
NP = Test not performed.
*Test did not produce reportable results.
186
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measurements. The EPA Environmental Response Team (EPA/ERT) took
responsibility for constructing the vessels, which were designed
by CH2M HILL. The flux chambers were basically sealed 55-gallon
drums with agitation devices, headspace purging, and sampling
apparatus. The flux chamber design is shown in Figure 4.
Two basic designs for the flux chambers were used; one that agi-
tated dilute sludges, and one that raked thickened sludges.
Freshly dredged bayou material at various dilutions was used in
the testing. The intent was to simulate material handling opera-
tions that may be used during remedial activities. For example, a
20 percent solids mixture was tested in one of the agitated flux
chambers to simulate a dilute sludge mixture that may be pumped
into a dewatering feed tank. Flux measurements were recorded as
agitation continued with these tests.
The raked tests used higher concentrations of sludge and an inter-
mittent raking to simulate handling operations. For example, a
35 percent solids sample was tested to simulate a backhoe or clam-
shell bucket exposing a soil or sludge face during excavation.
This test started with five quick revolutions of the internal rake
mechanism. Following the initial raking, the test material was
left undisturbed while flux measurements were recorded.
Sampling and analysis of gas emissions from the flux chambers used
a variety of methods. An organic vapor analyzer (OVA) equipped
with a flame ionization detector (FID) was used to indicate
instantaneous nonspeciated organic flux magnitude. An OVA
equipped with a photoionization detector (PID) with a 10.2-eV lamp
was used as a second instantaneous measurement of nonspeciated
organic flux magnitude. Samples were also collected in Tedlar
bags, which were transported onsite to mobile support labs that
used Ratfisch FID nonspeciated total hydrocarbon analysis, and
GC--tandem mass spectrometry using the EPA's trace atmospheric gas
analyzer (TAGA) mobile laboratory for speciated quantification of
the emission stream. XAD-2 tubes were also employed as a sampling
media and analyzed using GC methods in onsite labs.
The experimental plan was initially developed for 16 runs. Field
modification of the plan resulted in the array of 23 runs shown in
Table 4.
187
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,Air Inlet
Lightnin XJ-43
Mixer with Variable Speed
0-200 SCFH
Rotameter
Plexiglass
Inspection
Port
OO
GO
Lightnin 10"
A-310 Agitator
Raked Air Test Chamber
Typical Agitated
Air Test Chamber
Figure 4
Air Test Chamber
Design
Bayou Bonfouca
Slidell, Louisiana
-------
Table 4
Experimental Plan for Air Emission Flux Testing
Sludge Composition
As dredgeda
Diluted (high solidsb)
Diluted (low solldsd)
Diluted (high solids)
Diluted (low solids)
Diluted (low solids)
Diluted (low solids)
Diluted (low solids)
Type of Test
Stirred
Agitated (low speedc)
Agitated (low speed)
Agitated (high speed6)
Agitated (high speed)
Agitated (high speed) , heated
Agitated (low speed), oxidizer added @ 4:1
ratio1
Agitated (high speed), oxidizer added @ 4:1
ratio
Comments
4 runs
4 runs
4 runs
4 runs
4 runs
1 run
1 run
1 run
?As dredged solids: 35 to 43 percent solids, 1.1 to 1.6 percent PHAs by weight.
°High solids: 14 to 37 percent solids and 0.68 to 1.01 percent PNAs by weight.
-Low speed: less than 185 rpm with 10-inch Lightnin A-310 impeller.
"Low solids: 8 to 19 percent solids and 0.43 to 0.66 percent PNAs by weight.
|High speed: greater than 185 rpm with 10-inch Lightnin A-310 impeller.
xMoIar ratio of KMn04 to naphthalene in sludge samples.
The drums were all purged with filtered air at a rate of 100 scfh,
which equates to approximately one headspace every 1.5 minutes.
The purged air stream from each drum during a run was usually
exhausted to a carbon canister. The purged stream was periodi-
cally diverted to sampling equipment through three-way valves. As
shown in Figure 4, the headspace was thoroughly mixed during the
agitated tests by means of a flat-blade fan mounted on the agita-
tor shaft. Sampling intervals for the air tests were generally
15 minutes apart, while the duration of each test ranged from
approximately 40 minutes to 2 hours.
Results
Pre-Pilot Study GC/MS characterizations performed with a bayou
sediment sample indicated that there were around 100 hydrocarbon
compounds in the headspace above the sediment sample. These
results also indicated that there were approximately 10 ppm of
nolimethane hydrocarbons in equilibrium with the sediment sample.
The analysis was able to identify compounds that made up approxi-
mately 25 percent of the nonmethane hydrocarbon value. Based on
this analysis and previous work, the following target compounds
were identified:
Naphthalene
Benzene
Toluene
Xylenes
n-Propylbenzene
1,2,4-Trimethylbenzene
l-Ethyl,2-methylbenzene
1-Propylbenzene
189
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Trace atmospheric gas analyzer (TAGA) analysis by the EPA/ERT
identified speciated compounds as either naphthalene, benzene,
toluene, C2-benzenes, or CS-benzenes (C2 and C3 indicating the
number of carbons attached to the benzene ring, in any configura-
tion) . The XAD-2 method was expected to speciate naphthalene and
other PNAs. Ratfisch and OVA analyses with FID detectors measured
total hydrocarbons (including methane), while the HNu PID detector
gave results of total hydrocarbons without methane.
These five measurement techniques were used on each air test to
analyze the exhaust purge air. Among four of the measurements
(Ratfisch, TAGA, HNu, and OVA), some data spread is apparent for
total hydrocarbon concentration. Data spread is attributed mainly
to the following factors:
• Relative response was different with each instrument.
• The methane fraction was detectable only in the Ratfisch
and OVA analyses. This resulted in higher total hydro-
carbon concentration readings from these instruments,
compared to the HNu or TAGA analyses.
• The TAGA data was target-specific to detect only
naphthalene, benzene, substituted benzenes, and
toluene. The TAGA results did not measure total hydro-
carbons. TAGA data are therefore less inclusive than
Ratfisch, OVA, and HNu measurements.
• Tedlar bags used to collect samples for Ratfisch and
TAGA analyses were found to have lower naphthalene con-
centrations as time passed. This loss of naphthalene
was assumed to be due to adsorption of naphthalene onto
the inner wall of the Tedlar bag. Concentrations of
benzene, toluene, and C2- and C3-benzenes were observed
to remain constant over the same time periods. This
loss of naphthalene was modeled as a first-order
reaction and time corrected before reporting.
• Ratfisch analyses are known to have been performed on
bags that had lost a fraction of the naphthalene
sampled. Therefore, these samples were expected to
exhibit results lower than real time OVA analyses on the
same streams.
As an example, Figure 5 shows total hydrocarbon concentration data
obtained from each of the emission measurement techniques during
air test No. 5. Differences in instrument response may have con-
tributed to differences in OVA versus Ratfisch and TAGA versus HNu
results.
Comparison of XAD-2 results with those of other analytical tech-
niques showed that XAD-2 results were inaccurate. Followup test-
ing was initiated after completion of the pilot study in order to
examine XAD-2 performance. This testing indicated that the
190
-------
200
E
Q.
Q.
(A
0)
GC
w
rt
100
0
20
RunTime (min)
Legend:
+ HNu
• OVA
51 Ratfisch
O TAGA
A XAD
191
Figure 5
Air Emissions Test
30% Solids, 270 rpm
Bayou Bonfouca
Slidell, Louisiana
-------
particular XAD-2 tubes used for sample collection in the pilot
study collected approximately one order of magnitude less of the
compounds in question than another brand of XAD-2 tube. Further
attempts were made to evaluate the performance of the pilot study
tubes and apply correction factors to existing data. The results
of this testing indicated that the performance of the pilot study
XAD-2 tubes was not consistent or reproducible and the data could
not be corrected.
Flux calculations were performed using the HNu and TAGA concentra-
tion results. The HNu total nonmethane hydrocarbon measurement
was broken into fractions based on TAGA speciated results. Since
the HNu data did not speciate organic compounds, these concentra-
tion readings included minor compounds that the TAGA did not
include. The sum of TAGA speciated organics generally comprised
50 to 65 percent of the HNu readings. It was necessary to assign
a composition to the HNu results to allow conversion from vol-
umetric concentration data to mass flux data. It was assumed that
the TAGA characterization was the best available, and that it pro-
vided an adequate distribution of molecular weights to character-
ize the HNu data. Table 5 shows the range of TAGA characteriza-
tion data that was applied to HNu magnitude data.
Table 5
Concentration Ranges From Air Emission Testing
Compound ( s )
Naphthalene
Benzene
Toluene
C2-Benzenes
C3-Benzenes
Relative Percent Concentration
Rangea
5.3
0.3
1.2
1.7
1.2
- 95
- 24
- 26
- 32
- 31
aThese percentages are reported as relative, based on TAGA
analytical results for the above target list of compounds/
compound groups. The TAGA analyses do not account for
numerous other minor air emission compounds that may be pre-
sent.
The agitated and raked air tests resulted in total hydrocarbon
concentrations generally around 80 to 100 ppm(v) by OVA, from
30 to 40 ppm(v) by HNu, and from 15 to 25 ppm(v) by TAGA analy-
sis. The resulting flux values, calculated as explained in the
previous paragraph, are presented in Table 6.
192
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Table 6
Agitated Test Air Contaminant Flux
Sediment Test
Dilute Sediment-High Agita-
tion
Dilute Sediment-Low Agitation
Nondilute Sediment -Raked
Dilute Sediment-High Agita-
tion-Heated
Flux Rate (//g/m2-s)
330 to 490
270 to 450
110 to 200
730 to 1,100 (60 to 100°F,
respectively)
The raked tests showed slightly lower fluxes than the agitated
tests. The addition of KMn04 to test chambers had no observable
correlation with reducing emissions. The heated test indicated
that emissions did increase with temperature. For the heated
test, naphthalene was observed as the main contaminant by TAGA
analysis, ranging from 75 to 90 mass percent of the total contami-
nant concentration.
AIR DISPERSION MODELING
During the 1988 design investigations, CH2M HILL modelled air
emissions expected to result from site remedial activities at
Bayou Bonfouca using the industrial source complex--short-term air
dispersion model (ISCST). Theoretical equations from the listed
TSDF and AP42 references were used to model both organic and par-
ticulate flux from specific anticipated site activities. For this
early effort, organic emissions were assumed to be 100 percent
naphthalene. During the pilot study of November/December 1989,
data were gathered on speciated mass flux, dewatering unit perfor-
mance, and material handling characteristics. During the ensuing
predesign, the remediation scenario and equipment layouts were
revised. This section outlines the subsequent air modelling
effort based on newly acquired contaminant flux and likely equip-
ment layouts, which were developed following the pilot study.
Dispersion Model
Communication was incorporated early in this effort to include the
EPA, LDEQ, and USCOE in the choice of models used, input format to
the model, and output formats. The ISCST model was chosen based
on past performance and applicability to the situation at Bayou
Bonfouca. Two types of ISCST runs were performed. Individual
sources were modelled using EPA-approved default atmospheric
data. The individual sources were then combined into source runs
that used New Orleans, Louisiana, meteorological data over a
1-year period.
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Dispersion Model Inputs
Conceptual designs for equipment layout were used to situate area
and point sources at the site. Pilot study flux values were used
for most dredged sludge and sludge processing operations. TSDF
flux estimates were used for modelling the wastewater treatment
system, landfill operations, canal, waste pile, and contaminated
soil excavations, while the AP42 model was used for particulate
generation estimates associated with incinerator ash handling and
dry soil excavation. These sources were all modelled as area
sources in TSDF. Point sources included internal combustion
engines and the incinerator stack.
To provide input to TSDF, remedial operations were broken into
simple operations occurring over 8-hour work days. For example:
• Emissions from the dredging source were modelled to fit
typical clamshell operations.
• A 1-cubic-yard bucket, with an associated surface area
of 24 square feet of sludge, was assumed to be present
above the water surface continuously.
It was assumed that approximately every 2 minutes during
the 8-hour work day the bucket would drop its 1 cubic
yard of material, modelled as 1-foot-diameter spheres
(with an associated surface area of 163 square feet)
into a nearby barge for 15 seconds.
• During the time the empty bucket rotated back to the
dredge, it would be dirty with contaminated sludge.
This period was already taken into account by the
assumption that a full bucket would be present over the
water continuously.
• The storage barge was assumed to typically contain about
900 square feet of exposed sludge at any one time.
• Corresponding fluxes were assigned to the bucket, the
drop, and the barge surfaces based on the pilot study
fluxes for dilute sediment under low and high agitation,
and nondilute sediment without agitation, respectively.
Other area sources were modelled similarly, with flux values from
TSDF and AP42 being used where Pilot Study data were not
available.
Pilot study flux values were compared to TSDF estimates for flux
from the characterized sediment. TSDF estimates were based on a
contaminant mixture of 50 percent naphthalene, 50 percent ethyl-
benzene, and various other variables including windspeed (10 mph),
solids content, temperature, and specific total contamination con-
centration. For operations with dredged sediments, TSDF generally
predicted flux in the range of 240 yug/m2-s, while pilot study data
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indicated fluxes for various operations ranging from 200 to
485 /^g/m2-s. This favorable comparison led to incorporating pilot
study flux estimates for all dredged sediment operations, while
TSDF was used to model flux from other remedial activities such as
the wastewater treatment plant, excavations, and landfill opera-
tions. TSDF lent flexibility in incorporating changing process
conditions such as contaminant concentration, moisture content,
and material density from operation to operation. Many operations
dealt with relatively dry materials or water streams to which
pilot study data were not applicable.
There were two types of ISCST dispersion runs performed; individ-
ual source, and combined sources. The individual source runs were
based on a screening data set of meteorological conditions. These
conditions included various combinations of windspeed and atmos-
pheric stability to provide estimates of the highest modellable
downwind concentrations caused by individual sources. These runs
used receptors positioned in one direction emanating out from the
source. The meteorological data were entered with constant wind
direction in the direction of the receptor line and the ISCST was
configured to provide the highest concentrations observed at each
receptor.
Combined source runs were based on two different remedial equip-
ment layouts. Phase 1 was modelled to reflect equipment in opera-
tion during the initial preparation of the site, including waste
pile excavation, the Eastern Drainage Channel and Western Creek
excavations, and site preparation. Phase 2 was modelled to
reflect continuous dredging of the bayou, dredged material han-
dling and dewatering, incineration, and landfill disposal of ash.
For each phase, modelling runs were performed.
Five years of meteorological data were obtained from New Orleans,
Louisiana, from 1982 through 1986. These data were used to plot
year by year and 5-year-period wind rose diagrams. These wind
rose diagrams were used to observe the distribution of windspeed
and direction. Based on the wind rose plots, 1982 was identified
as the year most representative of the overall 5-year distribution
and was used as ISCST input for all combined source runs.
The combined source runs used a receptor grid, which was centered
about a point on the bayou bulkhead, and ranged to 5,000 meters
(3.1 miles) in the north, southeast, and west directions. ISCST
was then configured to provide the highest concentrations at each
receptor experienced during any a 1-hour and 8-hour period in
1982, and the annual average concentrations experienced at each
receptor point.
Dispersion Model Outputs
Individual source modelling results indicated a concentration
gradient emanating from each modelled source in the downwind
direction under the atmospheric conditions that produce the high-
est receptor concentrations. These gradients were plotted as
195
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circles surrounding each source. The sources were then positioned
on a site map. Figure 6 shows the highest-modelled receptor con-
centrations surrounding each source during Phase 2 of the remedia-
tion.
For example purposes, the concentrations plotted were chosen based
on fractions of threshold limit values; TLV/42 and TLV/100 values
for a mixture of 50 percent naphthalene and 50 percent ethyl-
benzene. The inner ring around a source is TLV/42, while the
outer ring is TLV/100. These concentration values were plotted to
give a preliminary idea of the areas possibly affected. They are
not the risk-based action limits that were eventually developed
for site remediation. These individual sources do not take into
account compounded concentrations from combined sources. The
dredge and barge locations shown in the southern bayou were
positioned to indicate receptor concentrations when downstream
dredging was in progress. Similar plots were developed for
particulates as total suspended particulate (TSP) and respirable
particulate (PM-10) during both Phase 1 and Phase 2 of remedia-
tion. Performing the runs sequentially, with a screening set of
meteorological data, indicated the order of magnitude of receptor
concentrations that were anticipated.
Combined source modelling was performed next; these results were
presented in isopleths positioned on a site map. Figure 7 shows
the isopleths resulting from the highest 1-hour receptor concen-
trations. One should note that these isopleths show the lateral
extent of the highest concentration during any 1-hour period based
on 1982 meteorological data. During an actual 1-hour period, wind
direction would direct individual plumes away from the sources,
not in all directions as shown. The compounded effect of multiple
sources is illustrated on these plots.
This plot shows the modelling results from the 1-hour maximum con-
centrations of nonmethane organics during Phase 2. Similar plots
were constructed for 8-hour maximum organic concentrations and
annual average concentrations. Total suspended particulate (TSP)
isopleth plots were also developed for these three scenarios. All
six scenarios were then repeated for Phase 1 remedial activities.
The models were all intentionally constructed without emission
controls (covers, foams, water sprays, etc.) on any of the
sources. The final results were felt to be representative esti-
mates of worst-case emissions that could be encountered during
remediation. Knowledge of the magnitude of these concentrations
also enabled air monitoring equipment to be specified. In addi-
tion, using the 1982 meteorological data and the anticipated
equipment layout for the remediation allowed site-specific conver-
sions from 1 hour to 8 hours and allowed annual average concentra-
tions to be calculated. These factors are presented below:
• To convert 1-hour (maximum) receptor concentrations to
8-hour (maximum) concentrations, multiply by 0.29
.196
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il
WWTS
BARGE
OFFLOAD
600
197
Figure 6
Individual Source
Dispersion Modeling
Phase 2, Organics
Bayou Bonfouca
Slidell, Louisiana
-------
758 ug/m3
(TLV/100J
1805 ug/m3
(TLV/42)
379 ug/m3
(TLV/200)
790 mg/m3
(TLV/400)
198
FEET
Figure 7
Combined Source
Dispersion Modeling
Phase 2, Organics
Bayou Bonfouca
Slidell, Louisiana
-------
• To convert 1-hour (maximum) receptor concentrations to
annual (average) concentrations, multiply by 0.012
This modelling effort also provided one workable method for esti-
mating receptor concentrations, which could be used by remediation
contractors to model actual remediation processes, and for
optimizing necessary control measures based on EPA-developed risk-
based action criteria.
CONCLUSIONS
The Bayou Bonfouca design investigations were planned as an inte-
gral part of the design and provided valuable input to help guide
the development of design basis scenarios. The design basis
scenarios were used for developing remedial action cost estimates
and schedules, for structuring primarily performance-based design
specifications, and for assessing probable remedial scope variance
ranges. Supplemental design investigations were defined and per-
formed, as directed by EPA, to address most areas of substantial
scope uncertainty.
Other specific conclusions resulting from consideration of the
Bayou Bonfouca Source Control OU design investigation results and
completed remedial design include:
• The cost of the Bayou Bonfouca Source Control OU design
investigations was approximately two percent of the cur-
rent estimated cost for remediation. The refined scope
definition and design benefits gained from the design
investigation data provide strong support for this level
of expenditure for this site.
• The field air contaminant flux testing functioned very
well to define air emission flux ranges for various pro-
posed remedial operations.
• The source-specific and combined source ISC computer
dispersion modelling output was presented in the format
of contaminant-specific concentration isopleths over-
layed on a base site map with assumed locations for
remedial operations. This format provided EPA with a
powerful and convenient tool for assessing the impacts
of proposed air contaminant action limits.
• The site remedial action will provide an excellent
opportunity to collect air monitoring data to compare
with the flux estimates and dispersion modelling results
from the Bayou Bonfouca design investigation.
• The dewatering studies have identified possible process
options for dredged sediment dewatering. Various dredg-
ing techniques may be used in the remediation and each
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will produce sediment with a different range of solids concen-
trations. The costs associated with dredging, dewatering, and
incinerator operation must all be weighed together in designing
and implementing an optimum remedial process.
In summary, the design investigation efforts and subsequent air
modelling efforts led to valuable design information for the reme-
diation of Bayou Bonfouca. The data has been valuable to CH2M
HILL, the EPA, USCOE, remediation contractors, and others in
designing remedial activities, estimating air emissions, evaluat-
ing air contamination action limits, developing cost estimates,
and developing bids that will eventually lead to the successful
site remediation.
DISCLAIMER
This paper represents the opinions of the authors and is based on
limited site investigation data. This paper does not represent a
comprehensive summary or interpretation of existing site remedia-
tion data.
REFERENCES
CH2M HILL. 1990. Volume I: Design Investigation Report, Bayou
Bonfouca Source Control Operable Unit. Prepared for U.S. Environ-
mental Protection Agency, Hazardous Site Control Division,
July 16.
CH2M HILL. 1990. Pilot Study Report, Bayou Bonfouca Source Con-
trol Operable Unit. Prepared for U.S. Environmental Protection
Agency, Hazardous Site Control Division, July 16.
CH2M HILL. 1990. Air Emissions and Dispersion Modelling Design
Analysis Report, Remedial Design Source Control Operable Unit,
Bayou Bonfouca Site. Prepared for U.S. Environmental Protection
Agency, May 30.
CH2M HILL. 1988. Technical Memorandum: Summary of Design Inves-
tigations, Bayou Bonfouca Remedial Design. Prepared for U.S.
Environmental Protection Agency, December 9.
U.S. Army Corps of Engineers. 1990. Part 2, Bayou Bonfouca
Source Control Operable Unit, November.
U.S. Environmental Protection Agency, Office of Air Quality Plan-
ning and Standards. 1989. Review Draft, Hazardous Waste Treat-
ment, Storage, and Disposal Facilities (TSDF)—Air Emission
Models, November.
U.S. Environmental Protection Agency, Office of Air Quality Plan-
ning and Standards. 1985. Compilation of Air Pollutant Emission
200
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Factors, Volume I: Stationary Point and Area Sources, AP-42,
Fourth Edition, September.
U.S. Environmental Protection Agency, Office of Air and Radiation,
Office of Mobile Sources. 1985. Compilation of Air Pollutant
Emission Factors, Volume II: Mobile Sources, AP-42, Fourth Edi-
tion, September.
Author(s) and Address(es)
Kevin Klink, P.E.
CH2M HILL
2300 Walnut Boulevard
Corvallis, Oregon 97339
(503) 752-427L
Jeffrey S. Obert, P.E.
CH2M HILL
2300 Walnut Boulevard
Corvallis, Oregon 97339
(503) 752-4271
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Value Engineering Studies
of the Helen Kramer Landfill Superfund Site
Amy M. Monti and Vern Singh
URS Consultants, Inc.
282 Delaware Ave.
Buffalo, NY 14202
(716) 856-5636
INTRODUCTION
Construction of the selected remedial alternative at the Helen Kramer Landfill Superfund Site in
Mantua, New Jersey is currently underway. URS Consultants, Inc., as prime contractor to the US
Army Corps of Engineers, performed the detailed design of remedial alternatives at the site and is
providing engineering services during construction. In response to several outstanding technical issues
that arose during the detailed design, URS proposed and carried out a series of Value Engineering
Studies. These studies identified a potential savings of $3 million by optimizing the design of
remedial alternatives which had been proposed in previous designs. The proposed remedial plan, as
stated in the USEPA Record of Decision (ROD) of 1985, consisted of a combination of slurry walls,
subsurface drains, and a pretreatment facility. The reports which lead up to the design of the
remedial action selected for use at the Helen Kramer Landfill site are as follows:
RI/FS 1985 R.E. Wright
ROD September 1985 EPA
Design Analysis Report (DAR) 35% January 1987 URS
Value Engineering Studies December 1987 URS
DAR 65% March 1988 URS
DAR 95% June 1988 URS
DAR 100% September 1988 URS
Final DAR & Final Specifications May 1989 URS
The Value Engineering or VE studies performed by URS Consultants are the subject of this paper;
The Helen Kramer site was the first Superfund remedial design to use this approach. Upon
Completion, the results indicated a substantial reduction in cost of the remedial action for the client,
the Corps of Engineers.
BACKGROUND
The Helen Kramer Landfill site was ranked fourth on the USEPA's National Priorities List. It
consists of a 66-acre refuse area and an 11 -acre stressed vegetation area adjacent to the perennial
stream Edwards Run, which is a tributary to the Delaware River. The site was initially a sand and
gravel quarry before becoming a landfill in 1963. Between 1963 and 1981 the landfill received
municipal, chemical, and hospital wastes. The wastes were dumped indiscriminately and resulted in
contamination of surface water and shallow groundwater. The site layout is shown on Figure 1.
The remedial design outlined by the USEPA in their Record of Decision called for:
o Groundwater/Leachate collection and treatment,
o Clay cap,
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o Upgradient slurry wall,
o Active gas collection and treatment,
o Dewater, excavate, and fill lagoons,
o Security fence, and
o Monitoring.
Upon reviewing the remedial design, URS identified a number of features which offered the potential
for value engineering. The features selected were high-cost items whose implementation could, from
a cost-effective standpoint, justify refinement and/or conceptual modification from the remedial
measures suggested in the RI/FS. These modifications would still be in adhering to the ROD. The
features which most availed themselves to value engineering were those pertaining to groundwater
withdrawal and treatment. The VE studies agreed upon were as follows:
TASK 1VE - Develop Site Hydrogeologic Model
TASK 2VE - Establish Current Groundwater Regime
TASK 3VE - Water Balance Analysis
TASK 4VE - Assess Groundwater Table Rise
TASK 5VE - Cost-Benefit Analysis of Upgradient Subsurface Drain
TASK 6VE - Study of Slurry Wall Along Edwards Run
TASK 7VE - Assess Impact of the Higher Permeability of the Marshall town
TASK 8VE - Downsizing of Treatment Facility
TASK 9VE - Develop Final Recommendations
DISCUSSION
The discussion of results is provided on a task-by-task basis.
TASK 1VE — Develop Site Hydrogeologic Model
The first task was dedicated to the development of a complete and computer useable
geologic/hydrogeologic model of the area. This model utilized data gathered during the RI/FS and
design investigations, published information for the area, and a current aerial photo of the site and
vicinity. The model depicted the relationship between the three hydrogeologic units of interest at the
site which are the shallow Mt. Laurel/Wenonah aquifer, the Marshalltown formation, and the
Englishtown aquifer. In cross-section, these units appear as shown on Figure 2. Wastes were
primarily deposited in the Mt. Laurel to the west of Edwards Run. Initial hydrologic properties of
each of the units were determined by geometric averages of reported values (e.g. hydraulic
conductivity). Initial piezometric heads were set to those felt to be representative of each of the three
units as based on the USGS topographic maps for areas beyond the landfill site, and the aerial photo.
Of particular note was the constant observance in piezometers and monitoring wells of upward flow
from the Englishtown through the Marshalltown in the vicinity of Edwards Run. For this reason,
Edwards Run was considered to be the eastern extent of the study area. The areal extent of the
regional model's shown on Figure 3. A discretization of the regional model is shown on Figure 4.
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TASK 2VE — Establish Current Groundwater Regime
In establishing the current groundwater regime for the Helen Kramer Landfill site, a two-phased
approach was taken. First, a regional groundwater flow model was developed and calibrated to
existing conditions using two calibration parameters. The first calibration parameter consisted of
water levels in the onsite monitoring wells and piezometers, and calculated water levels in the surface
features identified on the aerial photo and USGS topo maps. The second calibration parameter was
discharge into Edwards Run. The latter was calculated with the aid of nearby gauged streams in the
Delaware River Basin and approximated drainage areas.
In developing the regional model, offsite withdrawal wells (i.e. residential wells) were included in
addition to important hydrologic features such as streams and ponds whose extents were taken from
the aerial photo. The areal extent of the model was chosen so that the effect of boundary conditions
would be minimal on groundwater flow near the landfill. The dimensions of the model extended
8,000 feet from east to west and 6,000 feet from north the south. The western boundary of the
regional model lies approximately 5,000 feet beyond the western landfill edge. The eastern boundary
of the model was Edwards Run, which is considered to act as a hydraulic barrier and a discharge
point for both the Mt. Laurel and Marshalltown units given the aertisian conditions encountered in
this area. All units were modeled to be laterally continuous across the region. The orientation of the
model was chosen to parallel the bedding planes of the units in order to coincide with their general
flow patterns.
The computer model used was MODFLOW, a Modular Three-Dimensional Finite-Difference
Groundwater Flow Model by Michael McDonald and Arlen Harbaugh of the USGS (McDonald and
Harbaugh, 1984). Version 1.0 was used for the Helen Kramer site VE Studies. Version 2.0 is
currently being distributed which includes an automatic calibrator and post-processing interfacing
with Auto-CADD to plot hydraulic heads and drawdowns. Version 2.0 of MODFLOW can handle
60,000 finite-difference cells, a substantial improvement over version 1.0, which was limited to less
than 2,000. With MODFLOW, groundwater flow within the aquifer is simulated using a block-
centered finite-difference approach. Layers can be simulated as confined, unconfined, or a
combination of both. Flow from external stresses such as withdrawal wells, recharge, subsurface
drains, and streambeds can be simulated. The model may be used for either 2D or 3D applications,
and is capable of both steady-state or transient flow conditions.
In order to calibrate the regional groundwater flow model, steady-state conditions were simulated.
Recharge was calculated within VE Study 3 (Task 3VE) and considered to be constant over the extent
of the modeled area. Horizontal and vertical hydraulic conductivities were the parameters varied
during the calibration process within the measured ranges as these values were the most variable. The
hydraulic conductivity values which provided the "best fit" in getting the modeled water levels to
match the observed water levels are shown in Table 1 along with other hydrogeologic parameters from
the calibrated regional model.
Once the current groundwater regime was determined by the calibrated regional-scale model, the
results were input into the local-scale groundwater flow model, discussed under Task 4VE, which was
used to simulate site-specific perturbations of the groundwater flow regime in the immediate vicinity
of the landfill (i.e., implementation of slurry walls, groundwater withdrawal, etc.). It was this local-
scale model which provided the details necessary for the recommendations reached in these Value
Engineering Studies.
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TASK 3VE - Water Balance Analysis
Infiltration to the landfill is anticipated to contribute a significant amount of water to the
groundwater regime. Using USGS topographic maps, historical meteorological data (from the
National Oceanic and Atmospheric Administration for Philadelphia, PA, 1985), and runoff
coefficients calculated using a weighted average for the watershed, infiltration rates were determined
for the landfill and vicinity. Based on a 30-year period of record, precipitation in the vicinity of the
Helen Kramer Landfill site is 41.42 inches per year. The Water Balance Method (Thornthwaite and
Mather, 1955 and Fenn et al., 1975) was employed to calculate what percentage of that precipitation
percolates through the ground surface to the water table. Results showed that approximately 25% of
the precipitation percolated, 57% evapotranspired, and 18% became surface runoff. Twenty-five
percent of 41.42 inches, or 10.5 inches/year was used as the steady-state infiltration rate under natural
conditions at the site.
Once the landfill surface is capped, infiltration will be significantly reduced. In order to quantify
this reduction, the Hydrologic Evaluation of Landfill Performance (HELP) computer model was used
(Schroeder, et al., 1983). The proposed cap design consisted of a gas venting layer, two feet of low
permeability material, drainage layer, frost protection, and topsoil. Results of the HELP model
showed that infiltration through the clay cap would be reduced to approximately 1.6 inches/year, or
4 percent of average annual precipitation. This was the rate used over the extent of the landfill for
capped conditions in the local-scale simulations.
TASKS 4VE and 6VE — Assess Groundwater Table Rise
— Study of Slurry Wall Along Edwards Run
Hydrogeologic parameters determined in the regional-scale model were used as input to the local-
scale model. In particular, the regional-scale model provided steady-state water levels for all three
layers where no monitoring wells had been located.
Three-Dimensional Local-Scale Model
The three-dimensional local-scale groundwater model was situated within the confines of the regional
model as shown on Figure 5. The areal extent of the model was chosen such that one could examine
the maximum potential groundwater table rise outside the northern, western, and southern slurry
walls, and still provide the discretization necessary v/ithin the landfill. The eastern boundary was
chosen to coincide with an idealized Edwards Run located 50 feet east of the planned leachate
collection drain. For the purposes of comparative studies, this assumption was considered reasonable
and was useful in keeping the model size and simulation time of the program within reasonable limits.
This assumption was refined once the conceptualization of the remedial design was selected. At that
point two-dimensional simulations were performed which more accurately represented actual
conditions along the eastern edge of the landfill and vicinity. Two-dimensional simulations are
discussed more fully at the end of this task.
The same three hydrogeologic units were considered in the local-scale model as in the regional model.
However, the Marshalltown, which is considered to be a confining unit, was divided into two layers
in order to simulate a variable depth of slurry wall key. That is, the Marshalltown which generally
varies in thickness between 25 and 50 feet, was divided into a 5-foot layer and a 20 to 45-foot layer
when simulating a 5-foot key; and into a 10-foot layer and a 15 to 40-foot layer when simulating a
10-foot key; etc.
Finite-difference cell widths varied from 3 feet, to represent the actual thickness of slurry wall and
subsurface drains, to 900 feet in the central area of the landfill where a fine discretization was not
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considered to be critical. The grid was developed to incorporate possible features such as slurry walls
on all four sides and both upgradient and downgradient drains (collection or diversion).
The sixteen, three-dimensional transient cases shown in Table 2 were modeled with the calibrated
regional-scale model conditions being equivalent to time zero. Each model was simulated for a period
of 30 years. Variations among the first eight cases amounted to changing the depth of slurry wall key
into the Marshalltown, and the elevation from which groundwater would be withdrawn from the
downgradient drain. Accordingly, raising the downgradient drain height constituted adding a
downgradient slurry wall which was not included in the ROD remedial design. The elevation of the
drain was selected to be at elevation 20 feet which minimized the leachate withdrawal rate, but still
maintained a positive inflow of groundwater from the Marshalltown (bottom) into the landfill. This
ensured that no groundwater from the landfill would leak into the Marshalltown, bypass the collection
drain and flow to Edwards Run. Results of the sixteen simulations are presented in Table 3.
It was shown that by raising the collection drain elevation from the proposed 6-inches below Edwards
Run to an elevation of 20 feet, substantially less leachate would be withdrawn (28 vs 44 gpm). This
would reduce both the size of the onsite treatment facility, and thus the capital costs as well as the
annual operation and maintenance costs. The change in drain elevation, however, necessitates the
addition of a downgradient slurry wall. The cost-benefit analysis of this addition was the subject of
Task 8VE presented later.
It was further shown that the depth of the slurry wall key into the Marshalltown had a negligible
effect on reducing the leachate withdrawal rate. This conclusion was of great significance in reducing
the cost of the slurry wall design and construction.
Additional simulations were also performed under this task varying the hydraulic conductivity values
of the units, and simulating 100-yr flood events for Edwards Run as detailed in Table 2. Simulation
6VE11 is dubbed the "bathtub". A "bathtub" was simulated by fully enclosing the site with a slurry
wall, adding the selected cap, but not allowing for withdrawal of leachate from the landfill. This
would be the case if for example, construction of these features was complete, but the treatment
facility was not online. Results shown on Table 4 show that by two months, water within the landfill
will rise to the top of the slurry wall along the eastern edge and exert pressure on the cap, possibly
seeping through. This is a significant factor in establishing the construction schedule. It shows that
there was little delay time between completion of slurry wall construction and the need for leachate
withdrawal.
Simulations 4VE12 and 4VE13 simulated 100-year flood events in Edwards Run for cases of the
downgradient slurry wall present, and downgradient slurry wall absent, respectively. While the
duration of the flood event simulated was unrealistic, results showed that as expected, flows in the
leachate collection drain would be significantly increased without the presence of the downgradient
slurry wall. Where no slurry wall was present, flows increased from 45 gpm to 104 gpm over an 11
day period (the minimum time step printed); whereas when a slurry wall was in place, flows only
increased from 28 gpm to 45 gpm.
Twb-Dimensional Local-Scale Models
In order to more accurately define the irregular shape of the landfill near Edwards Run, a series of
two-dimensional models was developed. The depth of slurry wall key was assumed to be 5 feet for
all 2D simulations; all hydraulic conductivity values were the same as in the 3D local-scale model.
The parameters varied were the distances and water levels between Edwards Run and the
downgradient slurry wall and leachate collection drain. Figure 6 shows the location of the 2D sections
with respect to the 3D grid. Figure 7 presents a discretization across a typical 2D section which shows
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the finer grid along the eastern edge of the landfill to Edwards Run. Each of the 2D sections was
analyzed separately and the results combined to determine total anticipated withdrawal rates.
The width of each of the 2D sections was kept equal to the width of the corresponding rows in the
3D model. Initial heads were derived from actual conditions, however, potentiometric levels within
the Mt. Laurel were not permitted to rise above the ground surface during non-flood conditions. And
finally, the Marshalltown was divided into 4 and 8 layers, (instead of just 2) for Sections C and D,
respectively, for the purposes of developing a flow net.
Each cross-section was analyzed for two conditions, resulting in a total of twelve cases identified in
Table 5. Cases 1 through 6 represent the lack of slurry wall on the downgradient side of the landfill,
while Cases 7 through 12 represent its presence and the accompanying increase in collection drain
elevation. The transient flow analyses were performed for a period of 30 years. Results are presented
in Table 6.
Table 6 shows that steady-state flows to the leachate collection drain are 58.7 gpm (60 gpm) for the
current design under normal Edwards Run flow conditions. These flows are reduced to 35.7 gpm (40
gpm) when a slurry wall in introduced between the drain and Edwards Run. Over a period of 30
years and using 60 gpm and 40 gpm rates in the analysis, this results in a total reduction of 315
million gallons of collected leachate.
TASK 5VE — Cost-Benefit Analysis of Upgradient Subsurface Drain
The previous analysis established that, due to the construction of slurry walls, the groundwater level
to the north, west, and south of the landfill could rise by 2 to 3 feet over a period of 30 years. This
increase in groundwater levels would cause an increase in the hydraulic gradient across the slurry wall
and flow into the landfill either through the slurry wall, or the Marshalltown beneath it. It was
therefore surmised that a subsurface drain constructed at the current groundwater level outside of the
upgradient slurry wall could prevent such a condition. The cost-effectiveness of the upgradient drain
was reviewed under Task 5VE by estimating the potential costs associated with the construction of
the drain, and the potential savings in treatment plant capital and O&M costs resulting from reduced
leachate flows attributable to this drain.
A three-foot wide French drain approximately 5,500 feet in length was assumed at a distance of 20
feet from the upgradient slurry wall. This placed the drain very close to the point where groundwater
levels from the computer model were at a maximum. Three different depths were considered to
achieve the following:
(1) maintenance of the existing water level (elev. 63 ft.);
(2) significant reduction in the water level (elev. 43 ft.); and
(3) moderate reduction in water level (elev. 53 ft.).
Case 4VE6 was used as the base case for comparison purposes which consisted of a cap, a fully-
enclosing slurry wall with a key depth of 5 feet, and leachate collection drain at elevation 20 feet.
The resulting flow rates are shown in Table 7. The costs estimated for construction of the upgradient
drains, and the savings associated with leachate treatment are shown in Table 8. These estimates show
that upgradient drain construction costs far outweigh any potential savings in reducing the cost of
leachate treatment. This drain was therefore not recommended as part of the remediation.
207
-------
TASK 7VE — Assess Impact of Higher Permeability of the Marshalltown
The Marshalltown, into which the slurry wall will be keyed, has been considered to be an aquitard.
Large variations in permea- bility were measured in the laboratory varying from 3E"7 cm/sec to 2E~4
cm/sec. While still less pervious than the overlying Mt. Laurel and the underlying Englishtown
formations, the Marshalltown's effectiveness in reducing flow into the landfill is expected to be less
than what it would have ordinarily been if it were a true aquitard. The objective of this task was to
make an assessment of the variations in leachate quantities that would be withdrawn given different
permeabilities of the Marshalltown.
Again, Case 4VE6 was used as the base case. In this simulation, the horizontal conductivity value
assigned to the Marshalltown was 0.254 ft/day (9E~5 cm/sec), the vertical conductivity assigned was
0.0254 ft/day (9E~6 cm/sec). Both of these values were the result of the calibrated regional-scale
groundwater flow model. Variations of hydraulic conductivities were simulated as shown below:
7VE1 - Base case; slurry wall key at 5 feet
Marshalltown
Kh = 0.254 ft/day
Kv = 0.0254 ft/day
7VE2 - Increase values
Kh = 2.54 ft/day
Kv = 0.254 ft/day
7VE3 - Decrease values
Kh = 0.0254 ft/day
Kv = 0.00254 ft/day
7VE4 - Base case; slurry wall key at 20 feet
7VE5 - Use 7VE2; slurry wall key at 20 feet
7VE6 - Use 7VE3; slurry wall key at 20 feet.
Results are presented in Table 9. By increasing the hydraulic conductivity values by an order of
magnitude, withdrawal rates almost doubled. That is, flow increased from 28 gpm to approximately
51 gpm for a 5-foot key depth; and from 29 gpm to 54 gpm for a 20-foot key depth. By decreasing
the hydraulic conductivity of the Marshalltown, withdrawal rates decreased from 28 gpm to
approximately 15 gpm for both depths of slurry walls. Both the increase and decrease in rates was
attributable to upward flow to the Mt. Laurel through the Marshalltown on the eastern edge of the
landfill. While these results indicate that withdrawal rates are sensitive to the hydraulic conductivity
of the Marshalltown, a tenfold increase over the entire extent of the unit was felt to be unrealistic.
Therefore, the pretreatment plant design capacity was not modified. If necessary, additional daily
shifts could be added to reliably handle the flows that might arise if actual permeabilities were much
greater than those previously measured.
TASK 8VE - Downsizing of Treatment Facility
During the preliminary design phase, groundwater collection rates were developed and a 300 gpm
pretreatment facility was specified. The size of this pretreatment facility was dictated by the
generally larger leachate volumes collected during the first two years of its operation. As the flow
rates decrease with time, the required plant capacity also decreases. It was therefore prudent to study
208
-------
ways to develop a more balanced design concept, and realize a cost savings resulting from such a
design. The objectives of this task were: to develop cost estimates for various size (capacity)
pretreatment facilities; to make an assessment of the technical viability of reducing the pretreatment
plant size; to assess the placement of a slurry wall along Edwards Run; and to carry out a cost-benefit
analysis for the slurry wall and the downsized facility that results.
In addition to the pretreatment facility, two additional designs were evaluated based on the
withdrawal rates developed using results from the two-dimensional groundwater flow simulations in
Task 4VE. The first design included a cap, upgradient, north and south slurry walls, and a leachate
collection drain located on the downgradient edge of the landfill. The collection drain was located
at a depth approximately 6 inches below the elevation of Edwards Run in order to maintain flow into
the drain. The withdrawal rate associated with this first design was 58.7 gpm (approx. 60 gpm). The
second design consisted of a fully-enclosing slurry wall (addition of a slurry wall along the
downgradient side of the landfill) which allowed the collection drain to be located at an elevation of
20 feet. The withdrawal rate associated with this second design was 35.7 gpm (approx. 40 gpm).
Table 10 presents the flow rates for the three designs over a period of 30 years and the anticipated
number of shifts per week required for operation of each facility. The original flow rates of 60 gpm
and 40 gpm have been increased to process plant design flow rates as detailed in the table. The capital
costs associated with the pretreatment plant construction were developed under this task. Preliminary
design calculations had previously not included O&M costs for the pretreatment facility, therefore
these were developed as well to allow comparison of the life-cycle cost of the alternatives. The
leachate stream composition was assumed to be the same for all leachate flow rates and the same as
determined in the Treatability Study performed for this site. An onstream factor was included to
account for process down-time attributable to scheduled maintenance, process upsets, and potential
equipment failure. Major components of the pretreatment process train are shown on Figure 8. All
equipment was included with each of the three designs - that is, no equipment was left out of the
reduced flow rate designs. Equipment sizes were reduced in proportion to the flow rates.
Estimation of the capital costs of each system was based on an in-depth assessment of the system
components required. For each design, the system components were identified and sized on the basis
of the character and volume of leachate to be treated. Table 11 presents the cost-benefit analysis of
reducing the size of the pretreatment facility. Capital costs associated with the 180 and 120 gpm
facilities, while similar, are substantially less than those for the 300 gpm facility. The 120 gpm
facility has a slightly higher capital cost than the 180 gpm facility due to the construction of the
downgradient slurry wall. In comparing O&M costs, the 120 gpm facility is substantially less costly.
Overall then, the 120 gpm facility is anticipated to realize a $2.5 to $3 million savings in project cost
(in 1988 dollars) over the 300 gpm design.
TASK 9VE — Develop Final Recommendations
The recommendations detailed in the Conclusions section of this paper were presented to the client
based on the results of the Value Engineering studies. These recommendations provided for a savings
in total project cost estimated to be over $3 million in 1988 dollars.
CONCLUSIONS
Upgradient Subsurface Drain
Analysis of results from Task 5VE established that remedial action implementation would cause only
a small rise in the current groundwater level to the west, north, and south of the site. Costs analyses
showed that the construction cost of a subsurface drain upgradient of the slurry wall would be greater
209
-------
in comparison to the potential savings in reduced leachate flows to the downgradient drain. On the
basis of these findings, it was therefore recommended that no upgradient drain be constructed.
Depth of Slurry Wall Key into the Marshalltown
Analyses performed in Tasks 4VE and 7VE showed that an increase in the depth of slurry wall key
from 5 feet to greater depths has an insignificant impact upon flow patterns and withdrawal rates
from the leachate collection drain. A 5-foot key, is sufficient to create a flow pattern which causes
upward flow from the underlying Englishtown aquifer through the Marshalltown into the Mt. Laurel
thus preventing downward migration of leachate from the landfill into the underlying units. This
reduced the cost of the slurry wall in both the detailed design and during construction.
Slurry Wall Along Edwards Run and Downsizing of the Pretreatment Facility
Results of Task 4VE showed a significant reduction in withdrawal rates from the leachate collection
drain with the addition of a downgradient slurry wall along Edwards Run, and raising the elevation
in the drain to 20 feet. Based on results of the two-dimensional simulations, the flow rates to the
drain were reduced from approximately 60 gpm to 40 gpm. The offsetting cost for constructing the
downgradient slurry wall was estimated at close to over $1 million. The reduction in flow rates
corresponds to a potential for downsizing the pretreatment facility for a total overall savings of $2.5 -
$3 million (in 1988 dollars) in both capital and O&M costs. In addition, enclosing the landfill with
a slurry wall provides for full containment and offers greater overall reliability in leachate collection,
as well as provides a mitigative effect on the site from flooding of Edwards Run.
REFERENCES
NOAA, National Oceanographic and Atmospheric Administration, Climatological Summary for
Philadelphia, PA, 1985.
R.E. Wright Associates, Inc., Draft Remedial Investigation Report and Feasibility Study of
Alternatives, Helen Kramer Landfill Site, Mantua Township, Gloucester County, NJ, September
1986.
Thornthwaite, C.W., and J.R. Mather, "The Water Balance", Drexel Institute of Technology
Centerton, NJ, 1955.
Fenn, D.G., K.J. Hanley, and T. DeGeare, "Use of the Water Balance Method for Predicting Leachate
Generation from Solid Waste Disposal Sites", EPA/530/SW-168, 1975.
Schroeder, P.R., J.M. Morgan, T.M. Walski, and A.C. Gibson, The Hydrologic Evaluation of Landfill
Performance (HELP) Model, Volume I, User's Guide for Version I, EPA/530-SW-84-009, 1983.
McDonald, M.G., and A.U. Harbaugh, A Modular Three-Dimensional Finite-Difference Ground-
Water Flow Model, prepared by the U.S. Dept. of the Interior, USGS, Reston, VA, 1984.
210
-------
LEACHATE
COLLECTION
PONDS
SOOOY MILL
IMPOUNOMENT
LEGEND
4QO 0 «OQ
^^^^ su * ' SCALE IN FEET
*~ • 3*»>"'v 4flE*3 REFERENCE: RI/FS FIGURE 5-2 (R.E. WRIGHT, 1986)
URS
CONSULTANTS, INC.
SITE LAYOUT
FIGURE 1
211
-------
A-3694
to
h-»•
ro
I OO
HU
60
> 40
CD
UJ
UJ
U_
z
0-20
UJ -4O
-60
-8O
Marthalllown Formation
4OO
800
I2OO I6OO 2OOO
10 X VERTICAL EXAGGERATION
2400
28OO
3200
3600
-20 O
Cnglishtown Formation
•.•A..-.v,-,-f.-.v..v.-.v.v.v.-.-iv.v.-.v.il -BO
4O
20
O
CD
400O
REFERENCE: RI/FS FIGURE 4-3 ( R.E. WRIGHT. 1986)
URS
CONSULTANTS, INC.
CROSS-SECTION OF HYDROGEOLOGIC UNITS
FIGURE 2
-------
COLUMNS"
MAP TAKEN FROM USGS WOODBURY
QUAD. NEW JERSEY - PENN. 7.5
MINUTE SERIES! DATED 1967
-RESIDENTIAL WELLS
AREAL EXTENT OF REGIONAL
GROUNDWATER MODEL
FIGURE 3
213
-------
M_
ROWS
I 234567 8 9 10 II \Z 13 14 15 16 17 18 19 20
LAYER I
LEGEND
INACTIVE CELL
HELO-HEAD CELL
URS
CONSULTANTS, INC.
DISCRETIZATION OF REGIONAL GROUNDWATER SYSTEM
FIGURE 4
-------
LOCAL MODEL BOUNDARY
\
MAP TAKEN FROM USGS WOOOBURY
QUAD. NEW JERSEY-PENN. 7.5
MINUTE SERIES! DATED 1967
jeU**'
URS
CONSULTANTS, INC.
LOCATION OF LOCAL
GROUNDWATER MODEL
215
-------
'""•III, •'>''' "^V^ ^^
iiiiiiiiiiiiin LOCAL MODEL GROUNDWATER CELL BOUNDARIES
LOCATION OF 2D SECTIONS (A THROUGH F)
SCALE
0 200' 400'
URS
CONSULTANTS, INC.
LOCATION OF 2D SECTIONS
FIGURE 6
216
-------
ro
6
£ «u
s
EXISTING G.W.T
CMSTANCC IN fECT
URS
INC.
DISCRETIZATION OF TYPICAL 2D CROSS - SECTION
FIGURE 7
-------
CO
URS
CONSULTANTS. INC.
PRETREATMENT FACILITY FLOW DIAGRAM
FIGURE 8
-------
TABLE 1
DATA FOR LOCAL SCALE GROUNDWATER FLOW MODEL
Parameter
Mt. Laurel Marshalltown Englishtown
HYDROGEOLOGY
Horizontal hydraulic
conductivity (cm/sec)
Vertical hydraulic
conductivity (cm/sec)
Porosity
Fluid density (kg/m3)
Unit saturated thickness
Edwards Run water levels
adjacent to site
Infiltration
Length of simulations
7E
7E'5
0.35
1.000
variable
9E
-5
9E"6
0.40
1.000
25-40 ft
8.5 to 15.5 ft
Natural - 10.5 in/yr
Capped - 1.6 in/yr
30 years
10
-2
10
-2
0.25
1.000
25 ft
219
-------
TABLE 2
DESCRIPTION OF CASES 1-16
RUN*
CASE 1 4 VE 1
CASE 2 4 VE 2
CASE 3 4 VE 3
CASE 4 4 VE 4
CASE 5 4 VE 5
CASE 6 4 VE 6
CASE 7 4VE7
CASE 8 4 VE 8
CASE 9 4 VE 9
CASE 10 4VE10
CASE 11 4VE11
CASE 12 4VE12
CASE 13 4VE13
CASE 14 4VE14
CASE 15 4VE15
CASE 16 4VE16
DIMENSION
3D
3D
3D
3D
3D
3D
3D
3D
3D
3D
3D
3D
3D
3D
3D
3D
UPGRADIENT
DRAIN
DEPTH
FROM W.T.
(ft.)
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
SLURRY WALL
KEY INTO
MARSHALLTOWN
(ft.)
NONE
5
10
20
NONE
5
10
20
5
5
5
5
5
5
5
5
DOWNGRADIENT
DRAIN
WATER LEVEL
ELEVATION
(ft.)
6* BELOW E.R.
6" BELOW E.R.
6" BELOW E.R.
6" BELOW E.R.
20
20
20
20
20
NONE
NONE
20
6" BELOW E.R.
6" BELOW E.R.
20
6* BELOW E.R.
DOWNGRADIENT
SLURRY WALL
NONE
NONE
NONE
NONE
NONE
YES
YES
YES
YES
YES
YES
YES
NONE
NONE
YES
YES
NOTES:
INCREASED K IN MT. LAUREL
ENCLOSED SYSTEM
ELIMINATE DOWNGRADIENT DRAIN
SIMULATE 100 YR. FLOOD FOR 30 YRS.
SIMULATE 100 YR. FLOOD FOR 30 YRS.
INCREASED K IN MT. LAUREL
INCREASED K IN MT. LAUREL
AND MARSHALLTOWN
o
-------
ro
TABLE 3
GROUNDWATER FLOW RATES FOR CASES 1-16
RUN*
CASE1 4VE1
CASE 2 4VE2
CASE 3 4 VE 3
CASE 4 4 VE 4
CASE 6 4 VE 5
CASE 6 4 VE 6
CASE 7 4 VE 7
CASE 8 4 VE 8
CASE 9 4 VE 8
CASE 10 4VE10
CASE 11 4 VE 1 1
CASE 12 4VE12
CASE 13 4 VE 13
CASE 14 4 VE 14
CASE IS 4VE15
CASE 16 4 VE 16
TIME - 1 1 DAYS TIME - 1 YEAR TIME - 30 YEARS
L
W
10,237
10,481
10,685
10,675
7,567
7,751
7,941
7,979
42,533
7,794
11,043
50,106
53,259
62,919
L
E
2,045
2,169
2,282
2,290
0
330
404
404
288
657
8,390
8,308
2,131
4,243
U
187
273
264
233
121
156
165
160
144
161
126
79
522
915
N&S
76
78
79
80
0
0
0
0
0
0
307
280
0
0
TOT FLOW
TO DRAIN
(tt-3/d)
(gpm)
12,545
66
13,001
68
13,310
70
13,278
69
7,688
40
8,237
43
8,510
45
8,543
45
42,965
224
N/A
N/A
8,612
45
19,866
104
58,773
306
55,912
291
68,077
354
L
W
6,848
6,618
6,644
6,602
5,093
4,848
4,914
4,957
16,604
4,964
6,926
20,387
27,360
33,648
L
E
1,522
1,505
1,538
1,550
0
351
394
418
266
410
7,272
7,091
1,617
3,144
U
120
165
163
142
62
78
83
84
57
87
111
62
311
673
N&S
62
64
64
64
0
0
0
0
0
0
210
170
0
0
TOT FLOW
TO DRAIN
(fTS/d)
(gpm)
8,552
45
8,353
44
8,409
44
8,358
44
5,155
27
5,277
28
5,391
28
5,459
29
16,927
88
N/A
N/A
5,461
29
14,519
76
27,710
144
29,188
152
37,465
195
L
W
6,796
6,556
6,585
6.543
5,044
4,805
4,864
4,906
16,541
4,922
6,862
20,300
27,026
33,311
L
E
1,519
1,503
1,535
1,547
0
349
394
417
265
408
7,267
7,089
1,508
3,133
U
124
170
161
140
62
78
83
84
57
67
111
62
309
671
N&S
62
64
64
64
0
0
0
0
0
0
209
170
0
0
TOTFLOW
TO DRAIN
(ft-3/d)
(gpm)
8,501
45
8,293
44
8.345
44
8,294
44
5,106
27
5,232
28
5,341
28
5,407
29
16,863
88
N/A
N/A
6,417
29
14,449
76
27,621
144
28.843
150
37,115
193
LEGEND:
LW = LATERAL FLOW THROUGH THE MT. LAUREL FROM WEST
LE = LATERAL FLOW THROUGH THE MT. LAUREL FROM EAST
U - UPWARD FLOW FROM THE MARSHALLTOWN
N & S = INFLOW FROM NORTH AND SOUTH AT THE EASTERN END OF THE SLURRY WALL
-------
TABLE 4
GROUNDWATER LEVELS FOR CASE 11
Top of Time (months)
Slurry Wall
Row (_ftj 1 2 , 3 4 5_
7 25 23.3 24.5 24.9 25.0 25.1
8 25 23.2 24.4 24.8 25.0 25.0
9 25 23.2 24.5 24.9 25.1 25.1
10 25 23.3 24.6 25.1 25.3 25.3
11 25 23.9 25.2 25.7 25.9 25.0
12 25 24.3 25.6 26.1 26.3 26.3
13 29 24.4 25.7 26.2 26.3 26.4
14 29 24.9 26.1 26.6 26.7 26.8
222
-------
TABLE 5
SUMMARY OF 2-D MODEL ANALYSIS CASES
Downgradient
Upgradient Drain Downgradient
Slurry Wall Water Level Slurry Wall
Case
I
2
3
4
5
6
7
8
9
10
11
12
2-D
Run Cross-Section
6VE1
6VE2
6VE3
6VE4
6VE5
6VE6
6VE7
6VE8
6VE9
6VE10
6VE11
6VE12
A
B
C
D
E
F
A
B
C
D
E
F
Key Depth
(ft)
5
5
5
5
5
5
5
5
5
5
5
5
Elevation
(ft)
10.1
10.2
10.5
11.1
13.1
13.8
20.0
20.0
20.0
20.0
20.0
20.0
Key Depth
(ft)
NONE
NONE
NONE
NONE
NONE
NONE
5
5
5
5
5
5
(1) These levels varied with the level of Edwards Run for cases 1
through 6.
223
-------
ro
ro
TABLE 6
GROUNDWATER FLOW RATES TO LEACHATE COLLECTION DRAIN
RUN*
6VE1
6VE2
6VE3
6VE4
6VE5
6VE6
TOTAL
6VE7
6VE8
6VE9
6VE10
6VE11
6VE12
TOTAL
TIME = 11 DAYS TIME =1 YEAR TIME = 30 YEARS
L
W
510
365
1,525
4,343
4,604
2.267
13,614
436
286
1,277
3,493
3.974
2,022
11,488
L
E
145
151
666
1,677
2,072
525
5,236
12
10
55
199
188
92
556
U
13
13
45
132
100
40
343
6
5
21
68
60
27
187
TOT FLOW
TO DRAIN
(ft'3/d)
(gpm)
668
3.5
529
2.8
2,236
11.7
6,152
32.0
6,776
35.2
2,832
14.8
19,193
99.8
454
2.4
301
1.6
1,353
7.1
3,760
19.6
4,222
22.0
2.141
11.2
12,231
63.6
L
W
223
263
917
2,947
2,244
908
7,502
180
220
760
2,407
1,936
783
6,286
L
E
113
137
597
1,316
1,124
291
3.578
20
22
79
223
122
53
519
U
10
11
38
104
54
20
237
4
4
16
46
25
10
105
TOT FLOW
TO DRAIN
(ft-3/d)
(gpm)
346
1.8
411
2.2
1,552
8.1
4.367
22.7
3,422
17.8
1,219
6.4
11,317
58.8
204
1.1
246
1.3
855
4.5
2,676
13.9
2,083
10.9
846
4.4
6.910
35.9
L
W
222
262
916
2,947
2,235
893
7,474
179
219
762
2,401
1,917
767
6,245
L
E
113
137
597
1.316
1,121
290
3,574
20
22
79
223
122
52
518
U
10
11
38
104
54
19
236
4
4
16
46
25
10
105
TOT FLOW
TO DRAIN
(tt-3/d)
(gpm)
345
1.8
410
2.2
1,551
8.1
4,367
22.7
3,410
17.8
1,202
6.3
1 1 ,285
58.7
203
1.1
245
1.3
857
4.5
2,670
13.9
2,064
10.8
829
4.4
6,868
35.7
LEGEND:
LW - LATERAL FLOW THROUGH THE MT. LAUREL FROM WEST
LE - LATERAL FLOW THROUGH THE MT. LAUREL FROM EAST
U - UPWARD FLOW FROM THE MARSHALLTOWN
-------
TABLE 7
FLOWS TO LEACHATE COLLECTION DRAIN
RUN*
CASE 6 CH6 4VE6
CASE 1 5 VE 1
CASE 2 5 VE 2
CASE 3 5 VE 3
TIME - 1 1 DAYS TIME - 1 YEAR TIME = 30 YEARS
L
W
7,751
7,745
7,741
7.735
L
E
330
329
329
328
U
156
156
156
156
TOT FLOW
TO DRAIN
(fr3/d)
(gpm)
8,237
43
8,230
43
8,226
43
8,219
43
L
W
4,848
4,827
4.691
4,535
L
E
351
348
343
334
U
78
78
77
75
TOT FLOW
TO DRAIN
(frs/d)
(gpm)
5,277
28
5,277
28
5,277
27
5,277
26
L
W
4.805
4,740
4,642
4,476
L
E
349
346
341
332
U
78
77
76
74
TOT FLOW
TO DRAIN
(ft'3/d)
(gpm)
5,232
28
5,163
27
5,059
27
4,882
26
ro
ro
01
LEGEND:
LW - LATERAL FLOW THROUGH THE MT. LAUREL FROM WEST
LE - LATERAL FLOW THROUGH THE MT. LAUREL FROM EAST
U - UPWARD FLOW FROM THE MARSHALLTOWN
-------
TABLE 8
COMPARISON OF UPGRADIENT DRAIN CONSTRUCTION COSTS
AND LEACHATE TREATMENT COST SAVINGS
Cost
Elevation Construction Costs Savings (I)
10% Discount 6% Discount
63 ft MSL $6,025,310 $0 $0
53 ft MSL $6,844,410 $63,000 $92,000
43 ft MSL $8,482,610 $126,100 $184,200
(1) Cost savings based on a 120-gpm pretreatment plant.
TABLE 9
COLLECTION DRAIN FLOW RATES WITH CHANGING
MARSHALLTOWN CONDUCTIVITY (in gpm)
Time
11 days
1 yr
30 yrs
Case 1
43
28
28
Case 2
75
51
51
Case 3
29
17
15
Case 4
45
29
29
Case 5
79
54
54
Case
30
17
15
6
226
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TABLE 10
LEACHATE FLOW RATES TO COLLECTION DRAIN
(GPM)
Phase II
Design Case I Case II
216 58.8 35.9
165 58.7 35.8
95 58.7 35.7
70 58.7 35.7
50 58.7 35.7
19 58.7 35.7
Flow rates selected
for design 216 60 40
Flow rate for
process design 300 180 120
(1) Phase II design assumed 21 shifts/week (continuous) operation
in Year 1, 15 shifts/week operation in Year 2, 10 shifts/week
in Years 3 and 4, and 5 shifts/week for Years 5-30.
(2) Case I and Case II designs assume 10 shifts/week operation
throughout the 30-year estimated life cycle of the facility.
The Case I flow rates are for estimated leachate flows
collected without the installation of a downgradient slurry
wall. Case II flow rates are the estimated leachate rates
when a downgradient slurry wall is installed between the
leachate collection drain and Edwards Run.
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TABLE 11
TOTAL PRESENT WORTH COSTS
($1000)
10% Discounting
6% Discounting
ro
CO
Capital Cost
Treatment Facility
Downgrad. Slurry Wall
Subtotal
O&M Cost
TOTAL
Phase II
300 GPM
Facility
5,333
___
5,333
5,093
10,426
Case I
180 GPM
Facility
4,012
_ __
4,012
5,034
9,046
Case II
120 GPM
Facility
3,198
859
4,057
3,783
7,840
Phase II
300 GPM
Facility
5,333
___
5,333
7,436
12,769
Case I
180 GPM
Facility
4,012
___
4,012
7,351
11,363
Case II
120 GPM
Facility
3,198
859
4,057
5,524
9,581
Savings from Downsizing
to 180 GPM
Savings from Downsizing
to 120 GPM
2.586
1,406
3.188
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Remedial Action in and Around Light Industrial Activity at the
Denver Radium Superfund Site
Timothy R. Rehder
Remedial Project Manager
Affiliation: U.S. Environmental Protection Agency, Region 8
999 - 18th Street, Denver, CO 80202-2405
Phone: (303) 293-1529
Erna P. Acheson
Remedial Project Manager
Affiliation: U.S. Environmental Protection Agency, Region 8
999 - 18th Street, Denver, CO 80202-2405
Phone: (303) 293-1651
ABSTRACT
The Denver Radium Superfund Site consists of 16 separate sites located along the South Platte River
Valley in Denver. Contamination at the sites is the result of widespread radium processing which
occurred between 1914 and 1927. Operable Unit I of the Denver Radium Site covers one city block
and is the former location of a radium-processing facility. Currently, the site is zoned for light
industry and is occupied by five small businesses: (1) a warehouse/wholesale operation; (2) a sheet-
metal assembly business; (3) an appliance repair business; (4) a hardware fabrication business; and (5)
a grave-marker manufacturer.
The primary challenge presented by the site is that of removing approximately 33,000 tons of
radiologically contaminated soils and debris and, at the same time, allowing the businesses on site
(none of which are responsible parties) to maintain a semblance of normal operations. This required
multiple phasing of the decontamination and reconstruction work in order to maintain access to the
site for routine business operations. Four of the structures on site were underlain by contamination
which required relocating the businesses to allow for demolition of the floors and excavation of the
subgrade. This was accomplished by bringing mobile office space onto the properties and by
temporarily relocating business operations into previously vacant space.
In order to transport waste from the site in the most expeditious and cost-effective manner, EPA'
contractor renovated a rail spur that had been abandoned for more than 50 years. This allowed bulk
transportation of contaminated material in dedicated railroad gondola cars. To maximize the
efficiency of the loadout operation, an in-rail scale was installed at the Operable Unit along with a
gantry to facilitate the placing of hard lids on the railcars. Prior to and during the rail renovation
work, loadout of contaminated material was performed using 20-ton, truck-mounted containers.
BACKGROUND
Operable Unit I (OU I) of the Denver Radium Site is a 7.33 acre site that lies within the South Platte
River valley in an industrialized area of the Denver. Radium contamination at the site resulted from
the processing of radium ores by the Pittsburgh Radium Company during 1925 and 1926. This
company went bankrupt in 1926 as did most of the domestic radium industry when extremely rich
radium deposits were discovered in the Belgian Congo. The radium-contaminated materials at OU
I were subsequently forgotten until 1979 when an Environmental Protection Agency (EPA) employee
looking through old Bureau of Mines publications saw reference to the radium industry in Denver.
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The Record of Decision (ROD) for OU I, signed on September 27, 1987, called for capping the
exterior contamination at the site and excavating all contamination beneath structures and storing it
on site until a permanent deposal repository could be located. Plans for on-site storage were
abandoned shortly after the signing of the ROD when a commercial disposal facility in Tooele
County, Utah, was granted a license to accept radium wastes. Consequently, the remedial design
focused on excavation and direct off-site disposal of the radiologic contamination.
Standards for cleanup at inactive uranium mill sites (40 CFR 192) were identified in the ROD as the
relevant and appropriate cleanup levels. These standards state that the remedial action should be
conducted to provide reasonable assurance that the concentration of radium-226 when averaged over
an area of 100 square meters does not exceed background by more that 5 picocuries per gram (pCi/g)
in the top 15 cm of soil or 15 pCi/g in soil deeper than 15 cm.
OVERVIEW OF THE DECONTAMINATION PROCESS
Radiologic contamination at the Denver Radium Sites is excavated in six-inch lifts in order to
minimize the amount of "clean material" that is removed with the waste. After a lift has been
removed, the excavation is surveyed to determine whether it is necessary to remove another lift. The
practice of excavating six inches at time is based on average length of the travel path of gamma rays
emitted by radium-226 and associated radionuclides (approximately 8 inches in soil).
The determination as to what material exceeds the cleanup criteria is made by field personnel
measuring gamma-exposure rates using hand held scintillometers. Once the field instrumentation
indicates that the cleanup standards have been met, a final verification survey is performed by
collecting composite samples from the excavation and analyzing the samples in a van equipped with
an Opposed Crystal System (OCS). The OCS is a gamma spectroscopy device which provides more
accurate radium concentration data than the field instruments because it can distinguish the gamma
radiation being emitted by radium-226 from that being emitted by other naturally occurring
radionuclides (e.g. potassium-40 and thorium-232).
The cleanup work at the Denver Radium Site is being performed by two contractors: a
design/construction contractor and a transportation and disposal contractor. The design/construction
contractor is responsible for the following activities:
1. Gathering additional characterization data to supplement the data collected during the
remedial investigation.
2. Developing design documents.
3. Procuring and directing an excavation subcontractor.
4. Maintaining site health and safety.
5. Performing any sampling necessary for characterizing the contents of transportation
containers.
The transportation and disposal (T&D) contractor brings transportation containers to the site where
they are loaded, decontaminated if necessary and released by the design/construction contractor. The
transportation and disposal contractor then places hard covers on the containers and ships them to the
disposal facility. Approximately 85 percent of the waste that has been shipped from the Denver
Radium properties has gone via railroad gondola cars (100 ton capacity). The remainder has been
230
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shipped via 20-ton, truck-mounted containers which are loaded at the site and driven to a Denver rail
yard where they are placed on flatbed rail cars for shipment to the disposal facility.
HEALTH AND SAFETY
Remedial action workers at OUI performed the majority of the cleanup work in "Level D" protection.
This level of personnel protection was possible due to the emphasis placed on dust suppression. The
low technology approach of thoroughly wetting the excavation proved highly effective and generally
kept the concentrations of hazardous substances in the air well below permissible exposure limits.
Large fans were used during interior work to vent radon gas to the outside atmosphere. Air
monitoring for respirable dust, airborne radionuclides and metals was conducted in the controlled
areas using high volume samplers. In addition, portable, low-volume samplers were utilized to
gather breathing zone data for workers in areas where the potential for exposure was high.
Personnel protection was upgraded to "Level C" during two periods of site activity: 1) when
transformers were discovered in a septic tank; and 2) when workers complained of a pesticide odor
when working in the vicinity of a leaky underground storage tank. "Modified Level D" equipment
(tyvek coveralls, gloves and booties) was donned during bad weather periods when muddy conditions
increased the likelihood of picking up radiologic contamination.
PHASING OF REMEDIAL CONSTRUCTION
EPA Region VIII made the determination that the current property owners at OU I could successfully
assert innocent landowner defenses to CERCLA liability. For this reason, EPA attempted to conduct
the remedial action in a manner that would minimize the disruption to the on-site businesses. To this
end, the response action was conducted in three phases:
Phase A Exterior areas west and south of the Warehouse/Wholesale Company building
(west building) (Figure 1).
Phase B Interior Contamination in the west building.
Phase C Remaining exterior and interior areas.
PHASE A
Data gathered during the remedial investigation and remedial design indicated that contamination in
the west building was located beneath the southern wing of the structure (a 16,000 square foot
warehouse) and in an office area on the northern end of the building (Figure 1). EPA originally
intended to rent off-site warehouse and office space to temporarily dislocate the operations in the
contaminated portions of the building so that excavation of the radium-tainted soils could occur.
However, at the owner's request EPA was able to implement the following plan that eliminated the
need to rent off-site warehouse and office space:
1. EPA's contractor excavated 1950 tons of radium contamination from the exterior area
west of the west building.
2. The property owner entered a separate contract with the excavation contractor to
decontaminate the area south of the west building (565 tons removed). EPA provided
technical oversight.
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3. Radiologic contamination was loaded into 20-ton, truck-mounted containers.
4. EPA's contractor then performed a final verification survey to assure that the cleanup
standards had been met.
5. Upon completion of the verification survey, the owner contracted for the construction
of a new warehouse in the area south of the existing building with the intention of
vacating the existing warehouse upon completion of the new one (Figure 2).
During the course of the Phase A work, the transportation and disposal contractor proposed the
renovation of an abandoned rail spur located immediately west of the grave marker manufacturer's
building (North Building, Figure 2) so that the remaining material on site could be loaded into 100
ton gondola cars. Recognizing the logistical advantages of using gondolas instead of truck-mounted
containers, EPA agreed to allow loadout by rail provided that it resulted in no additional cost to the
government. The main problem presented by the rail loadout, was that in order to place material into
gondolas located on the spur, the contaminated material would need to be hauled up a very steep
grade that separated the warehouse/wholesale property from the grave-marker manufacturer and
hardware fabrication properties (Figure 3). The T&D contractor intended to surmount this obstacle
by installing a conveyor to take material from the lower level of the site to the track level (an
elevation difference of approximately 27 feet).
The renovation of the rail spur took eight weeks and involved lifting the buried rails, adding ballast
material, replacing 75 percent of the railroad ties, and the installation of a railroad crossing on a very
busy thoroughfare. During the renovation work, the T&D contractor installed an in-rail scale that
was accurate to within plus or minus 50 pounds. The scale enabled rail cars to be loaded to near
capacity and eliminated the problem of overloading (which at other Denver Radium OUs had resulted
in having to bring approximately 18% of the gondolas back to the site for partial off loading). The
configuration of the spur and the location of the scale limited the number of gondolas that could be
on site at any time to three. The T&D contractor erected a gantry immediately outside of the
controlled area which enabled two workers to secure the 10 by 52 foot, 1,200 pound hardcovers on
the loaded gondolas in less than 10 minutes per container.
PHASE B
During the construction of the new warehouse, remedial action began in the office and showroom
portion of the west building. Thirteen office workers were relocated to trailers in the parking lot west
of the building (Figure 2). EPA's contractor then erected airtight barriers to isolate the controlled
area from the rest of the building, removed the office partitions, removed the floor covering, and
jackhammered the floor to expose the contaminated subgrade. Radium contaminated soils (564 tons)
were removed via small conveyors and skip loaders and put into dump trucks that were driven to the
east side of the building so the waste could be loaded into the main conveyor (Figure 3).
Unfortunately, the conveyor installed by the T&D contractor was not designed to handle the type of
material that was being generated by the cleanup. The radium-wastes, typically, were fine grained
and cohesive, and tended to clog the grizzly and form bridges in the hopper. The T&D contractor
spent considerable time in efforts to keep waste moving through the conveyor. This situation did not
lead to significant project delays however, because the interior excavation work was not generating
prolific amounts of waste.
The decontamination and reconstruction of the office and showroom areas proceeded on schedule.
However, the contractor was not able to move directly into the warehouse area as planned because
the construction of the owners new warehouse was behind schedule. The project was delayed for two
233
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RELOCATION
TRAILER
West
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DRIVEWAY
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Bldg.
QUIVAS STREET
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FD(
SHOSHONE STREET
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h-
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weeks as the owner completed the new building and moved his inventory. Once remedial action
started in the warehouse, contamination ran 5 to 6 feet deeper than originally assessed. A total of
2,070 tons of radium-contaminated soils and debris had been removed from the warehouse by the
time it was ready for the final verification survey.
PHASE C
The final phase of the cleanup involved the dislocation of three separate businesses and the demolition
and reconstruction of 11,800 square feet of office and warehouse space. The first area to be
decontaminated in this phase of the project was the exterior area immediately west of the south
building (Figure 2). building. The contamination in this area ran more than fifteen feet deep and
required the removal of a septic tank that serviced the building. It was known during the design
effort that the septic tank would need to be removed. The Denver Building Department would not
allow the septic tank to be replaced so it was necessary to design a hookup to the city sewer system.
During the removal of the septic system, two highly deteriorated objects, suspected of being
transformers, were discovered inside the tank. The transformers were placed in sealed 55-gallon
drums and turned over to the property owner for proper disposal. The discovery of transformers
prompted the collection of samples to be analyzed for non-radiologic contamination to assess the
potential of encountering mixed (radiologic/hazardous) waste. Two soil samples were found to
contain PCBs in the 5 to 10 ppm range, however this did not pose a problem since the disposal facility
can accept PCBs up to a concentration of 50 parts per million.
Once the decontamination of the area west of the metal fabrication building was complete, the
excavation work moved to the open area in the center of the site. The most radioactive materials at
the site were encountered in this area. Approximately 20,000 tons of soil and debris were removed
from this portion of the OU, and activity levels between 600 and 1000 pCi/g were common. Gamma
exposure measurements in the excavation ran as high as 10 milliroentgens/hour and beta radiation as
high as 30 milliroentgens/hour. Contamination extended between 5 and 10 feet deep and was overlain
by 2 to 3 feet of clean material which was stripped off and stored on site to be used as backfill.
The first week of this exterior excavation work proceeded slowly due to clogging of the conveyor.
After experimenting with a number of methods designed to eliminate the clogging (various vibrating
devices), it was decided to take the low technology approach of building an earth ramp up to the track
level (Figure 3) and abandon the use of the conveyor altogether. The ramp was steep and there was
concern that snow storms would render it too slippery for the front-end loaders, but thanks to an
unusually mild winter this never became a problem.
Concurrent with this exterior work, EPA's contractor initiated cleanup activities in the hardware
fabrication building (east building, Figure 2). The assessment data indicated that the radium
contamination was present beneath the office portion of the building. Boreholes were drilled in the
office area during the remedial investigation and remedial design. Augur refusal was experienced
in each hole at a depth of about three feet. Given that the current office was at dock level, it was
assumed that another floor existed three feet below the present one and that contaminated material
was unwittingly used as fill when the office was constructed to its current configuration. Due to the
age of the building (built in approximately 1900 as part of a brewery) no drawings could be located
to confirm this.
Seven office workers were relocated into a trailer (Figure 2) so the floor could be taken up and the
underlying contamination removed. The excavation contractor encountered a layer of brick rubble
at a depth of three feet, but the radium contamination continued to a depth of eight feet.
Fortunately, the load-bearing columns in the building were setting upon whiskey-barrel caissons that
236
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extended beyond the depth of the contamination. In total, 797 tons of contamination were removed
from the interior of the east building.
While reconstruction was taking place in the east building, remedial action began in the sheet-metal
assembly building (south building, Figure 2). This building consisted of a two-story structure that
existed at the time of radium processing, and two additions that were built atop deposits of radium
contamination. The two-story building and the adjoining addition were occupied by a sheet-metal
assembly business, while the south warehouse was leased by a concert promoter who used the space
to store staging equipment. EPA's original plan was to relocate the concert promoter to an off-site
warehouse and move the part of the sheet-metal assembly operation into the south warehouse while
the middle section of the building was being decontaminated and reconstructed, and then move the
metals operation back to its original location so the south warehouse could be remediated. Fortunately
for EPA, the concert promoter was looking for an excuse to break his lease and moved out prior to
the start of the cleanup.
A large opening was cut in the cinder block wall that separated the middle addition from the south
warehouse to facilitate the relocation of the large metal shears and presses. Approximately 232 tons
of radium waste were excavated and shipped to the disposal facility during the decontamination of
the south building.
During the reconstruction of the south warehouse, remedial action continued in the area adjacent to
the rail spur and on the grave marker company property (north building, Figure 2). Small deposits
of radium contamination that were present in the parking area east of the north building were
removed using a skip loader and placing the waste into 1-ton cargo bags suspended from a forklift.
The cargo bags were subsequently transferred to a gondola. As this last stage of the cleanup
progressed, it became necessary to remove sections of the rail spur so that underlying contamination
could be excavated. Pulling up the rail spur limited the number of gondolas that could be brought
to the site per day from three to two to one.
At the time of publication, EPA's contractor had just finished demolishing an addition to the north
building and had removed the last deposit of radium contamination at the site. The original design
planned for partial undermining of the addition because assessment data indicated that contamination
only extended two feet beneath the structure. However, during remedial action it was discovered that
the contamination was more extensive, and the poor condition of the building's floor slab made it too
dangerous to continue the undermining operation.
SUMMARY
Remedial construction work at OUI of the Denver Radium Site was performed in three phases. The
first phase involved the excavation and disposal of 2,515 tons of radium-contaminated soils and
debris and lasted eleven weeks. The second phase of the cleanup was conducted over a period of 7
months and resulted in the excavation and disposal of 2,644 tons of radium contaminated soil and
debris. The third and final phase began on June 6, 1990. The site was verified as being free of
radiologic contamination on April 19, 1991, and reconstruction of the site will be complete in June
of 1991.
Approximately 32,500 tons of radium waste were excavated and shipped to the permanent disposal
facility during the three phases of the cleanup (final tonnage figures were not available a time of
publication). A total of 301 gondolas and 201 truck-mounted, bi-modal containers were loaded and
shipped from OU I in the period between October 1989 and April 1991. The phasing of the remedial
action resulted in the successful decontamination of the OU while minimizing the impact that the
cleanup operations had on the six businesses that operate on site and the approximately 110 people
that they employ.
237
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Streamlining Remedial Design Activities at the
Department of Energy's Monticello Mill Tailings NPL Site1
Debbie L. Richardson
Chem-Nuclear Geotech, Inc.
P. O. Box 14000
Grand Junction, Colorado 81502
(303) 248-6065
Harry A. Perry
Chem-Nuclear Geotech, Inc.
P. O. Box 14000
Grand Junction, Colorado 81502
(303) 248-6018
J. E. Virgona
U.S. Department of Energy
Grand Junction Projects Office
P. O. Box 2567
Grand Junction, Colorado 81502
INTRODUCTION
Purpose of this Paper
The Monticello Mill Tailings Site is located in San Juan County, Utah, within the city of Monticello
(Figure 1). Mill tailings and associated contaminated material remain on the millsite as a result of
uranium and vanadium milling operations. A Federal Facility Section 120 Agreement with the U.S.
Environmental Protection Agency (EPA) and the State of Utah, pursuant to the Superfund
Amendments and Reauthorization Act of 1986, became effective on February 24, 1989. As stated
in the Agreement, the U.S. Department of Energy (DOE) is the responsible party with respect to
present and past releases at the millsite. Responsibility for oversight of activities performed under
the Federal Facility Agreement will be shared by the Environmental Protection Agency and the State
of Utah. A Hazard Ranking System score for the millsite resulted in the inclusion of the Monticello
Mill Tailings Site on the Environmental Protection Agency's National Priorities List on November 16,
1989.
The Record of Decision for the Monticello Mill Tailings Site was completed on September 20, 1990.
This action initiated the requirement of the Superfund Amendments and Reauthorization Act of 1986,
Section 120, for federal facilities to commence substantial, continuous physical on-site remedial action
within 15 months of the completion of the Record of Decision.
The 15-month requirement made it necessary for the Department of Energy to develop a remedial
design and implement remedial action within the stipulated timeframe. This had to be accomplished
within the framework of the Federal Facility Agreement that stipulated additional timeframes for
*Work performed under the auspices of the U.S. Department of Energy, DOE Contract No. DE-
AC07-86ID12584.
238
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San Juan County
I
Figure 1. Monticello, Utah, Regional Location Map
239
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review and approval of remedial design documents by the Environmental Protection Agency and the
State of Utah prior to their implementation. It became imperative for the Department of Energy to
develop a streamlined approach for project implementation to meet the 15-month requirement, in
addition to the requirements of the Federal Facility Agreement.
This paper presents the process used by the Department of Energy to develop the plan that was
implemented to meet the 15-month requirement, and the implementation plan. The implementation
plan had to meet the project objectives discussed in the following section.
Project Objectives
The Monticello Remedial Action Project has the following project objectives:
o Develop a design for the remediation of the Monticello Mill Tailings Site that demonstrates
compliance with applicable and relevant or appropriate requirements established in the Record
of Decision,
o Develop a schedule that allows for review and concurrence of the remedial design as required
by the Federal Facility Agreement,
o Develop a plan for implementation of the remedial design that allows for the start of remedial
action within the
15-month timeframe.
These objectives must be met for successful implementation of the Monticello Remedial Action
Project.
BACKGROUND
Project Scope
Remediation activities for the Monticello Mill Tailings Site require the removal of an estimated 1.9
million cubic yards of uranium and vanadium mill tailings to an on-site repository. Most of the
tailings are contained in tailings piles on the millsite; however, tailings were transported by wind and
surface water to properties peripheral to the millsite. The plan for removal of the tailings will be
addressed in the remedial action design. This design must demonstrate that compliance with
applicable and relevant or appropriate requirements will be achieved.
Site Description
The Monticello Mill Tailings Site includes the millsite and peripheral properties. The Department of
Energy owns the millsite, a 78-acre tract within the city of Monticello (see Figure 2). An estimated
1.4 million cubic yards of mill tailings are present in the tailings piles, and an estimated additional
100,000 cubic yards of material are present on other areas of the millsite.
During the period of mill operation, private land to the north and south of the existing site was leased
for the stockpiling of ore. The former ore-stockpile areas and areas contaminated by airborne-
tailings particulate matter or surface-water transported contaminants cover approximately 300 acres
around the millsite and contain an estimated 300,000 cubic yards of peripheral property material to
be remediated (Figure 3).
240
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ro
MILLSITE BOUNDARY (78 ACRES)
CITY
OF
MONTICELLO
D
VANADIUM
TAILINGS^'
CARBONATE A AREA
TAILINGS
AREA
EAST TAILINGS AREA
ACID
TAILINGS
AREA
FEET
Figure 2. Monticello Millsite Plan
-------
An additional 100,000 cubic yards of contamination is estimated to exist on the Monticello Vicinity
Properties (Figure 3). This material consists of both air borne-tailings particulate matter and material
that was used as fill or construction material on the properties. The Monticello Vicinity Properties
Project was listed on the National Priorities List in 1986 and is being remediated pursuant to a Record
of Decision dated September 1989.
The tailings piles are located within the floodplain of Montezuma Creek. They are also partially in
contact with a shallow alluvial aquifer underlying the site. This alluvial aquifer is not presently used
as a drinking-water source; however, it does have a potential for agricultural use. A deeper aquifer,
known as the Burro Canyon aquifer, is a drinking-water supply. Analyses of samples from
monitoring wells in the Burro Canyon aquifer show no evidence of contamination. Two aquitards,
the Mancos Shale and part of the Dakota Sandstone, separate the Burro Canyon aquifer from the
overlying alluvial aquifer under most of the millsite.
Montezuma Creek, which flows through the millsite, is a small perennial stream. Low-flow
conditions prevail in the late summer, fall, and winter months. Within the project area, base flow in
Montezuma Creek is maintained year-round by ground-water discharge from the alluvial aquifer and
by releases from Monticello Reservoir, located approximately one-mile upstream from the millsite.
Protect Description
History —The Atomic Energy Commission bought the Monticello milling operation in 1948. Uranium
milling commenced in September 1949 and continued until 1960, when the mill was permanently
closed. Part of the land was transferred to the Bureau of Land Management; the remaining parts of
the site have remained under the control of the Atomic Energy Commission and its successor agencies,
the U.S. Energy Research and Development Administration and the Department Energy. The land
transferred to the Bureau of Land Management was recently returned to the Department of Energy.
In the summer of 1961, the Atomic Energy Commission began to regrade, stabilize, and vegetate the
tailings piles. The plant was dismantled and excessed by the end of 1964. Some of the plant was
buried on the millsite. Photographs suggest that contaminated soil was used as fill material to partially
bury the mill foundations.
The Department of Energy, under the authority of the Atomic Energy Act, initiated the Surplus
Facility Management Program in 1978 to ensure safe caretaking and decommissioning of government
facilities. In 1980, the millsite was accepted into the Surplus Facility Management Program and the
Monticello Remedial Action Project was established. In February 1989, the Federal Facility
Agreement established that the activities at the Monticello Mill Tailings Site must comply with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended by
the Superfund Amendments and Reauthorization Act of 1986. In February 1990, the Department of
Energy completed the Remedial Investigation/Feasibility Study-Environmental Assessment for the
millsite. The Monticello Mill Tailings Site Declaration for the Record of Decision was approved by
all parties in September 1990, establishing the selected remedy.
Selected Remedy — The remedial work at the site has been organized into three operable units (OUs)
to facilitate remedial design and remedial action. These are:
o Operable Unit I: Mill Tailings and Millsite Property
o Operable Unit II: Peripheral Properties
o Operable Unit III: Ground Water and Surface Water
24?
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CO
AREA OF CONTAMINATION WITHIN
THE PERIPHERAL PROPERTIES
Figure 3. Monticello Vicinity Properties and Area of
Contamination Within Peripheral Properties
-------
A separate Record of Decision will be prepared for Operable Unit III because the remedy selected
for remediation of ground and surface water depends on the removal of contaminated material from
the millsite and from the peripheral properties. The Record of Decisioikwill be completed after the
collection of additional surface- and ground-water monitoring data following tailings removal from
the millsite and the peripheral properties.
The alternative selected for Operable Unit I involves excavation and removal of contaminated
materials to an on-site repository located south of the existing millsite. Removal will be by
conventional earthmoving equipment and transport of tailings and other materials will be entirely on
site. Dust-control measures and access restrictions will be used to protect public health and the
environment during remedial action activities. To control runoff, diversion structures will be built
and collected water will be treated as appropriate. Tailings disposal will occur on and contiguous to
the existing millsite in a repository covered with a clay and multimedia cap. Design of the repository
will comply with 40 CFR 192 performance standards.
The alternative selected for Operable Unit II requires removal of tailings to meet the principal
relevant and appropriate standard, 40 CFR 192. Contaminated materials will be transported to an
interim storage area and then relocated with the millsite materials to the repository. Removal of
contaminated materials will be either by conventional construction techniques or by environmentally
sensitive removal techniques. The environmentally sensitive techniques, such as hand excavation or
use of high-suction vacuum equipment could be used in areas with mature dense vegetation that
would require decades to re-establish the native tree species.
The remedial designs prepared for the selected remedies for Operable Units I and II must demonstrate
compliance with applicable and relevant or appropriate requirements identified in the Record of
Decision.
DISCUSSION
Approach Used to Develop Plan for Meeting Project Objectives
Development of a plan to meet project objectives was conceived through a Value Engineering (VE)
Session. This session was designed to bring representatives from the involved agencies and their
contractors together for a "team approach" to project planning. This facilitated session started with
a "think tank" approach to identify the issues that needed to be addressed to design and implement
the project. This allowed each team member to put their concerns and concepts on the "on the table."
As a result of this effort, 48 key issues were identified as important to the development of the project.
These key issues were then ranked by the team according to how critical they were to project
progress. In addition to identifying critical issues, this phase of the session served to bring the team
members up to a comparable level of understanding of the scope of the project.
Once the critical key issues were identified, the VE team worked to resolve the issues. Resolved
issues included the need to phase the design and remedial action to meet schedule constraints and the
use of "working-level discussion documents" as a mechanism for resolution of regulatory compliance
issues. A commitment was made to prepare a Remedial Design Work Plan incorporating the team's
concepts on project phasing and identifying the required design documents and their contents. In
addition, the VE team made commitments to prepare working-level discussion documents addressing
key regulatory issues.
Besides resolving the tangible issues, the VE Session provided the mechanism for building a team
approach to project planning. This team-building effort enhanced the ability to communicate
between the involved team members, which included government agencies and contractors.
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Schedule for Remedial Design and Remedial Action
The schedule for remedial design and remedial action for the Monticello Mill Tailings Site is phased
to meet the CERCLA Section 120 requirement for federal facilities to initiate substantial continuous
physical on-site remedial action within 15 months after signing the ROD. In addition, the phase
approach meets the Environmental Protection Agency's "bias for action" strategy advocated in Office
of Solid Waste and Environmental Restoration Directive 9355.5-20, "Guidance on Expediting
Remedial Design and Remedial Action." Operable unit I of the project was divided into three general
phases: Phase 1 - Site Preparation, Phase 2 - Removal of Tailings and Construction of the Disposal
Site, and Phase 3 - Reclamation of the Millsite and Borrow Areas. Figure 4 depicts the schedule for
the three phases.
Phase 1 was further divided into three subphases: (1) Millsite Site Preparation, (2) Pre-excavation
Activities at the Millsite, and (3) Repository Site Preparation. Design of each subphase requires the
preparation of 30 percent and 90 percent design documents. This level of phasing at the onset of the
project allows for the preparation of focused design documents and for focused remedial action
activities. Preparation of design documents for Phase 1 will require less time than Phases 2 and 3
documents because of less complex engineering and regulatory compliance requirements. This phased
approach allows for the implementation of remedial action within the required regulatory timeframes
and is also a reasonable approach to construction.
Phase 2 requires the resolution of many significant regulatory requirements, particularly repository
design. The preparation and review and approval of the 30 percent and 90 percent design documents
for this phase are anticipated to require 2.5 years. If the design for all phases was one document,
remedial action could not be implemented within the required regulatory timeframes. Design of
Phase 3 activities was split out from the Phase 2 activities to reduce the scope of the Phase 2 design
documents.
The schedule identifies the preparation time for design documents and the review-and-approval
cycle. The need for an established review and approval process is critical to meet the remedial action
schedule. The timeframes shown on the schedule for review, comment resolution, and final
concurrence reflect the requirements of the Federal Facility Agreement for the Monticello Remedial
Action Project.
The draft Remedial Design Work Plan for the Monticello Mill Tailings Site includes this schedule and
describes the contents of the design documents. The Environmental Protection Agency and the State
of Utah are currently reviewing the Work Plan. When the Work Plan receives final approval,
commitments will be established for document preparation and submittal and for document review
and approval to meet the objectives for project scheduling.
Working-Level Discussion Documents
The VE Team identified many complex regulatory issues that are integral to the development of the
Phase 2 design. The Department of Energy has prepared working-level discussion documents on each
of these issues, providing the technical rationale for DOE's proposed compliance position. The
documents that were prepared are listed below:
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MONTICELLO REMEDIAL ACTION PROJECT
Mlllslte Site
Preparation
Pre-axcavatlon
Activities at
Mlllsite
Repository Site
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9 )
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riConetructlof
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i i
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ittart
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XV 690X
rtConitructlor
FY 95
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•• Complete FY 97
1 1 1 1 1 I 1 1 1 1 1
FY 91
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1 I START-FINISH V SUBMIT TO DOE HQ O SUBMIT TO EPA/STATE D CONSTRUCTION START FILE DEB
Figure 4. Monticello Remedial Action Project Schedule
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o Technical Approach for Designing the Monticello Repository Cover
o Ground Water Compliance Strategy for Engineering Design
o The Use of Engineering Controls in the Disposal of Low Level Radioactive Uranium Mill
Tailings
o Point-of-Compliance for Ground-Water Monitoring at the Monticello Repository -
Regulatory Interpretation
o Compliance with Applicable or Relevant and Appropriate Requirements for Peripheral
Properties
o The Level of Effort Used to Decontaminate Radiologically Contaminated Building Materials
and Mill Equipment in the Remedial Design for the Monticello Mill Tailings Site
Each paper evaluates issues that required analysis of site-specific conditions, evaluation of regulatory
requirements, and development of a specific position to achieve compliance. The papers were
submitted to the Environmental Protection Agency and the State of Utah for review and comment.
Meetings were held to discuss the papers and determine further actions necessary to assess compliance.
As a specific example of the use of these documents, the "Point-of-Compliance for Ground-Water
Monitoring" document is discussed in further detail. The point-of-compliance (POC) is the
location(s) at which a monitoring well(s) must be installed to determine if seepage from the repository
has degraded ground-water quality. The requirements of the State of Utah regulations and the
Federal regulations are different, and both are applicable and relevant and appropriate requirements.
Determination of the POC is critical to the design of the repository. The design effort must assess
changes in ground-water quality as a result of seepage from the repository. The design must
demonstrate that changes in ground-water quality will not exceed established ground-water quality
criteria at the POC. If this demonstration cannot be made, the design must be modified to provide
for additional control of seepage.
An understanding of the geohydrologic setting is critical to the determination of the POC. The
geohydrology of the proposed repository site is complex and determination of the location of
monitoring wells is not straight forward.
The position presented in this working-level discussion document identified DOE's interpretation of
regulatory requirements as they pertained to the current understanding of site-specific conditions.
However, uncertainties exist associated with the understanding of the site-specific conditions.
Although 69 wells on 200-foot centers were installed on the proposed repository site, location of the
POC cannot be agreed upon by the involved regulatory agencies and the Department of Energy.
The discussion document on the POC raised as many questions as it attempted to answer. However,
it developed a starting point from which the involved agencies could work together to move forward
on establishing the appropriate location(s) of the POC. On the basis of discussions between the
Department of Energy, the Environmental Protection Agency and the State of Utah, additional site
characterization is being conducted to obtain the data necessary for the determination.
Discussion and resolution of issues through the use of discussion documents focuses the design
process. Several directions can often be taken during design to meet design and compliance
objectives. The direction that meets regulatory requirements often is not obvious and is subject to
professional opinion. A team can use the working-level discussion documents as a mechanism to
determine the direction of the design effort. This subsequently results in the preparation of a design
that should meet regulatory requirements. Working-level discussion documents also facilitate the
review process because the review agencies are familiar with the design issues.
247
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CONCLUSION
The VE Session is a productive tool in development of a project plan. It served to bring the involved
government agencies and their contractors together to identify issues significant to the progress of the
project and to develop a plan for the resolution of those issues. This team approach also enhanced
the communication process between the agencies and their contractors.
The planning approach developed during the VE Session includes a phased schedule necessary to meet
the requirement for substantial continuous physical on-site remedial action within 15 months. The
schedule identifies focused remedial design packages that could be prepared and implemented within
the required timeframe. In addition, the schedule specifies the dates for delivery of documents to the
Environmental Protection Agency and the State of Utah and the time for review and approval of the
designs. Success of the project depends not only on the submittal of the appropriate designs but also
their review. The schedule and description of the contents of the documents to be delivered is
included in the Remedial Design Work Plan. Final approval of the Work Plan will establish
commitments for document preparation and submittal and for document review and approval.
The use of working-level discussion documents provides a method to focus discussions on regulatory
compliance issues and their resolution prior to submittal of design documents. This resolution
facilitates preparation of the designs and their review and approval.
ACKNOWLEDGEMENT
Work supported by the U.S. Department of Energy Office of Environmental Restoration and Waste
Management at the Grand Junction Projects Office under DOE Contract No. DE-AC07-86ID12584.
248
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CONSTRUCTION OF A KAOLIN CLAY CAP
for
BURIED NUCLEAR WASTE
Cliff Schexnayder
Nello L. Teer Company
211 W. Parrish Street
Durham, N.C. 27701
919/682-6191
Harvey E. Wahls
Department of Civil Engineering
North Carolina State University
Raleigh, N.C. 27695
919/737-7344
Introduction
A three (3) foot thick RCRA Standard kaolin clay cap was
one element of the total structural system used for the
permanent closure of a low-level radioactive waste burial
ground. Fifty-eight acres at the Department of Energy's (DOE),
Mixed Waste Management Facility burial ground facility on the
Savannah River Nuclear Plant site were closed during 1989 and
1990. The plant is located near Aiken, South Carolina, with its
South boundary adjacent to the Savannah River.
The contaminated waste had been placed from before 1976
until 1986. This waste was classified as low level to
intermediate level beta gamma waste. It consists of
miscellaneous materials that had been exposed to nuclear
radiation, including clothing, building materials, metal
vessels, pipes, construction equipment, and fluids such as oil
that were mixed with absorbent substances and placed in 55
gallon drums. In some areas, the nuclear wastes were placed in
metal boxes, known on site as B25 boxes. These boxes are
similar to connex containers.
During operation of the burial ground, most of the wastes
had been deposited in a series of parallel trenches which were
20 feet wide by 20 feet deep. Each trench was separated by a 10
to 20 foot berm of natural soil. The B25 boxes were sometimes
stacked in an orderly matrix within a trench. However, this was
not a standard practice and boxes had been randomly dumped into
some trenches. After either the loose mixed waste or the B25
boxes filled the lower 16 feet of a trench, four feet of a sandy
silt material was dumped and spread as an initial closure cap.
No effort was made to compact the waste in the trench or this
soil cap.
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It was observed that the soil cap, which had been shaped to
shed surface water, was settling and water was beginning to
accumulate in the low spots. This was considered undesirable
since there was the likelihood of surface water seeping through
the cap, becoming contaminated from the nuclear deposits and
then percolating downward to the groundwater table. As part of
the permanent closure plan, it was decided to densify the
nuclear waste within the trenches to reduce future settlement.
Densification of the waste by dynamic compaction was the first
step before constructing a new impervious kaolin clay cap.
The closure plan required a cap constructed to RCRA
regulation standards. To meet these requirements, it was
decided to specify a locally available tertiary kaolin clay.
From a test program previously conducted, it had been
established that the kaolin clay, if properly placed, would have
an in-situ permeability of less than 1 x 10 -7 cm/sec.
Design Clay Cap Test Program
Kaolin clay is mined commercially for use in the rubber and
paper industries as an inert filler. The majority of that
commercial production in the United States is from sedimentary
deposits lying along the Georgia/South Carolina "Fall Line."
The "Fall Line" is the common name given to the geologic
boundary between the Piedmont and Coastal Plain Provinces.
Kaolin clay beds of tertiary and cretaceous periods can be found
close to the surface in this region.
In the general area of the Savannah River Plant, there are
kaolin deposits having only a few feet of overburden. However,
overburden stripping depths of 50 ft. are common at many of the
operating open pit mines. Because kaolin is found in such
plentiful supply locally, it was identified as the material of
choice for this project after examining the possible use of
natural on-site clays, importing alluvial clay or the use of
soil bentonite mixtures.
The design test program examined both construction
techniques and resulting cap properties for Tertiary and
Cretaceous age kaolin. It became obvious early that the
Cretaceous kaolin was a sandier and less plastic material.
Therefore, only two test panels were constructed of rthe
Cretaceous clay- These panels proved that it would be very
difficult or impossible to achieve the required 1 x 10 -7 cm/sec
in-situ permeability with the Cretaceous kaolin. The
Cretaceous clay was, therefore, eliminated from consideration.
Tertiary clay from three (3) different active mines in the
Aiken, South Carolina area was used to construct seven (7) test
panels. From each source a panel was constructed at both
250
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standard proctor optimum water content and at two (2) to three
(3) percent wet of optimum. The construction technique for
these six (6) panels was to add moisture to the clay in a
separate conditioning area and then to transport the moisture
conditioned clay to the panel for placement and compaction. The
seventh panel involved a procedure of moisture conditioning
directly on the panel. This eliminated the transport of
moisture conditioned clay.
The Tertiary clays had natural water contents in the range
of 20 to 25 percent. During the test program, two (2) methods,
a stationary Gleason clay shredder and a BROS travelling
recycler, were utilized to break down the blocky chunks of clay
which were delivered from the mines. This size reduction
operation yielded a material having a maximum size of one and
one-half inches. The purpose of the size reduction was to
enhance the kneading effect of the rollers and to speed the
water absorption of the clay by creating more contact surface
area. Standard Proctor optimum water content averaged about
25.5 percent. Therefore, the natural material was always dry of
optimum, making it necessary to add water in order to achieve
the desired placement water content.
The one and one-half inch minus clay was spread in a six
(6) to nine (9) inch thick lift and water was added by
alternating passes of a water wagon and the BROS recycler. The
water wagon did not drive over the clay lift. It was equipped
with a nozzle which allowed spraying of the water onto the clay
while moving along the side of the conditioning area. The clay
was brought up to the desired water content, covered with
plastic and allowed to cure overnight. After this moisture
conditioning, the clay was picked up and transported to the
panel by a CAT 623E elevating, wheel tractor scraper. This is a
365 flywheel horsepower machine which, fully loaded, weighs
129,300 pounds. On the panel, motor graders spread the clay in
a uniform lift. Compaction was with a CAT 815B tamping foot
soil compactor.
Trautwein type, Sealed Double Ring Infiltrometers (SDRI)
were used to test in-situ permeability. A test in each of the
kaolin test panels was run for durations of between 98 and 158
days. The results of those permeability tests demonstrated that
in-situ permeabilities of less than 1 x 10 -7 cm/sec could be
expected if the Tertiary kaolin was compacted at water contents
two (2) to four (4) percent wet of standard Proctor optimum.
The average compaction recorded for the panels was between 94
and 100 percent.
Initial Specifications - Clay Cap Project
The purpose of the project specifications was to insure
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that the constructed kaolin clay cap would have a in-situ
permeability of less than 1 x 10 -7 cm/sec. Because of the time
required to perform in-situ permeability tests, three (3) to
five (5) months, another method had to be specified in order to
allow cap construction to proceed on a production basis, as over
500,000 tons of clay would have to be conditioned and placed in
a time frame of about 18 months. There is a good correlation
between placement water content and density, and permeability
for clay materials. This is well known and documented in the
literature (Lambe, 1955; Lambe and Whitman, 1969; Mitchell et
al, 1965; Mitchell and Jaber, 1990). The Design Test program
provided the water content and density parameters that could
produce the desired permeability end result without the
necessity of in-situ permeability testing.
The critical parts of the original project specification
concerning the kaolin clay cap are reproduced here using the
numbering system of the contract documents.
Specification No. 9513, Section 02290, Earthwork - Clay
Closure Cap
2.1 Products
2.1(c) Cretaceous kaolin shall not be used.
2.2(a) Materials - The clay shall be Tertiary
kaolin clay with the following properties:
2. Liquid Limit per ASTM D4318-84 shall be
between 75% maximum and 55% minimum.
3. Plasticity Index per ASTM D4318-84 shall be
between 44% maximum and 26% minimum.
4. Percent passing a number 200 sieve per ASTM
D442-63 shall be 90% minimum.
3.0 Execution
3.1(a) Preparation - Clay blocks shall be broken down
prior to conditioning to a maximum size of 1-
1/2 inch chunks to insure uniform wetting.
3.2 Installation
(c) Conditioning Requirements - Fill Area
1. Moisture conditioning of the kaolin shall be
conducted to achieve two to four percent wet
of the standard proctor optimum water content.
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2. Clay shall be placed in six (6) inch maximum
thickness unconditioned, loose lift.
3. Method chosen for conditioning should be
capable of penetrating at least two (2) inches
below the unconditioned clay lift to ensure
all the kaolin is moisture conditioned and
stratification between lifts will be
minimized. This does not apply to the first
clay lift placed.
5. See Appendix V for additional requirements.
(d) Clay Compaction Requirements
1. The kaolin clay shall be compacted to a
minimum of 95 percent of standard proctor
(ASTM D698-70), maximum dry density, with
water content of two (2) to four (4) percent
wet of optimum water content.
4. See Appendix V for additional requirements.
3.3 Clay Surface Protection
(a) The fill surface shall be sealed with a drum
compactor prior to the placement of the next
lift. The scarified surface shall be wetted
or dried to adjust the moisture content to the
specified placement range.
(e) Until placement of the soil cover, the fill
surface shall be kept moistened to prevent
shrinkage cracks.
(f) For prolonged delays in placement (weekends,
etc.) the surface shall be protected with a
six (6) inch layer of unconditioned material
or covered with plastic sheets.
3.4 Clay Placement Tolerances
(a) The finished clay cap shall be constructed to
the elevations shown on the design drawings
and shall be a minimum of 36 inches thick.
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(b) A topographical survey of the initial fill*
and the top of the clay layer shall be pro-
vided by the Subcontractor. The survey shall
be based on a 100 ft. minimum grid.
APPENDIX V - REVISION 1, September 23, 1988
Moisture Conditioning of Kaolin: Maximum Loose Lift
thickness is limited to six (6) inches due to the
observed tendency of the lift to fluff up two (2) to
three (3) inches after being recycled at its natural
water content.
Kaolin Placement and Compaction: A minimum of 12
passes with a CAT 815B is required. One pass is
defined as the drum of the compactor passing over a
location. The kaolin should be compacted to a
minimum of 95 percent of standard proctor maximum dry
density at water contents two (2) to four (4) percent
wet of optimum water content.
If the kaolins are moisture conditioned on the existing
fill, the lift surface should be leveled with a motor
grader after by filling in packed footprints with the
loose conditioned clay at the top of the lift prior
to placement the next lift.
Quality Control Test Requirements: There will be an
initial minimum of six moisture density relations on
which to choose the initial water content placement
range which is two to four percent wet of average
optimum water content.
Once the placement water content range has been
determined, the most important soil property to assure
uniformity of compaction is water content. One water
content is required for every 300 square yards in the
conditioning area to assure uniformity of water content
prior to placement and compaction. In the placement
area, uniformity of compaction is confirmed with in-
place nuclear densities with a minimum of one per 500
cubic yards with at least three per day, and at least
one per lift. To determine if the average optimum
water content is valid, one moisture-density relation
is required for each 5000 cubic yards of clay placed.
*The contoured earthen trench cover of on-site
silt upon which the clay was placed.
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Attached and part of Appendix V was Table 1, which presents
the required testing for kaolin clay cap quality control.
A few items in these initial specifications deserve note.
The compaction specification dictated both the method and the
result which had to be achieved: 12 passes with a CAT 815B, 95
percent density. The basis for establishing the acceptable
water content range was an average of the optimum water contents
as determined from the standard proctor curves. The acceptance
water content is to be taken in the conditioning area prior to
compaction. Density was to be confirmed by the in-place nuclear
method. These will be examined in detail in subsequent
sections.
Construction Operations
CLAY PULVERIZATION: The construction of a low permeability
clay liner involving over 500,000 tons of kaolin is basically a
big earthmoving project involving the expected types of
equipment; bulldozers, graders, scrapers, water trucks, and
compactors. There is one critical difference: on a heavy
embankment project, the key objective is maximizing strength and
minimizing compression, while in constructing a clay cap the
objective is to minimize hydraulic conductivity.
The critical construction operations for cap/liner
placement have been identified by research and these were
confirmed again by the design test program.
1. The clay must be broken down into small clods to create
surface area for water contact so that the material can be
remolded into a new homogeneous mass (Elsbury, 1989),
specification 3.1(a), 1-1/2 inch maximum clod size.
2. Water must be added and mixed with the clay in order to
obtain a uniform moisture content two (2) to four (4) percent
above optimum, specification 3.2(3) 1.
3. The moisture conditioned clay should be compacted by a
kneading method, Appendix V, CAT 815 requirement.
Recognizing these requirements, several pieces of equipment
and construction methods were investigated in the field on a
full production basis. The first task was to break down the
large clay clods (up to 18" inches) which came from the mine.
At the mine, clay excavation and the loading of haul trucks was
by hydraulic excavator, a John Deere 892D-LC. The clay was
transported to the jobsite by tandem truck, tandem truck pulling
a short pup trailer and by trailer trucks. The mining and
hauling operations were never a hindrance to production
operations. At the burial ground, the clay was dumped either in
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Table 1. FIELD AND LABORATORY QUALITY CONTROL TESTING REQUIREMENTS FOR CLAY MATERIAL, FROM APPENDIX V - REV. 1,
CONTRACT SPECIFICATIONS, MIXED WASTE MANAGEMENT FACILITY, DOE, SAVANNAH RIVER P1.ANT
ro
01
LAB IDENTIFICATION TEST SERIES INCLUDING:
LOCATION
(1)
BORROW PIT
BEFORE
MINING
DURING
MINING
STOCKPILE
AREA
CONDITION-
ING AREA
PLACEMENT
AREA
WATER CONTENT
ASTH D2216-BO
(2)
ATTERBERG LIMITS
ASTH 04318-84
(3)
MINUS #200 SIEVE
ASTM Dl 140-54
(4)
ONE TEST SERIES FOR EACH MOISTURE-DENSITY RELATION
THREE TEST SERIES WHENEVER CHANGE IN MINING LOCATION
ONE TEST SERIES
FOR EACH MOISTURE-DENSITY RELATION
ONE TEST SERIES
FOR EACH MOISTURE DENSITY RELATION
FIELD QUALITY CONTROL TESTS
MOISTURE
DENSITY RELATION
ASTH D698-78
(5)
THREE FROM FACE
BEING MINED
THREE FROM INITIAL
500 TONS DELIVERED
ONE/ 5000 CU YD
ADJACENT TO IN-
PLACE SAND CORE
DENSITY
ONE POINT
DENSITY
(6)
ONE/ EACH
NUCLEAR
DENSITY
NUCLEAR DENSITY
ASTM 02922-81
(7)
ONE/500 CU YD;
AT LEAST 3 /DAY,
AT LEAST I/DAY
WATER CONTENT
ASTM D2216-BO
(8)
ONE /1 000 TONS
ONE/ 300 SQ YD
IN -PLACE
SAND CONE
DENSITY
(9)
ONE/5000 CU
YD ADJACENT
TO IN-PLACE
NUCLEAR
NOTES:
1. In the conditioning area, microwave water contents on 100 gram ninin
contents.
2. Perform tn-place density tests at the base of compactor footprints.
3. Test results shall be filed with owner's representative dally.
clay samples may be used in place of ASTM D2216-80 oven dried water
-------
the panel construction area or at a stockpile location. The
freshly mined clay material had many large chunks.
If the clay was placed directly for cap construction, a CAT
D6 bulldozer was used to level the pile and smooth the material
into the specified six (6) inch lift. Major size reduction was
accomplished during this leveling, as chunks were broken down by
the weight and motion of the dozer. The dozer tracks would
bridge across low spots and place all contact pressure on the
largest chunks; these were the high points causing the
bridging. This would crush the largest chunks. After leveling
by the dozer, the material could be classified as six (6) inch
minus; therefore, further size reduction was still necessary. A
Howard rotavator accomplished the final size reduction during
the early clay cap construction. A rotavator is nothing more
than an oversized garden tiller. It has thirteen rows of three
tines per row for a total of 39 tines. The ones used on this
project were eight (8) feet in width, pulled by 140 HP farm
tractors, and powered by the tractor's PTO. The tractors could
pull through natural water content clay for pulverization work
at a speed of 175 ft/min. Clod reduction was accomplished by
mechanical pulverization.
A Gleason Shredder was used for a limited time on the
project. This same type machine had been tried during the
design test program. The shredder is a revolving blade with
teeth; it cuts the clay into the desired size in the same manner
as a meat grinder. It did a very good job of producing a
material within the desired size range. The drawback and
primary reason it was not used for mass production was the
shredder's pass through tonnage limitation. With the blade set
to operate at the project's required 1-1/2 inch maximum size
limit, pass through production was only 140 tons per hour.
The shredder added extra material handling steps to the
production process. For a short duration, the clay was loaded
directly into the shredder during excavation. The shredded
clay fell onto a fast revolving belt which would sling the clay
chips into a stockpile. A wheel loader was then used to load
the trucks for the haul to the jobsite. The other option was
not to change the mining and hauling operation of the raw clay,
but to build a stockpile at the burial ground, and use a loader
to feed the shredder from that stockpile. The shredder would
then create a second stockpile of sized material from which
self-loading scrapers would haul to the panels. This method of
operation was tried for about one month.
The final method examined and the one used throughout most
of the clay cap construction was mechanical pulverization by a
CAT SS-250 soil stabilizer. As with the rotavators, the
pulverization was accomplished after the raw clay had been
257
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leveled into a six (6) inch lift by the dozer. The SS-250 had a
working speed of 88 ft/min, or about half that of the farm
tractor-pulled rotavators, but the required pulverization could
be accomplished in half the number of passes. There are twice
the number of tines on the SS-250, thirteen rows of six (6)
tines per row. Experiments With both up-cutting and down-
cutting rotors were tried over the course of the project. The
best results were obtained using chopper tines and up-cut
rotation with the rear door closed. Maximum clod size would
increase as the door opening was increased. Typically, two (2)
passes with the SS-250 were necessary to bring the clay down to
the 1-1/2 inch maximum size requirement. However, in some
locations three (3) passes were necessary. This was usually
caused by the fact that when operating uphill, the operator
would have to increase the rear door opening.
On a normal stabilization project, the SS-250 will operate
at average propel pressures of about 2250 psi. Working the
kaolin on a flat surface up-cut mode, the propel pressure was
3500 psi. While on a seven (7) percent grade, the pressure
would go up to 3700 psi. The machine has a pressure override
value which is set at 3700 psi; therefore, when going uphill,
the operator would have to increase the opening of the rear door
to avoid stalling. The down-cut mode would have been easier on
the machine, only 2200 psi uphill, but pulverization was not as
good and the clay would stick to the rear door causing other
problems. In fact, even operating up-cut, severe pressure was
placed on the rear door. The rear door cylinder had an average
life of only 850 operating hours.
MOISTURE CONDITIONING: Once the clay had been processed so
that no individual clods were larger than 1-1/2 inch, moisture
conditioning could begin. The first efforts were crude, simply
having a standard water truck make multiple passes over the
pulverized clay until it became too slick for passage. Then
farm tractor rotavators would make a couple of passes to mix the
clay and water. After this mixing, the water truck could make
about two (2) more passes and then it became a sequence
operation of rotavator pass, water truck pass. It did not take
long to realize that multiple water truck passes without mixing
passes by the rotavator made for a situation where the water
collected in the tire ruts and those areas forever afterwards
had water contents higher than the mass of the panel. Another
problem with standard water trucks was that more water came out
at the middle of the spray bar where the pipe from the tank
connected than at the ends of the bar.
To get uniform coverage along the spray bar, a special bar
and pumping system was placed on each water truck. The spray
bar was a continuous loop system on these trucks and there was a*
circulating pump system so that the pressure at each nozzle was
258
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approximately the same. This solved the problem of uniform
coverage from the bar. To eliminate the problem of water
collecting in the ruts, it became standard operating procedure
to follow directly behind the water truck with either the
rotavator or the SS-250 stabilizer. By following directly, it
is meant that the truck and mixer operated in tandem usually
with no more than 10 feet of clear distance.
One other method of introducing the water was experimented
with for a few days. The SS-250 has an internal water spray
system. Water is introduced by a hose connection on one side of
the machine. A water truck must, therefore, drive alongside the
stabilizer, with the two machines connected by hose. This
internal SS-250 system exhibited the same problem as the spray
bar, the nozzles closest to the point where the water was
introduced put out more water than the nozzles on the end.
Uniform wetting could not be achieved.
The adopted production procedure was: (a) use the special
water trucks to add water with the rotavator following directly
behind for the early passes; (b) as the water content of the
clay increased, a point was reached where the farm tractor and
rotavator did not have the necessary power to thoroughly mix the
clay, at that point, the SS-250 would take over behind the water
truck; (c) once all the water had been added, the SS-250
stabilizer would make two (2) additional passes to complete the
mixing.
From moisture content tests of the pulverized clay, the
amount of water which had to be added could be calculated. All
of the water trucks had metering systems. The problem was not
figuring how much water to add in order to reach the specified
moisture content, but estimating the amount of evaporation which
would take place in the time interval required to add the water
and complete compaction. During a summer day shift, the amount
of extra conditioning water necessary to make up for evaporation
loss was about 3.2 gal/ton. Operations at night required only
0.8 gal/ton extra. Other factors which had to be considered
were direct sunshine and wind.
COMPACTION: A CAT 825 tamping foot compactor was tried on
the project. Considering the drum width and assuming one inch
of contact surface along that width, the contact pressure of the
CAT 825 is about 1.4 times that of the CAT 815. With the kaolin
conditioned to two (2) percent wet of optimum or higher, the
feet of the CAT 825 would be pushed completely down into the
moisture conditioned clay. The clay would then stick to the
drum and with the forward motion of the compactor, the newly
placed upper lift would be pulled up and torn away from the
previous lift. Operations with the CAT 825 were, therefore,
not satisfactory and all further compaction was with the 44,175
259
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Ib., CAT 815 compactor.
A 10 -7 Cm/Sec Product
The desired product was a kaolin clay cap which would have
an in-situ permeability of less than 1 x 10 -7 cm/sec. Quality
control, testing and acceptance of the in-place clay was by a
third party QC organization reporting to the project
construction management organization. Neither the construction
contractor, the construction manager, or the QC organization
could change or even interpret the contract specifications. For
a moisture conditioned and compacted panel of clay to be
accepted, it had to meet the LETTER of the specifications.
This type of construction quality control/acceptance is to
be expected when dealing with nuclear or hazardous materials.
But when this situation exists, the design engineer must
understand the nature of the materials being handled and
limitations in testing precision. The written specifications
must be such that every individual part of the construction
process is addressed in a realistic manner. No designer can
foresee every possible situation, therefore, provisions should
be built into the specifications which establish procedures to
resolve unique situations.
As an example of the unique situations which can occur
during waste projects, density could not be obtained on the
initial lifts in one specific area of the burial ground. At
first, it was thought that the maximum allowable lift thickness
had been exceeded and that was causing the problem. There was,
also, some question as to the quality of the clay. The kaolin
was removed and fresh clay was brought from the mine. The
results were no better; density was not achieved. It should be
remembered that Appendix V had specified the use of in-place
nuclear densities to confirm compaction, Table 1, Column 7.
Finally, special sensitive radiation testing equipment was used
to check the background readings from the buried waste. In this
particular area, the background radiation was slightly greater
and it was affecting the nuclear density meters. This was only
noticeable during testing of the first one or two lifts. The
testing in this area had to be changed to the sand cone
procedure for all density tests.
Compaction difficulties were encountered because of the
double specification, method and result. At the higher water
contents, 12 passes with the CAT 815 compactor caused an over-
rolling situation in terms of dry density. The density actually
began to decrease after about 8 passes. Specifications should
never be written in this manner. If density is the critical
parameter, that is what the designer should require. In this
260
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case, density was being used because of its correlation to
permeability from the test program. However, in the case of
liners, where clay soils are compacted wet of optimum, density
alone may not be a good gauge of permeability. It has been
found (Mitchell et al, 1965) that even though the dry density of
a compacted soil did not measurably increase with the
application of more compactive energy, the hydraulic
conductivity could be lower by a factor as high as 100. This
can be attributed to the kneading action of the additional
compactive effort.
When dealing with soils, more passes are not always better
in terms of dry density but they can lower the permeability.
This is a critical decision in establishing cap/liner
specifications and that decision must be made by the design
engineer, it cannot be imposed on the construction contractor by
an impossible double specification. On this particular project,
the decision was made to reduce the required number of passes to
eight, Appendix V - Rev. 13, and to change the minimum dry
density of 93 percent if the water content was greater than four
percent wet of representative optimum, 3.2(d)l.e, Rev, 13,
The required six (6) inch maximum lift thickness,
specification 3.2(c)2., caused problems initially. When a six
(6) inch kaolin clay lift was laid down as the first lift on top
of the trench cover, the kaolin would become contaminated with
the red sandy silt from below during the mixing and compaction
operations. The tines of the rotavators or the SS-250 would cut
into the lower layer where the kaolin lift was not the maximum
six (6) inches. The feet of the CAT 815 would puncture through
the kaolin and pull the red silt up into the white clay.
Because of the color difference between the two materials,
contamination was always easily discerned. The specification
did not allow for a thicker lift, and full mixing and compaction
were required. Mixing could have been achieved on top of the
other panels and the condition material hauled to the initial
placement panel as was done during the design test program.
Such a procedure would not have solved the compaction problem.
An alternate would have been to compact the initial lift with a
smooth drum roller, but that would have eliminated the important
kneading action during compaction. The adopted solution was to
allow a ten (10) inch initial lift, to condition that lift to a
depth of eight (8) inches and to retain the use of the tamping
foot roller, Rev. 12, Specification 3.2(c)6.
The Clay Closure Cap specifications addressed the
preparation, placement and compaction procedures for
construction and specified the minimum required quality control
testing for each stage of the work, Table 1. In Appendix V,
Rev. 1, under Quality Control Test Requirements, the water
content placement range was spelled out as "....two to four
261
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percent wet of average optimum water content." Procedures for
moisture conditioning prior to compaction were specified. Water
content tests were required in the placement area. Only density
tests and standard Proctor or one point compaction tests were
required in the placement area. The density tests were for
evaluation of the uniformity of compaction, while the Proctor or
one-point compaction tests were to confirm the validity of the
assumed optimum water content.
It was very clear that the intent of the initial
specifications was to establish the uniformity of the water
content prior to compaction and to check only the density after
compaction. If confirmation of the uniformity of the water
content after compaction was intended, water content tests would
have been required in the placement area. This is not an
unusual procedure. Daniel (1990) uses almost the exact same
statement, as contained in Appendix V, when he addresses water
content quality control for compacted soil liners. "The soil
must be within the proper range of water content prior to
compaction." Whereas, the Appendix V statement is "One water
content is required for every 300 square yards in the
conditioning area to assure uniformity of water content prior to
placement and compaction."
The specifications required six Proctor compaction tests,
three at the borrow area and three at the stockpile, for
selection of an initial average optimum water content and an
initial moisture content placement range, which was to be two to
four percent wet of the average optimum water content.
Additional standard Proctor compaction tests were required after
compaction "to determine if the average optimum water content is
valid." However, when a test did not confirm the validity of
the average, it was was not clear how the information was to be
used. Should it alter the acceptable water content range for
the specific section being evaluated or should it alter the
average optimum water content and placement range for future
compacted sections or both? Also, a one-point compaction test
was required in conjunction with each nuclear density test on
the compacted fill. The purpose of these tests was not stated
in the specifications, but their primary function would be to
provide additional estimates of the optimum water content and
maximum compacted dry density of the compacted fill.
The quality control procedures initially employed by the
inspectors deviated from the specifications in at least one very
significant aspect. The water content measurements during
conditioning were designated "for information only," and a
second set of "official" water content tests were made after
compaction. Water contents were reported to the nearest 0.1
percent, and acceptance of a specific compacted section required
all "official" water contents to be 1.5 to 4.5 percent wet of
262
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the predetermined average optimum water content, which
presumably was based on one or more standard Proctor compaction
tests.
Variability of Kaolin Clay
COMPACTED TEST PANELS: During the Design-Clay Cap Test
Program, three test panels Bl, B2, and B3 had been constructed
using clay from the same source as was used for project
construction. The variability of the test results for those
panels was particularly relevant to the interpretation of the
earthwork specifications. The average optimum water content
from standard Proctor tests of the kaolin was 26.8 percent, but
the individual test results varied from 24.2 to 29.2 percent.
At the same time the water contents of the compacted fill varied
from 26.4 to 32.8 percent, and these values were reported to be
from 1.7 to 6.8 percent above their respective optimum water
contents. Moreover, the standard deviations of the water
contents for each test panel ranged from 1.1 to 1.3 percent, and
the standard deviations of the differences between the field
water content (wf) and optimum (WQ t) were 1.0 to 1.6 percent.
The significance of the standard deviation is that
approximately two thirds of the test results should be expected
to be with + one standard deviation of the mean value. This
means that for test panel B3, for which (wf - w f.) had a mean
of 2.9 percent and a standard deviation of 1.0 percent, only
about two thirds of the measured water contents were two to four
percent wet of optimum. For the other two panels, the mean
values and standard deviations of (wj - wOpt) indicate that
significantly less than two thirds of the measured water
contents were in the range of two to four percent wet of
optimum. It is important to note that all of these test panels
satisfied the permeability criteria for the clay cap, Table 2.
CONSTRUCTION TEST DATA: During a one-month period early in
the project, more than 50 percent of the clay panels tested
were rejected because one or more of the "official" (after
compaction) water contents were not within the range of 1.5 to
4.5 percent wet of the established average optimum. In every
case, the conformance of the compacted density and water content
to specifications was evaluated on the basis of an optimum water
content of 25.6 percent and a maximum dry density of 95.9
Ib/cu. ft. Approximately 90 percent of the 44 reports showed
nuclear moisture and density results in conformance with
specifications. Only one case of inadequate density and high
water content was found. Four nuclear tests were designated as
nonconforming because the water content was less than 1.5
percent wet of the established optimum.
263
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Table 2. SUMMARY OF INFILTROHETKR TEST DATA. DBSICN-CI.AY CAP TEST PROGRAM
MIXED WASTE MANAGEMENT FACILITY. DOE, SAVANNAH RIVER PLANT
•ANEL
NO.
(1)
Al
A2
111
112
IS 3
Cl
C2
1)1
1)2
KAOLIN
CLAY
TYPE
(2)
CYPRUS
TERT
DIXIE
TERT
UUBER
TERT
CYPRUS
CRET
START OF
TEST
(3)
10/22/87
12/02/87
10/15/87
10/28/87
01/12/88
11/16/87
11/23/87
11/12/87
12/03/87
NO. OF
TEST
DAYS
(4)
134
98
141
124
101
158
106
117
141
AVERAGE
WATER
CONTENT
W (1)
(5)
27.0
30.6
29.6
30.7
29.4
26.8
29.8
24.6
22.7
AVERAGE
"«>"<»<
(6)
-1.3
2.0
3.5
3.6
2.9
0.4
2.7
3.4
2.0
AVERAGE Z
STANDARD
PROCTOR
COMPACTION
(7)
105
100
94
98
98
103
100
98
97
FINAL
INFILTRATION
RATE
(cm/sec x 10-7)
(8)
2.3
0.48
0.96
0.85
1.3
1.8
0.70
5.1
6.8
FINAL
WETTING
FRONT
DEPTH (la)
(9)
25.0
25.0
20.5
23.0
28.0
27.0
28.0
28.5
34.0
FINAL FIELD
PERMEABILITY
K(fleld)
(en/sec x 10-7)
(10)
1.6
0.32
0.61
0.56
0.91
1.2
0.49
3.6
5.0
AVG. LAB
PERMEABILITY.
K(lab)
cm/uec x 10-7)
(11)
0.81
0.28
0.34
0.25
0.27
0.34
0.43
1 .6
1.7
C73
NOTES:
1. All infiltrometer tests performed with a scaled double ring infiltrometer with a 12 foot square outer ring and a 5 foot square inner ring.
2. For all test panels, the final wetting front depth is equal to the total depth of compacted clay fill.
-------
An analysis of the 300 "official" water contents included
in this data base showed a mean water content value of 28.6
percent and a standard deviation of 1.5 percent. The mean
value was 3.0 percent wet of the established optimum, and, when
rounded to the nearest 0.5 percent, 76 percent of the water
contents were within the specified range of two to four percent
wet of optimum. Thus the compacted fill represented by this
data base was at least as uniform as the design test panels.
A plot of the moisture-density data, Fig. 1, from the
nuclear density tests shows the test data clustered along a line
roughly parallel to and wet of the "line of optimums" from the
test panel data. There is evidence in the literature to suggest
that this line represents moisture-density conditions of
approximately equal permeability-
EFFECT OF KAOLIN NATURAL VARIABILITY: Another important
factor was that the specifications, as initially applied, failed
to recognize the natural variability of the kaolin. Proctor
curves had shown optimum water content values from 24.1 to 27
percent. The chosen average optimum value was 25.6, which in
turn set the acceptability limits at between 27.6, plus two, and
29.6, plus four percent. This decision to use the average as a
benchmark presents several problems. Consider the case of a
batch of clay actually having an optimum of 24.1 percent. To
provide the required permeability, the clay would have to be
placed at a water content of between 26.1 and 28.1 percent.
However, by the written specification, any panels having test
below 27.6 would be rejected, this forced unnecessary rework of
acceptable clay. Now consider if the clay actually had an
optimum of 27 percent. In order to meet the minimum plus two
percent criteria, this clay would, as a minimum, have to be
placed at a 29 percent water content. In this case, clay which
was not even conditioned to plus two percent of its natural
optimum would be accepted by the average 27.6 minimum criteria.
These facts are diagramed in Fig. 2 based on the project data
discussed in the preceding paragraphs.
The correct criteria should look at the relationship
between water content and density. Plotting the test point, as
in Figures 1 and 2, will prove if the condition clay is
acceptable; it must fall within the band of the line of optimums
and the saturation line. Recognizing the situation, the clay
cap specifications were revised over the course of the project.
The revised specifications are presented in the following
section. These criteria, which are consistent with the
recommendations of Daniel (1990), provide a good guide for
future clay cap or liner specifications. The constraints and
the capabilities of large scale production oriented construction
operations are addressed and the variability of the clay and
testing precision are accounted.
265
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FIG. 1. Moisture-Density Data from Nuclear Density Test during
October 1989, Kaolin Clay Cap, Mixed Waste Management Facility,
DOE, Savannah River Plant
266
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RANGE of
QCla>
I
h-
DESI6N TEST
LINE
-------
PRECISION OF WATER CONTENT TESTS: The precision of the
testing procedures is recognized in the revised specifications.
Both optimum and field-compacted water content values are
rounded to the nearest half of one percent, 3.2(3)1.a. and h.,
and variance and retesting procedures are established
3.2(d)l.g., 3.7 and 3.8. More research needs to be performed to
address the precision of water content testing Of clay
materials. During the course of the project, samples were split
and separate water content tests were performed on each half.
Differences as great as 3.7 percent were noted. The average
difference was about 1.8 percent. If the water content values
were rounded to the nearest half of a percent, the average
difference was about 1.5 percent. A specification, which is
strictly enforced, that restricts the water content to a two (2)
percent range in combination with a test procedure that has a
precision range of 1.5 percentage points causes problems in the
field.
Revised Clay Cap Specifications
As the Kaolin clay placement operations progressed, changes
were made to the original specifications. The most significant
changes, are presented here, and as in the first Project
Specification section, the contract numbering system is
retained.
3.2 Installation
(c) Conditioning Requirements - Fill Area.
1. Moisture conditioning of the Kaolin shall be
conducted so as to achieve the water content
requirement, after compaction, as specified in
Section 3.2(d). Water content testing after
conditioning and prior to compaction shall be
for information only.
6. Place initial loose clay lift to a maximum ten
(10) inch thickness above the top of the
initial fill as defined by the recorded
topographical survey and to a thickness not to
exceed thirteen (13) inches. The top of the
lift shall be consistent in slope with the
contract drawings. The clay shall be con-
ditioned to a depth of eight (8) inches or two
(2) inches above the top of the initial fill.
No nuclear density test will be performed on
the initial clay lift. Compaction is to be
performed by a sheepsfoot roller. (This
entire paragraph was added.)
(d) Clay Moisture and Compaction Requirements.
268
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1. The Kaolin clay shall be compacted to the
following minimum compaction and moisture
content criteria:
a. The representative standard proctor opti-
mum water content and maximum dry density
that form the basis for clay placement is
to be selected by the Customer's Design
Engineer. This is based on the Design
Engineer's evaluation and judgment of stan-
dard Proctor compaction curves, one point
dried back compaction tests and the physi-
cal condition of the clay at placement
water content. The representative optimum
moisture content shall be rounded to the
nearest 0.5%.
b. The acceptable average water content range
for clay placement is one to six percent
wet of the representative optimum water
content. However, it is acceptable to have
one sample greater than six percent wet of
optimum water content.
c. The acceptable average water content is two
to four percent wet of the representative
optimum water content. Exclude one allow-
able sample greater than six percent wet of
optimum water content in determining the
average water content.
d. The minimum acceptable dry density for an
in-situ density test with a water content
between one percent and four percent wet of
the representative optimum water content is
95 percent of the representative standard
Proctor maximum dry density.
e. The minimum acceptable dry density for an
in-situ density test with a water content
greater than four percent wet of the repre-
sentative optimum water content is 93 per-
cent of the representative standard Proctor
maximum dry density.
f. The number of tests deviating from the
acceptable water content range (per
Specification 9513, Section 2290, 3.2(d),l,
b, c, d, and e) and the resampling guide-
lines (per Water Content Resampling Guide-
269
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lines, Specification 9513, Section 2290,
3.7 and In-Situ Density Retesting Guide-
lines, Specification 9513, Section 2290,
3.8), are based on the size of the
Subcontractor's average placement areas,
i.e., a maximum of 1,400 square yards. If
the Subcontractor significantly increases
the maximum size of his placement areas the
Design Engineer shall be notified for
review and redefinition of the guidelines.
g. The Customer's Design Engineer or his
approved designee may allow a variance
based on engineering judgment for Speci-
fication 9513, Section 2290, 3.2(d)
moisture content requirements. This vari-
ance will provide at Design's* discretion,
a means to accept lifts that are techni-
cally acceptable but fail to met special
moisture content requirements. All vari-
ances shall be approved and documented by
the Design Engineer or his designee.
Design shall reserve the right to reject
any or all requests for variances. Design
shall submit the variance form with Ebasco
Test Report for each lift for which the
variance was requested. The Report will
indicate that the test for that lift was
accepted without meeting the specified
moisture content requirements and filed
accordingly with the variance approval
attached. Lifts that fail to meet Section
2290, 3.2(d) moisture requirements shall be
in conformance with Specification 9513,
upon approval of a variance by Design.
h. The moisture content test shall be rounded
to the nearest 0.5%. See Appendix V. A
minimum of ten moisture tests are required
per placement area.
i. The nuclear density percent compaction
value shall be rounded off to the nearest
0.5%.
6. A one point dried back compaction test shall
be obtained (by others) in the third and fifth
*Design as used here means the design
engineering organization for the project.
270
-------
lift and any other lift as directed by
Customer's Design Engineer.
3.7 Water Content Resampling Guidelines (Performed
by Others)
(a) Where the water content samples for a clay
placement area are not within the acceptable
water content range, resampling is permitted.
Resampling consists of obtaining two addi-
tional samples in the vicinity of a non-
conforming tests. The new water content is
determined by averaging the two additional
test samples and replaces the non-conforming
tests.
1. If the water content of one test sample is
less than one percent wet of optimum water
content, resample in the vicinity of the non-
conforming test. If the resample water
content is within the acceptable water con-
tent range, disregard the non-conforming water
content.
2. If the water contents of the two test samples
are greater than six percent wet of optimum
water content, resample in the vicinity of
each non-conforming test. If both resample
water contents are within the acceptable water
content range, utilize both to determine if
the placement area is in conformance. If one
of the two resamples falls within the
acceptable water content range, the non-
conforming resample shall be disregarded. If
both resample water contents are outside of
the acceptable water content range, the
placement area is in non-conformance.
3.8 In-Situ Density Retesting Guidelines (Per-
formed by Others)
(a) Where the water content of the in-situ density
test sample for a clay placement area is less
than one percent wet of optimum water content
or the water content of the in-situ density
test sample is greater than six percent wet of
optimum water content and the dry density does
not meet the minimum requirements, an in-situ
density test is permitted.
1. If the water content of the in-situ density
271
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test is less than one percent wet of optimum
water content, retest within the vicinity of
the original test. If the water content for
the retest is within the acceptable water
content range, disregard the initial in-situ
density test.
If the water content of the in-situ density
test or retest is greater than six percent wet
of optimum water content, no retesting is
necessary if the dry density meets the minimum
requirement.
If the water content of the in-situ density
test is greater than six percent wet of opti-
mum water content and the dry density is less
than the minimum requirement, retest within
the vicinity of the original test. If the dry
density of the retest meets the minimum
requirement, disregard the non-conforming
test.
If water content of the in-situ density test
is within the acceptable range and the test
fails the dry density criteria, the Subcon-
tractor shall continue compaction efforts,
until the material meets the dry density cri-
teria.
APPENDIX V - REVISION 13, August 24, 1990
Kaolin Placement and Compaction: A minimum of 8 passes
with a CAT 815 sheepsfoot compactor or engineer-
approved alternate method is required. Additional
passes may be required to satisfy density requirements.
The CAT 825 sheepsfoot compactor is not an engineer-
approved alternate method. One pass is defined as a
compactor drum passing over a location one time. The
speed of the CAT 815 shall be less than 5 miles per
hour. The front and rear drums of the CAT 815 must be
offset from each other so that the feet do not fall
within the same imprint or along the same parallel
track. The kaolins shall be compacted to the minimum
compaction and water content criteria required by
Specification 9513, Section 2290, 3.2(d). An engineer-
approved single drum sheepsfoot compactor is allowed
for ditch and tightly spaced clay panel applications.
The Ingersoll-Rand SD100F is considered an engineer-
approved single drum sheepsfoot compactor. Specified
density requirements shall be met using the smaller
272
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compactors.
Quality Control Test Requirements: Once the placement
water content range has been determined, the most
important soil property to assure uniformity of
compaction is water content. Therefore, one water
content is required for each 100 tons of clay delivered
to the stockpile area to determine the average water
content of the clay as delivered. One water content is
required for every 300 square yards in the condition-
ing area, as requested by the Subcontractor, to assure
uniformity of water content prior to placement. One
water content shall be required for every 100 square
yards after compaction in the placement area. In the
placement area, uniformity of compaction is also
confirmed with in-place nuclear densities with a
minimum of one per 500 cubic yards or at least one per
lift. To confirm by direct method the reliability of
the nuclear densities, one in-place sand cone density
is required for every 5000 cubic yards placed. These
tests should be performed adjacent to the in-place
nuclear density tests. To determine if the
representative optimum water content is valid, one
moisture-density relation is required for each 5000
cubic yards of clay placed (in conjunction with the
sand cone density test).
Attached and part of revised Appendix V was Table 3, which
presents the revised testing requirements.
Conclusions
Under the revised specification and employing the methods
previously described, one crew would average 1000 tons of kaolin
cap conditioned and compacted per ten (10) hour shift. May was
the best production month with the crews averaging 1200 tons per
ten (10) hour shift. In the heat of the South Carolina August,
average crew production was only 960 tons per ten (10) hour
shift. As previously stated, evaporation loss during the day
shift was four (4) time as severe compared to moisture lost at
night. Correspondingly, night shift production was about ten
(10) percent greater than that achieved by the day shift. In
total, some 541,000 tons of kaolin clay went into the closure
cap.
Based on the experience and data from placing thos 541,000
tons of kaolin cap over this 58 acre site, it is concluded that:
1. Using standard heavy/highway construction equipment,
raw clay can be:
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Table 3. FIELD AND LABORATORY QUALITY CONTROL TESTING REQUIREMENTS FOR CLAY MATERIAL, FROM APPENDIX V - REV.
CONTRACT SPECIFICATIONS. MIXED WASTE MANAGEMENT FACILITY. DOE. SAVANNAH RIVER PLANT
13.
LAB IDENTIFICATION TEST SERIES INCLUDING i
LOCATION
(1)
BORROW PIT
BEFORE
MINING
DURING
MINING
STOCKPILE
AREA
CONDITION-
ING AREA
PLACEMENT
AREA
WATER CONTENT ATTBRBERG LIMITS MINUS t200 SIEVE
ASTH D2216-BO ASTM D431B-84 ASTM D1140-54
(2) (3) (4)
ONE TEST SERIES FOR EACH MOISTURE-DENSITY RELATION
THREE TEST SERIES WHENEVER CHANGE IN MINING LOCATION
ONE TEST SERIES FOR EACH MOISTURE-DENSITY RELATION
ONE TEST SERIES FOR EACH MOISTURE-DENSITY RELATION
FIELD QUALITY CONTROL TESTS
MOISTURE
DENSITY RELATION
ASTM 0698-78
(5)
THREE FROM FACE
BEING MINED
THREE FROM INITIAL
500 TONS DELIVERED
ONE/5000 CU YD
ADJACENT TO
IN-PLACE SAND CORE
ONE POINT
PROCTOR
(6)
ONE/EACH
THIRD AND
FIFTH LIFT
OR AS
DIRECTED BY
FIELD
ENGINEER
IN-PLACE
NUCLEAR DENSITY
ASTM D2922-81
(7)
ONE/500 CD YD
AT LEAST I/LIFT
WATER CONTENT
ASTM 02216-80
(8)
ONE/ 100 TONS
(IF STOCKPILE
IS USED)
ONE/ 300 SQ YD
(FOR INFORMA-
TION ONLY)
ONE/ 100 SQ YD
IN-PLACE
SAND CORE
DENSITY
(9)
ONE/5000
CU YD
ADJACENT
TO IN-
PLACE
NUCLEAK
DENSITY
-------
a. Pulverized to minus 1-1/2 inch chunks.
b. Moisture conditioned.
c. Compacted by fully-penetrating feet which knead the
clay for the full lift depth.
2. Uniform moisture application and conditioning requires
special water truck distribution systems.
3. Specifications must fully take into account the natural
variability of the selected capping or liner soil.
4. Moisture operations can be better controlled during
night operations.
5. There are limits to soil testing precision which must
be understood when developing project specifications.
6. Compaction procedures and acceptance criteria must be
designed to produce moisture-density conditions that
ensure levels of hydraulic conductivity- The appropri-
ate acceptance criteria may be quite different from
those required for stability of conventional earth
embankments.
Acknowledgements
The authors wish to thank Miss Ann M. Schexayder, Nello L.
Teer Company, for her efforts in assembling and sorting the raw
field data from which this paper was developed. Mr. Jeff Newell
of Chas. T. Main, Inc., was very helpful in providing a copy of
his unpublished presentation, "Clay Cap Test Program for Mixed
Waste Management Facility Closure at the Savannah River Site,"
which was given at the Vail, Colorado 1989, AEG meeting. Much of
the information presented in the "Design Clay Cap Test Program,"
section originated with Mr. Newell. A special word of
appreciation goes to Ms. Carine Fuller who typed this text and
all of the correspondence during project construction.
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APPENDIX I - REFERENCES
Daniel, D.E., (1990), "Summary Review of Construction Quality
Control for Compacted Soil Liners," Waste Containment Systems:
Construction, Regulation, and Performance, ASCE, Geotechnical
Special Publication No. 26, pp. 175-189.
Elsbury, B.R., and Sraders, G.A. (1989), "Building a Better
Landfill Liner," Civil Engineering, ASCE, Vol. 59, No. 4, pp.
57-59.
Lambe, T.W., (1955), "The Permeability of Compacted Fine Grained
Soils," ASTM, Special Tech. Pub. No. 163.
Lambe, T.W., and Whitman, R.V., Soil Mechanics, John Wiley and
Sons, Inc., Chap. 19.
Mitchell, J.K., Hooper, D.R., and Campanello, R.G., (1965),
"Permeability of Compacted Clay," Journal of the Soil Mechanics
and Foundations Division, ASCE, Vol. 91, No. SM4, pp. 41-65.
Mitchell, J.K., and Jaber, M., (1990), "Factors Controlling the
Long-Term Properties of Clay Liners," Waste Containment Systems:
Construction, Regulation, and Performance, ASCE, Geotechnical
Special Publication No. 26, pp. 85-105.
27R
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LESSONS LEARNED FROM REMEDIAL DESIGN
OF THE HELEN KRAMER LANDFILL SUPERFUND SITE
Vern Singh, P.E.
James Lanzo, P.E.
URS Consultants, Inc.
282 Delaware Avenue
Buffalo, New York 14202
(716) 856-5636
The Helen Kramer Landfill Superfund Site, in Gloucester County, New Jersey, is currently
undergoing remedial action. The remedial design was developed by URS Consultants, Inc., under a
Title I services contract to the U.S. Army Corps of Engineers, Kansas City District. The construction
is being carried out by IT-Davy, a joint venture of International Technology Corporation (IT) and
Davy McKee Corporation (Davy). As part of Title II services, URS is providing shop drawing review
and engineering services during construction.
The site was ranked fourth on USEPA's National Priorities List. It includes a 66-acre refuse area and
an 11-acre stressed area adjacent to a perennial stream, tributary to the Delaware River. The
remedial action contract, in the amount of $55.7 million, represented the second largest single contract
under the Superfund program at the time of award.
The remedial action includes an active gas collection and treatment system, a multilayer clay cap, a
soil-bentonite slurry wall around the entire site, a leachate/groundwater collection system, and an
onsite, 120-gpm pretreatment facility.
The design of the Helen Kramer Landfill Superfund Site remedial action is instructive at several
levels. It comprises almost all those elements of remedial action that apply to containment and
isolation of uncontrolled sites. It includes elements that are normally used to protect important
potable water aquifers and surface water streams. The design process was enhanced by a
comprehensive Value Engineering study, one ot the first Superfund remedial designs to include such
a feature. In all aspects, it was a very thorough effort on the part of all parties involved, and resulted
in complete and clear construction bid documents. The process, however, was also instructive in
unexpected areas, principally in the areas of access and real estate issues, interagency agreements, and
the impact that these matters can have upon scheduling.
INTRODUCTION
On May 30, 1986, the U.S. Army Corps of Engineers (USAGE), Kansas City District, awarded a
contract (USAGE Contract No. DACW41-86-C-0113 ) to URS Consultants, Inc. (formerly URS
Company, Inc.), to design the Remedial Action at the Helen Kramer Superfund site. The design
process comprised five discrete phases, with a delivery date scheduled for each phase. URS had also
been authorized to conduct a Value Engineering study during design. The actual submittal dates for
each phase (including the Value Engineering study), along with the originally scheduled dates, are
shown in Table 1. The contract was advertised for bid by USAGE on May 22, 1989, and awarded to
the IT-Davy Joint Venture on October 6, 1989, with Notice to Proceed on November 13, 1989. At
the time of this writing, construction is about 50 percent complete.
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TABLE 1
SCHEDULED VS. ACTUAL MILESTONE DATES
HELEN KRAMER LANDFILL REMEDIAL DESIGN
SCHEDULED
PHASE I
PHASE II
PHASE III
VALUE ENG.
PHASE III
PHASE IV
PHASE V
START
6-16-86
8-5-86
11 -8-86
-
-
1-27-87
4-17-87
SUBMITTAL
7-16-86
10-19-86
1-7-87
-
-
3-28-87
5-2-87
APPROVAL
8-5-86
11-8-86
1-27-87
-
-
4-17-87
5-2-87
ACTUAL
START
6-16-86
10-24-86
3-16-87
6-23-87
-
4-27-88
9-1-88
SUBMITTAL
7-16-86
1-9-87
-
9-8-87
3-14-88
6-25-88
9-16-88
APPROVAL
8-26-86
3-16-87
-
10-28-87
5-16-88
9-16-88
9-16-88
278
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BACKGROUND
Project Description
Site Location
The Helen Kramer Landfill site is located about five miles south of Woodbury, New Jersey. Edwards
Run, a freshwater perennial stream, is located immediately east of and adjacent to the landfill. The
site lies within the Delaware River drainage basin. Edwards Run empties into the Delaware River
via Mantua Creek. A Site Plan showing remedial action components is presented in Figure 1.
Several residences are located near the landfill. The nearest housing development lies within 0.25
miles of the site. More than 3,000 persons live within one mile of the site and more than 6,000 within
two miles. Natural resources near the site include agricultural lands, groundwater, and surface waters.
The climate is characterized as temperate humid, with about 41 inches of average annual
precipitation.
Site Description
The 66-acre landfill contained approximately 2 million cubic yards of mounded waste, with waste
thickness approaching more than 50 feet, and rising to as high as 50 feet above the surrounding
terrain. The surface of the mound was generally undulating and irregular, with slopes approaching
50 percent. Relief from the creek bed to the top of the landfill was nearly 100 feet. An additional
11 acres between the landfill and Edwards Run had been stressed by landfill activities. A two- to
three-acre pond, containing up to 2 million gallons of contaminated water, existed in the northeast
corner of the site, in the flood plain of Edwards Run. Leachate from the landfill collected in this
pond, with overflow going into Edwards Run. Numerous leachate seeps could be seen along the
landfill slopes near the creek. A three-acre swamp located east-southeast of the landfill also collected
leachate leaving the site. Vegetation in this swamp was stressed. A swampy area southeast of the
landfill exhibited no stress. Landfill surface cover was extremely poor, and rifts in the surface, as
well as protruding sharp objects, posed physical dangers. The site had no controlled drainage for
surface runoff.
Site History
The site was used originally as a sand and gravel pit. It became an operating landfill between 1963
and 1965, during which time landfilling was carried on simultaneously with sand excavation. Little
is known about landfilling activities prior to 1970.
In October 1973, inspectors from the New Jersey Department of Environmental Protection (NJDEP)
noted that chemical wastes were being deposited in trenches on site. Further discoveries of chemical
waste and drum disposal were made in January 1974 and, the following April, landfill leachate was
observed discharging into Edwards Run. Dumping of chemical wastes, both in bulk and drums, was
alleged by area residents to have continued into early 1981, when the landfill was closed by Court
Order.
Between 1974 and 1983, limited-scope investigations were carried out by NJDEP and USEPA. These
investigations showed that groundwater used by residents in the vicinity of the site had not been
degraded, but that extensive contamination from the site was entering surface water, and that leachate
was having toxic and possibly mutagenic effects on aquatic life. During 1981 a number of subsurface
fires broke out at the landfill. Air monitoring conducted during these fires showed emissions of
organic vapors and hydrogen cyanide. Consequently, in December 1982, USEPA prepared a Remedial
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HELEN KRAMER SUPERFUND SITE
FIGURE 1
-------
Action Master Plan for the site, and in 1983 conducted additional air monitoring, which confirmed
the presence of organic vapors higher than background levels.
It is estimated that, of 2 million cubic yards of waste at this landfill, approximately 500,000 gallons
was industrial liquid waste, several hundred cubic yards sludge, and over 3,000 cubic yards inorganic
wastes (such as heavy metals, salts, catalysts, and the like). An estimated 183,000 gpd of leachate and
contaminated groundwater was entering Edwards Run, threatening the quality of its water. [Edwards
Run has potential as a recreational or irrigational resource.] Laboratory testing had indicated the
potential for adverse effects upon biotic resources in Edwards Run. The shallow Mt. Laurel/Wenonah
aquifer in the vicinity of the site and of Edwards Run was contaminated. Constantly generated
landfill gas posed a danger of further fires as well as the possibility of further release of hazardous
chemicals into the air. Although no potable water supplies had shown evidence of contamination
attributable to the landfill, the potential for such contamination did exist due to their proximity to
the site. Potential for present and long-term risk to human health and the environment provided
justification for this site's being listed among the highest-priority sites on USEPA's National Priorities
List.
The Remedial Investigations (RI) and Feasibility Study were conducted by NUS Corporation under
USEPA Contract No. 68-01-6699, USEPA Work Assignment No. 29-2L30. Actual field work was
conducted by NUS's subcontractor, R.E. Wright Associates, Inc., of Middletown, Pennsylvania, from
August 1984 through September 1986.
Design Process
Phase I - Work Plan Development
USAGE had developed a detailed Scope of Work for the project that was based upon RI/FS
documents and that was consistent with the Record of Decision. Using this Scope, a fixed-price
contract was awarded to URS Consultants, Inc. During the negotiations, a predetermined scope of
subsurface investigations and completion schedule was agreed upon.
As part of Phase I, URS collected and reviewed the available technical information and developed
a Work Plan document which, among other things, attempted to fill data gaps. During the review of
these documents, however, technical experts on the joint (USACE/USEPA/NJDEP/URS) project
team concluded that the planned investigations were not adequate and that a much more extensive
investigation program was necessary in order to prepare bid documents for competitive bidding.
Since monies for these investigations had not been included in the original contract amount, this issue
required further discussion and contract modification. This delayed the initiation of Phase II by more
than two months.
Phase II - Predesign Investigation (35% Design)
This phase required an $800,000 level of effort within a period of 75 calendar days, including
collection, synthesis, and interpretation of data and preparation of a report, along with 35% design.
The job was challenging, considering the potential for mishaps when drilling in an uncontrolled
landfill. A great deal of credit was due to the joint project team and to URS's subcontractors for
completion of the work by the newly approved completion date.
Interval Between Phase II and Phase III
One of the requirements of Phase II was to present to USAGE a recommendation for Value
Engineering Studies. The following five items were identified for Value Engineering:
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• A study of groundwater flow conditions, including effects of remedial action upon
ground water levels, the need for a subsurface drain upgradieht of the slurry wall, and
the economic benefits of such a drain.
• A study of the benefits and costs of constructing a slurry wall along Edwards Run.
• A study of the impact of variations in aquifer permeability on project design.
• A study of the viability and benefits of downsizing the pretreatment plant.
• A study of the costs of pretreatment and discharge to a POTW vs. complete treatment
and discharge to surface water of groundwater/leachate on site.
USAGE issued a modification to URS's contract authorizing URS to conduct studies on the first 4
items only. Despite the complexity of the 3-D Model of this site, the VE Study was completed and
submitted in 78 days from Notice to Proceed. The following 8 findings were accepted for inclusion
in the design:
1) Implementation of remedial action at the site would cause an upward groundwater
flow beneath the entire site, preventing the possibility of contaminant migration
downward or laterally.
2) The rise of groundwater levels upgradient of the slurry wall should be inconsequential
enough as to require no mitigative measures.
3) A subsurface drain upgradient of the slurry wall would not appreciably reduce flows
to the collection drain. Such a drain is therefore not considered necessary.
4) The Marshalltown formation (underlying the Mt. Laurel/Wenonah aquifer), although
not clayey, acts as an aquitard and provides an adequate foundation for slurry wall
key.
5) The variations in Marshalltown permeability have a direct and profound impact upon
flows to the leachate collection drain.
6) Due to the fact that lateral flow is insignificant within the Marshalltown, the depth
of slurry wall key is not of great importance. A 5-foot key is adequate.
7) A smaller pretreatment plant is viable and would be economical. Economy would be
greater if the facility were sized for flows that assume a slurry wall between the
collection drain and Edwards Run.
8) The construction of such a slurry wall is technically feasible, and such a slurry wall
would provide a higher degree of reliability in the planned remedial action.
The required modification to the contract impacted the schedule of the next phase. It also included
a slurry wall on the east side of the project. Moreover, it became apparent that it would be preferable
if the design could be developed with no floodway encroachment. [Encroachment would have been
extensive if the original (FS Stage) concept were implemented.] Additional investigation seemed to
be warranted, but two things worked against this: (1) the need to complete the bid documents
expeditiously (the original completion date having long since passed), and (2) the difficulty of
gaining legal and physical access to the site. It was therefore concluded that the design would be
282
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developed using existing information, extrapolating to the areas where investigations could not be
conducted. This would become an important issue during the construction phase of the project.
Another factor entering the picture was the pretreatment criteria (for leachate/groundwater) set by
the Publicly Owned Treatment Works (POTW), which in this case was the Gloucester County Utilities
Authority (GCUA). GCUA and USEPA negotiators ultimately agreed to a batch-discharge to
GCUA's system. This of course meant that no discharge to GCUA sewers would be permitted
without prior testing/approval. This decision required adding a minimum of three pretreated
wastewater discharge/holding tanks to the project, each with a capacity of 350,000 gallons. After
receiving verbal approvals from the GCUA board, a draft Service Agreement developed by USEPA
was sent to GCUA for review and comment.
Phase III - 65% Design
With all previously identified elements included in the project scope, this phase was targeted for
completion within 60 calendar days. This phase proceeded smoothly.
Phase IV - 95% Design
This phase was carried out without serious difficulty and on schedule. However, it is worthy of
mention here that in spite of the design being almost ready for bid invitation, little progress had been
made on two important issues. These issues included, on the one hand, real estate access and
easements for construction, and, on the other, an agreement with the POTW to accept pretreated
leachate. These issues had not yet been settled. Both issues were vital if any remedial construction
were to begin.
During this phase two major engineering issues had to be overcome: completion of the landfill cap
in such a way that remedial action would not encroach upon the floodway of Edwards Run; and
construction of a slurry wall across the steep banks on the northeast and southeast ends of the landfill.
After several alternatives had been studied, Roller-Compacted Concrete (RCC) was incorporated into
the design. This feature promised not only to provide support to the cap, but also made it possible
to construct the slurry wall by creating somewhat milder slopes.
Phase V - 100% Design
Following review of the Phase IV submittal, specifications and drawings were finalized and submitted
to USAGE on September 16, 1988, in anticipation of bid invitation to follow shortly.
Invitation to Bid
The formal invitation to bid was not advertised until May 22, 1989, with bid opening on September
19, 1989, one year following completion of the design. As stated earlier, real estate adjoining the
landfill site, acquisition of which was required for construction of the remedial action, had not yet
been acquired. USAGE was of the opinion that until all the real estate issues were resolved, the
United States Government could not enter into a legal contract for construction.
Although more than 200 bid packages had been sold by USAGE--the cost of bid packages being set
low ($10.00) to encourage more bids—only three responsive bids were received. All bids were
substantially higher than the original Government estimate. A large number of potential bidders were
unable to secure bonds in the amount necessary to undertake the project. They claimed that even
though their firms were technically and financially qualified to complete the work, the bonding
283
-------
requirements denied them the opportunity to submit a bid that, as they maintained, would have been
advantageous to the Government.
Real Estate and Site Access
Access was needed to adjacent properties owned by parties other than the landfill owner. Two of the
three property owners in question owned land uncontaminated by the landfill. Six different access
procedures were used to acquire this land. These included purchase, leasing, relocation,
condemnation, access agreement, and an administrative order. Extensive negotiations were required,
making the process last an unexpectedly long time. The benefits of expediting the development of
the bid documents were essentially lost, and it resulted that real-estate issues had the greatest impact
on the remediation schedule.
This was one of the first acquisitions of property for the purposes of conducting a remedial action
that had been made through the Superfund program.
Remedial Action Construction
The Contractor began site work on February 20, 1990, and to date has completed 50 percent of the
remedial construction. From an engineering design point of view, two construction issues are worthy
of consideration: pretreatment plant design modifications, and construction of the RCC and the
slurry wall along Edwards Run.
Pretreatment Plant Design Modifications
This component of the remedial action, which is on a critical path, was originally scheduled for
completion for November 3, 1990. The facility would have then been available for treatment of
leachate and any contaminated groundwater from construction activities. In April 1990, however,
the project team was informed that GCUA pretreatment requirements (discharge criteria) had been
changed from those used in the plant design, and made more stringent. In order to meet these
requirements, a new engineering study had to be completed, and design modifications made. The two
key elements of the required process enhancements (water-phase activated carbon adsorbers and a
high-efficiency air stripper) were long-lead items. This fact, along with the necessary supporting
design drawing modifications and the contract modification process, caused the target date for
pretreatment plant completion to be pushed back to August 1991. This has had an impact on both
the cost and the overall project completion date.
Construction of RCC and Slurry Wall Along Edwards Run
The contract documents required the Contractor to drill a certain number of soil borings to define the
depth to the geological formation (Marshalltown) into which the slurry wall was to be keyed. Based
upon these investigations, the Contractor claimed that the ground was softer than he had anticipated
and further stated his opinion that the ground was possibly even unsuitable for support of the RCC.
This portion of the site had been the least explored. The meandering of the stream (Edwards Run)
had extensively reworked the soils. Additionally, sand and gravel mining, followed by landfilling
activities had further complicated the situation. To obtain more accurate data, the Contractor was
directed to undertake a detailed investigation of this area under USAGE direction. The results of this
investigation revealed that the geologic soil formation expected over most of this portion of the site
had been removed by stream erosion processes and had been replaced by a heterogeneous matrix of
floodplain alluvium of inconsistent texture and density. The depth to firm ground was variable at
best, and deeper than expected. Increased excavation depths also brought into focus potentially larger
volumes of contaminated groundwater. The stability of the excavation for the foundation became
28/1
-------
important, requirihg greater care in planning and execution. The net result again was an increase in
cost and an impact on schedule. As of this writing, it is still a matter of study whether conventional
construction methods or in-situ ground stabilization would be more suitable.
CONCLUSIONS
What may be deduced from this experience, for application on Superfund remedial projects of similar
scope, nature, and complexity? The most important lessons are the following:
1. The scope and costs of predesign investigations can be substantial, and greatly
variable, depending upon the degree of detail to which the investigations were carried
during the RI/FS process. It is prudent to define a scope acceptable to all parties
before negotiating a fixed-price design contract We have already seen this change
take place on design contracts being negotiated in the recent past.
2. Field investigations must be completed during the design process. Such investigations,
when left to the construction phase, can have a major impact on construction cost and
schedule. This point cannot be overstressed.
3. Real estate issues must be defined early in the design and should be given the same
priority as other elements of the project, if not a higher priority. Many times these
issues involve high-priced real estate, farmland, or property with sentimental value
for its owners. Property acquisition should be complete, or nearly so, prior to 100%
design.
4. When interagency agreements are involved, these agreements must be executed prior
to completion of bid documents. Incorporation of new technical or contractual
requirements during construction is costly and delays construction.
5. Agency review has an important impact on project team continuity and cost.
6. The importance of early and continuing attention to POTW issues cannot be
overstated.
The Helen Kramer Landfill Superfund site remedial design has, at many levels, been instructive. In
spite of the difficulties encountered, however, this remedial design is considered to have been a
success that has set precedents in many areas.
DISCLAIMER
This paper has undergone a relatively broad initial, but not formal, peer review. Therefore it does
not necessarily reflect the views or policies of URS, USEPA, or USAGE. It does not constitute any
rulemaking, policy, or guidance by USEPA or USAGE, and cannot be relied upon to create a
substantive or procedural right enforceable by any party. Neither URS nor the United States
Government nor any of its employees, contractors, subcontractors, or their employees makes any
warranty, expressed or implied, or assumes any legal liability or responsibility for any third party's
use or the results of such use of any information or procedure disclosed in this report, or represents
that its use by such third party would not infringe on privately owned rights.
We encourage your comments on the utility of this paper and how it might be improved to better
serve the Superfund program's needs. Comments may be forwarded to the attention of:
Vern Singh, P.E.
URS Consultants, Inc.
282 Delaware Avenue
Buffalo, New York 14202
285
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Contract Security in Superfund: An Open Dialogue Between Government
and the Remedial Construction Industry
James R. Steed
Former Unit Head
Texas Water Commission
Hazardous & Solid Waste Division
Currently with IT Corporation
2499-B Capital of Texas Highway
Austin, TX 78746
Earl G. Hendrick
Senior Remedial Project Manger
U.S. Environmental Protection Agency, Region 6
1445 Ross Avenue
Dallas, TX 75202-2733
INTRODUCTION
In the late 1980's as the larger and more complex EPA Superfund projects developed under the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and the
Superfund Amendments and Reauthorization Act (SARA), serious liability concerns began to
confront the construction industry. The liability exposure that remedial action contractors began to
face on hazardous waste projects had a profound effect upon the construction surety bond market
and changed approaches to contract performance security in a major way. Many of the early
hazardous waste problems, particularly in the government realm, were handled as conventional public
works jobs involving standard civil engineering and construction practices. As such, these projects
were structured with design plans and construction specifications serving as contract documents
accompanied by the customary performance bonds and payment bonds.
With the advancement of the larger hazardous waste projects through the investigation and design
stages into the construction phase, federal and state governments as well as private industrial owners
have begun to experience difficulty in obtaining bonding for their projects. Owners and especially
surety companies are forced to deal with the complex liability issues that abound in CERCLA, SARA
and hazardous waste in general. In view of the long-term liability concerns that face the surety
industry, a conservative approach to bonding hazardous waste work quickly evolved. The resulting
impact on remedial action construction projects has been of special concern in the government sector.
Lack of bonding has caused project delays from inability to solicit bids or created exceedingly high
costs from lack of a competitive arena. Consequently, government entities have been forced to
modify conventional approaches to construction contracts and to seek innovative solutions to
performance security needs -all within existing state and federal law. Closer examination of both
contracting options and financial risk exposure has provided new insight into the contractual solutions
of hazardous waste problems.
BACKGROUND
In the summer of 1988, the Texas Water Commission completed the Remedial Design of the Sikes
Disposal Pits Superfund Site and received EPA approval of the plans and specifications. The Sikes
Site, located in Harris County near the Town of Crosby and northeast of Houston, is an abandoned
hazardous waste dump area along the San Jacinto River bottom. Large sand pits and smaller
depressions scattered over 100 acres of this floodway became receptacles for the disposal of mixed
industrial wastes and refuse during most of the 1960's.
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The Record of Decision called for the excavation of contaminated materials with thermal destruction
on site. Involving the handling of over a half million yards of material and the incineration of over
210,000 tons of wastes, the Sikes project was the largest single Superfund remedy to be offered for
bids in the nation. The remedial design embraces a performance-based approach toward contracting
for the incineration services and for treatment of large volumes of contaminated shallow ground water
appurtenant to the excavation operations. Following completion of incineration, all temporary
remediation facilities are to be removed from the site and followed by fine grading and revegetation
of the landscape.
In August, 1988, the Request for Proposals for remediation of the Sikes site was advertised nationwide
in a two-step procurement approach to the contract for incineration services. Five remedial action
contractors were deemed qualified to submit bids for the project. The contract for which bids were
solicited contained the standard "public works" contract security requirements of a bid bond of the
customary 5% and the payment bond of the standard 100%. The performance bond was specified to
be $35,000,000 on this contract having an estimated total cost of $91,600,00.
Bids for the Sikes Remedial Action were opened on October 12, 1989 but the contract was not
awarded. Of the five contractors invited to bid, only two bids were received. One bid was
determined to be non-responsive, as it was not accompanied by the required bid bond. The other bid
was almost 50% more than the design engineer's cost estimate and exceeded the funds obligated by
the TWC and EPA for this project.
THE DIALOGUE
In seeking reasons for the lack of competitive bids, EPA and the Texas Water Commission interviewed
the other three contractors who had not submitted bids. All three companies cited either bonding
difficulties or liability concerns as reasons for declining to bid. Other interviews and contacts with
surety company representatives were initiated and significant information-gathering activity was
exerted by both state and EPA.
In discussions with contractors, bonding companies and other government representatives, several
messages became apparent regarding the contracting climate in hazardous waste. There is general
concern among the sureties that the performance guarantee bond will at some time in the future be
construed by a court of law, in the absence of other relief, as a kind of insurance policy to
compensate individuals for perceived harm suffered from the waste cleanup project. Apparently,
there is also concern that some hazardous waste projects may present the potential for a release of
environmental pollutants so catastrophic as to bankrupt the contractor into literal non-performance
hardship. The repeated point of concern was the potential for the designation under hazardous waste
laws of strict liability to the contractor on third-party claims. Strict liability, being liability without
a determination of pure fault, may hold a contractor liable, even though negligence is not shown. The
joint and several liability provisions of CERLA and SARA intensify the possibility of total liability,
even if a contractor were responsible for only slight contamination.
Other contractors and surety representatives cited:
o Design/build concept on projects where the contractor may be held accountable for
the method or scope of the remedy;
o Uncertain hazards associated with unknown materials at the site;
o Unnecessarily stringent cleanup criteria;
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o Lack of pollution liability insurance and uncertainty regarding the extension of SARA
Section 119 indemnification to bonding companies taking over projects;
o Concern that there is a limited amount of money in the EPA Trust Fund and the
possibility of the fund being nonexistent in the future;
o Inability of sureties to choose a completion option in a default and the possibility of
additional liability associated with the surety's being a facilitator of waste disposal.
Of universal concern to the bonding companies seems to be the project type/ project size ratio,
especially in hazardous waste. That is, a surety is frequently willing to bond a small Superfund
contract and is accustomed to bonding very large but traditional civil construction projects. However,
due to the liability concerns expressed above, the bonding company is apparently reticent about
underwriting a large hazardous waste project such as Sikes.
Of particular concern to the contractors interviewed were several common issues and questions:
o Insistence by government in requiring surety bonds but not accepting other contract
security instruments such as letters of credit;
o Amount of contract security and the need for any performance guarantee on a
service-type contract;
o Possibility of separating a remediation project such as Sikes into segments resulting
in some clean, less-risky conventional contracts and some hazardous waste handling
contracts;
o Advantages of limiting retainage from progress payments to some reasonable
maximum, particularly on a large service-type contract;
o Expressed written intent of the purpose of the surety bond as a guarantee of contract
performance and not as an instrument of relief for third-party damage claims;
o Established time limit on the protection extended by the bond and a formal execution
of a release of the bond upon completion of the work.
o Elimination of any warranty or post-completion guarantees from the contract
provisions whereby the success of the remedy cannot be guaranteed by the contractor
in any case.
SOLUTIONS AND RESOLUTIONS
This dialogue with the remedial contractors helped build the framework for establishing several
contract modifications, which would hopefully result in a contract procurement package more
palatable to the construction market. Careful study of existing bonding and contract law affecting
federal and state government procurement preceded the formulation of stated policies and revised
procedure for the needed modifications.
The extent of bonding requirements under both state and federal law was closely examined since the
project is 90% federally funded but is administrated by the State of Texas. The proposed Water
Commission contract for site remediation, while partially funded by EPA, would not be a federal
contract since the federal government is not a signatory of the contract. It was further noted that the
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federal law permits flexibility in evaluating the required amount of bonding. What had been cause
for some consternation with the surety companies interviewed was the Texas McGregor Act, which
requires 100% performance and payment bonds for the construction of public works in excess of
$25,000. The legal staff of the Water Commission issued a determination in early 1990 that the Sikes
Remedial Action Contract was for waste incineration services to be performed wholly on private
property and further that the project did not involve the erection of permanent structures or public
facilities and was therefore not within the concept of public works. While other Superfund projects
may incorporate the construction of permanent structures such as landfills, even if on private
property, the Sikes remediation encompasses neither public nor permanent facilities.
EPA and the Texas Water Commission decided that the government's interest in the project certainly
needed some measure of protection against failed performance, project abandonment and unpaid
subcontract material and labor claims. After studying the history and procedures involved in bank
letters of credit, the Commission made the commitment to accept these instruments for contract
security under certain specific conditions. Since the staff felt it would be exceedingly difficult to
dispense numerous payments on unpaid claims to vendors, subcontractors and laborers, in the event
of contractor default, it was agreed that some amount of payment bond should be required.
To reduce the sureties' concerns with very costly Superfund projects, the TWC and EPA decided to
divide the project into two clearly separate phases with separate contracts. The Phase A contract was
structured as essentially clean work involving site preparation with mobilization and erection of
incineration and water treatment equipment. Excavation and handling of hazardous waste was left
to the second or Phase B contract for destruction of contaminants. Modifications to the bid proposal
moved hazardous work from Phase A to Phase B. Completion of Phase A would be established upon
installation and mechanical demonstration of all project facilities. The trial burn of the incinerator,
where operating parameters are defined and acceptable results are proven with the actual hazardous
materials from the site, was then to be the first item of work in the second contract, Phase B.
With the segregation of work into two separate contracts, the work would be supported by separate
contract security instruments as well. A letter of credit to guarantee performance or a conventional
performance bond plus the desired payment bond would accompany each contract, one independent
of the other. Due to the phased funding of the Sikes project from EPA, both contracts would not be
executed at the outset. Rather, the contract security instruments for the Phase A contract would be
formally released upon completion of that phase simultaneously with submittal of papers of guarantee
for Phase B along with the Commission's release of the Phase B contract and Notice to Proceed to the
contractor. All of this served to break a very large contract into smaller and hopefully more
bondable contracts with the terms of possible liability for each more limited.
In response to the input of concerns from surety company representatives, the Water Commission staff
modified the conventional bond forms and established new policy regarding several issues:
o The Performance Bond would contain wording that makes it clear that the sole
guarantee was for completion of the required remediation and not to be construed as
any form of insurance against future third-party damage claims;
o Letters of credit and/or bonds would be formally released and returned to the
contractor upon successful completion of each contract, thus limiting the term of
liability under each guarantee;
o Surety companies were permitted some options with regard to the project completion
fulfillment in the event of contractor default;
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o Memoranda from EPA were distributed to bidders indicating that SARA 119
indemnification of the contractor would be extended to the surety company in its role
as a completing agent in the event of default.
The Water Commission and EPA staff conducted a thorough risk review of the project. After
analyzing job cost estimates, type of work involved in separated phases, and possible cost impacts
associated with default or abandonment, we established a performance security amount of $20 million
for each contract. As stated before, a payment bond was needed to assure payment of vendors,
subcontractors and laborers, and the payment bond amount was set at $5 million. Terms for strict
proof of payment and provisions for seizure of facilities under default were added to contract. The
required performance and payment security amounts were set at the same $20 and $5 million for both
Phase A and Phase B contracts. As discussed previously, these security instruments would be
submitted and executed separately for the two contracts in a hand-off fashion so that bonds and
letters for both would not be in effect at the same time.
Bidders had all pointed out the impact of the full 10% retainage on a project the magnitude of Sikes
and requested some established ceiling on the retained payment amounts. The potential cost savings
to the government were deemed quite significant. The Commission, with EPA approval, capped the
retainage during the costlier Phase B work at $2 million. This will be held until project completion
with the possibility of further reduction toward the end of the project.
RESULTS AND CONCLUSION
After making these changes to the contract documents, the Texas Water Commission reissued the
Invitation for Bids at the end of 1989. Project bids were opened for the second time on March 8,
1990, with much success. Of the five qualified proposers, four contractors submitted bids in a very
competitive range. The low bid was just under $90,000,000, two bids were for just over $95,000,000
and the highest bid was just over $98,000,000. The government's estimate for this modified
construction contract was slightly under $95,000,000. Because the spread between the high bid and
the low bid was only 10%, we are satisfied that all contractors were on equal footing. The Phase A
and Phase B contracts, subsequently awarded to the low bidder without protest, are each secured by
a $20 million letter of credit and the required $5 million payment bond.
Phase A work at Sikes is underway and on schedule. The open dialogue between government and the
remedial action contracting industry was responsible for substantial savings to the state and federal
governments and for the success of procurement under difficult circumstances with the development
and execution of innovative contracting procedures.
REFERENCES
Clore, Duncan L. Principals' and Indemnitors' Rights and Obligations. 3rd Annual University of
Texas Construction Law Conference. February 1990.
Nelson, Steven D. and Tom R. Barber. Surety's Performance Bond Options. 3rd Annual University
of Texas Construction Law Conference. February 1990.
Riddel, Ann. Payment Clauses in Construction Contracts. 3rd Annual University of Texas
Construction Law Conference. February 1990.
Ryan, William F., Jr. and Robert M. Wright. Hazardous Waste Liabilities and the Surety. American
Bar Association. Revised 1989.
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Stanley, Marc R. and Robert M. Fitzgerald. Payment Bond Claims. 3rd Annual University of Texas
Construction Law Conference. February 1990.
U. S. Army Corps of Engineers. Hazardous and Toxic Waste Contracting Problems. Environmental
Protection Agency. July 1990.
Walton, D. Gibson, Karen Tucker and Scott Marrs. Architects' and Engineers' Liability. January
1990.
Youngblood, Eldon L. Mechanics' Liens and McGregor Act Claims. 3rd Annual University of Texas
Construction Law Conference. February 1990.
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Remedial Design and Construction at the Charles George
Landfill Superfund Site
Robert K. Zaruba
Design Project Manager
U.S. Army Corps of Engineers
Omaha District
215 North 17th Street
Omaha, NE 68102-4978
(402) 221-7665
David J. Dickerson
Remedial Project Manager
U.S. Environmental Protection Agency, Region I
Mass. Superfund Section (HRS-CAN3)
Waste Management Division
JFK Federal Building
Boston, MA 02203
(617) 573-5735
INTRODUCTION
Capping as a form of source control is a common remedy for many hazardous and non-hazardous
waste sites. Traditional issues associated with cap design include, among others, cost-effectiveness,
permeability criteria, redundancy, cap material, constructibility and quality control, subsidence and
long term stability, gas and leachate collection and ease of operation and maintenance (O&M).
Capping materials range from natural soils to synthetic membranes, and cap designs have differed
from site to site. The long term effectiveness at minimizing the release of contaminants is a function
of both cap design and construction quality, O&M, local groundwater conditions and pre-capping
operational history.
This paper addresses the recent Superfund-financed construction of a 53 acre (as the footprint)
synthetic landfill cap, with emphasis on the technical and programmatic lessons learned. This cap
construction will be discussed within the context of the parameters listed above, as well as within the
three other operable units being implemented at this site. These other remedies at the Charles George
site include the provision of municipal water supply and the treatment of landfill gas, contaminated
groundwater and leachate. As more Superfund sites advance beyond the characterization, planning
and design stages, we believe that the implementation issues encountered at this "older" site, together
with our resolutions, should be shared to provide for smoother site clean ups and less-problematic cost
recovery cases elsewhere.
BACKGROUND
Located in a predominantly rural residential area 30 miles northwest of Boston in Tyngsboro,
Massachusetts, this site began as a small (< 1 acre) local dump in the mid-1950s. The George family
purchased the site in 1967 and significantly expanded landfill operations until shut down per order
of the state Attorney General in 1983. The landfill operated as a state-licensed hazardous waste
disposal site from 1973 to 1976, and, as listed in monthly operation reports, 5,509 drums and more
than 1,040 yd3 of metal sludges ("Toxic Metal etc.") were disposed at the site during this time frame.
(Depending on the interpretation of the monthly reports filed during these years, however, one could.
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easily argue that the 1,040 yd3 amount should be approximately 4,280 yd3). Other bulk liquid and
industrial/chemical wastes were probably disposed during other times as well. In total, approximately
4 million yd3 of mixed wastes have been disposed at the site.
A plan view of the landfill and surrounding area prior to cap construction is presented in Figure 1.
The landfill had typical relief of about 50 ft with a maximum of about 90 ft at the western end.
Landfill slopes varied from about 1V on 5H in the northwestern corner, where the landfill access road
and operations buildings were located, to a very steep IV on 2H at the western end. At least in some
areas, waste was placed at water table or bedrock depths as much as 20 ft below natural grade. In
other areas waste was disposed directly on native soils ranging from silty glacial till to sand and
gravel.
Two limited leachate collection and recirculation systems were installed by the owners during 1980
and 1981, but were plagued with operational problems. As a result, the eastern leachate system
drained into a combined surface runoff/leachate lagoon at the eastern perimeter of the fill. A similar
lagoon perched on the steep slope of the western perimeter received leachate from the western
leachate system. Prior to closure, contaminated storm runoff frequently ponded a local road, and,
in the summer of 1980, a landfill fire burned at the site for approximately two months. Beginning
in 1980, volatile organic compounds (VOCs) detected in site groundwater (e.g., acetone, 2-butanone,
benzene, etc.) were detected in the two deep bedrock water supply wells of a nearby condominium
complex. Pumpage of these 500 foot deep supply wells, located 800 feet south of the eastern lobe of
the landfill, influenced the site's eastern groundwater plume and pulled groundwater contaminants
downward and southward (Reference 1). These wells were ordered closed by the state in 1982.
The site was added to the Superfund National Priorities List in 1983. From August 1983 through
March 1984, emergency response actions were implemented involving a) the upgrade of an emergency
overland waterline serving the condominium complex, b) the coverage of approximately 20 acres of
exposed refuse and c) the installation of 12 shallow gas vents. In December 1983, EPA issued the first
of three Records of Decision (RODs) for the site which called for an extension of an existing
municipal water supply to serve the condominium area. Construction of this waterline, a 5 mile
extension to the City of Lowell's system, began in September 1986 and was completed in October
1988. The second ROD, issued in July 1985, selected a high density polyethylene (HOPE) cap for the
entire landfill, together with perimeter leachate collection and gas venting. Mobilization for the cap
construction began in December 1988, and the cap was completed in October 1990. The leachate
collection system was activated in January 1991, although start up problems have been experienced.
The third ROD, issued in September 1988, addressed leachate, contaminated groundwater, landfill
gas and sediments. These "phase three" remedies are currently in design.
As part of the extensive cost recovery litigation related to this site, all of EPA's remedies have been
aggressively criticized. Regarding the second (cap) ROD, defendants argue, among other things, that
the 10"7 cm/sec permeability design criteria was inappropriate, and that a glacial till cap would have
been more cost-effective and permanent than an HDPE one, especially given the high (3.5 ft/yr
maximum) subsidence rates observed. These arguments have been extensively reviewed by the
Agency, and, as discussed further below, EPA maintains that its remedy selections have been
appropriate. For a more comprehensive reading of the litigation remedial issues, see References 2,
3, 4 and 5.
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DISCUSSION
At Cap Design
EPA Region I contracted with Camp, Dresser and McKee Inc. (CDM) to develop the cap design.
Review of the design was conducted by EPA, the Omaha District and New England Division of the
Army Corps of Engineers (the Corps), the Massachusetts Department of Environmental Protection
(DEP), and, to a limited extent, a local Citizens Advisory Committee (CAC).
The design uses a 60 mil (1.5 mm) textured HDPE geomembrane as the only critical impermeable
layer of the synthetic cap composite (Figure 2). HDPE was selected because of its superior
performance and availability compared to the other alternatives considered during feasibility studies.
Note that the design includes a woven geofabric as the upper-most layer for additional strength. The
design also uses synthetic geonets above and below the HDPE membrane as the drainage layers for
excessive soil moisture runoff and leachate/gas transport, respectively. On the side slopes, the design
called for 12 inches of crushed stone (and no upper geonet) rather than the 18 inches of vegetated soil
used on the landfill crest.
Runoff is now drained to one of three sedimentation basins via a perimeter rip-rapped drainage
swale, and leachate is collected by a new french toe-drain located just inside this drainage swale
(Figure 3). A gabion-lined side slope bench was included in the design to assist in erosion control,
woven fabric anchoring and access during O&M. The 12 original gas vents have been connected to
the new expanded gas collection system via gravel trenches located below the cap. The 28 new vents
that penetrate the HDPE membrane are interconnected by a similar trench system as well as by the
lower geonet. The as-built plan of the cap is presented in Figure 4.
The maximum slope allowed per the design is IV on 3H to aid in liner installation, slope stability and
ease of O&M. This required that surrounding property be purchased, by the state, in order to extend
and flatten the slopes.
The new perimeter leachate collection system consists of a perforated HDPE pipe within an HDPE-
lined trench, and was designed primarily to collect side slope seepage draining from the lower geonet.
The original eastern and western leachate collection systems are tied-in to the new system, however.
In the original cap design, leachate was drained by gravity to two underground storage tank (UST)
sites. Taking advantage of the site topography, one UST site was located on the eastern perimeter and
the other on the western perimeter. Each site was designed to include two 7,000 gal USTs. No
provisions were made in the construction contract for treatment of this leachate, since this was outside
the scope of ROD II. The original design also called for three temporary percolation pits to be used
for lagoon and general construction dewatering.
B. Subsidence
It is generally acknowledged that localized subsidence is more of a problem with older landfills where
proper operations (e.g., placement, compaction, interim cover) were not followed. During the design
of this cap, landfill settlement and localized subsidence were analyzed based on existing literature.
The high strength woven geotextile (Figure 2) was included to protect against potential differential
settlements greater than those expected based on the literature. However, due to fissures in the fill
and evidence of settlement at the two landfill groundwater monitoring wells observed in late 1987,
a more rigorous site-specific analysis was performed. Based on two areal mappings dated
approximately 3 years apart (Reference 6), four optical cross-section surveys conducted between
October 1988 and April 1989 (Reference 7), and biaxial stress testing of the woven geotextile and the
HDPE geomembrane performed in October 1989 (Reference 8), it was concluded that the cap
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composite as designed will be able to withstand settlement-related forces with proper maintenance
(Reference 9, 10).
C Cap Construction
The construction contract was advertized for bids in Spring 1988, after access rights for construction
had been secured by federal court order. Six bids were received ranging from $13,800,000 to
$23,300,000, and the contract was awarded to Tricil Environmental Services on July 22, 1988 at a cost
of $15,567,675. On July 28, 1988 one of the unsuccessful bidders protested the award and delayed
mobilization until December 1988. Note that actual construction costs specific to the impermeable
HDPE layer, including material, transportation, installation and quality control came to $0.60/ft2
($0.31/ft2 for material + $0.29/ft2 for installation), for a total of $1,723,638 (Reference 11). This
compares favorably to the defendants' cost estimate of $2,030,000 for installation of 2 ft of glacial
till (Reference 2).
The contractor's first effort on site was to clear the area, demolish buildings and install the perimeter
fence. Next, fill was placed on the site to produce the maximum IV on 3H slope, and to provide a
smooth subgrade for the HDPE membrane. As the slopes were flattened, the gas collection trenches
and vents and the various cap components were installed. Several vents were relocated during
construction to areas where landfill gases were naturally venting. Not surprisingly, as the liner was
installed more and more gas was forced through the vents. Workers used blowers, respirators and,
in some cases, supplied-oxygen when working in gaseous areas.
Construction meetings involving Tricil, the Corps, EPA and the DEP were held weekly to discuss the
various construction issues and monitor the project's progress. Weekly construction tours were also
provided to the defendants' consultant during most of the construction period.
Liner installation occurred over two summers. Even with the synthetic cap materials, rain delays
were frequent. One day of rain could cause several days of delay due to the time required to
sufficiently dry the subgrade soil. In addition, rain would wash soil from unlined areas on to the
partially installed cap. This material in turn would have to be removed prior to further cap
installation. Finally, any soil that was washed out had to be replaced and compacted. Later in
construction a more granular fill was allowed as the subgrade material under the cap composite. This
material did not wash out as did the previously used material, it dried more quickly, and allowed for
a more efficient liner installation.
The percolation pits of the original design were not built for two reasons. First, buried refuse was
discovered at one location and second, in-situ permeabilities appeared to be too low to allow for
effective percolation. As a result, a lined holding pond was built just north of the landfill to contain
the western lagoon and contaminated runoff from other areas. The eastern sedimentation basin was
used to contain contaminated runoff in that area. Both basins were subsequently drained without
treatment after toxicity testing demonstrated that the ponded water was acceptable for discharge.
Perhaps the biggest change to the design involved deleting the two leachate USTs, and replacing them
with a pumping system designed to centralize all site leachate to the lined holding pond discussed
above. This was done to avoid construction issues (e.g., blasting, contaminated groundwater) and the
need for frequent tank draining, and to help integrate leachate collection with the phase three
treatment remedies. This new system includes two pump stations, one on either end of the landfill,
and a force main from each one which travels within the leachate toe-drain to the holding pond. This
allows for increased, centralized storage, and should provide for a more efficient interim leachate
management program until the on-site treatment plant is built per ROD III. Ironically, one of the
more difficult and time consuming tasks for this system was coordinating with the electrical utility
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company (among other problems, they refuse to set foot on Superfund sites). Unfortunately, start-up
problems involving the submergible pumps and their start-up capacitors have hampered full usage
of the collection system. A more specific response time requirement in the contract's warranty clause
could have improved the contractors' pump repair response times. The pump repair problems have
been compounded by safety concerns due to significant volumes of gas being collected by the leachate
toe-drain.
Another significant change from the original design involved the side-slope bench gabions. The
contractor questioned the necessity of the gabion's gutter function and the constructibility of the
gabions, and proceeded with an interim crushed stone bench to satisfy the anchoring and access
functions of the bench. A compromise was reached wherein if subsequent side slope erosion indicates
the need for additional drainage control, the existing crushed stone bench will be modified
accordingly.
The local community and CAC were also involved during construction. Their concerns included,
among others, truck traffic, road damage, erosion, the percolation pits, and bedrock blasting.
Initially, evening meetings were held every two weeks to discuss these issues, eventually tapering to
approximately one per month. Their adamant opposition to bedrock blasting was one factor in the
change from leachate USTs to pump stations, and also resulted in the contractor using mechanical
rock removal rather than blasting.
Value engineering (VE) during construction was very time consuming. Both the contractor and the
Corps' resident engineer actively engaged in submitting VE proposals. This is of course an accepted
and encouraged practice. However, in this instance review and approval of each proposal required
lengthy coordination and technical review among the Corps, EPA and the DEP. This often resulted
in considerable delays in the review process since concurrence by all three parties was necessary. To
compound the problem, rejected VE proposals were revised and submitted to readdress the original
design issue, especially regarding the side slope bench and the cover soil design. Regardless of these
issues, however, many VE proposals were successfully implemented. The formal VE study performed
during the phase three design should help avoid similar problems during the next round of
construction.
Finally, due to the subsidence concerns discussed above, as well as the on-going site litigation, a stop-
work order was issued to temporarily prohibit placement of the soil materials above the cap. This
allowed for a formal solicitation of comments regarding the type and depth of these materials,
especially in regard to the loads applied on the synthetic composite. Ultimately, the order was lifted
and the cover materials immediately above the cap were installed as originally designed (Figure 2).
IX Groundwater Monitoring During Cap Construction
Pursuant to an Administrative Order by Consent (AOC), a year long groundwater monitoring program
was undertaken by certain Potentially Responsible Parties (PRP) from November 1989 to October
1990. Consistent with a requirement in the third ROD for 12 consecutive months of compliance
monitoring, four wells (two couplets) in the eastern groundwater plume were monitored monthly
during this time. Also as part of this study, nine other site wells were monitored quarterly, and water
table elevations in 50 site wells were monitored monthly.
For most VOCs, the concentrations reported in this study for the eastern overburden plume were
significantly greater than as measured in early 1987 and March 1989, and several fluctuated markedly
throughout the 12 month monitoring period (Table 1) (Reference 12). In the most contaminated well
in this area (E&E/FIT 2), benzene concentrations ranged from 0.5 - 5.2 mg/L, and arsenic
concentrations ranged from 0.07 - 0.26 mg/L. Note that tetrahydrofuran, a VOC not included in
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EPA's Contract Lab Program target compound list, appears to be the most prevalent and most highly
concentrated VOC at the site, reported at a maximum of 11 mg/L (this compound was analytically
identified by EPA's National Enforcement Investigations Center in Denver, CO). Hypotheses for
these increased contaminant loadings include a) barrel deterioration and thus new sources within the
fill, b) reduced dilution as a result of capping, c) increased loadings as a function of construction
activities (e.g., clearing, increased compaction) or d) increased loadings from uncollected leachate
during cap construction. The latter argument seems less likely since leachate had been uncontrolled
for years prior to capping, and since recently reported contaminant concentrations in leachate (Table
2) (Reference 13) are less than those reported for eastern groundwater. See References 1, 12 and 13
for a more complete groundwater and leachate chemical database, including semi-volatile organics,
inorganics and conventional parameters.
The water table monitoring of this study confirmed the presence of approximately 10 ft of saturated
refuse under the early spring water table in the western area of the fill (landfill well JLF-1).
Additional mounding analysis performed by EPA in February and March 1991 indicates a
continuation of this problem. Upward vertical gradients in this area suggest that post-closure
mounding may continue to be a chronic source of groundwater contamination.
E. Phase Three Remedial Activities
(1) Groundwater and Leachate Treatment
ROD III calls for extraction of southwestern overburden and eastern overburden and shallow
bedrock groundwater for combined biological-based treatment with leachate on site. The
southwestern extraction trench design, developed by LAW Environmental, Inc. under contract
to the Corps, is currently at the 90-95 % completion stage, and should be ready for
advertizing in summer 1991. The cap's southwestern sedimentation basin was relocated (i.e.,
a change order was implemented) to allow for improved trench access and function as
compared to the conceptual location presented in the 1988 phase three feasibility study
(Reference 1). The design of the eastern extraction system, on the other hand, was postponed
pending the results of the 12 month groundwater monitoring study discussed above, and is
just now getting underway. Once designed, however, an additional advantage to the change
from leachate USTs to pump stations discussed above is that eastern extraction system
construction costs and schedule should be reduced since primary voltage power will now be
readily available in this remote area.
Certain PRPs are also performing on-site treatability studies as part of the AOC. While as yet
incomplete, the goal of these studies is to develop an optimized, pilot study-based conceptual
design for the groundwater and leachate treatment plant. The detailed plans and
specifications for the plant will then be developed through the Corps.
ROD III also includes provisions for an upgradient diversion trench in the northwestern area
of the site as an attempt to lower the water table within the landfill, although it cautions
against the consequent potential for gradient reversal. The groundwater monitoring study
discussed above (Reference 12) concludes that the trench may be ineffective at reducing the
amount of saturated refuse, due to the flat gradients in the western area and the potential for
inflow from rising shallow bedrock groundwater.
(2) Landfill Gas Treatment
ROD III also calls for incineration of landfill vent gas. The design approach has been to
pursue gas vent manifolding (above the cap) and flaring as an initial step to allow for updated
297
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(i.e., post-capping) gas quantity and quality characterization. This will allow for a maximally
cost-effective design of the incineration unit, should the updated gas data reconfirm the need
for this treatment. In this scenario, the flare would be used as a back-up treatment during
incinerator maintenance or down time. Note that some PRPs have expressed an interest in
pursuing a methane recovery project at this site.
Due to the significant gas flow in the leachate toe-drains, these drains will be connected to
the gas manifold system. The two landfill groundwater monitoring wells will also be tied-in
to the manifold. Additionally, the learning and seeding of the landfill crest originally
specified in the cap design has been transferred to the phase three design so that it may be
integrated with construction of the manifold. The manifold and flare design is on the same
schedule as the southwestern groundwater collection trench, and is also being developed by
LAW Environmental, Inc.
Selected worst-case vent emission data from three separate sampling events (1984, 1986 and
1987) (Reference 1) are listed in Table 3. Included in this table for reference are the ninety-
fifth percentile and maximum concentrations of nine carcinogenic VOCs from a 1990
California Air Resources Board (CARB) study of vent gas from 340 hazardous (n=26) and
non-hazardous (n=314) landfills (Reference 14). Note that for seven of these VOCs, the
maximum concentrations reported for the site are above the CARB study 95th percentile
concentrations, and two site contaminants (trichloroethene and carbon tetrachloride) had
maximum concentrations above the CARB maxima.
(3) Sediments
ROD III also addressed nearby stream sediments contaminated with polynuclear aromatic
hydrocarbons (PAH). The ROD selected a target cleanup level of 1 ppm for total carcinogenic
PAHs(e.g.,benzo(a)pyrene,benzo(a)anthracene,benzo(b)fluoranthene,benzo(k)fluoranthene,
indeno (1,2,3-cd) pyrene, and chrysene), and required that additional sampling be performed
during design to determine the exact extent of dredging. This design sampling, however,
performed in December 1988, indicated that the PAH concentrations were at or below the
ROD's target levels. Thus, this cleanup has been postponed pending further review of the
sediments' toxicity.
CONCLUSION
The issues that arise during construction of a project of this magnitude are complex, time-consuming
and difficult to resolve. Nevertheless, during construction components of the cap design were
improved based on field observations, value engineering and coordination between the Corps, EPA
and DEP bureaucracies. The level of effort required during construction by EPA and state personnel
for the review of field changes, VE proposals, Potentially Responsible Party (PRP) and community
relations, and general oversight may not be adequately recognized by program work load models.
Remedial decisions made prior to construction can be subject to change due to the VE process,
changed site conditions, community non-acceptance and the three-dimensional realities of
construction. In this instance, the operable unit segregation of leachate collection per ROD II from
leachate treatment per ROD III caused difficulties in managing leachate on an interim basis.
Significant changes to the construction contract were made, however, to allow for integration of these
two remedies. Similarly, contract changes were made to allow for a smoother transition to the phase
three gas collection and treatment remedies.
298
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Expanded groundwater monitoring has highlighted the temporal variability of groundwater
contamination, as well as the limitations of the Contract Lab Program's target compound list for sites
of this type. Continued monitoring will be required to assess the exact impacts of the cap on
improving groundwater contamination.
Because of the hydrogeological characteristics of this site, additional aquifer remediation beyond
source control is being pursued. This aquifer clean up, as well as the other ROD III remedies, will
take advantage of the lessons learned during construction of the landfill cap. Our implementation
experiences should also be considered for other similar sites in order to appreciate and plan for the
complicated issues that arise.
REFERENCES
1. Ebasco Services Inc. July 1988. Remedial Investigation and Feasibility Reports, Charles
George Landfill Reclamation Trust Landfill Site, Tyngsborough, Massachusetts. 325 pp. and
350 pp., respectively, plus appendices.
2. Dames & Moore and GEI Consultants, Inc. August 1990. Technical Comments on Remedial
Actions Selected for the Charles George Reclamation Trust Landfill, Dunstable and
Tyngsboro, Massachusetts. 32 pp. plus appendices.
3. Haley & Aldrich, Inc. August 1990. Review of Superfund Records of Decision, Charles
George Landfill, Tyngsborough, Massachusetts. Cambridge, Massachusetts. 29 pp. plus
appendices.
4. Fiering, M.B. and Harrington, J.J. August 1990. Comments to United States Environmental
Protection Agency Concerning the Remedies Selected and Implemented at the Charles George
Superfund Site. Harvard University, Cambridge Massachusetts. 32 pp.
5. U.S. Environmental Protection Agency Region I. October 1990. Charles George Land
Reclamation Trust Landfill Superfund Site, Response to Technical Comments Received
Pursuant to the February 26, 1990 Order on Remand. Boston, Massachusetts. 58 pp.
6. Ebasco Services Inc. November 1988. Interim Technical Memorandum Evaluation of Charles
George Landfill Settlement. 14 pp. plus appendices.
7. Ebasco Services Inc. September 1989. Technical Memorandum Evaluation of Charles George
Landfill Subsidence. 53 pp. plus appendices.
8. Memorandum From J. Hoar, CDM, to Dave Dickerson, EPA. November 1989. Subject:
Geomembrane/Geotextile Biaxial Stress Test. 3 pp.
9. Letter From Guy Wm. Vaillancourt, E.G. Jordan Co., to David Dickerson, EPA. November
1989. 3 pp.
10. Druschel, S.J. and Wardwell, R.E. 1991. "Impact of Long Term Landfill Deformations,"
Proceedings of the Geotechnical Engineering Congress 1991. ASCE, Boulder, Colorado, pp.
(unknown at present).
11. Personal Communication Between David Dickerson (EPA) and Charles Adams (Corps of
Engineers). September 1990.
299
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12. GEI Consultants, Inc. December 1990. Draft Groundwater Monitoring Report, Predesign
Activities, Charles George Reclamation Trust Landfill, Dunstable and Tyngsboro,
Massachusetts. Winchester, Massachusetts. 20 pp. plus appendices.
13. GEI Consultants, Inc. June 1990. Draft Leachate Treatability Study, Initial Phase Interim
Progress Report, Predesign Activities, Charles George Reclamation Trust Landfill, Dunstable
and Tyngsboro, Massachusetts. 24 pp. plus appendices.
14. California Air Resources Board. June 1990. Preliminary Draft, for Public Comment,
Analysis of Air Testing Data From Solid Waste Disposal Sites. 38 pp.
300
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00
o
CCAU
ru—i
0 ZOO 400 FEET
BASE PLAN TAKEN FROM PLAN PREPARED BY
LAflSEN ENGINEERS ARCHITECTS. ROCHESTER
N Y . 6/26/87
NOTE: this figure adapted from Reference 12, Figure 2.
-------
6' SELECT COMMON
FILL (WIN.)
6' WIN. COMMON
FILL AS REQUIRED.
LANDFILL SURFACE AFTER
PRELIMINARY GRADING
FILTER FABRIC (WOVEN).
DRAINAGE NET
60 MIL MOPE MEMBRANE
•DRAINAGE NET
FILTER FABRIC (NON-WOVEN)
SLOPES 4il AND LESS
NOTE
UPPER LWER OF
NiT SHALL EXTEND 6. MINIMUM
OF 5' UHDEB CRUSHED STONE
COVER AT INTERFACE Of CRUSHED
STONE AND SOIL COVER MATERIALS.
SLOPES STEEPER THAN 4: I
- 12' CRUSHED STONE
6'SELECT COMMON
FILL (MIN.)
6' MIN. COMMON
FILL AS REQUIRED.
LANDFILL SURFlCE Af
PRELIMINARY GRADING
Figure 2 -TYPICAL LANDFILL CAP CROSS-SECTION DETAIL
NTS
00
o
FG
61 MIN. SELECT COMMON FILL ON '
OF COMMON FILL AS REQUIRED TO
GRADE SIDESLOPE TO 3il (MAXIMUM'
3 MAX.
PERIMETER SURFACE WATER
DRAINAGE DITCH
KEY IN LINER SYSTEM AT
LANDFILL PERIMETER
,-LEACHATE TOE DRAIN
Figure 3 - TYPICAL CROSS SECTION
-------
CO
o
CO
/ EAST DETENTION
J^ BASIN
LEACHATE PUMP STATION
CHARLES GEORGE LANDFILL
TYNGSBOROUGH, MASSACHUSETTS
SUPERFUND SITE CLEAN UP
FIGURE 4 - AS-BUILT DRAWING
-------
TABLE 1 • ANALYTICAL RESULTS MONITORING WELL ElE FIT2
Charles George Land Reel Mutton Trust Landfill
Tyngsboro, Massachusetts
fseple Location EM Nt2 Eastern Shallow Overburden
Screened Interval 21.0 to 45.0
Date Saapled Jul-84 Oct-M Jan-85 Feb-87 Mar-89 Nov-89 Dec-89 Jan-90 Jan-90 feb-90 Har-90 Apr-90 Hay-90 Nay-90 Jun-90 Jul-90 Aug-90 Sep-90 Sep-90 Oet-90
Stapled by NUS NUS HUI ECJordan NE1C CEI GEI GEI CEI CEI GEI GEI 6EI GEI GE| CEI GEI CCI 6EI CEI
CLP Duplicate CLP Duplicate CLP Duplicate
VOLATILE ORGANIC! (ug/L) * * *
Acetone J74000 R3700 U 2700 J1300 500 280 74 190 J580 660
2-lutenone J7400 440 12 4400 4300 J1300 1100 450 93 200 J490
2-Hejianone 500 UJ 10
4-Nethy-2-pmtanone R4600 710 J140 110 56 11 J150 J140 170
Benzene 560 R2400 73 670 MM 500 550 500 630 1200 J1200 1900 5200 1200 1200 1400 1700 1400
Toluene 930 4550 36 820 TOO J240 220 160 39 130 J120 51 4110 78
Ethylbenzene 61 J440 71 510 530 340 420 480 630 1200 J930 1500 5900 1200 1100 1400 1700 1500
Chlorobentene UJ 11
Xylenes (total) 130 « 48 290 J220 2410 310 370 700 JS60 870 3100 1100 670 940 1100 1100
Oiloroethane 53 61 110 UJ UJ 160
Tatrahydrofuran NT NT NT NT 3200 1500 1300 1108 810 1600 J2600 3000 11000 2000 MOO J3000 2700
1.1-Dlchloroethane 84 2 UJ
Trans-1.1-dlcloroethane 75 J960 UJ
1.1.1-THchloroethane IJ170 UJ
Carbon Tetrachlorlda 50 UJ
Chlorofora 50 UJ
Nethylene Chloride 4350 10000 111300 J1100 04130 854 880 U
1.4-Dloxane NT NT NT NT 490 R R
Ethyl Ether 4170
• Volatile* Analyzed Outside Holding Tie*
NOTE: this table adapted from Reference 11, Table C-9.
-------
TABLE 2
CHEMICAL CONCENTRATIONS IN LEACHATE (ug/L)
CHARLES GEORGE LANDFILL - 1989
TYNGSBORO, HA
Chemical
Volatile Organic
Compounds:
Ethyl Ether
Hethylene Chloride
Acetone
1,1-Oichloroethane
2-Methyl-2-propanol
Tetrahydrofuran
1 , 2-0 i ch I oroethane
2-Hethyl-2-butanol
cis-1,2-dichloroe thane
2-Butanone
2-Butanol
1,2-Dlchloropropane
Trichloroethene
1,4-Dioxane
4-Methyl-2-pentanot
Benzene
A-Methyl-2-pentanone
2-Hexanone
n-Propylbenzene
1 ,3,5-Trimethylbenzene
1,2A4-Trimethylbenzene
Toluene
Chlorobenzene
Ethyl benzene
1 .4-Dichlorobenzene
1 , 2-0 Ich 1 orobenzene
m- and/or p-xylene
o-Xylene
Total Xylenes
Carbon disulfide
East Leachate
Lagoon
March. 1989
15
ND
59
3
ND
1200
ND
ND
4
ND
ND
ND
ND
1200
ND
1
ND
ND
ND
ND
0.87
6
ND
2
ND
0.55
6
2
NA
NA
West Leachate
Lagoon
March, 1989
10
ND
500
ND
ND
160
ND
9
2
530
ND
ND
0.54
ND
72
1
110
23
ND
ND
1
26
ND
3
1
ND
7
3
NA
NA
Eastern Leachate
Collection Manhole
August 3, 1989
LS-101
NA
ND
ND
ND
NA
550
NO
NA
NA
ND
NA
NO
ND
ND
NA
87
ND
ND
NA
NA
NA
260
33
310
ND
ND
NA
NA
470
68 *
(Duplicate)
LS-104
NA
ND
ND
ND
NA
620
ND
NA
NA
58
NA
ND
NU
ND
NA
85
ND
ND
NA
NA
NA
240
32
260
ND
ND
NA
NA
450
67 *
Seeps at Western
Toe of Landfill
August 3,1989
LS-102
NA
ND
ND
ND
NA
16
ND
NA
NA
NO
NA
ND
ND
ND
NA
6.1
ND
ND
NA
HA
NA
ND
ND
10
ND
ND
NA
NA
57
ND *
Southwest Swale
Area
August 3,1989
LS-103
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
East Seep
December, 1989
NA
NA
NA
NA
NA
2.100
NA
NA
NA
ND
NA
NA
NA
NA
NA
ND
NA
NA
NA
NA
NA
ND
ND
93
NA
NA
NA
NA
190
ND
CO
o
ND - Less than Limit of Detection
NA - Not Available
* - Trip Blank Resulted in 12 ug/l
NOTE: this table adapted from Reference 12, table A-l.
-------
Table 3
Charles George Landfill Worst-Case Vent Gas Data (mg/m3)
ECJ 1987 (a) NUS 1986 (b) NUS 1984-85 (b) CARB Study (c)
Chemical Vent 5 Vent 7 Vent 12 Vent 5 Vent 12 95th Percent!le Maximum
*********
5.4
4.4
0.7
7.0
15.2
26.4
94.1
186.7
12.0
4.7
***********
0.4
0.1
0.3
0.1
0.1
3.0
2.0
3.6
17.2
0.8
1.4
3.4
0.1
0.1
r**********«******»*
28.0
60.0
0.7 220.0
4.2
9.4
0.2 102.0
2.8
2.8 128.0
1.5 38.0
10.6 82.0
0.4 4.2
0.5 16.0
64.0
30.0
0.7 30.0
60.0
164.0
i**********i
4.1
0.8
0.2
0.1
2.9
1.8
2.0
280.0
677.7
177.8
5.0
16.0
0.6
0.6
0.4
0.5
1.2
37.8
77.8
94.4
6.7
17.8
13.3
1.0
222.0
70.0
170.0
3.8
0.4
3.2
2.6
1.8
133.3
288.9
40.1 306.0
14.0 59.4
84.0 560.0
12.4 518.4
11.2 1,536.0
25.5 187.2
2.8 392.0
1.0 53.9
3.2 13.2
tetrachloroethene
trichloroethene
methylene chloride
1,1,1-trichloroethane
benzene
vinyl chloride
1,2-dichloroethane
chloroform
carbon tetrachloride
toluene
ethylbenzene
total xylenes
chlorobenzene
4-methyl-2-pentanone
2-butanone
acetone
chloroethane
1,1-dichloroethane
trans-1,2-dichloroethene
a) E.C.Jordan Co./Ebasco Services Inc (see Reference 13 (RI), Tables 10-24 or 12-23).
b) NUS Corporation - all values are approximate (see Reference 13 (FS), Table F-2).
c) Converted from pom as listed in Reference 14, Table 1.
-------
H. COMMUNITY RELATIONS
307
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BELLS AND WHISTLES: COMMUNITY RELATIONS
DURING REMEDIAL DESIGN AMD REMEDIAL ACTION
(Author(s) and Address(es) at end of paper)
INTRCDOCTICtJ
Many project managers are familiar with the cxxnmunity relations
needed in order to get a Record of Decision (ROD) signed. These requirements
include: remedial investigation (RI) kidcoff meeting, RI public meeting,
community updates, press inquiries, other public meetings and briefings and
finally — the public comment meeting on the proposed plan in the feasibility
study (FS). The community relations program has successfully involved the
public in the Superfund process and has become an integral part of the RI/FS.
However, as projects move into the remedial design and remedial
action (RD/RA) phase, a strong community relations program should still be
maintained. Two problems can arise: RD/RA community relations requirements
are not as developed as in the RI/FS and, as can happen during the RI/FS
process, good community relations does not necessarily mean that all community
problems or objections can be adequately resolved. This paper will discuss
RD/RA community relations requirements under the National Contingency Plan
(NCP), why it is important to maintain good community relations, and three
case studies showing varied results. Finally, it will analyze what has been
learned and provide recommendations for appropriate RD/RA community relations.
The first case study will discuss a successful community relations
program during remedy selection that has been somewhat stymied by an
individual wanting to change that remedy. The second one will outline how
poor community relations during the RI/FS has led to numerous problems in the
community's accepting the selected remedy. The last one will discuss how a
oommunity initially resisted EPA actions but, based upon changes in EPA's
response to community needs, now accepts and supports the cleanup. In all
cases, the focus will be on the importance of good community relations during
RD/RA, how important it is to build upon the success of the RI/FS program, and
on numerous unexpected problems that still arise even in the best designed and
implemented RD/RA community relations program.
The NCP outlines three requirements for RD/RA community relations:
an announcement that EPA has signed a record of decision, an update of the
community relations plan (if needed), and an opportunity for a public meeting
when the design is completed.
While the Remedial Project Manager (RPM) may feel the majority of
community involvement may be over as soon as the ROD is signed, that may not
be the case as there may be an entirely new community dynamic at work. RD is
a process that normally does not incorporate public opinion. Because the
process does not have clear public participation milestones, EPA does not meet
with the community regularly. Accordingly, when issues do arise, a forum does
not exist for the public to communicate with EPA.
What may occur is a shift in community acceptance of the ROD,
whereby what at first appeared to be a good or accepted solution, may be met
with community hostility later. When information is not adequately conveyed
by EPA, many other comments, points of view or recommendations may surface
from external sources that may undermine the support of the ROD. Of course,
just the opposite may occur. The public may have accepted the ROD and is
waiting for EPA to implement the remedy.
308
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In either case, why should EPA implement more RD/RA community
relations than is required? After all, the ROD is signed. The public can't
change EPA's alternative now, can it? There are two answers to that question.
One is that EPA has the responsibility to keep the public informed and
involved in its Super-fund process. The second is that good community
relations simply helps avoid, mitigate or resolve community conflicts. This
selfish reason can help motivate EPA personnel to keep the public informed and
involved. For either reason, the gauntlet is still placed before EPA. Active
community relations is not only something that will keep the project moving
smoothly—it is also the right thing to do!
CASE STUDIES
I. Case Study
A. Site Description
1. Marion (Bragg) Dump Superfund Site
2. Marion (Grant County), Indiana
3. Final on NPL September 1983
4. RI authorized in 1985 (a few samples taken in 1985); RI started
February 1986
5. Originally operated as a local dump; accepted municipal
wastes, and semi-solid, liquid and potentially hazardous
wastes from nearby companies
6. Contaminants of concern: ammonia and inorganic compounds
(arsenic, barium), polycyclic aromatic hydrocarbons -
contaminating soils and ground water
7. Interim ROD (addressing surface soils and on-site wastes)
signed September 30, 1987; this is Operable Unit 1 (of
three; the remaining two to address ground water and the on-
site pond)
8. Major elements of remedy: capping the site, regrading portions
of site's surface to promote surface water runoff, fencing
the site, replacing on-site wells, deed restrictions,
protecting the site from Missessinewa River floods to help
maintain the cap, monitoring ground water
B. Issues and special problems during RI/FS
Few citizen concerns relating to the Superfund site were recorded
prior to the 1987 interim ROD. Concerns about other area dump sites were
expressed to the RPM, and referred to the Indiana Department of Environmental
Management (IDEM). Concern about public use of a neighboring recreational
facility was referred to the Indiana State Board of Health. Media coverage
was regular but not oriented toward controversy.
C. Attitude of community toward interim ROD
The RPM visited neighbors of the site and was available frequently
to them, but few residents attended public meetings. Most who attended the
January 1986 RI/FS kick-off meeting were homeowners living adjacent to an
operating landfill. They wanted it closed and were referred to the State.
They also were concerned about the possibility of arsenic in their wells and
309
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were given appropriate advice for this concern. At the time of the PCD, the
landfill they were concerned about was closed, and that group of citizens did
not attend the August 1987 FS/Proposed Plan public meeting.
No comments on the Proposed Plan were received from the general
public during a five and one-half week public comment period.
D. Remedial Design Community Relations
Acceptance of EPA's decision did not continue, unfortunately. A
local citizen-activist, previously inactive, became active after the ROD was
signed. She has maintained a volunteer leadership position in a local
environmental group ever since the ROD was signed; the group vocally and
industriously opposes the interim remedy. The activist's involvement is first
recorded in 1988. Opposition activities read like a laundry list:
April 29. 1988 - letter from the activist to Basil Constantelos,
then Director of the Waste Management Division in Region 5: she "would like
the Environmental Protection Agency to hold a public hearing within thirty
days ... in regards to the Marion/Bragg Dump ..." She did not fail to mention
she and friends had "walked on the dumpsite," describing portions of the visit
as "real gruesome, ... a mess!" Not trusting the chosen technology, she said
she looked forward to receiving his reply within 10 business days and to
meeting with EPA officials within 30 days. (EPA's responded that since there
was no new information about the site, there was no reason to have another
public meeting.)
September 12, 1988 - letter from U.S. Representative Jim Jontz to
Mr. Constantelos, in response to citizen pressure, requesting a meeting about
the site. Region 5 Administrator Valdas Adamkus replied that a meeting would
be held.
September 16. 1988 - EPA conversation record shows that Jontz's
representative thought there was "some misinformation out there," that
Congressman Jontz's office did not necessarily believe the remedy was wrong or
should be changed, and that he did not know why the opposition group was so
late in getting involved. He requested a meeting (referenced above) with EPA,
the congressman and members of the group.
Spring 1988 - letter-writing campaign to Basil Constantelos (it
cannot clearly be said that the local environmental group organized the
campaign) opposing the remedy, saying a clay cap was unacceptable, and that
instead of a cleanup they were getting a "cover-up." Most said they expected
a reply in 10 days and a public hearing in 30 days. The reply explained EPA's
public involvement process prior to the interim ROD. Why the remedy would
properly address contamination at the site was reiterated; the letter
concluded, "... [s]ince the remedy presented in the ROD has not been changed
and there has been no new information ... that significantly changes the
information upon which the selection of the remedy was made, there does not
appear to be any reason to have another public meeting at this time. ...
[T]here certainly has been every attempt made to communicate with the
community. ..." Also, "[t]he site will be cleaned up. A clean-up does not
310
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necessarily mean that the wastes will be removed." U.S. Senator Richard
Lugar, Senator Dan Quayle, State Representative Tracy Boatwright, and Basil
Constantelos also received opposition letters.
September 1988 - petition drive with more than 700 signatures:
"We demand, as an emergency measure, that a fence be constructed to
prevent children, adults, and wildlife from entering the Marion/Bragg
Dump. We demand signs be posted informing people that this is a
hazardous waste area. We demand both actions be taken within 30 days
upon receipt of this petition."
Copies were sent to Senators Lugar and Quayle, Congressman Jontz, former
Governor Robert Orr, Secretary of State Evan Bayh, IDEM Commissioner Nancy
Maloley, and other local and EPA officials. Signatures were gathered from
Marion and neighboring communities, including Indianapolis, which is more than
50 miles away. Three local activists, including the previously mentioned one,
submitted the petitions to EPA Administrator Lee Thomas. EPA's response said
concerns would be discussed in a meeting (mentioned above).
October 25. 1988 - meeting! The CRC, former RPM and new RPM
attended the meeting. TV, radio and newspaper media were present (probably
called by the local activist group); nearly 50 residents attended. The CRC's
notes said, "[w]hat was to have been a small information committee meeting
turned into a full scale media event and public meeting." In the 3-hour
meeting the RPMs and CRC were "questioned, drilled ... verbally abused" and
"on the firing line for the remedy selected for the ROD." EPA was criticized
for not keeping the public informed. The activist delivered a handwritten
list of 12 questions to the CRC. (The RPM responded to these in detail.) The
CRC told those present that if EPA was to revisit the ROD, a great deal of
time would be lost, that the study might have to begin anew. The activist was
reportedly "disturbed that [the CRC] mentioned this to the audience and
demanded [he] refrain from stating this fact. [The CRC] explained ... this
was the process and these were ... instructions." This meeting was held prior
to a congressional election. (The local newspaper reported the meeting in a
low-key way, not mentioning major controversy.)
February 1989 - community interviews for revision of the Community
Relations Plan (CRP), primarily in response to the activist and her efforts to
discredit EPA's decision. Many citizens expressed good will and a desire for
the cleanup to progress rapidly, but the activist had contacted the press and
her group, saying EPA was coming to town to discuss problems at the site with
her. As a result, an article appeared in the local paper the day before the
interviews, saying a meeting was scheduled with the activist, that she
"planned to talk to other environmentalists before the meeting so they could
help her plan for it," and that "[h]er organization disagrees with the EPA's
... cleanup plan."
February 2. 1989 - follow-up article quoted the CRC as saying,
"We're here to find out how we can best convey the information to the public,"
and that EPA requested of the activist and her group "if they would be willing
to come up with a list of residents to whom information might be mailed in the
311
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future." The activist told the reporter, "I think they ought to get off their
butts and do their job. They shouldn't be here asking me to do their job for
them. It's up to them to see who should be getting the information."
September 1989 - approximately 100 form letters sent by citizens
to Adamkus (copies to Lugar and Coats), protesting the remedy, and saying EPA
had not done an adequate job in the RE and had shown a "callous disregard" for
community health. Mary Gade, Associate Division Director, Office of
Superfund, responded, saying there was no new technical data indicating the
remedy needed to be reconsidered. She reiterated EPA's public involvement
process, and responded to each point in the letters.
October 19. 1989 - EPA meeting to announce the beginning of RA.
Thirteen people signed in (including three EPA officials, two IDEM officials,
the congressman's representative, and the City of Marion (Community Development
Director). The activist, her parents (who live in Marion) and another
representative of the environmental group attended. She opposed the cap, and
voiced concerns about ground-water quality and possible migration of
contaminants. Reportedly, she did not clearly elaborate, but did assert
resentment toward EPA for not keeping residents better informed. EPA held a
press conference after the meeting.
November 13, 1989 - another meeting requested by the congressman's
office. Locally generated publicity indicated this would be a "public
meeting." Less than 20 people attended, several of whom were EPA or Indiana
officials. Two activists attended from outside Marion; they had been involved
with the environmental group and begun attending site-related meetings.
Opposition was again raised to the remedy; they called it "Mickey Mouse."
(Prior to this meeting, EPA had received a letter from Lugar and Coats,
requesting information. They were told of the meeting, and of EPA efforts to
ensure the remedy was appropriate and properly constructed. They were
informed EPA had told the public EPA would "like to set up availability
sessions approximately once a month in Marion while work is going on at the
site.")
January 23, February 21 and March 20, 1990 - meetings to keep the
public apprised of construction activities, attended by about a dozen people
each.
April 25, 1990 - group tours outside the perimeter of the site,
attended by more than 30 persons, and several members of the media.
At two of the meetings, the activist handed lists of 27 more
questions for the RPM to respond to in writing. At all meetings, she hammered
out questions and challenged the remedy. On the April tour, the two non-
Marion activists attended, went on every tour (though tours were by sign-up
only), dominated questioning, and confronted EPA personnel in front of the
television camera. A 10-foot banner was hung on the site fence; it read
"Water Pollution Happening Here" in bright-red letters. The CRC and RPM were
asked if they wanted to pose with the banner for a photograph to be used on
postcards.
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Throughout - letters sent to various officials, including a
Freedom of Information Act request from the activist. In EPA's opinion, they
were responded to promptly and thoroughly. The consistent EPA response
outlined how the public had been kept informed, where the public information
repository was, and how the public could get more information.
August 21, 1990 - meeting regarding the proposed consent decree
for site cleanup, finally lodged July 20, 1990; public comment ran for 60 days
(extended on public request). EPA wrote and mailed a fact sheet, and locally
placed an advertisement announcing decree's lodging (neither required for this
DOJ action). The RPM also called the activist as soon as he found out what
day the Federal Register notice was published. The CRC, RPM and EPA attorney
were at the meeting, attended by approximately 40 citizens. Though the remedy
was not to be on trial, most people did not understand that, or else did not
accept it. Lots of hostility, derision and challenge was directed to EPA's
representatives, including from the non-local activists. (They video-taped
this meeting, as they had all other meetings.) Public comment was voluminous,
primarily relating to the remedy and/or ROD. (The Department of Justice (DOJ)
will, in this case, respond to comments about the ROD in a public document.)
As of this writing, the cap on the site is complete and RA is
almost finished. A major flood swept Indiana this winter, and covered parts
of the site; the cap held up very well, with need for minor repairs. When the
activist was told this, she replied, "Well, what about the next flood, or the
next one, or the next one?" She also wondered when the next meeting would be
held.
E. Community Relations Results
Clearly, this site has caused overwhelming consternation to
certain members of the community. The results of CR activities, in spite of
producing considerable quantities of information and using great amounts of
time and energy, and (according to whispered assertions) making many
townspeople pleased with what's being done at the site (and reportedly tired
of the activist), have not served to accommodate the activist or her group's
demands. And, because she has had considerable contact with her congressman,
unusual numbers of demands for meetings and information have been placed on
EPA. EPA has stood by its decision throughout, which has made it difficult to
implement effective CR activities for the broader community.
F. Analysis
It would be difficult to propose that something different could
have been done before the ROD to improve community relations. EPA personnel
who got involved after the ROD have been constantly met with derision and
challenge. Also, it has become known that even though the opposition is
outspoken, they do not necessarily represent a majority opinion. The Spring
1990 tours were particularly helpful in highlighting what has been done on
site, giving ordinary citizens information and a look at the work.
Perhaps this inflamed the opposition. An activist with the
tenacity, grit and sole-purpose nature of the Marion activist can become a
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formidable adversary, even after the ROD has been signed. Even so, her
concerns and questions are taken seriously and responded to in the best way
possible.
Perhaps the best thing that can be done at Marion (Bragg) is to
continue to respond to requests for information, to keep members of Congress
informed, not only of what is happening at the site but how EPA is responding
to constituents' concerns, and to develop creative ways of reaching the rest
of the public. The tour was one such effort. EPA efforts must be more than
just reactive or responsive, though.
Public meetings will continue to be held, to keep faith with EPA's
statement that they would be held regularly. It is important to continue
keeping the public informed, even "overinformed," and to be available as often
as is practicable.
Finally, it must be remembered that good community relations does
not necessarily convert all people to EPA's point of view. At this point, EPA
is not trying to convince the activist that the remedy is proper, nor that she
should accept it. EPA has decided, based on the best scientific evidence
available, that its decision is the best one for the site.
II. Case Study
A. Site Description
1. Westinghouse Sites, Bloomington IN. Consists of 8 sites: 6
covered under a consent decree (4 NPL, 2 non-NPL) and 2
removals
2. 7 sites located in Bloomington, IN and Monroe County; one site
located in Owen County, east of Monroe County.
3. 4 NPL sites final between September, 1983 and June, 1986.
4. RI never completed (see Section B).
5. Five of the sites are closed landfills; one is a former sewage
treatment plant; one is a salvage yard; one is an operating
factory.
6. Contaminants of concern: more than 650,000 cubic yards of PCB-
contaminated materials (soils, capacitors, sewage sludge,
stream bed sediments)
7. There was no formal ROD for this site. The Enforcement
Decision Document was signed in December 1984; this provided
the basis for the consent decree that was signed at the same
time.
8. The consent decree requires that the responsible party,
Westinghouse Corp., undertake a number of interim measures
to reduce any further migration of PCB's into the
environment (i.e., cap the landfills, clean stream beds,
monitor the sites). Once completed, Westinghouse is
required to construct and operate an incinerator for 11 to,
15 years to destroy the entire amount of contaminated
materials.
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B. Issues and special problems during RI/FS
As stated previously, this site did not have an RI/FS prepared for
it or a formal cxmimunity relations programs. EPA Region 5 first became aware
of a PCB problem in Bloomington in the mid 70's prior to the passage of
Superfund. At the time, the only legal authorities available were the Clean
Water Act and the Toxic Substances Control Act (TSCA); neither of these had
jurisdiction to require Westinghouse to pay for the PCB cleanup. By late
1980, EPA legal and technical staff had developed an enforcement case against
Westinghouse for PCB contamination at two of the six consent decree sites.
The Superfund law passed in late 1980 and EPA shifted its case,
filing a Superfund complaint against Westinghouse. Concurrently the City of
Bloomington and the County of Monroe filed suits for two other non-NPL sites.
Because of the ongoing litigation and because there was no formal
EPA guidance on how to conduct an RI/FS, EPA did not do an "official" RI/FS
for these sites. Rather, the team of experts and litigation witnesses
conducted a number of studies that identified the problems and proposed
solutions. Much of the rationale and decisions made regarding alternative
selection was conducted through review by experts and meetings with the
litigation team. Consequently, much of the decision-making process or
alternatives assessment was not documented. The primary reason for this was
that EPA was uncertain if this case would go to trial, so the information was
considered "enforcement confidential."
Finally, because the Superfund enforcement program was new, there
were not the formal procedures which are now in place to conduct RI/FS's at
responsible party lead sites. Rather, EPA prepared an internal Enforcement
Decision Document which outlined its negotiating position in case EPA were to
go to trial. Therefore, no formal Record of Decision was prepared at these
sites nor was there a formal community relations program in place during this
time.
The result of all these studies and internal discussions was that
EPA's Superfund case was joined by the City's and County's cases and taken to
Federal District Court for trial. The judge required the parties to negotiate
with Westinghouse to reach a settlement. The major parties - U.S. EPA, the
City of Bloomington, Monroe County, the Indiana State Board of Health (the
former Environmental Division is now the Indiana Department of Environmental
Management which is now called IDEM) and Westinghouse - spent more than 18
months working on a settlement.
By December 1984, the parties reached a settlement which required
Westinghouse to construct an incinerator to destroy all the PCB-contaminated
materials at 6 selected sites which contained the majority of the PCB
contamination in Bloomington and the surrounding area - more than 650,000
cubic yards of materials. In order to make the incinerator financially viable
for Westinghouse, the parties agreed that the fuel used would be the city's
municipal waste stream. It was also agreed that the incinerator would be used
only for this purpose and would operate for 11 to 15 years. Four of the sites
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were on the NPL; the other two were added at the request of the City and the
County to reduce their liabilities to clean up those sites.
Ihis agreement was filed in Federal Court and subjected to a
lengthy public comment period, from December 1984 to August 1985. More than
15 public meetings and information forums were held by EPA and the City of
Bloomington regarding all aspects of the consent decree. Despite numerous
comments opposed to the incinerator and the closed manner in which the
investigation and alternatives array process was developed, the consent decree
was lodged in Federal District Court in August 1985.
In spite of the court ordered decree, progress has been
exceedingly slow in implementing its terms. Westinghouse has implemented a
number of the interim measures but has been slow in designing and constructing
the incinerator. Additionally, Monroe County officials had raised some legal
issues that were time-consuming to resolve, and there has been a general
slowness by all of the parties to put together achievable schedules. In large
part, EPA was hampered by the lack of a full-time RPM and CRC devoted to the
site to insure that the project stayed on schedule. All this occurred from
mid-1985 to mid-1988 when EPA finally assigned a full-time, more experienced
RPM to the project.
Also, by 1989, all the consent decree parties were meeting
quarterly to discuss site problems and come up with solutions. By December
1990, EPA had negotiated an implementation schedule with all consent decree
parties. It outlined the submittal of permits, review and approval time,
public involvement steps, the timing for incinerator construction, test burns,
final approvals and actual start time for the incinerator.
C. Attitudes of community toward ROD
To this day, the community believes that it did not have adequate
opportunity to participate in the process to properly identify the problem (it
believes much more contamination exists), to look at possible solutions (it is
opposed to incineration and wishes it could have discussed alternatives), and
to have their voices heard in opposition (it felt the consent decree was a
"done deal" and public comment had no impact upon it).
During the negotiations and intensifying during the public comment
period, numerous local groups directly attacked EPA as doing a poor job in ;,
protecting the interests of Bloomington residents. The majority of protestors
and public comments were from college students, a fair number of "counter-
culture" individuals, university professors, and local branches of national
environmental and civic groups (League of Women Voters, Audubon Society).
There appeared to be very few comments from the average Bloomington resident
who may have felt the problem affected some persons on the other side of town
(most of the sites are located in poorer sections of Bloomington).
It appeared that very few persons were aware that the plan called
for incineration and what incineration would mean to Bloomington.
From mid-1985 to now, the most vocal local group opposed to the.
construction of an incinerator is People Against the Incinerator (PA3T). From
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their previous statements and physical appearance, PATI is perceived as a
"counter-culture" group and receives little credibility from roost Bloomington
residents. PATI has approached Region 5 and Headquarters numerous times over
the last six years to complain about: the remedy, the lack of an RI/FS, mixing
municipal solid waste with PCBs (because it believes it is an unproven and
dangerous incineration technology), and the lack of public involvement in the
decision-making process. PATI is also affiliated with and an active supporter
of Greenpeace Action and other nation-wide groups that are opposed to
incineration.
By mid-1989, IBM determined that ash from a hazardous waste
incinerator must be disposed of in a special waste landfill which must meet
the same requirements as a hazardous waste landfill. The Federal judge
required Westinghouse to identify a location for that landfill in Monroe
County. This meant that no longer would the ash be disposed of near the
incinerator as originally outlined in the consent decree but that the ash
would be transported to another location in the county. By early 1990, rumors
circulated that Westinghouse had found a location in a geologically
appropriate location north of town (In spite of the fact that Monroe County
consists primarily of a porous underground structure called karst which cannot
be used for landfills). A number of the residents in that area formed a group
named Coalition Opposed to PCB Ash in Monroe County (COPA).
COPA consists of business persons, nurses, service sector persons
and others heretofore not associated with this issue. COPA also has
considerable support from a wealthy resident whose home overlooks the location
for the proposed landfill. COPA has been trying to raise the community's
consciousness regarding the consent decree and the impact it will have upon
the oanmunity. Letters to the editor from COPA members have been published in
the newspaper, it has published a 11-page brochure, placed billboards and
posters in town, and even produced a 30-second television ad alerting Monroe
County residents to what it feels are problems with incinerating PCB's with
municipal solid waste. Based upon newspaper coverage and comments related
directly to this author on numerous occasions, they have been successful in
alerting many members of the public to this issue.
COPA has been effective in contacting State and Federal
politicians and working with them to stop the incinerator, and trying to
reopen the consent decree. Due to COPA, a recent bill was introduced and
passed through both chambers of the Indiana legislature that would effectively
block construction of the incinerator unless the local County solid waste
management district approved of it. If the Governor signs the bill and if the
county solid waste district does not approve the incinerator, this could pose
a major roadblock to construction of the incinerator.
Also, pressure from COPA has already been influential in the
mayor's race. The current mayor, who signed the consent decree in 1985, is
now lobbying EPA headquarters (HQ) for a change in TSCA's PCB cleanup rules to
allow the city more latitude in dealing with PCB cleanups. The mayor has
attacked Westinghouse's proposed technology as inadequate for health
protection even though she supported it previously. Her opponents have
accused her of using this as election year grandstanding.
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The best way to characterize the current level of community
attitudes towards the consent decree is that it has been "de-radicalized."
The entire issue of incineration, PCB control alternatives, hazardous waste
landfilling, the consent decree, and all associated topics have been topics of
newspaper editorials, television and radio shows, speaking engagements at
civic and public service clubs, and other public forums. The public feels the
consent decree approach is inappropriate and another alternative besides
incineration should be pursued in Bloomington.
D. Remedial Design Community Relations
Since remedial design for this site actually started after the
official lodging of the consent decree in Federal Court, EPA has a long
history of community involvement. Immediately after the consent decree was
lodged, EPA attorneys believed that community relations would be conducted
locally, and the city and county would establish a community relations
program. However, this did not happen and site-information gaps occurred.
EPA did send out sporadic fact sheets and press releases covering a number of
the interim measures from 1986 to 1988. Without a strong presence, however,
EPA did a poor job of communicating its actions and responding to community
criticisms of how the interim measures were completed.
At the same time, EPA was receiving a steady stream of letters to
the HQ Administrator and Regional Administrator complaining about EPA's so-
called illegal actions and the lack of public involvement in the decision-
making process. Recognizing this as a problem, a Public Information Center
was established in January 1989 in Bloomington to be an information conduit to
the public and to receive public input on the project. It is also an ideal way
for EPA to monitor public opinion by tracking telephone calls and newspaper
articles. Finally, the office allows EPA to be apprised of events in the
cxjmmunity.
EPA staff use this office when visiting the community to arrange
meetings with concerned individuals, brief elected officials, and by holding
press conferences on key announcements. Having a local office facilitates EPA
staff in responding to questions and following up on information requests when
making public appearances in Bloomington. Also, based upon the numbers,
types, and frequency of phone calls and walk-in visitors, it appears that
community members find the local office beneficial in recieving information
from EPA as well as sharing their views with the local office. EPA's CRC and
RPM keep daily contact with the contractor staff in the office.
By summer 1989, EPA had a request from PATI to start a Citizens
Information Committee (CIC) that would meet monthly to communicate with
residents about what is taking place at the sites in town. EPA agreed and
chose a representative sample of individuals and groups to be on the CIC. It
has been meeting since November 1989 and, while it has taken some time for it
to find its focus, it has proved to be a valuable communication technique for
EPA and the CIC members. CIC meetings have discussed, among other things,
pros and cons of incineration, Indiana requirements for hazardous waste
landfills, and a proposed schedule for incinerator and landfill construction.
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It has allowed EPA and the public to discuss various consent decree issues in
a cordial and informative manner.
Community relations plans have been prepared for the consent
decree and removal sites. Future community relations will include the monthly
CIC meetings, response to community requests for speaking engagements, and
development of fact sheets for the community at large. EPA will continue to
foster and maintain strong press relations so that EPA can get coverage of our
activities.
E. Community Relations Results
As EPA has increased its presence in the community, it has
improved its ability to communicate with residents. Previous communications
with EPA were done via telephone or letter. With an office staffed by
contract personnel, people drop by regularly to pick up fact sheets, EPA
policy guidance, EPA reports and other information generated during the course
of investigations.
Equally important is the image that EPA projects in Bloomington.
As the issues have increasingly entered the public forum, EPA is there to
respond to them with as much information as possible. EPA is no longer
surprised with announcements since local office staff are there to pick up the
information as soon as it is available. Based upon comments directed to one
of the authors, EPA has become somewhat trusted as a knowledgeable member of
the community and not perceived as "carpetbaggers11 who come and go without
sensitivity to the aommunity's needs. Also, because EPA has committed to the
monthly CIC meetings, EPA is perceived as a viable party to the consent
decree.
However, this does not mean that EPA's position is accepted in the
community. The community interpreted EPA's incineration implementation
schedule as a "war-cry" inciting it to mobilize its resources in order to stop
the incinerator.
Even with that type of response, EPA still recognizes that the
public demands and expects as much information from us as possible, and it is
our duty to supply it.
F. Analysis
Overall, community relations at this site have gone from terrible
to good in that disagreements still exist but now there is a regular forum to
discuss those. Because of this site's early history, there is still
considerable antagonism towards EPA and the other consent decree parties.
After all, an RI/FS was not done and pre-RDD public participation guidelines
were not followed. As a result, the public thinks the consent decree should
be null and void. That is quite a hole that EPA needs to dig itself out of.
Being aware of that negative perception, EPA's goal is not to try
to change the remedy, but to acknowledge the community's concerns. At the
same time, EPA firmly believes what it has done is neither illegal nor
invalid, and that it will proceed with the cleanup.
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The local office and the CIC have provided a communication avenue
to the community. They have provided a new array of individuals to talk to in
a non-threatening and informational forum. They have raised EPA's presence
and credibility in the community, and allowed EPA to provide much more
information to the public than ever before. EPA is well aware that many
negative perceptions continue. The goal, however, is not to try to change
minds or even to influence local decisions, but to simply provide information
so the public can make its own decisions.
This is never an easy task. Many times EPA personnel can be
intimidated by arguments made or by charges leveled in the newspaper.
Oftentimes, without a community relations plan that sets a context for EPA's
activities in a community, the RPM may not respond to complaints or charges,
and EPA is viewed as evasive. In this case, with a strong local presence and
knowledge of all the events occurring, EPA is in a position to aggressively
identify issues, make statements, or respond to charges in a positive manner.
While this level of effort cannot be afforded at every site, in Bloomington,
IN, it has proved to be money well spent.
III. Case Study
A. Site Description
1. Seymour Recycling Superfund Site
2. Seymour (Jackson County), Indiana
3. Final on NPL September 1983
4. RI started August 1983; RI report issued May 1986
5. Originally operated as recycling and disposal facility for
chemical wastes; 50-60,000 55-gallon drums and 100 large
tanks, all containing chemicals, found on site.
6. Contaminants of concern: Ground water - shallow aquifer highly
contaminated with more than 90 different hazardous organic
chemicals, including 1,2-dichloroethane, benzene, vinyl
chloride, & 1,1,1-trichlorethane. Major portion of the
contaminant plume extended approx 400 ft. from site
boundary; lower concentrations of organic contaminants found
as far as 1,100 ft. from boundary. Soils - hazardous
organic and inorganic chemicals (>54 identified, including
high concentrations of 1,1,2-trichloroethane, carbon
tetrachloride, 1,1,2,2-tetrachlorethane, & trichloroethene;
and low concentrations of inorganic compounds - lead,
arsenic, beryllium). Surface water & wildlife contamination
- contaminants reached East-West Creek.
7. ROD (addressing contaminated soil and ground water) signed
9/30/87
8. Major elements of remedy: Manor elements of ROD - (1) On-site
building demolished. (2) Soil vapor extraction system to
remove volatile organic chemicals. (3) Nutrient
application to soil to promote biodegradation of
contaminated soil. (4) Multi-media cap. (5) Ground-water
pump and treat system to prevent further contaminant
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migration and clean up contaminated ground water. (6)
Remove one foot of contaminated sediments and placed under
multi-media cap. (7) Seal residential and business wells in
Snyde Acres. (8) Dispose of other on-site materials. (9)
Restrict access to and use of site. (10) Monitor ground
water and air. NOTE: As a result of public ccnments and
information obtained during negotiations, EPA revised the
recoranended remedy. Changes - (1) Soil vapor extraction
(SVE) system modified to use horizontal rather than vertical
pipes. (2) Ground-water extraction system modified to use
two off-site extraction wells, in addition to the plume
stabilization well system already on the site (rather than
four on-site extraction wells, one on-site injection well,
and one off-site extraction well). Ground water would not
be pumped from the deep aquifer unless contaminant
concentrations at site boundary found to be above cleanup
standards. (3) Design of multi-media cap was changed. (One
layer eliminated, synthetic liner made thinner, slope
reduced).
B. Issues and special problems during RI/FS
A 1984 community relations plan recounts concerns of the public,
discovered during community interviews prior to the start of the RI.
Residents of Snyde Acres, a subdivision threatened by ground-^water
contamination, were particularly concerned about health risks. They felt the
community had not received adequate or consistent information. Also, since
studies and tests had been conducted for years, they thought cleanup should
start.
The Seymour Chamber of Commerce showed interest very early in the
site's history. It felt the site was an eyesore in the middle of prime
industrial property, and a deterrent to new business.
The Chamber organized a task force to study options for cleaning
up the site in the late 1970s. In 1980, local residents formed an ad hoc
group to bring public attention to the site and make information available,
maintain pressure on regulatory agencies responsible for action, and support a
proposal to provide City water to Snyde Acres residents (accomplished in
1985). Media attention and public scrutiny intensified when fumes released
hazards of unknown toxicity into the air in March 1980. The media reported
that about 100 nearby residents were temporarily evacuated from their homes.
Although residents' concerns about the threat of explosion or fire
at the site were allayed with a 1982 surface cleanup, their opinion of EPA
remained low because of the following perceptions:
* EPA delayed the cleanup;
* 1982 subsurface investigations were inaccurate or incomplete;
* EPA and the State had done little cleanup work;
* Potentially Responsible Parties were responsible for cleanup success;
* EPA did not support use of settlement monies for City water hook-up to
Snyde Acres (in fact, EPA and DOJ did not oppose this);
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* EPA was not cornmunicating well with the public.
Accurate and consistent coraraunication with the public, telling
people what was going to happen and when, sharing information with the Task
Force at least monthly (for dissemination to other interested parties) and
providing three information repositories (at the Chamber, City Hall and the
library) were requested of EPA.
Seymour's mayor had a poor opinion of EPA's cominunication with the
public, and suggested better and more regular information. The League of
Women Voters suggested more efforts be made to directly involve the public.
Media coverage abounded. The New York Times covered an October
1982, $7.7 million, court-supervised agreement with PRP's. The Indianapolis
Star reported on U.S. House Public Works Committee hearings on the cleanup at
Seymour (called a "case study" by the Committee's Chair; he wondered "....why
it took years to get federal action on the site and why local citizens could
not get state of federal officials interested.") The Chicago Tribune and the
Milwaukee Journal reported the controversy as well.
Considerable correspondence from the executive vice president of
the Chamber (the EVP), dating from 1984, while expressing appreciation for the
water hook-ups to Snyde Acres, reported growing local frustration at a lack of
current information. In response, a regular and frequent series of
updates/fact sheets was begun to keep the public informed of EPA activities.
October 1984 - correspondence from the EVP expressed concern about
potential danger from contamination in deep wells at the nearby Elks Club, a
desire for City water to be extended there, and displeasure with the proposed
timetable for the Remedial Investigation report and Feasibility Study. This
letter was copied to the U.S. Senators and Representative, and other
officials. EPA explained that extension of water was being considered and
that EPA was trying "to complete the RI/FS in the shortest timeframe possible
without jeopardizing the thoroughness and accuracy of the studies."
August 14, 1985 - the EVP again wrote EPA Regional Administrator
Adamkus:
"First, we do have a surface clean up and city water to Snyde Acres, but
not without having to push, prod, threaten and fight for every inch of
progress that was made. ... [A]nd of all the promises the EPA has made,
not one time, in my memory, have they ever got something done on time or
when they promised it. That leads me to believe your people are very
inefficient and/or your subcontractors are inefficient and unproductive.
... We consider the subsurface problem at SRC to be a most important
community problem and the continued wasting of time is irritating,
dangerous, and unhealthful. Therefore, we are asking for your personal
commitment to speed up the evaluation procedures of the groundwater
testing... Our desire is to get this whole problem behind us so we can
leave you and your people alone to address other problems "
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By this time, Congressman Lee Hamilton was writing EPA, concerned
about the delay. EPA's response said all necessary steps would be taken to
minimize the delay as much as possible.
January 1986 - the EVP wrote Judge William Steckler, who would
decide on EPA's request for an extension for the RI. He said he believed EPA
was acting irresponsibly and requested that the judge "get tough" with EPA.
The judge said he understood the community's frustrations and need for
information, and responded by saying he believed the request for an extension
to complete the RI/FS was needed and was made in good faith and in the best
interest of the public.
June 1986 - the EVP expressed to EPA his perception, from reading
the RI, "that we have some serious problems in every aspect of the
investigation," but that he had "every intention of waiting for" the FS, due
in September.
Further (Community anger and frustration is not documented beyond
the last 1986 letter.
The Phased Feasibility Study (PFS - to evaluate an interim remedy
for ground-^water contamination) was completed in August 1985; public comment
was accepted from August 15, 1986 to September 8, 1986. A public meeting was
deemed unnecessary for the PFS because completion of the final FS was due
September 1. The final FS was completed August 29, 1986, public comments were
accepted September 13, 1986, to October 24, 1986, and the ROD was signed
September 30, 1987.
C. Attitude of the community toward ROD
By the time of the October 1986 proposed-plan public meeting,
community anger and vociferous concern had quieted significantly. It is
interesting to note that the first person to speak from the floor was the
Chamber's EVP. His first statement was in thanks to EPA for having the
meeting, and for an excellent presentation. He asked several questions of
fact throughout the rest of the meeting. Some Snyde Acres residents asked
questions about the value of their homes, about health effects for residents
and about possible side effects of the remedy.
Other questions related to the funding of the cleanup (especially
as costs might affect the City in the future), and to the capacity of the
City's water treatment works to handle pretreated discharge from the site.
At no time did anyone angrily challenge EPA or the speakers.
October 20, 1986 - the EVP wrote Adamkus, expressing appreciation
to EPA staff for "an outstanding presentation" and stating that the Chamber of
Commerce accepted the proposed remedy. He encouraged EPA to do things as
expeditiously as possible to get started on the cleanup. He also requested a
listing of activities and a timetable.
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The League of Women Voters sent a letter expressing appreciation
for the meeting, saying it was the best one ever held in Seymour. They also
expressed an understanding of the decision-making necessary to choose a
remedy.
The Responsiveness Summary for the PFS recorded the submittal of
two letters from the public in favor of the remedy. The Responsiveness
Summary for the final FS recorded no comments from the general public, other
than those made at the public meeting.
The opinion of one news reporter, spoken to this author, is that
public opinion improved dramatically after the ROD was signed, in part because
of the excellence of EPA's public presentations.
About 14 people attended a public meeting on August 31, 1988,
about the proposed Consent Decree (to record who would conduct and pay for the
remedy). About 110 PRP's joined in the Decree, creating a trust fund to
manage and pay for the cleanup. (About $16 million had been accumulated at
the time of the public meeting.) In the agreement, the City agreed to treat
the site's pretreated, discharged water; to perform routine cap maintenance;
to finance two per cent of the cost of repairing the cap should it fail; and,
if the public treatment works were to become unavailable for treatment of site
discharge, to pay 15 per cent of the additional costs of treatment.
Near the end of the meeting, after several technical questions had
been asked, as well as questions as to how the public would be kept informed,
the EVP said he was pleased with the consent decree, but not without
acknowledging that getting to that point was a long and arduous task, and that
a lot of patience had been lost in the process. He also said that although a
timeline had been proposed, based on past experience he expected it not to be
met. Congressman Snores, and Senators Lugar and Quayle, concurred with the
EVP.
September 1. 1988 - the EVP wrote a letter to the CRC,
congratulating him and the RPM for running a smooth public meeting. He
restated his support for the remedy and said he thought the public was
pleased.
The tide had turned!
D. Remedial Design Community Relations
EPA has continued to make information available to the public,
though the frequency and regularity of written updates has diminished during
remedial action. Since February 1990, regular updates have been sent to the
local cable channel, where time has been purchased on a news program. The
update is read as a news story; every other time the story is accompanied by
video footage.
The latest public meeting was in March 1990. About 15 residents
attended. Letters, phone calls and complaints have been virtually non-
existent since the ROD was signed.
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An important aspect of comraunity relations in Seymour has been the
work of the Seymour Trust, and its Trustee, Monsanto Corp. An information
center has been set up at the construction site, with documents and a large
photo display for viewing, and personnel available for questions. The center
is an impressive effort by a PEP willing and able to provide the public with
detailed yet accessible information. A small tower has been built outside the
exclusion zone that can be used to view the site. While the Trustee manages
this, it has greatly enhanced EPA's community relations efforts.
E. Community Relations Results - outlined throughout
F. Analysis
The vigorous (even if perceived as belated) response of EPA to
demands for attention by the public and local officials helped convince
Seymour residents that the work being done, and the way it was being done, was
the best way to accomplish a long-term remedy that would best serve public
health and the environment. The EVP, a battering ram at times, demanded
response, but also served to make citizens aware of what was happening. The
reasoned (though occasionally vitriolic) content of his cxntnrnunication provided
a venue for response and action.
That EPA did respond, acknowledging the sense of demands (in
particular for information), and went along with local requests (such as for
three repositories and more than normal numbers of written updates), probably
added to the credibility of the Agency.
But the contribution of local City officials (such as the City's
attorney who worked so hard on the Consent Decree), and more than cooperative
trustees, especially Monsanto Corp., must be acknowledged as crucial. Only
with the cooperation of all parties were community relations efforts
successful.
Although "success" cannot always be measured by how well or how
much the public accepts the remedy, or how good they feel toward EPA, at the
Seymour Superfund site, "success" can incorporate these elements. Over the
many years of activity, public perception of EPA's role changed perceptibly.
Initial negative feelings were repeated at the public meeting, and EPA was not
allowed to forget it was considered slow from the start. But those factors
were not allowed to negatively affect the perception of a remedy and a Consent
Decree designed to protect health and the environment. RA has gone smoothly
ever since.
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IN CONCLUSION...
While many might think that what the authors are about to say is
obvious, it bears noting that the following must be understood when facing a
community during RD/RA.
First of all, community relations never ends at a Superfund site.
While adequate to good community relations activities might not produce the
results EPA personnel would want, too few, inappropriate, or poorly planned
activities will never result in positive community relations. This is true
during RI/FS, as well as post-ROD.
But, as RD/RA differs from RI/FS, so do community relations differ
for both phases of Superfund work. During RI/FS, a decision is led up to, and
finally made. Community relations during that time focuses on making
information available and involving the public in the decision. During RD/RA,
the dissemination of information is still important, but later challenge to
the decision can happen, in which case an expanded sense of how to keep the
public involved is needed.
The goal, however, is not necessarily to get people to accept the
PCD. That would be nice, always, but if EPA's process has been thorough and
of high quality, then the ROD will stand and some members of the community may
stay frustrated. EPA personnel must stay sensitive to that, but not let it
keep them from proceeding with RD/RA. After all, especially if opposition
borders on harassment, or does not truly represent the community at large, it
must be remembered the remedy is designed to protect human health and the
environment. That may be the most important message EPA can send: the EPA
personnel working in a local community are there because they want to and are
mandated to serve the public.
As much as some may not believe this, a single person can create a
movement in opposition to a remedy that can all but derail work at a site.
Work will go on, of course, demands for information (bordering on minutiae),
FOIA's, public attacks (including personal attacks), form letters, petitions,
ad nauseam f can make EPA personnel wish community relations requirements would
evaporate (perhaps accurately supposing that more opposition is in store).
Also, many people want to believe misinformation. If it is
presented by a voice that has developed its own credibility ("I was talking
with the Senator when I was in Washington, and he told me..."), then EPA will
have quite a job countering what is wrong, with what is correct. "You're a
bureaucrat, and..." has been thrown at many RPM's and CRC's, as we all well
know.
Some recommendations can be made. First of all, remember that,
while we all have individual limitations, if we have done our job accurately,
thoroughly and to the best of our abilities, we must not take attacks
personally. Some people may try to launch personal attacks, but, since we can
be secure in the quality of our work, attacks cannot be allowed to color our
willingness to respond to the community's needs. We are government
representatives and, as such, often are not trusted. If this is understood
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from the outset, we can actively work on creating a public face that is worthy
of trust for those who rely on us for information.
Second, we must keep actively involved with the public throughout
RD/RA. Many RPM's and CRC's are overworked, and cannot devote the "friipg they
would like to individual sites. But several things can be done to counter
this limitation. We must be willing to meet the public, and not use overwork
as an excuse to have as few meetings as possible. "X don't have anything new
to tell them" is also unacceptable. Sometimes people just want to see a face
and have someone who can answer questions. Being present often enough to be
able to recognize people, and build alliances, can go a long way to successful
community relations.
Third, existing local organizations can help build bridges in the
community. These people have already done much groundwork that can be
expanded on. They will appreciate it that you recognize their place in the
community, as well.
Fourth, phone calls should be used to keep people informed.
"We're here, we haven't forgotten you, we want you to feel comfortable calling
us" are all important messages to send, over and over again.
Finally, do quality work and build on what you and others have
done during RI/FS. Be prepared. Read notes and records so when you attend a
meeting you can anticipate concerns, recognize names, and provide information
that is relevant.
These are the "bells and whistles" that penetrate the noise of
opposition. They aren't "smoke and mirrors, " techniques to cover up and
mislead. EPA has an obligation to investigate, study and clean up, but also,
equally, to honestly inform and be available.
Author(s) and Address(es)
Karen M. Martin
U. S. Environmental Protection Agency, Region 5
Office of Public Affairs
230 South Dearborn St.
Mailcode 5-PA
Chicago, IL 60604
(312) 886-6128
and
John P. Perreoone
U. S. Environmental Protection Agency, Region 5
Office of Public Affairs
230 South Dearborn St.
5-PA
Chicago, IL 60604
(312) 353-1149
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Effects of Public Input and the Sampling Protocol on the
Remedial Design Process
Raymond M. Plieness
Bureau of Reclamation
Grand Junction Projects Office
PO Box 60340
Grand Junction, CO 81506
(303)-248-0688
INTRODUCTION
As the engineering world tackles the massive task of cleaning up our environment we find the
work not only technologically challenging but also requiring local, state, and world acceptance.
The trend of determining the most cost efficient remedy based only on technical factors without
public support can no longer be the rule. This approach has run at least one superfund site
ashore. The ship is moving ahead again largely due to the insistence that the program meet
remedial action goals with a cost effective remedy that maintains the flexibility to meet
residential homeowner needs as part of the design process.
As remedial actions increase in residential communities, the necessity of allowing flexibility in
the design process cannot be stressed enough. Without the ability to meet individual homeowner
needs, schedule and cost delays will be the rule not the exception. Even when utilizing remedies
that have been proven over time and are minor in technical considerations and relatively accepted
by the environmental and engineering communities, owner considerations must be included or
the remedy may not be -the most cost effective after schedule and cost delays are considered.
BACKGROUND
The Smuggler Mountain Site (site) is located in Aspen, Colorado. The old Smuggler Mine
workings are located ^at the base of the western side of Smuggler Mountain. Waste rock and
tailings from the mine cover much of the site. The mine wastes range from exposed, covered,
or in many instances, mixed with native or imported soils. Much of the 110 acre site is
developed. Some of the development is on top of the waste while in other cases waste piles have
been moved and remain on the edges of the developments in the form of berms and mounds.
The residential cleanup, operable unit # 1 (OU#1), consists of 2 large condominium complexes,
154 single family dwellings, numerous 4-12 unit apartment complexes, and a tennis club.
In the early 1980s soil analyses, first conducted by residents and later by the EPA and the
potentially responsible parties (PRP), identified concentrations of lead up to 46,000 parts per
million (ppm). Elevated levels of cadmium and other metals were also found. The potential for
ground water contamination was also identified during the investigations. The site was proposed
for the National Priorities List (NPL) in October 1984 and officially listed in May 1986.
In 1986, the EPA and the PRPs selected a remedy for soil cleanup in the residential area of the
site. The remedy included creating an on-site repository to dispose of waste soils over 5,000 ppm
lead. Waste soils with contamination concentrations between 1,000 and 5,000 ppm of lead were
isolated by capping them with 6 to 12 inches of clean topsoil and then revegetating them. This
also provided an alternative water source for residences who were utilizing ground water as their
source of domestic water. During the design of the remedy, EPA conducted additional soil
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sampling which indicated the contamination was highly variable in both the horizontal and
vertical profiles. Based on this new data, EPA elected to review the proposed remedy. In March
1989, EPA drafted and presented to the community of Aspen an Explanation of Significant
Differences (ESD). The main difference between the 1986 Record of Decision (ROD) and the
1989 ESD was that the depth of the clean fill cap was changed from 1 foot to 2 feet for areas
between the 1,000 ppm and 5,000 ppm range. Additionally, the requirement for the repositories
to have a cap permeability of 10-7 cm/sec was omitted as the soil sampling indicated the leaching
of the hazardous materials was not a problem.
Public reaction to the ESD was generally negative. The need for any remedy was questioned.
The risk assessment had not convinced the majority of the risk at the site.
Based on public reaction and the failure to gain public acceptance of the latest changes to the
remedy, additional meetings between the EPA and the Pitkin County Commissioners were held.
These discussions were the basis for yet another ESD in March 1990. The remedy was changed
from a 2-feet soil cap back to a 1-foot cap with a geotextile barrier for much of the site and a
6-inch soil cap with stringent institutional controls for the two large condominium complexes.
A requirement for additional soil sampling of each property was included in order to verify if
and to the extent that contamination existed on that property.
The public comments to this ESD were similar to those in the previous ESD. The questions still
indicated anger and frustration with the process. Many of the questions, however, were of a
more personal nature. The people wanted to know what the remedy meant to them as a
homeowner and what construction on their property would consist of.
DISCUSSION
The final ESD laid the ground work for building a firm base to approach the homeowners about
the effects of the remedy on their property. This provided an opportunity to deal with actual
homeowners and property issues rather than public outcry and general distrust. A main feature
of the ESD was a commitment to complete soil sampling on each individual property. This
commitment was the result of residents and local authorities requesting this procedure and EPA
reviewing the newest (1988) soil sampling data which indicated that significant random
distribution warranted the expense in order to save remedial action costs later. The public
comments in this area centered on the actual sampling protocol. The sampling plan was finalized
in June 1990.
The original approach to the sampling protocol was a statistical one which provided results that
required remediation of the entire property or none of the property. After numerous discussions,
the protocol agreed upon was a discrete sampling effort with individual results standing alone.
This approach was consistent with all previous sampling programs at the site. Samples
represented areas of specified size which determined which areas needed remedial action. The
flexibility within the protocol allowed field crews to designate areas for sampling that qualified
not only from a sampling approach but also from a design approach. The need to later remediate
these areas was discussed with the location flagging members and, occasionally, design team
members accompanied these teams to assure design needs were being met.
This sampling protocol provided the flexibility and forethought so that effective data could be
directly incorporated into remedial action designs. Too often the efforts of site sampling are not
well coordinated with the design parameters. In the latest sampling event at this site this problem
was avoided by careful consideration of the design approach during development of the sampling
plan and by effective follow through in the field.
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Much of the publics' concern over the previous processes at this site was considered when
developing the design philosophy. The following issues appeared to be the most important to
overcome in the design phase:
(1) The public consistently indicated a mistrust in the representatives sent to discuss the
remedy as previous representatives changed their decisions after consultations with the
home office.
(2) Numerous times the public agreed that the things discussed at these meetings might work
on their neighbors property but not on theirs.
(3) The public was no longer patient with excuses for schedule delays, and would likely not
tolerate them in the future.
The design philosophy was established to provide the greatest opportunity to move this project
into construction at the earliest possible date. The five underlying parameters of the philosophy
were:
(1) Keep your tool box as full as possible.
(2) Maintain consistency without sacrificing flexibility.
(3) Cost efficiency is required but to save a dime on individual considerations that do not
account for the increased costs overall will not be tolerated.
(4) Field designers must have the authority to agree to a remedy with the homeowner.
(5) The commitments made by the designers must be drawn for each lot with concurrence
signatures by the homeowner, EPA, and the contracting agent (the Bureau of
Reclamation).
To implement these parameters, a design criteria sheet was established for each physical item
anticipated on the site. To assist in this effort a group of properties chosen randomly, were
reviewed in detail with photographs and onsite review. The list of criteria was planned to be
general enough so that the designers could know the criteria by memory. It was felt that owner
reaction would be more favorable without the designer using a large volume of notes or guidance
sheets during interviews. It was also felt that if the design criteria were too specific, the
flexibility the program was striving for would be eliminated.
Based on this approach, 24 design criteria were developed.
The guidance sheets allowed for State and EPA approval. The public was also given an
opportunity to understand the design issues prior to discussing them in the field. A typical
design criteria sheet is shown in attachment 1.
Trees required special attention. Due to the publics' concern for remediation of their trees,
special care was taken to assure that all reasonable options were considered. Seven options to
remediate around trees were established.
The first design parameter was to keep the designer's tool box full. The tool box referred to the
options or methods available to the designer in accomplishing their work. The parameter tried
to avoid sending a plumber out to fix a leaky faucet with a hammer and nails, which sometimes
happens when options are discarded too early in the process. This parameter allowed the
designer maximum opportunities to successfully meet owner needs while maintaining the
remedial requirements. With the criteria sheets providing at least three options for each issue,
the tool box was full to meet the owner needs. This approach was foreign to many of the design
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staff. Often the trend of the design engineers is to design a feature, complete the required
drawings and specifications, and stand firm that this is the best way, and sometimes the only way
to solve the problem. By eliminating this thought process and assuring that the professional
engineering expertise was utilized to provide technically sound guidance to the owner in mixing
and matching their available tools, technically sound protective remedies were developed that also
were acceptable to the owner.
The second parameter was to maintain consistency without sacrificing flexibility. Again, the fact
that each criteria sheet had a minimum number of three criteria provided this flexibility. The
limitation to meet the issue with one of these three options assured relative consistency.
Consistency was also established by having field engineers review each others work, thus
providing a cross check and an assurance that the criteria sheets were being interpreted
uniformly.
The third parameter seemed to be the most troubling to the people involved in the project. The
legal staff pressed hard to assure that the absolute cheapest technical approach was completed.
Though cost efficiency was indeed the objective of all participants, the consideration of cost
effectiveness were not always the same. With a significant inflation rate to consider, it was
imperative that decisions be made that would allow for the remedy to start and finish as soon as
possible. Individual items of virtually no cost effectiveness were internally scrutinized. It
became apparent that the path to cost efficiency lie in assuring a reasonable remedy that the
public could accept at the earliest date was ultimately the most cost effective project. An
example of this was the change in the criteria sheet for flowers. Originally, up to 20 perennial
plants were being replaced. The public strongly disagreed with this approach, it was not an
improvement, and left them with less than they had prior to remediation. To compensate for the
change, the owners identified their plants and we would verify this during the preconstruction
conference. By doing this we saved the cost of having a horticulturist identify the 20 plants and
the increased cost of plants was minimal in most cases. This minor change may not make the
difference between public opposition and support, but, the attitude displayed by the cooperation
clearly provided a window of opportunity.
The fourth parameter allowed the field designers the authority to agree to a remedy with the
homeowner. This parameter, more than any other, made the designers task possible. The
homeowner's knowledge that the individual discussing their property could make onsite decisions
without approval by someone else, clearly made a difference in executing the design interviews.
The parameter is risky, but with selected staff it can produce a result that everyone can live with.
The fifth parameter provided an approved lot plan to the homeowner giving them that final level
of trust. Not only did it leave them with a document verifying the agreements made during the
interview, it also was one of the first times they received a hard copy commitment.
CONCLUSION
A design process can and should be formed to ensure that remedial goals are met, yet the process
should be flexible enough to meet individual owner requirements. Without a commitment to
model the sampling protocol around a remedial design approach and to meet homeowner needs
in the design, the overall cost effectiveness will likely suffer.
DISCLAIMER
The above are the opinions and thoughts of the author and should not be considered EPA's, the
Bureau of Reclamation's or the publics' position on these issues.
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REFERENCES
U.S. Environmental Protection Agency. September 1986. Record of Decision. Smuggler
Mountain. Pitkin County. Colorado
U.S. Environmental Protection Agency. March 1989 Soil Cleanup of Smuggler Mountain Site.
Explanation of Significant Differences.
U.S. Environmental Protection Agency. March 1990 Draft. Soil Cleanup of Smuggler Mountain
Site. Explanation of Significant Differences.
U.S. Environmental Protection Agency. July 6, 1990. Final Sampling and Analysis Plan for
Smuggler Mountain. Aspen. Pitkin County. Colorado.
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Field Design Criteria Sheet
Project: Smuggler Mountain Site
Issue Number: 3
Topic: Raised Patio, Decks, Walkways or Stairs
Date: March 8, 1990
Entry by: CBV
Structurally Sound is defined as an item that is functioning
properly for its intended purpose and will not be harmed during the
remedy.
Remedy Choices
A. Stay in place and excavate around if structurally sound, cost
effective and:
1. There is no access to the contaminated material under the
structure for people or animals, or
2. Access to the contaminated material under the structure is
available only through a locked passageway, or
3. Contaminated material under the structure is isolated by
a permanent cap, or
4. Skirting and a lockable access can be provided, or
5. A permanent cap can be provided under the structure
such as 1 foot soil cap over a geptextile or concrete
or asphalt.
B. Remove and replace with the same after remediating area below,
if:
1. Cost effective, and
2. Approval of owner (alternative is to not replace, remove
only)
C. Remove and replace with similar structure from approved choices
if:
1. Cost effective, and
2. Approved by owner, or
3. Existing structure is not structurally sound design and
can not be easily adjusted to such.
EPA Approval
Colorado State Approval
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III. CONSTRUCTION MANAGEMENT ISSUES
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REMEDIAL DESIGN AND REMEDIAL CONSTRUCTION
AT THE PICILLO FARM SITE
Mark L. Allen and Stephen J. Buckley
Bechtel Environmental, Inc.
P.O. Box 350
Oak Ridge, Tennessee 37831-0350
(615) 220-2000
INTRODUCTION
This paper describes the successful remedial design and remedial
construction efforts at the Picillo Farm Site in Rhode Island. The
source control remedial measures performed at the site and
described below illustrate how projects of this type can be
appropriately managed and completed to the satisfaction of all
participants.
In the Background section of this paper, the location and history
of the Picillo Farm Site is presented. While the site received
wastes for only a short time, it has special significance in the
development of the Superfund program and still affects program
decisions today. The Record of Decision (ROD) process and the
project scope are also described.
A detailed Discussion section relates how the work was organized
and performed. This section describes specific work practices that
resulted in cost or schedule benefits and lists recommendations and
suggestions for improving performance on similar projects.
BACKGROUND
Site Location
The Picillo Farm Site is located in Coventry, Rhode Island,
approximately 20 miles southwest of Providence and 1 mile southwest
of the intersection of Route 102 and Perry Hill Road (Figure 1).
The area used for disposal consists of approximately 8 acres of
cleared land that is surrounded by woodlands and wetlands and that
slopes to the northwest toward a swamp (Figure 2). This site was
listed on the first National Priorities List (NPL) published in
September 1983.
Site History
Over a period of months in 1977, drums of hazardous wastes and bulk
materials were illegally disposed at the site. A serier of
trenches were excavated at various locations and used for disposal.
An explosion and fire in September 1977 attracted the attention of
regulators to the disposal activities.
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PICILLO SITE PLAN
Figure 2
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Since the discovery of the dumping activities, a number of
investigations and remedial activities have been conducted. The
Rhode Island Department of Environmental Management (RIDEM) and the
Environmental Protection Agency (EPA) have been jointly involved in
these efforts.
In September 1980, the Northeast Trench was excavated by a RIDEM
contractor, and 2,314 drums were removed. Soils from this trench
were contaminated with PCBs and other organic contaminants and were
stockpiled in the southeast corner of the site. This material is
referred to as the PCS Pile.
Another RIDEM contractor began excavation of drums from the
Northwest Trench in March 1981 and concluded in June after 4,500
containers and the contaminated soils had been removed. Those
soils and drums were disposed offsite.
In May 1982, RIDEM contractors began excavation of the West Trench,
South Trench, and two slit trenches. During this effort, 3,300
drums were removed and disposed offsite. The contaminated soil
from the excavation contained elevated concentrations of phenol and
was placed into two piles near the center of the site (Phenol Pile
and Phase 3 Pile). This action completed the removal of buried
drums that had been identified by previous studies. Exploratory
excavations were conducted around the site and no additional drums
were discovered.
Table 1 shows the 1985 estimate of the soil pile volumes and
average contaminant concentrations.
Table 1
Average
Contaminant
Concentration
Volume* (1985)
PCS Pile 3,500 cy 36.8 ppm
(180 ppm max.)
Phenol Pile 2,000 cy 70 ppm
Phase 3 Pile 1,000 cy 3,000 ppm
* 1985 Estimate
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A RIDEM contractor began landfarming the Phenol Pile in September
1982 and continued for several months. Phenol concentrations in
this soil decreased from approximately 870 ppm to about 70 ppm.
Pilot studies conducted to determine the biodegradability of
contaminants in the PCB Pile showed that landfarming would not
produce satisfactory results on that material.
Following completion of additional studies and a public comment
period, the initial ROD was signed September 30, 1985. The
selected remedy addressed source control and involved the onsite
disposal of contaminated soils in a RCRA/TSCA landfill.
Groundwater remedial action was not specifically addressed. A
remedy for this issue was to be selected in a later ROD.
After the initial ROD was issued, the state of Rhode Island filed
suit to prevent implementation of the selected remedy. The basis
for this suit was a state law that prohibited the land disposal of
"extremely hazardous waste" as defined in the state statute. This
state law directly applied to the PCB Pile materials. At the time,
EPA's position was that Superfund remedy decisions were legally
exempt from State and local laws. However, the Superfund
Amendments and Reauthorization Act of 1986 (SARA) required EPA to
conform the selected remedy to the State's standard prohibiting the
land disposal of "extremely hazardous wastes." As a result, a
second ROD was issued March 3, 1987 that specified the offsite
disposal of contaminated soils and the implementation of other site
closure and operations and maintenance (O & M) activities. This is
the source control ROD that was ultimately implemented at the site.
Project Scope
In August 1987, four major chemical companies entered into a
Consent Decree and agreed to perform the following:
• Dispose of the PCB Pile, Phenol Pile and Phase 3 Pile,
accumulated samples, empty drums, and miscellaneous
debris at an offsite location
• Install a perimeter fence
• Install a run-on control and runoff management system
including filling, grading, and vegetating the site for
erosion control
• Maintain the site for one year
Bechtel under contract to these firms, provided design engineering,
project management, onsite construction management, and health and
safety services during the project.
Prior to field implementation of the remedy, a work plan covering
remedial design and remedial action was developed and negotiated
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with EPA and RIDEM. Bechtel then proceeded with developing the
remedial design and solicitation of bids for the remedial action.
Following EPA and RIDEM approval of design documents remedial
action commenced.
DISCUSSION
Project Schedule
The schedule was a major factor influencing the sequence and timing
of project operations. The project schedule as implemented is
shown in Figure 3.
The schedule for the project was complicated by the length of the
construction season and provisions of the Consent Decree. The
relatively short construction season required earthwork and seeding
to be completed by early-to-mid-October to avoid freezing weather
and conditions adverse to plant growth. The other complicating
factor was a provision in the Consent Decree that required the
removal of all hazardous materials from the site within 120 days of
work plan approval. Another provision required all work (except
seeding) to be performed within 90 days of waste removal; penalties
were to be assessed for each day of noncompliance.
As Figure 3 shows, all Consent Decree milestones were met and the
work was completed significantly ahead of schedule. Consent Decree
milestones are shown as planned events on Figure 3.
Work Plan
Immediately following the Consent Order effective date, Bechtel
began preparing the work plan. This document addressed all aspects
of the project and was prepared in accordance with the EPA document
"Remedial Design and Remedial Action Guidance."
The work plan consisted of the following:
• Introduction and Purpose
• Design Engineering
• Permits
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CO
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WORK / MONTH
ACTIVITY /WK. ENDING
PRC-OEStCN ACTIVITIES
•WORK PLAN* MCLUDES A
WORKER HEALTH AND SAFETY
PLAN. SPU CONTNGENCY PLAN 1
SCHEDULE
SITE OPERATION 4 MANTENANCE
PLAN AND CONTRACTOR QUALITY
ASSURANCE/OUA1JTY CONTROL
PLAN
EP/VRIDEM
FMAL APPROVAL
DESIGN ACTIVITIES
SURVEY SERVICES' WORK SCOPE.
TECHNICAL SPECIFCATON AND
DESIGN DRAWNQ
CONSTRUCTION TRANSPORTATION
AND DISPOSAL SERVICES' WORK
SCOPE -TECHNICAL
SPECIFICATIONS AND DESIGN
DRAWMGS
EPA/ROEM FMAL APPROVAL
CONSTRUCTION ACTIVITIES
CONSTRUCTDN AND FMAL
TOPOGRAPHIC SURVEYS
MOW. EATON AND SITE
PREPARATION
EXCAVATCN. TRANSPORTATION
AND DISPOSAL OF CONTAMMATED
SOL
TRANSPORTATION AND DISPOSAL
Of LIQUID SAMPLES
REQUIRED COMPLETION OF
DISPOSAL ACTTVTTeS
B ACKFUMQ. REGRADNQ.
FENCING. AND SEEDMG
DEMOBILIZATION
REQUIRED COMPLETION OF BACK-
FILLING, REGRADNQ AND FENCMG
ACTIVITIES
FMAL EPAfRIDEM MSPECT1ON
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NOTES
I PER THE
SHOULD
WEEKENI
DEADLIN
CONSTR
THE NEXT
2. PER PAR
CONSEW
DATEwA.
PLANNEC
FORCC*
AND DSP
ACTUAL
DETERM
RIDEM Al
PLAN ON
3. PER PAR
CONSEW
DATE (PF
COMPLE-
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THEPLAI
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THAN HA
REMOVA
CONSENT DECREE.
A DEADLWE FALL ON A
0 OR HOLIDAY. THE
E HAS BEEN
JED TO CONTINUE TO
T BUSMESS DAY.
AGRAPHIOdOFTHE
T DECREE. THE 'flVH
S USED TO BEGN THE
1 120 DAY SCHEDULE
PLETNO EXCAVATION
O5ALWORK. THE
DEADLME Of V30S WAS
NED BY FMAL EPA t
•PROVAL OF THE WORK
MM.
AGRAPHtO.dOFTHE
r DECREE. THE 7/11/W
IOPOSED DATE FOR
riON OF DISPOSAL
IS) WAS USED TO BEGIN
JNEDW DAY SCHEDULE
PLETINa WORK OTHER
ZARDOUS WASTE
L
LEGEND/PLANNED
• DATE DUE
y ISSUED TO EPAWOEM
A START CONSTRUCTION
A COMPLETT- CONSTXUCTON
•»•• REPRESENTS INTERMrTTEHT
ACTIVfnES
LEGeNO/ACTUAL
O START
• COMPLETE
O REVISED DUE DATt
:1M!iH
V4?l'li!{*lMI
,'lf:HI,'l«J
DAK BIOGE. IENNESSEE I
30
OCT NOV | DEC
1988
P1C1LO FARM SITE
KENT COUNTY. RHODE ISLAND
DFIAFT SCHEDLILE
pn>)Kt Compl.bon Sdwlul*)
REV.
JOB HO.
19161-100
FIOURENO
9-1
1 - DECEMBER lim
Figure 3
-------
• Remedial Action
- Site Preparation
- Land Surveying
- Disposal of Contaminated Materials
- Site Closure
- Construction Monitoring and Inspection
- Disposal Facilities
- Post Closure Plan
- Health and Safety Plan
- Contingency Plan
- Schedule
- Work Not Included
- References
- Design Drawings (preliminary)
The work plan formed the basis for the remaining activities at the
site and received final approval (with comments) in March 1988.
Remedial Design
To expedite the schedule and allow remedial action to be conducted
during the 1988 construction season, design work proceeded in
parallel with work plan preparation. The design was submitted to
EPA and RIDEM for review and comment at the 30% and 95% stages and
for final approval at the 100% stage. EPA, RIDEM, and Bechtel
agreed that a review at the 60% stage would not be necessary, and
this milestone was eliminated from the schedule. Concurrent with
the remedial design, solicitation packages for the remedial action
were prepared. These documents were issued to prospective bidders
when the design was undergoing EPA/RIDEM review at the 95% stage.
Once final agency approval was obtained, contractors were selected
and contracts finalized. Contractors mobilized onsite the week
following design approval,
Of particular interest during the design phase was the procedure
used for selecting the final disposal sites. Under the terms of
the Consent Decree, the Potentially Responsible Parties (PRPs) were
to attempt to locate disposal sites for the wastes. If the PRPs
were unsuccessful, the Consent Decree (and SARA) required the State
of Rhode Island to identify and make a disposal site available.
As part of this process, firms bidding on the remedial work were
required to present a primary and secondary disposal site for
review and approval. This list of primary and secondary sites was
compiled and submitted to EPA for review. EPA reviewed each
facility on the list for compliance with the "offsite policy" and
found none to be in compliance. Alternate disposal sites were then
identified, with the assistance of EPA, and amended quotations were
requested from the bidders. Contract award was based on the
amended quotations. ^
342
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After this selection process, EPA approved the following sites for
disposal of materials from the Picillo Farm Site.
PCB Waste Chemical Waste Management, Emelle, Alabama
Phenol Waste Chemical Waste Management, Fort Wayne, Indiana
Chemical Waste Management, Emelle, Alabama
Liquid PCB Chemical Waste Management, Chicago, Illinois
Waste
Remedial Action
Implementation of the source control remedy began in May 1988 with
the mobilization of construction forces to the field. Bechtel
personnel made initial contacts with local officials and explained
project operations to local emergency services representatives.
Community officials were brought to the site prior to excavation
activities to familiarize them with the site, access routes,
project personnel, and objectives.
Personnel working at the site were required to comply with the
approved Health and Safety Plan, which included a medical
surveillance program and detailed requirements for training and the
use of personal protective clothing. These measures remained in
effect until waste had been removed from the site and areas were
released for backfill/grading operations.
During excavation operations, haul trucks were preweighed at
portable scales erected and calibrated at the site and then loaded
on an uncontaminated haul road constructed adjacent to all three
waste piles. A backhoe stationed on top of the waste pile being
excavated was used to load the trucks. A bulldozer pushed material
to the backhoe to facilitate loading and minimize the loading cycle
time. Once a truck was loaded, it proceeded to the decontamination
area; there a tarpaulin was installed over the bed and the truck
was washed. After this decontamination, trucks proceeded to the
scales where they were weighed and inspected. Manifests were
completed prior to leaving the site. Waste loads were tracked and
completed manifests were compiled to verify proper disposal of the
wastes.
Water generated during decontamination and other onsite operations
was collected and used to moisture-condition the soils prior to
excavation and transport. As a result, all water generated during
the work was utilized and none required treatment or offsite
disposal.
Excavation of the PCB Pile began in June 1988 and continued for
approximately one week. During this time, 6,212 tons (3,800 cubic
yards) or 281 truckloads, of soil and debris were removed. Average
production was 43 truckloads or 956 tons per day. Virtually all
343
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excavation work was conducted in Level C personal protective
equipment.
The Phenol Pile was removed over a two-week period. In the
excavation of this material, production was limited by the
receiving capacity of the disposal facility- In all, 6,426 tons
(4,100 cubic yards) or 284 truckloads of material were removed and
transported. Average production was 31.5 truckloads or 714 tons
per day- Similarly, the Phase 3 Pile was excavated over a four-day
period, with 1,073 tons (700 cubic yards) or 45 truckloads removed
and transported. Daily production on the Phase 3 Pile averaged 11
truckloads or 268 tons.
Concurrent with the soil removal operation, waste samples stored in
an onsite trailer were examined, tested, combined and shipped
offsite for disposal. In all, 5,111 sample jars were handled, the
majority of which contained solid materials that could be disposed
with the soil and debris. After compatibility testing,
approximately 30 gallons of PCB-contaminated flammable liquids
remained. These liquids were disposed offsite by incineration.
During the latter stages of Phase 3 Pile excavation, EPA approved
the use of an adjacent borrow area as a source of material for
backfilling the West Trench area. This backfill operation began as
the Phase 3 Pile excavation was concluding and continued for seven
working days. A total of 5,200 cubic yards (717 truckloads) of
backfill were placed; average daily production was 743 cubic yards
or 102 truckloads. Other areas of the site were regraded to
promote runoff. The areas formerly occupied by the waste piles did
not require regrading or backfilling, because these areas were
excavated such that their drainage characteristics were similar to
the surrounding terrain.
Initial reseeding of the site was performed in mid-October 1988.
The entire area within the perimeter fence, and selected areas
outside the fence, were sown with a grass seed mixture formulated
to provide adequate cover and erosion resistance while requiring
little maintenance.
The final EPA/RIDEM inspection of remedial construction activities
was conducted November 28, 1988. All construction activities were
approved and final EPA/RIDEM acceptance was obtained on January 4,
1989.
The 0 & M period began after acceptance of the construction work
and continued for one year. During the O & M phase of the work,
periodic inspections were conducted with EPA and RIDEM personnel,
minor regrading and erosion repair was completed; and selected
areas of the site were reseeded. The O & M period ended in January
1990 with EPA and RIDEM approval of all activities. EPA and RIDEM
also concurred that the terms of the Consent Decree had been
344
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satisfied and released the PRPs from further obligations under that
agreement.
Current site status
At the end of the 0 & M period, the site was in a stable condition
with a well established cover of vegetation. The areas formerly
occupied by the Phenol Pile and Phase 3 Pile exhibited little
residual contamination. However, while contamination levels in the
PCB Pile area are below the Federal standard of 50 ppm, the levels
are above the state standard of 1 ppm. Any future remedial action
on this material will be performed by the state.
Groundwater contamination still remains at the site. The source
control remedial actions described above were not intended to
directly contribute to cleanup of the existing groundwater
contamination, and this issue is still under investigation by EPA
and RIDEM.
RECOMMENDATIONS
As a result of work at the Picillo Farm site, the following
recommendations are made.
• Where possible, define operable units or work packages so
that fixed unit price contracts can be used, enabling
improved cost/schedule performance
• Where possible, negotiate Consent Decree terms to fix the
scope (in this case, excavation of piles to existing
grade) and avoid contamination chasing
• Encourage EPA and state agencies to commit to review
times in the Consent Decree
• Negotiate an agreement with EPA and the state agency that
either agency's onsite representative may act for the
other when absent
• Develop a working relationship with EPA and the state
agency to facilitate understanding of project goals and
operations
• Involve the EPA Offsite Policy Coordinator in disposal
site selection from an early date to avoid last minute
changes in disposal site status
• Coordinate site activities with local officials and
emergency service personnel and enlist their help in
community relations
34
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• Ensure project objectives are adequately defined for all
onsite personnel
• Prepare a community relations plan and indoctrinate all
onsite personnel in dealing with media and visitors
REFERENCES
U.S. Environmental Protection Agency, Record of Decision, Picillo
Farm Site, Coventry, Rhode Island; September 30, 1985.
U.S. Environmental Protection Agency, Amended Record of Decision,
Picillo Farm Site, Coventry, Rhode Island; March 3, 1987.
Bechtel Environmental, Inc., Final Report for the Picillo Farm
Superfund Site Remediation Activities, Oak Ridge, Tennessee;
January 1989.
346
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Remedial and Post-Construction Activities
at the Triangle Chemical Company Site
Roger C. Brown, P.E., Project Manager
Roy F. Weston, Inc.
5599 San Felipe, Suite 700
Houston, Texas 77056
(713) 621-1620
INTRODUCTION
The conditions found at Triangle Chemical Company, which was a typical small chemical company,
may represent the picture of thousands of other similar companies around the country. This will only
become evident when they cease to operate or are forced to investigate "normal, minor" spills.
BACKGROUND
Triangle Chemical Company is a bankrupt, abandoned chemical blending and packaging company.
It is located on Coon Bayou which is a tributary of Cow Bayou in Bridge City, Texas. Figure 1 and
2 show the proximity and location of the site. EPA took control of this superfund site in 1982 after
a follow up visit of a fish kill investigation. The officials found the site deserted and subsequently
conducted an immediate response action. They removed approximately 1,000 drums containing
21,000 gallons of liquid waste which were stored on the ground in the open with no containment.
Figure 3 shows the condition of the site at the time.
Contamination remaining at the site was generally volatile organic compounds in the soil and upper
aquifer. In addition there were several large tanks with another 50,000 gallons of various chemicals.
These were emptied and cleaned during the Remedial Action(RA).
The soil below the surface layer is generally clay, with occasional sandy lenses, which are not
interconnected. The clay continues to about thirty five feet below the surface. There are some
shallow (less than 75 foot) wells in the area, but all known domestic water wells are in the deeper
aquifer at a depth of three hundred to four hundred feet.
The Site Remedial Investigation(RI) and subsequent Feasibility Study(FS), Remedial Design(RD),
administration of the Remedial Action(RA) and Operation and Maintenance(O&M) were all
performed by the Houston office of Roy F. Weston, Inc, West Chester, Pa.(WESTON) under a contract
issued by Texas Water Commission(TWC). This is a state lead Federal Superfund site. The RA
contractor was Ensco Environmental Services, Port Allen La.(ENSCO)
REMEDIAL ACTION
Following a detailed RI/FS by WESTON, mechanical aeration of the soil and natural attenuation of
groundwater were chosen as the selected treatment methods. Mechanical aeration (soil tilling) was
tested to verify the effectiveness, utilizing a full scale pilot study during the RD phase. The results
of this pilot study were also used to form the basis for development of field controls for the
remediation. The remediation was conducted by ENSCO on a compressed, 5 week, schedule, and was
completed in February, 1987.
347
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TRIANGLE CHEMICAL CD,
Figure 1 Site Location Map
Figure 2 Vicinity Map (from USGS Quad Orangefield TX-LA)
348
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1 , 1-
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Figure 3 1982 Aerial Photo before Immediate Response Action
349
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SOIL REMEDIATION
There were three areas identified on the site in which the upper four to six feet of soil were
contaminated with volatile organic compounds. This depth corresponds to approximately mean sea
level in each case with the groundwater level about one to three feet below the surface. These
contaminated areas are shown on figure 4 and are identified as till areas A, B, & C, inside the bold
outlines and can be seen in figure 5, also surrounded by hay bales. The soil in each of the areas is
generally sandy or silty for the first two feet and a heavy clay with occasional small sand lenses from
two feet to about thirty-five feet below the surface.
The Specifications called for the soil in each area to be tilled in layers up to eight inch thick until the
level of volatile organics in each layer tested below 5 ppm using a field jar test described later. Each
layer was to be tilled, tested and removed to a stockpile the same day so that loose soil would not be
left spread out and exposed over night. In addition, each of the active till areas were to be covered
at night to protect them from rain. This was to continue until no more contamination was detected
or until groundwater prevented them from continuing. After off site laboratory verification was
completed, the contractor would be allowed to use the decontaminated soil to backfill the excavations.
Early in the remediation, due to the limited space, ENSCO chose to use a large garden tiller, partially
shown in figure 6, but soon found out that a heavier machine was needed. The sandy soil broke up
easily with the small tiller, and only required a few hours of work before the six inch tilled layer was
ready to move to the stockpile and start on the next layer. The six inch layers were actually only
about four inches in place, so progress was slow. The highway mixer, shown in figure 7, was brought
in when progress was at about sixteen inches deep level, and progress improved considerably. The
mixer could cut to a depth of up to twenty four inches at one pass, but in order to break up the soil
into the smallest particles possible and expose them to the air, only twelve inch maximum layers were
used. At this thickness the tilled layer could still be completed and removed in one day. The mixer
made approximately four passes over each layer to fully pulverize it, then allowed it to volatilize for
an hour or so before reworking the same area. After working the soil the second time it usually
passed the test and was stockpiled. This process continued well below the groundwater level and in
the final layers the moisture content increased as it was tilled. Despite the moisture, the equipment
had very little trouble and the volatilization continues to approximately sea level. Tilling was slow
in the high moisture, heavy clay, and at times the tiller actually had to shave off small pieces to keep
it from balling up inside the machine. Tilling was stopped when groundwater accumulation in the
bottom of the excavation hindered the progress.
VERIFICATION TESTING
The verification test consisted of a series of tests conducted using a Foxboro 128 organic vapor
analyzer (OVA). The first test was done in place in the freshly tilled soil. The probe of the OVA was
carefully inserted about two inches into a fresh one inch diameter hole which extended to the bottom
of the tilled soil. This test indicated up to over 1000 ppm when the soil was first disturbed, but
quickly dropped after the soil was broken up. When no indication of contamination was found in the
in-situ test, a soil sample was collected for a field jar test. Each quart sample jar was filled
approximately half full with the loose soil from the areas that last yielded a reading. At least three
samples were taken from each layer. These were sealed with a layer of aluminum foil under the lids
and placed in boiling water for five minutes. This raised the temperature of the soil to 180° F. After
five minutes the jar was removed from the boiling water and was briefly shaken. The lid was
removed, and a small hole was created in the aluminum foil which was still in place on the jar. The
OVA probe was inserted into the small hole in the aluminum foil. If the reading was less than 5 ppm
on all tests for a layer then that layer was considered clean enough to be stockpiled and eventually
placed back in the excavation as backfill. Duplicate samples were analyzed for volatile organic
350
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Figure 5 Aerial Photo During Remedial Action
352
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Figure 6 Collecting Sample Behind Garden Tractor w/Small Tiller
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Figure 7 Large Highway Mixer
353
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priority pollutants using GCMS technology which were used to verify that the soil had been cleaned
up. The GCMS analysis in an off site laboratory test took several days, and were not used as a
control, but only to verify the results of the non-standard field test.
The air emissions during the soil tilling was very low. The work was all done in level "C" protection,
even though the levels of contamination in the air were seldom detectable in the breathing zone except
immediately behind the tiller.
The Triangle property is actually two properties separated by the Red Bird Chemical Co., which is
no longer in business. Compare the 1982 aerial photo in figure 3 with the property lines shown in
figure 4. Red Bird Chemical Co.'s activities and products were very similar to Triangle's, which lead
the Immediate Action Team to miss over 100 drums that were on the northerly piece of property,
beyond the Red Bird Property. These drums were in and around the shed in the upper center of
figure 3, and were removed and disposed of as part of the RA contract by ENSCO.
BUILDING & TANK DECONTAMINATION
Building decontamination was preceded by identifying, sorting, loading and disposal of the piles of
abandoned material, which had been scattered throughout the buildings. The carpeting in the offices
were removed because of several large stains frbm lab chemicals which had been spilled. All the
materials that were visually identified as possibly contaminated were sent to a class 1 hazardous
landfill, and the obviously uncontaminated materials were disposed of in a local class 1 non-hazardous
landfill. The building floors, including the office and lab area, were washed with hot detergent and
sealed. There was only one area in the mixing building that had chemicals splashed on the walls. This
area was cleaned similar to the tanks. The 23 tanks on site were cleaned using hot detergent, and
triple hot water rinse.
GROUNDWATER CONTAMINATION
The original RI, performed in early 1984 at this site, demonstrates one of the problems associated
with every soils investigation. Analysis performed on a discrete soil sample, from specific depth and
locations, may not be representative of what may exist in another area close to the first that was not
sampled. Samples were collected, and penetrations were made to depths of at least twenty feet in all
accessible areas over the entire site on a typical grid pattern. The major soil contamination on site was
found in the top six feet of soil, and only slight contamination was found in the groundwater deeper
than that. At this time, one monitoring well was placed upgradient of the soil contamination, and two
were placed downgradient. No measurable contamination was detected in any of these three original
wells. The remediation method chosen included removing and replacing the upgradient well, M W
#2, because it was in an area which was to be tilled. The replacement well, M W #4, was placed in
a central downgradient from the soil contamination location in order to monitor potential
contamination in the area. It was installed by ENSCO as close to the building as possible in order to
be out of danger from future occupants traffic. Total priority pollutants of over 25000 ppm were
detected in the groundwater sample collected from this well. Methylene Chloride, which had not been
previously found on site, was one of the major contaminant detected in this well. Because of this,
and other questions concerning the construction of this well, two additional monitoring wells were
installed in the area. One, M W #5, was placed about fifteen feet east of M W #4, and the other one,
M W #6 was placed west of M W #4, in another downgradient location where part of a building had
been removed by ENSCO during the RA. Both M W #6 and M W #5 confirmed that there was indeed
significant contamination in the groundwater. A supplemental groundwater investigation was
performed which confirmed that this was a small plume of contamination in the shallow groundwater.
During this investigation monitoring wells were installed, and cone penetrometers were used on the
downgradient property, inside the buildings, and in a grid pattern adjacent to the plume. One 80 foot
354
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deep well, M W #7, which extends to the second waterbearing zone was installed adjacent to M W #6.
Two of the new wells in the area of M W #5, M W #10 and M W #11, show some contamination, but
not to the same degree as M W #5 & #6. Neither the new deep well, nor the 400 foot wells on the
neighboring properties to the north and south, revealed any detectable priority pollutants when
sampled and analyzed. Pump tests and modeling of the shallow and deep groundwater movement was
conducted and natural attenuation was again confirmed as the selected method of remediation.
DATA EVALUATION AND CONCLUSIONS
Data from quarterly O&M groundwater samples collected since 1987 has produced a data base which
has been used to project the natural attenuation rates expected. Out of the more than twenty volatile
organic compounds which were found on site, six compounds were selected as indicators of the level
of contamination on site. These six compounds, Vinyl Chloride (VC), Methylene Chloride (MC), 1,1-
Dichloroethene(l,l-DCEE), l,l-Dichloroethane(l,l-DCEA), l,2-Dichloroethene(l,2-DCEE), and
Trichloroethene (TCE) are used to determine if improvement or deterioration of the groundwater is
taking place. Figure #8 and #9 are graphs of the levels of each of these in the monitor wells M W
#5 and M W #6, respectively.
Reduction of concentration of chemicals in the groundwater at a specific location is the result of
many simultaneous attenuation processes. These include migration downgradient with the
groundwater, dispersion, dilution by recharging sources, as well as natural attenuation by degradation,
evaporation or volatilization. The attenuation rate itself is dependent on the characteristics of each
chemical, as well as the saturation level of each chemical, in the particular combination with the other
chemicals present.
OBSERVATIONS AND CONCLUSIONS
The attenuation rate was projected using the first order decay [Y=Y0(e"kt)] of each compound based
on the data collected to date. Figures #10 and #11 presents a sum of the projected levels of all six
of the target compounds for each of the two heaviest contaminated wells, M W #5 and M W #6. This
was done for each contaminant separately by taking the natural log of each contaminant level and
projecting them to a level of 1 ppm. The projected logs are then converted to contaminant levels
before being combined with others from that monitoring well to be graphed. The projections are
based on the samples which have been collected on a quarterly bases since these two monitoring wells
were installed in April 1988. The projected attenuation has not changed significantly with each year's
added data. This seems to indicate that the use of the first order decay was a reasonable method for
projecting natural attenuation at this site. This may be applicable to similar other sites which no
longer have a contaminant source.
355
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TRIANGLE CHEMICAL CO. SITE
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MONITORING WELL »5
4/05/88 | 7/27/88 '| 2/21/89 I 8/17/89 I 2/22/90
6/08/88 11/3,0/88 6/09/89 12/13/89
DA|E OF SAMPLE
D VC +• MC o 1,1-OCEE \ A 1,1-OCEA X 1.2-DCEE V TCE
Figure 8 Monitoring Well #5 Contaminant Level By Contaminant
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TRIANGLE CHEMICAL CO. SITE
MONITORING WELL *6
4/05/88 I 7/27/88 | 2/21/89 | 8/17/89 | 2/22/90
6/08/88 11/30/88 6/09/89 12/13/89
DATE OF SAMPLE
D VC + MC o 1.1-OCEE
1,1-DCEA X 1,2-OCEE V TCE
Figure 9 Monitoring Well #6 Contaminant Level By Contaminant
356
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TRIANGLE CHEMICAL CO. SITE
TOTAL INDICATOR COMPOUNDS IN MW «5
—i—I—i—I—i—I—i—I—i—I—r
0 23 I 47 I 70 94 118 142 166 | 190 I 214 238 252 | 286
11 35 58 82 106 130 154 178 202 226 250 274
TIME (MONTHS)
O TOTAL CONCENTRATION + LINEAR REGRETION
Figure 10 Monitoring Well #5 Contaminant Reduction Projections
TRIANGLE CHEMICAL CO. SITE
TOTAL INDICATOR COMPOUNDS IN MW »6
1 1
10
9
G" ®
\
o>
•i 7
1
IT
5 5
o
1
0
5 3
2
1
0
- *
- I??
° +
+
+
+
+
+
+
*
-*-
— -1-
0 23 47 70 94 118 142 166 190 214 238 262
35
58
82 106 130 154 178 202 226
TIME (MONTHS)
D TOTAL CONCENTRATION + LINEAR REGRETION
250
Figure 11 Monitoring Well #6 Contaminant Reduction Projections
357
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CONCRETE COVER APPLICATIONS IN LINED DRAINAGE DITCH CONSTRUCTION
Camille K. Costa, P.E.
Dynamac Corporation
Public Ledger Bldg., Suite 872
Philadelphia, PA 19106
(215) 440-7340
Craig c. Marker
Dames and Moore
University Office Plaza
Christiana Bldg., Suite 204
Newark, DE 19702
(302) 292-2550
358
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INTRODUCTION
This paper presents details on the application of concrete on top
of synthetic liners to mitigate the problem of instability of
protective soil covers. The application is based on remedial
actions taken at a Superfund site which included the retrofitting
of drainage ditches with synthetic liner systems.
The original design called for the use of a textured geosynthetic
liner with 12 inches of protective soil cover on top. During the
construction phase, the required compaction was very difficult to
achieve especially along the slopes of the ditches. This problem
entailed a modification in the design. The modification called for
the replacement of the protective soil cover with a 4 inch
fibermesh concrete cover.
The economical factor makes the use of concrete covers less
attractive but if an erosion prevention media is used with the
soil, the concrete option will be more cost effective. In addition
the weight of the concrete cover is less than that of the
protective soil cover, which means that less tensile stress is
exerted on the liner materials. Using a concrete cover in lieu of
the protective soil cover did not change the design function of the
ditch, but rather enhanced it.
BACKGROUND
Project Description
The Delaware City facility is located in New Castle County,
Delaware. The facility processes Vinyl Chloride Monomer (VCM) to
manufacture a Polyvinyl Chloride (PVC) resin.
A wastewater treatment system comprising six surface impoundments
and two drainage ditches operates at the facility- The surface
impoundments include two concrete-lined aeration lagoons, three
earthen lagoons and one stormwater pond used primarily for
stormwater detention. The two ditches convey stormwater and/or
process wastewater.
The aerated lagoons received plant process wastewater for
treatment. PVC solids used to accumulate in the bottom. The
solids were periodically removed and the lagoons were periodically
drained. As for the earthen lagoons, they received various
materials from the facility. They also accumulated solids which
were periodically excavated and disposed of. The same applied to
the stormwater pond.
The drainage ditches were unlined. They conducted stormwater and
wastewater sump overflows from production areas to the earthen
lagoons and the stormwater pond. Periodically, solids have
accumulated at several locations along the ditches.
359
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In 1982, both VCM and Ethylene Dichloride were found in a water
supply well on an adjacent property- This triggered a
hydrogeological investigation to evaluate the extent of the
contamination at the site. Following the investigation phase, a
feasibility study was prepared to identify appropriate remedial
measures to address this problem. The proposed improvements
included removing and disposing of contaminated sludge and soil
from the existing drainage ditches and surface impoundments, and
retrofitting them with geosynthetic liners. This paper addresses
the retrofitting of the drainage ditches only, namely the South
Ditch.
ORIGINAL DESIGN
The South Ditch was sized to handle the 100 year - 1 hour storm.
The assumed drainage area and the estimated storm flow rates were
as follows:
Drainage Area: 19.96 Acres
Stormwater Flow Rate: 57.3 cfs
Ditch Design Capacity: 61.5 cfs
A typical cross-section of the ditch is shown in Figure 1.
The design called for the use of a single synthetic liner at the
bottom of the ditch, after proper subgrade preparation. The ditch
liner consisted of 40 mil textured high density Polyethylene (HOPE)
liner and an 8 ounce nonwoven separator geofabric below it. The
selection of the HOPE liner was based on compatibility testing.
The liner was to be covered by one foot of soil to provide exposure
protection from ultra-violet degradation, rodents, etc... The
specifications required that all compacted structural fill achieve
at least 90 percent of the materials maximum Standard Proctor (ASTM
D-698) dry density. It also required that cohesive materials be
compacted within + 3 percent of the materials optimum moisture
content as defined by ASTM D-698.
To provide for erosion protection and maintenance of the drainage
ditches, the design specified the use of synthetic geotextile grid
(geoweb) to be incorporated into the ditch. The geoweb was used to
line the ditch above the protective soil layer. The lining was
provided to prevent scour and assist in sediment
removal/maintenance of the ditch.
The primary function of the ditches was to collect storm runoff at
the site. Sediment and heavy PVC solids were to be removed
primarily before they enter the ditches. The Operation and
Maintenance of the ditches called for a quarterly inspection to
observe any erosion problems and remove sediments in excess of six
inches to maintain the channel's hydraulic capacity.
360
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linen LIMIT AS SHOWN
ON PLANS (TTP.|
-TtK- ; ,
1 - w /" **"*•&*. >
ANCHOR- TRENCH WITH
COMPACTED CLAr
36B 08TAIL ( «
11
Figure 1
South Ditch
Typical Section
-------
THE PROBLEM
Discussion
During the construction of the South Ditch, several problems were
encountered with the placement of the protective soil cover. These
problems occured after periods of rainfall which saturated the
placed protective cover. Since the 40-mil textured HOPE liner was
located beneath the soil cover, water which infiltrated the soil
layer was contained by the impermeable geomembrane. The
accumulation of water between the soil-geomembrane interface
created two problems:
1. Achievable compaction of the soil cover was reduced because of
the increase in water content above that of optimum.
2. A slip surface was created at the lubricated soil-geomembrane
interface.
A select backfill material was utilized to construct the protective
soil cover. The gradation of the select material is outlined in
Table l. The maximum dry density of the soil as determined by the
Standard Proctor Test was 119.2 Ibs/C.F. The optimum water content
at the maximum dry density was 13.4 percent. During the
construction of the protective soil cover, moisture content of the
soil increased to more than 20 percent. This significantly reduced
the achievable dry density of the soil. As a result, the required
90 percent compaction of the soil layer could not be achieved.
After storm events at the site, minor slope failures along the
protective soil cover occurred. The soil would slough down the
slope sometimes exposing the HOPE liner. This suggested some type
of slope instability. It is believed that as water infiltrated the
protective soil cover and accumulated above the HOPE liner a slip
surface was created at the soil geomembrane interface. It is
estimated that the friction angle at the soil-geomembrane interface
was reduced from approximately 28° to as low as 10° - 15°. Basic
soil mechanics tells us that the friction angle of the interface
must at least be as great as the angle of the slope itself. In
this case a 3:1 slope corresponds to 18.4°. Therefore, without
slope stability calculations, it can be seen that a failure would
occur at the reduced friction angle. As outlined below,
calculations were performed to confirm the slope instability. As
seen from these calculations, the factor of safety against slippage
along the slope was reduced from 1.6 to 0.8 at the estimated
reduced friction angle.
362
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TABLE 1
Gradation Analysis for
the Select Backfill Material
at the South Ditch
SIEVE SIZE PERCENT PASSING
1 1/2" 100
1" 98.3
3/4" 97.5
1/2" 96.1
3/8" 95.3
#4 93.5
#10 89.7
#20 80.6
#40 58.9
#60 41.5
#100 31.2
#140 27.9
#200 24.3
363
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FIGURE 2
Partial Cross-Section of South Ditch With Soil Cover
Calculations
Given:
= Slope Angle = 18.4°
= Friction Angle of Soil at Dry Conditions = 28°
= Friction.Angle of Soil at Saturated Conditions
= 15'
Analysis:
Resisting Force
Driving Force
F.S. against Sliding
= F = N tan 5 = W cos 6 tan 6
= W sin 6
= Resisting Force/Driving Force
= W cos 6 tan 6/W sin 6
Factor of Safety (F.S.) = tan 6/tan 6
a) Soil at dry conditions
F.S. = tan 28°/tan 18.4° = 1.60
Required F.S. = 1.2
b) Soil at wet conditions
F.S. = tan 15°/tan is.4° - 0.8
Required F.S. = 1.2
364
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THE SOLUTION
Discussion
The problem of the soil sliding on the surface of the textured HOPE
liner required a modification to the South Ditch design. This
modification entailed the replacement of the protective soil cover
with a four inch fibermesh concrete cover. Fiber expansion sealed
joints were to be placed every 12 linear feet of the ditch. An
eight ounce nonwoven, needle punch geotextile was to be installed
between the concrete cover and the HOPE liner to absorb any
moisture which may leak through expansion joints or cracks in the
concrete. The laboratory filtration tests conducted on woven and
nonwoven geotextiles showed that nonwoven material exhibit the best
overall behavior. The mass removal efficiency was found to range
from 2 to 29 percent for run durations ranging from two hours to
seven hours. The size removal efficiency for 1.0 /^m diameter
particles ranged from nil to 56 percent.
A typical cross-section of the modified ditch design is shown in
Figure 3.
Design Calculations
In order to determine the stability of the concrete cover on top of
the liner, a tensile stress analysis was performed for the HOPE
liner, in addition to a comparative weight analysis between the
concrete cover and the protective soil cover. Finally, an analysis
was done to verify that the concrete cover will not slide on the
HOPE liner.
365
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LIMER LIMIT nS SHOUH
OH PLOH9 (TYP )
RNCHOR TRENCH UITH
COHPOCTEO CLOY
SEE
-EXISTING
GROUND
TEXTURED HOPE LINER L|'6-J
8 OZ. NONUOVEN
GEOFflBRIC
H" CONCRETE
INVERT PROTECTION
L
Figure 3
Modified South Ditch
Tupical Section
-------
w
FIGURE 4
Typical Cross-Section of South Ditch
Weight Analysis
Given:
Soil Depth =
Soil Wet Density =
Soil Compaction =
Concrete Depth =
Concrete Density =
Ditch Width
Analysis:
Actual Soil Density
Soil Weight
Concrete Weight
Tensile Stress Analysis
1 ft.
119.2 pounds per cubic feet (pcf)
90% Standard Proctor
4 in.
150 pcf
20 ft.
119.2 X 0.90 = 107.3 pcf
107.3 x 1 x 20 = 2146 Ibs./ft. of ditch
150 x 4/12 x 20 = 1000 Ibs./ft. of ditch
Given:
Concrete Density = 150 pcf
Concrete Depth = 4 in.
6 = Slope Angle = 1 V to 3 H =18.4°
61 = Friction Angle Concrete to Geotextile =30°
62 = 63 = 64 = 65 = Friction Angle Geotextile to Liner = 23'
66 = Friction Angle Geotextile to Subbase = 25°
Slope Length = 9.5 ft.
HOPE Yield Stress = 95 Ibs./in.
Geotextile Yield Stress = 180 Ibs./in.
367
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Analysis:
W = Weight of concrete cover applied on the face of the slope
= 9.5 X 4/12 X 150 = 475 Ibs./ft.
W cos 6 = 475 cos 18.4 = 451 Ibs./ft.
W sin 6 = 475 sin 18.4 = 150 Ibs./ft.
F1 = Shear force above the upper geotextile
(W cos 6) tan '$.,
= 451 tan 30° = 260 Ibs./ft.
F2 = Shear force below the upper goetextile
(W cos 6) tan 62
= 451 tan 23° = 191 Ibs./ft.
Since F1 > F2 then the geotextile is in tension
Liner Stress = (260 - 191)/12 = 5.75 Ibs./in.
F.S. = Factor of Safety = Yield Stress/Actual Stress = 180/5.75 = 31
Required F.S. = 10
F3 = Shear Stress above the 40 mil textured liner
= (W cos 6) tan 53
451 tan 23 = 191 pcf.
F4 = Shear stress below the 40 mil textured liner
(W cos 6) tan 64
451 tan 23 = 191 pcf
Since F3 = F4, the geomembrane does not take any tensile stress. It is in
pure shear.
F5 = Shear Stress above the lower geotextile
= (W cos 6) tan 65
451 tan 23 = 191 pcf.
F6 = Shear stress below the lower geotextile
= (W cos 6) tan 56
451 tan 25 = 210 pcf
Since F5 < F6 , no tensile stress is taken by the lower geotextile
368
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3..
FIGURE 5
Partial Cross-Section of South Ditch With Concrete Cover
Sliding Analysis
Given:
6 = 18.4°
= 30.
= 25
=
-------
Construction
The modified design aimed to have a ditch which is watertight,
moderate in cost, strong and durable, provide maximum hydraulic
efficiency and have a reasonable amount of flexibility. Concrete,
composed of selected aggregates with proper control of placing,
finishing, and curing will require minimum maintenance and have a
long service life.
1. The Concrete Mix
The modified design included well graded sand in the concrete
mix to ensure a reasonable good finish. In addition, pea
gravel (No. 4 or 3/16 to 3/8 in.) content of the mix was
reduced to about 5 percent to improve the finishability of the
concrete. As a rule of thumb, the maximum size of aggregate
should not be greater than one-half the thickness of the
lining. In addition, the concrete was to placed by hand and
screeded from the bottom to the top of the slope. A slump of
2 to 2 1/2 inches was specified for this application.
2. Reinforcement
Though steel reinforcement was not required, the modified
design required the addition of Fibermesh fiber to the
concrete mix. Fibermesh is a concrete engineered fiber
composed of virgin polypropylene which provides protection
against nonstructural cracks in concrete, increases impact
capacity, reduces permeability, adds shatter resistance and
can eliminate the need for welded wire fabric used for crack
control. Fibermesh fibers provide dimensional stability by
reducing intrinsic stresses or relieving them until the
concrete has developed sufficient integrity to sustain the
stresses without cracking. The reduction of early age crack
formation substantially reduces the number of weak planes and
potential future crack formation.
3. Placing the Concrete Cover
A protective layer of geofabric was placed on the HDPE liner.
After placing the required forms above the geotextile,
concrete was dumped and spread by hand on the sides and
bottom. Screed guides were laid on the geofabric and the
concrete was screeded up the slope to proper thickness. One
or two passes with a long-handled steel trowel completed the
finishing. Transverse grooves were cut at 12-foot intervals,
and the lining was cured by use of solvent-based concrete
curing compound with at least 20 percent solids.
Since the concrete cover was constructed by hand, concrete was
placed in alternate panels to facilitate placing, finishing
and curing operations. Overall shrinkage cracking was reduced
370
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since enough time elapsed before placing the intervening
panels.
4. Contraction Joints
Transverse contraction joints were provided in the concrete
cover by cutting grooves in the upper surface of the slabs
while the concrete was still plastic. As a result, shrinkage
cracks will be largely confined to the location of these
grooves. To maintain the shape and the function of the
contraction joints, the modified design called for placing a
sealant in the grooves. All joints were sealed with Sikaflex,
a moisture-cured, 1-component, polyurethane-base, non-sag
elastomeric sealant. This sealant is highly elastic and it
cures to a tough, durable material with exceptional cut and
tear resistance. In addition, Sikaflex exhibits excellent
adhesion and resistance to aging, weathering, and chemical
action.
Cost Analysis
A comparison is presented below to compare the cost of using
soil or concrete for invert protection.
1. Using Soil
Given:
Ditch Length = 1 ft.
Ditch Width = 24 ft.
Soil Depth = 1 ft.
Cost of Soil (including placement and compaction)
= $ 7.00/C.Y.
Cost of installed geoweb (to be used for soil protection)
= $ 1.50/S.F.
Analysis:
Volume of Soil = 24 x 1 x 1 = 24 C.F./ft. of ditch required
= 0.9 C.Y./ft. of ditch
Total Cost of Soil = 0.9 x 7 = $6.3/ft. of ditch
Total Cost of Geoweb= 24 x 1.5 = $36/ft. of ditch
Total Cost per ft. of Ditch = 6.3 + 36 = $42.30
2. Using Concrete
Given:
Ditch Length = 1 ft.
Ditch Width = 24 ft.
Concrete Thickness = 4 in.
Cost of Concrete with Fibermesh (including placement,
leveling, finishing etc ...) = $70/C.Y.
Cost of Geofabric (including placement) = $3.00/S.Y.
371
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Analysis:
Volume of Concrete Required = 24 x 4/12 x 1
= 8 C.F./ft. of ditch
= 0.30 C.Y./ft of ditch
Total Cost of Concrete = 0.30 x 70 = $2I/ft, of ditch
Amount of Geofabric Required
Total Cost of Geofabric
Total Cost per ft. of Ditch =21+8= $29
= 24 x 1
= 24 S.F./ft. of ditch
= 2.67 x 3 = $8/ft. of ditch
CONCLUSIONS
New construction often justifies putting the liner on the prepared
soil subgrade and then concrete on top of it. This can be a viable
alternative to mitigate problems associated with soil invert
protection construction. As outlined in this paper/ concrete
covers have the following advantages:
1. Their application can be more economical when compared to soil
reinforced with an erosion prevention media.
2. Concrete weight can be less than the soil weight, depending on
the depths, which will translate into less tensile stress
exerted on liner materials.
3. Concrete has a good factor of safety against slippage along
liner slopes and to a lesser degree on earthen slopes.
4. The use of proper construction materials, (concrete mix,
curing compound, sealant, etc...), and methods reduces
maintenance work and provides long service life.
As for disadvantages, the forming for concrete placement can be
difficult because the liner system cannot be punctured. In
addition, concrete covers will not function properly on long, steep
slopes.
372
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References
Dames and Moore, "Facility Design Report, Liner Retrofitting-
Surface Impoundments and Drainage Ditches", July 1990.
Dames and Moore, "South Drainage Ditch, Design Modification",
Correspondence to R. Sturgeon, November 7, 1990.
Fibermesh Company, "Collated, Fibrillated Polypropylene Fiber Spec-
Data", August 1988.
Koerner, R. M., "Designing with Geosynthetics", 1990.
Lawson, C.R., "Filter Criteria for Geotextiles: Relevance and Use",
Journal of the Geotechnical Engineering Division, American Society
of Civil Engineers, October 1982.
Sika Corporation, "Sikaflex-la, Technical Data", February 1986.
U.S. Environmental Protection Agency, EPA/625/4-89/022,
"Requirements for Hazardous Waste Landfill Design, Construction,
and Closure", August 1989.
U.S. Department of the Interior, Bureau of Reclamation, "Concrete
Manual", 1975.
PHOTO RECORD
PHOTO 1 - Saturated Surface of Protective Soil and Erosional Damage in South Ditch
373
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PHOTO 2 - Water Retained at the Soil-Liner Interface Even Though the Contractor Removed Water From
Liner Surface Prior to This Picture Being Taken
PHOTO 3 • Wooden Forms Placed Along Length of South Ditch in Preparation of Concrete Pours for the
Invert Protection
374
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PHOTO 4 - Using the Back of the Rakes in Construction to Prevent the Concrete From Becoming
Segregated and to Protect the Liner From Being Punctured
PHOTO 5 - South Ditch Completed
375
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A Case Study of Change Orders
at a Superf und Site
Geneva Industries Superfund Site
Houston, Texas
Paul B. Cravens, P.E., Head
Design Engineering Unit
Superfund and Emergency Response Section
Texas Water Commission
P.O. Box 13087 Capitol Staiton
Austin, TX 78711-3087
(512) 463-7785
INTRODUCTION
PROJECT OVERVIEW
The remediation of the Geneva Industries Superfund Site, as specified in the Record of Decision
(ROD), consists of two phases. The first is the source remediation (the removal of PCB contaminated
soils to an action level) and the second is the groundwater remediation (the pumping and treatment
of contaminated groundwater to an action level). The source remediation phase of this project has
been completed and the groundwater phase is in design at this time. This paper describes the work
completed to date.
FOCUS OF PAPER
When the Notice to Proceed was issued on May 23, 1988, the prime contractor for the Geneva project
expressed confidence that the 331 days allowed in the contract would be more than adequate. Two
years and two months later, after court injunctions, material overruns, and construction delays, the
site was accepted and a Certificate of Completion was issued. The project was finished 430 days past
the originally projected completion date and more than 27 percent over the initial contract price.
The focus of this paper is to examine the causes of these cost overruns and time delays and analyze
them to develop some lessons learned.
BACKGROUND
SITE HISTORY
The Geneva Industries site is a 13 acre tract located at 9334 Caniff Road in Houston, Harris County,
Texas immediately adjacent to the corporate limits of the city of South Houston (See Figure 1). The
site is an abandoned refinery which manufactured a variety of organic compounds, including
polychlorinated biphenyls (PCBs) from 1967 to 1973. Geneva Industries declared bankruptcy on
November 26, 1973. From 1974 until the facility was closed in 1980, several corporations continued
recovery operation for biphenyls and naptha at the Geneva facility. The current owner purchased
the property in May of 1982 to salvage the equipment from the site for resale.
Numerous spills over the history of the plant resulted in several areas of contaminated soil on the
ground and in the adjacent drainage ditch. An EPA investigation team found soils containing up to
376
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GENEVA INDUSTRIES SITE
Figure 1
377
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9,000 parts per million (ppm) PCB on the site, and up to 104 ppm in the drainage paths leading off-
site. In addition to PCB, many other hazardous and/or toxic compounds, including PNA's and TCE's,
were quantified in the soil on the site. A Planned Removal was performed during the period from
October 1983 to September 1984. Although the removal actions mitigated the immediate hazards to
human health and the environment, they did not address the long term problems. As a result of an
MRS (hazard ranking system) score of 59.46, the site was placed on the National Priorities List (NPL)
in September 1983, making it eligible for funding under the Superfund program.
In December of 1983, the EPA awarded the Texas Department of Water Resources (precursor to the
Texas Water Commission) a grant to execute a remedial investigation and feasibility study (RI/FS)
at the Geneva Industries site. This study was completed in May of 1986 and the EPA issued a Record
of Decision (ROD) on September 18, 1986. The source control portion of the ROD specified, in part,
the removal and off-site disposal of drums, surface structures, contaminated liquids, and all soils
contaminated to a level greater than 50 parts per million of PCB's. (This ROD and the subsequent
design were pre-Land Ban.) The Texas Water Commission (TWC) received a grant for the design of
the remedy in March of 1987 and the design was completed in November 1987.
CONSTRUCTION HISTORY
EPA awarded construction funds for the Geneva project in December 1987. A contract for the work
was awarded on April 8, 1988 for 16.1 million dollars ($16.1M). The winning Contractor planned to
remove the contaminated soil to an approved landfill site in Alabama. The Notice to Proceed for field
work was issued on May 23rd, on which date the Contractor immediately began mobilizing. By July
15th all the support facilities were in place and clearing and grubbing and dismantling of structures
began. The schedule called for excavation of contaminated soil to begin on August 1st.
During this time, EPA was questioned by officials from the State of Alabama as well as Alabama
Congressional representatives concerning the shipment of wastes from the Geneva site into Alabama.
On July 22, 1988 EPA directed TWC to delay shipping wastes pending resolution of the Alabama
inquiries. Thus began a series of delays, lasting over the following three months. The causes of these
incidental delays included compliance difficulties by the landfill in Alabama and efforts by the State
of Alabama to prevent the shipment of wastes.
Alabama obtained a temporary restraining order, issued on October 21, 1988, restricting EPA from
spending federal funds to implement the ROD. A preliminary injunction, for the same purpose, was
issued on October 31, 1988. This put the project in an indefinite state of delay. TWC and EPA
choose to continue the project in a state of delay rather than terminate the remediation contract. On
November 22, 1988, TWC directed the contractor to partially demobilize from the site. In December,
the court issued a permanent injunction, thus extending the delay.
The delay continued until June 7, 1989, when the injunction was overturned. On June 14, 1989, TWC
directed the contractor to resume work effective June 26th. After re-mobilizing and re-training
personnel, production runs began on July 12, 1989 to the landfill in Alabama. The excavation of
contaminated soils was completed on September 20, 1989. The amount excavated exceeded the bid
amount by about 32 percent. The completion of back-filling the excavation was completed on
January 18, 1990. Construction of the clay cap was completed the first week in June. Final
completion of the project was June 20, 1990.
SCOPE OF WORK
The scope of the work at the Geneva site was fairly straight-forward. After mobilizing to the site,
the contractor began clearing operations, including the removal of structures, tanks, and foundations.
378
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The site was then divided into one hundred 50 by 50 foot grid blocks, these being subdivided into 25
by 25 foot squares. The contractor then excavated contaminated soil to a predetermined minimum
depth, tested each 25 by 25 foot square for PCB's, and continued excavating if the tests indicated a
PCB content greater than the 100 ppm action level. The excavation was thus advanced in 12-inch or
6-inch increments, depending on the level of contamination, until the working area was found to meet
action levels. Payment on this bid item was per ton excavated off-site, so truck scales were
constructed at the interface with the "hot zone".
Since the ROD determined that it would not be economically feasible to remove all of the
contaminated soils at the site, some contamination was left in place. To prevent migration of the
remaining contaminants, specifications called for the construction of a perimeter bentonitic slurry
trench cut-off wall. This trench was advanced nominally 30 feet below the ground surface to key
into a natural clay aquitard. Thus, with lateral movement retarded by the slurry wall and downward
contaminant migration blocked by the aquitard, there remained the need for a protective cover.
Construction of the slurry wall began on the north side of the site, away from the main excavation.
Upon completion of the removal of contaminated soils, the excavation was back-filled in compacted
lifts with imported clayey soils. Back-filling continued simultaneously with the construction of the
slurry wall. The site was back-filled above the original site elevation, to ensure positive drainage off-
site.
Upon completion of the back-fill and slurry wall, a final protective cap was constructed. This
consisted of a layer of low permeability clay atop the general back-fill, a geo-textile fabric to act as
protective barrier, 60 ml continuous HDPE impermeable liner, a geo-textile fabric, a layer of sand
for drainage, geo-textile filter fabric to protect the sand from infiltration by the overlying topsoil,
and topsoil, which was seeded and watered to promote a protective vegetative cover. The surface of
the cap has a slope of about 2 to 5 percent and a side slope of about 3 horizontal to 1 vertical. Runoff
is collected in a cap perimeter drainage ditch, which discharges to an adjacent flood control ditch.
A permanent security fence was constructed around the perimeter. A cross section showing the final
cap details is provided as Figure 2.
CHANGE ORDER HISTORY
There were a total of 32 changes to the original scope of work, authorized through change orders to
the contract, resulting in both debits and credits. From the original contract price of $16.1 M, the cost
of the work increased to $20.5M. There were a total of 25 debit and 7 credit change orders. This
includes a $710,300 credit change order adjusting the original bid price for underruns in specific line
item bid quantities. The twenty-five debit change orders came to a total of $5.1M, while the credit
change orders, including the adjustment for underrun quantities, came to a total of $736,000. A
graph illustrating the cumulative costs of the project is provided as Figure 3.
Figure No. 4 illustrates the cumulative costs of just the change orders. Change Order Number 17,
marked on the figure, is primarily for an increase in the volume of contaminated soil excavated and
removed to the approved landfill in Alabama. Change Order No. 23 is also marked on the figure, and
is for a partial reimbursement of costs associated with the Alabama lawsuit delay. The change order
adjusting the cost of the project to reflect final quantities installed (material underruns) is marked
on the figure as Change Order No. 31. Finally, the last change order on the figure, Change Order No.
32, is for the previously unsettled portion of the costs associated with that delay.
379
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Geneva Industries Superfund Site
Cross Section of Final Construction
CO
GO
O
\
Perimeter
Fence
Erosion
Control Fabric
Geofabric
Geogrid
Gravel
60 ML HOPE
with Geofabic Protection
Anchor
Trench
Slurry Wall
Topsoil
2 Feet Thick
Sand
Two Feet Thick
Clay Liner
3 Feet Thick
•Representative, Not to Scale.
Geofabric
\ \ \\ \ \
\
\
\
\
\ \ \ \ \ \ \
30 " Minimum
Figure 2
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Geneva Industries Superfund Site
Cumulative Project Costs
$25
Millions
$20-
$15-
$10-
$5-
$0
C.O. #23
C.O. #17
-a—a—a—a—B-
Initial Contract Price: $16.1M
Credit C.O. adjustment for
final quantities installed.
0 5 10 15 20 25
Change Order Numbers
Final Project Cost: $20.5M
30 35
Figure 3
381
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Geneva Industries Superfund Site
Cumulative Change Order Amounts
Millions
Adjustment C.O. #31
i 1 1 r
10 15 20 25
Change Order Numbers
Original Contract Amount: $16.1M
30 35
Figure 4
382
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DISCUSSION
BIG PICTURE OF C.O/S ON THIS PROJECT
Change orders are the result of a modification in the scope of work that is either desired by the owner
or the contractor, for their own benefit, or are due to some changed condition encountered during
the post-award planning or the construction stages. Such modifications are negotiated in advance and
authorized using field orders, and then are finalized through the change order process. The
modifications may include changes in project cost, changes in project schedule, or both. An increase
in the project schedule that is allowed by a change order will usually include costs associated with
those additional days (fixed costs).
Changed conditions on any large project can be expected, but this seems especially so for a Superfund
project. The nature of a Superfund site is that so much of the problem is hidden from view. The
field studies conducted to document the extent of contamination, and therefore the amount of work
to be done during remediation, is a forensic science, and an imperfect one. Relying on a limited
number of small diameter drilled core holes, limit use geo-magnetic or other fledgling technologies,
and the examination of aerial photographs and plant documentation rarely provides as complete a
picture as is desired or necessary to predict the work ahead.
Excessive changed conditions during construction, with their related costs, are particularly harmful
to Superfund projects. Budgets and schedules at these sites are critical due to the long range planning
and budget goals associated with the Superfund program. The high unit costs attendant to hazardous
waste remediation means that changed conditions can quickly result in significant changes in project
costs. The nature of the work also means that such changes in scope can delay the completion of the
project. At Geneva, there was the additional circumstance of the work being put into an indefinite
period of delay due to legal actions brought against the project by the State of Alabama.
SORTING THE C.O.'S
The thirty-two change orders executed for the Geneva Industries Superfund project were the result
of a wide variety of circumstances. For the purpose of this paper, the change orders have been
grouped into five general categories, relating each of them to a type of cause. These are:
Unknown Conditions: These are conditions completely unanticipated in the plans and specifications,
that once discovered, resulted in additional work or services. Examples of unknown conditions
encountered during the project include:
contaminants discovered in areas previously thought to be clean;
high PCB content sludge discovered in existing tanks that were thought to be empty;
and
the discovery of buried drums outside of drum storage areas.
Changed Conditions: This relates to work that was anticipated in the plans and specifications, but
changed in some manner that resulted in additional work or services. This category does not include
changed quantities. Project specific examples include:
improvements to the design, including gates, drainage structures, water treatment
plant, etc.;
an increase in the State of Alabama waste disposal tax;
additions to the design, such as riser casings for planned pressure relief wells; and
changes in contractor services over holidays, etc.
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Changed Quantities: This is a subset of Changed Conditions, and relates to work that was anticipated
in the plans and specifications, was bid by unit price and quantity, and an increase or decrease in the
bid quantity was experienced. The changed quantities change orders for this project included:
an increase in the estimated bid quantity for clearing and grubbing;
an increase in the estimated bid quantity for demolition and removal of structures;
a large increase in the estimated bid quantity for the primary work of excavating,
transporting, and disposing of the PCB contaminated soils;
an increase in the estimated bid quantity for the construction of the slurry wall; and
a decrease in the estimated bid quantities for specific elements of the permanent cover
at the site.
Weather Related: The contract allowed for redress in the case of unusual inclement weather that
effected the work at the site. This category relates to costs associated with both the increased cost
of work due to adverse weather and the fixed costs associated with the impact on the schedule due
to weather related delays. The weather impacting this project included a hurricane, a tropical storm,
and an unusually wet winter during which moisture sensitive work was attempted.
Delay Related: This relates to all costs associated with the delay caused by the aforementioned lawsuit
brought against the project by the State of Alabama. These costs included:
the basic costs of maintaining a skeletal staff and facility at the site during the delay;
an additional increase in the disposal tax in Alabama; and
the cost of storing geo-fabrics that had been ordered just before the delay went into
effect.
The change orders had the potential of changing either the cost of the work, the schedule or both.
If the schedule was altered, all associated costs were accounted for in the change order.
ANALYSIS
MAJOR COST ITEMS
A comparison in the cost of each type of change order as a percent of the cumulative cost of all
change orders is provided on Figure 5. (Please note that this comparison includes credit change orders
as well.) Discounting the anomalous (hopefully) lawsuit related delays, conditions not anticipated at
all by the specifications (such as weather delays and the discovery of piers and buried drums)
accounted for only 8 percent of the costs of the change orders. Changed conditions not related to
excess materials, such as improvements to the design, only comprised 9 percent of the total change
order amount.
The bulk of the increase in the cost of this project was due to excess quantities of materials that were
anticipated and designated in the bid specifications for removal from the site. Actually, the
proportional impact of these overruns is even greater that suggested by Figure 5. When the credit
adjustment for the change order for material underruns is added back in, excess quantities comprise
over 70 percent of the total change order costs.
Over 90 percent of the excess material cost increases were associated with the overrun in Bid Item
12A. (This bid item was for the excavation, transport, and disposal of the PCB contaminated soils.)
The bid form estimated the quantity to be removed at 47,400 tons. The final quantity was 62,293
tons, an increase of over 31 percent by weight. In addition to the increase costs due to the excavation,
384
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Geneva Industries Superfund Site
Comparison of Types of Change Orders
Excess Quantities
66%
Weather Related
2%
Unknown Cond.
6%
Changed Conditions
9%
Delay Related
17%
All Change Orders
Includes Debit and Credit C.O.'s
Figure 5
385
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hauling, and disposal of this excess material, there was also a significant additional cost due to higher
disposal taxes on the increased material and also costs associated with increasing the project schedule.
OVERRUN OF PCS CONTAMINATED SOIL
The estimated total volume of PCB contaminated soil was derived from the contents of the Remedial
Investigation (RI) report. A total of 23 borings (five of these had monitor wells installed) and 10 test
pits were completed on-site during the RI. Seven additional monitor wells were constructed off-site.
The RI report also indicated that additional sampling had been conducted prior to the RI by EPA
during a planned removal, including sampling and sounding of tanks, and then again about the time
of the RI for specialized testing. No further soil samples were taken until the start of the remedial
construction activities. The last test boring was completed in October of 1984.
The Engineer developed stratigraphic cross sections from the boring and laboratory test data. From
these cross sections, total volume estimates for various action levels of PCB contamination were
developed. These values were increased by 30 percent to allow for data gaps. Still, the actual volume
of contaminated soil removed was more than 30 percent beyond this amount. Although there is
always the possibility of gross error having occurred in calculating the volumes, or in interpreting test
data, all such work was subject to internal Quality Assurance and TWC/EPA review.
It is reasonable to next examine the timeliness of the field data. The deep excavation in the area of
the old waste pond, the area where the deepest contamination was expected and was indeed found,
was not well underway until October of 1989. This is just about 5 years after the completion of the
last boring during the Remedial Investigation. It is very likely that over this period of time, the
contamination continued to extend outward from its original position, thus increasing the volume of
contaminated soil.
OTHER OVERRUNS
The remaining items in which overruns were experienced were insignificant in their impact on the
cost of the project compared to the Bid Item 12A overrun. Clearing and grubbing ran 195 percent
over the bid amount, bid by the ton. This item is difficult to estimate on any project. However, the
cost of the excess clearing and grubbing comprised less than 1 percent of the total debit change
orders. The remaining overruns were within the norms for exceeding bid estimates, that is within 15
percent.
ALABAMA LAWSUIT COSTS
The change order cost to the project for the Alabama lawsuit was second only to excess quantities.
The project was effectively delayed eleven months. The TWC and EPA initially believed the
Alabama legal actions could be overturned within a short period of time. When it was apparent that
the delay would extend over several months, it was decided that demobilizing from the site, keeping
a facility in place with a minimal staff, and keeping the contract in effect, was preferable to canceling
the contract and having to re-bid once the lawsuit was resolved.
The most painful aspect of the Alabama delay was in coming to an agreement as to what were the
costs incurred by the contractor. The delaying injunction stipulated that the project would be put
on hold in all respects, and regular payments to the contractor could not be made. Upon the removal
of the injunction, the contractor presented an invoice for the delay period costs. The final
resolution of these costs was not reached until well over a year after the injunction was lifted and four
months after completion of the work.
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EFFECT OF CHANGE ORDERS ON SCHEDULE
Keeping a Superfund project on schedule is often as important as keeping it within budget. Figure
6 shows the impact of the change orders on the Geneva project schedule. It should be noted that the
effect on the scheduled completion is indicated by this figure. In fact, the project was completed 72.5
days beyond this date, due to difficulties the contractor had in completing the slurry wall. By far,
the vast majority of the delays experienced were related to the Alabama lawsuit. Non-lawsuit related
delays comprised less than 5 percent of the total delays.
Of the non-lawsuit related days, most were due to either changed quantities or weather related delays.
Time extensions for changed quantities and weather delays were very difficult to negotiate with the
contractor, who felt a considerably larger number of days should have been granted. Increases in
material quantities effected the schedule the most and were the most costly due to the tempo of work.
Although the project schedule was extended by over a month to account for several periods of
rainy/freezing weather, the costs associated with these days constituted only 2 percent of the
cumulative change order costs. It is apparent that weather delays have a relatively low impact on the
cost of the project compared to other change order issues.
CONCLUSIONS (LESSONS LEARNED)
RELATED TO UNKNOWN CONDITIONS
Comprising 6 percent of the cost of the total change order amount, the unknown conditions at this
site proved to be a nuisance, but manageable. In hindsight, a closer inspection of the slurry wall path
with respect to the location of the since removed horizontal tank structures might have resulted in the
slurry wall being moved to avoid the old foundation piers. Certainly, all of the tanks still on site
should have been re-inspected in the RI phase. The state of the art of geomagnetic surveys today
probably could not have detected the buried drums during the RI Phase, with existing metallic
structures still on-site. It may be worthwhile to conduct another survey once the site is cleared of all
surficial tanks and piping.
RELATED TO CHANGED CONDITIONS
The changed conditions experienced at the Geneva site were reasonable and typical of a dynamic
project this size. The bulk of the cost of this category of change orders was related to an increase in
the disposal tax in Alabama, an occurrence out of the purview of the contractual parties.
RELATED TO CHANGED QUANTITIES
The complicated nature of Superfund work often means that each phase of the work is time
consuming. Many months and often years pass between the original site investigation and the actual
remediation. In this case, it was nearly five years after the RI field work was completed that real
progress at the site was realized. The continuing migration of contamination over this period of time
is very likely the prime reason for the large overrun in the quantity of contaminated soil that was
removed from the site.
It would be advisable to include in the Feasibility Study a projection of the migration of
contamination over time, providing estimates at a yearly interval of what the change in the volume
of contaminated soil (or water) might be. This would understandably be difficult, especially with
complicated contaminate sources, constituents, and subsurface conditions. In lieu of this, it would
be prudent to call for a verification drilling and testing program when the project is close to bid. This
would provide the EPA advance notice of significant changes in volumes, allowing additional funding
387
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Geneva Industries Superfund Site
Changes to Project Schedule
(Values Shown are Calendar Days)
00
GO
OO
Change Related
72,5
Delay Related
285
Original Schedule
331
Original Schedule
and Changes
Changed Quantit es
34
Unk, Cond tion
7
Weather Related
31,5
Breakout of Changed
Conditions Days
Original Project Schedule: 331 days
Revised Project Schedule: 688,5 days
('Work completed 72.5 days beyond this,)
Figure 6
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to be arranged if necessary. Furthermore, the Engineer could ensure the change in site conditions do
not adversely affect the design and would allow the bid form to be adjusted for the larger volumes
to obtain a lower initial unit cost. If managed correctly, the verification sampling and testing program
could run concurrently with the design and not impact the project schedule.
RELATED TO WEATHER DELAYS
It is essential that clear and definitive language be developed to cover the possibility of weather
affecting the project schedule. Any weather days anticipated in the schedule should be clearly
identified in the bid documents. Wording should also be provided to protect the owner (State/EPA)
when the contractor is suffering from rainy weather primarily due to poor drainage practices. Better
discussion of weather delays in the contract documents would have reduced the amount of time spent
negotiating with the contractor days due for inclement weather.
RELATED TO THE ALABAMA LAWSUIT
Outside forces can surprise any project and put it into a state of delay. If another government body
is involved in the delay, it is essential that all parties to the contract be privy to negotiations and
events that transpire, which might effect the project.
The parties to the contract should come to terms immediately as to what costs would be allowed under
the contract during the delay. At the end of the delay, the contractor at Geneva attempted to claim
interest charges based upon the delay costs. Since interest as a cost item was not negotiated at the
beginning of the delay, these claimed costs could not be allowed and the contractor filed for
arbitration. Months of negotiations were required to settle the issue, costing hundreds of man-hours
by both state and EPA personnel.
CLOSING
In theory, the change order process looks so neat and orderly. But the lack of specific enough
language in a contract, coupled with the uncertain nature of Superfund sites, can turn changed
conditions into a nightmare. And the costs are not just in increased contract price and delays in
completion. The fractious nature of change order negotiations can shift the focus of the State/EPA
Project Manager, the Engineer, and the contractor, and the project suffers. Change orders
negotiations based upon clear and concise contract language can be relatively painless, and allow
everyone to get on with the real work at hand.
REFERENCES
1. Site Investigation (RI Report) for Geneva Industries, Houston, Texas. IT/ERT/Rollins, TWC,
and EPA. June 1985.
2. Feasibility Study (FS Report) for Geneva Industries, Houston, Texas. IT/ERT/Rollins, TWC,
and EPA. April 1986.
3. Record of Decision (ROD), Remedial Alternative Selection, Geneva Industries, Houston,
Texas. EPA. September 1986.
4. Contract Documents and Specifications (Remedial Design Report), Geneva Industries,
Houston, Texas. IT Corporation, TWC, and EPA. January 1988.
5. Final Report of Remedial Activities (Includes all project files), Geneva Industries Superfund
Site, Houston, Texas. IT Corporation, TWC, EPA. September 1990.
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Transportation and Disposal of
Denver Radium Superfund Site Waste
Rick Ehat, Construction Liaison Engineer, P.E.
Elmer Haight, Construction Liaison Engineer, P.E.
Bureau of Reclamation
Denver Office
PO Box 25007
Denver CO 80225
(303) 236-8335
INTRODUCTION
This paper is intended to describe the organizational makeup, the contract methods utilized, the
contractors' methods, and as an update of the current status of the Denver Radium Superfund Site
(DRSS). A very similar paper was presented in 1989 by Mr. Elmer Haight at the 10th National
Conference of Superfund '89, and this paper is an updated version of that original presentation. Some
background information is also presented to provide a better understanding of the overall project.
When Madam Curie discovered radium in 1898, she set in motion a chain of events which left an
unwanted legacy for following generations. By the early 1900's, radium was touted for its medicinal
properties and ability to destroy or inhibit cell growth, and it became widely used as a treatment for
cancer. As a result, demand for radium skyrocketed, starting the radium boom of the early 1900's.
Prior to 1914, there was little or no domestic production of radium. Rather, radium-bearing ore was
shipped from the United States to Europe, where it was refined. About 1914, it became evident that
processing in the United States would be advantageous. The U.S. Bureau of Mines entered into a
cooperative agreement with a private corporation, the National Radium Institute (NRI). According
to the agreement, the NRI was to develop and operate a radium processing plant in the United States.
The demand for radium grew, and new sources for radium were sought. Carnotite, a radium-bearing
material, was identified in Colorado about that time, and it seemed appropriate to locate the NRI in
Denver. Carnotite provided the ore from which radium was extracted by several processors in Denver
from 1914 to about 1920.
The Denver radium industry remained strong until around 1920 when very rich deposits of radium-
bearing ore were discovered in the Belgian Congo. The Denver producers could not compete, and the
Denver radium industry closed almost overnight.
The health-related implications of radium processing were not known or considered a problem in
those days. Although much of the radium was recovered, process residues containing radioactive
materials were discarded.
In 1979, the Environmental Protection Agency (EPA) discovered a reference to the NRI in a 1916
U.S. Bureau of Mines report. Subsequent research revealed the presence of many sites in the Denver
metropolitan area containing material requiring remedial measures. One of the sites being remediated
was the location of the original NRI. This site contains about 88,000 tons of contaminated material.
Studies were subsequently conducted to identify the potential hazards on all of the known sites.
There are 44 properties that have low levels of radioactive contamination that could potentially
endanger public health or the environment.
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The DRSS was placed on the National Priorities List in 1983. Due to the enormity and complexity
of the DRSS, the EPA determined that response actions could be conducted in groups or operable
units, and 11 operable units were established. Nine of the eleven operable units are being serviced
by the Bureau of Reclamation's (Reclamation) transportation and disposal contractor.
The work falls under the jurisdiction of EPA's Region VIII, which is headquartered in Denver.
EPA's agreement with the Department of Energy (DOE) is to provide the final studies and site
investigations and to develop appropriate specifications for the excavation of the contaminated
material and restoration of each of the sites to as near the original condition as possible. This is a
difficult task because each property where contaminated material is located is unique. It involves
open areas in some cases and in others it includes contamination in and under buildings.
Strong efforts are made during all site work to keep existing active businesses in operation. The
logistics of this presents a significant challenge to DOE and their contractor, Geotech, which provides
the engineering and construction oversight for the remedial action work. The work involved for each
operable unit is covered by its own construction subcontracts.
Since 1988 to date, a total of 13 separate subcontracts to perform excavation loadout and
reconstruction have been awarded and completed. Three are currently under way and four are
scheduled in the future in order to finish this project by the fall of 1992.
INTERAGENCY AGREEMENT
During the investigation stage, EPA asked Reclamation to provide remedial action assistance in the
transportation and disposal phases of the project. An Interagency Agreement was signed in September
of 1988. Reclamation became responsible to contract for all aspects of the transportation of the
material and disposal in a proper facility. Reclamation is providing the contract administration and
construction management for the work.
Most of the overall coordination with interested and affected parties such as the owners and local,
State, and Federal governments is handled by EPA personnel. Matters involving cost recovery,
obtaining State of Colorado participation in funding, and working with various entities to assist in
identifying and obtaining permits and licenses are handled primarily by EPA.
The matter involving cost sharing is important as it pertains to maintaining a timely schedule of work,
because remedial work could not start on operable units until all agreements were finalized. Schedules
were directly tied to signing of these agreements.
QUANTITIES AND LOCATIONS OF WASTE MATERIAL
Since Reclamation involvement started in 1988, the estimated total amount of material to be
transported has risen from 140,000 tons to an estimated 385,000 tons used at the time the solicitation
was issued. This is due to better information further defining limits of contaminated material at each
site. Determining the depths and lateral extent in some cases is quite difficult. Access to some sites
is limited; buildings remain in place; and the sheer magnitude of the project all make accurate
computation of quantities difficult.
Of the nine operable units involved in Reclamation's transportation and disposal work, the estimate
of material from the smallest unit or property within a unit is approximately 20 tons. The largest
operable unit contains approximately 158,000 tons. Transportation and disposal service must be
provided to a wide variety of areas from a restaurant franchise to a large scrap metal processing
facility covering several city blocks.
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CONTRACT INFORMATION
For the transportation and disposal work, Reclamation chose a "requirements-type" contract.
"Delivery orders" are made against the contract as the work progresses. The solicitation was issued
in November of 1988. Technical qualifications of the firm receiving the award were of paramount
importance. Price was also of great importance. The interested firms were asked to submit separate
proposals, one for technical evaluation and one for price evaluation; the technical proposals carried
60 percent of the total available points and the price, 40 percent. Technical proposals from the firms
were evaluated by a committee of professionals, performing each review without discussion among
themselves. Following the independent review and scoring, the committee met to discuss the
individual firms' proposals. Consensus scores were arrived at for each item rated as it compared to
the preestablished evaluation standard. After best and final proposals were submitted and evaluated
in the same manner as the initial proposals, a contract was awarded to
Chem-Nuclear Systems, Inc. (Chem-Nuclear), of Columbia, South Carolina, a subsidiary of Chemical
Waste Management, Inc. Chem-Nuclear has been in business since 1969, is highly qualified in the
radiological waste disposal field, and has an excellent transportation safety record for this type of
material. The contract value is expected to be about $70 million if the final quantity of material is
near the originally estimated quantity of 385,000 tons.
The major subcontracts involved under Chem-Nuclear's contract include rail service, trucking, and
also the disposal facility. The disposal facility is Envirocare of Utah, Inc. (Envirocare), a facility
located about 80 miles west of Salt Lake City, Utah.
The base contract was set up to provide for transporting and disposing material from time of
mobilization through September 30, 1989. Option years include in sequence the fiscal years (October
1 through September 30) of each year until September 30, 1992. Chem-Nuclear's proposal contained
slightly different prices to perform the work for each succeeding year.
The Government places delivery orders against the contract based on the quantities to be hauled arid
the prices submitted by the contractor for each calendar period of performance.
The quantities estimated by Geotech are "in-place" volume. Through experience, a conversion factor
of 1.6 tons-per-cubic- yard was established and applied to this project. The contract includes a
schedule of anticipated volumes of material to be disposed of. But, as so often is the case in this
business, the actual amount of material removed varies considerably when the ground is opened and
the contaminated material is literally chased. This problem, coupled with the involvement of
approximately 20 different subcontracts for the excavation, has made the original schedule only a
guide.
The bid schedule contains only four pay items. The most significant one is the per-ton, all-inclusive
price for transporting and disposing of waste. Other items include the holding of loaded containers
while waiting for waste certification test results (this is paid for by day for every day held beyond
7 days), moving empty containers from one unit to another to accommodate loading schedule changes,
and return of loaded containers to the operable unit where loaded in the event the material is outside
of the waste classification limits of the solicitation.
DESCRIPTION OF THE MATERIAL TO BE HANDLED
The waste is considered naturally occurring radioactive material (NORM) of low specific activity.
It is not considered "radioactive" under the Department of Transportation's (DOT) definition in 49
CFR 173, but the contract requires that certain portions of those regulations be followed in
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transporting waste. Much of the material looks like ordinary soil, and the debris is mainly building
materials, pavement chunks, tree stumps, and similar items.
The primary radioactive contaminants include Radium-226 (Ra226), found in concentrations of
approximately 100 picocuries-per-gram (pCi/g) - with very limited amounts containing
concentrations up to 65,000 pCi/g. There is also Thorium-230 (TH230), concentrations approximately
100 pCi/g - with very limited amounts of material over this concentration.
Some NORM waste has been found to contain other nonradioactive contaminants. To date, this
material has been classified as exempt from the Resource Conservation and Recovery Act (RCRA),
as determined by the EPA. In order to properly dispose of this RCRA exempt NORM waste,
Reclamation had to negotiate a change order with the contractor. This was accomplished and a total
of 2,100 tons to date has been disposed of under the contract modification.
SAMPLING AND TESTING
The sampling and testing program set up and conducted by EPA, DOE, and Geotech for waste
certification provides needed information concerning the character and composition of the waste.
The representative sampling is done at the time of loading, and thus a determination can be made
concerning the average concentrations of Ra226 and TH230 in the waste, and to otherwise determine
if the waste is acceptable to the disposal facility. Some confirming record tests are also performed
at the disposal site by Envirocare.
LOADOUT OF CONTAMINATED MATERIAL
The methods used to date for loadout have been varied and depend upon the situation at the site.
Loadout of NORM material has occurred most commonly as follows: Load directly into the container
within the exclusion zone with some occasional rehandling and stockpiling of the waste. The
container is then frisked and decontaminated, if necessary, and released for shipment. The
decontamination is performed by Geotech.
Several other specialized site specific situations have occurred. The load is dumped at the edge of an
exclusion zone directly into a container. In this specialized case, the containers are also frisked to
check for external contamination prior to release for shipment. The load is hauled from the exclusion
zone through a "clean" area and dumped into a container. In this case, material was placed into bags
and put into a front end loader bucket for the short haul to the container. In another case, material
was placed from the exclusion zone into a front end loader bucket which was then covered with
plastic for the short haul to the container. In all cases, this involved relatively small quantities of
material. At another site, due to the existing grade and site layout, a conveyor system was installed
to load material from a lower elevation directly into railcars. This system was required to be fully
enclosed with shrouded downshoots and water sprinkler nozzles for health and safety concerns for
prevention of airborne contaminants. During operation, numerous problems developed, primarily due
to saturated material. A ramp was then constructed by the loadout contractor for direct dumping into
the railcars. The conveyor system was installed, operated, maintained, removed, and decontaminated
by Chem-Nuclear, the transportation and disposal contractor.
An important item to consider during specifications development is whether or not transportation and
disposal should be a separate contract from remediation. A critical item, if they separate contracts,
is a detailed description of the exact conditions associated with the loadout. The location, method of
loadout (if appropriate), decontamination responsibility, and how the decontamination area will be
finally cleaned should be well planned and specified in detail.
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TRANSPORTING THE WASTE
Chem-Nuclear is transporting the majority of the material in 100-ton railroad gondola cars and the
remainder in smaller containers of 20-ton capacity. The sampling and testing procedures will
accommodate these containers. Samples are analyzed by the opposed crystal system (OCS) gamma-ray
spectrometer. The radium concentration determined by the OCS is used to confirm that the average
radium concentration does not exceed the maximum allowed by the disposal facility. Laboratory
testing for TH230 and numerous other tests are performed as appropriate. Split samples are provided
to the disposal facility for comparative testing upon their request.
As test results become available, containers are released for disposal. Note that in order to allow for
holding cars, and an extended amount of time due to testing delays, a contract bid item is used to pay
per day for holding cars in excess of 7 days.
Since the first delivery order, Chem-Nuclear has been working intensely at getting railroad spur
tracks improved and installing new ones at several operable units. This not only involves coordination
among the railroads, owners, and others, it also involves coordination with Geotech to ensure the
transportation phase remains compatible with the loading operations. Railroads need to provide the
necessary switches and track and also schedule availability of gondola cars.
Operable units where rail service is not available, or where it is not feasible to construct spur track
into the areas, are served by trucked roll-on, roll-off, 20-ton containers.
All containers must meet DOT requirements for shipping radioactive waste. They must be closed,
tight containers set aside for exclusive use for DRSS wastes. If the material is such that it will stick
to the gondola, the gondola car is lined with 6-mil polyethylene sheets. All cars are filled and steel
clad lids cover the entire car's top. The lids weigh about 1,200 pounds, and were originally lifted on
and off by a small forklift. The contractor later designed and built a gantry crane which was used
to easily lift on and off the lids. The forklift method was eventually discontinued at all sites, except
for special instances.
The first lids used were called "trak-pak" and were plastic tarps supported by a network of trusses.
The first hard lids referred to "NFT" or fixed lids which were purchased/developed and worked into
the fleet of railcars near the beginning of the job. These lids were reusable, metal box tubing framed,
and covered with metal skinned styrofoam panels.
Then, in the summer of 1990, Chem-Nuclear tried what were called "soft tops" for gondola covers.
These consisted of heavier plastic covers which contained a drawstring for a snug fit on the ends of
the gondolas. Due to the harsh climatological and wind conditions the railcars are subjected to, this
type of soft plastic covers was discontinued.
The contractor then developed another "metal clad" lid which consisted of approximately the same
frame as the "NFT" lids but additional supports were added across the frame at 2-foot intervals. The
metal clad lids were constructed by combining three equivalent interchangeable sections into one lid.
These lids were then covered with corrugated galvanized sheet metal.
After loading, decontamination, and lidding, the gondolas are then switched and start their journey
to the disposal facility by Burlington-Northern tracks to Speer, Wyoming, where they are switched
to Union Pacific to continue to Envirocare's disposal facility. The disposal facility has direct rail
service and has easy truck access from U.S. Interstate Highway 80.
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Material from operable units not served by rail is loaded into the 20-ton containers. Chem-Nuclear
has provided a transportation terminal in Denver, located at 1960 A 31st Street, where empty
containers are stored and released as needed to operable units for loading. After loading, the vehicle
and container is decontaminated by Geotech, and travels back to the transportation terminal for
weighing. It then proceeds to the railroad's intermodal yard for loading on flatcars for the trip to Salt
Lake City, Utah. It is then picked up by truck and transported to a holding area at Envirocare to wait
for test results allowing disposal. Truckers must meet stringent qualification requirements. Vehicles
are inspected daily. City routes have been established to avoid residential and school areas, and all
routes meet the approval of local Transportation Engineering Departments. Security at the
transportation terminal is 24 hours a day, 365 days a year.
All containers are weighed using State certified scales manned by State certified weighmasters.
The problems with the transportation and disposal operation itself have been limited, largely due to
the contractor's site management and coordination efforts. The significant problems which have
occurred are: 1) limitations on railcar movement due to problems with coordination between multiple
railroads; 2) scheduling fleet size and lead time required, and maintaining an established fleet
economically for long periods of time using difficult and uncertain data as the basis for these
decisions; 3) disposing of frozen material; and 4) reacting to short term schedule fluctuations in a
timely manner. Even though the remedial action contracts require a weekly schedule be provided,
the fluctuations are many times only predictable from 1 to 3 days in advance due to the nature of this
remedial action.
To date, one claim for extra compensation has been filed alleging increased costs due to schedule
fluctuations different from those portrayed in the specifications. This issue is not resolved at this
time.
During the summer of 1990, Chem-Nuclear's parent company Chem Waste Management purchased
Geotech, DOE's contractor. As a result, this purchase created the appearance of a conflict of interest
as determined by Reclamation. This is due to the fact that Geotech is directly in control of the
quantity of material being excavated and ultimately transported and disposed of by
Chem-Nuclear.
Reclamation is currently seeking approval of a waiver by the Assistant Secretary of Interior as
required by the Federal Acquisition Regulations (FAR) which adds oversight of the as-directed
excavation operation performed by Geotech's subcontractors by an independent contractor.
DISPOSAL FACILITY
Envirocare of Utah, Inc., was chosen by Chem-Nuclear as the only operating NORM waste disposal
facility in the country that can receive radium waste in bulk form. It has been used to receive
material from several sources including at least 2.5 million cubic yards of mine tailings. It became
fully licensed in February of 1988. After years of comprehensive studies, this disposal site was
selected by DOE and the State of Utah as the best out of 29 potential sites in Utah. The facility is
designed to handle over 20 million tons of contaminated material. The facility lies above a substantial
clay layer which provides a good bottom seal for the cells. The percolation rate through the layer is
extremely low. The facility is far from surface water or potable groundwater. The DRSS cell is
excavated several feet down from the ground surface in an area about 600 feet wide by 800 feet long.
It is filled layer by layer with waste until all waste under the contract has been deposited in the cell.
Railcars, as they arrive are held on Envirocare's railspur, capable of holding more than 250 railcars
at one time, until official clearance to dispose of the material is received. They then proceed to the
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area where the covers are removed, and the gondolas are put onto a rollover machine where each car
is secured in the machine and turned over about 150 degrees to dump its contents onto a concrete pad
beneath the machine. Cycle time is about 6 minutes-per-car. The waste is then loaded into dump
trucks with a front loader for the 4,000-foot trip to the cell. The dumped loads are spread into
approximate 12-inch lifts, moistened if necessary to facilitate compaction and control dust, and rolled
with a standard roller to at least 90 percent of laboratory maximum dry density using the standard
Proctor Method ASTM D-698.
All containers are decontaminated using a high-pressure washer prior to being released for return to
Denver. Only the outside needs to be decontaminated, since the containers will be covered for the
return trip and reused for this project. At the end of the job, the entire container, inside and Outj
must be cleaned as necessary for the container to be released for nonrestricted use.
The completed cell will be topped with a 7-foot layer of compacted clay which provides a radon
barrier. A 6-inch layer of gravel bedding topped with 18 inches of cobbles will provide the top and
side slope erosion protection. A drainage ditch and operation and maintenance road will surround
the cell. It is designed to be relatively maintenance free for up to 1,000 years.
The average moisture is 5 inches per year so downtime due to heavy rains or snow is minimal. Long
term assurances by trust agreement are provided for the continued maintenance of the facility. The
facility is appropriately licensed in accordance with the requirements of 40 CFR 192(a), fully
approved by the State of Utah, and is under their constant monitoring and inspection. Disposal
activities are in accordance with the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA), Section 121(d)(3). Groundwater and air monitoring measures are thorough.
Problems have occurred at the disposal site due to material becoming frozen during the shipping
process. Upon attempting to dump frozen material from the cars using the rollover machine, railcar
derailment and/or damage to the rollover machine would occur. Repairs are costly and time
consuming. As a result of these first winter problems, the dumping operation now has changed
during the winter months. The solution to the problem used was the night prior to unloading, several
cars are parked in a temporary shelter which is heated using portable space heaters, and a ramp has
been constructed up to a platform on which sits a backhoe which excavates material from the cars.
The rollover machine is not utilized during this period. The cars are also lined at the loading site with
plastic sheets to prevent material from sticking to the car ribs.
Envirocare has recently expanded its ability to take a more diverse group of materials by obtaining
a new disposal license. This may be utilized in the future by modification of contract in case the
situation arises to allow disposal of material which has NORM as well as other hazardous waste
components.
PERSONNEL PROTECTION
The work is little different in many respects than other work involving heavy equipment. This,
coupled with the special hazards associated with radioactive materials and other possible
contaminants, makes safety considerations of great importance. The contractor submitted an all-
inclusive safety program specific to the work before transportation and disposal work began.
In addition to the typical personnel protection measures, any person working on the operable units
must have physical examinations and attend the safety courses as required by the Superfund
Amendment and Reauthorization Act (SARA) and Occupational Safety and Health Act (OSHA),
including a baseline analysis for heavy metals. Also, certain site specific training and specialized
radiological training is required to work on the properties being remediated.
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External thermolyminescent dosimeters (TLDs) are required to be worn by all onsite workers.
Geotech provides the TLD service. They are worn whenever anyone enters the restricted area and are
left at an onsite trailer when leaving the restricted area. The TLDs never leave the site.
PUBLIC RELATIONS
Public relation aspects of the work are highly important and are primarily EPA's responsibility. When
the subject of radioactive waste comes up, the public perception is that it is highly dangerous. The
DRSS material averages about one-tenth of the value considered radioactive by DOT guidelines.
Meetings with various groups help dispel fears and are very important to the timely completion of
the work. Contacts have been made with local groups in the vicinity of the transfer station, and also
with the cities and communities along the Colorado, Wyoming, and Utah routes for hauling of the
materials. The fears subside, to a great extent, when the public is presented with the facts concerning
the nature of the material, and when details of the Emergency Preparedness Plan are discussed.
SCHEDULING AND COORDINATION
The solicitation contained a master schedule for the work. This was intended to present only an
indication of the sequence and duration of the work expected for the operable units involved. Waste
may be hauled from as many as six operable units at one time, so a long-range, 30- to 60-day forecast
schedule is necessary so there is some advance planning opportunity.
Communication and planning are the key elements to the success of this project. In order to ensure
this process is maintained, Reclamation conducts biweekly meetings with the principal participants
in the project. Representatives from Reclamation, EPA, Chem-Nuclear, Geotech, and the Colorado
Department of Health are present at these coordination meetings. The meetings are informal and a
free flow of information is encouraged. Usually, the quantity of material for loadout can only be
predicted for a few days ahead and often changes daily. This presents formidable challenges to the
transportation and disposal contractor to meet the demands of the loadout subcontractor. Flexibility
and resourcefulness are required to prevent delays. The performance of the contractor to date has
been exceptional in this regard.
Chem-Nuclear is required to handle a tremendous coordination and planning effort. It begins with
estimating the quantity and using projected start dates and production rates obtained from Geotech
and then sizing the hauling fleet, preparing containers, and scheduling the fleet. Chem-Nuclear also
arranges for holding areas, scales, haul routes, and intermediate inspection points. For each loadout
subcontract, at each loadout site, Chem-Nuclear must coordinate a loadout location consistent with
Geotech's decontamination process, and develop a lid-handling facility. In several locations, Chem-
Nuclear extended or refurbished existing rail lines to locations which could easily be serviced by the
loadout subcontractor. Coordination on a daily basis is required from the railroad companies to
efficiently order switches and, also, scales were installed at several sites which were utilized to more
efficiently load the railcars. If no scale is available at the site, the amount of material loaded is
estimated based on numbers of buckets and by experience for the particular type of material. If a
car is too heavy to legally travel the rails or highway, the container is returned to the site to be
downloaded at Chem-Nuclear's expense.
A value engineering (VE) study was performed in order to try to solve a difficult scheduling and
engineering problem at the Duwald Steel site (operable unit No. II). This process was extraordinarily
challenging because it included active participation between five divergent groups representing two
contractors and three government agencies (Geotech, Chem-Nuclear, EPA, Reclamation, and the
Colorado Department of Health). The basic problem was how to remediate the site while still
allowing the owner to remain in business in a congested and dynamic scrap metal operation. Several
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large buildings and major utilities on the site are founded on contaminated material and a large metal
shredding machine integral to the owner's business must remain in service. This is the last DRSS
operable unit and all of the DRSS disposal must be completed by the end of fiscal year 1992 (the end
of the transportation and disposal contract). Attacking this problem, the VE team devoted a full week
to identifying all problems and developing proposed solutions with an implementation plan. The plan
included action items with due dates to ensure success of the process. The VE team was implemented
and facilitated by Geotech personnel.
CONCLUSION
Reclamation has utilized their knowledge of construction contracting to provide the support needed
by EPA in accomplishing the transportation and disposal phases of the DRSS work.
Reclamation's contractor, Chem-Nuclear, is successfully servicing DOE's remedial action contractors
by providing the types of containers in the required quantities for loading. The transportation and
disposal work is proceeding without significant problems. Reclamation's contracting and construction
management capabilities make this agency very qualified to provide the services EPA needs to manage
this type of work.
ACKNOWLEDGEMENT
Certain portions of background information for this paper were obtained from various EPA
documents and fact sheets. These were of great help in developing this paper. The personnel whose
work was used in some way include Timothy Rehder of EPA and Rich Grotzke and Jamie Macartney
of Reclamation. Some information was also obtained from Jeff Stevens of Chem-Nuclear and Ron
Carlson of Geotech.
REFERENCES
1. Final Draft, Remedial Investigation - Denver Radium Superfund Site 5I-8L01.0, April 30,
1986.
2. Various EPA "Fact Sheets".
3. Solicitation No. 8-SP-81-15150, Transportation and Disposal Services - Denver Radium
Superfund Site, Denver, Colorado.
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Cost Estimating Systems for Remedial Action Projects
Gordon M. Evans
U.S. Environmental Protection Agency
Risk Reduction Engineering Laboratory
26 West Martin L. King
Cincinnati, OH 45268
(513) 569-7684
Jim Peterson
U.S. Army Corps of Engineers
Missouri River Division
P.O. Box 103 Downtown Station
Omaha, NE 68022
(402) 221-7443
INTRODUCTION
Given the great uncertainties that surround design and construction activities for the remediation of
hazardous, toxic, and radioactive waste (HTRW) sites, it stands to reason that cost estimates based on
the same level of information will necessarily reflect this uncertainty. Proof of this can be seen in
the extreme cases of cost escalation witnessed in a number of remediation projects as they move from
design to completion. This fact presents a compelling need for cost estimating tools that are flexible
enough to provide relatively accurate cost estimates based on the ever increasing amounts of
information detailing site conditions, and yet simple enough to insure ease of use and rapid generation
of results.
Toward this end, the United States Environmental Protection Agency (USEPA) and the United States
Army Corps of Engineers (USAGE) have been coordinating the development of independent, yet
complementary, cost estimating computer programs. By insuring overall compatibility between the
key aspects of software during the development process, users of these two cost estimating systems
will enjoy the ability to generate estimates at various stages in the remedial action design and
construction process by simply selecting an appropriate mix of software tools based of the level of
design data that is available to them. Thanks to a series of informal meetings between the USEPA
and USAGE, there was early agreement on a set of common goals and objectives thus insuring that
users would be able to combine the separate results from each model into a single unified solution.
This paper provides a discussion of the two software tools that are currently under development, and
will highlight their respective capabilities, both separately and in conjunction with the other.
BACKGROUND
Historically, remediation projects have experienced cost increases not seen in other construction
projects. These cost increases can be attributed to a number of factors, chief among which is the
incomplete characterization of the site and the extent of contamination. From the perspective of the
cost engineer, this uncertainty will have an adverse impact the cost estimate. Cost estimates generated
on the basis of unknown or uncertain information will always be subject to question. The end result
is that many projects are grossly underestimated during early project stages, leading to a host of
associated problems for site managers.
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In July 1989, the USEPA and the USAGE, each with strong interests in this area (and each with
ongoing software development projects) initiated discussions to determine the feasibility of
developing an integrated system of cost estimating tools for hazardous waste remediations based on
software development already underway. The ultimate objective of the cooperative effort would be
to insure that more accurate cost estimates are available for remediation work at early and
intermediate stages of a remediation project where limited design information is available.
DISCUSSION
Cost estimates for HTRW remediation work generally reflect the type of costs that are associated with
conventional construction projects. However, there are further considerations which complicate the
generation of an HTRW cost estimate. For example, additional costs must be factored in for items
ranging from special health and safety requirements to permitting activities.
Another problem arises from the selection, design, and construction of one or more treatment
technologies, clearly a site specific item. The failure to completely characterize the site during the
RI/FS process means that projects are bid by performance specification, where contractors are
required to design and construct the required treatment technology system to fit the special needs of
a site. This type of procurement is typically done with a lack of detailed design information. This
means that a cost estimate for the treatment technology must be priced out by a process method rather
than at the individual line item (unit cost) level. While the line item approach is capable of generating
more accurate estimates than the process method, it also requires the type of detailed information that
is often unavailable at early design stages. As a site becomes better characterized over time, it may
be desireable to revise estimates, substituting line item estimates where possible. The focus of the
USEPA and USAGE collaboration is to develop cost estimating software tools that will integrate the
estimation of both system costs and detailed line item costs.
The USEPA's system, RACES (Remedial Action Cost Estimating System) is a treatment technology-
based HTRW cost estimating system that is currently under development by the Risk Reduction
Engineering Laboratory. RACES asks the user to select a specific treatment technology, to input
known and assumed site characteristics, and to assign general cost factors. The end product is a
comprehensive (and easily modified) estimate of capital and operating costs, both on a life cycle and
a present value basis. While the RACES system has been developed for use in the preliminary and
intermediated design phase, it is also suitable for budget estimating.
The system relies upon two types of cost data to generate it's estimates: (1) unit (line item) costs, and
(2) cost estimating relationships (CER's). Unit costs are comprised of specific discrete components
or items of work that are typically found in the construction industry. These individual unit costs
are collected into assemblies and then reported to the user in that fashion. Presently, RACES has
compiled unit costs based on some 600 detailed tasks originally drawn from the R.S. Means and
Richardson Engineering databases (and used by permission of the respective organizations). As part
of the coordination with the USAGE, future versions of RACES will rely on unit costs taken from
the Corps of Engineers own Unit Price Book (described below).
Conversely, CER's are algebraic equations used to estimate costs based on relevant variables. CER's
are primarily used to estimate costs of complete treatment systems and subsystems over a range of
capacities. The CER's in RACES are derived from a number of sources including published cost
engineering reports, expert opinion, and independent cost engineering analyses. Each CER will be
independently validated before release. The use of this approach is most appropriate when it is
impractical to develop a unit cost item for every component of a system covering every possible size.
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The RACES system is focused on two general classifications of HTRW technologies: (1) control
technologies (i.e., slurry walls, subsurface drains, etc.), and (2) treatment technologies (i.e.,
incineration, air stripping, etc.) Within the RACES system, unit costs are used to generate costs for
control technologies. Treatment technology costs are generally arrived at through the use of CER's.
The USAGE system, M-CACES (Micro-Computer Aided Cost Engineering System) is, in contrast,
a "bottoms-up" estimating tool. It is utilized primarily for development of cost estimates for which
detailed design information is available. M-CACES is a proven system and has been used by the
Corps to estimate the cost of both military construction and civil works projects. It is the HTRW
portion of M-CACES that is currently under development by the Corps.
Estimates derived from M-CACES reflect labor, equipment, and material costs taken from the
USAGE'S Unit Price Book (UPB) database, which is maintained and updated regularly by the Corps.
At the present time, the UPB database contains more than 20,000 individual line items covering all
aspects of construction work. To meet the needs of the HTRW portion of M-CACES, the UPB is
being updated to include specific line items relating to HTRW, mixed, and radioactive wastes. At the
present time, over 1,700 HTRW line items have been developed for the UPB. An additional 900
HTRW line items, and up to 1,000 mixed and radioactive waste line items, are scheduled for
development during 1991.
The interest in an interface between RACES and M-CACES arose from the fact that RACES provides
the only known tool (partial or completed) for predicting HTRW treatment technology costs. As
mentioned earlier, in order to provide performance specification contract estimates, the Corps of
Engineers must necessarily generate estimates without formal design documents. RACES can provide
treatment technology cost forecasts which the Corps can supplement with the standard line item
estimates available through M-CACES. Since the RACES generated treatment technology cost
estimates are based on CER's (without the support of material and labor details) they will be
represented in M-CACES as elemental costs, unsupported by line item detail. From a software
perspective, any treatment technology estimates are placed in an output file from RACES and then
imported into M-CACES.
Since the initial meetings in early 1990, collaboration between the USEPA and USAGE has extended
beyond the confines of computers and software to encompass the broad range of cost engineering
issues confronting practitioners in this field. A case in point stems from the joint concern over a lack
of standard database to collect and categorize the costs from completed remediation projects. The
existence of such a database is a critical component in verifying the accuracy of any cost estimating
system. As a result, a side effort was undertaken to develop a common database structure for use by
all government agencies.
The first step in this process was the development of a standard HTRW work breakdown structure
upon which a code of accounts would be based; a work breakdown structure is a hierarchical
breakdown of the work into a numbered structure, organized in a logical manner. Toward this end,
representatives from the USEPA, USAGE, Navy, and DOE met in January of 1991 to develop a draft
HTRW Code of Accounts. After breaking the work into four major phases (assessment,
engineering/design, construction/remediation, and construction management), the group focused it's
efforts in two to the four phases, the assessment phase and construction/remediation phase. Draft
copies of the Codes of Accounts for these two areas are being reviewed within the various agencies
with a goal to issue a final version by September 1991. Issues yet to be resolved include the
establishment of collection procedures for cost data and management of such a database.
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CONCLUSION
Previously, neither agency has had a complete software tool for use in the preparation of HTRW cost
estimates. When work on RACES and the HTRW portion of M-CACES is finally completed, the two
systems will be able to provide cost engineers with a comprehensive estimation tool that allows the
generation of estimates at various levels of site detail. The collaboration between cost engineers at
the USEPA and the USAGE continues. Representatives of other Federal agencies, such as the
Department of Energy, are also providing input to this effort based on their own remediation needs.
It is clear that these informal inter-agency efforts will continue into the future, and may someday
lead to larger and more comprehensive estimating systems.
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HTW Construction Documentation Report:
A Necessary Element in a Successful Remediation
Heidi L. Facklam, P.E.
U.S. Army Corps of Engineers
Missouri River Division
P.O. Box 103, DTS
Omaha, NE 68101-1013
(402) 221-7340
INTRODUCTION
To most people a hazardous and toxic waste (HTW) remedial action consists of two elements, design
that culminates in plans and specifications, and construction that implements the design. However,
a third element, documentation and evaluation of the completed remedial action as it was actually
constructed is also needed. Existing HTW guidance provides for a remedial action report, but the
focus of this guidance is to provide certification that the remedy was performed in general accordance
with the design and is operational and functional. Existing guidance does not address the type of data
or information useful to evaluate the long term effectiveness and performance of the remedy or
improve future designs. A HTW Construction Documentation Report, which would document
construction activities and evaluate construction data, is an essential element in a successful
remediation.
BACKGROUND
POST REMEDIAL ACTION GUIDANCE:
US Environmental Protection Agency. Existing HTW guidance on post remedial action reports on
Superfund projects is contained in US EPA publication, "Superfund Remedial Design And Remedial
Action Guidance". A remedial action (RA) report is to be prepared by the agency that has primary
responsibility for construction inspection. It is to contain the following elements:
• "Brief description of outstanding construction items from the prefinal inspection and an
indication that the items were resolved
• Synopsis of the work defined in the SOW and certification that this work was performed
• Explanation of any modifications to work in the SOW and why these were necessary for the
project
• Certification that the remedy is operational and functional
• Documentation necessary to support deletion of the site from the NPL.
For a responsible party remedial action, the document of settlement may specify different final
inspection/ certification conditions."
US Army Corps of Engineers. The Corps of Engineers included post remedial action reporting
guidance in the "Superfund Management Guide" which provides Corps personnel with general
guidance on management of EPA Superfund work assignments. It states that the Corps
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"will forward to the EPA Region all pertinent documents once the project is completed.
Documents include reports sufficient to develop a chronological record of site activities, e.g.,
contractor daily reports, change orders, problems and solutions regarding compliance with
environmental and contractual requirements, laboratory and monitoring data, etc. An
Abstract of these data should also be sent to the Design Division and HQUSACE
(DAEN-ENE-B), for information purposes only. For example, include:
(a) synopsis of work described in the contract and certification that this work was
performed;
(b) explanation of any modifications to original work scope and reasons they were
necessary for the project;
(c) listing of the criteria, established before the remedial action was initiated, for judging
the functioning of the remedy and explanation of any modification to these criteria;
and
(d) results of site monitoring, indicating that the remedy meets the performance criteria."
To date, post remedial action reports have not been prepared for all construction projects completed.
Distribution of completed reports has been limited. In some cases, the designers have not been
provided with the reports. Reports prepared to date have included varying levels of detail. A report
prepared for a landfill closure provided photographs, drawings, lessons learned, and some details
about actual construction. A report prepared for a total containment remedy contained little
information or data from actual construction activities. Although both reports provide the
certification that the constructed remedy is operational and functional, they contain little information
to provide a basis for evaluating the long term effectiveness and performance of the remedy or to
provide information useful to designers of similar components.
DOCUMENTATION AND EVALUATION GUIDANCE:
Even though existing post remedial action guidance does not address documentation and evaluation,
guidance does exist that can be readily adapted to remedial actions.
Landfill Document Report. Specific guidance for a construction documentation report that would
be useful in evaluating the long term performance and provide for technology transfer is presented
in EPA's Technical Resource Document on Design, Construction, and Evaluation of Clay Liners for
Waste Management Facilities. Documentation is addressed as the fifth element of a construction
quality assurance plan. Major elements of the construction documentation report are listed as
engineering plans, engineering cross-sections, comprehensive narrative, series of 35-mm color prints,
and construction certification. Wisconsin Department of Natural Resources regulations include a
complete chapter on landfill construction documentation which expands on the elements presented
in EPA's Technical Resource Document.
US EPA's SITE Program. US EPA's Superfund Innovative Technology Evaluation (SITE) program
provides an interesting parallel to remedial actions. At the completion of each demonstration project,
a technical report documenting performance data resulting from the demonstration is required. The
"Demonstration Report" includes testing, procedures, data collected and QA/QC conducted. It
summarizes the results in terms of performance (effectiveness and reliability) and cost. The report
is used as a technology transfer tool.
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US Army Corps of Engineers. The Corps of Engineers, perhaps because of its unique role in
designing, constructing, operating and maintaining major civil works projects, i.e., dams, locks, etc.,
has long recognized the need for and the value of documenting construction activities and evaluating
the performance of completed civil works construction projects. Two separate Engineering
Regulations (ERs) govern these activities. The first regulation is "CONSTRUCTION FOUNDATION
REPORTS." The purpose of this regulation is to require the preparation of
"as-built foundation reports for all major and all unique civil works and military construction
projects. Major construction projects are those that fall in the category of multimillion dollar,
multipurpose projects, whereas unique construction projects are those, regardless of size, on
which difficult, critical or unusual foundation problems were encountered, or for which
unique design and/or construction procedures were developed."
It states the following reason for preparing foundation reports and their intended uses:
"Properly prepared foundation reports insure the preservation for future use of complete
records of foundation conditions encountered during construction and of methods used to
adapt structures to these conditions. During construction, voluminous records often are
maintained that are filed on completion of the project without regard to possible future
usefulness. When an occasion arises at some later date requiring reference to these records,
considerable time is consumed and difficulty encountered in finding all the needed
information. Such information is readily available if it is assembled in a concise foundation
report at the time of construction.
The most important uses to which foundation reports are put are (1) in planning additional
foundation treatment should the need arise after project completion, (2) in evaluating the
cause of stress, deformation or failure of a structure, and in planning remedial action should
failure or partial failure of a structure occur as a result of foundation deficiencies, (3) for
guidance in planning foundation explorations and in anticipating foundation problems for
future comparable construction projects, (4) as an information base in determining the
validity of claims made by construction contractors in connection with difficulties arising
from alleged foundation conditions or from alleged changed conditions, and (5) as part of the
permanent collection of project engineering data..."
The second regulation is "EMBANKMENT CRITERIA AND PERFORMANCE REPORT." The
purpose of this regulation is to require the "preparation of an as-built embankment report that
summarizes the design criteria and embankment performance for all earth and earth-rockfill
construction projects." It states the following reasons for preparing Embankment Criteria and
Performance Reports:
"A properly prepared report will provide a summary record of significant design data, design
assumptions, design computations, specification requirements, construction equipment,
construction procedures, construction experience, field control and record control test data,
and embankment performance as monitored by instrumentation during construction and
during initial lake filling. The report will provide in one volume the significant information
needed by engineers to (1) familiarize themselves with the project, (2) re-evaluate the
embankment in the event unsatisfactory performance occurs, and (3) provide guidance for
designing comparable future projects."
Many similarities exist between civil works projects and remedial actions. A civil works project can
have an expected design life in excess of 100 years. If complete removal and destruction of
contamination is not achieved during a remedial action, contamination may exist indefinitely. Failure
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of a civil works project as well as a remedial action may endanger the public. Thus, the
documentation and evaluation practices vital to the success of civil works projects are appropriate for
HTW remedial action projects.
DISCUSSION
The value of documentation is highlighted by the fact that construction activities are seldom exactly
as assumed during design. The main factors in these differences are contractors and site conditions.
No two construction contractors operate in the same manner. Personnel, equipment, and resources
vary. Site and subsurface conditions are difficult to assess completely and accurately during
investigation and design. The effectiveness and perfomance of a remedy can not be evaluated without
actual construction details and data. Future design can not benefit from past construction activities
without a method of technology transfer. The importance of feedback from construction activities
is enormous.
In order to accomplish this, good documentation and evaluation practices must be implemented.
These practices will result in an HTW Construction Documentation Report. A properly prepared
report will record and preserve construction records, conditions, and activities in a readily accessible
form and evaluate construction data. The report may be used by various or- ganizations to provide
the following:
(1) Record of construction activities. Historical documentation will be available as to quantities
excavated, cleanup levels, materials or equipment used. This is particularly important in
rapidly advancing areas of innovative technology and to provide factual data for potential
litigation.
(2) Field data applicable to design of future operable units. Many times, construction activities
of one operable unit provide valuable design information for another operable unit on a site.
Information may include dewatering quantities, additional characteristics of subsurface
conditions, and borrow material used.
(3) Information required for long term performance monitoring and site maintenance. Long term
performance monitoring and site maintenance are required at HTW sites where the remedial
action results in any hazardous substance, pollutants, or contaminants remaining on the site.
This monitoring may continue for a period of 30 years or more. Good data on construction
activities will identify areas that need closer attention during long term maintenance.
Problems occurring during construction may identify areas needing particular monitoring to
ensure adequate performance of the remedial action.
(4) Baseline information for design of repair/modifications in case of failure. In the event of
failure of any portion of the remedial action, the construction documentation report will pro-
vide a starting point for evaluation of the nature of the failure. Cause of the failure, design
and/or construction related, is important in the design of the repair/modification.
(5) Basis for SARA mandated review/evaluation. SARA (Superfund Amendments and
Reauthorization Act of 1986) requires "review of such remedial action no less often than each
5 years after the initiation of such remedial action to assure that human health and the
environment are being protected by the remedial ac- tion being implemented." SARA section
406
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(6) Account of lessons learned. The complete account of the lessons learned, supported by data,
is also an important part of the construction documentation report.
The HTW Construction Documentation Report, in conjunction with the Design Analysis, Site
Maintenance Plan, Construction Specifications, and As-built Drawings will form the permanent col-
lection of project engineering data.
Documentation and evaluation practices are the responsibility of both the construction quality
assurance (CQA) staff and the designers. Successful remediation is a team effort. The HTW
construction documentation reports should be prepared by persons who have firsthand knowledge of
the project design and construction. Where possible, the authors should be the designers and the CQA
staff responsible for the detailed work on the project. The CQA staff would be responsible for
compiling field data/activities and lessons learned. Where possible and considered efficient, data
collection can be included in the construction contract. Based on the data and their CQA experiences,
the CQA staff would make appropriate recommendations for future monitoring, design or
construction activities. The designers would be responsible for evaluation of the data.
Recommendations that would affect future design work at the site or affect the operation and
maintenance of the site should be a joint effort of the CQA staff and the designers. Reports should
be finalized within six months after the project is substantially complete.
Costs for preparation and reproduction of a HTW construction documentation report should average
about 1 percent of the total construction costs for projects under $10,000,000 and 0.5 percent for
projects exceeding $10,000,000.
CONCLUSIONS
Timely and comprehensive HTW Construction Documentation Reports are an essential element in
assuring the successful long term effectiveness and performance of a remediation and will provide
technology transfer to improve future designs. Rapid implementation to prevent further loss of
valuable information is critical. Support from US EPA, designers, and construction CQA staff is
vital.
DISCLAIMER
Missouri River Division, HTW Design Center for the Corps of Engineers fully supports the need for
HTW Construction Documentation Reports and continues to work towards its implementation.
REFERENCES
U.S. Army Corps of Engineers. 23 May 1980. "Engineering and Design: Required Visits to
Construction Sites by Design Personnel," Engineer Regulation ER 1110-1-8, Washington, D.C.
U.S. Army Corps of Engineers. 15 December 1981. "Engineering and Design: Construction
Foundation Reports," Engineer Regulation ER 1110-1-1801, Washington, D.C.
U.S. Army Corps of Engineers. 31 December 1981. "Engineering and Design: Embankment Criteria
and Performance Report," Engineer Regulation ER 1110-2-1901, Washington, D.C.
U.S. Army Corps of Engineers. 5 January 1987. "Engineering and Design: Superfund Management
Guide," Engineer Pamphlet EP 1110-2-6, Washington, D.C.
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U.S. Environmental Protection Agency. 1986. "Superfund Remedial Design and Remedial Action
Guidance," OSWER Directive 9355.0-4A, Washington, D.C.
U.S. Environmental Protection Agency. 1986. "Superfund Innovative Technology Evaluation (SITE)
Strategy and Program Plan," EPA/540/G-86/001, Washington, D.C.
U.S. Environmental Protection Agency. 1988. "Design, Construction, and Evaluation of Clay Liners
for Waste Management Facilities," EPA/530/SW-86/007F, Washington, D.C.
U.S. Environmental Protection Agency. 1989. "The Superfund Innovative Technology Evaluation
Program: Progress and Accomplishments Fiscal Year 1988 (A Second Report to Congress),"
EPA/540/5-89/009, Washington, D.C.
Wisconsin Department of Natural Resource. 1988. "Landfill Construction Documentation," Chapter
NR 516, Wisconsin Administrative Code, Madison, Wisconsin.
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CHANGE ORDERS CAM RUIN YOUR DAY:
AM ANALYSIS OF CONSTRUCTION CHANGE ORDERS
IN THE REGION 6 SUPERFUND PROGRAM
(Author(t) and Addresses) at end of paper)
I. INTRODUCTION
One of the problems of living in an imperfect world is spending a
lot of time and money undoing past mistakes, resolving unexpected
difficulties, or adjusting one's priorities based on new
information. While this may sound like the beginning of a lofty
sermon, these basic concepts form the basis for the very down-
to-earth changes that occur on every construction project in the
form of change orders. The likelihood that some changes will be
required in the course of any construction project, whether it is
the assembly of a stealth fighter or the addition of a family room,
is very high.
While the term "change order" has historically caused Region 6
management to wince, the Superfund design and construction program
addresses the treatment of historical contamination which has
typically not been well characterized, such that change orders are
almost inevitable. However, while some change orders are
unavoidable, others can be averted, or their negative impacts can
be minimized. Remedial Project Managers (RPMs), in conjunction
with their management, EPA Headquarters, the State, and the
designers, can improve the Remedial Design process to minimize
those change orders which can be avoided and adequately prepare for
those which cannot.
This paper attempts to provide a snap shot description of the types
of change orders encountered in Superfund construction projects in
Region 6. Nine completed projects and one on-going project which
were Federally-funded and conducted by either the State or EPA were
analyzed as a basis for the conclusions in this paper. The
Table I. Analysis of cost overruns based on total Remedial Action
costs.
CHANGE FINAL
ORDERS RA COST COST
SITE (Si.oocn rsi.ooo) INCREASE
Geneva $4,386 $20,521 27%
Old Inger* $2,827 $7,866 56%
Highlands $1,397 $5,419 35%
Bio-Ecology $1,578 $5,317 41%
PetroChem $27 $1,717 2%
Crystal City $147 $1,239 13%
Triangle ($27) $480 -5%
Odessa 2 ($45) $344 -12%
Odessa 1 ($11) $159 -16%
United Creosoting $37 $133 38%
*Data obtained from pending change order claims.
Project is ongoing, and final costs not available.
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construction activities at these sites were conducted between the
years 1987 and 1991, with final construction costs ranging from
about $133,000 to $20.5 million.
Table I shows that, in general, the more expensive projects
experienced more significant overruns than the smaller projects
did. The exception to this trend was the United Creosoting
demolition, which was the smallest project, but registered the
third highest percent overrun. The possible reasons for this are
discussed in Section II.
II. ANALYSIS OF CHANGE ORDERS IN REGION 6
A. Evaluation of Change Orders Based on Remedy Type
The activities conducted at the sites included building demolition,
road construction, waste vault construction, water supply system
installation, landfarming, soil aeration, slurry wall construction,
and excavation and off-site disposal. Since most of the projects
for which construction activities are complete resulted from
relatively "old" Superfund Records of Decision (pre-SARA RODs), the
technologies represented are more conventional construction
activities, Therefore, little information on the construction of
newer innovative technologies such as soil washing or "high tech"
remedies such as onsite incineration is available in the Region to
date. Table II shows the types of remedies selected.
Table II. Relationship of remedy type to RA cost overruns.
SITE
Old Inger
Bio-Ecology
United Creosote
Highlands
Geneva
Crystal City
PetroChem
Triangle
Odessa 2
Odessa 1
ROD
pre-SARA
pre-SARA
pre-SARA
pre-SARA
pre-SARA
post-SARA
post-SARA
pre-SARA
pre-SARA
pre-SARA
COST
REMEDY TYPE INCREASE
Excavate/landfarm 56%
Excavate/landfill 41%
Clean/demolition 38%
Excavate/off-site 35%
Excavate/off-site 27%
Excavate/landfill 13%
Clean/Road 2%
In-situ aeration -5%
Clean/water supply -12%
Clean/water supply -16%
This study showed that certain types of construction are more prone
to change orders than others. In particular, those projects which
involve the excavation, removal, and handling of hazardous wastes
(contaminated soil, sludges, lagoons) will generally experience
significant changes due to additional waste quantities and unknown
site conditions. However, those sites which involve "clean"
construction activities such as road construction and water supply
system installation can be executed with few changes, since the
design of such projects can be well specified. Figure 1
illustrates this point, showing that most sites with remedies
410
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LU
tn
<
LU
tr
o
z
LU
O
cr
LU
Q_
60%
50% -
40% -
30% -
20%
-20%
10% -
-10% -
GENEVA Ol BIO HIGH CC TRI UC
SITE NAME
I//I HAZARDOUS WORK Y///A CLEAN WORK
OD1 OD2
PC
Figure 1. Percent increase in project costs based on type of
remedy.
involving hazardous work experienced significant overruns (Geneva,
Highlands, Bio-Ecology, Old Inger), while those projects involving
"clean" construction had smaller overruns or were actually
completed under budget (Petro-Chem, Odessa 1 & 2).
The exceptions to these general observations included the United
Creosoting and Triangle Chemical sites. At United Creosoting,
while the construction activities at the site were primarily non-
hazardous, a significant increase in price resulted from
encountering hazardous wastes in the form of asbestos-backed floor
tiles in the homes. At the Triangle site, additional contaminated
soils were encountered, but the quantity of trash and debris to be
removed from the site was over-estimated in the bid package,
resulting in a net decrease in project costs.
B. Relationship of RI/FS Spending to Remedial Action Overruns
Common sense would lead one to the conclusion that a poorly
characterized site would likely experience significant overruns in
contract price due to excess waste quantities and differing site
conditions. In order to confirm this hypothesis, the costs
411
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Table III. Comparison of RI/FS spending to RA cost overruns.
RI/FS COSTS RATIO OF RI/FS RA COST
SITE (THOUSANDS) TO RA COSTS INCREASE
Old Inger $348 4.4% 56%
Bio-Ecology $357 6.7% 41%
United Creosote* — ~ 38%
Highlands $355 6.6% 35%
Geneva $1,065 5.2% 27%
Crystal City $652 53.1% 13%
PetroChem $329 19.2% 2%
Triangle $175 36.5% -5%
Odessa 2 AWS $181 52.6% -12%
Odessa 1 AWS $161 101.0% -16%
*Available RI/FS data covers entire site while
RA costs are associated only with interim remedy.
associated with the Remedial Investigation and Feasibility Study
(RI/FS) for each site were compared to the percent overrun
experienced at the site. Instead of comparing RI/FS spending
directly with RA cost overruns, a ratio of RI/FS costs to total RA
costs was established to account for the relative size of the
projects, and this ratio (percentage) was then compared to RA cost
overruns.
As Table III demonstrates, those projects with a very low RI/FS to
RA ratio (less than 7%) showed significant cost increases, while
those projects with a higher ratio showed smaller RA cost
increases. If RI/FS spending is taken as a reasonable indicator
of the degree of characterization of the site, the data confirms
that a poorly characterized site (represented as a site with an
RI/FS to RA spending ratio of less than 7%) will experience
significant overruns, while sites which are better characterized
(RI/FS to RA spending ratio of above around 20%) will generally
experience lower overrun percentages . The United Creosoting site
was excluded from this analysis, since the costs associated with
the RI/FS for the interim remedy (house demolition) could not be
segregated from the total RI/FS costs for the entire site.
III. INCREASES IN CONTRACT PRICE
For this study, the change orders in Region 6 were segregated into
six cost increase categories and one cost decrease category. The
cost increase categories include excess waste quantities, force
majeure, administrative delays, differing site conditions, scope
changes, and pollution liability insurance. Project cost decreases
which could not be factored into the categories above were
classified as scope reductions.
The increases in project costs after issuance of a contract can be
classified by category into avoidable and unavoidable increases in
-------
contract price. Those change orders resulting from things within
the control of the Government or the contractor, such as inadequate
Site characterization, administrative difficulties, and changing
Government needs or priorities, were classified as "avoidable".
However, change orders caused by acts of God or third parties were
classified as "unavoidable".
A. Avoidable Increases in Contract Price
Those categories of change orders which have been classified as
avoidable increases in contract price include excess waste
quantities, administrative delays, differing site conditions, and
scope changes. In most cases, the savings associated with the
elimination of these change orders result from competitive prices
(through from the bidding process) and reduction of unnecessary
project administrative effort.
While these types of change orders could generally be reduced or
avoided, elimination of the change order may not result in as
significant of a reduction in contract price as might be expected.
This is due to the fact that the overall scope of a Superfund
project is "fixed" by the performance standards established in the
ROD, and the Government will most likely pay for remediation of all
material exceeding these standards, whether or not the full amount
is known at contract award. For example, though EPA may not be
aware of all of the materials which exceed the cleanup criteria,
all of these wastes must be addressed to comply with the ROD.
1. Excess Waste Quantities
The largest single contributor to increased costs in Superfund
construction, and probably the most difficult to address, is excess
waste quantities. As shown in Figure 2, the dollar amount of
excess quantity change orders represents approximately 70 percent
of all change orders processed in Region 6.
The primary reason that excess waste quantities are frequently
encountered at Superfund sites is that the extent of contamination
is usually inadequately defined. In the past, EPA's field efforts
during the Remedial Investigation (RI) have served as the only
information about waste quantities upon which the design is based.
The Remedial Investigation and Feasibility Study is usually
conducted under an eighteen-month schedule leading up to the
publication of EPA's Record of Decision for the site. Typically,
little time has been taken for any supplemental field work to
answer questions raised but not answered during the RI.
As indicated in Section II, the thoroughness of the RI/FS, among
other things, appears to have a significant impact on the
percentage overrun the project will experience. However, the fact
that the data collected during the RI is insufficient can be
addressed by additional sampling and testing during the Remedial
Design. While the target duration for an RD is currently 18
months, RPMs should evaluate the feasibility of such a schedule
based on the quality of the data available for the site.
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SCOPE SEDUCTION** C8.3>0
DELAY CB.OX5
EXCESS OUAN.
DIFFERING SITE C5.18Q
SCOPS CHANGE
FORCE MAJEURE C3.2X}
PL I C1.3»0
Figure 2. Dollar contribution of various change order types to
overall cost of change orders in Region 6.
Additional field work should be incorporated into the design if
better characterization of the site is necessary. RPMs and
designers should also account for the age of the RI data when
evaluating whether additional field work is warranted.
2. Administrative Delays
Administrative delays at Superfund sites have proved to be a
recurring problem in Region 6. These delays may result from a
number of conditions, including access problems, difficulties ift
obtaining permits, non-compliance of an off-site facility, and
contractual or legal problems. These types of delays were
encountered at four of the ten Region 6 sites analyzed.
At the Crystal City site, administrative delays represented 51
percent of the overrun for the project. After EPA's selection of
the remedy, the city of Crystal City, owners of the site, had
expressed strong dissatisfaction with remedy selected by EPA in the
ROD. While access had been obtained from the city for the conduct
of the RI/FS and the remedy, the Remedial Action contractor arrived
at the site with his equipment to find the gates padlocked and
patrolled by the local authorities. In this case, verifying that
access was in fact available prior to issuing a notice to proceed
may have reduced or eliminated these delay costs. EPA is now
requiring states which conduct remedial actions under cooperative
agreements to provide assurances of access and a completed design
package before awarding RA funds.
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3. Differing Site Conditions
Conditions at a site which differ significantly from what is
represented in the construction drawings and specifications are
considered differing site conditions. This type of change may
result from buried debris or concrete structures not shown on the
plans, additional waste of a different character or in a different
location than expected, or inadequate onsite materials or
facilities which were specified for use by the design.
The United Creosoting site experienced a 23.5 percent increase in
contract price due to a differing site condition. This project
involved the demolition of six Government owned homes which were
built over old creosote waste pits. Upon initiation of the
demolition activities, the contractor discovered that the floor
tiles in the homes were backed with an asbestos material. This
required special handling and disposal which had not been
anticipated in the original design.
The reason for encountering differing site conditions is similar
to that associated with excess waste quantities: inadequate or
incomplete information about the site. Although some conditions
cannot even be conceived of during the design, others should be
expected as a matter of course for Superfund work. Designers
should visit the site at a minimum to evaluate the current site
conditions, and RPMs should provide time and money in their design
schedule and budget to do additional field investigations based on
their own evaluation and the designer's recommendations.
4. Scope Changes
It is almost inevitable that during the course of a construction
project, the owner needs additional work done related to the
principal construction effort which was not part of the original
contract scope of work. For example, EPA may request additional
sampling and analysis, surveying, or design changes which are not
specified in the contract.
At the Petro-Chemical site, additional surveying was requested by
EPA to further define surface drainage patterns. Based on this
data, the drainage design was revised to correspond to actual field
conditions. This change of about $18,000 proved to be one of the
most significant change orders for the site.
Some scope changes may result from oversights in the original
design. For example, the design for the Geneva Industries site
omitted the installation of pressure relief well casings through
the RCRA cap as specified in the ROD. Additionally, the locations
of the casings for the ground water remediation pumping wells were
changed. These changes resulted from a decision during the design
to delay implementation of the ground water remedy design and
construction until later. As a result, some of the activities
associated with the ground water remediation (such as well
placement) which needed to be addressed during the source control
construction were overlooked. While this change order was small
415
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($3,500) compared to others for this site, such changes can be
avoided.
B. Unavoidable Increases in Contract Price
1. Force Maneure
Force majeure change orders result from events or third party
actions which are not within the control of the contractor or the
owner (EPA or the state). Such events include unusual or extreme
weather conditions and actions of third parties. In Region 6, two
of the ten sites studied experienced force majeure events for which
change orders have been processed. By nature, these events can
neither be anticipated nor avoided. The project manager must rely
on contingency planning and budgets to address such problems.
For the Geneva project, the off-site landfill facility selected by
the RA contractor to receive wastes from the site was located in
Alabama. As the contract-scheduled date for shipment of wastes
from the site approached, the Alabama Attorney General filed suit
against EPA requesting an injunction to stop implementation of the
remedy selected in the ROD. The complaint stated that, as an
"affected state", Alabama had not been given the opportunity to
comment on the selected remedy. The request for injunction was
granted by a Federal District Court, and the project was delayed
for nine months while EPA fought (and succeeded) to overturn the
ruling. The costs associated with this delay exceeded $680,000.
2. Pollution Liability Insurance
About 1.3 percent of the change order dollars spent in Region 6
have resulted from EPA's payment of the contractor's pollution
liability insurance premiums. This accounted for about 23.5
percent of the changes at the Crystal City site and about 5 percent
at Old Inger. In order to improve competition by increasing the
field of contractors eligible to bid on Superfund construction
projects, the Superfund Amendments and Reauthorization Act (SARA)
provided procedures by which EPA could pay for pollution liability
insurance premiums if contractors could not obtain the insurance
at a fair and reasonable price.
In the case of Crystal City, EPA elected to pay for the
contractor's coverage in the form of a change order. However, at
other sites, these premiums have been paid in a separate
procurement action. At Old Inger, the pollution liability
insurance change order paid for an extension of the contractor-
purchased coverage because the contract duration was significantly
increased by the excavation and treatment of additional waste
quantities.
IV. Decreases in Contract Price
In many cases, decreases in contract price are warranted because
of scope reductions and material underruns. The aggregate of these
reductions in contract price may prove to be significant. Overall,
416
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scope reduction change orders represented about 2 percent of the
total change order dollars changing hands on Region 6 Superfund
construction projects. At the two Odessa sites, only one change
order was processed for each site at the end of the project to
adjust for final installed quantities.
These change orders may result from contingency bid items (such as
access road repair) which are not necessary, unit price bid items
for materials which are not needed, or improvements or adjustments
to the specific work which result in a lower cost to the
Government.
Some problems may be associated with significant decreases in
contract price. Typically, if a unit price bid item underruns by
more than 15 percent, the contractor is entitled to an adjustment
in the unit price to reflect any per unit cost increases he may
incur as a result of handling a lesser quantity. Additionally,
major reductions in scope may cut into a contractor's profit,
resulting in potential claims.
V. MINIMIZING CHANGE ORDERS AND CONTINGENCY PLANNING
Minimizing the change orders in a construction project can save
the Government money in a number of ways:
-all the work incorporated in the original solicitation
benefits from the scrutiny of a competitive procurement,
-the negotiated price of a change order, though
reasonable, may not be the cheapest way to get the job
done,
-the cost of additional staff time and travel associated
with negotiating change orders can be avoided, and
-costly extensions to the project schedule which have
the domino effect on other portions of the project can
be avoided.
There are a number of things an RPM can do to minimize the change
orders he may experience during the remedial action. First, it is
essential that, prior to initiating the remedial design, he
thoroughly review (and requires the designer to review) the
available data for the site, including the Remedial Investigation,
Feasibility Study, treatability study results, after action reports
from any removals conducted at the site, and supplemental field
work data. The RPM should ask questions such as the following:
-How well is the depth of contamination defined?
-Do we know what is in all the tanks onsite?
-What wastes were removed or consolidated during the
removals?
-Were there any buildings onsite which are no longer
there? Have their foundations been accounted for?
417
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-Did the treatability studies provide sufficient design
parameters for a treatment system?
-Are there any easements or restrictions on the site property
which may impact the construction.
Second, RPMs and their management should not hesitate to conduct
additional field investigations and pilot tests if the current data
is sketchy. This type of field effort can be very beneficial,
since it can be tailored to specifically address the data gaps
identified during the data analysis. The time and money spent to
better characterize the site is almost always less than the
resources expended in change orders resulting from poorly defined
waste quantities and site conditions.
Finally, if the high degree of uncertainty concerning the
conditions at the site cannot be avoided, the RPM should evaluate
contracting mechanisms which minimize the impacts of this
uncertainty to both EPA (or the State) and the contractor. For
example, the contract could establish a minimum quantity of waste
which is anticipated and solicit a unit price for additional
quantities above this amount.
In all cases, EPA should establish a contingency fund in the
cooperative agreement, interagency agreement, or Work assignment
for unexpected and unavoidable changes. EPA's Superfund Remedial
Design and Remedial Action Guidance. June 1986, recommends
establishing a change order contingency of between 8 and 10
percent, depending upon the total cost of the project.
However, based on the experience of Region 6, the overruns
experienced at a site relate to the complexity of the remedy,
uncertainties concerning the quantity of wastes, and the degree to
which wastes must be handled. For those sites involving excavation
and handling of contaminated soils or sludges with a high degree
of uncertainty concerning waste quantities, higher contingencies
are warranted. The four Region 6 sites which fall into this
category (Geneva, Old Inter, Highlands, and Bio-Ecology) had
Table IV. Suggested contingency fund limits as a percentage of
estimated construction cost.
CONTINGENCY FOR GIVEN
LEVEL OF UNCERTAINTY
REMEDY TYPE LOW MEDIUM HIGH
NON-HAZARDOUS 5% 10% N/A
SIMPLE HAZARDOUS 15% 20% 30%
COMPLEX HAZARDOUS 25% 35% 45%
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overruns ranging from 27 percent to 56 percent. Conversely, those
sites requiring conventional construction activities with little
or no waste handling will be well served by an 8 to 10 percent
contingency. Table IV provides a suggested guide for establishing
contingency limits based on these factors.
V. Conclusions
While it would be nice for Remedial Project Managers to develop
superhuman x-ray vision to determine what's under the ground and
in the ground water, EPA can minimize the uncertainty associated
with Superfund remedial actions using very human methods. Each
player in the design and construction process has a part in
improving the design information for the site and producing a
reasonably accurate design. Designers should take responsibility
for identifying and informing EPA and the State of data gaps and
design uncertainties. Regional management and Headquarters should
readjust expectations concerning design schedules to allow time
for improving the design data picture through additional field work
and careful design reviews. Finally, the RPM should be attentive
to problem areas prone to change orders, uncertainties in waste
quantities, and faulty or inadequate designs, and he should
establish appropriate contingency budgets and schedules based on
the data uncertainties and project complexities.
MARK J. FITE
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 6
1445 ROSS AVENUE (6H-SC)
DALLAS, TEXAS 75202
(214) 655-6715
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Remedial Action Bids and Cost Estimates
Amy R. Halloran
Dikran Kashkashian
CH2M HILL
P.O. Box 4400
Reston, VA 22090
(703) 471-1441
Kenneth W. Ayers
U.S. Environmental Protection Agency
401 M Street S.W.
Mailcode OS-220W
Washington, D.C. 20460
(703)308-8393
INTRODUCTION
Cost estimates for Superfund Remedial Actions (RA) are prepared during the Feasibility Study
(FS) for the ROD and during the Remedial Design (RD) by the design engineer. According to
EPA Guidance, these two cost estimates are targeted to fall within +50/-30 percent and +15/-5
percent, respectively, of the actual cost of the RA. This paper compares the ROD estimates and
the engineer's estimates to the bids and actual costs of RAs at 24 federal-lead Superfund sites.
BACKGROUND
The Hazardous Site Control Division of EPA, in conjunction with CH2M HILL, has developed a
database of bids that were received for RAs at federal-lead Superfund sites. For each site, the
database contains a description of the RA aad technologies used in the remediation. It also con-
tains, on a line item basis, the ROD and engineer's cost estimates and the contractors bids. If the
RA has been completed, the dollar value of any change orders is also presented. The database
currently contains entries for 52 sites and actual completion costs for 25 of the sites. Table 1
contains a summary of the cost information in the database. Table 2 lists the technologies used
for the RAs in the database.
For this study, the differences between the ROD estimate, the engineers' estimate, the contractors'
bids, and the final cost of the RA, including change orders, were calculated for each of the sites
in the database. These differences were then compared to the desired cost ranges to determine if
they were within the target ranges. Factors such as the size of the projects (the final cost of the
projects) and the remediation technologies used in the RAs were compared to the differences to
see if they influenced the accuracy of the cost estimates or the spread of the contractors' bids.
DISCUSSION
ROD Estimate vs Actual Costs
Figure 1 presents the differences between the ROD estimates and the actual costs for RAs for 21
federal-lead Superfund sites. The differences were calculated by subtracting the actual cost of the
RA (including change orders) from the ROD estimate and dividing the result by the actual cost.
The result was then multiplied by 100 to yield the percentage difference. The target range for the
cost estimates, +50/-30 percent, is also presented on Figure 1. *
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For the 21 sites, 10 of the ROD estimates underestimated the final RA cost and 11 overestimated
the cost. The average difference was -1 percent. In comparison to the target range, 14 (67
percent) of the cost estimates were within +50/ -30 percent of the actual cost. At only one site was
the ROD cost estimate more than 50 percent greater than the actual RA cost. However, 6 of the
sites underestimated the RA cost by more than 30 percent.
Figure 2 presents a plot of the absolute value of the difference between the ROD estimate and the
actual site cost vs the cost of the RA. Although there is a significant amount of scatter in the data,
this figure indicates a trend that, on a percentage basis, the accuracy of the ROD estimates tends
to increase with the cost of the project.
For Table 3, the technologies used in the RAs for the 21 sites were divided into three categories:
Alternative drinking water supplies, soil treatment or landfilling, and water treatment. From this
table there appears to be a trend in the relationship between the technology used and the accuracy
of the ROD estimate. All of the ROD estimates for the RAs that involved providing an alternative
drinking water supply overestimated the actual RA cost. These estimates were all within the target
range of +50/-30 percent. Conversely, all of the ROD estimates for the RAs that involved water
treatment underestimated the actual RA cost by 19 to 55 percent. These trends may have
implications for remedy selection at the ROD stage. The accuracy of the ROD estimates for the
RAs which used soil treatment or landfilling did not have a trend.
Engineers' Estimates vs Actual Costs
Similar calculations were performed to compare the engineers' estimates to the actual RA costs.
Figure 3 presents the differences for the 19 sites in the database with both engineers' estimates and
actual costs. For the sites, 12 of the engineers' estimates overestimated the actual costs whereas
only 7 of the estimates underestimated the actual costs. Only 40 percent of the engineers' cost
estimates fell within the targeted range of +15/-5 percent, although the average difference was
only 2 percent, which is well within the range.
Figure 4 presents a plot of the absolute value of the difference between the engineers' estimate and
the actual RA cost vs the cost of the RA. This figure indicates that the accuracy of the engineers'
estimates increases with the cost of the RA, on a percentage basis. This is the opposite of the
trend found in a study conducted by the U.S. Army Corps of Engineers (COE) but is the same
trend that was noted for the ROD estimates in this study. If Figure 4 is compared to Figure 2, it
can be seen that the engineers' estimates are much closer to the actual RA costs than the ROD
estimates are. So although less than half of the engineers' estimates are falling within the target
range, the estimates are generally closer to the final RA costs than the ROD estimates are.
Table 4 lists the technologies used for the RAs with the percent difference between the engineers'
estimates and actual RA costs. Unlike the ROD estimates, there does not appear to be any
relationship between the technologies used for the RAs and the accuracy of the engineers'
estimates.
Award Bids vs Actual Costs
Figure 5 shows a plot of the percent difference between the ROD estimate, the engineers' estimate,
the award contractor's bid, and the actual cost of the RAs for 25 of the sites in the database. This
figure shows that the ROD estimates are the furthest from the actual RA costs and that the
engineers' estimates and the award bids fall within the same range of the actual costs. However,
whereas the engineers' estimates on the average overestimated the actual cost by 2 percent, the
award bids underestimated the costs by 7 percent. The change orders had a range of -$1.5 million
421
-------
to $5.0 million for a total of $13.3 million for the 25 sites investigated. This includes the 4 sites
which had negative change orders. According to the EPA and Army Corps of Engineers (ACE)
sources who provided the change order data, the major source of these change orders was an
increase in the amount of contamination that required remediation.
Figure 6 illustrates the spread of the contractor's bids received for the RAs. To account for the
large range in the size of the projects, the bids for the sites have been plotted onto 3 graph: one
for sites with bids less than $2 million, one for sites with bids between $2 and $20 million, and one
for sites with bids greater than $20 million. As can be seen in the figure, there is a large spread
in the contractor's bids received for each RA. In general, the highest bid was much greater than
the next most expensive bid, while the low bid was fairly close to the second and third lowest bids.
The low bids are the closest to the actual costs and the high bids are the furthest. The high bids
are, on the average, 48 percent greater than the actual costs of the RAs. The average ratio of the
high bid to the low bid was 1.7 to 1.
CONCLUSIONS
The conclusions that can be drawn from the above discussion of the information in the bid tabs
database include:
A majority of the ROD estimates are within +50/-30 percent of the actual cost of
the RA. Therefore the ROD estimating tools appear to be operating as anticipated.
For these limited data, the ROD estimates for alternative drinking water RAs
consistently overestimated the actual RA cost and the water treatment RAs
underestimated the actual costs. These trends may have implications for remedy
selection at the ROD stage.
Less than half of the engineer's cost estimates are within the target range of +15/-5
percent of the actual RA cost, although the average difference is only 2 percent.
The accuracy of the ROD and engineer's estimates increases with the size of the
RA, on a percentage basis.
The change orders for the sites in the database ranged from -$1.5 million to $5.0
million per site and were due to changes in conditions from the RI/FS data.
The average ratio of the high bid to the low bid was 1.7 to 1 and the largest ratio
was 4.6 to 1.
REFERENCES
Hazardous and Toxic Waste (HTW) Contracting Problems: A Study of the Contracting Problems
Related to Surety Bonding in the HTW Cleanup Program. U.S. Army Corps of Engineers, Water
Resources Support Center, IWR Report 90-R-l. July 1990.
422
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Table 1
SUMMARY OF RA COST INFORMATION IN DATABASE
Page 4 of 4
Site
Baird & McGuire
Cannon Engineer
Charles George If
Nyanza Chemical
W. Sand & Gravel
Bog Creek Farm
Brewster Uellfield
Bridgeport Rental
Ca I dwell Trucking
Glen Ridge Radium
Haviland Complex
Helen Kramer LF
Lang Property
Met a I tec/Aerosys .
Vestal Water Sup.
Wide Beach Devel.
Aladdin Plating
Blosenski LF
Bruin Lagoon
Croydon TCE Spi 1 1
DE Sand & Gravel
RA CONSTRUCTION COSTS ($1,000)
ROD Estimate
$5,862
$210
$13,613
$11,545
$1,380
$6,927
$532
$57,672
$269
$98
$37,525
$2,322
$2,919
$389
$8,795
$4,461
$2,711
$53
$830
Engineer's
Estimate
$9,404
$319
$14,986
$12,884
$1,056
$14,391
$41,455
$233
$169
$35,998
$4,125
$3,490
$1.126
$15,573
$1,106
$4,998
$1,215
Lou Bid
$10,528
$114
$15,567
$8,565
$879
$12,407
$569
$52,456
$199
$146
$183
$55,679
$2,709
$2,401
$852
$15,500
$7,734
$1,100
$3,982
$48
$1,519
2nd Low Bid
$11,737
$307
$16,490
$10,332
$925
$14,241
$733
$56,799
$228
$166
$61,951
$2,946
$2,741
$865
$8,865
$1,137
$5,299
$52
$2,395
3rd Lou Bid
$12,545
$421
$18,440
$11,239
$994
$14,666
$781
$61,815
$230
$434
$73,899
$3,480
$3,377
$1,162
$7,025
Highest Bid
$18,330
$421
$23,320
$14,199
$1,275
$14,666
$1,032
$84,984
$915
$434
$183
$73,899
$4,680
$7,518
$865
$15,500
$8,865
$1,484
$9,474
$52
$2,395
Actual
$975
$245
$3,775
$3,316
$863
$11,000
$1,653
$36
ro
CO
-------
Table 1
SIMWRY OF RA COST INFORMATION IN DATABASE
Page 5 of 4
Site
Kane & Lombard
Lackawanna Refuse
Moyers Landfill
S. MD Wood
Davie LF
Hoi I ings worth
Miami Drum Service
Cemetery Dump
Lake Sandy Jo LF
LaSalle Electrical
Metamora LF
New Lyme LF
Old Mill
Verona Uellfield
Bayou Bonfouca
Bio-Ecology Sys.
Cecil Lindsey
Crystal City
Geneva Industries
Odessa Chromium I
Odessa Chromium II
RA CONSTRUCTION COSTS ($1.000)
ROD Estimate
$4,692
$3,000
$1,017
$1.883
$4,230
$34,495
$12,000
$10,842
$3,920
$2,497
$29
$1,600
$14,992
$247
$476
Engineer's
Estimate
$3,989
$23,210
$26,828
$1,964
$2,337
$34,495
$12,112
$5,719
$1,147
$3,695
$5,814
$22
$1,091
$22,526
$247
$476
Low Bid
$4,542
$15.902
$28,527
$2,599
$1,496
$706
$16,328
$3,148
$2,398
$17,605
$14,295
$13,748
$4,486
$1,098
$3,989
$3,789
$19
$1,080
$16,135
$170
$389
2nd Low Bid
$17,000
$31 ,476
$2,925
$1,573
$934
$16,791
$3,277
$3,039
$25.158
$13.845
$4,544
$1,180
$5.504
$4.997
$25
$1,438
$16, 169
$173
$416
3rd Low Bid
$19,286
$32,355
$2,962
$1,589
$19,886
$3,645
$3,891
$27.131
$15,572
$4,594
$1 ,633
$5,086
$26
$1,465
$17.384
$181
$478
Highest Bid
$4,542
$40,378
$33,891
$3,385
$2,680
$934
$19,886
$4,254
$3,891
$39,866
$14,295
$18,544
$7,476
$1.633
$5,504
$5,086
$26
$2,241
$29,831
$244
$601
Actual
$3,300
$2,104
$1,700
$2,640
$15,077
$4,856
$5,289
$19
$1,228
$21,093
$170
$389
-------
Table 1
SUMMRY OF RA COST INFORtMTION IN DATABASE
Page 6 of 4
Site
Old Inger
Old Midland
Petro-Chem. Sys
Sikes Disposal
Cherokee County
As Trio Lidgerwood
As Trio Wyndmere
Clear Creek
RA CONSTRUCTION COSTS ($1.000)
ROD Estimate
$3,062
$11,700
$796
$102,217
$3,200
$76
Engineer's
Estimate
$2,058
$94,529
$679
$371
$176
$121
Low Bid
$4,739
$13,871
$1,690
$89,949
$632
$302
$194
$211
2nd Low Bid
$6,782
$16,376
$1,998
$95,440
$724
$337
$202
$482
3rd Low Bid
$7,487
$19,199
$2,301
$95,899
$351
$208
Highest Bid
$8,384
$19,682
$3,169
$98,380
$724
$380
$233
$482
Actual
$5,039
$1,717
$321
$209
fO
cn
-------
Table 1
SUMMARY OF RA COST INFORMATION IN DATABASE
Page 7 of 4
Site
San Gabriel Area 1
United Chrome
RA CONSTRUCTION COSTS (SI, 000)
ROD Estimate
$1,580
Engineer's
Estimate
$850
$805
Lou Bid
$752
$751
2nd Low Bid
$800
$1,071
3rd Lou Bid
$831
$1,101
Highest Bid
$879
$1,154
Actual
$1 ,349
ro
-------
Table 2
RA TECHNOLOGIES IN BID TAB DATABASE
Adsorption
Air Stripping
Alternative Drinking Water Source
Capping
Dechlorination
Demolition
Drum & Debris Removal
Excavation
Extraction
Filtration
Gas Ventilation
Groundwater Recharge
Groundwater Reinjection
Groundwater Collection
Incineration
Landfill Gas Collection
Landfilling
Leachate Collection
Monitoring
Off-site Disposal
Oil-Water Separation
Precipitation
Pumping
Regrading
Reverse Osmosis
Sheet Piling
Slurry Wall
Soil Vapor Extraction
Solidification
Solids Dewatering
Solvent Extraction
Stabilization
Steam Cleaning
Subsurface Drains
Surface Controls
Thermal Treatment
427
-------
lOOx (ROD Estimate - Actual Cost)/Actual Cost
W Sand & Gravel
Caldwell Trucking
Lang Property
Metaltec
Vestal Water Supply
Alladin Plating
Croydon TCE
Davie LF
Cemetery Dump
Lake Sandy Jo
New Lyme
Old Mill
Bioecology
Cecil Lindsey
Geneva Ind.
Odessa Cr I
Odessa Cr II
Old Inger
Petrochem
United Cr
428
-------
Figure 2: ACCURACY OF ROD ESTIMATE VS RA COST
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Actual RA Cost, million $
429
-------
Table 3
ACCURACY OF ROD ESTIMATES VS RA TECHNOLOGY USED
Technology
Site
Accuracy of
ROD Estimate
Alternative Drinking Water Sup-
piy
Western Sand
Caldwell Trucking
Croydon TCE Spill
Odessa Chromium I
Odessa Chromium II
42
10
46
46
22
Soil Treatment/
Landfilling
Lang Property
Metaltec
Alladin Plating
Davie Landfill
Cemetery Dump
Lake Sandy Jo
Old Mill
Bioecology Systems
Crystal City
Cecil Lindsey
Geneva Industries
Old Inger
Petrochemical Systems
United Chrome
-38
-12
-59
43
11
60
-19
-53
30
48
-29
-39
-54
17
Water Treatment
Vestal Water Supply
New Lyme Landfill
Old Mill
Bioecology Systems
Geneva Industries
Old Inger
-55
-28
-29
-19
-53
-39
430
-------
[(Engineer's Estimate - Actual Cost)/Actual Cost] x 100
W Sand & Gravel
Caldwell Trucking
Lang Property
Metaltec
Vestal Water Supply
Blosenski LF
Lake Sandy Jo
New Lyme
Old Mill
Bioecology
Cecil Lindsey
Crystal City
Geneva Ind.
Odessa Cr I
Odessa Cr II
Petrochem
Lidgerwood
Wyndmere
United Cr
431
-------
Figure 4: ACCURACY OF ENGINEER'S ESTIMATE VS RA COST
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Actual RA Cost, million $
432
-------
Table 4
ACCURACY OF ENGINNERS' ESTIMATES VS RA TECHNOLOGY USED
Technology
Alternative Drinking Water
Supply
Soil Treatment/
Landfilling
Water Treatment
Site
Western Sand
Caldwell Trucking
Blosenski Landfill
Odessa Chromium I
Odessa Chromium II
Lang Property
Metaltec
Lake Sandy Jo
Old Mill
Bioecology Systems
Crystal City
Cecil Lindsey
Petrochemical Systems
United Chrome
Vestal Water Supply
S. Maryland Wood
New Lyme Landfill
Old Mill
Bioecology Systems
Geneva Industries
Lidgerwood
Wyndmere
Accuracy of Engine-
ers' Estimate (%)
8
-5
-33
46
22
9
5
-11
18
10
-11
13
20
-40
31
-40
-20
18
10
7
15
-16
433
-------
Percentage Dlfference.%
01
o
Caldwell Taicking
Lang Property
Metaltec
Alladin Plating
Blosenski LF
S. MDWood
New Lyme
Bioecology
Crystal City
Geneva Ind.
Old Inger
Wyndmere
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-------
Percentage Difference, %
W Sand & Gravel
Vestal Water Supply
Croydon TCE
Davie LF
Cemetery Dump
Lake Sandy Jo
Old Mill
Cecil Lindsey
Odessa CrI
Odessa Cr II
Petrochem
Lidgerwood
United Cr
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Bids, $1,000
Cannon
W. Sand & Gravel
Brewster Wei!
Caldwell Truck
Glen Ridge Rad.
Vestal Water
Blosenski Lf
Cecil Lidsey
Miami Drum
Odessa Cr
Lidgerwood
Wyndmere
Clear Creek
San Gabriel
United Cr
Geneva Industries
Bayou Bonfouca
Old Inger
436
-------
Bids, $1,000
Baird & McGuire
Nyanza Chem
Bog Creek
Lang Property
Metaltec
Alladin Plating
DE Sand & Gravel
Kane & Lombard
Davie Lf
Lake Sandy Jo
LaSalle Electric
Old Mill
Verona Wellfield
Bioecology Sys
Crystal City
Old Midland
Petrochem
Sikes
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Bids, $1,000
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Cherokee Co.
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Charles George Lf
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RAC To PRP
The Thin Gray Line
Philip D. Kessack, Esq.
Ronald N. Stewart, Esq.
ICF International, Inc.
9300 Lee Highway
Fairfax, Virginia 22031
(703) 934-3964
(703) 934-3631
DISCLAIMER
The following paper represents only the opinions of the authors and does not necessarily represent
the opinion, policy or analysis of ICF International, Inc., or its affiliated companies.
It should also be stressed that this paper only addresses the potential CERCLA liability of
Response Action contractors who are performing Response Action activities under EPA contracts.
It does NOT address the many additional liabilities that may apply to response activities provided
on behalf of other Federal agencies or other public and private sector entities.
Finally, this paper is not intended to provide legal advice to the reader. The state of case law
relating to the issues set forth in this paper is rapidly evolving and the reader should check with
appropriate legal counsel with regard to any legal issues addressed herein.
INTRODUCTION
One of our military's major concerns during Operation Desert Storm was the danger posed by land
mines placed between our troops and their objectives. Our field commanders could have taken
the attitude: "Hey, war's a risky business. If you're going to get into the business, you're going to
have to take the risk." But they didn't. Recognizing that the land mines constituted a dangerous
threat, they took the time to evaluate and quantify the threat and then devised a broad range of
countermeasures to minimize the risks. And they were successful!
Like the soldiers and Marines confronting the minefields, the response action contractor ("RAC")
is engaged in an inherently risky enterprise. And as with our soldiers and Marines, it is not
enough to simply say "Hey, its a risky business." The United States Environmental Protection
Agency ("EPA") and RACs must take time to evaluate and quantify the risks associated with
response actions and develop appropriate safeguards to ensure that EPA has access to a sufficient
number of qualified RACs to perform its CERCLA responsibilities in an effective and cost
efficient manner.
RACs must address the inherent risks associated with remediating hazardous substances releases
on two conceptual levels. The first level involves protection of personnel, equipment and business
viability from risks typically associated with traditional engineering services. This is normally
provided through: (1) ongoing safety and technical programs to ensure that personnel are properly
trained, (2) preventative maintenance and periodic inspections to ensure that equipment is in good
working order, (3) clearly defined operating procedures and QA/QC crosschecks to ensure that
procedures are being fully implemented, and (4) standard commercial insurance coverages.
439
-------
The second level involves potential liability for environmental claims by third parties arising out
of hazardous substance releases or associated response action activities. This second level of
liability is more difficult to manage because it is almost impossible for RACs to quantify and
evaluate such risks in the current legal and regulatory situation. The environmental engineering
field is relatively new and many of the procedures and technologies used to characterize arid
measure hazardous substances are risky and unproven. The health risks associated with many
hazardous substances are still unknown. Insurance to cover RAC liability risks is difficult to
obtain, very expensive, and typically excludes coverage relating to pollution releases.1 Many
environmental statutes and regulations are vague and conflicting, making it difficult for the RAC
to quantify and evaluate the potential liabilities to which it may be exposed in performing
remediations.
It is this second level of risk, relating to potential third party claims for damage resulting from a
pollution release, that is addressed in this paper. More specifically, the focus will be on risks
associated with RACs' arranging for the transportation and disposal of removed or remediated
hazardous substances under CERCLA in support of EPA response action contracts.
First, the legal liabilities associated with disposal of removed and remediated hazardous substances
will be examined. Second, the special status of RACs will be examined within the context of
CERCLA liability. Third, the legal risks to RACs who become involved in the decision-making
process relating to the transportation and disposal of hazardous substances will be evaluated.
Finally, specific recommendations will be made with regard to actions to more effectively
quantify and evaluate the risks faced by contractors performing CERCLA remediation for EPA,
with a view toward ensuring that EPA can continue to obtain such services on a cost-effective
basis.
BACKGROUND
CERCLA2 was enacted in 1980 in response to the dangers posed by the sudden or otherwise
uncontrolled release of hazardous substances, pollution and contaminants into the environment
from abandoned dumps, unregulated landfills and other facilities not covered by the Solid Waste
Disposal Act of 19653 ("SWDA"), as amended by the Resource Conservation and Recovery Act of
19764 ("RCRA"), and other federal environmental statutes.5 CERCLA provides a federal
statutory framework for identifying, evaluating, and remediating polluted sites and for allocating
the responsibility for payment of the associated costs of such response actions. EPA has been
given the primary regulatory authority for the implementation of CERCLA.6
CERCLA authorizes EPA to initiate removal7 and remedial action8 whenever there is a release
or substantial threat of release of a "hazardous substance" into the environment or whenever there
is a release or threat of a release of a "pollutant" or "contaminant" that may cause an imminent and
substantial danger to public health.9 In performing its functions under CERCLA, EPA has
contracted with private sector engineering and construction firms to obtain assistance in
performing these response actions. In an effort to improve efficiency and reduce the
administrative burden on EPA employees, at least one EPA Region appears to be attempting to
shift responsibility for arranging for disposal of hazardous substances to RACs under EPA
contracts such as the Alternative Remedial Contracts Strategy or "ARCS".10 Since the
CERCLA-related liabilities associated with the transportation and disposal of hazardous
substances can be substantial, there is are important issues as to whether this proposed shift in
responsibility could result in a substantial increase in potential liabilities for RACs and whether
such a shift in liability is consistent with Congressional intent to limit the CERCLA liability of
RACs that provide environmental clean-up services. This is an example of the types of issues
with which this paper will be most concerned.
440
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DISCUSSION
Ai The Concept of Potentially Responsible Parties
JU Legislative History
One of the fundamental premises underlying CERCLA is that the parties who commercially
benefit from activities that lead to releases or threatened releases of pollution should bear
responsibility for the costs of these releases.11 This is reflected in the legislative history of
CERCLA. As stated by the Senate Committee on Environment and Public Works:
The goal of assuring that those who caused the chemical harm bear the cost of that
harm is addressed in [S. 1480] by the imposition of liability. Strict liability, the
foundation of S. 1480, assures that those who benefit financially from a commercial
activity internalize the health and environmental costs of that activity into the cost
of doing business. Strict liability is an important instrument in allocating the risks
imposed upon society by the manufacture, use, and disposal of inherently
hazardous substances ....
To establish provisions of liability any less than strict, joint, and several liability
would be to condone a system in which innocent victims bear the burdens of
releases, while those who conduct commerce in hazardous substances which cause
such damage benefit with relative impunity.12 (emphasis added)
The Congressional debates on CERCLA further expanded on this point. As noted in Ohio v.
Georgeoff;.
EPA argued that "society should not bear the cost of protecting the public from
hazards produced in the past by a generator, transporter, consumer, or dump site
owner-operator who has profited or otherwise benefitted from commerce involving
these substances and now wishes to be insulated from any continuing
responsibilities for the present hazards to society that have been created ....
[Relieving industry of responsibility establishes a precedent seriously adverse to
the public interest " S. Rep. No. 848, 96th Cong., 2d Sess. 98 (1980). On the
Senate floor, Senator Chaffee stated that "governments must have a tool for holding
liable those who are responsible for those costs." Cong. Rec. S 15,003 (daily ed.
Nov. 24, 1980). See also, id. S.14,971 (remarks of Sen. Tsongas); id. at S.14,971-72
(remarks of Sen. Bradley); Cong. Rec. H 11,799 (daily ed. Dec. 3, 1980) (remarks
of Rep. Jeffords).13
Subsequent cases have reaffirmed this goal of holding those who commercially benefit responsible
for any losses resulting from their commerce in hazardous substances. As noted in United States
v. Aceto Agricultural Chemicals Corp., "CERCLA places the ultimate responsibility for cleanup on
'those responsible for problems caused by the disposal of chemical poisons.'"14
2j. CERCLA Classification of Potentially Responsible Parties
To accomplish the goal of holding those who benefit financially from certain activities
accountable for any environmentally-related losses associated with those activities, CERCLA
section 107(a) provides four categories of activities that cause the party conducting the activity to
automatically become a potentially responsible party ("PRP")15 and strictly liable under
CERCLA. These categories are:
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(1) the owner and operator of a vessel or a facility,
(2) any person who at the time of disposal of any hazardous substance owned or operated any
facility at which such hazardous substances were disposed of,
(3) any person who by contract, agreement or otherwise arranged for disposal or treatment, or
arranged with a transporter for transport for disposal or treatment, of hazardous substances owned
or possessed by such person, by any other party or entity, at any facility or incineration vessel
owned or operated by another party or entity and containing such hazardous substances, and
(4) any person who accepts or accepted any hazardous substances for transport to disposal or
treatment facilities, incineration vessels or sites selected by such person, from which there is a
release, or threatened release which causes the incurrence of response costs, of a hazardous
substance . . . . 16 (emphasis added)
3.. Owners and Operators
The first two categories in section 107(a) relate to the "owner and operator" (section 107(a)(l)) and
the "owner or operator" (section 107(a)(2)), respectively, of any "facility."17 "Owner or operator"
is defined (in part) in section 101(20)(a)(ii) as "[A]ny person owning or operating ... [a] facility . .
. ,"18 Facility is defined (in part) in section 101(9)(B) as "[A]ny site or area where a hazardous
substance has been deposited, stored, disposed or, or placed, or otherwise come to be located . . .
,"19 In addition to these rather broad statutory definitions, the terms "owner or operator" and
"facility" have also been liberally construed by the courts in accordance with CERCLA's remedial
intent.20
The two status categories set forth in sections 107(a)(l)-(2) essentially focus on "generators" of the
released hazardous substance.21 Although "generator" is a RCRA term of art, it is also
frequently applied as a generic term to anyone who has commercially benefitted in connection
with the hazardous substances involved in the "release" event.22 Under sections 107(a)(!)-(2),
liability attaches to anyone who owned or operated the facility at the time of the "disposal,"23 as
well as anyone who currently owns or operates the facility.24
The RAC liability issues discussed in this paper focus on the remaining two section 107(a) PRP
categories: (1) those who arrange for transportation of hazardous substances for treatment and/or
disposal and (2) those who actually transport such hazardous substances to a treatment/disposal
facility that they selected.
4i Persons Who Arrange for Transport for Treatment and/or Disposal
It is critical that response contractors and other persons who perform environmental clean-up
work under EPA contracts understand the elements and implications of section 107(a)(3) in order
to gauge their potential liability under CERCLA. Response contractors are frequently asked to
perform projects on a "turnkey" basis. Where this responsibility includes making the decisions
regarding the arrangements for the transportation and disposal of hazardous substances, unwary
response contractors may inadvertently be assuming a dramatic increase in liability risk under
CERCLA without sufficient offsetting compensation.
Under section 107(a)(3), "covered persons" (i.e., potentially responsible parties or "PRPs") include:
[A]ny person who by contract, agreement or otherwise arranged for disposal or
treatment, or arranged with a transporter for transport for disposal or treatment, of
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hazardous substances owned or possessed by such person, by any other party or
entity, at any facility or incineration vessel owned or operated by another party or
entity and containing such hazardous substances . . . ,25 (emphasis added)
The District Court in United States v. Ward enumerated the requirements for a prima facie finding
of CERCLA liability under section 107(a)(3) as follows:
In order to establish liability under section 107(a)(3) the government must prove:
(a) the defendant was a person within the meaning of the statute; (b) he owned or
possessed hazardous substances; (c) he, by contract, agreement or otherwise,
arranged for disposal or treatment, or arranged with a transporter for transport for
disposal or treatment of those substances at a facility; (d) there was a release or
threatened release of a hazardous substance at the site; (e) the release or threatened
release caused the incurrence of response cost.26
As set forth in Ward, the first element in establishing section 107(a)(3) status is whether the party
sought to held liable is a "person" as defined by CERCLA. Section 101(21) broadly defines
"person" to include an "[Individual, firm, corporation, association, partnership, consortium, joint
venture, commercial entity, United States Government, State, municipality, commission, political
subdivision of a state, or any interstate body."27 There would appear to be little which falls
outside of this definition.
The second element is that the person who arranged for disposal must have "owned or possessed"
the hazardous substances for which disposal was arranged. At first glance, this would appear to
protect a response contractor since it could argue that it did not own or possess the hazardous
substances at the time that it arranged for their disposal (i.e., the hazardous substances were still
"owned or possessed" by the client - either EPA or the PRP). In fact, some early cases seemed to
indicate that actual ownership or possession of hazardous substances was required to meet the
section 107(a)(3) liability requirements.28
However, in United States v. Northeastern Pharmaceutical & Chemical Company, Inc.
("NEPACCO"), the court made it clear that it was willing to impose "constructive" ownership or
possession on those parties who had "the authority to control the handling and disposal of
hazardous substances that is critical under the statutory scheme."29 Other courts have
subsequently followed the NEPACCO court in applying the concept of constructive ownership or
possession.30
Note that under the third element in Ward, there need not have been a written contract. To
become a PRP under section 107(a)(3), one need only perform any of the activities set forth in
that section.31
Under the third element set forth in Ward, the person must also "arrange" for disposal or treatment
or arrange for transportation of the hazardous substance for disposal or treatment. The term
"arrange" is not expressly defined in CERCLA, nor is there any significant legislative history on
the definition of this critical term.32 Despite the relative lack of legislative history on this point,
the courts have concluded that a liberal judicial interpretation of "arrange" is fully consistent with
CERCLA's "overwhelmingly remedial" statutory scheme.33
The remaining part of the third element of section 107(a)(3) liability in Ward is that the hazardous
substances must have been transported to a "facility." As noted previously, this term is so broadly
defined in CERCLA that almost any arrangement which is made will involve transportation to a
"facility."
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The fourth element in Ward is a determination that the type of hazardous substance found at the
facility at the time of the release or threatened release is the same as that which was disposed of
by the PRP. Once the same type of hazardous substance is identified at the site, the burden of
proof shifts to the PRP to establish that the hazardous substance was not part of the PRP's original
disposal. Courts have construed section 107(a)(3) so as to make this an extremely difficult burden
for defendants. The PRP must, in effect, account for 100% of its hazardous substances which
were alleged to have been disposed of at the site in order to demonstrate that its hazardous
substances were not a part of the release which is the subject of the CERCLA action.34
Finally, the Government must prove that there was a release or threatened release of a hazardous
substance from the disposal site and that the release "causes" the incurrence of response costs. "
While the hazardous substance at the site must be the same kind as that which the allfeged PRP
disposed of, it need not be specifically identified as a part of the actual release.35
The Ward court did not allude to the additional express CERCLA requirement that the facility
from which the release occurred be "owned or operated by another party."36 (This element was
not applicable to the facts involved in the Ward case.) The "other party" owner/operator element
could be critical, however, under certain circumstances. For example, if the contractor merely
moves a hazardous substance from one location to another, both of which are owned and operated
by the same person, this activity would arguably be excluded from potential strict liability under
section 107(a)(3) despite the fact that the contractor made the decision as to where to move the
hazardous substances for the purpose of treatment or disposal.37 The logic behind this
exemption is that since the contractor is not moving the hazardous substances out of the ultimate
control of the owner or operator, it should not be linked to the liability that would normally be
associated with such a decision. (The "other party or entity" criteria would not have been met.)
5. Transporters of Hazardous Substances
Section 107(a)(4) focuses on those who transport hazardous substances: "[A]ny person who accepts
or accepted any hazardous substance for transport to disposal or treatment facilities, incineration
vessels or sites selected by such person, from which there is a release, or a threatened release which
causes the incurrence of response costs, of a hazardous substance . . . ,"38 (emphasis added)
To be liable under section 107(a)(4), the transporter must:
• be a "person"
• who accepted hazardous substances for transport
• to a disposal or treatment facility selected by the transporter
• from which there is a release or threatened release.
As noted previously, since section 101(21) broadly defines "person" to include essentially all types
of business entities, the transporter will normally be a "person" within the meaning of CERCLA.
The transporter must also "accept" the hazardous substances for the purpose of transporting to a
disposal or treatment facility. (This is a factual issue."*
The third element of section 107(a)(4) liability is trai. • 'in of the hazardous substance to a
disposal or treatment facility. Section 101(26) broadly defines "transport" as "[T]he movement of a
hazardous substance by any mode . . . ." and includes common and contract carriers.39 As noted
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in section 101(29), the terms "disposal" and "treatment" are given the meaning provided in SWDA
section 1004.40 Under SWDA section 1004(3), the term "disposal" is broadly defined to include
spilling, leaking and other discharges.41 Under SWDA section 1004(30), the term "treatment" is
also broadly defined to include "any method" to change the "physical, chemical, or biological
character or composition" of the hazardous material or render it nonhazardous.42 (As noted
earlier, the term "facility" is broadly construed to include almost any location to which the
hazardous substance has been moved.)
Note that under section 107(a)(4), the treatment or disposal site must be "selected" by the
transporter. A transporter is generally not liable during the transport phase for any release of
hazardous substances which is beyond its control43 or for any subsequent release from the
facility to which the hazardous substances have been shipped.44 In fact, section 306(b) expressly
exempts the transporter from any liability under section 107(a) so long as:
(1) it has not selected the disposal site, (2) it is not otherwise a PRP related to the hazardous
substances involved, and (3) the release has occurred subsequent to actual delivery at the
facility.45 By selecting the disposal site, however, the transporter is likely to acquire PRP status
under section 107(a)(4). As stated in United States, v. New Castle County:
The conduct which justifies the imposition of liability is the transportation to a
facility that the transporter itself selected, presumably on the theory that such a
party has actively involved itself in the process of storing or disposing of hazardous
substances and should be made to share the cost of any resulting harm to the
environment. A common carrier that merely delivers the substances to a location
selected by another is not liable for releases at the facility, but is liable for any
releases occurring during the period of transportation. 2 S. Cooke, The Law of
Hazardous Wastes at section 14.01[5][e] at 14-93. [n.47]
NOTE 47: It is generally accepted that, in order to find liability as a transporter
under section 107(a)(4) of CERCLA, there must be a finding that the site was
selected by the transporter. See generally Jersey City Redevelopment Authority v.
PPG Indus. 18 Envt'l L. Rep. 20364-20366 (D.N.J. 1987).46 (emphasis added)
By the mere act of selecting the treatment/disposal facility, therefore, the transporter can
dramatically increase its potential liability under CERCLA.
The final element - whether there was a release or threatened release of hazardous substances
from the selected treatment or disposal facility - is a question of fact.
IL The Standard of Liability for PRPs
L. Strict Liability
Courts have generally agreed that the standard of liability under CERCLA is "strict liability" even
though this is not expressly stated in the statute.47 Under the CERCLA strict liability scheme,
anyone who engages in an activity which the statute proscribes under section 107 is liable even
though no negligence or intentional misconduct is involved - i.e., liability attaches without regard
to fault or intent. In so holding, the courts have relied to a large extent on the legislative history
of CERCLA, which contains numerous references calling for strict liability.48 As stated in a
Senate Committee Report:
In some of these cases the choice is not between an innocent victim and a careless
defendant, but between two blameless parties. In such cases, the costs should be
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borne by the one of the two innocent parties whose acts instigated or made the
harm possible.49
It is clear that the drafters of CERCLA intended that the strict liability standard of section 311 of
the Clean Water Act be applied to establish the standard for liability under CERCLA.50 Section
101(32) refers to the "standard of liability" under section 311 of the Clean Water Act,51 which
has been interpreted by the courts as imposing a strict liability standard.52
The fact that the drafters clearly limited the available statutory defenses under CERCLA in
section 107(b) further indicates that they intended that a standard of strict liability should apply to
CERCLA.53 Further, legislative affirmation of the strict liability interpretation can be inferred
from the fact that Congress left the liability provisions essentially unchanged under the SARA
amendments (with the exception of providing limited relief for RACs under certain defined.
circumstances).54
2. Joint and Several Liability
It is also now generally agreed that, although CERCLA does not expressly so provide, liability
under CERCLA section 107 will be deemed to be "joint and several."55 The theory underlying
the legal concept of "joint and several liability" is essentially that the courts have recognized that
there may be times when several parties may have jointly contributed to a loss as part of a
common endeavor. Rather than place the burden on the injured party to determine which party
caused a defined part of the loss, the injured party may bring an action against one or all of the
other parties for the full amount of the claim. This has the effect of shifting the burden of
identifying the other parties to the common endeavor and allocating the relative shares of the loss
to the defendants who are generally in a better position to make those determinations.56
The Department of Justice position on this issue is consistent with the common law approach that
joint and several liability applies whenever the acts of two or more persons combine to produce an
"indivisible" harm.57 The application of a common law approach to CERCLA section 107
liability was clearly intended by the drafters of CERCLA.58
The courts which have considered this issue have generally taken the position that joint and
several liability is appropriate,59 unless there is some reasonable basis for dividing the harm to
apportion the contribution of each party.60 One court rejected a defendant's suggestion of
apportionment based solely on volume, noting that this approach was "arbitrary" since the
offending wastes had been commingled at the site.61 Another court adopted the apportionment
scheme62 contained in the original House CERCLA bill63 which apportioned the damages
based on the following criteria:
• The ability of the parties to demonstrate that their contribution to a discharge, release, or
disposal of a hazardous waste can be distinguished.
• The amount of hazardous waste involved.
• The degree of toxicity of the hazardous waste involved.
• The degree of involvement by the parties in the generation, transportation, treatment,
storage, or disposal of the hazardous waste.
• The degree of care exercised by the parties with respect to the hazardous waste concerned,
taking into account the characteristics of such hazardous waste.
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• the degree of cooperation by the parties with federal, state, or local officials to prevent
any harm to the public health or the environment.64
The NEPACCO court, noting that both the language of CERCLA and its legislative history were
not entirely clear on the issue of joint and several liability,65 essentially endorsed this approach
and decided the issue of joint and several liability on the "facts of the case" (finding liability to be
joint and several since the harm was "indivisible").66 Once a PRP has been linked with a
CERCLA site, however, the burden of proof shifts to the defendant to establish that there is a
reasonable basis for apportionment of the response cost.67
3. Right of Contribution
The legal concept of "contribution"68 means that a party who has been found liable for the cost
associated with a loss has the right to bring a legal action against other parties who had
contributed to that loss in order to recover the cost associated with the portion of the loss caused
by those other parties. Although CERCLA did not originally provide an express right of
contribution, numerous provisions within the statute are indicative of the legislative intent that
such a right was meant to exist under CERCLA.69 For example, sections 107(i)-(j)70 expressly
retain "common law rights" and section 107(e)(2)71 preserves any rights of action which liable
parties may have based on "subrogation72 or otherwise against any other person." Sections
lll(a)(2) and 112(a)73 also allow suits under section 107 to recover response costs incurred "by
any other person . . . ,"74 Further, section 112(c)(2) specifically provides rights of subrogration
to the Government, "the Fund" and to any person paying claims for damages under CERCLA in
connection with a release of hazardous substances.75
Prior to 1986, many courts also held that parties who were liable under CERCLA had a right to
contribution from other responsible parties.76 The 1986 SARA amendments expressly provided
a right to contribution from any person who is liable or potentially liable under section 107.77
4. Retroactive Liability
Defendants in CERCLA cases have argued that its "retroactive" effects in the imposition of
liability violate the due process requirements of the Constitution. These arguments have been
rejected by the courts.78 In NEPACCO, the court held that sections 104 and 107(a) of CERCLA
were intended to apply retroactively and that, therefore, these provisions were presumed to be
constitutional.79
CERCLA section 106 orders have also been attacked as unconstitutional on the grounds that they
impose liability for conduct that occurred before CERCLA was enacted, in violation of
constitutional due process requirements. This argument has also been consistently rejected by the
courts.80
Qi Statutory Defenses to PRP Liability
Consistent with Congressional intent to hold those persons who commercially benefit from
activities involving hazardous substances responsible on a strict liability basis, section 107(a)
expressly limits PRP defenses. Under section 107(a), liability is "subject only to the defenses set
forth in subsection (b) of this section . . . ."81 (emphasis added) Section 107(b) provides:
There shall be no liability under subsection (a) of this section for a person
otherwise liable who can establish by a preponderance of the evidence that the
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release or threat of release of a hazardous substance and the damages resulting
therefrom were caused solely by-
(1) an act of God;
(2) an act of war;
(3) an act or omission of a third party other than an employee or agent of the
defendant, or than one whose act or omission occurs in connection with a contractual
relationship, existing directly or indirectly, with the defendant (except where the
sole contractual relationship arises from a published tariff and acceptance for
carriage by a common carrier by rail), if the defendant establishes by a
preponderance of the evidence that
(a) he exercised due care with respect to the hazardous substance concerned, taking ' •
into consideration the characteristics of such hazardous substance, in light of all
relevant facts and circumstances, and (b) he took precautions against foreseeable
acts or omissions of any such third party and the consequences that could
foreseeably result from such acts or omissions; or
(4) any combination of the foregoing paragraphs.82 (emphasis added)
Note that in order to assert one of the section 107(b) defenses, the PRP must establish that the
release or threatened release of the hazardous substances resulted solely from one or more of the
events listed in that section. If the PRP is even partially responsible for the release, it is
precluded from asserting any of the section 107(b) defenses.
The statutory defenses under section 107(b) are narrowly construed by the courts.83 Since these
are "defenses" which would only come into play after PRP liability had been established on a
prima facie basis, the burden of proving their existence and applicability falls on the PRP.
Not only must the release have been caused solely by a third party who is not an employee, agent
or contractor of the PRP, but also the PRP must have exercised reasonable care under the specific
circumstances surrounding the release and taken precautions against the foreseeable acts of third
parties as well as the potential results of those acts. Therefore, unless the PRP can clearly
establish that the release occurred as a result of circumstances totally beyond its control and that it
had exercised due care and took appropriate precautions, it is strictly liable for the response cost
under section 107(a).
Finally, the court cases generally support the position that (at least with regard to employees and
agents of a PRP) section l07(b) provides the PRP's only statutory defenses to strict liability under
CERCLA.84 Section 114(a) provides that CERCLA does not preempt the States from adopting
more stringent liability schemes.85
In view of the significant potential dollar liability which can be associated with PRP status and the
limited statutory defenses available to PRPs, RACs must carefully evaluate whether their activities
are likely to cause them to also acquire PRP status or whether they qualify under CERCLA for
any "status exemption" from federal strict liability under section 119, as discussed below.
D. "Response Action Contractors"
Going back to our opening Desert Storm analogy, the RAC is much like the soldier or Marine who
has been tasked to clear a lane in the minefield. Contractors are hired to assist in investigating or
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cleaning up a site which is already contaminated when they arrive. As with that soldier or
Marine, the contractor usually has very limited initial knowledge of the nature, extent or
condition of the "mines" that it has been asked to defuse. Similarly, in performing site
environmental work under Government direction for the public benefit, the contractor would,
under section 107, be assuming substantial liability risks resulting from contamination which it
had no role in causing. The palpable inequity of this situation and the delay in clean-up progress
caused by the general unwillingness of contractors to "step into" such site liabilities led Congress to
provide in the SARA amendments for a specific status exemption from section 107 strict liability
for "response action contractors."
Ij. The Legislative Background of Section 119
When enacted in 1980, CERCLA did not initially provide any special status for response
contractors. Five years later, when the SARA amendments were being considered in Congress,
there was widespread concern over the relatively slow progress of CERCLA clean-up efforts.
This lack of progress was attributed in part to (1) the unwillingness of many large, experienced
environmental firms to take on certain response action projects for fear of incurring joint liability
with PRPs and (2) the limited availability of reasonably-priced insurance to cover CERCLA
liability. (Despite the SARA changes, this situation still prevails today.)
It is now clear that EPA lacks the budget and internal resources to fully implement CERCLA
without the active involvement of engineering and construction contractors.86 To perform its
mission under CERCLA, EPA must therefore have a sufficient pool of qualified response
contractors who are willing to perform environmental services at realistic rates of compensation.
In view of the complexity of the problems at NPL sites, it is essential that EPA be able to utilize
the larger environmental engineering firms that possess the requisite multi-disciplinary resources
and large-scale construction experience.
Recognizing this need, Congress was concerned that the high level of potential liability associated
with removal and remediation services, combined with insufficient insurance coverage, was
driving the larger firms out of this market. The larger environmental engineering firms were
unwilling to put their substantial corporate assets at risk merely to obtain cost-reimbursement type
contracts from EPA with fees substantially lower than those available in private markets. As a
result, EPA was faced with the prospect of having to contract with an increasingly expensive pool
of less capable contractors.
In 1986, Congress acknowledged the need to offer some level of protection to response contractors
by including section 119 in the SARA amendments to CERCLA. This new section created a
special status for "response action contractors," which is a defined term under CERCLA. Those
who meet the statutory definition of "response action contractor" would now be afforded limited
statutory protection from federal strict liability associated with a release or threatened release of
pollution resulting from response action activities.87
The legislative history of section 119 provides some indication of the intended scope of the
limitations on response contractor liability. The House Conference report on the final version
noted that, under earlier versions, section 119 had been broader in scope. For example, an earlier
Senate amendment had called for modifying the definition of "owner or operator" in section
101(20) to exclude "response action contractors" from liability as an owner or operator under
CERCLA except to the extent that there was a release "primarily caused by the activities of such
person."88 This change was not included in the final version. Also, an earlier House amendment
eliminated RAC liability under any federal or state law for damages resulting from non-negligent
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actions of response action contractors. In the final version, section 119 coverage was limited to
federal law.89
The House Conference Report also noted the limitation on the strict liability exemption in section
119(d), which provides that a potentially responsible party may not be considered a "response
action contractor" with respect to a release for which it is responsible under section 107, nor does
it qualify for indemnification under section 119(c).90 Also noted in the House Conference
Report was the limitation in section 119(b)(l) that the "third party" statutory defense in section
107(b)(3) is not available to potentially responsible parties with respect to any costs or damages
caused by any act or omission of a "response action contractor."91
The rationale for RAC federal strict liability exemption in section 119(a) (and for indemnification
in certain instances, as provided in section 119(c)), was discussed in an earlier House Report:
Under the concept of strict, joint and several liability which is applied to hazardous
waste sites, any response action contractor -working at that site is potentially liable
for all removal and remedial costs associated with a release or threatened release of
a hazardous substance from the site. This is so even though the contractor is
following the requirements set forth in its agreement with the Administrator,
another Federal agency, a state or political subdivision or a potentially responsible
party. The imposition of such liability is not appropriate in these cases, and for that
reason, section [119] exempts response action contractors from liability. Even with
such an exemption, insurance to cover liability arising out of the contractor's
performance in carrying response action activities where the liability is caused by
negligence of the contractor either cannot be obtained or is very expensive. New
section [119] therefore authorizes the Administrator of EPA to indemnify response
action contractors.92 (emphasis added)
The legislative intent was to provide limitations on strict liability which would make it possible
for response contractors to proceed with clean-up work without "betting the company" in the face
of "evolving state and Federal laws (including CERCLA), which have increasingly subjected
contractors to strict or near absolute liability standards."93
1± Qualifying as a "Response Action Contractor" Under CERCLA
Merely performing services related to clean-up of a contaminated site does not guarantee that the
contractor will qualify for the protected status of "response action contractor" under CERCLA
section 119. Several statutory requirements within CERCLA must be met first.
The first requirement is that the contractor must meet the definition of "response action
contractor," as set forth in section 119(e)(2):
The term "response action contractor" means -
(A) any -
(i) person who enters into a response action contract with respect to any release
or threatened release of a hazardous substance or pollutant or contaminant from a
facility and is carrying out such contract; and . . .
(B) any person who is retained or hired by a person described in subparagraph
(A) to provide any services relating to a response action.94 (emphasis added)
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Based on the language of section 119(e)(2), the contractor must qualify under each of the
following elements of that clause:
1. The contractor must be a "person";
2. The contractor must enter into a "response action contract";
3. The contract must relate to a "release or threatened release of a hazardous substance or
pollutant or contaminant";
4. The release must be from a "facility"; and
5. The alleged liability must have "resulted from" the release or threatened release to which
the contractor has responded.
As noted earlier, "person" is broadly defined by section 101(21) and essentially covers virtually any
type of business entity that a contractor might form.
The second element is that the contractor must enter into a "response action contract." CERCLA
section 119(e)(l) defines "response action contract" as:
[A]ny written contract or agreement entered into by a response action contractor (as
defined in paragraph (2)(A) of this subsection) with --
(A) the President;
(B) any Federal agency;
(C) a State or political subdivision which has entered into a contract or cooperative
agreement in accordance with section 9604(d)(l) of this title; or
(D) any potential responsible party carrying out an agreement under section 9606
or 9622 of this title;
to provide any remedial action under this chapter at a facility listed on the
National Priorities List, or any removal under this chapter, with respect to any
release or threatened release of a hazardous substance or pollutant or contaminant
from the facility or to provide any evaluation, planning, engineering, surveying
and mapping, design construction, equipment, or any ancillary services thereto for
such facility."95 (emphasis added)
Therefore, in order for the response activities to fall within the technical definition of a "response
action contract," the following criteria must be met:
1 . The contract must be in writing;
2. The person performing the activities must otherwise be a RAC as defined in section
3. the work must be performed for certain narrowly-defined parties;
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4. the response action must either be a "remedial action" provided at a facility listed on the
National Priorities List or a "removal" action;96 or
5. the response action contractor must be performing certain other defined services.
The "in writing" requirement is consistent with the intention in section 119 of restricting
protection to clearly defined categories.
Implicit in the second element is a requirement that the response contractor be performing
response action activities. The mere fact that the contractor is involved in a release or threatened
release does not automatically entitle it to the protective provisions of section 119.
The third element requires that the contractor's client be one of the parties specifically set forth in
section 119(e)(l).97 If not, the response contractor will not qualify for RAC status under section
119.
The fourth element requires that, in order to qualify the contractor under section 119, the services
must be:
• A remedial action performed at a facility listed on the National Priorities List;98 or
• A removal action under CERCLA
The fourth element also requires that the contract relate to a "release or threatened release of a
hazardous substance or pollutant or contaminant." This is consistent with section 104(a)(l), which
provides authority for the Government to take remedial action under CERCLA. Section 104(a)(l)
provides, in relevant part, that the Government can take such action:
Whenever, (A) any hazardous substance is released or there is a substantial threat
of such release into the environment, or
(B) there is a release or substantial threat of release into the environment of any
pollutant or contaminant which may present an imminent and substantial danger to
the public health or welfare . . . . 99 (emphasis added)
Finally, the fourth element requires that the release occur from a "facility." As noted earlier,
section 101(9) broadly defines "facility" to include essentially every location where a hazardous
substance has come to be located, so it is probable that this requirement will be met in almost
every case.
The fifth element lists additional types of services for which a RAC will be covered under section
119. These are consistent with section 107(d), which limits liability of those providing certain
non-construction services.100
Assuming that the contractor has met all of the requirements set forth in sections 119(e)(l)-(2), it
would qualify as a "response action contractor" for the limitations on federal strict liability and
(where EPA has granted coverage) for indemnification.
3. Protected Activities Under CERCLA sections 119fa) and 119fc)
Section 119(a) provides limited exemption from liability for RACs, while section 119(c) allows for
indemnification coverage for RACs under certain limited circumstances.101 Section 119(a)(l)
provides as follows:
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A person who is a response action contractor with respect to any release or
threatened release of a hazardous substance or pollutant or contaminant from a
vessel or facility shall not be liable under this subchapter or under any other Federal
law to any person for injuries, costs, damages, expenses, or other liability
(including but not limited to claims for indemnification or contribution and claims
by third parties for death, personal injury, illness or loss of or damage to property
or economic loss) which results from such release or threatened release.102
(emphasis added)
Section 119(a)(2) provides that the above exemption from federal strict liability shall not apply in
the case of a release that is caused by conduct of the RAC which is "negligent, grossly negligent,
or which constitutes intentional misconduct."103 In other words, the protection granted by
section 119(a)(l) is only against federal strict liability.
As noted above, this exemption from strict liability is given only to "response action contractors,"
as defined in section 119(e)(2), which includes "any person who is retained or hired" by response
action contractors.104 Moreover, the exemption only applies to CERCLA and other federal
law, not to state strict liability laws.105 Many states have passed "mini-Superfund" statutes
containing strict liability schemes, under which a contractor that qualifies as a "response action
contractor" under CERCLA would nevertheless face potential liability without regard to fault in
connection with any activities involving a contaminated site in which the state may have an
interest.106
The wording of section 119(a)(l) would nevertheless appear to make the RAC's exemption from
federal strict liability fairly expansive. However, section 119(a)(3)107 notes two further
limitations on the this exemption. First, "warranty" liability under federal, state, or common law is
unaffected.108 Second, employer obligations to employees under applicable law are not
affected. RACs must therefore take special care to avoid prohibitions of certain statutes
concerning worker health and safety and "right to know."109
Although section 119 is generally perceived to cover releases associated with the response action
itself, it has been suggested that section 119 could be interpreted so as to apply only to a pre-
existing release.110 "New" releases which occur during the performance of the response action
would, under this view, arguably not be covered by the section 119 exemption.111
The basis for this more restrictive interpretation of section 119 appears to be that section 119 only
applies where a RAC is performing services ". . . with respect to any release [from a facility]" and
that the section 119 limitations on liability only apply to "fSJuch release . . . ." (emphasis added)
The terms "with respect to" and "such release" are not further defined in CERCLA.
Under this more restrictive interpretation, it is arguable that the subsequent actions of the RAC
constitute a subsequent and separate "disposal" which falls outside of the section 119 relationship
of the RAC to "such release."
In Tanglewood East Homeowners v. Charles-Thomas Inc.112, the court determined that a
developer could be liable under section 107(a)(2) despite the fact that it was not an owner or
operator at the time of the original disposal of the hazardous substances constituting the release.
The court reasoned that "[t]here may be other disposals when hazardous materials are moved,
dispersed or released during landfill excavation and fillings."113 (emphasis added) Thus, an
action following the original release could be deemed a subsequent "disposal" or "release" for
purposes of section 107(a)(2) liability.
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Based on the reasoning set forth in the Tanglewood case, it could be argued that the word "such
release" only applies to the original (or pre-existing) release and not to the subsequent "disposal" or
"release" caused by the RAC's performance of the response action. Under this reasoning, a RAC
would only be protected from federal strict liability under section 119 with respect to the pre-
existing releases to which it was responding. It would not be protected under section 119 for any
subsequent release.
Applying the rule of statutory interpretation that every part of a statute must be viewed as having
some meaning and purpose, courts would probably reject this extremely narrow interpretation of
the section 119 language "with respect to ... such release" on the grounds that it would tend to
render section 119(a) meaningless. This analysis is consistent with the legislative history of section
119, which noted that it would be "inappropriate" to apply strict liability where the RAC is merely
"following the requirements set forth in its agreement with [EPA]."114 Following this line of
reasoning, RACs would be protected from federal strict liability with regard to secondary releases
as long as they otherwise qualified under section 119.
It should be noted, however, that this issue exemplifies the ambiguities involved in CERCLA
liability provisions. So long as these ambiguities remain, there will be a lingering concern on the
part of the RACs as to whether the potential profits are worth the potential liability risks
associated with CERCLA response actions.
4L Application of CERCLA Section 119 to Arranging for Disposal
Assuming that the contractor qualifies for RAC status under section 119(e)(2), the next issue is
whether the following actions are covered by the section 119 limitations on liability:
• Arranging for the treatment and/or disposal, or arranging for the transportation for the
treatment and/or disposal of hazardous substances; and
• Transporting the hazardous substances to a disposal facility selected by the transporter.
The definition of "response action contract" under section 119 includes "removal" and "remedial"
actions. "Removal" and "remedial" actions, in turn, include "arranging for "disposal" and
"transport" of the hazardous substances, based on the following analysis.
The section 101(23) definition of "removal" includes:
"[T]he disposal of removed material, or the taking of such other actions as may be
necessary to prevent, minimize, or mitigate damage to the public health or welfare
or to the environment, which may otherwise result from a release or threat of
release.115 (emphasis added)
Although the term "transportation" is not specifically mentioned in the definition of "removal," it
is an natural part of the disposal process. "Disposal of removed materials" is generally interpreted
to mean the full range of activities involved in this process. An argument can also be made to the
effect that the absence of the term "transport" in the definition of "removal," coupled with its
inclusion in the definition of "remedial action," would indicate that transportation of a hazardous
substance in connection with removals is not a protected activity under section 119. However, this
would seem to go against the Congressional intent behind this provision discussed earlier.
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The CERCLA section 101(24) definition of "remedial action" includes:
"... offsite transport and offsite storage, treatment, destruction, or secure
disposition of hazardous substances and
associated contaminated materials."116
Note that the definition of remedial action includes both "transport" and "disposal" of the
hazardous substances.
Based on the definitions for "removal" and "remedial action", these actions typically involving the
disposal of hazardous substances would appear to be included in the definition of a "response
action contract."
^ Limitations on Section 119 Status Arising out of Other CERCLA Provisions
Assuming that the RAC is otherwise qualified for section 119 protection, the remaining question
is whether any other provisions of CERCLA could still preclude this protection. For example,
section 107(a) provides:
Notwithstanding any other provision or rule of law, and subject only to the defenses
set forth in subsection (b) of this section - ....
(3) any person who by contract, agreement, or otherwise arranged for disposal or
treatment, or arranged with a transporter for transport for disposal or treatment, of
hazardous substances owned or possessed by such person, by any other party or
entity, at any facility or incineration vessel owned or operated by another party or
entity and containing such hazardous substances, and
(4) any person who accepts or accepted any hazardous substances for transport to
disposal or treatment facilities, incineration vessels or sites selected by such person,
from which there is a release, of a threatened release which causes the incurrence
of response costs, of a hazardous substance, shall be liable .... 117(emphasis
added)
At first glance, it would appear that the express language contained in section 107(a) is absolute in
that no statutory defenses other than those expressly stated in section 107(b) may be used by a
PRP as a defense to its liability under section 107(a). The liberal construction of this provision (in
favor of the Government) is supported by case law.118
Although the express language of section 107(a) seems clear on its face, however, it must still be
evaluated in the context of the entire statute, subsequent amendments to the statute, and the
legislative intent supporting such subsequent amendments.
The current section 107(a) language was in the original 1980 statute. Section 119, however, was
subsequently introduced as a part of the 1986 SARA amendments. If section 119 is read as
amending the section 107(a) limitation on defenses, then the RAC may be able to perform the
disposal and transportation activities covered by sections 107(a)(3)-(4) at the reduced level of
liability provided under section 119(a).
It is clear from reading sections 107(a) and 119(d) together that a potential conflict exists between
these two provisions. Since this conflict cannot be fully resolved from the expressed language of
the provisions themselves, the courts are likely to look to the legislative history to resolve any
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conflict or ambiguity.119 One might ask, then, whether the legislative history of section 119(d)
is sufficiently clear to override the apparent restrictions on allowable statutory defenses set forth
in section 107(a).
Section 119(d) states:
The exemption provided under subsection (a) of this section and the authority of
the President to offer indemnification under subsection (c) of this section shall not
apply to any person covered by the provisions of paragraphs (1), (2), (3), or (4) of
section 9607(a) of this title with respect to the release or threatened release
concerned // such person would be covered by such provisions even if such person
had not carried out any actions referred to in subsection (e) of this section.™
(emphasis added)
By applying generally accepted principles of statutory construction,121 section 119(d) could be
interpreted as providing that those persons who would not be liable under section 107(a) had they
not carried out the covered response activities would thus be entitled to the section 119 limitations
on liability if otherwise qualified. In other words, by expressly citing section 107(a) and
excluding those persons who would otherwise be liable under section 107(a), Congress has clearly
included within the section 119(a) status those persons who would be subject to section 107(a)
liability solely as a result of their RAC activities.
This reading is consistent with Congressional intent to place limits on RAC liability in order to
ensure that sufficient qualified contractors are available to competitive prices.
Section 104(a)(l), which was also included in the 1986 SARA amendments, also seems to support
this interpretation. Section 104(a)(l) states:
In no event shall a potentially responsible party be subject to a lesser standard of
liability, receive preferential treatment, or in any other way, direct or indirect,
benefit from any such arrangements as a response action contractor, or as a person
hired or retained by such response action contractor, with respect to the release or
facility in question.122
Section 104(a)(l) specifically addresses response actions performed by potentially responsible
parties and states. The pre-existing PRPs referred to in section 104(a)(l) are expressly precluded
from the section 119(a) limitations on liability. Unless section 119(a) covers the actions of RACs
that would otherwise result in section 107(a) status, there would be no reason to specifically
preclude preexisting PRPs from qualifying for the RAC limitations on liability. Under general
principles of statutory construction, statutes should not be read to make "surplusage" of any
provision.123 Based on this principle, it is likely that the courts will read section 104(a)(l) as
creating an exception under section 107(a) to the limitations on liability afforded to RACs under
section 119(a).
It could also be argued that under the interpretation of sections 119(d) and 104(a)(l) address
essentially the same types of restriction on PRP's qualifying for section 119(a) limitations on
liability. In this event, one of the two provisions would be "surplusage". On closer examination,
however, section 104(a)(l) provides a narrow exception to the section 119(a) limitation on liability.
Section 104(a)(l) must be read within the overall context of section 104, which relates only to
response actions by pre-existing PRPs. Section 119(d), on the other hand, applies to those
additional parties who subsequently become PRPs independent from the RAC activities (e.g.,
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successor in interest to a PRP, subsequent owner of the facility, etc.). Therefore, each of these
provisions has a valid purpose in the CERCLA statutory scheme.
E. Potential RAC Liability for Subsequent Releases
JL Does the Section 119 RAC Strict Liability Exemption "Follow the Waste"?
In U.S. v. Conservation Chemical Co., the court stated that "[CERCLA's] legislative history is
replete with statements that generators of hazardous substances remain ultimately liable for those
substances regardless of their place of disposition. In other words, the generators retain a
continuing liability."124
The question has been raised as to whether the section 119 limitation on liability and
indemnification provisions "follow the waste" to the ultimate disposal site.125 This question has
important implications for the RAC.
It would seem that RAC activities which would otherwise incur liability under sections 107(a)(3)-
(4) are exempt from strict liability by virtue of section 119(a) for losses associated with the site of
the response action. Under this analysis, RACs theoretically could still be liable, however, for
subsequent releases from the facility to which the hazardous substances from the response action
are taken for treatment and/or disposal // the RAC had selected the disposal facility.
Assuming that the section 119 limitations on liability do encompass the actions taken by a RAC to
"arrange for the disposal and select the facility to which the wastes are to be transported, then it
reasonably follows that Congress must have intended to extend section 119 protection to include
those events that directly flow from those decisions. In other words, if the RAC's act of
"arranging" is exempt from strict liability under section 119(a), and if the only connection to the
subsequent release from the disposal facility is that the RAC made the arrangements, then section
119 arguably should preclude any strict liability that "resulted from" the arrangement decision.
This conclusion is supported by the language of section 119 itself, which provides that the RAC is
exempt from any federal strict liability which "results from" the release to which the RAC is
responding. However, such a conclusion is by no means an inescapable one.
From a practical viewpoint, if courts determine that section 119 does not "follow the waste," such
decisions could lead to the very result that section 119 was presumably introduced to prevent - the
mass exodus of environmental engineering firms from the pool of RACs available to EPA for
performance of contaminated site cleanups. This important question has not been definitively
resolved by the courts.
2i The Nexus Issue
The theory that section 119 is intended to "follow the waste" is consistent with the concept of
"nexus" as it relates to response actions performed by governmental agencies.
Courts in various jurisdictions have required that there must be some "nexus" (or relationship)
between the owner of the hazardous substances and the person who subsequently "arranges" for
the treatment/disposal of those hazardous substances.126 As the court stated in United States v.
New Castle County:
In [NEPACCO and Aceto], this nexus or relationship was present due to the
commercial relationship of the person fixed with arranger status (which in some
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instances was coupled with the actual control that person had over the hazardous
wastes) and the hazardous wastes which were disposed. [Note 42.]
Note 42. Such a relationship is certainly present in those cases where the arranger
owned the hazardous substance, see, e.g., Aceto, 872 F.2d at 1382. It is also present
in those cases where a corporate employee, such as a plant supervisor, was an
arranger, see e.g., Nepacco, 810 F.2d at 743.
In FMC Corp. v. Northern Pump Co., the court stressed, however, that the application of nexus
was not unlimited and that the nexus must generally be "commercial" in nature.127
It is significant to note that the Court in State of New York v. City of Johnstown, N.Y, specifically
found that the required nexus was absent in a situation where the only linkage between the
"owner" of the hazardous substances and the state defendant was the state's performance of
regulatory functions under CERCLA and its state counterpart. The Johnstown court held that:
The cases clearly show that there has to be some nexus between the allegedly
responsible person and the owner of the hazardous substances before a party can be
held liable under 42 U.S.C. section 9607(a)(3). See Edward Mines Lumber
Company v. Vulcan Materials Company, 685 F.Supp. 651, 656 (N.D. 111. 1988);
There is no such nexus between the State and defendant here. The State was
attempting to remediate the hazardous waste problems at both sites and cannot be
considered in the class of liable parties along with [the defendants].128
This interpretation was reaffirmed by the Court in U.S. v. New Castle County, in which it was
again stressed that, in such cases, the governmental agencies were merely performing regulatory
functions for the benefit of the general public and did not benefit commercially from their actions
to dispose of the hazardous substances removed from the site.129 However, the New Castle
court took note of the holding in String fellow that the state would be held liable as a PRP where it
operated a landfill to dispose of hazardous substances owned by the state.130 The basis for the
distinction between states' performing of "regulatory functions" versus activities "for commercial
benefit is supported by section 107(d)(2).131
While case law on this specific point is virtually nonexistent, there would seem to be a correlation
between (1) the lack of nexus between a governmental agency acting in its regulatory capacity and
the owner or operator and
(2) the lack of nexus between the RAC and the owner or operator. Unlike the "commercial"
contractor who seeks favorable commercial relationships with generators by providing "discount"
disposal services, RACs have no commercial relationship with the PRPs at the site. In fact, the
RAC actually has a strong disincentive to seek improper disposal sites since "remedial action"
under section 101(24) only includes "secure disposal sites" and the RAC could potentially lose its
section 119(a) protection by negligently selecting a facility that was not "secure."
From a legal perspective, the required "nexus" between the RAC and the "owner" of the hazardous
substances is also absent. The RAC has no direct relationship with the PRPs at the response action
site. In fact, such a relationship is specifically prohibited by the terms of RAC contracts with
EPA.132 The client of the RAC is the authorized governmental agency. If the governmental
agency lacks the required "nexus,"133 then by definition, the link between the owner of the
hazardous substances and the RAC is broken as well. As the Court stated in United States v, A &
F Materials Co, Inc.:
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Thus, liability for releases under [section 107(a)(3)] is not endless; it ends with that
party who both owned the hazardous waste and made the crucial decision how it
would be disposed of or treated, and by whom.134 (emphasis added)
This position was reinforced by the Court in FMC Corp. v. Northern Pump Co. where the court
stated:
The original intent behind CERCLA was to impose liability upon those who caused
the pollution, not to automatically radiate liability upon anyone with some nexus to
the site.135
Since the only nexus of the RAC to the pollution is through the governmental agency acting in the
performance of its authorized regulatory functions under CERCLA or the comparable state
statute, such liability should not "automatically radiate" to the RAC unless the RAC negligently
selects an "unsecure" treatment or disposal facility.
Congressional intent in support of this position can be inferred from the express language set
forth in section 107(d)(l) where the statute clearly reflects the Congressional intent to protect
those who render ". . . care, assistance, or advice . . . with respect to an incident creating a danger
to public health or welfare or the environment as a result of any releases of a hazardous substance
or the threat thereof."
Finally, the Congressional intent can be inferred from section 107(e)(l) which specifically
precludes a PRP from seeking indemnifications relating to the release of hazardous substances
from "any other person" who is not already a PRP.136 Again, this concept is consistent with
Congressional intent to hold those who "benefit commercially" from the use of hazardous
substances from shifting liability to those attempting to resolve the problem.
L. Steps EPA Could Take to Resolve RAC Uncertainty Regarding Section 119
It is clear that there may be substantial risks for RACs who perform work involving contaminated
sites. Currently, the nature and level of such risks are difficult for RACs to evaluate, due in part
to their doubts as to the breadth of their strict liability exemption under section 119. The
"meaning" of section 119 in the context of CERCLA generally is subject to varying
interpretations. The legislative history is not dispositive on many points. Interpretations of
CERCLA's liability provisions by the courts have been far from uniform. Given these
uncertainties, it is no surprise that RACs continue to be concerned as to their legal vulnerability
under CERCLA. This is no doubt reflected in decisions as to whether or not to bid for EPA
remediation contracts and at what prices.
In this paper, we have identified several CERCLA provisions that are susceptible to multiple
interpretations. These interpretations are crucial to the determination of potential RAC liability
exposure associated with arranging for the transportation and disposal of hazardous substances.
However, few of these interpretations have been fully or uniformly adopted by the courts (or by
EPA).
The discussions set forth in this paper are not likely to resolve the uncertainties RACs may have
as to exactly where they stand with regard to section 119 protection, but hopefully will clarify the
questions that must be resolved to optimize RAC cooperation with EPA in environmental clean-ups.
Until these questions are resolved, responsible RACs will undoubtedly take a conservative
approach in making work commitments involving contaminated sites. This is only logical, given
that if RACs' protection under section 119 is less than expected, they may well be subject to
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strict, joint and several liability for any subsequent or new release or threatened release of
hazardous substances in a scenario of ever-increasing liability due to on escalating response
costs.137
EPA has a strong vested interest in minimizing any confusion regarding RACs' exemption from
strict liability under section 119. Clear official guidance from EPA could help to slow the exodus
of larger environmental consulting firms from the pool of available response contractors. These
firms could then calculate with a greater feeling of certainty the risks associated with work
involving contaminated sites. Such guidance could also help reduce the cost of cleanups since a
larger pool of RACs could lead to more competition and a better cost/benefit ratio for
Government expenditures in this area.
The courts have repeatedly acknowledged their deference to EPA with regard to the interpretation
of CERCLA language relating to substantive matters.138 By taking a more pro-active role in
attempting to resolve ambiguities as to the extent of RAC exemption from strict liability under
section 119, EPA could help the create the long-needed atmosphere of contractor confidence
required to propel clean-up efforts along more quickly.
In this regard, EPA might consider statutory construction and policy issues such as the following:
• Do sections 119(a)(l) and (c) apply to subsequent releases resulting from RAC response
action activities?
• Does section 119(a)(l) provide a statutory defense under section 107(a), despite the express
language of section 107(a) limiting statutory defenses to those set forth in section 107(b)?
• Do sections 119(a)(l) and (c) "follow the waste" so as to protect the RAC with regard to a
post-disposal release from a facility selected by the RAC pursuant an EPA contract?
• Does section 101(23) (defining "removal") encompass the transportation of removed
hazardous substances to a facility1]
EPA's clarification of these issues could resolve existing ambiguities relating to potential RAC
liability under CERCLA. EPA could address these issues through:
• Use of EPA's influence with Congress to seek appropriate statutory amendments removing
ambiguities in sections 101(23), 107(a) and 119.
• Promulgation of clarifying regulations on these issues to reflect EPA's interpretation and
policy positions.
• Publication of formal guidance documents regarding these issues.
• Clarification of language in EPA contracts to more clearly define RAC status, indemnity
options and exemption from strict liability.
• Coordination with Department of Justice to ensure that enforcement of CERCLA reflect
EPA policy and interpretation of these issues.
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CONCLUSION
As noted throughout this paper, varying interpretations of CERCLA provisions affecting RAC
liability are both possible and reasonable. Some of these interpretations would indicate that the
RAC's exemption from strict liability could be more limited than is generally perceived. Other
interpretations, as noted herein, would indicate less potential liability exposure for RACs.
CERCLA is a product of many compromises and last minute drafting changes. Due to the nature
of the legislative process, many CERCLA provisions may have been intentionally left vague so as
to obtain the necessary support for passage of the final bill. Vagueness in some CERCLA
provisions is compounded by a limited legislative history and varying interpretations by well-
. 1 OQ
meaning courts.
The key issue, however, is that such ambiguities do exist and that they represent a potentially
unacceptable business risk for RACs in the context of contaminated site cleanup work for the
Federal Government. EPA should therefore take a pro-active role in defining the exact nature
and extent of potential RAC liability associated with EPA response action contracts.
1. Even where specialized pollution coverage is available, it is filled with exclusions and
typically offered only on a "claims-made" basis.
2. Comprehensive Environmental Response, Compensation and Liability Act of 1980
("CERCLA"), Pub. L. NO. 96-510, 94 Stat. 2767 (1980) (codified as amended by the
Superfund Amendments and Reauthorization Act of 1986 ("SARA"), at 42 U.S.C. §§ 9601-
9675 (1982 and Supp. V 1987).
3. Solid Waste Disposal Act of 1965 (codified at 42 U.S.C. §§ 6901-6992k).
4. Resource Conservation and Recovery Act of 1976, Pub. L. No. 94-580 (1976), U.S. Code
Cong. & Admin. News (90 Stat.) 2795 (codified at 42 U.S.C. §§ 6921-6939a).
5. See United States v. Aceto Agricultural Chemicals Corp., 872 F.2d 1373 (8th Cir. 1989)
("Aceto"). See also H.R. Rep. No. 1016, 96th Cong., 2d Sess., pt. 1 at 1, 17-22 (1980),
reprinted in 1980 U.S. Code Cong. & Admin. News 6119, 6119-25; S. Rep. No. 848, 96th
Cong., 2dSess. 2-13(1980).
6. See 47 Fed. Reg. 42,237 (1981); Exec. Order No. 12,286, 46 Fed. Reg. 9,901 (1981). See
also, CERCLA §§ 101(2), 102(a), 42 U.S.C. §§ 9601(2), 9602(a); EPA Determinations to
Initiate Response and Special Conditions, 40 C.F.R. § 300.130 (1990); Federal Agencies:
Additional Responsibilities and Assistance, 40 C.F.R. § 300.175(b)(2) (1990).
7. See CERCLA § 101(23), 42 U.S.C. § 9601(23).
8. See CERCLA § 101(24), 42 U.S.C. § 9601(24).
9. See CERCLA § 104(a)(l), 42 U.S.C. § 9604(a)(l).
10. Alternative Remedial Contracts Strategy contracts involve response actions, including
removal and remediation engineering and construction services.
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11. See United States v. New Castle County, No. 80-489 (D.C. Del. 1989), 30 Env't Rep. Cas.
(BNA) 2134. See also notes 12-14, infra, and accompanying text.
12. S. Rep. No. 848, 96th Cong., 2d Sess. 13 (1980), reprinted in 1 Senate Comm. on Env't and
Public Works, 97th Cong., 2d Sess., A Legislative History of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (Superfund), Public
Law 96-510 at 320 (1983).
13. Ohio v. Georgeoff, Case No. C81-1961 (N.D. Ohio May 3, 1983), 19 Env't Rep. Cas.
(BNA) 1113, 1124 (1983); see also Ohio ex rel. Brown v. Georgeoff, 562 F. Supp. 1300
(N.D. Ohio 1983).
14. See supra, note 5, Aceto, 872 F.2d 1373 (quoting Dedham Water Co. v. Cumberland Dairy
Farms, Inc., 805 F.2d 1074, 1081 (1st Cir. 1986).
15. The term "potentially responsible party" is not expressly defined in CERCLA. This term
first appears in § 104(a), where it is used to identify "persons" who are potentially liable
for response costs under CERCLA by virtue of being "covered persons" under §§ 107(a)
16. 42 U.S.C. § 9607(a).
17. 42 U.S.C. §§ 9607(a)(l)-(2). There is nothing in the legislative history of these subsections
to indicate that the use of "and" versus "or" was intended to connote a different meaning
for each of the two subsections involved.
18. 42 U.S.C. § 9601(20)(a)(ii).
19. 42 U.S.C. § 9601(9)(B).
20. See, e.g., U.S. v. Carolawn Co., 21 Env't Rep. Cas. 2124, 2131 (D.S.C. 1984); Edward
Mines Lumber Co. v. Vulcan Materials Co., 861 F.2d 155, 157 (7th Cir. 1988).
21. "Generator" is a generic term used to identify those persons who were responsible for the
"generation" of the hazardous materials relating to the release. See Brennan, Joint and
Several Liability for Generators Under Superfund: A Federal Formula for Cost Recovery, 5
J. Envtl. L. 101 (1986).
22. See 40 C.F.R. § 300; See also U.S. v. South Carolina Recycling and Disposal, Inc., 653 F.
Supp. 984, 1005 (D.S.C. 1984).
23. SWDA § 1004(3), 42 U.S.C. § 6903(3), defines disposal as follows:
The term "disposal" means the discharge, deposit, injection, dumping, spilling,
leaking, or placing of any solid waste or hazardous waste into or on any land or
water so that such solid waste or hazardous waste or any constituent thereof may
enter the environment or be emitted into the air or discharged into any waters,
including ground waters.
See, also, Tanglewood East Homeowners v. Charles-Thomas Inc., 849 F.2d 1568 (5th Cir.
1988) (relating to subsequent disposals by virtue of movement or mixing of contaminated
soils.)
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24. Note that there is a potential difference between current and prior owner/operators under
§ 107(a). The status of a current owner or operator under CERCLA § 107(a)(l) refers to
anyone who owns and operates a facility from which there has been a release or threatened
release, whereas CERCLA § 107(a)(2) refers only to an owner or operator who owned or
operated a facility at the time at which such hazardous substances were disposed of at that
facility.
25. 42 U.S.C. § 9607(a)(3).
26. United States v. Ward, 618 F.Supp. 884, 889 (E.D.N.C. 1985).
27. 42 U.S.C. § 9601(21).
28. See supra, Ward, 618 F. Supp. at 889.
29. United States v. Northeastern Pharmaceutical & Chemical Company, Inc., 579, F. Supp.
823, 848 (W.D. Mo. 1984), aff'd in part, rev'd in part on other grounds, 810 F.2d 726, 743
(8th Cir. 1986), cert, denied, 484 U.S. 848 (1987) ("NEPACCO"). See also United States v.
Aceto Agricultural Chemicals Corp., 872 F.2d 1373, 1380 (8th Cir. 1989)
30. Aceto, supra, note 29, 872 F.2d at 1380; Jersey City Redevelopment Authority v. P.P.G.
Industries, 665 F. Supp. 1257, 1260 (D.N.J. 1987); Allied Towing v. Great Eastern
Petroleum Corp., 642 F. Supp. 1339, 1350 (E.D. Va. 1986).
31. See 42 U.S.C. § 9607(a)(3).
32. In explaining the compromise bill that eventually contributed the "arranged for disposal"
language to CERCLA, its co-author, Senator Randolph, stated that: "It is intended that
issues of liability not resolved by the act, if any, shall be governed by traditional and
evolving principles of common law." 126 Cong. Rec. 30,932 (1980).
33. Aceto, supra, note 30, 872 F.2d at 1380; See also, NEPACCO, 810 F.2d at 743; Dedham
Water Co. v. Cumberland Farms Dairy, Inc., Case No. 86-1216 (1st Cir. 1986), 25 Env't.
Rep. Cas. (BNA) 1153, 1159 (1986).
34. See United States v. Conservation Chemical Company, 619 F. Supp. 162 (W.D. Mo. 1985).
35. Id.
36. See 42 U.S.C. § 9607(a)(3).
37. See NEPACCO, 810 F.2d at 743.
38. 42 U.S.C. § 9607(a)(4).
39. See 42 U.S.C. § 9601(26), which provides, in full, as follows:
The term "transport" or "transportation" means the movement of a
hazardous substance by any mode, including pipeline (as defined in
the Pipeline Safety Act), and in the case of a hazardous substance
which has been accepted for transportation by a common or
contract carrier, the term "transport" shall include any stoppage in
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transit which is temporary, incidental to the transportation
movement, and at the ordinary operating convenience of a common
or contract carrier, and any such stoppage shall be considered as a
continuity of movement and not as storage of a hazardous
substance.
40. 42 U.S.C. § 9601(29), see 42 U.S.C. § 6903.
41. 42 U.S.C. § 6903(3) defines "disposal" as follows:
The term "disposal" means the discharge, deposit, injection,
dumping, spilling, leaking, or placing of any solid waste or
hazardous waste into or on any land or water so that such solid
waste or hazardous waste or any constituent thereof may enter the
environment or be emitted into the air or discharged into any
waters, including ground waters.
42. 42 U.S.C. § 6903(30).
43. CERCLA § 101(20)(C), 42 U.S.C. § 9601(20)(c), provides:
In the case of a hazardous substance which has been delivered by a
common or contract carrier to a disposal or treatment facility and
except as provided in section 9607(a)(3) or (4) of this title (i) the
term "owner or operator" shall not include such common or contract
carrier, and (ii) such common or contract carrier shall not be
considered to have caused or contributed to any release at such
disposal or treatment facility resulting from circumstances or
conditions beyond its control.
44. See United States v. New Castle County, No. 80-489 (D.C. Del. 1989), 30 Env't Rep. Cas.
(BNA) 2134. See also notes 12-14, supra, and accompanying text.
45. CERCLA § 306(b), 42 U.S.C. § 9656(b), provides:
A common or contract carrier shall be liable under other law in lieu
of section 9607 of this title for damages or remedial action resulting
from the release of a hazardous substance during the course of
transportation which commenced prior to the effective date of the
listing and regulation of such substance as a hazardous material
under the Hazardous Materials Transportation Act [49 U.S.C.A.
App. § 1801 et seq.], or for substances listed pursuant to subsection
(a) of this section, prior to the effective date of such listing:
provided, however, that this subsection shall not apply where such a
carrier can demonstrate that he did not have actual knowledge of
the identity or nature of the substance released, (emphasis in
original)
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46. United States v. New Castle County, No. 80-489 (D.C. Del. 1989), 30 Env't Rep. Cas.
(BNA) 2134, 2153(1989).
47. See, e.g., New York v. Shore Realty Corp., 759 F.2d 1032, 1042 (2d Cir. 1985); United
States v. Miami Drum Services, Inc., 17 Envtl. L. Rep. (Envtl. L. Inst.) 20539 (S.D. Fla.
1986); United States v. Argent Corp., Civ. No. 83-0523 BB, 21 Env't Rep. Cas. (BNA)
1356, 1357 (D.N.M. 1984); United States v. Conservation Chemical Co., 589 F. Supp. 59
(W.D. Mo. 1984).
48. See supra, text accompanying notes 11-14.
49. S. Rep. No. 848, 96th Cong., 2d Sess. 34 (1980), reprinted in 1 Senate Comm. on Env't and
Public Works, 97th Cong., 2d Sess., A Legislative History of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (Superfund), Public
Law 96-510 at 320 (1983).
50. See 126 Cong. Rec. 30,932 (1980) (statement of Senator Randolph: "Unless otherwise
provided in this act, the standard of liability is intended to be the same as that provided in
section 311 of the [FWPCA]. I understand this to be a standard of strict liability.")
("FWPCA" refers to the Federal Water Pollution Control Act, 33 U.S.C. §§ 1251-1387.)
51. "The term 'liable' or 'liability' under this subchapter shall be construed to the standard of
liability which obtains under section 1321 of Title 33." (i.e., § 311 of FWPCA), 42 U.S.C. §
9601(32).
52. See, e.g., United States v. Le Beouf Bros. Towing Co., 621 F.2d 787, 789 (5th Cir. 1980),
cert, denied, 452 U.S. 906 (1981); United States v. Tex-Tow, Inc., 589 F.2d 1310 (7th Cir.
1978); Burgess v. M/V Tamano, 564 F.2d 964, 982 (1st Cir. 1977), cert, denied, 435 U.S.
941 (1978). Courts have also held that CERCLA strict liability applies to off-site
generators in CERCLA cleanup actions. Cf. United States v. A & F Materials Company,
Inc., 578 F. Supp. 1249 (S.D. 111. 1984); United States v. Price, 577 F. Supp. 1103 (D.N.J.
1983).
53. See 42 U.S.C. § 9607(b).
54. See 42 U.S.C. §§ 9601-9675 (Supp. V 1987).
55. See C. Chadd & L. Bergeson, Guide to Avoiding Liability for Waste Disposal, Corporate
Practice Series (BNA) 44 (1985).
56. Black's Law Dictionary, 4th Ed. (1968)
57. See C. Chadd & L. Bergeson, supra, note 55, at 44-45. See also NEPACCO, 579 F. Supp.
at 843-46; United States v. Chem-Dyne Corporation, 572 F. Supp. 802, 810 (S.D. Ohio
1983) (the defendant has the burden of showing the harm is capable of division); United
States v. Wade, 577 F. Supp. 1326, 1338-39 (E.D. Pa. 1983); Miami Drum Services, 17
Envtl. L. Rep. (Envtl. L. Inst.) 20539 (S.D. Fla. 1986).
The Committee on Energy and Commerce specifically endorsed the Chem-Dyne case,
referring to it as "the seminal case. . . which established a uniform federal rule allowing
for joint and several liability in appropriate CERCLA cases." See H. Rep. No. 253(1), 99th
Cong., 2d Sess. 74 (1985).
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58. See supra, note 32.
59. See cases cited in note 57, supra.
60. See supra, note 57, United States v. Wade, 577 F. Supp. 1326; United States v. Ottati &
Goss, Inc., No. C80-225-L, slip op. (D.N.H. Dec. 9, 1985) (burden of showing
apportionment is on the party seeking to limit their liability); Cf. Restatement (Second) of
Torts §§ 433A, 433B, 875, 881.
61. United States v. South Carolina Recycling and Disposal, Inc. Civ. No. 80-1274-6, 20 Env't
Rep. Cas. (BNA) 1753, 1759 (D.S.C. 1984)
62. United States v. A & F Materials Company, Inc., 578 F. Supp. 1249 (S.D. 111. 1984).
63. Known as the "Gore amendment." See Representative Gore's remarks on joint and several
liability in 126 Cong. Rec. H 9463-65 (daily ed. Sept. 23, 1980). See generally Note, Joint
and Several Liability for Hazardous Waste Releases Under Super fund, 68 Va. L. Rev. 1157
(1982).
64. See C. Chadd & L. Bergeson, supra, note 55, at 45-46.
65. NEPACCO, 579 F. Supp. at 844.
66. Id.
67. See supra, notes 60-62 and accompanying text.
68. "Contribution" essentially is the right of one joint tortfeasor to collect a proportionate
share of the damages from another joint tortfeasor. See Restatement (Second) of Torts §
886A.
69. For a comprehensive discussion of contribution in CERCLA, See United States v.
Conservation Chemical Company, 619 F. Supp. 162, 224-230 (noting that contribution
developed as an equitable remedy, calling for courts to do what is "fair and equitable"
under the circumstances (citing the Restatement of Torts § 886, Comment c)). For the
CERCLA statutory implementation of this concept, see infra, note 73 and accompanying
text.
70. 42 U.S.C. §§ 9607(i)-(j).
71. 42. U.S.C. § 9607(e)(2).
72. "Subrogation" is essentially the right to "stand in the shoes of another" for purposes of
collecting on a claim.
73. 42 U.S.C. §§ 961 l(a)(2), 9612(a).
74. See 42 U.S.C. § 9607(e)(2).
75. 42 U.S.C. § 9612(c)(2).
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76. See Colorado v. ASARCO, 608 F. Supp. 1484 (D. Colo. 1985); United States v. Ward, 22
Env't. Rep. Cas. (BNA) 1235 (E.D.N.C. 1984); Wehner v. Syntex Agribusiness, Inc. 616 F.
Supp. 27 (E.D. Mo. 1985).
77. See 42 U.S.C. § 9613(f) (Supp. V 1987).
78. See United States v. Conservation Chemical Company, 619 F. Supp. 162, 217-221 (1985)
(citing United States v. Shell Oil Company, 605 F. Supp. 1064 (D.C. Colo. 1985), Ohio ex
rel. Brown v. Georgeoff, 562 F. Supp. 1300 (N.D. Ohio 1983)).
79. NEPACCO, 579 F. Supp. at 839 (citing Ohio ex rel. Brown v. Georgeoff, 562 F. Supp.
1300 (N.D. Ohio 1983).
80. See e.g., United States v. Shell Oil Co., 605 F. Supp. 1064 (D. Colo. 1985).
81. 42 U.S.C. § 9607(a).
82. 42 U.S.C. § 9607(b).
83. See, e.g.. United States v. Parsons, Case No. 4:88-CV-75-HLM (N.D. Ga. 1989), 30 Env't
Rep. Cas. (BNA) 1160, 1162.
84. See e.g., New York v. Shore Realty Corp., 759 F.2d 1032 (2d Cir. 1985).
85. CERCLA § 114(a), 42 U.S.C. § 9614(a); See Allied Towing v. Great Eastern Petroleum
Corp., 642 F. Supp. 1339, 1350 (E.D. Va. 1986).
86. See Assessing Contractor Use in Superfund, Office of Technology Assessment at 3 (1989):
"The dependence on contracting is an outcome of both congressional and EPA decisions in
the early 1980s."
87. CERCLA § 119(a)( 1), 42 U.S.C. § 9619(a)( 1).
88. H.R. Conf. Rep. No. 962, 99th Conf., 2d Sess. 236 (1986)
89. Id. at 237.
90. Id. at 238.
91. Id.
92. H.R. Rep. No. 253(V), 99th Cong., 2d Sess. 68 (1985).
93. H.R. Rep. No. 253(111), 99th Cong., 2d Sess. 26-27 (1985). The Judiciary Committee,
which issued this report, noted that insurance for response action contractors was
becoming essentially non-existent. The Committee's thinking behind the indemnification
and limitation of limitation of liability sections of § 119 was summarized as follows:
In summary, this section, in combination with the new liability
standards for contractors established in H.R. 2817, addresses the
two major problems created by the current liability insurance
shortage. First, it provides a reasonable incentive for insurers to
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provide prospective insurance to contractors. Second, it recognizes
that regardless of the liability standard, it will some time before
insurers can provide adequate insurance, and therefore, it provides
an interim form of protection to keep the Superfund clean-up
program functioning until insurers reenter the market.
94. 42 U.S.C. §§ 9619(e)(2)(A)-(B).
95. CERCLA § 119(e)( 1), 42 U.S.C. § 9619(e)( 1).
96. Remedial Investigation and Feasibility Study ("RI/FS") activities are generally performed
under the definition of "removal action." Also, any "qualifying" activities otherwise
covered by CERCLA section 119(a) must be performed at a National Priorities List site in
order for the contractor to qualify for RAC status. See, 40 C.F.R. § 300.430 (1990); see
also New York v. General Electric Company, 592 F. Supp. 291, 302 (N.D.N.Y. 1984):
The liability provisions were an essential element of the statute
because the Fund itself could not adequately remedy the pervasive
waste problem. It is clear beyond doubt that the liability provisions
are independent of the National Priorities List of sites eligible for
Superfund money, since the "requirement for a National Priority
List was not intended to be a limitation on liability but rather was
the result of the great concern voiced by Congress that the limited
trust fund monies not be used for ill-conceived or disorganized
cleanup efforts." Plaintiff's Memorandum of Law in Opposition to
Defendant's Motion to Dismiss Complaint at 20. See, e.g., 126
Cong. Rec. S14982 (daily ed. Nov. 24, 1980) (comments of Sen.
Dole); id. at SI4978 (comments of Sen. Humphrey); id. at SI 5007
(comments of Sen. Helm).
97. This is a critical element which is often overlooked by response contractors, who may
automatically assume they have RAC status under
§ 119 merely because they are performing "response actions." Although most governmental
agencies would presumably fall within § 119(e)(l)(B), performing response action services
for private sector PRPs is not a protected activity unless the PRP is obtaining those services
in order to comply with a § 106 administrative order or a § 122 consent order.
98. See CERCLA § 105(c)(l), 42 U.S.C. § 9605(c)(l).
99. 42 U.S.C. 9604(a)(l).
100. See 42 U.S.C § 9607(d)(l).
101. 42 U.S.C. §§ 9619(a), (c)
102. 42 U.S.C. § 9619(a)(l).
103. 42 U.S.C. § 9619(a)(2).
104. See 42 U.S.C. § 9619(e)(2)(B).
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105. 42 U.S.C. § 9672(a). Regarding the limits of § 119, the House Conference Report noted
that "Liability which might arise under non-Federal laws, however, is untouched . . . ." It
was the conferees' "hope that [§119 would] induce States to deal with the question of
liability within their own borders." The report further "urge[d] States to take note of the
Federal standards and review their own standards of liability." See H.R. Conf. Rep. No.
962, 99th Cong., 2d Sess. 237 (1986).
106. See, generally, 1989 Review of State Laws Related to Response Action Contractors,
Hazardous Waste Action Coalition of the American Consulting Engineers Council. States
listed as establishing "strict liability" for RACS under state statute include: California,
Connecticut, Delaware, Florida, Georgia, Illinois, Indiana, Kentucky, Mississippi,
Missouri, Nebraska, Nevada, New Hampshire, North Carolina, Ohio, Oklahoma, Oregon,
Pennsylvania, South Carolina, Utah, and Vermont. (The specific requirements of each
state vary.)
107. 42 U.S.C. § 9619(a)(3).
108. The question could arise as to whether a RAC's failure to disclaim warranties of
merchantability or fitness for a particular purpose and/or consequential damages under the
Uniform Commercial Code ("UCC") could, in effect, subject it to liability as severe as that
of § 107(a). Generally, the UCC applies only to "goods" not services. However, one might
ask whether this warranty exception could "chill" innovative contractors' efforts to
introduce new technologies into environmental work unless they are able to maintain a
disclaimer of responsibility for pollution resulting from use of such new technologies.
The legislative history of § 119(a)(2) suggests that the intent of this section may have been
somewhat more limited in scope, i.e., that it was "designed to insure . . . that a
manufacturer's warranty covering equipment employed by a response action contractor or
state remains in effect." See H.R. Rep. No. 253(V), 99th Cong., 2d Sess. 67 (1985).
109. See generally, Emergency Planning and Community Right to Know Act, codified at 42
U.S.C. §§ n',001-11,050 (1986); 40 C.F.R §§ 355-372 (1990); Occupational Safety & Health
Administration (OSHA) Hazard Communication Standard, 29 C.F.R. § 19110.1200 (1990).
110. Moskowitz, Super fund Contractor Indemnification: A Cure in Search of a Disease, 20
Envtl. L. Rep. 10,333 (1989).
111. Id. at 10334.
112. Tanglewood, supra, note 23, 849 F.2d 1568.
113. Id. at 1573.
114. H.R. Rep. No. 253(V), 99th Cong., 2d Sess. 68 (1985).
115. 42 U.S.C. §9601(23).
116. 42 U.S.C. § 9601(24).
117. 42 U.S.C. § 9607(a).
118. New York v. Shore Realty Corp., 759 F.2d 1032 (2d Cir. 1985).
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119. U.S. v. Chrysler Corp., No. 88-534-CMW (D.C.Del. 1990), 31 Env't Rep. Cas. (BNA) 1997,
2002.
120. 42 U.S.C. § 9619(d).
121. As noted earlier, the courts have established several general principles for interpreting
statutory language. One of these principles is that the specific exclusion of one activity in
the statutory clause means, by implication, that all other related activities not expressly
excluded are included.
122. 42 U.S.C. § 9604(a)(l).
123. See Pettis ex rel. United States v. Morrison-Knudsen Co., 577 F.2d 668, 673 (9th Cir.
1978).
124. U.S. v. Conservation Chemical Co., No. 82-0983-CV-W-5 (D.C. Mo. 1985), 24 Env't Rep.
Cas. (BNA) 1008, 1065 (1985).
125. Moskowitz, supra, note 110.
126. Aceto, supra, note 15; NEPACCO, supra, note 30; U.S. v. A & F Materials Co., Inc., 582 F.
Supp. 842 (S.D. 111. 1984); Edward Hines Lumber Company v. Vulcan Materials Company,
685 F. Supp. 651, 656 (N.D. 111. 1988).
127. FMC Corp. v. Northern Pump Co., 688 F. Supp. 1285 (D. Minn. 1987).
128. State of New York v. City of Johnstown, N.Y., 701 F. Supp. 33 (N.D.N.Y. 1988).
129. U.S. v. New Castle County, supra.
130. String fellow, No. CIV 83-2501 JMI (MX) (Order on Directed Verdict) (California)
(Special Master).
131. 42 U.S.C. § 9607(d)(2), which provides:
No State or local government shall be liable under this subchapter for costs or
damages as a result of actions taken in response to an emergency created by the
release or threatened release of a hazardous substance generated by or from a
facility owned by another person. This paragraph shall not preclude liability for
costs or damages as a result of gross negligence or intentional misconduct by the
State or local government. For the purpose of the preceding sentence, reckless,
willful, or wanton misconduct shall constitute gross negligence, (emphasis added)
132. The conflict of interest provisions of ARCS and other EPA remediation contracts prohibit
RACs from having any relationship with PRPs for the site involved. See also applicable
regulations in Federal Acquisition Regulation (FAR), 48 C.F.R. Subpart 9.5;
Environmental Protection Agency Acquisition Regulation (EPAAR) 40 C.F.R. Subpart
1509.5.
133. See, U.S. v. New Castle County, supra.
134. United States v. A & F Materials, Co., Inc., supra.
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135. FMC Corp. v. Northern Pump Co., 688 F. Supp. 1285 (D. Minn. 1987).
136. CERCLA § 107(e)( 1), 42 U.S.C. 9607(e)( 1) provides:
No indemnification, hold harmless, or similar agreement or conveyance shall be
effective to transfer from the owner or operator of any vessel or facility or from
any person who may be liable for a release or threat of release under this section,
to any other person the liability imposed under this section. Nothing in this
subsection shall bar any agreement to insure, hold harmless, or indemnify a party
to such agreement for any liabiliity under this section.
137. The current cleanup cost of an NPL site is currently averaging more than $25,000,000 and
increasing. See Note, The Potentially Responsible Trustee: Probable Target for CERCLA
Liability, 77 Va. L. Rev. 113, 113 n.4 (1991) (citing Marzulla, Superfund 1991: How
Insurance Firms Can Help Clean Up the Nation's Hazardous Waste, 4 Toxics L. Rep.
(BNA) 685, 685-86 (1989)).
138. See, e.g., Brock v. Writers Guild of America, West, Inc. 138.3., 762 F.2d 1349, 1353 (9th
Cir. 1985); Comite pro Rescate de la Salud v. PRASA, Case No. 89-1091 (1st Cir., October
26, 1989) 30 Env't Rep. Cas. (BNA) 1473 (1989); Chevron U.S.A., Inc. v. Natural
Resources Defense Council, Inc., 467 U.S. 837, 843-845 (1984); Mayburg v. Secretary of
Health and Human Services, 740 F.2d 100, 106 (1st Cir. 1984); But see, Cardoza v. Fonseca,
480 U.S. 421, 445-48 (1987); General Electric Co. v. Gilbert, 429 U.S. 125, 141-42 (1976).
139. See, e.g., Note, "Arranging for Disposal of Hazardous Substances:" Expansive CERCLA
Liability for Pesticide Manufacturers after U.S. v. Aceto Agricultural Chemicals Corp., 35
S.D.L. Rev. 251, 259 (and sources cited in note 70 therein); Note, Waste Not, Want Not:
Arranging for Disposal" Under CERCLA Section 107(a)(3), 4 J. Envtl. Law and Litigation
143, 146-47 (and sources cited in note 17 therein).
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CGS
An Expert System for the Analysis of Changes Claims
Moonja P. Kim
Michael L. Kayman
U.S. Army Corps of Engineers
Construction Engineering Research Laboratory
2902 Newmark Drive
Champaign, Illinois 61820
(217) 373-6713
James E. Diekmann
Michael A. Rotar
Department of Civil, Environmental, and Architectural Engineering
University of Colorado at Boulder
Boulder, Colorado
(303) 492-7315
ABSTRACT: The U.S. Environmental Protection Agency Superfund projects represent over $500
million of construction related environmental remediation contracts. The Department of Defense
spends even more dollars on Installation restoration programs. The largest portion of these funds is
committed under the Federal Acquisition Regulations (FAR) construction contract language. Due to
the uncertainties when costing out the hazardous waste site projects, history shows that about 30 cents
of remedial contract claim will arise for every dollar of construction funds which are committed.
Most of these claims are settled at the jobsite without relying on formal dispute resolution procedures.
Some of the claims, however, evolve into full blown contract disputes. The resulting litigation
wastefully consumes important resources like time, money and especially project engineering talent.
Many contract disputes could be avoided if the disputing parties took fast action and were better
informed. Additionally, the efficiency and effectiveness of the settlement of jobsite claims could be
improved if simple, quick, easy-to-obtain claims analysis were available to site engineers.
This paper reports on an ongoing research project to develop an expert system to educate and advise
inexperienced site engineers about the legal consequences of construction disputes. The part of the
system described in this paper is called Claims Guidance System (CGS) - Changes Guide. It evaluates
the validity of claims brought under the "Changes Clause" found in the Federal Acquisition
Regulations (FAR). This paper discusses the domain of application, the major design details of the
system, and the auxiliary features of the system.
INTRODUCTION
The Hazardous Waste Site remedial projects from the SuperFund projects and from the Installation
restoration program of Department of Defense represent billions of dollars of construction
expenditures. These Government agencies' experience with previous large construction programs
indicates that 30% of the total appropriated funds will be expended for unanticipated claims and
disputes. Many of these claims and disputes can be avoided or their results mitigated by prompt
contract administration at the construction jobsite. Analysis of contract claims requires technical
knowledge, factual knowledge and legal knowledge. Field engineers have the required technical and
factual knowledge but many young inexperienced engineers lack the legal knowledge necessary to
analyze claims. In an ideal world, the field engineer would have ready access to timely, low cost legal
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advice. In the real world, however, the engineer is often compelled to make judgements having legal
ramifications without the benefit of professional legal advice. As a result of the lack of training in
basic contract law, field engineers might be unaware of accepted legal bases or the resultant
consequences of their decisions.
This paper presents a progress report on a project to develop an expert system program which can
advise and educate an inexperienced field engineer about the legal consequences of certain contract
dispute situations. The expert system assumes the role of a claims advisor and a contract dispute
resolution aid. The logic of the system is built around the Federal Acquisition Regulations (FAR)
language and therefore the system is suitable for EPA, Army Corps of Engineers, and other federal
construction projects.
The majority of litigation that takes place in construction concerns either differing site condition,
changes or delay disputes. The expert system described in this paper is designed to analyze claims
which arise under the Changes clause, as found in the Federal Acquisition Regulation (FAR). The
entire scope of the research effort encompasses expert systems for differing site conditions, changes
and delays. (Gjertsen 1990) Previous systems focused on the Differing Site Condition (DSC) type of
claims. (Diekmann 1990, Kim & Adams 1989, Kraiem 1988b). In the Changes system three overall
goals were important in the design of the system:
1. To create a basic understanding in the junior field personnel of the issues surrounding the
Changes clause, i.e., as an educational aid.
2. To provide a proximate evaluation of the chances for entitlement on the claim, i.e., as an
evaluator or a decision-making aid.
3. To document the existing facts and views of the person analyzing the case, i.e., as a
documentary aid.
We will proceed by first describing the fundamental legal principles of the domain. We then discuss
the features of the system which enable it to satisfy the three design goals noted above. We end our
discussion with conclusions about the success of the system thus far and recommendations for future
work.
CHANGES CLAUSE CLAIMS AND ENTITLEMENT
The Changes clause provides a legal mechanism under which the Government may make unilateral
changes to suit their requirements (Directed changes), and the contractor can obtain suitable
compensation or equitable adjustment for the changes for actions of the government which it
considers as a change (constructive changes) (Cibinic 1981). A changes clause claim is usually an
attempt by the contractor to recover additional expenses that it has incurred or will incur in order to
comply with a directed or constructive change.
The Changes clause specifies a number of requirements for a change to be valid. Changes must be
within the scope of the work of the contract. Also, the contractor must comply with the requirements
of providing adequate notice, within time limits set by the clause. Established contract interpretation
guidelines are usually applied to evaluate the contents as well as the quality of the claim. These
guidelines can be classified into three groups; language analysis, surrounding circumstances, and post-
interpretation dispute resolution principles (Cibinic 1981). Apart from these guidelines, the
contractor must satisfy several implied duties. The contractor has an implied duty to proceed with
the changed work, as well as a duty to clarify patent ambiguities before submitting a bid. The
contractor must have made a reasonable site inspection before bid and failure to do so will, in some
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circumstances, may invalidate the contractor's claim. Superior knowledge (prior knowledge) on the
part of either the Government or the contractor can tilt the case in favor of the other party.
Given this summary background it is apparent that judging the quality and validity of a Changes
claim is a difficult undertaking for those field engineers who have insufficient legal training. The
following sections describe how the system is structured to allow it to make this proximate evaluation.
PROXIMATE ANALYSIS
The knowledge base used in CGS has been obtained in a number of ways; from past research,
literature, case law and actual experts. Valuable insight for this system has been obtained from our
previous work with DISCON (Kraiem 1988a) and Claims Guidance System (Adams 1988). The
knowledge for the system is organized into production rule groups and the rule groups are organized
into inference trees. The purpose of the group trees is to organize the knowledge and to direct the
analysis along a reasonable inferencing path. A typical rule group tree is shown in Figure 1.
As a result of our knowledge acquisition efforts we identified 20 different legal issues which were
potentially applicable to change claim analysis. The complete list of legal issues is reproduced in
Table 1. No single issue is determinative of the outcome of a claim. Evaluation is based on all of the
facts and circumstances of each case.
1. Scope of Work
2. Implied Warranty
3. Impossibility
4. Read as a Whole
5. Prior Course of Dealing
6. Explanation Prior to Dispute
7. Interpretation Different than Intention
8. Silence as Approval
9. Normal vs. Technical Meaning
10. Enumerated List
11. Trade Practice
12. Omissions
13. Order of Precedence
14. Parole Evidence
15. Duty to Inquire
16. Contra Preferentem
17. Site Inspection
18. Superior Knowledge
19. Final Payment
20. Notice Requirements
Table 1: 20 Legal Issues
Because the Changes clause is so broad, claims can be made under it based on number of different
legal theories. Some of the legal issues are appropriate for some claims and not appropriate for others.
One question confronted early in the design of CGS was whether a claim would need to navigate all
of the potential issues or just the subset pertinent to that particular claim. A system which forced
each candidate claim to negotiate all of the issues was easier to develop. However, such a system
would be wasteful of the user's time and it could lead to inappropriate reliance on irrelevant issues.
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The decision was taken to design an expert system within the COS expert system whose only job is
to select the appropriate legal issues for the claim to negotiate. This expert sub-system was called
SELECTOR.
SELECTOR
The SELECTOR program was developed to conduct a pre-analysis of constructive Changes claims.
The reasoning used in SELECTOR initially focuses on the primary basis of the dispute. SELECTOR
suggests three primary bases:
BASIS 1: The contractor has encountered difficulty in completing the work either due to a design
defect (for design specs) or due to unforeseen circumstances (for performance specs).
BASIS 2: The contractor and the owner disagree on what work is called for under the contract due
to some discrepancies in, or different interpretation of, the contract requirements.
BASIS 3: The contractor claims that the owner, by its action or inaction, caused the problem.
Depending upon the basis, SELECTOR then identifies the appropriate theory of recovery and chooses
the appropriate contract issues to test the validity of the theory. For example, if the basis of the
dispute is an alleged defect in the specification (BASIS 1 - Design Spec) then the theory of recovery
is "Implied Warranty of Specification". In contrast, if the dispute is based on an alleged unforeseen
difficulty (BASIS 1 - Performance Spec) then the theory of recovery is "Impossibility of Performance".
The theory available under BASIS 2 is "Contract Interpretation" with various sets of issues being used
for different types of disagreements. Typical issues for "Contract Interpretation" are:
Read as a Whole
Order of Precedence
Trade Practice
Normal vs. Technical Meaning
Omission
Enumerated List of Items
Additionally, if there is pre-dispute evidence, then some of the following issues are also checked:
Prior Course of Dealing
Interpretation Different than Intent
Parol Evidence
Site Inspection
Superior Knowledge
Finally, if the basis of the dispute is "Owner Actions" (BASIS 3), then the guideline is "Silence as
Approval" or "Superior Knowledge". Clearly, SELECTOR is more complex than the preceding
paragraphs suggest, by using SELECTOR the user avoids the need to check all of the guidelines
shown in Table 1.
INFERENCE MECHANISMS AND UNCERTAIN REASONING
The advantages of selector notwithstanding, a comprehensive analysis of a Changes clause claim could
involve five or six different issues. Some of those guidelines might point to a valid claim; others
might indicate an invalid claim. The next challenge in developing CGS was developing a suitable
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inference mechanism. Several alternatives were tried before the final scheme was selected. COS
draws a conclusion from the sub-conclusions of each of the issues selected by SELECTOR. The task
of the inference mechanism is to combine the various sub-conclusions into a rational overall
conclusion. The approach finally used in CGS is based on two primary variables, GP and CI:
GP: For each legal issue, a variable called GP (Government Position) is defined. GP
measures the strength of the owner's (i.e., government's) position on a given issue on a scale
of -100 (strongly against) to +100 (strongly for).
CI: For each legal issue, a variable called CI (Certainty Indicator) is defined which is
measured on a scale of 0 to 1.0. CI is the sole carrier of uncertainty in the system.
Uncertainty accumulates locally (in each issue) for each CI when the user indicates some level
of uncertainty regarding the input to the systems. The system allows most questions to be
answered on a scale of Definitely No - Probably No - Possibly No - Unknown - Possibly Yes
- Probably Yes - Definitely Yes. If the user ever chooses the Probably or Unknown
responses, the CI (i.e., the level of certainty in the conclusion) is reduced.
The product of the GP and the CI values are found and tested to ensure that they pass a threshold
value. The threshold serves to remove any GP values which have been so diminished by low
confidence (i.e., low CI values) as to become suspect. The system potentially contains 20 GP-CI
products which are then weighted and combined to form a final conclusion. The weights for each
issue are chosen to reflect the relative importance most courts and Boards of Contract Appeal allocate
each issue in reaching their judgments. The weights used in the current implementation of CGS are
shown in Table 2. Note that the weights range from 1 to 6, where 6 represents the most significant
issues.
The system uses the product of the negative GP/CI values to determine the strength of the
contractor's position and the product of the positive GP/CI values to determine the strength of the
owner's (government's) position. Conclusions about the results of the claim are constructed depending
upon whether the respective positions are Weak, Moderate or Strong. In close cases, i.e., where both
parties have cases of similar strength, the system issues a caution to that effect. Otherwise, the system
concludes for the strongest party using appropriately weak or strong language, as well as language
indicating the confidence of that conclusion.
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Issue
1 . Scope of Work
2. Implied Warranty
3. Impossibility
4. Read as a Whole
5. Prior Course of Dealing
6. Explanation Prior to Dispute
7. Interpretation Different
than Intention
8. Silence As Approval
9. Normal vs. Technical Meaning
10. Enumerated List
1 1 . Trade Practice
12. Omissions
13. Order of Precedence
14. Parole Evidence
15. Duty to Inquire
16. Contra Preferentem
17. Site Inspection
18. Superior Knowledge
19. Final Payment
20. Notice Requirements
Weight
2
6
4
6
6
6
4
4
5
5
5
5
5
3
3
3
1
1
2
2
Table 2: Weights Used for Final Conclusion
PRELIMINARY TESTING
The system for determining the final conclusions resulted from several design-test-redesign iterations.
The system behavior was first tested against existing case law to ensure that its results conformed to
current judicial opinion. Each version of the knowledge system was tested by four evaluators against
10 different cases from the Boards of Contract Appeals (BCA). A listing of the cases used for these
analysis can be found in Appendix 1. The result from each test case was classified as belonging to
one of three outcomes:
Group 1 - The system reached the same conclusion as the BCA and for the same reasons.
Group 2 - The system reached the same conclusion as the BCA but using a different line
of reasoning.
Group 3 - The system reached different conclusions from the BCA
Of the 40 test cases (4x10 cases) used to evaluate the current system, 28 were correct for the correct
reasons (Group 1), 3 were Group 2 and the remaining 9 cases (22.5%) resulted in conclusions which
were different from the BCA (Group 3). While the 70% (28 of 40) success rate of this version of CGS
is not good enough for a final system, it is good enough to encourage us to continue development.
When we analyze the cases which reached inappropriate results we find that all three of the Group
2 cases and five of the nine Group 3 cases resulted from difficulties with the "Implied Warranty"
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portion of the analysis. Clearly one of the priorities of this research program is to strengthen the
"Implied Warranty" analysis.
The next phase of testing, which is ongoing at this time, is testing with a group of field engineers in
actual field conditions. The purpose of this round of testing is not only to verify that the system gives
correct answers, but also to validate the concept of the system as a training aid for inexperienced field
personnel.
EXPLANATION AND TRAINING
Expert system programs have a unique capability to provide explanations of their behavior to their
users. In the design of COS we tried to capitalize on this explanation capability to provide the field
engineer with a construction claims decision support environment. The importance of the training
aspect of this claims guidance was best described in a treatise on legal reasoning in expert systems
(Gardner 1987). According to Gardner, easy cases are settled by rules established by statutory and
case law. When the accepted rules conflict with each other, then cases (the difficult cases) are settled
by application of principles. CGS, like most current expert systems, is a rule based system and
therefore, it is relatively adept at reaching correct "rule based" decisions for the easy cases. When CGS
is faced with a case with conflicting rules the system must rely on some automated inferencing scheme
to arbitrate between the conflicting rules. The current version of CGS uses the previously described
system of weights, thresholds and certainty indicators. There are many other artificially intelligent
approaches to uncertain reasoning and conflicting evidence (Bhatnagar 1986). We investigated several
advanced approaches to automated reasoning in the course of this project and we concluded that a
better long term goal was to let the people do the difficult reasoning and let the computer support the
process of difficult reasoning. That is, it is very important to educate the users as to the principles
involved when rules conflict so that the system queries can be answered correctly. To that end we
provided the users with a continuously accessible decision support system. The support system was
implemented using the "hypertext" facility of the expert system shell.
Five major features have been provided for decision support to aid the field engineer:
1 - General Information
2 - Explanation
3 - Citation
4 - Quotation
5 - Examples
Figure 2 shows a typical question screen from the system with the hypertext explanation features
shown below the question. These features appear in inverse video on the screen. They can be
activated either by a mouse or by a function key. The control returns to the original screen as soon
as the user is done with the decision support screen and presses the spacebar.
All five decision support features are designed to help the system user gain a better understanding
of the principles involved at a given point of a consultation. The General Information screen appears
at the beginning of the analysis of each of the 20 issues to explain the nature of the issues and how
it relates to the other issues of the analysis. The Explanation feature provides additional explanation
about each question being asked as part of an issue. Explanations can include elaborations,
definitions, further information on the issue and help in responding to the question. The Example
feature provides hypothetical examples of the application of the principle or legal rule involved.
Often these examples are taken from BCA cases. Quotations provide pertinent explanatory text found
in BCA or appellate court rulings where the case provides an exceptionally lucid description of the
principle or legal rule involved. The Citations feature provides a list of citation on which the other
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help screens are based. Figures 3 through 7 are examples of each of the five decision support
facilities included in CGS.
These decision support features are designed to help the field engineer understand the important
principles. However, it is essential that the system not instill over confidence in the field engineer.
We have taken great care to provide sufficient cautions in the system regarding the benefits of
professional advice. Even so, there are those who criticize this work saying that it impinges on the
domain of attorneys and that engineers should not make legal or quasi-legal determinations. Yet,
engineers dp. make such determinations every day at construction projects. In developing this system,
we are not trying to require engineers to make legal judgments; rather, we are attempting to improve
the quality of the judgments which engineers are already required to make.
DOCUMENTATION AND REPORTING
At the end of the consultation session, the system generates a report which includes general
information about the case at hand, all questions asked and their responses, all relevant information
such as dates, which was provided by the user. In addition, the report includes any clarification or
further information requested by the system, and all the conclusions provided by the system, and all
the additional information provided by the user during the session. The final report can be provided
as an ASCII text file or as a printed report. It can be used for documentation of the consultation, or
it may be sent from the field office to a central claims office for review before further action by the
field.
CONCLUSIONS
The Changes clause expert system is designed to provide pre-legal assistance to inexperienced site
engineers in handling potential claims under the Changes clause of a standard federal construction
contract. It is designed to evaluate the validity of a claim, educate the user as to the legal principles
involved, and document the facts and reasoning about the claim. This expert system has been
designed to function on microcomputers with standard capabilities and its intended use is to be at the
actual sites of construction.
Until we have more field trials we cannot recommend how to best use the system in practice.
However, several potential modes of use are possible. The most obvious mode is to allow the
government's field engineering staff to use the system by all junior engineers as a means of education
and to improve the quality of claims analysis. The system produces ample documentation of the facts
of the case and the thoughts and reasoning of the engineer who analyzed the case. In remote
locations, the system generated report can be sent on for further analysis.
Another mode of use for the CGS system is as a vehicle for alternative dispute resolution (ADR). Two
mechanisms suggest themselves, a cooperative system and a competitive system. In the competitive
system both parties to the dispute would have access to the system. Each side would run the system
and then compare notes. If used in this way the system would serve to identify areas in which the
parties agree and in which they disagree. By highlighting the areas of disagreement, the scope of the
required negotiations can be limited. In the cooperative approach, both sides would run the system
together. They would jointly answer the questions posed by the system. By cooperatively running
the system, the two sides would be furnished with a device to facilitate a dialogue regarding the facts
of the case (Kayman 1991).
We believe that CGS and its associated claims modules have potential for improving the decisions of
field engineers. Much more information is available about this work. Those interested in a
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comprehensive description of the Changes clause expert system are requested to refer to our previous
work (Dagli 1990, Gjertsen 1990 and Rotar 1990).
ACKNOWLEDGEMENTS
The work here is the result of the efforts many people. To Dhaval, the author of the original system;
to Knut who selected the SELECTOR; to Mike who kept us honest; to Michael our resident legal
eagle; and to Sharon our resident conscience; Thanks. Thanks also to our committee of domain
experts from the Corps of Engineers and the EPA for the contribution of their time and expertise.
Finally, thanks to CERL and EPA for funding this exciting and important work.
REFERENCES
Adams 1988
Bhatnagar 1986
Cibinic 1981
Dagli 1990
Diekmann 1990
Gardner 1987
Gjertsen 1990
Kay man 1991
Kim 1989
Kraiem 1988a
Adams, Kimberley K., "The Development of an Expert System for the
Analysis of Construction Contract Claims," unpublished M.S. Thesis,
University of Illinois, Urbana-Champaign, Illinois, 1988.
Bhatnagar, Raj K., and Kanal, Laveen N., "Handling Uncertain Information:
A review of Numeric and Non-numeric Methods," in Kanal, Laveen N., and
Lemmer, John F., Uncertainty in Artificial Intelligence. North-Holland,
Amsterdam, 1986.
Cibinic, John Jr. and Nash, Ralph Jr., Administration of Government
Contracts George Washington University, 1985 (2d ed.).
Dagli, Dhaval, "An Expert System to Provide Prelegal Assistance in the
Handling of Potential Claims Under the Changes Clause," Unpublished M.S.
Thesis, University of Colorado, Boulder, Colorado, 1990.
Diekmann, James E. and Kraiem, Zaki, "Uncertain Reasoning in Construction
Legal Expert Systems," ASCE Journal of Computing in Civil Engineering, Vol.
4, No. 1, January 1990.
Gardner, A., Artificial Intelligence and Legal Reasoning. MIT Press 1987
Cambridge, Massachusetts, 1987.
Gjertsen, K., "An Expert System for Claims Classification," Unpublished M.S.
Thesis, University of Colorado, Boulder, Colorado, 1990.
Kayman, M. L. and Kim, M. P., "Expert Systems in Alternative Dispute
Resolution," Proceedings of the Third International Conference on Artificial
Intelligence and Law (published June 1991).
Kim, M. P. and Adams, K., "An Expert System for Construction Contract
Claims," Construction Management and Economics 1989, at pp. 249-262
Kraiem, Zaki J., "DISCON: An Expert System for Construction Contract
Disputes", Unpublished Ph.D. Thesis, University of Colorado, Boulder,
Colorado, 1988.
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Kraiem 1988b Kraiem, Z. and Diekmann, J., "Representing Construction Contract Legal
Knowledge," ASCE Journal of Computing in Civil Engineering, Vol. 2, No.
2, April 1988.
Levitt 1987 Levitt, Raymond E., "Expert Systems in Construction: State of the Art," in
Expert Systems for Civil Engineers: Technology and Application, ed. Mary
Lou Maher, American Society of Civil Engineers, 1987.
Rotar 1990 Rotar, M. A., "Evaluation, Testing and Modification of an Expert System for
Claims Analysis Under the Changes Clause," Unpublished M.S. Thesis,
University of Colorado, Boulder, Colorado, 1990.
APPENDIX 1: LIST OF CASES
Century Constr. Co. v. United States. ASBCA 31702, 89-1 BCA (CCH) 1F 21,333 (Oct. 18, 1988).
Trescon Corp. v. United States. ENGBCA 5253, 88-3 BCA (CCH) T 21,163 (Sept. 23, 1988).
Caddell Constr. Co. v. United States. ASBCA 33792, 89-1 BCA (CCH) IF 21,201 (Sept. 14, 1988).
Guv F. Atkinson Co. v. United States. ENGBCA 4771, 88-2 BCA (CCH) U 20,714 (Apr. 29,
1988).
Robert E. McKee. Inc. v. United States. ASBCA 33770, 87-2 BCA (CCH) 11 19,916 (June 1, 1987).
Wallace L. Boldt. Inc. v. United States. ASBCA 27188, 84-1 BCA (CCH) 1T 17,173 (Feb. 16, 1984).
Butt & Head. Inc. v. United States. ASBCA 26186, 84-1 BCA (CCH) f 17,103 (Dec. 21, 1983).
G. G. Norton Co. v. United States. IBCA 1647-1-83, 84-1 BCA (CCH) 1T 16,923 (Nov. 14, 1983)
W. M. Schlosser Co.. Inc. v. United States. VABCA 1802, 83-2 BCA (CCH) 1F 16,630 (June 21, 1983).
Uribe Co. v. United States. AGBCA 80-114-1, 83-1 BCA (CCH) 1f 16,199 (Dec. 17, 1982).
481
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Precedence^
\\Q_PRECEDENCE: PRIOHITIES
Exp.,Q,C,Exam.
Unknown unacceptable)
Is (here a specific clause or provision In the contract
slating the priority ol the contract documents?
Yes
Not Applicable
VO.PRECEDENCE: CLAUSE
Exp.,C,Exam.
Is the order ol precedence clause
In lavor ol the Owners position?
Unknown
Would you like to
go back and change
your response?
DYfrPY
Please explain
why the clause)
lavors the
Owner's
PN
Unknown
\\O_PRECEDENCE: ASSERTION.VALID
Exp.,C,Exam.
NOTE:
In case ol absence ol such a specific clause,
the general rule ol common law Is that specific
provisions will prevail over general provisions,
and that written or typed provisions will prevail
over printed provisions.
QUESTION:
Considering this rule, do you think the
Contractor's assertion is valid?
Please explain
why the
Contractors
assertion is.
valid
Please explain why
the clause does not
lavor the Owner
position?
Please explain wh
Unknown
Would you like to
go back and change
your response?
No
^PRECEDENCE: ld\
V GPtS.O....-J
Figure 1. Sample Rule Group Tree
482
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Figure 2. Sample Question Screen
483
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GENERAL INFORMATION
Order of Precedence:
Contracts often will contain a clause which
specifically delineates the priorities in the
contract documents. Such a clause may/ for example,
state that anything typed in by the parties takes
precedence over information on a preprinted form. In
interpreting the contract, if two provisions conflict
the order of precedence clause determines which
interpretation the parties should follow.
In the absence of a specific order of precedence
clause, the courts have developed several general
rules. These general rules apply unless they are
superseded by specific contract language:
1. Specific provisions prevail over
general provisions;
2. Typed clauses prevail over hand
printed clauses; and
3. Specifications have precedence over
drawings.
4. Large scale drawings prevail over
smaller scale drawings.
Figure 3. General Information Screen
ORDER OF PRECEDENCE
*** Is there a specific clause in the contract stating
the priorities of contract documents or clauses?
Quotation
"A special provision noting the order of
precedence of contract clauses takes over to express
the contractual intent by specifically providing which
of the two conflicting requirements shall take
precedence and be effective." John A. Volpe
Construction CO., VACAB 638, 68-1 BCA P6857 (1968).
Figure 4. Quotation Screen
484
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ORDER OF PRECEDENCE
*** Is there a specific clause in the contract
stating the priorities of contract documents or
clauses?
Explanation
Owner contracts often contain specific
provisions dealing with the order of precedence among
the various portions of the contract should 2 or more
clauses appear to be in direct conflict. The use of
such a clause has the advantage of allowing for a
mechanical resolution of a conflict. Such a clause
may, for example/ state that any requirements noted
in the attachments to the contract provided by the
parties take precedence over information in the
specifications. In interpreting the contract/ if two
provisions conflict, the order of precedence clause
determines which interpretation the parties should
follow. If the contract contains such a clause it is
binding on both parties.
If, however, the conflict is obvious or patent,
the order of precedence clause may not be applied
because the Contractor has an affirmative duty to
clarify patent conflicts, errors and omissions with
the Owner prior to submitting his bid.
Figure 5. Explanation Screen
485
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ORDER OP PRECEDENCE
*** Is there a specific clause in the contract stating
the priorities of contract documents or clausejs?
citation . - . '- .' • • , .-.. . > v'; '::-'" •• :" •''•.• •:. ff-' -
Hensel Phelps Construction Co. v. U.S., CAFC No. 88--
1545 (Decided September 29, 1989).
Edward R. Harden Corp. v. U.S., 803 P.2d 701 (Fed. cir.
1986) . .. . ' • ."•'.• . : ,-V ., .' ,:V V ' i " '/'• .^. '
Franchi Construction Co. v. U.S., 609 P.2d 984 (1979).
De Palco, Inc., ASBCA 20630, 76-2 BCA Pll>971 (i976)>
Figure 6. Citation Screen
ORDER OF PRECEDENCE
*** Is there a specific clause in the contract stating
the priorities of contract documents or clauses?
Example
FAR 52.214-29 (Jan 1986) provides a sample order
of precedence clause: "Any inconsistency in this
solicitation or contract shall be resolved by giving
precedence in the following order: (a) the Schedule
(excluding the specifications); (b) representations and
other instructions; (c) contract clauses; (d) other
documents, exhibits, and attachments; and (e) the
specifications."
Figure 7. Example Screen
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THE TUNNEL SYNDROME SOLUTION-CAN IT BE
APPLIED TO CLEANUP PROJECTS?
(Author(s) and Addresse(s) at end of paper)
INTRODUCTION
Some innovative solutions unique to tunneling projects have
recently achieved success in resolving disputes and reducing
claims. The purpose of this paper is to suggest that there are
similarities between hazardous waste cleanup and tunnel projects
and that those solutions can be applied with equal success.
What are the most common causes of construction disputes?
Consensus is that these are:
• Defective contract documents (i.e., errors and omissions)
• Unknown conditions
• Incompetent contract administration
• Incompetent contractor project management
• Interference of third parties
BACKGROUND
Up until the mid-1960s, the construction industry in the United
States functioned as a triad working as a team. The owner
established performance standards and criteria and retained
design professionals to develop the basic concepts and design for
the desired end product. The owner and the design professional
acting as the owner's agent then engaged a general contractor to
perform the physical construction in the field. Parties employed
an experienced cadre of professional inspectors and craft
supervisors. As problems arose, either with contract documents
or unknown field conditions, a team effort was utilized to
quickly solve the problem and devise an equitable contract
adjustment within the terms of the contract.
487
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Why have conditions changed? Three factors have greatly
influenced the current construction contract environment. These
are:
• The development of risk avoidance language for contract
documents.
• The emergence of regulatory considerations wherein the
scope and standards for the project are established by a
third-party agency rather than the owner who controls the
purse strings.
• With more emphasis on risk transfer, the emphasis has
shifted to individual objectives and rights, all subject to
disagreement and litigation.
DISCUSSION
Of all the risks facing both tunneling and hazardous waste
cleanup projects, none is more significant than the ground
itself, i.e., the unknown conditions.
The design professional needs information about conditions in the
ground to design a product that will meet performance, cost and
operational requirements of the owner (or of EPA regulatory
standards). The contractor needs information in order to select
crews, equipment, methods and sequence which will be the basis
for his price quotation. Then there is a third factor which is
that the ground may not behave as anticipated when the
construction methods and means are applied. A. A. Mathews in his
paper of October 1987, entitled "Special Contract Provisions for
Reducing Construction Costs," summarized this phenomenon as
follows:
It is well known that the behavior of an underground
structure is influenced by the construction method and
the quality of its workmanship, as well as the design
itself. Likewise, the construction method must be
compatible with the geotechnical conditions to be
encountered. There is, then, an ongoing and intimate
relationship between the studies of the geotechnical
engineer, the work of the designer, and the operations
488
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of the builder. While the designer must understand the
geotechnical conditions which will affect his design,
the design must be compatible with the methods which the
contractor is likely to use.
In other words, the ground is the common adversary, and the
solution is to join forces to defeat it. This concept of
tunneling as a battle was first set forth by Gary S. Brierley in
his paper entitled "Tunneling: A Battle Against the Ground":
Successful tunneling is analogous to winning a battle.
On the basis of almost 20 years of experience in the
fields of geotechnical engineering and tunneling, the
author has come to view the Ground as a tenacious
adversary. Merely by doing what comes "naturally" when
"provoked" by human beings, the Ground presents an array
of defenses that make even good field commanders blanch
at the prospect of battle.
Basically, what we are concerned about in this paper is how the
owner approaches the issue of unknown conditions which result in
changed conditions pertaining to the ground as the project
proceeds. In this case, the owner could be a private party, a
committee of contributors or sponsors, a state regulatory agency
or a public agency. Before Differing Site Conditions and Changed
Conditions clauses were incorporated into construction contracts,
contractors working under fixed price or guaranteed maximum price
contracts would include in their bids an amount to cover the cost
of contingencies derived from unanticipated or unknown conditions
at the site. Often these contingencies did not occur or did not
incur in the amount anticipated. To avoid the increased costs
that resulted from this practice, the use of a Differing Site
Condition clause was instituted in federal contracts.
Theoretically, this eliminated the need to include a contingency
factor as the contract contained provisions for a price
adjustment and a time extension.
In the process of design, the owner's team utilizes the services
of a geotechnical engineer who develops data and often provides
489
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interpretations. Traditionally, the design professional has
viewed these reports strictly for the purpose of design and has
provided the data to the contractor only because of the case law
surrounding superior knowledge. Disclaimers are inserted, and
there is often an attempt to transfer risk of the "ground" to the
contractor. Just as often, this results in claims. (Refer to
Figure 1.)
Even when Differing Site Condition clauses are used, disputes
often result over the interpretation of what was "materially
different" or what was a condition that was not to be anticipated
at this particular site.
Disputes were a frequent result of these disclaimers and
exculpatory clauses. A whole body of case law has evolved. In
light of the fact that the owner and the design professional have
months and years of "decision time" to obtain and analyze
geotechnical data, while the contractor has usually about 30 to
45 days to put his bid together, courts tend to apply a "fair and
reasonable" approach to give the contractor an equitable
position. If the contractor uses the best available information
and good judgment in selecting the crews, equipment, means and
methods but then finds that the ground requires a change of crews
and equipment at increased cost, the courts will often rule that
this is prima facie evidence that a differing site condition has
occurred. (Refer to Figure 2.)
This concept of the ground as the common enemy has led to the use
in tunneling of some unique third-party dispute resolution
processes built around a common geotechnical data base and a
requirement that the contractor's bid documentation be available
for dispute resolution purposes.
The dispute resolution alternative process now being used for
tunneling consists of three elements.
490
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• A Dispute Review Board which is formed at the time that the
project starts and consists of a representative appointed
by the contractor, a representative appointed by the owner
and a neutral third party appointed by the other two.
• The concept of a single geotechnical design report used by
both the design professional and the contractor and
containing all information and opinions developed during
the prebid phase.
• The concept of placing in escrow bid documentation to be
used by the dispute review board.
If a contractor can demonstrate that the selection of crews,
means and methods was reasonable and that a change in crews,
means and methods is now required because of ground problems,
this in itself may be proof of a changed condition. (See Figure
3.)
The Straight Creek Tunnel (now called the Eisenhower Tunnel) in
Colorado is an excellent example of how this concept developed.
The Eisenhower Tunnel crossing the Continental Divide at 1-70
consists of two bores. The first bore containing two lanes of
traffic had significant ground problems. The geotechnical
information was probably the most extensive for any tunnel in the
world. Investigation revealed that the claims arose not because
different materials were encountered but because the ground
behaved differently than expected, and thus the crews, means and
methods selected by the contractor at bid time had to be
changed. On the first bore upon receipt of a claim, the Colorado
Highway Department made the decision that the material was as
anticipated in the geotechnical reports; therefore, conditions
were not changed. The argument revolved around the issue as to
whether or not the material behaved as anticipated. By mid-1970,
losses to the contractor had increased to the point where it
could no longer continue normal operations without going
bankrupt. The highway department had but two alternatives which
were to negotiate an addendum to the existing contract or declare
491
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the contractor in default and attempt to have the bonding
companies take over the job.
Wisely, the highway department decided to settle the claim for an
additional amount of $5 million with future tunnel work to be
paid on a time-and-material basis. The highway department never
would admit that a differing site condition had been encountered.
Bidding and construction for the second bore was approached in an
entirely different manner utilizing the concepts discussed
above. A Dispute Review Board was established. Bid
documentation was placed in escrow to be examined at any time by
the Chief Engineer of the state highway department to determine
the contractor's bid concept. Rather than bid as a lump sum plus
profit, costs were bid as a unit price plus a fixed fee. All
disputes on the second bore were satisfactorily resolved.
Starting with the Eisenhower Tunnel second bore in 1975, the
disputes review board concept has been utilized on a number of
major construction projects, most notably in the underground
construction field. To date, 12 completed contracts and 21
contracts under construction employ this approach. Most
importantly, where disputes review boards are employed, there has
been no litigation. Currently, disputes review boards are
planned for 26 future projects in the underground construction
area alone, primarily tunneling.
The other two elements of the process, the geotechnical design
summary report and the escrowed documents, are more controversial
yet are important elements of the process.
The concept of a complete Geotechnical Summary Report for use by
both the designers and the contractor was first presented as
early as 1974.
492
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"Better Contracting for Underground Construction,"
National Committee on Tunneling Technology, National
Technical Information Service, November 1974
DISCLOSURE OF ALL SUBSURFACE INFORMATION, PROFESSIONAL
INTERPRETATIONS, AND DESIGN CONSIDERATIONS
Owners, engineers, and contractors agree that adequate
and timely subsurface study of the facility site is
necessary. . . . Difficulties also arise from the
failure to make the data and interpretation thereof
available to those people interested in bidding on the
work.
. . . Although engineers consider that where time
and money are available, subsurface information adequate
for design purposes is obtained, contractors maintain
that sufficient information on subsurface conditions to
eliminate contingencies from their bids is never
provided. Information that is considered to be basic
data includes such items as the following:
• Rock cores or soil samples recovered and
photographs of these.
• Water-level measurements, including times, dates,
and correlation with drilling operations.
• Method and equipment used in sampling.
• Observations made during drilling with respect to
drilling rate, drill-water conditions, bit pressure, and
rotational speed.
• Field-test data, e.g., pump or packer tests,
records of geophysical down-the-hole tests, deformation
and strength tests.
• Field or laboratory test results on specimens,
including petrographic examinations.
• Certain measurable items in the core log,
including sample depths and core recovery.
• Identification and description of lithological
and structural units as found in outcrops and rock cores
or soil samples.
• Assessments of characteristics of discontinuities
such as planeness, roughness, coatings, filling
material, and leaching.
493
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Other subsurface information, although not in the
same category as geologic data, is quite as basic to the
contractor's need-to-know. Knowledge of the exact
location and condition of existing substructures and
utilities is an important prerequisite to design of the
project and just as important in the development by the
contractor of the method of constructing the project as
designed.
Opinions of qualified professionals regarding the
characteristics of the subsurface are rarely given to
prospective bidders, in the belief that such disclosures
will only promote the subsequent submission of claims by
the successful contractors. Whether or not this is
true, if interpretative reports were obtained they must
be revealed in the event of litigation. Therefore,
prospective bidders should receive these reports. The
more information they receive, the more accurately they
can evaluate the job. ... If adverse conditions, not
apparent from the basic data, were foreseen by the
owner's geologist, these should be disclosed prior to
bidding and not during the course of costly litigation.
• • •
Geotechnical interpretation involves geological
assessments of geophysical exploration, assessments of
soil or rock characteristics such as relative strengths,
hardness, induration, and degree of weathering or
alteration, geological maps and sections, soil profiles,
and all recommendations and comments pertaining to the
design and construction of the works based on
examination of the factual data.
It is not customary for design engineers to reveal
their professional judgments in formulating a design;
however, if the geotechnical report has a significant
effect on the design, then this information should also
be revealed.
In sum, all subsurface data obtained for a project,
professional interpretations thereof, and the design
considerations based on these data and interpretations
should be included in the bidding documents or otherwise
made readily available to prospective contractors. Fact
and opinion should be clearly separated. . . .
Some disclaimer is still appropriate pertaining to interpretation
and opinion. The report referred to above recommends:
494
-------
• Information obtained by others, perhaps at other
times and for other purposes, which is being furnished
prospective bidders in order to comply with the legal
obligation to make full disclosure of all available
data.
• Interpretations and opinions drawn from basic
subsurface data, because equally competent professionals
may reasonably draw different interpretations from the
same basic data.
Information, interpretations, and opinions, such as
described above, should be specifically identified as
such and differentiated from the basic subsurface data
being furnished. Further, if disclaimer is made of
responsibility for accuracy, then notice should be given
that such information, interpretations, and opinions are
not included as a part of the contract. Bidders will
then be in a position to evaluate them and price their
bids accordingly.
CONCLUSION
The escrow document concept is even more controversial.
Nevertheless, it has been used with great success on a number of
tunnel projects. It is based upon the concept of an equitable
adjustment wherein the contractor is to stay "whole," that is, in
the same position as if no problems had occurred. (Refer to
Figure 3.) If all parties accept that the ground is the common
enemy, then the contractor's bid documentation should reflect how
the contractor interpreted the available information in his
selection of crews, equipment, methods and the risk leading to
profit. The bid documentation in escrow provides a basis for
keeping the contractor "whole." Escrowed bid documentation
should assist the disputes review board in arriving at an
equitable adjustment.
The concept of the disputes review board in place from the
beginning of the project integrated with escrowed bid documents
and a geotechnical summary report should be considered for
hazardous waste cleanup as a means of avoiding or settling
disputes and facilitating the progress of this important program.
495
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REFERENCES
Brierley, G. S. "Tunneling: A Battle Against The Ground."
Brierley, G. S. and Cavan, B. 1987. "The Risks Associated With
Tunneling Projects." Tunneling Technology Newsletter.
Environmental Perspectives 1990.
Groten, J. P. 1990 "Dispute Resolution Devices for the
Construction Industry: An Overview." The Punch List, Vol. 13,
No. 3.
KC-News 1990. Volume VII, Number 3
Mathews, A. A. 1987. "Special Contract Provisions for Reducing
Construction Costs."
"Better Contracting for Underground Construction, National
Committee on Tunneling Technology" 1974. National Technical
Information Service U.S. Department of Commerce.
Sperry, P.E. 1976. "Evaluation of Savings for Underground
Construction" Made for the Subcommittee on Contracting Practices
U.S. National Committee on Tunneling Technology.
Author(s) and Addresse(s):
Norman B. Lovejoy
Kellogg Corporation
26 W. Dry Creek Circle
Littleton, Colorado 80120
(303) 794-1818
496
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Figure 1
The Ground
Basis for Bid vs. Basis for Design
Geotechnical
Data and Opinions
^
CO
Basis for Bid
• Crews
• Equipment
• Methods
• Sequence
• Profit
• Contingency
• Disclaimers
• Exculpatory Clauses
Basis for Design
• Performance
• Initial Cost
• Operational Cost
• Life Cycle Cost
LIBVG 4067 4/30/91
C& KELLOGG
-------
Figure 2
The Common Enemy
CO
00
Decision Time: Owner
Plans and Specifications
Geotechnical
Summary
The Ground
Cost Comparison
i
Crew, Equipment, Methods
Decision Time:
Contractor
Bid/Construction Period-
Claim
LIBVQ4O66 4/30/91
C& KELLOGG
-------
Geotechnical
Reports
CD
CO
• Crews
• Equipment
• Methods
Figure 3
Staying "Whole"
Estimate/Bid
Documentation
Dispute
Review Board
t
Modified
• Crew
• Equipment
• Methods
t
Problem with
Ground
Recommendation/
Decision
:-:^^^
LIBVG4065 4/30/91
BK KELLOGG
-------
The First Step for
Strategic Environmental Project Management:
Environmental Cleanup Project Contract
(Author(s) and Addresse(s) at end of paper)
1) INTRODUCTION
A complex threat to the world's population has emerged since
the demise of the cold war, namely, the destruction of the earth's
environment. It has been estimated that in the near future, the
industrialized nations of the world will need to spend 2.5% of
their gross national product on programs designed to repair the
environment. Environmental cleanup construction projects are
extremely costly and highly visible to the public. Resources
available to pay for these clean-up projects are increasingly
difficult to find. Because once strained international relation-
ships have become friendly, policy makers foresee a decline in
defense spending. This decline will create federal funds not
previously available, and according to Senator Sam Nunn, Chairman
of Senate1 Armed Forces Committee, the funds should be earmarked
for the restoration of the environment. Because a comprehensive
construction management plan for environmental cleanup projects has
never been developed, the Department of Defense (DOD), the
Department of Energy (DOE), and the Environmental Protection Agency
(EPA) have a clear and immediate interest in developing better
technologies for cost-effective methods of identifying, treating,
and cleaning up sites containing toxic, radioactive, and hazardous
materials. EPA and DOE district officers have also expressed an
urgent need for radioactive and hazardous by-product cleanup
guidelines. Research in this area will coordinate the development
of these cleanup efforts, ensuring that these toxins to the
environment are handled with the utmost efficiency. (7)
In June, Senator Nunn proposed the creation of a Strategic
Environmental Research Program to be administered by a new Defense
Environmental Research Council. "Understanding what we are doing to
the environment today, cleaning up the damage we have done in the
past, and modernizing U.S. industries and government to establish
and maintain technological leadership in this critical area in the
future," are the newest goals for policy makers.(9) Nunn believes
that environmental technology will be the growth industry of the
500
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next 20 years. Because forms of environmental destruction such as
global warming, deforestation and rapidly increasing atmospheric
concentrations of gases could exacerbate ethnic or regional
conflicts, Nunn says it is imperative for the U.S., especially the
defense establishment, to marshal a global response to these
problems by developing the technology to clean up our environment.
This development will also help DOD and DOE meet their environmen-
tal cleanup and treatment obligations more quickly, efficiently and
at a lower overall cost.
2) SIGNIFICANCE OF RESEARCH
2.1 Historical Background: The year 1990 was the 10th year
since the passage of the Comprehensive Environmental Response,
Compensation and Liability Act - the landmark legislation that
launched Superfund. The decision by Congress on November 1990 to
reauthorize Superfund virtually intact through 1995 will likely
give the program the opportunity to move forward unencumbered by
the rancor and stalemate that characterized its last reauthoriza-
tion in 1985-86. (5)
One of the most controversial aspects of the Superfund
makeover in term of construction management is its approach to
assessing construction riskiness and setting construction stan-
dards. For example, EPA should identify a construction's risks,
set cleanup objectives based on those risks, on the perspective
future of the site and on citizens' concerns, and then select a
construction standard from those among those alternatives that meet
the standards.
Another area of controversy is a lack of standard construction
guidance. It has been very confusing and hard for the construction
industry to work in the environmental cleanup construction projects
since practices on design and construction differed markedly from
region to region. At the recent Superfund conference in Washing-
ton, D.C., the private sector construction industry clearly
indicated that they would see more liability issues on federal led
501
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cleanup projects unless they are provided the standard technical
guidance in taking over construction risk assessments for all
Superfund sites. (11) Contractors and engineers are also concerned
about the ability to which the standard technical guidance provide
the useful data-base on new innovative construction methodology.
EPA Deputy Administrator told Superfund attendees that the
program remains beset by regulatory glitches, a lack of standard
construction guidance and "cultural" impediments such as liability
and risk aversion. "We hope that by moving on first two, we can
have an impact on the third," he said. (6)
2.2 Current Construction Practices; The United States has
led the world in the technological advancements made in construc-
tion management (CM) over the last thirty years. Despite infra-
structure construction capabilities that surpass those of any other
countries, the construction management strategies for environmental
cleanup projects are severely underdeveloped. Groundwater
barriers, surface seals/caps, solidification and stabilization
methods have been developed from general construction practices,
but these also suffer from a lack of sufficient long-term study.
The environmental construction segment of the industry is notorious
for it's lack of consistent project management guidance and lack of
qualified supervision. There are very few construction companies
that have attempted to build structures to aid in the cleanup of
the environment. Consequently waste treatment plants, landfill
sites, water treatment plants, radioactive waste disposal sites,
water reservoirs, and structures that prevent soil erosion present
unique problems for environmental protection managers. These
problems are compounded by high risks, fluctuations in federal
regulations and post-construction liability, all resulting in wary,
medium-size construction businesses that avoid environmental
construction altogether. (16)
There is uncertainty in the assessment of problems and
uncertainty in the solutions. Conventional methods are used
502
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currently in cleanup sites, but this has created a patch-work of
inconsistent methods, increased confusion and has only provided the
nation with a temporary solution for problems that last for
centuries. Non-conventional construction methods, non-guided
quality control systems, construction sites that are widely spread
out, and non-guided life-cycle activities have inhibited the
natural development of project management systems and the testing
of many different environmental construction projects.
The construction management system for environmental cleanup
projects differ fundamentally from conventional facilities
projects, creating a multitude of problems not found in conven-
tional construction areas. The difficulties of managing such
projects are compounded by a lack of well-documented guidance and
by procedural requirements imposed by the government agencies
involved. By integrating environmental construction needs with
infrastructure experience, better applications can be developed to
address the environmental problems facing the industrialized world.
With clear goals and objectives, the construction industry, policy
makers and researchers can insure that the United State's environ-
mental remediation construction capabilities will be on the cutting
edge of technology. This research is significant because we need
cost-effective construction management alternatives to plan,
execute and operate/maintain environmental remediation construction
projects.
2.3 Overall Objectives: The overall objective of this
research is to develop a Strategic Environmental Project Management
(SEPM) system. This is the first step towards establishing an
integrated environmental construction management system, designed
specifically for the contaminated site cleanup projects. There are
two primary objectives to this research.
The first, which is a prerequisite to the second, is to
acquire detailed information about the formation and character-
istics specific to environmental cleanup construction projects.
The SEPM system has an "Integration" feature to address the
503
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legal/contractual and financial/cost considerations
as they impact the technical requirements for a SEPM system.
Design, engineering, construction, operation, and maintenance
activities will also be defined during the explanation of technical
procedures for the SEPM system. Upon review by appropriate federal
agencies and private contractors, the manual version of SEPM
system, Draft Technical Guidance (DTG), will be produced in the
designated format at the end of first phase.
The objective of the second phase is to integrate and
implement the results of the first phase into the computerized SEPM
systems. The computerized SEPM system will also have the features
of database and decision support analysis to provide advisory
assistance for each component of the SEPM system. Those features
will support the management of environmental cleanup construction
projects and decision-making by providing lessons-learned and
advisory information based on similar experience with projects.
(12) Personnel without extensive first-hand experience in a
particular environmental construction project will benefit from the
expertise provided through examples from the SEPM system. The
breakdown of detailed research activities is shown in Figure 1.
2.4 Current Objectives: The objective of the current
research is to develop a Environmental Cleanup Project Contract
(ECPC) system, the first step towards technical requirements for a
SEPM system, designed specifically for the contaminated site
cleanup projects. A brief description of the process and of our
developmental work for the ECPC system are shown in the Appendix 1.
504
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Development of Manual Version of
Strategic Environmental Project Management Si
Technical
Requirements:
*Legal/Contractua
Issues
*Financial/Cost
Issues
1
Draf
1
I '
Technical
Procedures:
il *Design
"Engineering
"Construction
"Operation/
Maintenance
I
i
t Technical Guidance
(DTG)
/stem
13
ff
P
CO
0)
'. Research: "Ir
itegration"
Development of Computerized Version of
Strategic Environmental Project Management Sy<
1
Database
Function
t
Testing
U
I
Decision Support
Function
*
& Validation of System
1
ser Group Meeting
ij
stem CD
II Research: "Implementation"
Figure 1. The Breakdown of Research Activites
505
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3) SCOPE OF RESEARCH
3.1 Phase I Research Activities
a. Review current and recent environmental cleanup construction
projects; These include contaminated site clean-up
projects. Data and information will be obtained relative to
the general service provided under the projects, such as
feasibility study, development considerations, execution of
the projects, procurement experiences, facility requirement,
and performance of the facilities in service. Federal envi-
ronmental procurement personnel and their counterpart,
private developing and design-build-engineering contractors
will be consulted.
b. Identify Technical Requirements; Two key parameters will be
studied for the technical requirement of SEPM system. First,
in legal/contractual issues, considerations and parameters for
the scope of services included in contracts will be identi-
fied. Responsibilities of the involved parties, contract
duration, basis for contractor selection, contract enforcement
provisions, facility ownership, disposition of the facility at
the conclusion of the contract, and other relevant legal
contractual issues will also be covered in this issue.
Second, in cost/financial issues, economic analysis and
feasibility, construction accounting, construction insurance
handing liability change, costs and investment, and construc-
tion financial arrangement will be examined as they impact a
project's requirements and execution. Information will be
obtained through contact with the involved federal agencies
and user group meetings.
c. Identify Technical Procedures; Based on the identified
technical requirements, the content and composition of
technical procedures for environmental cleanup construction
projects will be identified. This includes the identification
of the appropriate sources for design, engineering and
506
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construction criteria and the composition of technical
requirements for a SEPM solicitation document. This also
includes initial project planning activities, solicitation
requirements and procedures, contractor selection criteria and
procedures, design/construction administration, and conditions
for the operation and maintenance of environmental construc-
tion projects.
d. Produce a Draft Technical Guidance (DTG); Upon review by
the appropriate federal agencies and private contractors, the
DTG for the SEPM system will be produced in the designated
format. The DTG system documentation shall provide a
complete functional description, system schematic, and unique
features of the environmental cleanup construction
project.
3.2 Phase II Research Activities
a. Computerize a Draft Technical Guidance; Integrate and
implement the Draft Technical Guidance into a PC-based
computerized system. Specific computer software such as
HYPEPJVIEDIA will be used in the computerized process of the
Draft Technical Guidance.
b. Add Database and Decision Support Functions: The two key
features functions will be added to the SEPM system to support
the management of environmental cleanup construction projects
and the decision-making by providing lessons learned and
advisory information based on similar environmental project
experience. First, the objective in providing the database
function is to translate data and resources through a series
of data generation, information gathering, information
processing, and physical realization cycles. Typically, the
construction database will be used by designers, architects,
contractors, and maintenance personnel. Each of them would
address different questions. However, they may have a common
507
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shared database. It becomes imperative that the system be
able to identify the user and defines intelligently the query.
Table 1 gives clearer view of the database scheme. At each
level it is obvious that the level of details and requirements
would be different. Second, the process models highlight the
specific nature of the decisions, feedbacks, and information
required to support the SEPM system. While each of these
decisions is made by different groups with unique experience,
using information and rules that seem radically different from
each other, there are many similarities. Specific decision
support requirements will be added in the SEPM system as
follows: (13)
1. Retrieve a single item of information,
2. Provide a mechanism for ad hoc data analysis,
3. Aggregate prespecified data,
4. Estimate the consequences of proposed decisions,
5. Propose decisions,
6. Implementation of decision,
7. Monitoring decision.
c. Conduct Testing and Validation of SEPM system; Due to the
fiscal and legal implications of the SEPM system it must be
very thoroughly tested. The DTG system documentation shall be
reviewed by professional engineers and contractors in the area
of environmental cleanup construction project. Suggestions
shall be solicited for modifications to the system, and all
noted errors and deficiencies will be corrected.
d. Conduct User Group Meeting; Input from knowledgeable
persons from the targeted user communities such as in the
Environmental Protection Agency (EPA) and US Army Corps of
Engineers (USAGE) shall be solicited. Their comments and
suggestions shall be requested concerning the utility and
completeness of the system, needed improvements in the user
interface, and DTG system documentation.
508
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Table 1. Database considerations for the SEPM system
Question Design activities
1 Identification
of pieces of data
2 Attribute
identification
3 Entity set
4 Use of entity
set
5 Users of
information
6 Identification
of user ' s query
7 Feedback
consideration
8 Updating
process
source
Process
model
Process
model
Process
model
Process
model +
grouping
Site interview
+ published
literature
Process
models +
site interview
Process
model +
queries
Resultant of
previous
seven stages
Kesuitant
Individual
identification
Qualitative
description
Grouping
of objects
Uses vs
classification
Users view of
information
system
General and
specific
queries
User interac-
tion require-
ments
Updating and
integrity
procedures
d. Conduct User Group Meeting; Input from knowledgeable
persons from the targeted user communities such as in the
Environmental Protection Agency (EPA) and US Army Corps of
Engineers (USAGE) shall be solicited. Their comments and
suggestions shall be requested concerning the utility and
completeness of the system, needed improvements in the user
interface, and DTG system documentation.
4) FUTURE RESEARCH
Through the proposed research, the principal investigator
plans to establish a platform for future investigations in life-
cycled project management system for environmental cleanup
construction project. The development of the SEPM system has been
recognized as the first step towards the goal of a life-cycled
project management system at a recent symposium for concerning
509
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federal infrastructure and environmental cleanup projects.(10) In
addition, the basic framework developed in this work will be an
important tool in related area of interest to the principal
investigator. This interest includes study of the development of
an Unified Project Model for Design/Engineering/ Construction to
represent environmental construction project data in real-time.
The common theme for all this work is the improvement of the state
of construction engineering practice by increasing our capability
to realistically analyze, construct, and manage environmental
cleanup construction projects.
Future research will develop a Life-Cycle Project Management
(LCPM) system to improve the integrated cost, schedule, and quality
management of environmental cleanup construction projects by
applying innovative productivity methods, assuring completion
within time and budget, and enhancing the quality of the con-
struction project. As described previously, the basic framework
for construction management strategies will be developed such that
it can be easily extended to include the interaction of more models
than will be included in the current study of SEPM model.
The intelligent cost and schedule control models will be
modified from traditional techniques in order to meet the unique
nature of environmental cleanup projects. An intelligent risk
management model will be developed and incorporated into the
integrated environmental LCPM model.
Further work is also envisioned to develop an innovative
application model for robotics, remote sensors, and other innova-
tive non-human technologies will also be developed and linked to
the risk management model and the integrated LCPM model. Also
innovative contract and quality control models have the potential
to be included for the integrated environmental LCPM model.
The current phase of research is an essential first step for
more advanced studies. By stydying the construction management
strategies for environmental cleanup construction projects, the
*
current work will help focus the direction of future research.
510
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REFERENCES
1. Butler, H.P-, "State Participation under Superfund,"
Hazardous Materials Control Research Institute, pp. 418-
422, 1982.
2. Clair, A.E. and J.S. Sherman, "Development of a Framework
for Evaluating Cost-Effectiveness of Remedial Actions at
Uncontrolled Hazardous Waste Sites", Hazardous Materials
Control Research Institute, pp. 372-376, 1982.
3. Galbraith, J.R., "Organization Design: An Information
Process View", Interfaces 4(3), 28-36, 1974.
4. Gay, F.P-, etc, "US Army Corps of Engineer Role in
Remedial Response", Management of Uncontrolled Waste
Sites, pp. 414-417, 1982.
5. Engineering News Records, "Superfund at 10: EPA's
Battered Child", Special edition, November 26, 1990.
6. Engineering News Records, "Construction 2000: Environ-
mental Cleanup Construction Projects", Special edition,
December 3, 1990.
7. Lawefsky, M.E., "California Superfund Sites: Insight From
A Computerized Database", Hazardous Waste and Hazardous
Material, Vol 5(4), pp. 313-320, 1988.
8. Morgan, B.V., "Lessons Learned by the Courses of Engi-
neers on Two Superfund Remedial Projects", Management of
Uncontrolled Waste Sites, pp. 17-20, 1983.
9. Office of Technology Assessment, "Superfund Strategy",
Congress of the United States, 1989.
10. Park, H.Y., "Construction Management Alternatives for
Environmental Cleanup Projects", Construction Engineering
Research Laboratory, U.S. Army Corps of Engineers,
Champaign, IL, May, 1989.
11. Pierce, J.J. and etc, "Hazardous Waste Management', Ann
Arbor Science, 1981.
12. Sanvido, V.E. and Inyong Ham, "A Top-Down Approach to
Integrating the Building Process", Engineering with
Computer 5, 91-103, 1989.
13. Saaty, T.L., "Multicriteria Decision Making: the Analytic
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Hierarchy Process," University of Pittsburgh, Mervis
Hall, Pittsburgh, PA, 1988.
14. Saucier, R.T., "Executive Overview and Detailed Summary,"
Technical Report DS-78-22, Environmental Lab, US Army
Corps of Engineers, Vicksburg, MS, 1978.
15. Stecher, E.F., "Impervious Linear Installation Along a
Canal Bottom", Hazardous Material Control Institute, pp.
19-22, 1989.
16. U.S. Environmental Protection Agency, "An Introductory
Guide to the Role and Responsibilities of the Superfund
Remedial Project Manager (RPM)", The RPM Primer, Wash-,
ington, D.C., 1987.
17. Werner, J.D., "Remedial Action Management and Cost
Analysis", Management of Uncontrolled Hazardous Waste
Sites, pp. 370-375, 1983.
18. Wine, J. and H. Burns, "The States and EPA: an Evolving
Partnership under Superfund, Management of Uncontrolled
Hazardous Waste Sites", Hazardous Materials Control
Research Institute, pp. 428-430, 1983.
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APPENDIX I
Today more than ever there is a great national push for better
and more efficient use of the ten year old Superfund that was
supposed to solve environmental cleanup problems. As much as the
larger consturction contractors would like to be involved in
environmental concerns, they still believe that the timing is not
right. Much of this can be blamed on the risk factor, and
confusion due to inexperience with complex environmental cleanup
projects.
One major problem with environmental cleanup projects is a
confusion about the contractual/legal dealings between the govern-
ment and the contractor. With today's laws, the contractor assumes
much of the risk involved in cleanup projects. Contractors may be
liable for current projects even ten years from now. This is
normal for typical building or roads contracts, but because the
environmental cleanup industry is still in the embryotic stages of
development, contractors do not want to be held responsible for
untried practices.
In order to get more contractors involved, the proper type of
contract should be developed to explain the mechanism of risk-
sharing and to provide clauses for contractual indemnity. We in
the Center for Infrastructure Research (CIR) at the University of
Nebraska-Lincoln, are currently in developing a contract outline
that can be structured to environmental cleanup projects that
satisfy the contractor's need for risk-sharing and indemnity. The
Design-Build type of contract was based on the Environmental
Cleanup Project Contract (ECPC), allowing the contractor to use
creative design/engineering/construction practices deemed best for
specific situations under government scrutiny- This ECPC will also
assure the owners and government that the contractor is competent
and will not try to cut corners. Another main emphasis has been on
the creation of a communication channel between the contractor and
the owner/funder for every phase of construction process.
51.3
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Communication has been identifited as an important area of
improvement due to the unclear nature of design/engineering/
construction cleanup practices which are subject to change in
unexpected circumstances.
On the following page is the Environmental Cleanup Project
Contract (ECPC) which is a standard form for a Design-Build
agreement for cleanup projects between the contractor and the
project owner/funder. This is the skeleton of an ECPC and does not
attempt to actually cover all issues of the agreement process. Its
standardization, however, makes for easily read scope of what has
to be accomplished between the owner/funder and the contractor.
With the ECPC the contractor and the owner/funder have a form of
agreement that allows the contractor a greater amount of freedom,
while giving the owner/f under the assurance that work will be
conducted in a safe and professional manner.
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E C P C
Environmental Cleanup Project Contract
Section 1
This section involves the agreement. It defines:
A) The organization of the construction team -
contractor with design/engineering capabili-
ties and the project owner/funder.
B) The environmental site assessment.
C) The description of construction work - what
the construction team is to accomplish.
D) The safety requirements and responsibilities.
E) The agreement between parties.
Section 2
This section explains the contractors responsibilities,
It defines:
A) Contractors services (what is to be done).
B) Contractors abilities and qualifications.
C) Contractors responsibilities during construc-
tion.
D) Contractors additional services.
Section 3
This section defines the owner/funder responsibilities,
It defines:
A) Responsibilities to the Contractor.
B) Long term responsibilities of the site.
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Section 4
This section defines responsibilities and qualifications
of all subcontractors and material suppliers.
Section 5
Details about the contract time schedule are included in
this section. It defines:
A) Substantial completion.
B) Extensions of work
Section 6
This section deals with project payment. It is recom-
mended that with the Design-Build type contract a cost
plus fixed fee type of payment should be considered. Not
only does this insure payment to the contractor but also
will maintain the best quality of work which is so very
important for such circumstances.
Section 7
This section deals with changes incurred on the projects.
A) Change orders.
B) Emergencies - common only to hazardous waste.
Section 8
This section includes risk sharing. It defines:
A) Insurance - must be made more available to
contractor.
B) Liabilities - mechanism/formula of risk shar-
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ing between the parties.
C) Indemnity.
Section 9
This section deals with termination of agreement.
A) Termination rights of contractor.
B) Termination rights of project owner/funder.
Section 10
Laws for agreement. Enables government to enforce
critical contracts that may endanger life. Also includes
typical laws more common to construction contracts.
Section 11
This section explains the important design/engineering/
construction principles. It defines:
A) Arbitration board and mini-trial procedures
through the process of a court trial. Estab-
lishing the communication channel is essential
for the ECPC to work in an environmental
cleanup construction project and quick dispute
settlement process.
B) Constructability issues
C) Value engineering issues.
Section 12
Miscellaneous provisions. Self explanatory.
Author(s) and Address(es)
James H. Paek, Ph.D.
Department of Construction Management
University of Nebraska
W145 Nebraska Hall
Lincoln, NE 68588-0500
(402) 472-3737
5.17
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Permitting Superfund Remedial Actions
or
Nightmare on NW 57th Place
Lynna R. Phillips, P.E.
Ebasco Environmental Division
Ebasco Services Incorporated
145 Technology Park
Norcross, GA 30092
(404) 662-2314
Gail E. Scogin
United States Environmental Protection Agency
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-2643
INTRODUCTION
Local governments have a legitimate need to assure that activities conducted within their borders do
not jeopardize the public health or welfare. Uncontrolled construction activities can damage or
disrupt utilities, hinder traffic, impede fire or police services and restrict the local government's
delivery of essential services. Construction activities may also create threatening or dangerous
situations. Most local governments utilize a system of permits to protect their infrastructure from
damage or undue disruption.
Superfund-financed remedial actions are exempt from Federal, State, and local permits for the
portion of work conducted on-site. As a result, project managers often view obtaining permits as
unnecessarily burdensome and time-consuming. Vet, circumstances may warrant the efforts needed
to obtain permits for on-site as well as off-site actions. These permits will, for example, assure EPA
that the adverse effects to local communities of its activities are minimized. Also, the permitting
process itself creates a systematic method for coordinating with local governments and agencies.
However, this process requires significant advance planning as well as substantial resources to avoid
project delays.
Ideally, obtaining permits is straightforward and progresses smoothly. At its worst, permitting turns
into a quagmire of unexpected requirements, delays, and budget overruns. At the Hollingsworth
Solderless Terminal Company site, the EPA and its contractors expended extraordinary effort to
permit a relatively simple remedial action. This paper reveals the permitting nightmare we
encountered, provides insights into the process and identifies some potential pitfalls. The experience
gained during the ordeal may prove useful in avoiding permitting problems at other sites.
BACKGROUND
The Hollingsworth Solderless Terminal Company (Hollingsworth) site is located at 700 NW 57th Place
in the City of Fort Lauderdale, Broward County, Florida. The site encompasses approximately 3.5
acres. The Hollingsworth facility consists of two buildings separated by a public street. The entire
facility is bounded by asphalt alleyways, a second public street, and other industrial properties.
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Land use in the vicinity of the Hollingsworth site is a mix between commercial, industrial, and
residential. The area immediately surrounding the site has a high density of medium and light
industry. The Fort Lauderdale Executive Airport, Seaboard Coastline Railroad, and Interstate 95
(1-95) are nearby. Beyond 1-95 to the east is a large residential community.
The City of Fort Lauderdale's primary water supply, the Prospect Well Field, is approximately two
miles west of the site. This well field includes 38 functional wells located around the Fort Lauderdale
Executive Airport and Prospect Lake. The wells closest to Hollingsworth are within a quarter to a
half mile.
The primary source of drinking water for three million residents of South Florida is the Biscayne
Aquifer. This highly permeable, unconfined aquifer is composed of limestone and sandstone and
underlies the site. Both the Executive Airport and Prospect Lake wells tap the Biscayne Aquifer for
water supply. In the area of the site, the top of the aquifer is near the natural ground surface, and
its base is approximately 250 feet deep. The upper 60 to 70 feet of the aquifer are primarily
composed of fine to medium grained sands. This zone is underlain by a transition zone of cemented
shell and sandstone and finally by the limestone which forms the major water producing zone of the
Biscayne Aquifer. The regional direction of ground water flow is southeast.
The Atlantic Ocean is located approximately five miles to the east of the site and the Everglades lie
about 10 miles to the west. The average rainfall for this area is approximately 70 inches per year.
The site is located within the 100 year flood plain and is topographically flat.
From 1968 until 1982, Hollingsworth was in the business of manufacturing solderless electrical
terminals, consisting of a conductive metal portion and a plastic sleeve. The terminals attached by
means of crimping rather than by soldering. The manufacturing process included heat treatment in
molten salt baths, degreasing, and electroplating.
For approximately eight years, Hollingsworth disposed of wash water and process wastewater
contaminated with trichloroethene (TCE) into drain fields adjacent to the manufacturing plant and
into an injection well onsite. These disposal practices contaminated the soil and groundwater. The
primary contaminants of concern at the site are TCE, vinyl chloride, trans-1,2-dichloroethene, and
cis-1,2-dichloroethene.
As early as 1977, the Broward County Environmental Quality Control Board and the Florida
Department of Environmental Regulation (FDER) were concerned with the environmental status of
the site. These agencies requested EPA assistance in 1981. The EPA included the site on the first
official National Priorities List published in 1982, and, in the same year, commissioned a Remedial
Action Master Plan. The Potentially Responsible Party, Hollingsworth, initiated Remedial
Investigation activities in 1983, after filing Chapter 11 Bankruptcy. The EPA subsequently conducted
the Feasibility Study and issued a Record of Decision in 1986. The EPA completed the Remedial
Design in 1988 under the REM II Program. In 1989, under the REM III Program, Ebasco Services
Incorporated (Ebasco) received the work assignment to implement the fund-lead remedial action. The
EPA later transferred this work assignment to ARCS IV.
DISCUSSION
The remedial design, finalized in 1988, prescribes in-situ treatment of soil; and extraction, on-site
treatment, and injection of groundwater. The aspects of the design related to the permitting issues
include:
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(1) Installation of three wells to extract contaminated groundwater from the aquifer,
(2) Construction of two stripping towers to remove the volatile contaminants, and
(3) Installation of two wells to return the treated water to the aquifer.
The estimated duration of water treatment is nine months at a design rate of 450 gallons per minute.
The design specifies remediation of TCE- contaminated soil by in-situ vacuum extraction or an
alternate approved method.
The design also specifies above-ground vaults for housing the extraction well pump motor control
panels, valves, and pressure gauges. These vaults, approximately six feet long, three feet wide, and
two feet deep were to be located at the extraction wells and were to be surrounded by protective pipe
bollards.
Several components of the water treatment system are located in the public alleyways surrounding the
site. These components include two of the three extraction wells and associated above-ground vaults,
both injection wells and a majority of the interconnecting underground piping. The third extraction
well and its above-ground vault, both stripping towers, the construction office trailer, the
construction laydown area and the soil treatment area are all located on Hollingsworth property. The
stripping tower, construction office trailer, soil treatment and construction laydown areas are fenced.
Ebasco procured a remedial action subcontractor to construct and operate the required treatment
systems. In December 1989, Ebasco issued the Notice to Proceed to its subcontractor, Westinghouse
HAZTECH, Inc. (HAZTECH). The subcontract specified that HAZTECH was responsible for
securing all necessary permits. By early January, Ebasco and HAZTECH had identified the permits
and discussed the associated schedules for obtaining them.
The identified permits and the issuing agencies were:
Permit Issuing Agency
1. Building City of Fort Lauderdale
2. Electrical City of Fort Lauderdale
3. Fencing City of Fort Lauderdale
4. Temporary Traffic Modification City of Fort Lauderdale
5. Right-of-way Construction City of Fort Lauderdale
6. Extraction Well Construction South Florida Water Management District
7. Extraction Well Water Use South Florida Water Management District
8. Injection Well Construction Florida Department of Environmental
Regulation
9. Injection Well Use Florida Department of Environmental
Regulation
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HAZTECH discussed the permitting process with the City of Fort Lauderdale (the City) officials.
HAZTECH understood that permits could be issued within two weeks after application and submittal
of required information by a licensed contractor. HAZTECH identified the Departments within the
City government which would issue the needed permits:
Building and Zoning Department:
Building
Electrical
Fencing
Required Submittals
Site lay out plan showing locations of all equipment and facilities to
be installed; tie-down plans for the construction office trailer
Electrical plans and specifications
Plans showing the relationship of proposed fencing to buildings,
property lines, and city streets
Engineering Department:
Permit
Traffic
Modification
Right-of-Way
Construction
Required Submittals
Plans showing obstructions in the
and required traffic rerouting.
right-of-way
Plans showing right-of-way lines, proposed underground
pipe routing, location of existing utilities (in particular, existing
potable water lines), location of wells and associated fixtures,
profiles of proposed piping and existing utilities, details of well
fixtures, and details and specifications of piping, paving, drainage,
and trenching
The permitting nightmare began in January, 1990, when HAZTECH applied to the South Florida
Water Management District (the District) for water well construction and water use permits. The EPA
provided the district with pertinent data from the Feasibility Study and the Remedial Design along
with a description of the relationships between the EPA, Ebasco and HAZTECH. The EPA also
requested that permitting fees be waived. Based on the District's projected review time, we expected
the construction permit within two weeks and the water use permit within 45 days.
When contacted about the injection well permits, FDER informed HAZTECH that no permits were
required because the wells were part of a Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) clean-up and the site groundwater clean-up criteria were within state
primary and secondary drinking water standards.
As it turned out, only two permits actually contributed to the difficulties which are the topic of this
paper: the City right-of-way construction permit and the District water use permit. We obtained the
other permits without adverse impact to cost or schedule.
To obtain the right-of-way construction permit, HAZTECH met with City Engineering Department
officials in mid-February 1990 and submitted engineering drawings. After the City engineers
reviewed the drawings, they noted that the installation of the above-ground structures, the vaults,
might require closure to traffic of all or a part of the public alleyway. Therefore, before they could
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issue a permit, the Property and Right-of-Way Committee (the Committee) would have to review the
submittals and recommend issuance of a permit. HAZTECH also learned that the City viewed this
project as a private rather than a public construction activity and that the City might consider closing
the alleyway to traffic for the project duration as a "permanent" closure. If so, a license agreement
with the City allowing use of City property for the year-long duration would have to be in place prior
to obtaining the construction permit.
Following the meeting, HAZTECH wrote a letter requesting to be placed on the agenda of the next
Committee meeting. In an attempt to expedite the project, the EPA Remedial Project Manager
(RPM) wrote a letter to the City noting that the project was a joint EPA and FDER project. This
letter also described the contractual relationships between the EPA, Ebasco, and HAZTECH.
On March 7, EPA, HAZTECH, and Ebasco representatives attended the Property and Right-of-Way
Committee meeting in Fort Lauderdale. The Committee decided that a complete closure of the
alleyway for a year was necessary to ensure the public's safety. The Committee expressed concern
about the closure's effect on access to adjacent properties. HAZTECH informed the Committee that
they had talked with the adjacent business and property owners and encountered no objections to the
closure. After further discussion, the Committee decided to approve the closure of the right-of-way
under one condition: the owner of the business facing the portion of the alleyway to be closed (Mr.
X) must submit a letter stating that he had no objections. The Committee members suggested that
they would require a license agreement to use City property, followed by the engineering permit.
The originally scheduled date for site mobilization was March 1, 1990. This schedule had already
been delayed a week when the Committee met on March 7. As it turned out, the cost and schedule
impacts were just beginning.
Immediately after the meeting, HAZTECH and Ebasco representatives contacted Mr. X to discuss the
required consent letter. Mr. X implied an offer to provide the necessary letter in exchange for
construction work on his property. HAZTECH declined his offer, and, as a result, received no letter.
HAZTECH notified the Committee that no consent letter would be forthcoming and learned that, as
a result, the Committee would need to consider the situation further. HAZTECH requested a slot on
the agenda of the next Committee meeting.
During this time, the EPA and Ebasco considered several options to eliminate the need for closing
the entire alleyway for the duration of the project. One option involved relocating the two extraction
wells from the alleyway onto private property. This relocation would, however, require permission
from the property owner, along with the design engineer's review and possible revision to the
groundwater modeling used as the basis of the original design. In addition, HAZTECH would need
to redesign the piping, perform additional utility searches and property surveys, as well as revise the
engineering drawings.
The second option involved placing the wellhead appurtenances in below-grade vaults with
traffic-bearing covers, thus necessitating an alleyway closure of only one month during construction.
HAZTECH would have to reconfigure the well piping and components, replace the already fabricated
above-grade vaults with traffic-bearing below-grade vaults, and revise the drawings. This change
would again require a review by the design engineer.
The third option involved shifting the locations of the wells slightly so that the above-grade vaults
would block only half the alleyway. This option would require that the piping be installed two feet
deeper than planned in order to maintain required clearance from the existing potable water line and
that pertinent design drawings be revised.
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The EPA decided to use the last option, since it had the least impact on the original design and on the
overall cost of the project. HAZTECH prepared revised engineering drawings for submittal to the
Committee.
In late March a Committee member visited the site. He viewed the affected section of alleyway and
identified several other access routes to Mr. X's property. He acknowledged that the change allowing
one open lane for traffic would be helpful in persuading the Committee to delete the requirement for
a license agreement so that we would only have to get the engineering construction permit.
On April 4, HAZTECH and Ebasco representatives attended their second Committee meeting. The
Committee member who had visited the site recounted his findings and the Committee deleted its
requirement for the consent letter. HAZTECH submitted drawings, identifying the revisions allowing
half the alleyway to remain open to traffic. The Assistant City Manager agreed that the standard
engineering permit was now all that would be required based on code requirements and the fact that
the City Engineer had issued permits for similar partial closures in the past.
Disagreeing with this decision, the City Attorney indicated that the City should still require a license
agreement. The Attorney was concerned about possible future legal actions by Mr. X. The Attorney
suggested that the license agreement include a clause providing the City full indemnification from
any legal actions and made the following points:
(1) The project was in the public interest but the location of the wells was for the
convenience of the EPA; and
(2) The City was accommodating the EPA by allowing the placement of the wells on city
property.
The Committee finally decided on a permitting approach that would require a license agreement
containing a special provision for full indemnification of the City from any legal actions.
The Committee recommended this approach at the City Commission meeting and the City Commission
approved. On May 9, when the project was ten weeks behind schedule, HAZTECH and Ebasco
received the proposed license agreement from the City. This document was to be fully executed by
HAZTECH and Ebasco corporate officers as licensees and the City of Fort Lauderdale as licensor
prior to the issuance of the engineering construction permit.
After reviewing the document, HAZTECH and Ebasco were concerned about the clauses covering
indemnification and insurance. If they signed the document, these clauses would conflict with
existing agreements between Ebasco and the EPA and between Ebasco and HAZTECH.
These clauses, extracted from the proposed document, are as follows:
Indemnification
LICENSEE hereby agrees to protect, defend, indemnify, save and hold the CITY, its officers,
employees and agents harmless from and against any and all claims, suits, causes of actions
or demands of whatsoever nature, including any and all lawsuits, penalties, damages,
settlements, judgments, decrees, costs, charges and other expenses including attorneys' fees,
or liabilities of any and every kind, nature and degree, in connection with or arising from any
activities associated with the project contemplated by the License granted herein. The
indemnity and hold harmless herein shall include by way of illustration, but not by way of
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limitation, any and all such claims, suits, causes of action, demands relating to personal
injury, death, damage to property (including, but not limited to, diminutions in property
value, trespass to property, or denial of access to property resulting from activities resulting
from the project contemplated by the License herein), or any actual or alleged violation of
any constitutional or property right or interest, applicable statute, ordinance, administrative
order, rule, or regulation or judicial order, judgment or decree. LICENSEE further agrees
to investigate, handle, respond to, provide defense for, and defend any such claims, demands,
etc. at its sole expense and agrees to bear all other costs and expenses related thereto, even if
the claim is/are groundless, false or fraudulent.
Insurance
Without limiting any of the other obligations or liabilities of LICENSEE, LICENSEE shall
provide, pay for and maintain in full force and effect the insurance coverage as set forth in
this section at all times during the performance of the operations or projects contemplated by
this Revocable License, as will ensure the CITY the protection contained in the foregoing
indemnification provisions undertaken by LICENSEE.
Comprehensive General Liability with minimum limits of One Million ($ 1,000,000.00) Dollars
per occurrence combined single limit for Bodily Injury Liability and Property Damage
Liability Coverage must be afforded on a form no more restrictive than the latest edition of
the Comprehensive General Liability Policy, without restrictive endorsements as approved by
the CITY'S Risk Manager, and must include:
a. Premises and Operations; and
b. Notice of Cancellation and Restriction or both — the policy(ies) must be
endorsed to provide the CITY with thirty (30) days' notice of cancellation
and/or Restriction.
LICENSEE shall provide CITY with a certified copy of all insurance policies required by this
article showing that CITY has been named as insured under such policies or, in the
alternative, a certificate evidencing that the required additional endorsement has been
obtained under such policies at the time of execution of this Revocable License by
LICENSEE.
HAZTECH agreed to sign the license agreement upon assurance from Ebasco that any unanticipated
additional incurred costs would become a reimbursable contract modification. Ebasco was concerned
about providing open-ended indemnification to the City, along with obtaining and paying for
insurance necessary to assure the City of protection required by the indemnification provisions.
Ebasco communicated its concerns to the EPA Attorney, as well as to the RPM. Ebasco agreed to
sign the document upon assurance from the EPA of full cost reimbursement for expenditures incurred
on its behalf. The EPA directed Ebasco to negotiate the indemnification and insurance requirements
with the City so that Ebasco could sign the document.
Ebasco legal staff spoke with the City Attorney several times but the City would not modify its
requirements. The City's main argument in refusing to modify the indemnification clause was that
this case involved a year-long partial closure of public right-of-way, land owners had easement rights
to these rights-of-way, and one land owner objected to the closure. Ebasco notified the EPA that
negotiations had failed and we had reached an impasse.
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The permitting situation had become more, not less, complicated. Site mobilization had been delayed
four months. In late June, Ebasco met with the EPA to discuss possible engineering solutions. We
had learned that restricting the use of the right of way for more than thirty days required not only
a construction permit, but also a license agreement with the City. Therefore, we considered using
below-grade instead of above-grade vaults. We hoped that this design change would solve the
on-going problems in obtaining a construction permit by eliminating the need for the license
agreement. The rationale was that the "below-grade vault" option would eliminate the need for
closing the alleyway, except briefly during actual construction.
We thought we had solved the problem. HAZTECH revised the drawings and, after the necessary
reviews, submitted them to the City. To our dismay, the City responded in mid-July that it still
required a license agreement, although one somewhat different from the original. In the new version,
the insurance clause remained unchanged and this sentence had been eliminated from the
indemnification clause:
"The indemnity and hold harmless herein shall include by way of illustration, but not by way
of limitation, any and all such claims, suits, causes of action, demands relating to personal
injury, death, damage to property (including, but not limited to, diminutions in property
value, trespass to property, or denial of access to property resulting from activities resulting
from the project contemplated by the License herein), or any actual or alleged violation of
any constitutional or property right or interest, applicable statute, ordinance, administrative
order, rule, or regulation or judicial order, judgment or decree."
Thus, the revised document was not substantially different from the original one.
When HAZTECH realized that the design change had not solved the problem as anticipated, they
considered just starting over. They proposed to bypass the Committee by submitting the newly
revised drawings to the City Engineering Department. This proposal seemed logical because the
Engineering Department had the authority to issue permits for short-term (less than thirty day) partial
right-of-way closures. When approached with the idea, one City official strongly advised against this
strategy. He suggested that the City would not alter its requirement for the execution of the license
agreement because previous submittals and City requirements were now on record. HAZTECH
dropped the idea. The project was four and half months behind schedule and EPA still did not have
a construction permit.
By mid-July, the EPA had received all permits except the elusive right-of-way construction permit
and the extraction well water use permit from the South Florida Water Management District. EPA's
need for the water use permit depended on obtaining the construction permit.
HAZTECH had applied for the water use permit along with all the others in January. In February,
the District expressed concern about the elapsed time between the completion of the design and the
commencement of the remedial action. They requested additional data because of several new
conditions:
(1) The City had applied for increased pumpage from one of its well fields in the vicinity
of the site;
(2) Remedial clean-up activities were on-going at the nearby Prospect Well Field; and
(3) Two sites within the immediate vicinity of the Hollingsworth site were undergoing
contamination assessment work.
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EPA responded to the District's request for additional data by supplying a 1989 groundwater modeling
report. In March, Ebasco provided the analytical data from recent groundwater sampling along with
current groundwater level data. The EPA then had the groundwater model for the site updated using
this new information and data supplied by the District. In late May, the EPA submitted the modelling
results which indicated current groundwater flow conditions at the site to the District. This
information satisfied the District and it issued the water use permit in mid-August. Although not as
frustrating as the construction permit, obtaining this permit took six and a half months instead of the
45 days planned.
By this time, Ebasco senior management and legal staff had completed their review of the revised
license agreement. The legal staff advised against signing it. However, senior management wanted
to sign it in the interest of maintaining good relations with the client. Ebasco and HAZTECH
ultimately decided to sign the license agreement.
In the meantime, the EPA attorney sent a letter to the City attorney. As a result, the City finally
proposed satisfactory indemnification and insurance language. The indemnification clause was the
same as the previous one except that the following sentence was added:
"Notwithstanding the foregoing, LICENSEE shall not be liable to so protect, defend, save and
hold harmless the Indemnitees to the extent that any such claims, suits, causes of action or
demands result from the negligence or fault of any of the Indemnitees."
The City modified the insurance clause to a requirement for maintaining comprehensive general
liability insurance. The City deleted the requirement for insurance that would assure the protection
required by the indemnification provisions and that named the City as an additional insured.
Ebasco and HAZTECH signed the license agreement in September, the City signed it in October and
within a week, HAZTECH obtained the construction permit and Ebasco and HAZTECH had
mobilized on-site and were drilling wells.
Mobilization occurred on October 16, 1990, after a delay of seven and a half months. The costs
associated with this permitting delay are sobering.
CONCLUSION
The EPA chose to obtain permits for the Hollingsworth Site Remedial Action because of the location
of the site and because of the environmental sensitivity and complexity of the aquifer that is the
object of the clean-up. In addition to the physical aspects of the site, permitting was warranted by
EPA's desire to maintain good working relations with the City of Fort Lauderdale, the FDER, and
the South Florida Water Management District because future Superfund actions in the area are
anticipated.
What did we learn from this experience? By obtaining permits, EPA helped to alleviate potential
future problems and embarrassments due to mishaps involving local community resources. Yet,
reflecting on the chronology of events in pursuing these permits, we have the following
recommendations:
(1) Consider the specific situation. Because of the dynamic nature of groundwater, when
groundwater remediation is included as part of a remedial action, there is a strong potential
for permitting delays. This potential increases if the site is located in an environmentally
sensitive area and increases even more if the remedial design is not immediately followed by
its implementation.
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Construction activities within cities are particularly susceptible to permitting problems. Cities
sometime hinder activities that are to their citizens' benefit in the process of protecting their
infrastructures. We should identify all construction to be carried out on city-owned property
and consider the associated permitting implications. Ideally, the design specifies all
installations in relation to right-of-way lines and minimizes construction on city-owned
property.
(2) Consider other options. In our case, we may have been able to streamline the process, or
avoid the permits altogether, and still accomplish our goals. We could have, for example,
obtained FDER concurrence on the Superfund permit exemption and then approached the
City officials about this exemption.
(3) Begin the planning process early. EPA should not only identify the required permits as early
as possible, but should also contact issuing agencies for detailed information concerning
required submittals and expected review times. If the design contains sufficiently detailed
information, the EPA contractor responsible for obtaining permits can initiate pursuit of them
either before or concurrently with subcontractor procurement. Then, even if the permitting
agencies require additional and updated information or if design changes are necessary, EPA
can minimize or avoid construction delays.
(4) Where possible, determine actual and potential requirements before initiating the permitting
process. EPA and its contractors should contact local government and agency officials to
discuss the permits on an informal basis. EPA should provide as much detail and get as much
information as possible, before making formal submittals. We discovered that once we
formally submitted permit applications, we were caught in a web of procedures and
requirements that made it difficult to make changes or start over.
(5) Involve appropriate individuals at the first signs of difficulty. One of the pitfalls we
experienced was in our treatment of each stumbling block. We approached each impediment
as a single problem which when solved would allow us to proceed. In this case, we could have
involved the EPA project officer, contracting officer, and attorney as well as the contractor
legal staff at an earlier point. These individuals would then have had an opportunity to offer
helpful suggestions that may have eliminated or reduced the time and effort we ultimately
expended.
(6) Maintain consistent EPA involvement with its contractors as well as with the local
governments and agencies. EPA should write a letter to each permitting agency identifying
the project as a U.S. EPA Superfund cleanup, describing briefly the project and its expected
benefits, identifying the relationships between the EPA, its contractor and subcontractor,
naming all the participants, and specifying the type of permit needed. Unfortunately, this
procedure will assist, but does not guarantee trouble-free permitting.
Eliminating delays and budget over-runs is an important part of construction management.
Permitting is one aspect of every project that can potentially lead to delays and budget overruns. This
paper describes a nightmarish situation often repeated in government contracting. There are no
simple solutions or short cuts to the permitting process. When complicated by insurance and
indemnification issues, the process can take some unexpected twists. An attitude of awareness and
forward planning is one of the best tools we have.
DISCLAIMER
The preparation of this document has been funded in part by the United States Environmental
Protection Agency. It has been subjected to Agency and Ebasco review and approved for publication.
It represents the authors' personal points of view. Any questions or comments regarding the content
of this paper should be directed to the authors.
527
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STATE OVERSIGHT AT TWO URANIUM MILL
SUPERPUND SITES IN COLORADO
(Author(s) and AddreM(es) at end of paper)
INTRODUCTION
The State of Colorado has acted as lead agency for oversight at
two uranium mill tailings sites, which are also Superfund
sites. The two sites are the Uravan Project located in
southwestern Colorado near the Colorado-Utah border and the
Cotter/Lincoln Park Project located near Canon City, Colorado,
approximately 96 miles south of Denver.
When oversight of the projects began, it became apparent that
the State needed to develop organized and comprehensive
oversight management programs in order to document progress and
determine conformance with the approved Remedial Action Plans
(RAPs). The oversight management programs provide a detailed
road map for inspections and documentation of the actions
taken. The oversight programs will ultimately be used to
document activities for delisting of these sites from the
National Priorities List.
The State of Colorado's strategy on these two sites has been to
assign On-Site Coordinators (OSCs) who spend significant time
at each site. By spending much of their time on site, the OSCs
are aware of current progress, are better able to understand
the site conditions and are available to help analyze and solve
problems that develop in the field.
No matter how comprehensive the preliminary investigations and
studies are, unanticipated conditions are encountered once
implementation of a remedial action plan begins. Examples are
given of field changes that were made based upon unanticipated
conditions such as geohydrology and constructability. The OSCs
are empowered to authorize changes in the field in order to
accomplish the objectives of the RAPs. This has enabled both
projects to proceed in a timely manner but has also required
that the OSCs fully understand the purpose and intent of each
project component. The time spent at the site observing the
construction activities has been beneficial both to the State
and to the companies involved.
BACKGROUND
The State of Colorado filed suit in Federal Court against
several corporations in December 1983, pursuant to the
Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA) at seven sites throughout
Colorado. During litigation, a Memorandum of Agreement was
signed between the U.S. Environmental Protection Agency (EPA)
and the State of Colorado (the State). This agreement defined
the roles and responsibilities of each agency and made the
State lead agency for cleanup oversight at these Superfund
528
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sites. The Uravan and Cotter/Lincoln Park sites had previously
been placed on the National Priorities List (NPL) by EPA. The
Uravan and Lincoln Park sites were the first two Colorado
lawsuits which were settled. The Uravan Consent Decree and the
Remedial Action Plan were filed with the court in October 1986
and implementation of the reclamation plan was started in the
fall of 1986. The Cotter/Lincoln Park lawsuit was resolved in
April 1988 and construction activities began in June 1988.
After settlement of the lawsuits, the State had the
responsibility for overseeing the cleanup of contamination at
the two uranium mills. Remedial actions are anticipated to
take approximately 20 years at each site. The Consent Decrees
required that the companies (Umetco Minerals Corporation at
Uravan and Cotter Corporation at Cotter/Lincoln Park) perform
the remedial activities at their own expense. On-Site
Coordinators (OSCs), who have the same authority as that vested
in a Federal "On-Scene Coordinator," were hired by the State to
oversee implementation of the remedial activities. Although
the State has the responsibility for accepting completion of
the numerous remedial activities at each site, EPA will make
the final decision on delisting each site from the NPL.
Therefore, the State On-Site Coordinators work closely with EPA.
The role of the State's two On-Site Coordinators is to ensure
proper Quality Assurance/Quality Control and to work with the
responsible party to meet the objectives of the respective
Remedial Action Plans. To accomplish this, the State has hired
consultants to assist. One consultant, W.R. Junge and
Associates, developed an Oversight Management Program (OMP) for
each site. The Oversight Management Programs were tailored for
use by each OSC because each site is different and each
Remedial Action Plan is distinct. However, the same basic
principles were used in developing each program.
The goal of the OMP is to document, in an organized manner,
that all remedial activities at the site have been conducted
properly and that these actions meet the applicable, relevant,
and appropriate standards. To accomplish this goal, a specific
inspection strategy and a detailed inspection system were
developed for remedial activities to assure adequate tracking,
monitoring, evaluation and documentation of the construction
and environmental monitoring activities. In an era of limited
resources, it is imperative that an effective, streamlined and
manageable system be designed and implemented. For this
reason, a computer-based data management system was used in
developing the Oversight Management Program. Preparation of
these programs required the OSCs to fully understand the scope
529
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of each project. The basic concepts in developing these
programs can be used to develop similar programs for other
sites that are cleaned up under the Comprehensive
Environmental, Response, Compensation and Liability Act
(CERCLA); Resource Conservation and Recovery Act (RCRA); and
the Uranium Mill Tailings Radiation Control Act (UMTRCA).
Implementation of the RAPs with the onset of field activities
uncovered the existence of unanticipated conditions at each
site. This situation occurs for each major project undertaken,
no matter how extensive the previous investigations. Because
the On-Site Coordinators are actually on site, they can quickly
be made aware of problems and help to resolve them in an
expedient and cost-effective manner. Several examples of field
modifications based upon actual field experience are discussed
in this paper.
DISCUSSION
Uravan Uranium Mill Site
The Uravan project is located in southwestern Colorado near the
Colorado-Utah border (Figure 1). The site consists of
approximately 10 million cubic yards of uranium tailings
located in two piles on a structural bench approximately 100
feet above the San Miguel River. Six ponds, referred to as the
Club Ranch Ponds, containing evaporated residues from liquid
mill waste, called raffinate, are also present in the river
valley- Deposits of remnant tailings and a pile of raffinate
crystals removed from the Club Ranch Ponds are also located in
the river valley. Contaminated soils and other materials are
also present in the mill area. The company-owned town of
Uravan once existed in the river valley but was removed in 1987
as a part of the Remedial Action Plan.
Activity at the site commenced in 1913 with the construction of
the first radium mill. Operation of a vanadium mill at Uravan
started in 1936. By 1944, Union Carbide, under contract to the
U.S. Army Corps of Engineers, was processing uranium at the
site for use in the Manhattan Project. The possibilities of
beneficial uses of atomic energy and radioactive materials led
to the formation of the United States Atomic Energy Commission
and the birth of the uranium industry in Colorado.
Construction of the large tailings piles at the site started in
the 1940's and continued until 1984 when Union Carbide
suspended operations at the site. The construction of the Club
Ranch Ponds for containment and evaporation of mill liquors
commenced in the middle to late 1950's. These ponds continued
to be used until 1988.
530
-------
Figure 1. Map showing the location of the Uravan and Cotter mill sites.
531
-------
The remedial actions at the Uravan site include consolidation
of all tailings and contaminated soils into the two existing
tailings piles. The tailings piles will be capped with a
multi-layer earthen and rock cover designed to reduce
infiltration and erosion. The raffinate crystals are to be
placed in a below-grade, clay-lined repository located adjacent
to the tailings piles. Approximately 550,000 cubic yards (cy)
of the estimated 800,000 cy of crystals have been moved.
Approximately 450,000 cy of the estimated 600,000 cy of remnant
tailings and contaminated soils have been moved and
consolidated.
Control of contaminated liquids at the Uravan site includes
interception of hillside seepage below the tailings piles and
withdrawal of contaminated ground water from underneath the
valley area. Treatment for both systems involves evaporation
of the contaminated liquids in double-lined ponds equipped with
leak detection systems.
Implementation of the Remedial Action Plan at Uravan is on
schedule and is ahead of schedule for some elements. This is
due to an abundance of dry weather and cooperation between the
company and the State of Colorado in implementing the remedy.
Uravan Oversight Management Program
One of the first tasks undertaken by the company, once the
Consent Decree was ratified by the Court, was the preparation
and submission to the State of Plans and Specifications for the
construction of the remedial actions at the site. During the
review of the Plans and Specifications for the Uravan Project,
it became evident that an organized, comprehensive state
oversight program would be needed in order to track the
progress of the project and to keep the On-Site Coordinator
organized during the inspection of numerous project elements.
The Uravan Project is broken down into thirty sub-projects and
literally hundreds of project elements in the Plans and
Specifications. A step-wise, building-block approach is needed
to inspect such a project. The Uravan RAP calls for a
Construction Report to be submitted at the completion of each
sub-project. Each sub-project is in turn broken down into
tasks and each task is composed of individual project
elements. At the completion of each task, a Compliance Report
is submitted to the State for review and approval. These
reports contain a description of the work performed, the
results of the quality control tests, such as liner seam tests
or soils compaction tests and any field changes made, including
532
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an explanation of the conditions leading to the changes. The
Compliance Reports are then compiled for each task and
submitted together with As-Built Drawings as the Final
Construction Report for each sub-project.
It is particularly important to catalogue and inspect the
various project elements because, once an element is
constructed, it is often covered up by future work. In order
for the State to certify that the entire project has been
properly completed, each project element must be inspected to
determine conformance with the Remedial Action Plan and the
approved Plans and Specifications.
The establishment of an Oversight Management Program for the
Uravan Site was undertaken by the State in late 1987 and was
completed in February of 1988. The program consists of a
series of data base computer files that track the status of
documents, construction dates, project elements and inspection
dates.
Figure 2 shows the format of the document log file. This file
tracks the submittal dates for the most current revision of
approved plans, as well as the Final Construction Report for
each sub-project and the performance evaluation report. The
revision number for each document is contained in the file but
not shown in this figure.
A portion of the Construction Tracking Progress Report is shown
in Figure 3. This data base contains the actual and reguired
start dates and completion dates for each sub-project as
specified by the Remedial Action Plan.
A third file, the Construction Database, contains a break out
of each sub-project into tasks and elements. The Compliance
Report number for each task and element is also specified.
This file tracks dates of inspections for each element and the
approval date for each task. A text file within the
construction database contains a description of how each
element is to be inspected. Inspection results and other field
observations are also recorded in this file. This allows the
production of an inspection report from one file. Field
changes are handled in another text file.
Several types of reports or data summaries can be generated
from the Construction Database, including Inspection Reports,
Project Summary Reports and Inspection Tracking Reports. These
summaries can be used to update interested parties regarding
the progress of the project.
533
-------
The Inspection Tracking Report (Figure 4) shows the inspection
status of each element for each task. This file allows
Department management and the OSC to gauge the progress of each
task as well as the progress of the OSC in inspecting each
project element or task. A text file also exists within the
data base for each project element, task and sub-project. The
file can be updated as additional elements are inspected.
The Project Summary Report shown in Figure 5, taken from the
Construction Database, is a compilation of sub-projects and
major tasks with the Compliance Report number for each task.
This report summarizes the status of compliance reports
submitted by the company for each portion of the entire project.
When a Compliance Report is submitted by the company, the
Construction Database text file for each construction element
is reviewed to determine if any unresolved problems exist. The
text files for each element of the Compliance Report is a
record of the State's inspection and approval of the
construction task.
The approval of a Final Construction Report is handled in the
same way and is composed from the inspection report text file
for each construction task.
The State Oversight Management Program at Uravan has been used
primarily as an inspection guide and inspection record.
Efficiency of OSC field review activities is improved by the
use of the program. This allows the OSC to preview the
important inspection activities for each construction element
and to act in a quality assurance role during inspections.
The Oversight Management Program is an on-going record of
activities at the site. Ultimately, the program will be used
to verify compliance with the Remedial Action Plan and to allow
delisting of the site.
Armed with the Oversight Management Program and a thorough
knowledge of the goals of the Remedial Action Plan, the OSC is
prepared to deal with the challenges of implementation.
Uravan Field Oversight
In several instances, unanticipated field conditions were
encountered during construction of the various phases of the
project. The presence of the State's On-Site Coordinator at
the site during these instances provided useful and important
insight into the problem. Solutions were discussed in the
field with engineers and construction personnel, which allowed
534
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CONSTRUCTION AREA
UMETCO-URAVAN
Document Tracking Log
DOCUMENT
NUMBER
DATE DATE
SUBMITTED APPROVED
400 ATKINSON CREEK AREA
400.0 Final Plans S-400-1
400.1 Quality Plan QP-400-1
400.2 Final Constr Rept.
400.4 Design Changes
400.9 Performance Eval. PE-400-1
06/09/87 02/09/88
06/09/87 02/09/88
401 CLUB RANCH PONDS
401.0 Final Plans S-401-1
401.1 Quality Plan QP-401-1
401.2.1 Constr Rept.
401.2 Final Constr Rept.
401.4 Design Changes
401.13 Performance Eval. PE-401-1
04/03/87 08/11/87
04/03/87 08/11/87
402 RIVER PONDS AREA
402.0 Final Plans S-402-1
402.1 Quality Plan QP-402-1
402.2 Final Constr Rept.
402.4 Design Changes
402.7 Performance Eval. PE-402-1
06/09/87 02/09/88
06/09/87 02/09/88
404 TAILINGS PONDS
404.0 Final Plans
404.1 Quality Plan
404.2 Final Constr Rept.
404.4 Design Changes
404.11 Performance Eval.
S-404-1 06/12/87 02/09/88
QP-404-1 06/12/87 02/09/88
PE-404-1
406 CLUB MESA AREA
406.0 Final Plans
406.1 Quality Plan
406.2 Final Constr Rept.
406.4 Design Changes
406.9 Performance Eval.
S-406-1 06/09/87 02/09/88
gp-406-1 06/09/87 02/09/88
PE-406-1
413 MILL AREA
413.0 Final Plans S-413-1
413.1 Quality Plan QP-413-1
413.2 Final Constr Rept.
413.4 Design Changes
413.12 Performance Eval. PE-413-1
06/09/87 02/09/88
06/09/87 02/09/88
Figure 2
A portion of the Document Log Tracking File
for the Uravan Project
535
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UMETCO-URAVAN
Construction Log
Progress Report
CONSTRUCTION ACTIVITY
INITIAL INITIAL
DATE DATE
Required Actual
COMPLETION COMPLETION
DATE DATE
Required Actual
400 ATKINSON CREEK DISPOSAL AREA 06/30/92
Remove Contaminated Materials None
401 EXISTING CLUB RANCH PONDS
Cease Discharge to CRP'S None
Remove Club Ranch Pond Liquids None
Remove Contaminated Materials 09/30/89
Lining of the Club Ranch Ponds None
Remove New Pond Liners None
Final Reclamation None
10/06/88
09/21/89
12/31/93
12/31/92
06/01/88
12/31/88
12/31/88
12/31/91
None
PER RAP
05/31/88
12/23/88
402 RIVER POND AREA
Cease Discharge to River Ponds
Remove Liquids from Ponds
Remove Contaminated Materials
Final Reclamation
404 TAILINGS PILES
Dewater Tailings Piles
Cease Storage of Liquids TP#2
Side Slope Cover
Top Cover-Clay and Random Fill
Top Cover-Riprap
Diversion Channels
406 CLUB MESA AREA
Remove Contaminated Materials
Install Runoff Controls
Remove Storage Pond Liquids
Final Reclamation
413 MILLS AREA
Removal of Heap Leach Site
Removal of Barrels
Removal of Boneyard Material
Final Reclamation
None
12/31/87
09/30/89
None
02/17/88
12/15/87
09/29/89
08/13/90
04/13/87
Annual
12/31/88
12/31/91
02/17/87
04/26/89
04/26/89
09/07/90
09/30/88
None
04/30/88
None
None
None
09/22/88
09/12/88
None
12/31/89
12/31/89
12/31/96
None
12/31/96
06/30/93 09/06/89 12/31/94
None 07/25/90 06/30/93
None Annual
None 12/31/95
None Fall 86 12/31/88
None 12/05/87 12/31/87
None 02/18/87 12/31/88
None None
04/05/89
09/13/89
11/20/88
02/16/88
12/07/88
Figure 3
A portion of the Construction Log Tracking file
showing start dates and completion dates for each sub-project.
536
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UMETCO-URAVAN SITE
STATE INSPECTION REPORT
1990 INSPECTION UPDATE
CONSTRUCTION
TASK
INSPECTION APPROVAL
DATE DATE
STATUS
404 TAILINGS PILES
404.5 DEWATERING LIQUIDS ON TAILINGS PILES
404.5.1 Inspect Surface Water Collection System
404.5.2 Verify Construction of Ditches and Sumps
404.5.3 Confirm Minimum Pool Size
404.6 PLACEMENT OF CONTAMINATED MATERIAL
404.6.2 Verify Size, Shape, Nesting of Scrap
404.6.3 Observe Placement of Contamination Mat'l
404.6.4 Check Contaminated Material Soils Tests
404.7 RIPRAP COVER FOR ROCK BUTTRESS
404.7.1 Confirm Riprap Specifications
404.7.2 Observe Riprap Placement
404.7.3 Observe Riprap Compaction
404.7.4 Verify Riprap Thickness
404.8 RECLAMATION COVER FOR EXISTING 3:1 SLOPES
404.8.1 Confirm Thickness&Compaction/Exist. Fill
404.8.2 Confirm Clayey Soil Material Properties
404.8.3 Observe Clayey Soil Placement
404.8.5 Check Clayey Soil Tests
404.8.6 Verify Clayey Soil Thickness
404.8.7 Confirm Random Fill Material Properties
404.8.8 Observe Random Fill Placement
404.8.9 Observe Random Fill Compaction
404.8.10 Check Random Fill Soil Tests
404.8.11 Verify Random Fill Thickness
404.8.12 Confirm Riprap Specifications
404.8.13 Observe Riprap Placement
404.8.14 Observe Riprap Compaction
404.8.15 Verify Riprap Thickness
404.9 RECLAMATION COVER FOR 5:1 SLOPES AND TOP
404.9.1 Confirm Placement of Interim Cover
404.9.2 Confirm Compaction of Interim Cover
04/18/89
09/21/88
09/21/88
09/21/88
08/15/88
12/12/89
09/28/89
09/28/89
06/20/89
03/14/89
09/28/89
06/20/89
09/22/88
08/16/89
05/16/89
09/29/89
10/20/88
07/05/89
07/05/89
06/13/89
09/29/89
09/28/89
09/28/89
03/28/89
09/28/89
07/16/90
04/18/89
04/18/89
04/18/89
04/18/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
11/20/89
Pending
Pass
Pass
Pass
Pass
Pending
Pending
Pending
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
1995
n/a
Figure 4
A Portion of the Inspection Tracking Report.
This information is stored in the Construction Database.
537
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UMETCO-URAVAN SITE
PROJECT SUMMARY
CONSTRUCTION SEGMENTS
CONSTRUCTION
SEGMENT
COMPLIANCE APPROVAL
REPORT DATE
STATUS
400.0 ATKINSON CREEK CRYSTAL AREA
400.5 SURFACE RUNOFF CONTROL FACILITIES
400.6 CLEANUP OF CONTAMINATED MATERIALS
400.7 INSTALLATION OF SYNTHETIC LINERS
400.8 FINAL RECLAMATION
401. CLUB RANCH PONDS AREA
401.5 SURFACE RUNOFF CONTROL FACILITIES
401.6 CLEANUP OF CONTAMINATED MATERIALS
401.7 INITIAL REMOVAL/RAFFINATE CRYSTALS & SOIL
401.8 PREPARATION FOR LINING EXISTING CRP (1-6)
401.9 CONSTRUCTION OF THE LEAK DETECTION SYSTEM
401.10 INSTALLATION OF SYNTHETIC LINERS
401.11 FINAL CLEANUP
401.12 FINAL RECLAMATION
402. RIVER PONDS AREA
402.5 SURFACE RUNOFF CONTROL FACILITIES
402.6 CLEANUP OF CONTAMINATION MATERIALS
402.7 FINAL RECLAMATION
404. TAILINGS PILES
404.5 DEWATERING LIQUIDS ON TAILINGS PILES
404.6 PLACEMENT OF CONTAMINATED MATERIAL
404.7 RIPRAP COVER FOR ROCK BUTTRESS
404.8 RECLAMATION COVER FOR EXISTING 3:1 SLOPES
404.9 RECLAMATION COVER FOR 5:1 SLOPES AND TOP
404.10 SURFACE RUNOFF CONTROL FACILITIES
404.11 MONITORING DEVICES
CR-400-1
CR-400-2
CR-400-3
CR-400-4
CR-401-1
CR-401-2
CR-401-3
CR-401-4
CR-401-5
CR-401-6
CR-401-7
CR-401-8
CR-402-1
CR-402-2
CR-402-3
CR-404-1
CR-404-2
CR-404-3
CR-404-4
CR-404-5
CR-404-6
CR-404-7
04/20/89
04/20/89
11/26/90
11/26/90
04/18/89
11/20/89
11/20/89
11/20/89
1992
1992
1992
1992
1993
Pending
Pending
Pass
Pending
Pending
Pending
Pending
2003
2003
Pending
Pass
Pass
Pass
Pending
Pass
Pending
Pass
Pass
1995
Pending
Pending
Figure 5
A portion of the Project Summary Report taken
from the Construction Database File
533
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for development of workable solutions and achievement of
constructable remedies that attained the goals of the Remedial
Action Plan.
As an example, one of the first projects undertaken was the
construction of two 15-acre evaporation ponds in the valley.
These ponds were placed adjacent to the six existing unlined
raffinate containment ponds. During the course of pond
excavation, it was found that seepage from the existing ponds
was migrating upvalley into the new pond area. The project
engineer, OSC and the construction foreman evaluated the
problem in the field. It was decided to excavate a trench to
bedrock in order to intercept the seepage. In addition, the
design of the one affected pond was modified by adding a
seepage interception drain under one corner at a level below
the leak detection system. In a matter of three hours, a
solution to the problem had been agreed upon and construction
initiated. The trench sump was monitored and showed a steady
decrease in flow. Within sixty (60) days all flow from the
trench had stopped.
The design of the leak detection system for the evaporation
ponds is another area where field modifications were made. The
original design specified in the RAP called for three parallel
drain lines underneath each pond. These lines converged to a
single sump.
As construction progressed, it became evident that the leak
detection system did not cover some critical areas of the ponds
and was short in comparison to the length of seams in the
synthetic liner. The system was redesigned to a dendritic
pattern in order to cover more areas and was also made longer.
The final design decisions on location and extent of the system
were made in the field.
In another instance, problems arose with the placement of the
raffinate crystals in the crystal repository. The raffinate
crystals have a hygroscopic nature and are largely composed of
water (moisture content-70%). Excavation caused breakdown of
the solid crystals and appeared to increase the free water
content due to the further breakdown of the crystals.
Placement of the crystals also appeared to increase the free
water content. Unlike soil, the free moisture content of the
crystals increased as the material was worked. This phenomenon
was observed in the field early in the placement process as
pumping was obvious. The project engineer, OSC and
construction manager met and discussed the problem. Through
trial and error and field observation, a series of procedures
were developed to handle crystals with varying moisture
539
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contents. The key element was to avoid handling the crystals
as much as possible. Lift thicknesses were allowed up to four
feet for wetter material. The lifts were placed in segregated
cells and allowed to "set up". In 3 to 5 days depending upon
the weather conditions, the cells would "set up" much like
concrete. Several cells were excavated in order to determine
the degree of compaction and consolidation of the lifts. Sand
cone and standard Proctor density tests using a single point
method were also conducted to confirm compaction.
The development and use of a State Oversight Management Program
has benefited the Uravan project by organizing the inspection
activities to be conducted in an enforcement role. With the
existence of the Oversight Management Program, the emphasis has
been on evaluating and solving problems in the field by
allowing the State OSC to operate in a quality assurance
capacity.
The ability of the OSC to be on-site to observe field
conditions encountered and to approve changes in the field has
allowed the Uravan cleanup to proceed in a timely manner with
minimum delays and at a cost saving to the company. The OSC
must have a complete understanding of the intent and content of
the RAP in order to make timely and correct decisions. The
Oversight Management Program for Uravan is one tool that is
useful for this task.
Cotter Uranium Mill Site
Cotter Corporation (Cotter) is a uranium mining and milling
company that owns and operates a uranium-vanadium mill near
Canon City, Colorado. The Cotter Canon City mill site is
located in Fremont County in the south central part of
Colorado, approximately 96 miles south of Denver (see Figure 1)
and two miles south of Canon City.
The Cotter mill facility, which was constructed in 1958,
produces uranium concentrate (yellowcake) and recovers
molybdenum and vanadium as a byproduct. The mill is licensed
by the Colorado Department of Health, but has not operated
since 1987 because of the low cost of uranium from foreign
competitors.
The Cotter site includes approximately 1.4 square miles (880
acres) and contains an inactive mill (alkaline leach process),
an active mill (acid leach process), a partially reclaimed
tailings pond disposal area and an active tailings pond
disposal area. During operation of the old mill from 1958 thru
1979, tailings and liquids (raffinate) were disposed on site
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into several unlined ponds (Figure 6). During the period from
1978 to 1981, two new clay- and synthetic-lined impoundments
were constructed. The raffinate was transferred into the
primary impoundment and the solid tailings were transported
into the secondary impoundment. The primary impoundment is
presently being used for storage of the acid leach mill
tailings and water from ground water interception facilities.
The mill site is located within the drainage area of Sand
Creek. Sand Creek is an ephemeral stream until it nears the
Arkansas River, where it becomes perennial. The Sand Creek
channel travels in a northerly direction from the mill, under a
flood control dam constructed by the Soil Conservation Service
in 1971, into a suburb of Canon City called Lincoln Park and'
eventually enters the Arkansas River. Lincoln Park is the name
the EPA used when the site was placed on the NPL.
The major source of contamination is located in the area where
the tailings were originally stored in unlined ponds. The
mill-derived constituents found in the uranium tailings were
released to ground water on-site and generally followed the
Sand Creek drainage into Lincoln Park and into the Arkansas
River.
Historically, the Soil Conservation Service (SCS) dam prevented
surface water flow from the site into Lincoln Park. However,
hydrologic and water quality data indicated that a shallow
ground water pathway existed beneath the SCS dam. This pathway
allowed ground water to migrate from the site into Lincoln
Park. Since this was a major pathway of contamination, the
Remedial Action Plan (RAP), agreed to by Cotter and the State,
required Cotter to construct a clay hydrologic barrier and
water withdrawal system at the upstream side of the SCS dam.
Other remedial activities included construction of ground water
flushing systems and additional monitoring wells; expansion of
the secondary impoundment; further removal of soils; and
additional studies of surface water and soils media.
Cotter Field Oversight
At the SCS dam, the RAP required a trench to be excavated to
the Vermejo shale formation, which dips 11 degrees in a
southerly direction below the dam and towards the mill site.
The Vermejo Formation outcrops near the crest of the dam.
After the trench was excavated into the shale and verified by
the OSC, a 14-foot-thick, compacted layer of clay soil was
placed at the downstream end of the trench and the
over-excavated area was backfilled with loosely-placed random
fill. As part of the water recovery system, a 2-foot-wide
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SECONDARY IMPOUNDMENT
APPROXIMATE
UOCAT10N OF
HYDROLOGIC
BARRIER
KEY:
* Rotary
O Core
® Rotary and Core
(twinned hole)
PRIMARY IMPOUNDMENT
ADRIAN BROWN CONSULTANTS. INC.
DRILL HOLE LOCATIONS
CONTOUR INTERVAL=10-
Figure 6 - Cotter Uranium Mill Site Map
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drain material (pea gravel) was to be placed against the
upstream wall of the trench. This proved to be impractical as
the excavated material was primarily alluvium, which constantly
sloughed during excavation. This caused over-excavation and
created an uneven upstream face. The construction of the
2-foot-thick gravel drain proved to be impossible, as shown on
the construction drawing (Figure 7). The contractor proposed
constructing a vertical trench in the random fill (Figure 8).
First, the random fill would be placed in 2-foot layers; then,
a backhoe would excavate the trench. The trench would be back
filled with pea gravel and then another 2-foot layer of
uncompacted random fill would be placed before excavating the
trench through the random fill to the pea gravel. During the
excavation of the trench, any random fill that caved in on the
gravel was removed by hand. This system worked because it made
construction easier, inspection of the trench and fill was easy
to do, and it met the intent of the remedial activity. The
system has been operable with no problems for 2 1/2 years.
In the fall of 1988, Cotter expanded the secondary impoundment
by raising the side slopes around the east portion of the
impoundment with compacted clay- A forty mil synthetic liner
was then connected to the old liner, which had been placed in
operation in 1980. The impoundment was then flooded with
highly acidic (pH 2.0) raffinate. During the fall of 1989, a
mill worker performing a routine inspection observed a soft
area underneath the exposed liner. Cotter management and the
On-Site Coordinator were immediately informed. An
investigation followed.
Because the pond was only a few feet deep, a clay dike was
constructed to isolate the problem area. Liquid within the
dike enclosed area was drained and the liner was exposed. The
seam between the old and the new liner was intact, but several
small holes were observed. These were mostly in the new
liner. The liner was removed in the problem area. It was
observed that only the upper few inches of the underlying clay
liner were impacted by the raffinate. The soft, wet clay was
removed, replaced with clean clay and recompacted. The liner
was then replaced. There have been no other observed problems
with the liner.
Since the State representative was on-site, he was available to
be immediately notified of the problem, to observe the
investigation, to participate in the resolution of the problem
and to assure that the remedial activities were performed
properly.
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01
+ 30-
+ 20-
Rock Surface Preparafion os per
Section 6.3.8 of the Speci f tcotions
istinq Bench
-1-62 Appronmole Heel of Enisling
Sond CreeK Dom
Approxirnole 'Top of
Weathered Rock
BARRIER X-SECTION AT STATION 14+QO
SCALE IN FEET
0 10 20 40
Figure 7 - Engineering Design for Construction of the Clay Hydrologic Barrier and Gravel Drain
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01
>£»
cn
54 80-,
5460-
5440-
5420-
BARRIER CROSS SECTION C-C' AT STATION 13*50 ( NEAR C-C- )
Figure 8 - Construction As-Built Drawing of the Hydrologic Barrier and Gravel Drain
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Cotter Oversight Managment Program
Both the Uravan and Cotter Oversight Management Programs were
tied directly to requirements set forth in the respective
remedial action plans.
However, the Cotter RAP was considerably different than the
Uravan Remedial Action Plan. While the Uravan plan was
primarily construction-oriented, Cotter's plan required several
studies to be completed off-site, besides doing remedial
construction activities on-site. Therefore, the Oversight
Management Program (OMP) at Cotter had to be set up differently
than at Uravan.
The Cotter OMP requirements included following the schedule for
remedial activities, preparing plans and reports, and
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conducting specific remedial actions. The OMP was divided into
two key systems. The systems were termed (1) Status of
Remedial Activities and (2) Oversight Activities.
The Status of Remedial Activities system provided a method to
track scheduled activities and report requirements set forth in
the RAP. This sub-program was used to track scheduled dates
required in the RAP, to verify that these dates had been met,
to assist in the planning of the State's oversight activities,
and to record the State's approval of the documents or
activities.
The Oversight Activities system described the specific
inspection and review activities, including corrective actions,
if necessary, to be conducted by the State's On-Site
Coordinator.
The Oversight Activities sub-program was used to verify that
remedial activities at the site were conducted in accordance
with the RAP requirements; to provide a detailed, retrievable
record of State oversight activities; and to confirm that the
requirements set forth in the RAP were completed successfully.
Memo fields were provided for each oversight activity so that
inspection or review notes could be entered, reviewed, and
edited if necessary. Additionally, memo fields were provided
for recording non conformance items and corrective actions.
All memo fields were keyed to the date of inspection, the
subject of the inspection and the inspector. A specific
oversight activity may be inspected more than once and,
accordingly, entered in the memo fields.
Although the Uravan and Cotter remedial programs are different,
the Oversight Management Programs developed for the State have
been very beneficial and successful. It has also been adapted
for use at other Superfund sites in Colorado, where the State
is responsible for oversight management.
CONCLUSION
The Oversight Management Programs were developed as a tool for
eventual delisting of State lead Superfund sites from the
National Priorities List. As these sites are projected to take
over twenty years for remedial action to be completed, it is
likely that different personnel will be around than those who
started the job. Therefore, the State had to find a way for
the OSCs responsible for delisting the sites (possibly in the
year 2010) to have all of the information available to them,
presented in a succinct but complete manner, without having to
go through thousands and thousands of records. It is
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anticipated that, the Oversight Management Programs written for
the Uravan and Cotter Superfund sites will accomplish this
task.
The State of Colorado's experience with oversight has been that:
1. Organization of the project through the use of a simple
oversight management program is imperative to assure and to
document that the activities are being performed in
accordance with the intent of the Remedial Action Plans.
Program development has also focused attention on the
intent and purposes of the Remedial Action Plan for each
site.
2. The ability of the OSCs to be on-site is critical to the
understanding of problems that arise. The on-site presence
reduces misunderstandings about conditions observed and
minimizes projected delays. Project delays have been
further minimized by allowing the OSCs to approve many
changes in the field.
The State of Colorado's approach to project oversight has
provided five important benefits:
1. The site remedial action plan is well defined;
2. Implementation of the remedial action plan is well
documented;
3. The site conditions and situation are understood;
4. Additional quality assurance is provided; and
5. Project delays and costs are minimized.
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REFERENCES
Brown, A., et al 1989. First Draft Proposed Pilot Test Design
Plan for the Old Tailings Ponds Area Flush. Adrian Brown
Consultants, Inc.
Cotter Corporation, 1989. Final Construction As-Built Report
for the Hydrologic Barrier at the Soil Conservation Service
(SCS) Dam.
Gossett, W.R. 1984. Engineering Report and Design
Specifications for Water and Waste Managment Plan, Part I,
at Cotter Corporation Uranium Processing Facilities, Canon
City, Fremont County, Colorado. Morrison-Knudsen Co., Inc.
Junge, W.R. 1989. Oversight Management Program for the Cotter
Remedial Action Plan, Canon City, Colorado. W.R. Junge and
Associates.
Junge, W.R. Simpson, D.H. and Stoffey P.S., 1988. Inspection
and Certification Program for CERCLA Remedial Activities at
Uravan, Colorado. Colorado Geological Survey.
State of Colorado vs. Cotter Corporation Final Consent Decree,
1988.
State of Colorado vs. Union Carbide Corporation and Umteco
Mineral Corporation Final Consent Decree, 1987.
Umetco Minerals Corporation, 1987-1988. Final Plans and
Specifications for the Uravan Project, 31 Volumes.
Author(s) and Address(es)
Don Simpson, Senior Geologist
Phil Stoffey, Senior Geologist
Colorado Department of Health
Radiation Control Division
4210 East llth Avenue
Denver, CO 80220
(303) 331-8480
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Mobilizing for Remedial Construction Projects
R. Gary Stillman, PE CCE
Weston Services, Inc.
Roy F. Weston, Inc.
1 Weston Way
West Chester, PA 19380
(215) 430-7437
INTRODUCTION
The start of a remediation project is an exciting time. Expectations are high for a successful project.
The design and studies are now complete and the engineers can start to realize the fruition of their
labors. The local populace can see first hand that the problem near to them is now being remediated.
The mobilization of the project occurs after the remediation contract has been signed and prior to the
remediation starting in the field. However, unless the mobilizing of the project is completed as
scheduled and within budget, this excitement may turn to despair.
The mobilization of the field construction forces and materials is a critical time in the project. Plans
have to be written and filed, equipment delivered onsite, and personnel trained. This paper will
explore the requirements for a successful mobilization and develop a checklist that the project or
construction manager can utilize to ensure that this activity will be complete as required and when
needed.
Most remediation companies have procedures to be followed or plans to be approved prior to starting
onsite. The contract with the client may also have submittals and policies that have to be completed
or followed prior to starting onsite. Examples of these submittals are:
o Quality Control/Quality Assurance Procedures and Plan
o Site Health, Safety, and Emergency Response Plan
o Work Plans
o Disposal Studies
o Project Schedule
o Cost Estimate
In addition to the early plans, the mobilization itself entails planning and procurement to ensure that
the project is ready to start on time with all necessary materials on hand.
The four major areas of mobilization to be discussed in the following paragraphs are plans and
submittals, project controls, procurements and the onsite mobilization.
BACKGROUND
The activities described in this paper are for a remediation project that is ready to start in the field.
The record of decision has been issued and the design is complete. The client has awarded the work
to a remediation firm and requires specific documentation prior to starting onsite. The scope of the
project is for construction only and does not include detailed design or definition of the overall
remediation approach.
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DISCUSSION
PLANS AND SUBMITTALS
Prior to the start of the remediation, many clients require plans and reports to be written and
approved. For example, the U.S. Army Corps of Engineer projects require the submittal and approval
of definite plans such as the Quality Assurance/Control Plan, Site Health and Safety Plan, Work
Management Plan, and an environmental report. Most remediation companies also require the
corporate approval of these plans prior to construction.
The Quality Assurance/Control Plan (QAP) defines the corporate management structure required to
ensure a successful project. The Quality Assurance management team assigned to the project will be
identified. The person(s) onsite who is responsible for the QA/QC functions will be named. This
person will usually report directly into the corporate department and indirectly to the site manager.
It is expected that a member of the firm's senior management will be assigned to oversee the project.
The QAP will also identify what site specific tests are to be performed and what work is to be
witnessed. These steps will help to verify that the quality of work being installed is as specified. The
timing and frequency of the tests will be listed so the site quality assurance person will be available
to supervise.
The Site Health, Safety and Emergency Response Plan (SHERP) is probably the most important
submittal of the pre-construction period. This report includes both general construction and remedial
construction components of the work.
The SHERP consists of five main section. The first section deals with the scope of work for the
project. The remediation technique and the contaminants to be removed would be described in this
section. Owner furnished materials and services are identified so the contractor will not provide nor
perform more work than they contracted. This section should reiterate the contractual scope of work
and provide the basis for the work plan.
The second section is the listing of hazards associated with the project. The hazards can include
physical, chemical, biological, and weather. Physical hazards can be the structural integrity of the
facility for the personnel to travel through. They also can refer to debris or buried objects in the
ground.
Chemical hazards refer to the chemicals and contaminants that are found on the site. Pre-
construction sampling for the design has usually identified the chemicals. The characteristics of the
chemicals and their effects are also listed in the section.
The biological hazards can include both wastes and animals. The presence of biological waste at the
site represents problems that need to be identified. Animals at a site can pose a definite threat to the
workers. Bites from snakes, dogs, and insects can injure or disable the workers.
The weather conditions are a hazard to the workers who must wear personal protective equipment.
Hot sunny weather will limit the time in the suits and can cause heat stroke or other disabilities.
The scope of work and list of hazards are the basis of the next two sections which are risk assessment
and level of protection requirements. The risk assessment will break down the scope of work into
distinct activities where identifiable risks are present. Some risks, such as wildlife and exposure, can
impact the entire project, whereas the chemical contaminants may only affect parts.
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The level of protection required for the different stages of the work is based on the risk assessment.
Based on engineering, proper work sequences will be established that may minimize or lessen the level
of protection. Having a worker in a high level of protection should only occur if engineering
modifications or construction sequencing cannot help lessen the level. The air and site monitoring
that is required will be described in this section.
The final section of the SHERP deals with the contingency plans for project. These plans are the
basis for action if something goes wrong such as an injury occurs, fumes escape, or liquids spill. The
escape routes, hospitals and doctors are all listed so the field personnel can react.
Other submittals that may be required are the security, environmental, and disposal plans. Depending
on the client, project and corporate requirements, these documents can be lengthy and detailed.
The security plan outlines how to secure the site for the duration of the project in order to minimize
disruptions. Fencing and guard services are examples of the approaches.
The environmental plan discusses how the immediate area around the site can be protected from
onsite contaminates caused by the remediation. During excavation and site work, dust control is a
problem which can be remedied by watering the site. To minimize soil runoff, methods of erosion
and sedimentation control are defined. Pre-construction surveys to define background limits for air
and water are outlined and the tools listed.
The disposal plan will list the wastes that have to be disposed of offsite. Included in this plan are the
methods of transport of the wastes, what wastes are hazardous or non-hazardous, and the required
disposal procedure. The disposal facilities that are to be utilized are also to be listed in this plan.
As part of the early submittals, the project team must review what permits are required for the work.
Local or state officials may need to be notified. Fire, building or demolition permits usually take
weeks to obtain, so early application will be necessary. The facility being remediated may have its
own unique permits to be obtained prior to starting.
The submittal and approval of these plans and permits is required prior to arriving and starting work
at a site. This approval process is an important part of the mobilization process.
PROJECT CONTROLS
The establishment of a project control procedure prior to mobilization should be a requirement of all
remediation firms. The control procedure should include the work plan, the project schedule and
estimate, and the cost and scheduling monitoring system.
The work plan is sometimes included as one of the early submittals, however it is an integral part of
the project control plan. This plan details the sequencing of the work activities for the remediation.
Each of the activities are defined with the inter-relationship between them identified. This document
is worked closely with the scope of work so that entire remediation effort is covered. The number
of work crews and the equipment required are based on the work plan.
As part of the work plan, a work breakdown structure (WBS) of the project is established. The work
plan is listed by WBS so the work activities are defined for scope. The WBS is the basis of the activity
number for the project schedule and the cost breakdown of the estimate. Progress is monitored for
both cost and schedule by the WBS.
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The time-phasing of the work plan creates the project schedule which is developed utilizing critical
path method (CPM) techniques. The CPM schedule will identify the critical path of activities that
the work must follow and finish on time in order for the project to be completed within schedule.
The start and complete dates of the activities and float for each will be developed. The development
of the project schedule must be completed before the mobilization is started. The schedule activities
are coded by the WBS.
The project estimate is developed based on the work scope and plan in conjunction with the schedule.
This document will develop the cost of the activities listed in the work plan according to the WBS.
Various techniques or approaches can be used for estimating the cost of each activity once the
quantity of work has been established. Approaches based on productivity units or crew sizing for the
labor cost can be utilized. For the material or equipment pricing, unit prices are developed based on
vendor quotations or historical information (including manuals). The actual approach to the estimate
is based on the information available, time allowed, and the experience of the estimator.
In developing the estimate, the level of protections must be known for both adjustments to the work
productivity and number of crews required as well as for the cost of the personnel protective
equipment (PPE). A review of the SHERP will provide the necessary information on the PPE
required for each activity. The impacts on productivity due to the levels of protection is one of the
main cost drivers for remediation work.
One major part of any remediation estimate is the cost of offsite disposal. For the projects where the
wastes are remediated onsite or encapsulated, the cost will be less. However, the offsite disposal may
include PPE and other wastes. For other projects such as a drum removal or the removal of
contaminated soil, the disposal may be up to 80% of the cost of the work. The development of the
estimate for disposal is based on the disposal plan which is developed as one of the early submittals.
The estimate detail will be by WBS so it can relate to the project schedule. The use of the WBS will
allow each work activity to have durations, start and complete dates, and costs. This level of
information will help in the monitoring of the project. These two documents need to be completed
prior to mobilizing onsite.
The integration of the estimate with the accounting and cost monitoring systems will also occur during
the mobilization period. The project estimate is allocated into the accounting system WBS (the
project's code of accounts). The WBS provides the structure with which the costs will be tracked.
The relationship between the schedule and cost monitoring system will allow the costs expended to
be related to the completeness of the work. Earned value calculations and performance indexes can
be developed using the actual costs and percentage complete of the schedule.
The project control system plan needs to be established prior to mobilizing. The work plan, schedule,
and estimate must be completed and budgeted at this time.
PROCUREMENTS
During the pre-mobilization and mobilization periods, procurements of the necessary materials,
equipment, and subcontracts are occurring in order for the work to proceed. The timing of the
deliveries of these items to the site is an important part of the project and is based on the work
schedule.
Prior to the placement of any purchase orders or subcontracts, a review of the terms and conditions
of the contract with the client must occur. This review will identify any commercial requirements
that must be flowed down to vendors or subcontractors. Examples of these requirements include the
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insurance limits, prevailing wage rates, union restrictions, and indemnification. The purchasing agent
must include these client dictated terms and conditions in the procurement documents.
The client may indicate what vendors or subcontractors may be used (or not used) on the project and
ask for a review of the bid list. The number of bidders for each solicitation may also be dictated by
the client.
The first priority will be the procurement of the temporary construction facilities which will be
required onsite during the mobilization period. A checklist of typical early construction facilities is
included as Figure 1. The trailers required for the project will be procured along with the furniture,
utilities, and office equipment.
Decontamination facilities that have to be procured such as wash stations or decontamination trailers
will be obtained. Monitoring equipment for the perimeter of the site will be specified and procured
at this time. The attached checklist will aid in these early procurements that will be required.,
The health and safety supplies that are required for the mobilization and early activities must be
obtained. A review of the SHERP and the schedule will identify what PPE and other materials are
required early at the site. Other materials may include power washers, wash basins, caution tape or
fencing, signs etc. The work can not proceed unless the correct health and safety supplies are at the
site.
The construction equipment required for the work is based on the requirements set forth in the work
plan and costed in the estimate. The schedule will identify when the equipment is due onsite and the
require duration. Whether the equipment is rented, leased, or purchased is usually based on the time
required on the site. How the equipment will be used and if it can be decontaminated will assist in
this decision.
The work plan and estimate will identify what work will be subcontracted and the scope of each
subcontract package. The schedule will state when the subcontractor is due on the site to perform the
work. The soliciting of subcontractor bids for the work may occur during the pre-mobilization period
but is schedule dependent. However, the project team must know what are the packages with their
scopes and estimated values at this time. Early subcontracted services to be obtained during
mobilization may include surveyors, drillers, and security.
Offsite services required during the construction will be procured at this time. These services include
non-hazardous waste disposal, laundry, sanitary facilities, and temporary office help.
Remediation projects require samples to be taken and analyzed. The awarding of the laboratory work
is a major effort during this time period. Also a determination of whether an onsite laboratory would
be cost-effective should be performed. Often the client will have pre-qualified laboratories for the
work.
If the remediation is to occur outside the firm's normal working area, local contacts have to be made.
The establishment of blanket ordering agreement with local material and office supply firms should
be set at this time. Credit applications and a bank account will be established.
A successful mobilization and start of a project is dependent on how complete these pre-mobilization
procurements are. Checklists, review of the estimate and site visits all aid in the earlier procurements.
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ONSITE MOBILIZATION
All the activities described in the above paragraphs usually occur prior to mobilizing onsite.
However, the actual moving to the site can present a myriad of activities that have to be completed
before the actual site remediation can begin.
The first activity onsite is usually a pre-construction conference with the client's representative
responsible for the work. Work restrictions, facility permits, and local building and safety codes will
be discussed at this time. If the work is to occur at an on-line facility, plant personnel may be
introduced to the remediation team as points of contacts. This meeting may (and should) occur
several weeks before moving onsite so permits and other potential problems can be identified and
obtained.
The security requirements of clients vary. On-line facilities may require that all workers check in
every day. Badges may be required on each worker. Time (and costs) must be allotted for the
security restrictions. These requirements are usually listed in the security plan.
Among the first activities on the site will be surveying and the laying out of the site. The "hot" zone
will be established and marked by fencing, tape, or stakes. Likewise the contamination reduction
zone and the clean areas will be determined at the site. The site security requirements will be
enforced at this time based on the layout.
After the zones are laid out, the construction village and decontamination facilities will be
constructed. The trailers will be set and utilities established. At some sites, initial sitework might be
required prior to setting the construction village. The sitework may include road work, clearing and
grubbing, or the setting of perimeter fencing. Gravel can be placed for parking or roadways.
The building of the decontamination facilities is an important part of the site mobilization. These
facilities include the cleaning pad for the equipment, the personnel wash stations, the PPE disposal
drums, and the "decon" trailer. These temporary facilities must be completed prior to the remediation
work initiating.
There are personnel related activities that have to be completed during this mobilization period. Most
SHERP's require the onsite workers to receive site specific safety training. This training session can
last several days depending on the size of the project. New workers coming to the site at a later date
will also have to receive this site specific training. Site personnel may need to have physicals or blood
tests in order to work on the site. These initial blood tests will be used as a baseline to verify any
contamination that the worker may receive during the remediation process. Many clients and
remediation firms require drug tests for the site personnel before they can start work at the site.
The onsite mobilization is the ending of the pre-construction planning and the beginning of the actual
remediation onsite.
CONCLUSION
The length and cost of the mobilization period for a project will vary depending on the project's size
and remediation technique. For example, the mobilizing of a transportable incinerator may take
several months and cost hundreds of thousands of dollars. Mobilization for a small remediation
project may only last a few days. This period must be scheduled properly and all activities identified.
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All the mobilization activities are inter-related and their completion is required before moving onsite.
The early submittals such as the QA plan and SHERP will aid in the development of the work plan
which is the basis of the project schedule and estimate.
The estimate and schedule are used to help determine the procurement requirements of the project
as to what items are required, their duration onsite, and their quantity. The completion of these
procurements is necessary for the onsite mobilization and remediation to proceed.
The estimate also forms the basis of the budget for the project. For a remediation project to be
completed within budget, careful tracking of the commitments and expenditures is necessary for
management to understand the financial status of the project and to take corrective actions.
Coordination between the updating of the schedule and tracking of the actual costs will provide
management the tool for this understanding.
Having achieved mobilization within cost and on schedule will not guarantee a profitable and
successful project, but it will allow the work to start when and as planned.
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FIGURE 1
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TASK NAME TASK NUMBER:
SUBMfTTALS
HEALTH & SAFETY PLAN
WORK PLAN
DISPOSAL PLAN
TRANSPORTATION
ACCOMODATKJNS
PERMITS
UTILITIES (POWER.WATER.HEAT.SANITARY)
SAFETY EQUIPMENT PEP
FACILITIES
OFFICE TRAILER
STORAGE TRAILER
DECON TRAILER
DRINKING WATER
FAX MACHINE
COPY MACHINE
TEMPORARY STORAGE TANKS
MANLIFTS
PHONE(S)
WALKIE-TALKIES
FUEL SOURCE/GAS CORD
FENCING. CONSTRUCTION
FENCING. SILT
SECURITY SERVICES
PUMPS
DRUMSADVERPACKS
EQUIPMENT
BACKHOE. EXCAVATOR
DUMP TRUCK
TRUCK/VAN - PASSENGER
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STEAM CLEANER
COMPRESSOR
WET/DRY VAC.
TEMP. ELEC. EQUIP.
ROPES
CAUTION TAPE
LOCKS
LADDERS
DUMPSTER/ROLL-OFF
NON-HAZ. CONTAINERS
HAZ. CONTAINERS
GANG BOX W/ SAWSALL W/ EXTRA BLADES
GANG BOX W/ SLEDGE
GANG BOX W/ BOLT CUTTERS
MECHANICAL HAND TOOLS
ELECTRICAL HAND TOOLS
SEE ATTACHED LIST
NO. TYPE
RESPONSIBILFTY
PM CM SM NOTE
RESPONSIBILrTY
PM CM SM NOTE
RESPONSIBILITY
PM CM SM NOTE
ON
HAND
SOURCE/COMMENTS
ON
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SOURCE/COMMENTS
ON
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NR . NOT REQUIRED
0 - OWNER
1 • INDIVIDUAL
557
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Construction Disputes On
Hazardous Waste Projects
Theodore J. Trauner, Jr., P.E., P.P.
J. Scott Lowe, P.E.
1334 Walnut Street
The Hamilton Building
Suite 200
Philadelphia, PA 19107
(215) 546-0288
INTRODUCTION
The purpose of this paper is to provide a framework for the recognition and prevention of potential
construction disputes on hazardous waste sites. On many projects accomplished to date, costs have
been experienced well beyond those anticipated because of the occurrence of construction claims.
Therefore, it behooves all parties concerned with new projects to educate themselves and their staffs
such that disputes can be minimized and measures can be incorporated into the contract documents
to allow a cost effective method of resolving potential problems.
The objective of this paper is threefold: 1. to assist in the identification of potential problem areas
which may create an environment amenable to claims and disputes; 2. to suggest areas where better
planning and execution can reduce the incidence of disputes, and: 3. to suggest mechanisms that can
be used to allow for prompt and equitable resolution of problems should they occur.
BACKGROUND
All construction projects have the chance of experiencing a claim or a dispute. To understand the
nature of disputes, some basic definitions are in order. The first two terms that must be understood
are changes and claims.
In all construction contracts, some form of a clause dealing with changes is invariably incorporated.
A change in the simplest form is a requirement by the Owner to the Contractor to perform s»me work
which is different from that which is specified in the contract documents. For the time being, we
will confine our comments to projects which are design specifications as opposed to performance
specifications.1 In essence, when a contractor bids a fixed price job or even a unit price job, he is
bidding to perform exactly what work is specified/defined in the contract documents. The contract
documents being the plans and specifications. If the contractor perceives that he is being asked to
perform any work which is not specifically defined in the contract documents, then he will request
additional compensation in the form of a change order. Thus in the simplest sense, a change is any
deviation from the contract documents.
Design specifications define in detail the work to be performed by the Contractor. There it virtually no design
requirements placed upon the Contractor but instead he is required to comply with the detailed requirements specified in the
contract documents. In a performance specification, the design is not defined. Instead a Contractor is required to produce an
end product which performs in the manner described. In performance specifications, the Contractor does assume a design role.
Normally, most hazardous waste projects are not amenable to performance type specifications.
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A claim is normally termed a dispute. In essence it is a foul and vile word for a change. If,one
pauses and reflects for a moment, if the two parties agree that an item is different and a change, they
can usually resolve it by change order. It is only when agreement cannot be reached that it becomes
a claim. Therefore, a claim is simply an unresolved change order.
Claims occur when a disagreement exists at any of four levels. First, the Owner and Contractor may
not agree that a change exists. In other words, while the contractor believes that some work is
different than that specified, the Owner or its designer may disagree, asserting that the work is
incorporated in the already existing contract documents. Second, the Owner and Contractor may
disagree as to the party responsible for the change. In other words a question of liability for the
change exists. The Contractor may assert that the change was caused by the Owner, while the Owner
believes that the Contractor caused the change situation to occur through some action or inaction of
his own. Third, the parties may disagree on the impact of the potential change. For instance, the
Owner may agree that a change exists and that it was responsible for it, however, it believes that there
is no effect or impact to any of the contractor's work or time on the project. Fourth, the Owner and
Contractor may reach agreement on the preceding three points but cannot agree on the costs
associated with the change. To summarize these four areas, the following four questions must be
resolved:
1. Is it a change - i.e. something different than the requirements of the contract?
2. Who is responsible or liable for the change?
3. What are the impacts of the change?
4. What are the costs of the change associated with the specific impacts?
Disputes on hazardous waste projects may emanate from many sources. While it is impossible for this
paper to address all possible sources, the most common ones include, directed changes by the Owner,
errors and omissions in the plans and specifications, differing site conditions, and constructive
changes. The Discussion section of this paper will elaborate on each of these areas.
As was noted above, most construction contracts are set up to handle changes should they occur. This
is done through the changes clause. Similarly, construction contracts recognize the potential for
differing site conditions, sometimes termed changed conditions or concealed conditions by
incorporating clauses which address these. The astute Owner must recognize that hazardous waste
projects are particularly amenable to certain types of changes and concealed conditions and, therefore,
must structure the contract to allow as many vehicles as possible to be used to reconcile any problems
as they occur. The ultimate goal being the reduction of claims and the avoidance of costly litigation.
These areas will also be pursued in more detail in the following sections of this paper.
In order to summarize the diverse areas of disputes in the remaining discussion, the next section of
this paper will be organized into the specific sections dealing with: Changes - Directed and
Constructive; Differing Site Conditions; and Errors and Omissions. Within each discussion comments
will be provided concerning how they can be reduced and also how contractual considerations can
help alleviate disputes in each of these areas. Finally, the area of delays and inefficiencies will be
addressed since this area generally constitutes the most expensive form" of disputes which occur, and
can apply to any of the three preceding areas.
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DISCUSSION
Prior to a specific discussion of changes and claims, it is worthwhile to pause and reflect on the
elements that are unique to hazardous waste projects. As was noted above, every project is
susceptible to changes. Hazardous waste projects, however, have risks which are not within the
normal experiences. For example, the work environment on the project is different than what most
construction personnel are used to. They are working with hazardous materials. Therefore, special
and more stringent procedures are followed throughout all operations. As a consequence, a higher
level of care and skill must be applied throughout the project. This necessitates better education of
the crews and more diligent supervision by the foremen and superintendents.
Construction operations are often conducted very differently than normally pursued. For instance,
in an excavation operation, the risks of cross contamination demand a well planned methodical
removal method that will not normally yield the same efficiencies one might estimate. Hence, unit
costs are higher and must be so anticipated up front.
When designing and estimating a hazardous waste project, all parties must recognize the unique
character of the work. Site borings or investigations are a good example of this. Normally, a designer
or a contractor will draw conclusions about the site and how the work must be performed based on
"representative" borings taken throughout the site. In a normal project this is reasonably reliable since
soils follow patterns, seams, profiles, etc. The material at a hazardous waste site, however, was
deposited by man in a random fashion. Therefore, despite indications of trends from borings spaced
at 500 feet, the material between may vary considerably. Therefore, our entire mind set must change
when approaching both the design and the construction of a hazardous waste project.
In assessing the time required to perform work, one must recognize that unanticipated problems may
occur and that the more stringent methods of execution will demand longer time durations for
activities than normal. Consequently, project and activity durations must be adjusted and understood
prior to beginning operations. Oftentimes, delays are not really delays, but merely the reality of the
actual time required to perform the work.
Hazardous waste projects are relatively new to the construction arena. Therefore, it is not surprising
that Designers, Contractors, and Owner's Representatives are not as familiar with the project and its
needs as they would be for more conventional jobs. This lack of familiarity denies them the ability
to anticipate and recognize problems and also to resolve them as expeditiously as possible.
Given this understanding, let us now look at the areas that can lead to claims and how we can best
control them.
Changes - Directed and Constructive
As was noted above, changes and claims may emanate from many sources. The first item noted was
changes which are directed by the Owner. This type of change normally occurs when it is recognized
that the Owner desires something to be added to the work which was not originally specified in the
contract. A wide spectrum of reasons exists for why this occurs. For example, the Owner may find
that the low bid received and awarded is lower than the funds available. Consequently, the Owner
may be able to have some additional work performed which was desired but was not considered
essential. When the contract documents were created, this work was not incorporated in the interest
of insuring that the bids would be within the funding available. Now that the Owner recognizes that
the bids are below budget, the decision is made to expand the work by adding those items that were
desirable but not originally included.
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The Owner may also recognize during the project that some additional work is required that was not
originally identified during the project design concept. This is not necessarily an omission but rather
a lack of recognition of a need. Regardless of the initiator, the Owner directs the Contractor to
perform additional work in accordance with the changes clause.
In order to reduce the chance of changes or claims in this area, an Owner may consider including
work in the bid documents in the form of alternates or adds. When an alternate is used, the Owner
is not obligated to award the execution of that work. Instead, the Owner awards the base contract
work and can award as many of the alternates or adds as it deems appropriate. The Contractor has
already submitted prices for each add item, and, therefore, there should be no dispute as to the cost
of respective items. The Owner should be cautious, however, that add items are not set up such that
one item requires the execution of another add item by virtue of the physical construction parameters
involved. As long as that does not occur, no problem should exist.
Another consideration by the Owner, may be to include a contract clause for "If and Where Directed
Items". A sample of this type of clause is included at the end of this paper for reference. It is not
suggested that this clause be used verbatim. It is included for reference only, and must be written
and coordinated with the contract documents as a whole. The random use of "off the shelf clauses
can lead to significant problems in the formulation of a construction contract. Therefore, any ideas
gleaned from this paper must be carefully reviewed with the advice of construction counsel. Clauses
such as the If and Where Directed clause are particularly amenable to contracts with unit price items.
Normally, hazardous waste projects have a significant amount of these items.
In essence, an Owner can reduce the chance of problems vis-a-vis directed changes by carefully
considering the amount of work that is necessary, evaluating the importance and benefit of work that
is desirable but not mandatory, and structuring the bid and contract documents accordingly.
In setting up contract documents for changes, the Owner should pay particular attention to structuring
a changes clause which has a clearly defined method for establishing the cost for the change. By
doing this, at the minimum, the fourth area of change resolution - cost - should not create a problem.
The second type of change that creates problems for both parties is known as constructive changes.
A constructive change is a change that is effectively or constructively created by the Owner's action
or lack of action. An entire litany of constructive changes exists and have been identified in
numerous publications. For the purposes of this paper, a few illustrative examples will be provided
such that the reader will understand the concept. If the concept is understood, reasonably any form
of constructive change can then be identified. The initial example that will be used is for a
constructive change known as "late inspection".
Presume that a contractor is working on a site and as part of the contract requirements must perform
some work underground concerning drainage for the site. The drainage requirements specify that the
contractor must install a double walled pipe to remove contaminated liquid from one area of the site
to a treatment facility in another area of the site. The contract further specifies that before the
contractor can backfill the pipe, he must have it inspected and approved by the Owner's
representative. Furthermore, the contract states that an inspector will be available within 24 hours
notice from the Contractor. Given this background, consider the following scenario.
The contractor excavates for the first 500 feet of pipe. He has placed his bedding and set his pipe and
has notified the inspector that he is ready for an inspection. The notification was made at 10:00 am
on a Tuesday morning. The inspector, however, does not show up until Thursday at approximately
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2:00pm. Given this simple scenario, the four questions which were noted above would have to be
considered.
First, is this a change?
Clearly, it is. The contract said 24 hours and the Owner did not live up to this. It is something
different than that which was specified.
With regard to the second question of liability, it appears that the Owner is liable since notice was
given and the Owner's representative did not comply. Presuming that the Contractor can show an
impact to his operations, such as a delay, idle equipment, demobilization and remobilization of
manpower, etc., than the third question is answered. If an impact can be defined, than a cost can be
associated with that specific impact and all elements of a change order are fulfilled.
In the example described above, a change situation was created by the lack of action of the Owner.
Since no revisions were made to the drawings, or no directive was given to the contractor, we do not
have a directed change. But we have effectively or constructively created a change to the contract.
Other types of constructive changes, can include such things as:
Requiring a higher standard of performance.
Improper rejection.
Impossibility of performance.
Withholding material information.
The list could go on at length. Rather than attempting to describe all possible constructive changes,
the reader must recognize that the action or lack of action of the Owner can lead to these types of
changes. In order to prevent them, the Owner should insure that its staff is educated in the area of
constructive changes, and the types and nature of them. Also, the Owner's staff must understand its
obligations under the contract and fulfill them such that no assertion can be made that a constructive
change occurred.
The results of constructive changes can be varied. The majority of the time, these types of changes
will lead to either extra work, delays, or inefficiencies. If the contract is heavily weighted on unit
price items, then the recommendation concerning the If and Where Directed clause would apply in
this circumstance. For delays and inefficiencies, suggestions will be provided later in this, discussion
under that specific topic.
It has been the author's experience that constructive changes that occur on hazardous waste projects
are caused many times by lack of experience on hazardous waste work. For example, remediation
projects that specify excavation and disposal are often managed by personnel with a background in
heavy or horizontal construction (as opposed to vertical construction). While this certainly is
appropriate, it may still be short of the more significant requirement of experience with hazardous
waste. Excavation and backfilling on a dam while conceptually similar, may be markedly different
in actual execution on a hazardous waste site. Therefore, additional training and education should
be considered for the personnel to be employed in the construction resident roles. As an example of
how a lack of understanding can create a problem, consider the following.
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During the excavation of a landfill area on a military base, the Contractor uncovered some
unexploded ordnance. On the first two occurrences of this, the Owner negotiated a method and price
for removal and a bilateral change order was executed. Shortly thereafter, however, more "live
rounds" were discovered. The ordnance ranged from small arms rounds to 500 pound bombs. The
Owner directed the Contractor to develop and submit a unit price for the removal of all ordnance
regardless of the type. This ultimately led to delays and numerous disputes over the actual cost of
removal.
Differing Site Conditions
Differing site conditions, concealed conditions, or changed conditions are a very common problem
in hazardous waste projects. This occurs because most projects deal with either underground or
buried conditions or deal with items that are behind walls, in ceilings, etc. Hence, the chance for
hidden or unforeseen conditions is enhanced.
Generally, differing site conditions are divided into two types, Type I and Type II.
Type I differing site conditions are those which occur because what actually exists at the site differs
materially from the representations made in the contract documents. For example, a recent project
for removal of hazardous waste at an abandoned landfill had contract documents that reflected the
presence of several Key Indicator Compounds (KICs). While the compounds were clearly defined and
the anticipated levels of concentrations specified, certain compounds were not included since the
investigation by the designer did not show their presence. In particular, PCBs were not included in
the KICs and the Contractor reasonably would not have anticipated their existence. The original
studies for the project appeared to be thorough and showed only trace amounts of PCBs, such that
no remediation for them would be anticipated. In reality, the excavation and testing by the
Contractor during the remediation revealed extremely high concentrations of PCBs such that the
material excavated from the site had to be disposed of at landfills which would accept PCBs but which
were never anticipated by any of the parties nor in the contract. As a consequence, the Contractor
was required to perform extra work, was delayed in the progress of his work, and also experienced
a high degree of inefficiency in the excavation, testing, and disposal operations. This was a Type
I differing site condition. What was encountered was materially different than that which was
represented by the contract documents.
A Type II differing site condition exists when material is discovered which is unusual or unexpected
and would not normally be anticipated for that type of work in that location. This type of differing
site condition occurs very seldom, but is noted so that the reader will have a more complete reference
concerning differing site conditions.
In order to reduce the incidence of concealed conditions, the Owner is well advised to not be miserly
during the site investigation phase of the project. Oftentimes a few more borings and a more diligent
investigation of the facilities will uncover items that may not otherwise be noted and could lead to
changes and claims later on during construction.
A second consideration again is the use of the If and Where Directed clause. A third consideration
is to have the contractor perform site investigations as a first phase of a multi-phase contract with
the option of not continuing after the initial phase if conditions warrant a reconsideration of the
project parameters.
It is not recommended that the Owner attempt to protect himself by the use of exculpatory clauses
such as a "don't rely on the borings" type of clause. While these clauses may have some degree of legal
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enforceability, they may still initiate litigation, in which case nobody wins - except maybe the
attorneys.
In performing site investigations, the Owner may consider an independent firm from that which is
providing the design services. In the alternative, the Owner may use a second firm to run a check on
the investigations performed by the design firm. While some may feel that this is a needless expense,
money up front is usually cheap in the long run.
A final consideration with respect to the contract documents would involve the use of a variations in
estimated quantities clauses. This type of clause is set up to allow a contract adjustment if quantities
for a specific unit price item experience a significant overrun or underrun during the actual project.
A sample of this type of clause is included at the end of this paper. Once again it is recommended
that the structuring of the specific clause be prepared with the assistance of qualified construction
counsel. By having such a clause, the Owner may reap the benefit of reduced costs for overruns, and
equity would be afforded the Contractor for underruns such that fixed costs may be covered.
Errors and Omissions
The final area that will be noted involves that of errors and omissions in the plans and specifications.
This is a delicate subject and one that most designers do not like to discuss.
An error or omission basically is a mistake in the contract documents made by the design engineer.
Merely because an error or omission exists does not mean that the designer is liable for any increased
costs. Let us address the two items separately.
An omissions is just that. An item of required work was not included in the contract documents. The
contractor, Owner, or designer may note this during the execution of the project and a change order
would follow. Hopefully, the change can be resolved through the mechanisms set up in the contract
with no cause for dispute. Oftentimes, however, this does lead to a dispute because the designer is
alarmed that the Owner will assert that he should pay for the omission. Generally, this is not
reasonable. If the designer had included the item in the contract documents originally, the bids
should have been correspondingly higher and, thus the Owner would have paid for the work anyway.
Since it is now being added as a change, the Owner has not been charged for anything extra or for
a mistake. To require the designer to pay for the omission would really be giving the Owner
something for nothing or in more technical terms, the Owner would be unjustly enriched. The only
caution that should be noted is that if the cost of the work is higher because of the omission than it
would have been if included in the original documents, then the designer may be liable for the
difference in the costs. This then would became a question of design negligence which is also the
basic premise for errors.
An error is simply a mistake made in the contract documents. No set of contract documents are
perfect. Some degree of errors should be expected. For that reason owners are encouraged to allow
for some contingency in their budget. The important question is when does an error become the
responsibility of the designer and not the Owner?
Basically, the designer becomes liable for an error if it can be shown that the error resulted from not
applying the standard of care which is normally anticipated for that type of design work in that part
of the country. This is almost always a question of expert opinion and the Owner should be cautious
not to embark on a costly witch hunt without seeking help from qualified independent personnel. If,
indeed it can be shown that the error is negligence on the part of the designer, than the Owner would
be entitled to compensation from the designer.
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In the area of errors and omissions, the Owner is cautioned not to be too aggressive with the designer.
This does not mean that the Owner should not pursue problems that legitimately are the liability of
the designer. What it does mean is that if the Owner looks to the designer for every small problem
that occurs, the designer will attempt to push every possible change back into the Contractor's lap.
The positions taken include things such as:
"A knowledgeable contractor should have known that it was the intent of the contract documents."
or
"The contractor should have discovered that problem during their site visit."
or
"It may be a problem, but there was no real extra costs for the contractor."
In all of these responses, the contractor is then forced to make a claim against the Owner and a
dispute ensues. If need be, the Owner may seek independent review of the changes in order to
ascertain if changes do exist and the impact and respective costs.
The final area that will be addressed is that concerning delays and inefficiencies.
Project delays can lead to huge disputes with significant cost ramifications. While this area has been
the subject of numerous articles and books, only a few brief comments will be offered here.
To reduce the chance of problems with delays on a hazardous waste project, the Owner should require
and maintain a thorough and detailed construction schedule for the entire job. It is strongly suggested
that the Owner require a Critical Path Method (CPM) schedule and that it be updated throughout the
project at reasonable time intervals, such as monthly.
Despite the use of a good CPM schedule on the job, delay claims may still arise. To reduce the
amount of disputes in this area, the Owner may consider a specific clause dealing with specified
amounts of compensation for the contractor should delays occur. A sample of this type of clause is
also included at the end of this paper. Once again, the reader is cautioned that the clause must be
developed for your specific project with the assistance of qualified construction counsel.
Finally, in the area of delays, if it is determined that a contractor is delayed during the job and is
entitled to a time extension, the Owner is wise to grant the time extension rather than attempt to put
it off until the end of the job. Delaying the time extension decision can lead to other compounding
claims on the project and an even bitter and more costly dispute.
The area of inefficiency is similar to the area of delays. Normally inefficiency claims arise because
of changes, differing site conditions, delays, etc. In essence, the Contractor is claiming that its
operations were not performed as efficiently because of one of these causes and requests additional
compensation for its work. An example of this would be the following.
In a recent hazardous waste project, the contractor encountered hazardous wastes on a haul road on
the project. The contract documents represented that no hazardous materials would be anticipated in
this area. This differing site condition required the contractor to construct a new haul road for the
bulk of the excavation work. As a consequence, the distance for hauling was significantly increased
and the unit cost of the excavation was increased. In other words, the contractor's excavation
operations did not proceed as efficiently as he could reasonably have planned based on the contract
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documents. This problem could have been resolved when the situation was first identified. Instead,
the Owner attempted to deny the differing site condition and compounded the dispute. Furthermore,
the Owner did not maintain good records on the remaining excavation and was at the mercy of the
contractor's records to document the impact to the operations.
A question the authors are commonly asked is what type of problems should be expected on a
hazardous waste site. Unfortunately it is not easily answered. In general, one should anticipate the
absolute application of Murphy's Law - if something can go wrong, it will.
It is impossible to list all types of problems that could occur. The project planner must discipline
himself to reflect on the nature of the job and the vagaries of the site. Based on this, a list of all
potential problems ^hould be developed along with possible solutions to those problems. In that
manner one is better prepared to handle problems should they occur.
Examples of problems that have been observed cover a broad spectrum. For example:
1. In the excavation and removal of hazardous wastes, huge overruns of contaminated material
were experienced. Though on a unit price basis, the Contractor experienced significant cost
increases for several reasons. First, the receiving landfill had daily limits. As a consequence,
the Contractor had to find a second approved landfill at a greater distance from the site and
at an increased cost. Second, the testing, stockpiling, processing, and hauling was
dramatically changed because of the volume of material. This also affected the unit cost.
2. During a clean up of an existing toxic landfill site, an underground spring was discovered.
Once the pit was opened, the spring fed water through the site. This created a large volume
of contaminated water that had to be treated and increased the cross contamination on the site.
3. During remediation on a government facility, live munitions were discovered in the
excavation process. This effectively changed the entire nature of the job.
4. In the remediation of a site, the Contractor was required to segregate non-contaminated
material and replace it after the contaminated material was removed. When this began, it was
discovered that the material would not compact as normal soils would. Hence, the final
ground elevation was higher than planned which affected the placement of fabric covers and
the hydrology of the site.
CONCLUSIONS
While many ideas can be gleaned from the problems that have already occurred on hazardous waste
projects, the following major points summarize the thrust of this paper.
1. Prepare good complete contract plans and specifications such that the incidence of errors and
omissions are reduced and hence the incidence of changes and claims. If possible, have an
independent review of the contract documents prior to the bid letting. This review should be
performed by an organization other than the project designer and should focus on the
completeness of the documents and the constructability of the project overall. Even with this
effort it is likely that some errors and omissions will occur.
2. The Owner should go the "extra mile" to make sure that detailed site investigations are
performed to reduce the chances of differing site conditions. Money up front is cheap in the
long run.
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3. The Owner and its representatives must be educated in the area of constructive changes and
must understand their obligations under the contract. By doing this, the occurrence of
constructive changes will be reduced. Also, if constructive changes occur, they will be
resolved more quickly.
4. If an Owner recognizes that some work is desired but may have to be excluded due to funding
limitations, consideration should be given to add or alternate items in the bid documents.
5. Drafting of the contract documents should include consideration of such items as If and
Where Directed clauses, Variations in Estimated Quantity clauses, and clauses dealing with
allowable costs for delays. The contract as a whole should be reviewed by qualified
construction counsel. This review should not be made with the intent of "sticking it to the
Contractor" but rather in structuring equitable clauses that will reduce the chances for
disputes and will incorporate mechanisms that can help resolve them should they occur.
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SAMPLE CLAUSE
"If And Where Directed" Items
The Proposal Form may request bids on one of more Pay Items to be incorporated into the Project
"if and where directed" by the Engineer. The Engineer shall have sole discretion in determining
whether and to what extent such items will be incorporated into the Project. Incorporation of such
items into the project shall only be made on written directions of the Engineer. In the absence of
written directions, no such items shall be incorporated into the Project and if incorporated shall not
be paid for. The Engineer may order incorporation of such items at any location within the contract
and at any time during the work. These items will not be located on the Plans. The estimated
quantities set out in the Proposal for such items are presented solely for the purpose of obtaining a
representative bid price. The actual quantities employed may be only a fraction of, or many times
the estimated quantity. The Contractor shall make no claim for additional compensation because of
any increase, decrease or elimination of such items.
SAMPLE CLAUSE
Variations in Quantities
Unit cost adjustments based on increases or decreases in contract quantities will be considered only
for an increase in excess of 125 percent or decrease below 75 percent of the original contract quantity.
Any allowance for or against the contractor on account of an increase in quantity shall apply only to
that portion in excess of 125 percent of the contract quantity, or in case of a decrease below 75
percent to the actual amount of work performed.
SAMPLE CLAUSE
Compensation For Project Delays
COMPENSABLE DELAYS - The Owner will provide an equitable adjustment to the Contractor only
for delays created by the Owner's acts or omissions. Unless otherwise specified, the Contractor
assumes the risk of damages from all other causes of delay.
The term "delay" shall be deemed to mean any event, force or factors which extends the Contractor's
time of performance of the Contract. This Subsection is intended to cover all such events, actions,
forces or factors, whether they be styled "delay", "disruption", "interference", "impedance", "hindrance"
or otherwise.
Strict compliance with the provisions of this Subsection will be an essential condition precedent to
any equitable adjustment for delays.
Only the additional costs associated with the following items will be recoverable by the Contractor
as an equitable adjustment for delay:
a. Non-salaried labor expenses.
b. Costs for materials.
c. Equipment costs.
568
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d. Costs of extended job-site overhead.
e. An additional HO Suggested) percent of the total of items a, b, c, and d, for home
office overhead and profit.
All costs claimed must be adequately documented when measuring additional equipment expenses (i.e.
ownership expenses) arising as a direct result of a delay caused by the Owner, do not use in any way
the Blue Book or any other similar rental rate book. Use actual records kept in the usual course of
business,and measure increased ownership expenses pursuant to generally accepted accounting
principles.
The parties agree that, in any adjustment for delay costs, the Owner will have no liability for the
following items of damages or expense:
a. Profit in excess of what provided herein;
b. Loss of profit;
c. Labor inefficiencies;
d. Home office overhead in excess of that provided herein;
e. Consequential damages, including but not limited to loss of bonding capacity, loss of bidding
opportunities and insolvency;
f. Indirect costs or expenses of any nature;
g. Attorneys fees, claims preparation expenses or costs of litigation.
569
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Comparative Roles of the Environmental Protection Agency and the
Bureau of Reclamation During Construction and Implementation of
the Lidgerwood, North Dakota Superfund Project
L. O. Williams
U.S. Environmental Protection Agency
999 18th Street, Suite 500
Mailcode 8HWM-SR
Denver, Colorado 80202
(303) 293-1518
Jeffrey M. Lucero
Division of Environmental Affairs
Bureau of Reclamation
Great Plains Region
Mailcode GP-156
P.O. Box 36900
Billings, Montana 59107
(406) 657-6590
INTRODUCTION
The Lidgerwood Project is one of three remedial actions which constitute the on-going cleanup at the
Arsenic Trioxide Superfund Site (Site). As the lead agency throughout the Remedial Design and
Remedial Action (RD/RA) phases of the Project, the U. S. Environmental Protection Agency (EPA)
was responsible for the coordination of all activities related to the Lidgerwood Project. Through two
Interagency Agreements (IAG), the U. S. Bureau of Reclamation (BOR) was "contracted" by EPA to
develop the RD and perform direct procurement and construction oversight of the RA activities on
behalf of EPA.
Through a cooperative team effort with EPA, BOR issued the specifications, awarded the contract,
and completed construction for the Lidgerwood Water Treatment Plant Facility (Plant) as scheduled.
While the opportunities for conflicts and problems during RD/RA were myriad, only those which
were of major impact to the Lidgerwood community, construction completion, or funding are
documented in the following discussion. Many of these pertain to notification issues, reimbursement
of EPA funds, cost overruns, and recycling concerns. Suggestions based on the practical "hands-on"
knowledge gained from the Lidgerwood Project are offered for consideration to individuals and
"teams" who may be initiating or conducting RD/RA at other Superfund sites.
BACKGROUND
The Site consists of 20 townships which encompass approximately 500 square miles in the southeastern
corner of North Dakota. The Site area is composed of sparsely populated farmland interspersed by
small communities such as Lidgerwood. Approximately 4,500 people live within the Site area, of
which an estimated 1,000 reside within Lidgerwood. Lidgerwood serves as a trade center for the
surrounding agricultural area and provides commercial enterprises such as implement, chemical, and
seed dealers, as well as grain elevators.
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The Site topography consists of gently rolling hills and flat plains shaped by past lakes and glaciers.
Ground water in the region is composed of unconfined glacial drift aquifers, as well as the deeper
Dakota Sandstone Aquifer. Heavy grasshopper infestations of agricultural crops in the 1930's and
1940's resulted in widespread and frequent applications of arsenic-based pesticides. It is estimated
that more than 165 tons of arsenic contained within grasshopper bait were spread throughout the Site
area during this period. In 1979, routine sampling of ground water, as required by the Safe Drinking
Water Act (SDWA), discovered that the water supply for the City of Lidgerwood (City) exceeded the
Maximum Contaminant Level (MCL) for arsenic.
The Site was placed on the National Priorities List (NPL) in September 1983 and the Remedial
Investigation and Feasibility Study were completed in 1986. Elevated levels of arsenic, exceeding or
approaching the MCL of 0.05 milligrams per liter (mg/L), were identified in Wyndmere, Rutland,
and portions of the surrounding rural areas. Arsenic contamination at the Site appears to have been
limited to seven major glacial drift aquifers within the region. A Record of Decision (ROD), signed
in September 1986, excluded the Cities of Lidgerwood and Wyndmere because their respective water
treatment plants already provided effective removal of arsenic from the ground water. Further
investigation of the Lidgerwood Plant was approved as a result of operational problems which plagued
the Plant after the first six months of operation. These analyses contributed to the inclusion of the
Lidgerwood Plant in the Arsenic Site in a ROD supplement dated February 5, 1988.
The Site area and Project location are illustrated in Figure 1. EPA also refers to the Lidgerwood
Project as Operable Unit II, Remedial Activity 1.
PROJECT HISTORY
The Lidgerwood Plant was designed, constructed and brought into operation in late 1985 to remove
arsenic, iron, and manganese from the ground water. The original Plant was a single story,
prefabricated structure with dimensions of 32 feet in length and 28 feet in width. It consisted of a
packaged aeration, detention, and filtration system; a concrete clearwell and backwash water recovery
sump located below the operating deck; service/backwash pumps; and the required appurtenances to
manually operate the Plant.
As originally designed, the Plant treated the contaminated ground water pumped from City wells to
provide the City's water supply. The treatment process involved oxidation by aeration and the
addition of potassium permanganate, followed by addition of a polymer to enhance flocculation of
the suspended particles within the detention basin, and finally sand filtration. The removal of arsenic
occurs as a result of incidental coprecipitation with the iron. Following treatment, the water was
pumped to an elevated water storage tank from which water was gravity-fed into the distribution
system. Filters were backwashed on an as-needed basis by utilizing treated water stored in the
facility's clearwell. Specific details of the original Plant design and operation procedures are clearly
documented in the Design Summary Report (EPA, 1989a).
After an initial six months of acceptable Plant performance, operational difficulties developed and
the Plant was reported to have been down as much as 70 percent of the time prior to intervention by
the EPA in October 1988. At times, the Plant produced "pink" or "brown" water which indicated an
excess of unreacted permanganate or an excess of unreacted manganous ion, respectively.
Periodically, product water failed to meet one or more of the SDWA criteria. During periods when
the Plant was not functional, untreated water was delivered directly to the City distribution system.
The operational difficulties experienced by the Plant resulted in elevated arsenic, iron, and manganese
concentrations in the distribution system. Under the SDWA, arsenic is regulated at an MCL of 0.05
mg/L. This primary drinking water standard is enforceable and based upon adverse health effects.
571
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NORTH DAKOTA
X^ MILNOR
T^W DE LAMERE
V^
Figure 1 --
North Dakota Arsenic Trioxide Superfund Site Area arid
Lidgerwood Project Location
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Non-enforceable secondary drinking water standards exist for both iron (0.3 mg/L) and manganese
(0.05 mg/L) based upon "taste and staining." Because the MCL for arsenic in the untreated water was
exceeded, the Lidgerwood Plant was included as part of the Arsenic Trioxide Superfund Site.
Many of the Lidgerwood residents did not perceive the arsenic concentration to be a problem since
there was no associated difference in the color, smell, or taste of the ground water when compared
with "safe" drinking water. However, the occurrences of pink or brown water did cause residents to
become concerned about potential health threats from the addition of chemicals by the Plant to the
treated water. The inability of the Plant to function properly had also led residents to consider it as
an experimental facility, and their trust and confidence in "the Government" to resolve the operational
problems and complete the Lidgerwood Project had steadily decreased. The residents generally felt
that the Plant was an unnecessary and wasteful project which had been forced upon them, at an
average cost of $1,000 per residence, by "the Government."
EMERGENCY RESPONSE ACTION
In February 1988, the selected remedy for the Site - which included expansion of an existing rural
treatment system, continued monitoring, and institutional controls - was formally extended to include
the Lidgerwood Project. EPA selected modification of the Plant including automation of the
backwash system, increasing the existing potable water storage and treatment capacity, and
reimbursement of the City's construction costs as the most cost effective long-term alternative for
remediating the elevated concentrations of Lidgerwood's drinking water. In October 1988, EPA
initiated an Emergency Response Action at the Lidgerwood Plant in response to the Plant being shut
down over an excessive period of time. Through an IAG, the BOR was initially "contracted" to
develop and implement immediate measures which would make the Plant operational and capable of
providing safe drinking water to the community.
At a meeting held in October 1988, the Plant's operating history was reviewed; problems identified;
and a plan of action determined. The problems which were identified consisted of: high backwash
frequency, poor filter media performance, clogged filter underdrain nozzles, and disposal of backwash
water including sludge and precipitates. The immediate solution, proposed by the City, included
removal and replacement of the filter media, replacement of the filter underdrain nozzles, and
transport of the backwash water to the City sewage lagoon. An action memorandum issued by the
EPA On-Scene Coordinator (OSC) in December 1988 specified the nature of BOR's role during the
emergency response period. The initial BOR involvement was to include:
1. Technical guidance on rehabilitation of the filter media;
2. Recommendations of methods to handle the backwash water including the sludge;
3. Review of the original Plant design and operation and technical assistance regarding
the Plant modifications proposed by the City's architect/engineer; and
4. Training the Plant operators.
After the first meeting in October 1988, BOR assisted in replacing the filter media and underdrain
nozzles. At the same time, a General Filters Company customer service representative was at the
Plant to "activate" the proprietary coating to the new media. In addition, the representative changed
the potassium permanganate feed point, recommended the use of a different polymer, and provided
Plant start-up services.
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The Plant returned to operation on November 10, 1988. Results of the first effluent sample showed
that the arsenic level had been successfully reduced from 0.118 mg/L to 0.017 mg/L, which is well
below the MCL of 0.05 mg/L. By June 1989, there had been three documented excursions of purple
water in the clearwell since the November 1988 startup. Additionally, there were 18 upsets of pink
water in the clearwell, one upset of overdosing of polymer, and one flooding of the backwash
recovery sump. Frequent backwashing was required due to built-up head losses. Subsequently, the
backwash water had to be hauled to the sewage lagoon as often as every other day. Approximately
four hours of intensive work by the operators was required on a daily basis to maintain acceptable
treatment capabilities of the Plant.
ROLE DEVELOPMENT
Subsequent discussions in December 1988 between the EPA and the North Dakota State Department
of Health (State) resulted in the designation of EPA as lead agency for the RD/RA phases of the
Lidgerwood Project. During this time, the EPA Project Manager was responsible for coordination
of all activities for the Lidgerwood Project. These included direct conduct of Community Relation
activities; development and oversight of various interagency documents with the State, the City, and
BOR; and related responsibilities concerning funding for the Project. These multiple
coordination/lines-of-communication are discussed in detail below and illustrated in Figure 2.
City and State Involvement. A three-party agreement, known as a Superfund State/Political
Subdivision Contract (SS/PSC), between EPA, the State, and the City was mutually negotiated and
signed in March 1989. This document delineated the roles and responsibilities of each party and
provided for direct coordination between EPA and the City. A Cooperative Agreement (CA) also
signed in March 1989 awarded funding to the City for their participation in oversight of the Project.
Community Relations Development. In an effort to address the Lidgerwood community's strong
discontent which centered upon the non-functioning Lidgerwood Plant, a Work Assignment (WA) was
allocated to CH2M Hill to update and revise the existing Community Relations Plan (CRP).
Interviews with representatives from the Lidgerwood City Council and community members were
conducted in August 1989. The primary interest identified by the interviews was a strong desire to
see the treatment plant operate as it was intended without spending additional funds. Health issues
resulting from episodes of colored water, related financial issues, and Project information needs of
the community were also identified. It was determined that biweekly updates which would describe
the on-going and anticipated construction activities would be published in the weekly Lidgerwood
Monitor newspaper during the active construction period. It was believed that the updates, in
association with the actual modifications, would best address the issues which had been identified.
Remedial Design Summary. Because the BOR was already on-site for the Emergency Removal and
had done a preliminary analysis of the Plant's inability to operate correctly, it was determined that
the most expedient method for design and implementation of the Plant modifications was to have
BOR follow through with development of the RD. Due to the serious nature of the situation, an
accelerated design and construction schedule was established by EPA and BOR as follows:
Concept RD (30 percent complete) -- February 1, 1989.
Final RD Approved -- March 31, 1989.
Invitation for Bid -- June 6, 1989.
Bid Opening -- July 14, 1989.
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Contractor
Communitl y
Relatig/ns
cn
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Bid Award — August 15, 1989.
Construction Complete — January 30, 1990.
As part of the RD process, various laboratory investigations were conducted by BOR to determine
if the Plant's chemical process for the removal of arsenic and the accompanying iron and manganese
could be made more reliable and effective. Changes in the equipment and operation of the Plant were
proposed by BOR and subsequently incorporated in the Lidgerwood RD based upon the results of
these investigations. These changes and the investigation results are documented in the Lidgerwood
Modification Design Report which was first published in June 1989 (EPA/BOR, 1989). The
investigation tasks and their respective analytical interpretations are summarized in Table 1.
In general, the Plant was originally designed to:
- Oxidize ferrous iron to ferric hydroxide;
- Oxidize manganous irons to manganese dioxide;
Add polymer to aid in the precipitation process;
- Filter for the removal of precipitates;
- Chlorinate to inhibit microbiological growths and leave a residual for disinfection;
and
- Remove arsenic trioxide by co-precipitation with iron.
The original Plant had a treatment capacity of 252 gal/min. Based on the review of operational
records, consultants' reports, on-site inspection, manufacturer's review, and laboratory analyses by
BOR during Phase I, several problems were identified. The RD modifications consisted of removing
some of the alterations which had been made to the original Plant design by the City in its attempts
to make the Plant operate properly, and the addition of equipment which would ensure that the Plant
could consistently deliver water which met the current water quality criteria with respect to arsenic
content. A 28-by-28 foot building addition would house additional equipment including an enlarged
detention tank that would provide an additional hour of detention to the water following
permanganate addition, a second clearwell which would increase the clearwell capacity by 25,000
gallons, a stirrer to ensure proper mixing of the permanganate and polymer, two backwash pumps of
proper capacity and head, motor operations and controllers to automate the backwash process,
analytical equipment to allow the operator to measure iron and manganese concentration of the
finished water on-site, and a disposal trench system to percolate the filtrate from the backwash water
sludge. Specifically, the modifications to the Plant were incorporated in the RD as follows:
1. Mixing - The plenum under the existing aerator was converted into a rapid mixing
tank. This improved mixing of polymer and potassium permanganate to obtain a more
thorough chemical reaction. A 1.0-hp mixer was provided to accomplish the mixing.
2. Backwashing and Automation - The existing Plant required frequent backwashing,
often on a daily cycle. The backwash process reduces Plant production time which
depletes the amount of filtered potable water potentially available to the community.
Also, a substantial amount of product water is used during backwash, thereby,
reducing the amount of potable water provided to Lidgerwood even further. A new
process was designed to reduce backwash frequency. Two properly sized backwash
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Table 1 — Laboratory Investigation Tasks and Analytical Interpretation
TASK CONCLUSIONS
1A Reaction Times - Oxidation
Using Potassium Permanganate
(KMn04) of Manganese (Mn) and
(Fe) with associated Removal
of Arsenic (As)
1. Fe and As precipitate
out of solution in about 20
minutes in a very fine, poor Iron
settling floe.
2. Detention time of 60-90 minute
produces water with acceptable Fe,
Mn, As levels and a suitable floe
size.
1B Effect of Polymer Addition
on Removal of Iron, Manganese,
and Arsenic, and on Floe
Development
1. The addition of Percol LT-20
(polymer) produces heavier, more
filterable and better settling
precipitate.
2. Lag time between KMn04 and
polymer addition is not
significant.
1C Effect of Newly Activated
Sand on Iron, Manganese,
and Arsenic Removal
1. Newly activated sand is
effective in removing both
manganese and arsenic from water
treated with permanganate.
2. Iron precipitates before
it reaches the activated sand.
1D Effect of Adding Ferrous
Chloride (FeCl2) on Iron,
Manganese, and Arsenic
Removal
1. The higher the iron content
in raw water, the more effective
the KMn04 is in removing arsenic.
2. FeCl2 aids in coagulation, but is
less effective than polymer.
1E Testing of Effects of Mis-
cellaneous Variables on Iron,
Manganese, and Arsenic Removal
1. Lower reaction temperatures
hinders Mn removal, but do
not substantially reduce Fe or As
removal.
2. Cl2 is less effective than KMn04
in Fe-As removal.
3. Seeding does not significantly
enhance Fe-As removal.
4. Arsenic tends to reenter
solution with time, see (1F).
1F Effect of Extended Holding
Times (up to 12 weeks) on
dissolution of Arsenic, Iron,
and Manganese
1. Fe and Mn concentrations were
undetectable during the test
periods. Soluble As in the test
water did not change significantly
during the 12 weeks.
2 Total Organic Carbon (TOO
Sulfide in Lidgerwood Raw
Water
1. The TOC of the raw water was
found to be 2.8 mg/L.
2. Sulfide in the raw water was less
than the detectable limit of
1.0 mg/L.
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Table 1 — Laboratory Investigation Tasks and Analytical Interpretation
TASK CONCLUSIONS
3A Settling Rates of Oxidation
Products
1. Precipitate currently produced
at the Plant is very fine and light,
resulting in slow settling
characteristics and a low percentage
of solids.
3B Settling Rates of Sludge
1. Aged sludge settles well in lower
layer; from 0.145 percent solids to
1.74 percent after one hour and to
4.17 percent after 48 hours.
2. Long settling times improve
solids level to 4.54 percent after
three weeks, including weekly
resuspension,
4A Chemical Oxidation Demand
(COD) in Lidgerwood Raw Water
1. Although initially scheduled
for analysis, COD tests were
subsequently determined to be
unnecessary.
4B Analysis of Coating on
New Activated Sand
1. Activated coating on new sand
is 0.40 iron, 0.027 manganese,
0.0004 arsenic, as weight percent of
total sand.
2. Characteristics of new sand
coating appear similar to greensand.
4C Analysis of the Scale on Flow
Nozzles
1. Nozzle scale contained 38 percent
iron, 0.29 percent manganese, and
0.01 percent arsenic.
2. Scale buildup in the nozzles was
probably caused by faulty
backwash procedures.
4D Analysis of Coating on Used
Sand
1. Activity of sand appears to
diminish with filtration cycles.
2. See Task No. 8 for further
studies on effect of filtration
cycles on activated sand.
5A Sludge Dewatering Study
1. Sludge bulk volume can be reduced
significantly by a filter press.
2. Dry weight percent of sludge was
found to be 3.4 silica, 7.4
manganese, 29.3 iron, 20.6 calcium,
2.4 arsenic, 36.0 sulfate salts.
5B Lidgerwood Water Treatment
Plant Sludge Studies (National
Sanitation Foundation)
1. The National Sanitation
Foundation decided not to
characterize Lidgerwood Water
Treatment Plant sludge at this
time.
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Table 1 — Laboratory Investigation Tasks and Analytical Interpretation
TASK CONCLUSIONS
6A Proposal to Replace 6-in of
Activated Sand in One Filter
Cell with Anthracite
1. An anthracite top layer
would result in longer activated
filter runs because of deeper bed
penetration of the precipitate.
2. Anthracite will reduce the
plugging tendency of upper part
of filter bed by polymer.
6B Proposal to Replace Activated
Sand in One Filter Cell with
"Greensand"
1 . The surface of activated sand
is chemically similar to commercial
greensand.
2. Equal volumes of greensand have
many more active sites than
activated sand.
Operator Training in Process
Water Sampling and Chemical
Handling
1 . Poor analytical procedures and
chemical feed rate adjustments.
2. Handling and storage of chemicals
are messy and unsafe.
Effect of Process Cycles on
1. Lidgerwood "Activated" sand has
some properties of greensand.
2. Particle size distribution is not
affected by backwash.
3. Most precipitated particles are
filtered in upper 6-in of sand bed.
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pumps, each with a capacity of 630 gallons per minute at 30 feet of water head, were
provided. To reduce operator involvement, automation of the backwash sequence was
included in the design. The backwash operation could then be controlled by a
sequencing timer. This could be initiated manually, by a preset filter head loss
trigger, or by a timer.
3. Detention Time - A new detention tank, 15 feet square by 10 feet high with internal
baffling, was installed between the mixing chamber and the existing detention tanks.
The new tank added 60 minutes to the existing chemical reaction time bringing total
detention time to about 80 minutes. The increased detention time ensured the
occurrence of almost total oxidation of the iron and manganese. The longer oxidation
time also allows the precipitates to form prior to filtration by the activated sand
media. This not only prolongs the life of the filter media coating but also minimizes
the occurrence of discolored water caused by incomplete manganese reactions.
4. Variation of Manganese in Raw Water - A spectrophotometer was purchased for use
in the Plant. The spectrophotometer allows for the timely and accurate determination
of the current manganese concentration in the raw water. Proper dosages of potassium
permanganate can then be fed into the system to provide for oxidation demand and
recharge of the coating on the sand media. Another instrument, a Hungerford and
Terry Color Monitor, was purchased to monitor the filter effluent and detect any
unreacted manganese which had broken through the filter media with a resultant
product water of undesirable quality in the clearwell.
5. Fluctuation of Flow Rates from Water Well Pumps - A flow regulating valve was
installed in the raw water influent line to provide a constant inflow rate to the Plant
regardless of which well pump is operating.
6. Backwashing Recovery Basin Operation - The backwash water would be collected in
the recovery basin. After a quiescent period of a few hours, the supernatant is
recycled to the mixing tank. The recycled supernatant volume is estimated to be
11,340 gallons. The precipitated sludge, about 1,260 gallons, is then pumped to the
existing sludge recovery tank ("blue tank") located to the south of the treatment Plant.
Here, the precipitates are retained within the fine sand bed while filtrates are
collected within a perforated plastic pipe. The filtrate then flows to an existing
manhole which has been converted to a distribution box. From the distribution box,
the filtrate is distributed to a disposal trench system through approximately 100 feet
of perforated pipe above gravel-filled trenches. Distribution lines are located two feet
below existing grade, but above the historical high ground water table.
This method of sludge/precipitate disposal should be satisfactory during spring,
summer, and early fall months. During winter, however, sludge will be retained in
the backwash recovery sump. If solids/precipitates accumulate too quickly, the settled
sludge can be pumped to a tank for disposal. If precipitates accumulate as anticipated,
no more than 4 percent solids, they will be held in the backwash recovery sump until
spring when the ground thaws and the percolation system can be used. Periodically,
precipitates which have accumulated in the blue tank will need to be removed and
appropriately contained so they can be disposed of at an approved landfill. This
disposal method will prevent the arsenic from reentering the ground water.
The original backwash water recycle pump was rated at 65 gallons per minute at 20
feet of head. The sludge pump was rated at 130 gallons per minute at 20 feet of head.
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Both pumps were utilized in the RD modifications though operation of these pumps
is now automated with adjustable timers.
7. Inadequate In-Plant Clearwell Storage - A BOR study concluded that an additional
20,000 gallons of clearwell capacity will be required to satisfy the Lidgerwood
community's requirements for potable water while maintaining steady-state Plant
operation. The study considered the quantity of filtered water used for backwashing
procedures and the amount of time needed to backwash during which the Plant cannot
treat ground water.
8. Post Chlorination - There are now three post treatment chlorination injection points
to ensure the disinfection of treated water. Utilizing gaseous chlorine, chlorine is
added at the influent pipeline to clearwells No. 1 and 2 and at the discharge water
pumps that feed the elevated water storage tank. The operator controls the rate of
chlorine usage (and the resultant chlorine residual) at each injection point by the use
of a dedicated gas chlorine flowmeter. A free chlorine residual of 0.5 to 1.0 parts per
million is maintained in all treated water.
9. Clearwell Capacity - A BOR study of the operation of the Plant indicated that an
additional clearwell capacity of approximately 20,000 gallons would improve and
simplify Plant operation. The new clearwell is located under the new addition to the
building. The walls of the clearwell were used as piers for the building and a support
for the detention tank. This produces a total clearwell capacity of 33,000 gallons at
little additional cost over that of the needed building addition to the Plant.
The location of the new clearwell permits isolation of the backwash feed water from
product water storage which provides a simplification in Plant operation. The existing
product forwarding pumps were also relocated above the new clearwell.
10. Access Ports - There was no access to the filter underdrains which made these areas
impossible to maintain and service. Drains and access ports were added to the filter
underdrains so that they could be cleaned out when needed.
11. Building Size - An addition to the original Plant was built to accommodate the new
equipment which almost doubled the size of the structure. The addition is structurally
and visually similar to the original building for technical as well as aesthetic
considerations.
Other possible, although less serious, causes for Plant difficulties were identified. These include:
The presence of sulfides or organic chelating agents in the raw water and
A crowded Facility.
In addition to hardware changes, some changes in Plant operations were also investigated. These
included:
1. Reactivating recycle of the supernatant liquid from the backwash water sump.
2. Revising the operation cycle of the Plant.
a. Run the Plant in one continuous stretch during the day.
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b. Backwash at the end of the day.
c. Add a short filter-to-waste step to the backwash cycle to avoid putting the
first filtrate, which is frequently "off-spec," into the clearwell.
d. Modify the concentrations of chemicals fed to the process.
e. Use greensand in place of the presently used filter medium.
f. Addition of a six-inch layer of anthracite to the top of the filters to improve
filter operation and to prolong filter runs.
g. Disposal of sludge generated by the Plant is presently estimated to amount to
slightly less than two tons of dry solids per year, consisting largely of iron
hydroxide and manganese dioxide.
Startup and Operator training was divided into three areas. First, a refresher course was conducted
at a facility which also conducts iron removal. Second, Plant operators were trained on the use of the
specialized instruments as described in "4. Variation of Manganese in Raw Water" above. These
instruments were also used to assess the quality of the water being delivered to the City of
Lidgerwood and to ensure that no off-spec water is sent to the City. Last, operators were provided
training based upon the Designers Operating Criteria (DOC). The DOC was developed by the
Research and Design Divisions of BOR to reflect the completed modifications and process changes.
The RD was completed and approved in March 1989, only five months after initial involvement by
EPA and the BOR. Through a second IAG, BOR was contracted to perform direct procurement and
construction oversight of RA activities on behalf of EPA. Total costs for the RD, construction, and
training required for the Plant modifications were determined as shown below:
Actual Design Costs: $196,708.25 (approx. 620 staff days)
Estimated Construction Costs:
Actual Construction $389,000.00
BOR Oversight $172,525.00 (includes an estimated 137 staff days)
Citv Oversight $15.000.00
Total $576,525.00
Estimated Project Cost: $773,233.25
Remedial Action Contractor. The RA contract was awarded to Wanzek Construction on June 5, 1989.
The Lidgerwood Project team was now complete and ready to begin the RA phase of the process.
The team members included the EPA RPM; a representative of the EPA Drinking Water Branch; the
North Dakota State Project Officer; representatives of the City of Lidgerwood which included both
the Mayor and the Plant operators; the Project manager for BOR (located at the Billings office) as
well as representatives of the Bismarck, Denver, and on-site offices of BOR; CH2M Hill; and Wanzek
Construction. Other coordinating members not directly part of the team included the EPA OSC, and
internal EPA personnel within Region VIII and headquarters associated with the acquisition of
funding for the Project.
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DISCUSSION
The construction contract required a total of 20 submittals from the Wanzek Construction. BOR was
obligated to respond to each submittal or resubmittal within 15 calendar days of receipt, including
the actual day of receipt and the date of response. This short turnaround time led to the adoption of
a "fast-track submittal review." BOR would respond to the contractor in writing while BOR's Denver
Office completed the review and transmitted their findings to the BOR Project Office by overnight
mail. A tabulated system was used to track all the required submittals for the contract.
On-site construction began September 18, 1989. The major components of the construction phase
included:
- Site work and earthwork;
- Concrete work;
- Wooden Buildings;
- Detention Tank;
- Mechanical work;
- Electrical work;
- Painting;
- Bottled water supply program; and
- Sequence testing, startup, and Plant operation.
PLANT OUTAGE NOTIFICATION
A Plant outage of 21 days was provided for in the RD and specifications issued for the Project. This
Plant outage was required so that the pumps, piping, existing equipment, and new equipment could
be connected or reconnected in the appropriate progression. The specifications did require a 14-day
written notification of appropriate parties prior to beginning the outage. Unfortunately, this did not
specify if receipt of the notification or the date of mailing was to occur 14 days prior to the outage.
This became very important since the RPM did not actually receive written notification until four
days prior to the outage.
EPA and CH2M Hill had anticipated a 14-day period in which to publish a notification in the
Lidgerwood Monitor which would inform the community of the actual dates for the already expected
Plant outage and the beginning of a bottled water program. Instead, EPA was forced to use more
imaginative methods in which a copy of the prepared notice was "faxed" to BOR in Lidgerwood where
copies for hand flyers were prepared. The local Boy Scout Troop (No. 293) then delivered the flyers
to Lidgerwood residents on a door-to-door basis.
A related problem concerning late notification of the Plant outage to the BOR, Billings office resulted
in late notification to the three suppliers for the bottled water program. Fortunately, the suppliers
583
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were able to obtain adequate quantities of water to meet demand during the initial two weeks of the
program and order additional quantities for the remainder of the program.
Another dilemma associated with the Plant outage was that construction began shortly before the
Thanksgiving-Christmas-New Year's holiday season. No prohibition against conducting the Plant
outage during the actual holidays was included in the specifications. Wanzek Construction originally
planned to shutdown the Plant for 21 days starting on November 27, 1989, as part of their
construction schedule. However, delays in the manufacture of the detention tank led to delays in
Plant shutdown. After the detention tank was finally completed, the contractor informed all parties
of their intent to start the shutdown on December 4, 1989. Attempts by EPA and BOR to have the
contractor postpone the shutdown until after the holidays proved fruitless. As a result, the Plant was
shutdown at 8:00 a.m. on December 4, 1989, and was scheduled to be back on-line by December 21,
1989. Unfortunately, the Plant did not resume operation until December 30, 1989. In addition to
incurring stipulated penalties for exceeding the allotted 21-day Plant outage, the contractor's delay
in resumption of Plant operations had a predictable impact on the community's perception of "the
Government's" ability to conduct construction activities in accordance with our own schedule as
publicized in The Monitor.
BOTTLED WATER PROGRAM
In addition to the problems related under "Plant Outage Notification," additional issues developed due
to the use of three separate supply contractors within Lidgerwood. In an effort to improve public
perception of EPA and other governmental agencies, it was determined that three contractors within
the local community would be used to distribute the bottled water. Three contractors were used so
that residents could go to a business that they usually frequented and, therefore, would not be further
inconvenienced by the program. Friction between the BOR and the vendors developed because of
differences in the cost per unit reimbursed to the individual vendors. Reimbursement was based upon
bids submitted by each vendor and reflected slight variations between the retail outlets.
Other "special concerns" surfaced which had not been previously considered by EPA. These issues
particularly influenced the community's regard for EPA since the resolutions directly impacted
individual residents.
1. Would the local elementary and high school be eligible for participation in the free
bottled water program? Yes, since children, especially those of elementary school age,
are more sensitive to even short-term exposure to potential health hazards.
2. Would the local nursing home be eligible for participation in the free bottled water
program? While the nursing home could technically be considered a business, it was
determined that the nursing home was more realistically a residence to each
"customer." As such, each resident of the nursing home was eligible to participate in
the program.
3. How could "shut-ins" participate? Would water be delivered to their homes or could
neighbors pick up the bottled water for them? It had been determined that the free
water would be distributed on the honor system only. While residents were asked to
write their name and the number of gallons being taken, the forms were not analyzed
to determine if individual residents had taken more than EPA's estimate of three
gallons of potable water required by an individual per week. Therefore, the three
vendors were instructed to allow neighbors to sign and pickup water for their
neighbors. While water would not be delivered to a resident's home, one vendor did
provide assistance from the store to residents' vehicles.
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4. Would private businesses, such as the Lidgerwood Cafe, be eligible to participate in
the program? This was considered but not implemented.
The bottled water program lasted approximately six weeks which included a 26-day Plant
outage and a 10-day overlap in the event that other problems arose which would require the Plant to
shutdown or made the water unacceptable to Lidgerwood residents. Approximately 14,000 gallons
of bottled water were distributed to the Lidgerwood community of which 11,000 were distributed in
plastic one-gallon containers. Approximately one week into the program, it was brought to the
attention of BOR and EPA that empty water containers were becoming quite numerous. A recycling
facility in Moorhead, Minnesota agreed to recycle the containers and the Culligan vendor agreed to
serve as a local collection point for the containers. During the three week recycling period,
approximately 6,000 containers were collected and transported for recycling.
COMMUNITY RELATIONS ISSUES
As discussed previously, construction updates were to be published in The Monitor as a means of
easing resident's concerns regarding the Plant. While the first article was more detailed in its
description of the Plant operating procedures and difficulties, all the articles followed a format of
"Introduction, Background/Progress to Date, Future Activities," and "For More Information" sections.
In conjunction with monthly site visits by EPA, informal availability sessions were conducted by the
RPM. These availability sessions were publicized within the "Future Activities" section of the articles.
EPA and CH2M Hill took great pains to present the articles in a readable manner and to discuss the
potential health risks such that residents would not become overly concerned. It was the City's belief,
however, that the articles had overstated any health risk and had caused undue terror within the
community. In particular, the City felt that the free bottled water program served to further
accentuate EPA's stance on health risk and was very much against its implementation.
In dealings with the City, EPA was sensitive to the adversarial roles which had inadvertently
developed. It was EPA's determination that a proactive and positive attitude which was favorable to
the City would greatly change this adversarial relationship. As the construction progressed and the
Plant's operational problems diminished, it was hoped that the City would also come to trust EPA and
the other governmental agencies involved with the Project. These hopes were soon shattered as
exemplified by the events which occurred in relation to a chemical storage cabinet. The cabinet was
replaced twice, despite additional fees for transportation and restocking, at the City's request. The
City, however, had formally appointed the Mayor as EPA's only point of contact. Therefore, EPA
was criticized for taking direction from another City employee. The City also protested the additional
costs involved since the City was providing ten percent of the Project cost.
FUNDING/REIMBURSEMENT OF PROJECT COSTS
The cabinet incident also served as an warning of similar events to come. At a prefinal conference
for the Project held on January 30, 1990, the City was informed that their ten percent cost share of
Project costs incurred to date would be due on February 15, 1990, in accordance with the SS/PSC.
In August, 1990, EPA's finance section alerted the RPM that the reimbursement costs had not yet
been paid by the City. After verbally notifying the City of the delinquent payment, a check for only
one-third of the overdue reimbursement was submitted to EPA. EPA advised the City and State,
which was obligated to provide reimbursement costs in case of default by the City, of the City's legal
responsibilities as mutually agreed upon in the SS/PSC and CA, and the possible accrual of interest
on the delinquent payment in a written response dated September 14, 1990. A check for the full ten
percent of the Project costs incurred as of January 1990 was subsequently submitted by the City on
September 25, 1990.
An estimated 137 staff days for oversight by BOR was provided in the second IAG awarded by EPA.
It was soon realized that, due to the complexities of the Lidgerwood Project, the presence of an on-
site inspector during all phases of construction and Plant startup was crucial to its successful
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completion. To date, over 450 staff days by BOR have been required to oversee this Project. In
addition, indirect costs incurred by the BOR have escalated from an estimated 35 percent at the
beginning of the Project to over 75 percent at completion of the Project.
Besides escalating the total cost of the Project, the additional costs required renegotiation of both the
SS/PSC and CA documents already in place with the State and the City. These documents placed a
ceiling on the amount of funding which could be expended by EPA for the entire Project. Because
the City, and indirectly the State, had agreed to pay ten percent of the Project cost; both the State and
City had to agree to any cost increase proposed by EPA. As expected, the renegotiations brought up
sensitive issues with the City which have already been discussed.
PROJECT COMPLETION
On January 16, 1991, a final inspection was conducted by the City in conjunction with the Project
team. Based on the Plant inspection and results of the approved water quality monitoring program,
it was determined that modification of the Plant was 100 percent complete and operating as required.
The construction contract was $302,250.00 as awarded. Liquidated damages and change orders
resulted in a final contract cost of $318,947.09 which is a 5.52 percent overrun of the original contract
value. Current costs for the entire Project including RD, construction, and oversight by BOR and
the City are $811,708.25
The Project team's assessment that the Plant was complete formally ended the shakedown and
evaluation period and provided for the City to assume all operation and maintenance activities of the
expanded Plant. The Completion of the Lidgerwood Project is documented in an RA Report which
was approved by EPA on March 21,1991. Because Lidgerwood is part of the larger Arsenic Trioxide
Site, the Lidgerwood Plant will remain on the NPL even though the Project is complete. The entire
Site will be eligible for deletion from the NPL once the Wyndmere and Richland rural water
treatment projects are also complete. The RA Report for the Wyndmere project was also approved
on March 21, 1991, and the Richland project is estimated to be completed by the end of 1992.
CONCLUSIONS
While the Lidgerwood Project has been successfully concluded, the various problems and issues which
developed during the conduct of the Project indicate that actions could be taken to prevent their
reoccurrence on "the next project." The following suggestions are offered to individuals who may be
implementing that next project.
1. Regardless of the anticipated schedule for the project, the specifications would
include a clause prohibiting any type of inconvenience to the community, such as the
Plant outage, from occurring over major holidays -specifically the Thanksgiving-
Christmas-New Year's holiday season.
2. Any required notification clause would specify that receipt of notification is the
appropriate action for compliance and would be subject to penalties in excess of
standard penalties for other tasks within the Project.
3. With regard to a bottled water program, it is strongly suggested that a single vendor
be used to supply all the water so that competitive friction does not develop. Advance
consideration by the lead agency of the special concerns discussed in the "Bottled
Water Program" section and the availability of recycling options should also be
evaluated before considering bottled water as an alternate water supply.
4. Any construction changes which involve additional costs should be approved through
the formal concurrence chain only and, thus, avoid any extraneous disputes.
*
5. The BOR should be encouraged to provide a firm indirect cost percentage, even if it
is overestimated, so that EPA can better estimate and request funding in advance of
project needs.
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6. A better estimate of actual oversight requirements should be provided by BOR, even
if it is overestimated. Again, this will enable EPA to better estimate and request
funding in advance of project needs.
Despite the "Discussion" which seems to indicate that nothing went right on the Lidgerwood Project,
there are many items which were done exceptionally well and which EPA would recommend doing
again. First, the development of the Lidgerwood Design Report (EPA/BOR, 1989) documented the
efforts of EPA and BOR to experimentally examine factors which affect the removal of arsenic from
water. This Report has been widely requested by private industry as well as public agencies, and is
one of the most informative resources for state-of-the-art arsenic removal. This may become even
more important in the near future as EPA continues to consider lowering the MCL for arsenic in
drinking water.
Second, oversight by the BOR resulted in a cost overrun of only 5.52 percent for the entire
construction contract. This is undoubtedly due to the excellent oversight provided by BOR. In
addition, BOR's involvement greatly facilitated the retrofit of the Plant due to their extensive
technical and construction expertise. EPA would highly recommend their involvement as a project
team member for the next project.
Last, it is observed that EPA's efforts to remedy the adversarial relationship between EPA and
the City were mostly unsuccessful. Despite this, it is recommended that these efforts be used for any
adversarial relationship encountered on the next project with strict adherence to the formal
communication channels. If the relationship is improved, the mutual benefits of improved
coordination will more than outweigh the efforts expended.
REFERENCES
EPA (U. S. Environmental Protection Agency). 1985. Investigation of Arsenic in Southeastern North
Dakota Ground Water: A Superfund Remedial Investigation Report. Prepared by the North
Dakota State Department of Health: Bismarck, North Dakota.
. 1986a. Water Treatment Alternatives for the Reduction of Arsenic in Ground Water Supplies
of Southeastern North Dakota (Feasibility Study). Prepared by the North Dakota State
Department of Health: Bismarck, North Dakota.
. 1986b. Record of Decision: Remedial Alternative Selection for the North Dakota Arsenic
Trioxide Site.
. 1988a. Action Memorandum dated February 5, 1988 approving "Supplemental Remedial Action
for the Cities of Lidgerwood and Wyndmere, North Dakota." Denver, Colorado.
. I988b. North Dakota Arsenic Trioxide Feasibility Study Analysis. Prepared by the North
Dakota State Department of Health: Bismarck, North Dakota.
. I988c. Action Memorandum dated October 21, 1988: "Request for Removal Action Approval
at the Arsenic Trioxide Site; Lidgerwood, North Dakota." Denver, Colorado.
. I989a. Design Summary Report: Lidgerwood Water Treatment Plant, Arsenic Trioxide Site.
Prepared by the U. S. Bureau of Reclamation (BOR): Denver, Colorado. Specification No. 60-
C0211.
. I989b. Community Relations Plan for Lidgerwood, North Dakota: North Dakota Arsenic
Trioxide Site. Prepared by CH2M Hill: Milwaukee, Minnesota.
. 1991. Superfund Site Remedial Action Report Lidgerwood Water Treatment Plant
Modification. Prepared by BOR: Bismarck, North Dakota.
EPA/BOR. 1989. Modification Design Report Lidgerwood Water Treatment Plant. BOR: Denver,
Colorado.
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IV. GROUNDWATER REMEDIATION
588
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Pitfalls in Hydrogeologic Characterization
Steven D. Acree
R.S. Kerr Environmental Research Laboratory
U.S. Environmental Protection Agency
P.O. Box 1198
Ada, OK 74820
(405) 332-8800
INTRODUCTION
The primary objective of the site characterization program
is the collection of information necessary to support remedial
action decisions and designs. Information concerning contaminant
sources, the severity and extent of contamination, and the
hydrogeologic properties of the surface and subsurface materials
should be gathered during the hydrogeologic characterization
phases. In addition to the acquisition of detailed hydrogeologic
and contaminant data, much site specific information concerning
other pertinent physical, chemical, and biological processes is
required to effectively evaluate contaminant fate and transport
processes and for implementation of remediation technologies.
The failure to obtain the appropriate characterization data may
result in such problems as the implementation of an inappropriate
remediation technology, the design of an inefficient remediation
system, and the incursion of excessive remediation costs.
The objective of this study is to highlight common omissions
in the hydrogeologic phases of site characterization programs.
The problems identified in this paper were common to many of the
characterizations which were reviewed. The specific focus of
this paper is the identification of data gaps which affect
ground-water remedial action decisions and designs. The early
elimination of these data gaps from site characterization
programs leads to more informed decisions concerning remedial
alternatives.
BACKGROUND
The site characterization programs conducted under the RCRA
and CERCLA authorities at over thirty sites have been reviewed in
detail and are compiled for this study. Based on these reviews
several common gaps in the identification of contaminant sources
and the characterization of hydrogeologic properties were
identified. Data from several sites have been used to illustrate
these problems and the effects on ground-water remedial
decisions. For additional information concerning many of the
pertinent issues in hydrogeologic and contaminant transport
assessments, the reader is referred to such publications as U.S.
Environmental Protection Agency (1989a, 1989b, and 1990).
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The use of a phased approach to site characterization offers
the opportunity to evaluate data needs in relation to an evolving
conceptual model. This was the approach adopted at many of the
study sites. The objective of the early characterization phases
should be the acquisition of a high quality base of fundamental
information from which the initial conceptual model is built or
refined. Data gaps should be identified following each phase.
The program should then be modified to collect the detailed data
required for resolution of these data gaps. While the
acquisition of "detailed data incurs greater initial costs, the
ultimate savings in remediation costs may be substantial through
choice of the most appropriate and efficient system.
The level of detail required for an adequate site
characterization is dependant upon the subsurface heterogeneity
at the site and the remedial technologies under consideration.
The hydrogeologic settings of the sites chosen for illustration
are predominantly unconsolidated sediments (gravels, sands,
silts, and clays) deposited in fluvial and deltaic environments.
The hydrogeology at each of these sites exhibits a high degree of
heterogeneity and is considered complex. The assessment of fluid
flow and contaminant transport in weathered and fractured
crystalline rock settings is a highly complex issue and is not
addressed in this paper. The reader is referred to such
publications as Georgia State University (1988) and Schmelling
and Ross (1989) for discussions of special topics and techniques
associated with hydrogeologic characterization in fractured rock.
DISCUSSION
The basic objectives of site characterization programs are
generally well defined prior to implementation. However,
specific data pertinent to remedial decisions are sometimes not
obtained. The collection of these data may be neglected due to a
lack of awareness of certain pertinent issues. The most
significant data gaps identified in review of these
characterization programs involved source identification,
definition of the contaminant plume, and recognition of the three
dimensional aspects of ground-water flow and contaminant
transport. Specific discussion and examples concerning the
potential effects of these data gaps on remediation design are
provided below.
Source Identification
Many characterization programs initially failed to acquire
sufficient information to adequately define the sources of
ground-water contamination at the site. In determining the
extent of ground-water contamination from known or suspected
sources, the available data often indicated the existence of
additional sources. In some cases the characterization programs
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were not modified to locate these sources or to fully define the
associated contamination.
Sources for continued ground-water contamination may
continue to exist in the subsurface after the obvious surface
sources (e.g., surface impoundments, tanks, pipelines,
contaminated surface soils, etc.) have been removed. These
sources include non-aqueous phase liquids (NAPLs) and
contaminants adsorbed to naturally occurring organic material or
the surfaces of soil particles (Figure 1). The immiscible phase
liquids may exist as mobile fluid masses or as immobile residual
contaminant masses which are trapped in pore spaces by capillary
forces. The occurrence of contaminants in any of these phases
represents the existence of sources for continued contamination
of ground water. Many characterization programs did not fully
evaluate the existence of these additional contamination sources.
Incomplete source characterization may preclude effective source
removal. The removal of these contaminant sources is a vital
element of remediation efforts.
The choice of appropriate remediation technologies (e.g.,
ground-water pump-and-treat systems, bioremediation, non-aqueous
phase liquid recovery, soil vapor extraction, etc.) may be
dictated by the existence of these subsurface sources. Non-
aqueous phase liquids trapped in soil pores within the saturated
zone are not readily removed using conventional ground-water
extraction. The dissolution of these compounds into the ground
water is controlled by diffusive liquid-liquid partitioning.
Removal of this source using conventional ground-water extraction
may require an unacceptable length of time. The evaluation of
enhanced remediation technologies at such sites is warranted.
ADVECTION
ADVECTION
^ORGANIC CARBON OR
MINERAL OXIDE SURFACE
LMUMJOUO
PARTTnOMNG.
A B
Figure 1. Sources for ground-water contamination in the
subsurface. (a) Desorption of contaminants adsorbed to organic
carbon or mineral surfaces. (b) Partitioning of non-aqueous
phase liquids trapped within poire spaces by capillary forces
(from Keely, 1989).
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The presence of immobile, adsorbed constituents may also
dictate the use of enhanced remedial designs. The rates at which
these constituents desorb to the ground water depend on the
sorptive properties of the constituent and the properties of the
aquifer materials. The number of pore volumes of ground water
which must be removed for remediation to be achieved also depends
on ground-water flow velocities. Ground-water flow velocities
during remediation may be too large to allow the constituents to
desorb to equilibrium concentrations. This leads to a decrease
in the contaminant removal efficiency of the system. As
contaminant concentrations are decreased in the aquifer, the
contaminant removal efficiency, as measured by the mass of
contaminant per volume of recovered ground water, will also
decrease. In such situations the use of enhanced technologies
(e.g., pulsed pumping or bioremediation) should also be evaluated
to increase the efficiency of the system and reduce the time
required for remediation.
Two case histories illustrate the potential effects of
incomplete source identification on remedial design. In the
first example, hazardous wastes, including various organic
liquids, were used and disposed at the site. Based on the
specific gravities and solubilities of these fluids, the
potential for NAPLs with densities less than water (LNAPLs) and
greater than water (DNAPLs) to be present in the subsurface
existed.
The characterization program was designed to provide
information concerning the existence and extent of dissolved
phase contamination. A direct evaluation of the presence or
extent of subsurface NAPLs was not initially conducted. In
addition, the available data were not examined for possible
evidence of NAPLs (e.g., subsurface soil staining, constituent
concentrations in percentages of solubility limits, accumulation
in wells, etc.). In response to elevated constituent
concentrations in ground water, a ground-water extraction system
was installed to provide hydraulic containment at the
downgradient property boundary-
The extraction wells were designed to fully screen the
saturated zone from the water table to the top of a semi-
confining unit identified at depths of approximately 50 feet
beneath much of the site. Operation of several of these wells
resulted in extraction of both contaminated ground water and
DNAPLs. Renewed interest in the presence and extent of
subsurface DNAPLs led to the detection of significant
accumulations of DNAPLs in many wells which were screened above
the semi-confining unit.
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DISPOSAL
AREA
\ 'r/
WELL
DNAPLs^
FEET
Figure 2. Schematic map with ground-water extraction well
locations and the known extent of subsurface DNAPLs, as defined
by accumulation in wells, depicted.
The onsite region contaminated with potentially mobile,
subsurface DNAPLs was found to be extensive (Figure 2). These
fluids represent a major source for ground-water contamination
which was not previously recognized. The extent and mobility of
the DNAPLs at this site are currently not well defined.
Additional studies are required to provide this information and
for the design of the most appropriate remediation system.
Another example of complications in remedial design arising
from incomplete source characterization is illustrated in Figure
3. Analysis of the hydrogeologic and ground-water quality data
from this site indicated that multiple sources of ground-water
contamination might be present. However, the characterization
program was not modified to provide sufficient data to determine
the locations of all sources or the extent and severity of
contamination resulting from these sources. As a result, the
remediation program proposed for the site (ground-water
extraction and treatment) did not effectively address all
sources.
An analysis of the proposed system indicated that
significant quantities of ground water containing relatively high
concentrations of constituents could be drawn into less
contaminated portions of the aquifer by the recovery wells. This
situation could result in an increase in the concentrations of
sorbed constituents within the less contaminated portions of the
aquifer and the extraction of greater volumes of ground water to
achieve remedial goals. Additional information concerning the
extent and severity of contamination was required to design a
more efficient remediation system.
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POTENTIAL
SOURCES
FLOW
EXTRACTION
O -^ WELLS
0 500
FEET
Figure 3. Schematic map showing contaminant distribution in
relation to the known and potential sources, the locations of
ground-water extraction wells, and the anticipated ground-water
flow directions during recovery.
Definition of the Extent of Contamination
Characterization programs sometimes fail to sufficiently
delineate the plume of ground-water contamination for remedial
purposes. Knowledge concerning the distribution of constituents
within the subsurface is required to design a remediation system
or to ensure hydraulic containment is maintained within the
saturated zone. The horizontal and vertical extent of each
constituent should be defined to the specified remedial goals.
The optimum spacing of wells and the choice of appropriate screen
intervals will principally depend on the mobility of the
particular constituents of concern, the composition of the
aquifer materials, and the hydrologic properties of the system.
A detailed definition of the contaminant plume provides data for
calibration of contaminant transport models and allows the design
of more efficient remedial systems.
The following case history illustrates one of the potential
remedial design complications which can result from insufficient
information concerning the contaminant plume. In this situation,
ground-water monitoring wells were concentrated within a limited
area of the contaminant plume (Figure 4). An additional well was
installed within the contaminant plume and immediately upgradient
of a potential ground-water discharge point. However, data were
not acquired to evaluate the potential for ground-water discharge
or recharge.
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FLOW
WELL
CONTAMINANT PLUMES
o
500
FEET
Figure 4. Schematic map showing the contaminant source area, the
locations of ground-water monitoring wells, the direction of
ground-water flow, and the estimated extent of the contaminant
plumes.
Elevated concentrations of both relatively mobile and less
mobile constituents were detected in ground-water samples. The
available data were not sufficient to accurately define the
extent of ground-water contamination due to these constituents.
This resulted in a large degree of uncertainty as to the
appropriate design or placement of the system components to
either remediate or hydraulically contain the contaminated ground
water as efficiently as possible. Remedial design using only
these data might result in the installation of a system which is
highly inefficient and might not achieve the remedial goals
within appropriate time periods. It would also be difficult to
monitor the effectiveness of the remediation system since the
contaminant distribution prior to remediation was not well
defined. Additional ground-water monitoring data were required
to reduce the uncertainty in remedial design.
Hvdrogeologic Description
Frequently, the hydrogeologic system is poorly defined
during site characterization. Subsurface heterogeneities result
in complex transport pathways. These heterogeneities are
difficult to adequately characterize. However, the value of this
information in evaluating contaminant transport and remedial
designs for the site may be significant. One feature of many
characterization programs is the lack of hydrogeologic data
collected on a scale consistent with the degree of heterogeneity
at the site.
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Lithologic samples are often obtained at vertical intervals
of several feet during drilling. At these same sites the
lithology may be varying within a similar or smaller interval.
This may result in the formulation of an inaccurate conceptual
model. A preferred approach is to obtain continuous cores or
continuous split spoon samples from a representative number of
borings during the initial characterization phase. The use of
geophysical logging tools also provides additional data for
stratigraphic correlations. Based on the interpretation of these
data, the sampling interval for additional wells and borings can
be established.
Many characterization programs did not obtain sufficient
data to define ground-water flow directions and contaminant
transport paths within the saturated zone. The most common data
gaps involved the lack of either a sufficient number of
piezometers screened at appropriate depths or adequate hydrologic
testing to define the three dimensional ground-water flow field.
These data are valuable in refining the conceptual model for
ground-water flow and contaminant transport in support of
remedial design. The evaluation of these efforts may lead to an
increased understanding of the dominant transport pathways at the
site.
A related problem which leads to additional uncertainty in
areas with significant vertical hydraulic gradients is the use of
wells with long screen intervals to obtain piezometric data. The
design considerations of wells installed to monitor ground-water
quality and those of piezometers are often quite different.
Piezometers should be discretely screened over a relatively small
interval within a hydrogeologic unit. The use of spatially
clustered piezometers screened within the hydrogeologic units of
interest provides more detailed data than can be obtained using
wells constructed with long screen intervals. The value of this
detailed information depends on the particular hydrologic system
and the degree of subsurface heterogeneity at the site.
The acquisition of detailed stratigraphic and hydrologic
data should be conducted in the early phases of characterization.
The initial characterization phase should include geological and
geophysical logging of a sufficient number of borings to provide
data for the production of detailed hydrogeologic cross sections.
A network of piezometers should be installed, screened at
appropriate depths, and monitored to determine ground-water flow
directions and any variations related to climatic and
anthropomorphic factors. Such factors include seasonal increases
in ground-water recharge, variations in the recharge/discharge
relationships of ground water to surface water bodies, crop
irrigation, and local ground-water usage patterns. Each of these
factors should be evaluated in determining ground-water flow *
directions at a site. A program of hydrologic testing should
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also be conducted to provide data for identification of
preferential transport paths. The results of these
investigations should then be used to refine the conceptual model
for the site.
Two examples of the many situations in which detailed
hydrogeologic evaluations could be used to refine the conceptual
site model and to enhance remedial designs are provided below.
The first example is based on a compilation of potential problems
identified in review of several hydrogeologic investigations.
These problems (Figure 5) include the construction of wells
screening multiple hydrogeologic units, the inappropriate use of
long well screens, the lack of a sufficient number of wells
screened at appropriate depths, and the spacing of borings for
lithologic control.
The three wells illustrated in this figure are screened at
different depths above, across, and below a potentially extensive
clay unit. Based on the intervals and the different units which
are screened, the piezometric data are not sufficient to
adequately define the ground-water flow directions. The
installation of additional wells would be required to determine
flow directions in each unit. It should also be noted that well
2 is screened across the interpreted clay layer. In this
position it may serve as a conduit for the rapid transmission of
contaminants across the clay layer.
100
100
Figure 5. Hydrogeologic cross section showing wells with screened
intervals and piezometric data for each well. Elevations are in
feet above mean sea level.
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The lengths of the well screens in this illustration (20 and
30 feet) may not be appropriate for obtaining either detailed
potentiometric data or water quality data. The long screens
would not be appropriate for obtaining detailed data in regions
where vertical hydraulic or water quality gradients existed.
Data concerning vertical gradients may be obtained using
spatially clustered wells screened at various depths within
discrete units. The use of clustered well installations should
be evaluated prior to the installation of wells designed with
long screens.
It may also be argued that the spacing of the borings in
this illustration is too great to provide sufficient lithologic
data for development of the conceptual model. The hydrogeologic
interpretation presented in Figure 5 is only one of several
possible interpretations which are supported by the limited data.
Additional data would be required to reduce the uncertainty
concerning interpretation of the clay units as either an
extensive layer or as discrete lenses. Additional borings,
surface geophysical surveys, and hydraulic testing would provide
data which could be useful in discerning the appropriate
interpretation.
Each of the practices discussed above will lead to
uncertainty in the conceptual model for ground-water flow and
contaminant transport at a site. This increased uncertainty
translates directly to uncertainty in the appropriate design and
placement of an effective remediation or hydraulic containment
system. The evaluation and modification of such practices should
be conducted throughout the characterization program to ensure
that the quality and quantity of data are sufficient to
adequately support the remedial design phase.
The final case study illustrates one of the effects of
subsurface heterogeneity on remediation efforts. In this
example, a ground-water extraction system was installed at a site
to provide hydraulic containment and contaminant mass removal.
The extraction wells were designed to fully screen the saturated
zone from the water table to the top of a semi-confining unit.
Two hydrogeologic units with distinct hydraulic properties were
identified within the screened interval (Figure 6). The lower
unit exhibited a significantly greater hydraulic conductivity
than the upper unit. In addition, contaminant concentrations
were significantly greater in the upper unit than in the lower
unit. As a result of the differences in hydraulic properties,
the water recovered by the wells was predominantly from the lower
unit.
The use of this design resulted in increased transport of
highly contaminated water from the upper unit into the lower unit
prior to recovery. This system was inefficient in terms of
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Q
t
TOTAL
Q
LOW
K
LOW
Q
HIGH
K
HIGH
Figure 6. Schematic diagram of ground-water extraction well
construction and the hydrogeologic cross section. The relative
hydraulic conductivity (K) of each unit and contribution to the
total discharge (Q) from each unit in the saturated zone are
shown.
achieving the goal of contaminant mass removal compared to a
system using extraction wells screened within individual
hydrogeologic units. In the present case, larger quantities of
less contaminated water must be extracted to recover equal
volumes of contaminants. This situation may also lead to an
increase in the concentrations of sorbed constituents within the
lower unit resulting in increased difficulty in achieving
remedial goals. However, the information gained from monitoring
the performance of this system has provided much useful data for
the design of a more efficient system.
CONCLUSIONS
Several practices identified during this review lead to
increased uncertainty in the design of remediation systems.
These data gaps often involve the failure to recognize and
characterize all significant sources for ground-water
contamination at a site. These sources include NAPLs and
adsorbed constituents which remain in the subsurface after the
surface sources of contamination have been removed. The
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potential for the existence of subsurface NAPLs should be
thoroughly evaluated during the site characterization program.
Other common data gaps involve a poor definition of the
horizontal or vertical extent of ground-water contamination and
the failure to evaluate the three dimensional aspects of
contaminant transport at the site. These data gaps may result in
the design of a remedial or hydraulic containment system which is
inefficient or does not meet the required performance standards.
An increased awareness of the pertinent site characterization
issues and the implementation of a responsive characterization
program are necessary to provide the information required for
improved remedial designs.
DISCLAIMER
This paper has been reviewed in accordance with the U.S.
Environmental Protection Agency's administrative review policies
and approved for presentation and/or publication.
REFERENCES
Georgia State University, 1988. Symposium Proceedings of
International Conference on Fluid Flow in Fractured Rocks, May
15-18, 1988, Georgia State University, Atlanta, Georgia.
Keely, J.F., 1989. Performance evaluations of pump-and-treat
remediations, Ground Water Issue, EPA/540/4-89/005, Center for
Environmental Research Information, Cincinnati, Ohio.
Schmelling, S.G., and R.R. Ross, 1989. Contaminant transport in
fractured media: Models for decision makers, Superfund Ground
Water Issue, EPA/540/4-89/004, Center for Environmental Research
Information, Cincinnati, Ohio.
U.S. Environmental Protection Agency, 1989a. Seminar on site
characterization for subsurface remediations, CERI-89-224, Center
for Environmental Research Information, Cincinnati, Ohio.
U.S. Environmental Protection Agency, 1989b. Seminar publication,
Transport and fate of contaminants in the subsurface, EPA/625/4-
89/019, Center for Environmental Research Information,
Cincinnati, Ohio.
U.S. Environmental Protection Agency, 1990. Handbook, Ground
water, Volume 1: Ground water and contamination, EPA/625/6-
90/016a, Center for Environmental Research Information,
Cincinnati, Ohio.
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Areawide Implementation of Groundwater Institutional
Controls for Superfund Sites
David G. Byro
U.S. Environmental Protection Agency
841 Chestnut Building
Mallcode 3HW21
Philadelphia, PA 19107
(215) 597-8250
Maria T. Goman
The County of Chester
Health Department
326 North Walnut Street
West Chester, PA 19380
(215) 344-6225
INTRODUCTION
Institutional controls (ICs) are non-engineering mechanisms used to prevent or reduce human
exposure to contaminated areas. ICs are primarily used at hazardous waste sites to supplement
engineering actions when there remains a continuing level of risk to human health. The two most
frequently invoked ICs are deed restrictions to limit land use and local restrictions on the
installation of new groundwater wells where alternative water supplies are provided. This paper
provides recent experience gained by EPA-Region III and Chester County Health Department
(CCHD) in controlling the use of contaminated groundwater.
The use of ICs to supplement remedial actions is prevalent within EPA's Superfund Program. A
recent search through EPA's RODs database revealed that approximately forty-three percent of
EPA's Record of Decisions (ROD) include ICs.
Even though they are commonly required, ICs are usually difficult if not impossible to implement
as specified in the ROD. This is often caused by lack of planning prior to finalizing the ROD.
The resultant requirements for ICs are frequently vague, lacking details concerning the legal
authority for the 1C and who is responsible for its implementation. From the Federal perspective,
implementation of ICs is further complicated due to lack of Federal authority. The authority for
ICs is usually derived from either state or local laws. Consequently, as Superfund site managers
attempt to implement the ROD, they are often faced with time consuming negotiations with the
public and state or local authorities. The net effect is delays in the schedule for implementation
of the remedial action.
On the other hand, state and local agencies with the authority to implement beneficial ICs are
sometimes hampered due to the lack of data. For example, many local authorities regulate well
con- struction and can consequently protect the public from contaminated groundwater.
Nevertheless, due to the lack of information flow, they may be unaware of the existence of a
Superfund site and may unknowingly be approving new water supplies from the contaminated
aquifer. This is partially due to the fact that the Superfund Program addresses contamination on a
site specific basis. There is no inherent mechanism to provide local authorities with site related
data on an areawide scale.
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This report documents a recent initiative by EPA-Region III and CCHD which resulted in the
successful implementation of groundwater IC's at nine sites within Chester County, Pennsylvania.
This initiative is analyzed from the perspective of both EPA and CCHD. It is provided to assist
other hazardous waste site managers and local authorities implement similar procedures where
groundwater ICs are a required or beneficial supplement to a remedial action.
BACKGROUND
Chester County is located in southeastern Pennsylvania outside of the city of Philadelphia. Land
use in the County has been historically dominated by agriculture. Recently however, there has
been a significant increase in single family residences. Due to its predominantly rural
composition, approximately sixty percent of the 376,396 residents in the County rely on private
residential(individual) wells for their water supply.
Industry utilizes only one percent of the available land in the County. Nevertheless, ground water
contamination, especially by the volatile organic compounds(VOCs), associated with industrial
solvents, have long been a significant health threat to County residents. As noted in Figure 1,
there are nine Superfund sites in Chester County, eight of which have VOC contaminated ground
water.
Between 1986 and 1990, RODs were prepared for three of the Superfund sites in the County. Each
ROD contained future well installation restrictions as a supplement to alternative water supply
actions. In each case the language is very vague. This indicates the authors had little
foreknowledge concerning the legal authority for the 1C and who was responsible for its
implementa- tion. The relevant 1C language from the three RODs is:
1. "Administrative controls to prevent the installation of new ground water extraction wells
for use within the area affected by ground water contamination should be implemented."
2. "Additional deed restrictions or other institutional devices may be required to reduce the
risk of new wells being developed in the area and creating new health risks."
3. "...and to restrict use of ground water by placing limitations on the installation of ground
water wells."
CCHD was established in May 1968 under Pennsylvania's "Local Health Administration Law" (PA
Act 315). CCHD has actively pursued the sources of the County's groundwater contamination and
has identified at least two Superfund sites. One area that is regulated by CCHD is the
construction of new individual wells. Their Well Permitting Program requires applicants to test
their well water for pH, nitrates, coliform, bacteria, iron, manganese, chloride, color,
MBAS(detergents) and odor. Approximately 1,200 new wells are permitted each year.
In October 1989, EPA-Region III presented an overview of the nine Superfund sites within
Chester County to representatives of CCHD. After this exchange, the Department became
concerned that their Well Permitting Program was approving individual water
supplies in areas where the supply may be contaminated from
Superfund sites. By using water from this source, the homeowners were possibly placed at risk
without their knowledge.
During 1990 CCHD and EPA worked together to incorporate special procedures within CCHD's
Well Permitting Program to control the installation of new wells within the Superfund sites' area
of contamination. This effort included mapping a reasonable area of concern around each
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SUPERFUND SITES IN CHESTER COUNTY, PA.
(LISTED ON THE NATIONAL PRIORITIES LIST)
1. AIW FRANK
INTERSECTION ROUTE 202
A ROUTE 30
EXTON 19341
2 BLOSENSK1 LANDFILL
ROUTE 340
WAGTONTOWN 19376
3. KJMBERTON SITE
COLD STREAM & HARES HILL
ROAD
KJMBERTON 19442
MALVERN TCE SITE
258 N. PHOENDCV1LLE PIKE
MALVERN 19355
PAOLI RAIL YARD
RR SERVICE SHOP
PAOU 19301
RECTICON / ALLIED STEEL
ROUTE 724 S. WELLS ROAD
PARKERFORD 19457
STRASBURG LANDFILL
STRASBURG ROAD
NEWLIN TOWNSHIP 19320
BARKMAN / WELSH ROAD
LANDFILL
WELSH ROAD
HONEYBROOK 19344
WILLIAM DICK LAGOONS
TELEGRAPH ROAD
WEST CALN TOWNSHIP 19376
\
o»-
MMYLAND
FIGURE 1
tree U.S Environmental Protection Afeacy, 1990.
prepared by: Cboter Couoiy PUoiuoi Coounaooe A Chester County Health Department,
1990.
603
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Superfund site within the County. For those sites that have been fully evaluated, the area of
concern was well documented and quite specific. However, in those areas where the site has not
been extensively studied, a conservative approach was taken and the area of concern was
established to include any area within 1/4 mile of the site. The area of concern can be modified
as more data becomes available. In addition, site specific lists were compiled containing the
names of the EPA project manager and responsible parties, the contaminants of concern and the
recommended analytical methods. Finally, CCHD management provided these maps and lists to
their Well Permitting Program staff and revised their permit procedures for wells drilled within
the area of concern.
DISCUSSION
The existing CCHD regulations require prior approval of all wells which are proposed to be drilled
within the County. The applicant must submit a permit application to the CCHD before
proceeding. The application must include the exact location of the proposed well and the location
of potential pollution sources (i.e. on-lot sewage systems, fuel tanks, buildings, etc.). The process
has now been modified so that upon the Department's receipt of a well application, the well's
location is checked against the Superfund site maps to determine if it is within any area of
concern. If the well is located within these areas, as condition of the approval to drill, the
applicant is required to test the supply for the contaminants associated with the specific Superfund
site in addition to the analysis routinely required for all new wells in Chester County. The
analytical method used must have a method detection limit lower than the maximum contaminant
level (MCL). For VOCs, EPA Method 502 or 524 is recommended. The applicant is also supplied
the names of the Potentially Responsible Parties(PRPs) and the EPA Project Manager for the site.
Once the well is drilled, the well driller is responsible for supplying the Department with the
driller's log and construction information (depth of casing, type of grout, depth of pump, etc.).
The owners must then test the well and obtain a passing analysis prior to receiving approval to use
the supply. If the MCLs are exceeded, the well owner must treat the supply for the contaminants
of concern. When the treatment unit is installed, a staff member visually verifies the placement of
the treatment unit and the supply is retested to assure that the treatment unit is working. As a
condition of the approval of the water supply, the applicant is required to analyze the supply
yearly for those contaminants that originally exceeded drinking water standards.
By requiring the additional testing around Superfund sites, CCHD has gained some level of
confidence that the homeowners are not unknowingly being exposed to unsafe levels of
contamination. Also, as all contaminated wells are reported to the EPA Project Manager, EPA
may be able to utilize this additional data in their analysis of the site.
CCHD has found that public reaction to the program ranges from extreme gratitude for informing
the homeowner of the potential problem, through mere acceptance of the addition testing require-
ments, to "what do you mean I have to test? My grandfather has been drinking this water for 40
years and he is not dead yet?"
Overall, the project does not consume a large amount of staff time since CCHD staff already
reviews every well drilled within the County. The benefits of assuring safe water far outweigh
the minute time cost of County personnel. Unfortunately, unless there is a cooperative PRP,
homeowner/well applicant must assume the entire cost of analysis and/or treatment. However,
the homeowner may legally pursue the PRP to recover the cost if contamination is found and can
be directly associated to the site. This has not occurred yet but the potential exists.
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CONCLUSIONS
This simple interagency coordination has provided significant environmental benefits for little
resources. It has provided support to CCHD in enforcing their well permit program and has
enabled EPA to implement the 1C requirements of three RODs. In addition, since the ICs have
been implemented Countywide, they are controlling some of the risks associated with five other
Superfund sites while remedial investigations and feasibility studies continue.
Institutional controls have often had a negative impact on the schedules for the clean-up of
hazardous waste sites by consuming the manager's time trying to implement them. The well
permit review procedures implemented in Chester County, PA has partially resolved this problem
for a number of sites. There is the potential to gain further environmental benefits nationwide by
implementing similar procedures wherever a local or state agency has the authority to control the
installation of new wells.
REFERENCES
1. Chester County Health Department: Chester County Health Department Rules and
Regulations: West Chester, PA: CCHD: Undated.
2. Nicholas, Sara: Institutional Controls at Superfund Sites, A Study of Implementation and
Enforcement Issues, Ten Case Studies and Analysis: U.S. EPA: Sept. 22, 1988.
3. Sobotka & Company, Inc. for U.S. Environmental Protection Agency: Implementation of
Institutional Controls at Superfund Sites, Final Draft: Washington, D.C.: U.S. EPA: Oct. 15,
1989.
4. U.S. Environmental Protection Agency: Draft Policy Directive on the Use of Institutional
Controls: Washington, D.C.: U.S EPA: Sept. 30, 1988.
5. U.S. Environmental Protection Agency: Declaration for the Record of Decision
(Kimberton Superfund Site): Philadelphia, PA: U.S. EPA: June 30, 1989.
6. U.S. Environmental Protection Agency: Record of Decision, Remedial Alternative
Decision (Blosenski Landfill): Philadelphia, PA: U.S. EPA: Sept. 29, 1986.
7. U.S. Environmental Protection Agency: Record of Decision, Walsh Landfill Superfund
Site: Philadelphia, PA: U. S. EPA: June 29, 1990.
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Verifying Design Assumptions
During Construction of Groundwater Remediations
Michael E. Grain
U.S. Army Corps of Engineers, Omaha District
215 North 17th St., Omaha, Nebraska 68102
(402) 221-4494
David J. Becker
U.S. Army Corps of Engineers, Missouri River Division
P.O. Box 103 DTS, Omaha, Nebraska 68102
(402) 221-7340
INTRODUCTION
The design of groundwater remediations is filled with uncertainties, often despite good pre-design
field investigations. Construction and startup provide the true test of assumptions made during the
design process. These phases of the project must be planned properly so as to gather the information
necessary to verify the design assumptions. This paper is intended to review basic data which is easily
gathered during construction, but all too often is not. This information can be used to improve the
operation of the system, speed the resolution of problems or construction claims, or allow for
alterations in the design prior to completion of construction. This information is not meant to be a
substitute for good pre-design investigations. Two case studies will be discussed which highlight
some impacts of construction-generated data.
BACKGROUND
Typical Design Assumptions
Despite often extensive site investigation and data gathering activities which take place during the
remedial investigation (RI) and pre-design stages of most groundwater remediation projects, many
assumptions must still be made during design. These assumptions usually relate to the conceptual
model of the site conditions and the performance characteristics of certain components of the
remediation system. Assumptions related to the site model may include stratigraphy between
boreholes, aquifer properties, chemical concentrations (both contaminants and natural ions), and
seasonal variations in water levels. Assumptions related to the remediation system itself may include
yields from extraction wells or trenches and well efficiency. Though many of these parameters are
estimated through sampling or testing during the investigation phases of the project, the number of
data points available to develop these estimates are usually limited due to time and funding
restrictions. Therefore assumptions must be made by the designer regarding the degree to which the
available data are representative of the site conditions between measurement points. Additional data
generated during construction can be used to refine the site model and verify assumptions regarding
performance of the remediation system components.
Case Studies to be Considered
As examples of these typical design assumptions, background information for two sites, the Millcreek
Superfund Site, Ohio and a Superfund site in the Southwestern U.S. are presented. In the next
section, the verification of these assumptions are discussed.
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Millcreek Superfund Site
The site is located in Millcreek Township in Erie County, Pennsylvania, approximately 2 miles
southwest of the city of Erie. The 75-acre site was originally a swamp which was filled with foundry
sand and slag beginning in 1941. Approximately 4 acres of wetland remain in the southern portion
of the site. The north and west portions of the site are covered in deciduous forest. The remainder
of the site is covered with low brush and young trees. The site is essentially flat, with the exception
of a few mounds of foundry sand up to fifteen feet high. The site is bordered on the north and west
by residential areas and a baseball park; and on the east by a combination of residential and
commercial/industrial areas. Marshall's Run creek flows along the eastern property boundary. Site
features are shown on Figure 1.
The site operated as an unpermitted landfill from 1941 until 1981. Wastes disposed of at the site
included non-halogenated solvents, polyester resins, caustics, paint wastes, ink wastes, waste oils,
PCB-contaminated solvents, ethylene glycol, grease, and graphite. The site was placed on the
National Priorities List in 1984 after preliminary sampling indicated that the soils on site were
contaminated with PCB's, polynuclear aromatic hydrocarbons, chlorinated solvents, and heavy metals.
The groundwater in the eastern portion of the site and east of Marshall's Run was contaminated with
chlorinated solvents.
The site is underlain by glaciolacustrine deposits of fine sand and silt with occasional clayey or
gravelly zones. These deposits range in thickness from 15 to 28 feet across the site. They are
underlain by very dense fine grained glacial till 2-10 feet thick which directly overlies shale bedrock.
Groundwater occurs in the glaciolacustrine deposits and the fill at depths of approximately 2 to 10
feet below the ground surface. Groundwater flow is to the north with some localized lateral discharge
to Marshall's Run and the swamp in the southern portion of the site. Contaminants in the
groundwater consist primarily of volatile organics, with 1-2 dichloroethene (DCE) being the most
frequently detected compound. DCE concentration ranged as high as 1000 ug/1 on site and 100 ug/1
in offsite downgradient wells. Substantially elevated, but somewhat lower, concentrations of
trichloroethene (TCE) and vinyl chloride were also found in both onsite and offsite monitoring wells.
The extent of DCE contamination in groundwater is shown on Figure 2.
In 1986 EPA issued a Record of Decision which recommended excavation and consolidation of
contaminated soils on-site under a RCRA cap, site grading and placement of a soil cover over the
remainder of the site, and pumping and treating of contaminated groundwater. EPA tasked the Army
Corps of Engineers with pre-design, design, and construction management to implement these
recommendations.
Extensive pre-design investigations were performed. These included drilling and sampling fifty
additional soil borings, installing sixteen new monitoring wells, aquifer testing, sediment and surface
water sampling, and treatability testing. Extensive computer modeling of groundwater flow and
contaminant fate and transport in both the unsaturated and saturated zones was also conducted.
Groundwater flow modeling was performed using a two-dimensional model. This model was utilized
to simulate various extraction system configurations. Aquifer testing conducted on site indicated that
yields from individual wells would be very low across much of the site, which implied that a very
large number of wells would be required to capture and remediate the plume. Therefore, it was
decided to utilize collection trenches instead of wells. Groundwater modeling indicated that five
trenches located along the north and east boundaries of the site would most efficiently capture the
plume. The locations of the trenches are shown on Figure 1.
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Design assumptions which were made included the following:
1) Extensive characterization of the site had been performed and it was recognized that
there was a high degree of aquifer variability across the site. However, for modeling
purposes, simplifying assumptions had to be made regarding the distribution of
hydraulic conductivities and other aquifer properties.
2) A 72-hour pump test was planned during the pre-design investigations. After drilling
of the soil borings and installation of the monitoring wells was completed, a location
was selected for the pump test that was considered to be representative of "average"
aquifer conditions near the center of the plume. After installation of a 6-inch
diameter pumping well, it was discovered that the well would produce less than 1
gpm. It was then decided to pump two monitoring wells with slightly higher yields
(6-8 gpm) in order to supply water to perform on-site pilot treatability testing. Slug
tests were also performed on all of the monitoring wells. Data collected from the slug
tests and pumping during pilot testing were used to determine hydraulic conductivities
across the site.
3) The yield from the collection trenches was estimated using the groundwater flow
model. Each trench was simulated as a line sink with a fixed groundwater elevation.
The operational water level in all five trenches was fixed at the same elevation.
4) The trenches were assumed to be 100% efficient, i.e. groundwater was assumed to be
at a uniform elevation along the length of the trench during operation which was the
same as the groundwater elevation in the aquifer.
5) Contaminant concentrations in the water produced from each trench were estimated
using a solute transport model.
The verification of the design assumptions for the Millcreek site are discussed in a subsequent section.
Superfund Site, Southwestern U.S.
This site is located in a desert basin in a southwestern state. The site is essentially flat with a slight
topographic slope to the south-southwest. Currently, the site is used as a municipal airport
surrounded by industrial and agricultural concerns. Residential development has also been increasing
in the area.
The site was placed on the National Priorities List in 1983 after the discovery of TCE contamination
in drinking water wells at the airport and surrounding facilities. Subsequent remedial investigations
delineated TCE contamination in two aquifers in alluvial sands and gravels underlying the site. The
shallowest plume, with maximum TCE concentrations in excess of 3000 ug/1, extends approximately
7000 feet in a southwesterly direction, generally parallel with the groundwater flow direction.
Monitoring well locations and plume configuration is shown on Figure 3. This plume has affected
an aquifer not generally used for drinking water. The deeper plume has, however, affected a wider
area of the local drinking water aquifer with much lower TCE concentrations.
In 1987, a Record of Decision was signed requiring remediation of the shallow aquifer as an Operable
Unit, pending a final site remedy. The selected remedy was for a pump and treat system utilizing air
stripping for water treatment and injection wells as a disposal option. The design of the system was
608
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undertaken by a contractor in the summer of 1988. The Corps of Engineers participated technically
by providing review comments on the design.
During the early stages of design, the decision was made to allow the design and construction to
proceed in two phases; the first of which would address the downgradient half of the shallow plume.
Information generated during the first phase would be used to refine the design of the remainder of
the system. Groundwater modeling of the performance of the entire system was performed using a
three-dimensional contaminant transport model. Design of this first phase was completed in early
1989 and construction was begun in spring of 1989. Start-up of the treatment plant and the phase one
wells was conducted in December 1989. The locations of the five extraction and seven injection wells
and the treatment plant are shown on Figure 4.
Design assumptions for this effort included the following:
1) The entire site was adequately characterized by monitoring wells with the exception
of the downgradient end of the plume; therefore, the design assumed aquifer
thickness, depth and character for most of the extraction/injection wells. This is in
part the result of a lack of adequate pre-design effort.
2) Although one modest length pump test and one air stripper/injection well test were
performed prior to design, these tests were run in the same general vicinity in the
upgradient half of the plume. Single-well, short-term pump tests performed in most
of the site monitoring wells provided some additional data on hydraulic conductivity
distribution, but again wells were widely spaced in the downgradient portion of the
plume. Therefore, the design was forced to assume hydraulic conductivities over
much of the phase one construction area.
3) The yields for each of the production wells were assumed to be 100 gpm in the
computer simulations performed during design.
4) The efficiencies of extraction and injection wells installed in the shallowest aquifer
(using the screen slot size, gravel pack, and reverse rotary drilling methods specified
in the design) were assumed to be reasonably good (i.e. the wells would produce the
required drawdown in the aquifer outside the wells without breaking suction on the
pumps).
5) TCE concentrations at the phase one production wells were inferred from the plume
mapped from the limited monitoring well data. The variability due to screened
interval and pumping rates were not considered. The data were used to project
atmospheric TCE loading from the air stripper. In addition, the monitoring wells
indicated that natural total dissolved solids (TDS) values varied considerably from
under 2000 ppm to over 5000 ppm. Despite this variability, the design incorporated
pH control for scaling prevention in the air stripper based on a single assumed value
estimated from limited existing data. Other effects of the high TDS were not
explicitly considered.
The verification of the design assumptions for this site are discussed in a subsequent section.
DISCUSSION
Various parameters can be gathered during construction to support certain assumptions. These fall
into three categories: 1) record keeping - of materials encountered and construction details; 2)
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performance testing - well efficiency, production rate, aquifer response; and 3) measurement of
existing aquifer conditions.
Good Record Keeping
A great deal of information is routinely generated during construction which can be used to evaluate
the validity of design assumptions. However, much of this data is often lost due to inadequate
documentation at the time of construction. This can be caused by specifications which do not require
construction contractors to provide such documentation, inadequate inspection by the owner's
representative, or simply the failure of designers to communicate their information needs to field
inspectors.
Construction specifications often do not contain detailed requirements for logging of boreholes drilled
for extraction wells, monitoring wells, and piezometers during construction. This is critical to
assessing the validity of the conceptual site model developed during the investigation and design
phases of the project. The location of components of the remediation system very seldom coincides
exactly with the location of borings performed prior to construction, thus requiring the designer to
interpolate between existing data points to estimate the subsurface conditions at a particular well.
Documentation of the subsurface conditions actually encountered during construction allows the
designer to continuously refine the conceptual site model and assess any potential impacts to the
design. Construction borings should be logged in detail by a geologist or soils engineer. The field
classifications of the materials encountered should be spot-checked by conducting a limited number
of laboratory classification tests (grain size analysis, Atterburg limits, etc.) on samples from each
boring. If responsibility for logging is placed on the construction contractor, specifications should
contain a detailed description of the information to be included on the log and should specify the
scale at which the information is to be presented to assure adequate resolution of the details shown.
Materials encountered during the excavation of collection trenches should also be documented if the
construction method permits. This can be done with an excavation or trench log with complete
material descriptions and locations referenced by stationing along the trench. Such documentation
of subsurface materials and conditions during construction activities can be used to determine if the
actual conditions differ from those assumed in the design in a manner that will adversely affect the
performance of the remediation system. Such documentation may also be invaluable in resolving
differing site condition claims with minimum disruption to the project.
Good documentation of the as-built configuration of extraction and monitoring wells, piezometers,
and groundwater collection trenches is also critical. Specifications should require the construction
contractor to prepare detailed installation diagrams and as-built drawings for all of these features.
The specifications should give a detailed listing of the information to be included on well installation
diagrams. Along with boring logs and performance testing, these records can be utilized to help
determine potential causes for differences between the actual performance of the system and design
predictions.
Dewatering is often required during construction of groundwater collection trenches or other
components of the remedial action which may or may not be directly related to removal of
groundwater. Regardless of the reason why the operation is performed, construction dewatering
provides an excellent opportunity to observe the aquifer response to hydraulic stress on a scale usually
not possible during earlier site investigation phases. However, documentation of dewateting
operations is usually not sufficient in detail to allow any meaningful relationship to be developed
between the results of those operations and the aquifer properties assumed for design of the
groundwater collection system. It will never be practical to conduct construction dewatering in the
type of controlled and carefully monitored manner normally associated with a pump test. Promoting
such undue restriction on construction operations is not the intent of this discussion. Simple records
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of pumping rates and schedules, water levels in excavations and existing monitoring wells or
piezometers, and drawings showing the locations of wellpoints, etc. could be easily maintained by
either the construction contractor or field inspectors. This information would allow designers to
determine the aquifer response to pumping and make simple comparisons to the response which would
be predicted using aquifer properties assumed for design.
Maintaining good construction records is the responsibility of designers, field inspectors, and
construction contractors. Designers must include provisions in construction specifications to require
contractors to provide adequate documentation of conditions encountered and the as-built
configuration of wells and trenches. Designers must also communicate effectively with the field
inspectors so they know what data they should be collecting, what portions of the construction
operation may require special documentation, and why this information is important. Finally, this
data must get back to the designers so that faulty design assumptions can be identified in a timely
manner. If changes in the design are required as a result of these assumptions, they can be made
before construction is completed and the contractor has demobilized. All of these procedures can be
implemented at minimal cost to the project.
Performance Testing
The principle design assumptions for most groundwater remediations are the production rate and
aquifer response. When the extraction well or collection trench is installed, the production rate using
the specified pump is easy to measure and compare to the assumed value. After measurement of a
static water level, the production rate should be measured along with the pumping water level in the
well or trench. The pumping rate and pumping water level should be recorded at a specific time after
pumping began. The ratio of the pumping rate to the drawdown, known as the specific capacity,
measured just after construction and development serves as a benchmark against which long term
performance is measured. If degradation of the well or trench occurs because of scaling or fouling,
the specific capacity will decrease. Future maintenance of the system can be based on the subsequent
specific capacity values dropping to a predetermined percentage of the original specific capacity.
The water levels measured in the pumping extraction wells or trenches are often significantly
different from the levels predicted based on modeling or analytical equations. This can be due to
unexpected aquifer conditions, but can also be a function of the head loss experienced by the flow
into the well. This loss is quantified by the well efficiency which is defined as the drawdown in the
formation outside the borehole divided by the drawdown measured in the well. Well efficiency can
be measured during initial testing of the well by measuring the water level in the well and in a
piezometer (small diameter well used for water level measurements) placed just outside of the
extraction well borehole. Piezometers do not cost a great deal and they do not need to fully penetrate
the aquifer. A piezometer will yield a more accurate measurement of the aquifer response than the
extraction well. A significant difference in the drawdown may indicate that the extraction well
borehole was damaged during drilling, or the well screen or sand pack was improperly chosen for the
flowrate. These problems can then be addressed directly by rehabilitation, redevelopment, or
replacement of the well, rather than concluding that the aquifer is incapable of supporting the design
yield.
Even with data available from a pump test performed during the remedial investigation or pre-design
activities, the design of extraction or collection systems cannot fully account for the natural
heterogeneity of the aquifer. Once the extraction well or trench is installed, the opportunity exists
for another test of aquifer characteristics. A short term capacity test conducted separately on each
extraction well or trench as part of construction can yield valuable additional data. This data can be
used to refine the design groundwater model, perhaps even while the drilling contractor is in the field.
The need for additional wells/trenches or changed well/trench placement can be added directly. The
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location-specific data can also be incorporated into a site model to be used for optimizing long term
operation and maintenance of the system. Drawdown can be observed in existing monitoring wells
or in monitoring wells installed as part of construction. Locations of observation wells would be
chosen as for any pump test. One drawback to consider is the potential need for containment of the
contaminated water until the treatment plant is functional.
Finally, the careful documentation of the development of an extraction well, including sand
production, turbidity, and volume extracted, can provide data which can assist in evaluating later
problems. Sand production records during development can be important in diagnosing pump wear
problems during operation. Development records can be evaluated to better design the screen size
and gravel pack on later wells; slow development suggests that the gravel pack may be too coarse for
the screened interval or that a certain zone should not be included in the screened interval. The
amounts of water produced during development can also be used as a guide in planning the initial
pumping rates during the capacity tests.
Measurement of Initial Site Conditions;
The measurement of actual groundwater conditions in extraction wells/trenches prior to system start-
up can identify significant differences in contamination concentrations, natural ions, and water levels
from those projected in design. These differences can affect how the system will be operated and
even how the treatment plant would be constructed.
Most significant of the site conditions is often the contaminant concentration. Significant variation
from concentrations assumed in design can cause less-than-efficient operation of the treatment plant.
The extraction wells are typically constructed to maximize yield, normally screening as much of the
aquifer as possible, often much more than the screened length of the monitoring wells. Collection
trenches also collect from more of the aquifer than a narrowly screened vertical monitoring well.
These conditions often yield more "average" aquifer conditions, perhaps mixing vertically stratified
or horizontally varying water quality. Actually testing the contaminant levels in the wells under
capacity test conditions (after development) can improve the quality of data available for final
treatment design. This assumes that the treatment plant is not completed prior to well/trench
completion. Again, if no treatment facility is in place, storage of the pumped water must be available
or other provisions for disposal must be made.
In addition to the contaminants of interest, the natural cation and anion concentrations should also
be measured to verify the levels assumed in the design for scaling and precipitation prevention
measures. Depending on the site conditions observed in the RI and any pre-design and the type of
treatment, this could have significant impact on the operation of the plant and any disposal system,
including injection wells.
Finally, in areas where seasonal water level fluctuations or outside aquifer stresses may affect the site,
the measurement of variations in the water levels in the trenches or wells for a period prior to system
start-up may be appropriate. This would be most helpful if the wells/trenches were installed as early
as possible in the construction sequence. This information may assist identifying unexpected
decreases or increases in well/trenches yield due to changing water levels. It may also assist in
identifying variations in contaminant flow direction which may require a different extraction system
configuration. This should not be a substitute for good pre-design information on water levels and
flow directions, but would quantify the impact on extraction wells themselves or refine the
understanding of the effects using the new data.
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Verification of Design Assumptions at the Case History Sites
As typical examples of the design/construction assumption verification process, the results of the
initiation of construction at the Millcreek and the Southwestern U.S. Superfund sites are discussed.
These are not intended to be examples of "how to" or "how not to" but a good review of what is
typically encountered and what went right and how things could have been better.
Millcreek Site
Construction at the Millcreek site was initiated in the spring of 1989. Installation of the groundwater
collection trenches was a separate contract and was the first activity to be performed. This was to be
immediately followed by construction of the water treatment plant under a second contract. Grading
and capping of the site would be conducted under a third contract initiated sometime during
construction of the treatment plant.
The collection trenches were installed using a trenching machine which excavated the trench and
placed the perforated drain pipe and granular backfill in a continuous operation. Trench 4 was the
first to be installed. Soon after the initiation of the trenching operation, it became apparent that it
would be necessary to dewater the soils in the vicinity of the trench alignment prior to excavation of
the trench. The trenching machine was not capable of excavating through the saturated fine-grained
soils encountered without becoming jammed and pulling the drain pipe apart in the trench. A line
of wellpoints was installed parallel to the trench alignment and pumped to draw the groundwater level
down close to the bottom of the trench. The trenching machine then installed the trench in the
dewatered soils with much less difficulty. However, concerns were raised about the quantity of water
produced by the dewatering operation in relation to the anticipated flow rate for the trench. The
contractor reported that pumping rates as high as 150-200 gpm were required to maintain the
groundwater level near the bottom of the trench. Computer modeling during design had predicted
equilibrium flows from Trench 4 of approximately 12 gpm. Trench 5 was installed next using the
same wellpoint dewatering methods. Once again, high dewatering flows were experienced. This
pattern continued as the remaining trenches were installed, although the flow rates were not as high
as those experienced at Trench 4. This raised the concern that the design treatment plant capacity
may be too low to accept the flow rates which might be required to achieve the design groundwater
elevations in the trenches during operation. This could result in incomplete capture of the plume.
The construction contractor had begun taking daily water level readings from monitoring wells during
installation of the trenches to assess the effects of the dewatering operation. Midway through
construction, a flow meter was installed on the dewatering pump and some notations of flow rates
were kept. These records were not required by the specifications but the contractor shared the
information with the Corps. However, a thorough examination of the data revealed that the amount
of detail given was not sufficient for the purpose of using it to determine the validity of design
predicted flow rates. While the water level data was fairly detailed, the pumping records consisted
of the contractor's personal estimates of the pumping rates and some flow meter readings. However,
examination of the flow meter revealed that it was installed so that the pipe was only partially flooded
and that continuously fluctuating water levels in the pipe made the meter readings unreliable. There
was also no record of when the pumps were turned on and off. This made it impossible to relate the
aquifer response seen in the water level data to the pumping from the dewatering operation.
It was decided to run performance tests on trenches 4 and 5 to determine if the aquifer properties
assumed for design were valid. Prior to testing, a line of temporary piezometers was installed
perpendicular to the trench alignment for use as observation wells during the test. An electric
submersible pump was temporarily installed in the trench sump. Each trench was pumped for
approximately 90 hours. Pumping was started at a high rate to draw the water level in the trench
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sump down to the design operating elevation. The pumping rate was then periodically decreased to
maintain the water level in the sump at this level. Water levels in the trench sump, the observation
well, and several monitoring wells were periodically measured and recorded during and after
pumping. A piezometer had been installed in the granular backfill of each trench during construction
and this piezometer was also monitored during each test. The data from the tests was used to
recalculate the aquifer hydraulic conductivity for comparison to the values assumed for design. The
non-steady state flow rates produced during the tests were also compared to the steady state flow rates
predicted by modeling during design.
Trench 4 produced substantially more flow than predicted by modeling during design indicating that
it may intercept a more permeable zone not intercepted by nearby wells and therefore not
characterized by the aquifer testing performed during site investigations. Water levels in the
piezometer in the trench backfill were also substantially higher than the water level in the trench
sump. This apparent hydraulic gradient along the length of the trench may be due to a separation or
blockage of the drain pipe, interception of a large recharge source by the trench at some point
between the sump and the piezometer, or the piezometer may be located outside the trench backfill.
The presence of this gradient violates the design assumption of a uniform groundwater elevation along
the entire length of the trench.
The results of the performance testing of Trench 5 closely verified the design flow rate and the
aquifer hydraulic conductivity. However, whereas the groundwater model had predicted that it would
take several months to reach a steady state flow rate in the trench, the performance test indicates that
this flow rate will be reached much sooner than anticipated.
Based on the rather mixed results from the performance tests performed on Trenches 4 and 5,
performance tests are planned for the remaining three trenches. This will allow the actual steady state
flow rate to the treatment plant to be more accurately estimated and potential impacts to the plant
design determined. The data from each test will be used to recalculate the hydraulic conductivity of
the aquifer at that location for comparison to design values. If these values do not compare well to
design values, the groundwater model will be re-calibrated using the new values and any impacts on
plume capture evaluated. The operational water levels in some of the trenches may be varied to
minimize the system flow while still achieving plume capture. In conjunction with the trench
performance tests, groundwater samples will be taken from the trench sumps during pumping to
verify the predicted contaminant loading to the treatment plant. A dye tracer test will also be
conducted on Trench 4 to verify the integrity of the drain pipe.
In retrospect, the project would have benefitted had performance testing of the completed collection
trenches been included in the construction specifications. This would have resulted in more timely
acquisition of the data and allowed any changes in the treatment plant design to be implemented with
minimal impact to the plant construction. It also may have been more cost-effective to have the
construction contractor perform the tests prior to demobilizing from the site, thus reducing setup costs
for the tests.
Superfund Site, Southwestern U.S.
Construction was initiated at this site in the spring of 1989. The first activity undertaken was
construction of the seven proposed extraction wells. As mentioned above, the phase one well locations
addressed the downgradient portion of the plume. The extraction wells locations were chosen without
the benefit of pre-design borings at the proposed well sites.
Several of the large diameter wells had been installed when it became apparent that the aquifer
conditions were not as anticipated. Well yields were much lower than expected. Boring logs indicated
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less sand and gravels than expected; one well failed to encounter productive sand and gravels until
the well was advanced into the lower aquifer. When the impact of this became clear, the construction
was halted and EPA was petitioned for an extension in schedule to accommodate re-design. Though
this is an example of poor site characterization prior to final design, it is also useful to note the well
logs and production records generated in construction were used in the re-design phase to refine the
site conceptualization.
A second round of well installation was begun in the summer of 1989. Well locations were shifted
to the west approximately 900 feet as shown on Figure 4. Pilot borings were drilled at the five new
locations prior to well construction and were completed as piezometers. The pilot borings were logged
by geologists from the design firm to allow for screen design and to confirm the assumed aquifer
stratigraphy.
When it became clear that the aquifer would be productive at the new locations, large diameter
extraction wells were installed approximately 50 feet from the pilot borings. These wells were
developed and test pumped. Water levels were measured in the pilot boring piezometers during the
tests to obtain aquifer parameters. The aquifer parameters determined from the tests will be available
for incorporation into models used for the next phase of design, as well as for analyzing impacts of
any future system operating change. During the well tests, water levels were also measured in the
pumping well. The water levels and pump rates can be used as the benchmark specific capacity for
future comparison to determine degradation of capacity.
The production rates were still somewhat less than the 100 gpm per well anticipated in design. The
impact of this on the operation of the treatment plant was assessed. The designers concluded that the
air stripper could still function to meet regulatory requirements. The production rates achieved were
still believed to be capable of establishing a suitable capture zone and this was subsequently proven
in system start-up.
Though the pilot boring piezometers were not located immediately adjacent to an extraction well and
could not be used to assess well efficiency, they do better represent the actual aquifer response near
the extraction wells than the pumping level in the extraction wells themselves. Without the well
efficiency information it is not completely clear if the extraction well capacities are significantly
hampered by formation damage from drilling or poor well design, though it seems unlikely that the
wells are highly inefficient.
The seven injection wells were not tested upon completion as injection wells, though a significant
portion of their screened length was above the static water level in unsaturated sand and gravel zones.
Pumping tests were conducted and yielded some information in a manner similar to the extraction
wells; however, after system start-up it became apparent that several injection wells could not accept
adequate water. An additional injection well had to be drilled to maintain adequate capacity. In
hindsight, proper testing by injection of water prior to start-up may have been useful. In addition,
poor injection well efficiency may be partially to blame for the low capacity, but there was no
provision for evaluating injection well efficiency.
Based on observed ion concentrations in monitoring wells, the design incorporated the addition of
sulfuric acid prior to air stripping to control pH and to prevent scaling. Actual extraction/injection
well-specific cation/anion concentrations were not obtained after well construction. After system
start-up, some injection wells began to display significant scaling problems. This problem could have
possibly been addressed during the well installation and the treatment plant phase of construction if
the appropriate analytical data had been gathered. The pH control system possibly could have then
been suitably modified prior to plant completion.
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The design allows for individual extraction wells to be sampled. With one exception, the TCE
concentration appear to be in reasonable agreement with the values projected from monitoring wells.
The well in the most downgradient position, initially yielded water with nearly non-detectable levels
of TCE. Unfortunately, this well also produced the largest yield. The production from this well was
not significantly reduced for much of the operation to date and now does produce water with low
levels of TCE. The TCE plume after almost a year of system operation is shown on Figure 4.
Overall, the first phase of the remedial action is apparently performing satisfactorily. The design of
the second phase of the remediation, for the heart of the plume, is about to begin and the information
generated by the first phase will greatly assist in the effective design of the second phase. This case
study illustrates several lessons learned, most of which should be applied to the upcoming second
phase of construction:
1) Scheduling of construction should allow the well production to be determined before
piping or treatment plant modification is precluded.
2) As was apparent in the first phase, a pilot boring program provides good information
for final well placement and screen design before well construction.
3) The practice of performing pump tests on the wells after installation coupled with
water level measurements in nearby pilot boring piezometers provided an excellent
opportunity to refine the site model. Similar data from the second phase will allow
even better modeling for optimizing system operation.
4) The use of injection wells for treated water disposal will be re-evaluated for the
second phase. The injection testing of the recharge system may be preferable to
simple pumping tests. Nearby piezometers for measuring well efficiency should be
considered to help diagnose any problems.
5) The second phase of construction should continue to allow for obtaining specific well
concentrations of ions and TCE. This will be particularly important since the average
TCE concentrations should be about five times higher than those encountered in the
first phase. The treatment plant will be modified to include offgas treatment and the
TCE mass loading rates will be important assumptions to verify in construction.
CONCLUSIONS
This paper urges designers to include adequate requirements for data gathering during construction.
There is a need to include the proper provisions for this in the plans and specifications as well as in
the instructions to the field. In addition, the construction schedule should consider, to the extent
possible, the ability to incorporate information from initial well/trench construction in the final
design of other site activities.
Construction specs should include provisions for 1) accurate logging of wells, trenches, and borings;
2) accurate as-built drawings of wells and trenches; 3) measurement of individual well capacities in
a way which allows for evaluation of aquifer characteristics and provides an initial specific capacity;
4) documentation of well development and dewatering operations; 5) measurement of well efficiency;
6) sampling of individual extraction wells or trenches for the contaminants of concern if applicable,
natural cations and anions; and 7) measurement of variations in static water levels in newly
constructed wells or trenches, if likely to be subject to such fluctuations.
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The need for and means to obtain all of this information should be explained clearly to the field
inspection team. This requires thoughtful preparation of the instructions to the field. Participation
of designers with the field inspectors in the initial oversight of certain activities may be particularly
helpful.
Finally, if possible, the construction sequence should be structured to allow the full benefit of
information gained during the construction. This may be achieved by: 1) the phasing of construction;
2) the drilling of pilot holes or proposed monitoring wells first, 3) installation and sampling of at least
some of the wells or trenches prior to initiation of treatment plant construction. Though under many
circumstances this may not be feasible, consideration should be given to this possibility in light of the
degree of uncertainty inherent in the various design assumptions.
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00
GROUNDWATER TRENCH #3
GROUNDWATER TRENCH #5 K
O
GROUNDWATER TRENCH #2
GROUNDWATER TRENCH #4
FIGURE 1
MILLCREEK SUPERFUND SITE
SITE PLAN
-------
Mich
00
CO
FIGURE 2
MILLCREEK SUPERFUND SITE
DCE CONCENTRATIONS IN GROUNDWATER
SITE BOUNDARY
\
Concentrations in ug/1
600'
-------
0 500 1000 1500 2000
FEET
5 LEGEND:
O Rl MONITORING WELL
PLUME CONTOURS FOR TCE (ug/l) JUNE 1987
SUPERFUND SITE
SOUTHWESTERN U.S.
FIGURE 3
Rl PHASE WELL LOCATIONS AND TCE PLUME
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i AIRPORT
APPROXIMATE| PLUME BOUNDARY
(1 ug/l TCE) OCT-NOV 1990
500 1000 1500 2000
FEET
LEGEND:
• Rl MONITORING WELL
• NEW MONITORING WELL
13 ABANDONED EXT. WELL LOCATION
• REVISED EXT. WELL LOCATION
A INJECTION WELL
FIGURE 4
SUPERFUND SITE
SOUTHWESTERN U.S.
RA PHASE I WELL LOCATIONS
621
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HYDROLOGIC RISK ASPECTS
OF HAZARDOUS WASTE SITE REMEDIATIONS
William Doan, Thomas Scott, and Robert Buchholz*
(Author(s)' Address at end of paper)
INTRODUCTION
The identification of hydrologic parameters is an im-
portant aspect of hazardous waste sites that is frequently
overlooked in Remedial Investigations/Feasibility Studies
(RI/FS) and Final Remediation Design.
Many hazardous waste sites are located in flood plains
near streams and rivers. The manufacturing/industrial
plants that generated the hazardous waste were originally
located near streams and rivers because there was a steady
water supply and/or convenient discharge point for waste by-
products. Unfortunately, because these sites are located in
floodplains, they are also susceptible to flooding. If the
site is flooded, contaminants may be transported downstream
from the site and potentially impact the environment and
communities downstream. This is especially critical if the
site is flooded during a cleanup where the surface of the
site is disturbed, exposing previously buried contaminants.
Another problem encountered in many cleanups is the im-
pacts the final site design may have on the surrounding area
from a hydrologic standpoint. The impacts a final design
may have on the surrounding watershed must be identified,
especially in urban areas. Changing the site characteristics
can increase runoff to the surrounding area and induce
flooding. If drainage channels are not designed properly,
the result can be a long term maintenance problem. Many
problems encountered at completed cleanup sites could have
been avoided if a hydrologic/hydraulic analysis had been
completed during the RI/FS phase. This is a small up front
cost that could avoid long term maintenance headaches and
costly redesign. It could also eliminate or reduce poten-
tial litigation from local entities should a cleanup design
result in transport of contaminants downstream.
This paper deals with various ways traditional hydro-
logic engineering methods may be used to provide both a bet-
ter overall understanding of the site and a better engineer-
ing solution to cleaning up the site.
*Hydraulic Engineers, Hydrologic Engineering Branch, Omaha
District, U.S. Army Corps of Engineers
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FEDERAL REGULATIONS
Several Federal regulations exist which require the
characterization of flooding potential at hazardous waste
sites. The primary purpose of the regulations are to mini-
mize adverse effects to man and the environment. The intent
of the regulations is to insure that one of the primary
goals of remediation of hazardous waste sites is to limit
the migration of hazardous waste below a specified risk lev-
el. Appendix 1 describes pertinent regulations in further
detail.
REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES
EPA's Handbook "Guidance for Conducting Remedial Inves-
tigations and Feasibilities Studies Under CERCLA" lists the
types of surface water information required to provide an
adequate site characterization. The list of surface water
information required includes:
Stream flows
Stream widths
Stream depths
Channel elevations
Overland flow
Soil erosion rates
Sediment transport
Surface water impoundment dimensions
Flooding tendencies
Stream volumes
Transport times
Dilution potential
Potential spread of contamination
Channel flow patterns
Flow restricting structures
With most RI/FS reports few, if any, of the parameters
listed above are identified in detail. When the parameters
are defined, they are usually defined for normal flow condi-
tions only. Normal flow conditions are for the most part,
innocuous in terms of contaminant transport potential. High
flows are much more critical because they can exceed the ca-
pacity of the main channel and flow into overbank areas. The
flow depths and velocities in the overbank may be high,
thereby increasing the erosion potential of the site and
consequently, the contamination potential.
Realistically, flooding depths, velocities, and areal
extent cannot be physically measured during a typical RI/FS
623
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site visit. With a minimum amount of effort, though, the
critical surface water parameters can be determined through
routine methods involving statistical analysis and mathemat-
ical modelling.
Many established techniques and methodologies used in the
analyses of traditional water resources projects can be used
directly in analyzing and designing cleanups of hazardous
waste sites. While there are exceptions to the rule, most
RI/FSs do not use these methodologies in the RI/FS and de-
sign processes. By using standard methods of hydrologic en-
gineering, the characterization of certain hazardous waste
sites and the design of remediation efforts would be greatly
enhanced and the end product would be a better engineering
solution to the problem.
HYDROLOGICAL INVESTIGATIONS FOR RI/FS
Listed below are several steps in a typical RI/FS process,
and methods of traditional hydrologic analysis that would
improve the overall analysis.
I. Physical Characteristics of the Site -
The site physical characteristics are intended to de-
fine potential transport pathways and receptor populations
and to provide sufficient engineering data for development
and screening of remedial action alternatives. In terms of
surface water hydrology, EPA's Handbook "Guidance for Con-
ducting Remedial Investigations and Feasibility Studies Un-
der CERCLA" states that the transport mechanism is primarily
controlled by flow. The mechanism would probably not be
chronic or a continuous process over time. This transporta-
tion mechanism, though, would most likely be episodic in na-
ture and occur at periods of high flows when the flow veloc-
ities are large enough to cause significant erosion
problems.
Flood Flows- Flood flow frequency analysis is based on the
observation that the peak annual flows in creeks and rivers
can vary greatly from year to year. There are established
hydrologic methods for estimating flood events and are sum-
marized below along with an example.
Statistical Methods- If the site is next to a major riv-
er or creek, there is a possibility that a stream gage with
a long term period of record may be located nearby. The
United States Geological Service maintains stream gages
throughout the U.S. In 1981, the U.S. Water Resource
Council, comprised of members of several Federal Agencies,"
such as U.S. Army Corps of Engineers, EPA, USGS, etc. devel-
624
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oped consistent techniques for flood flow frequency analy-
sis. These techniques are published in Bulletin 17B
"Guidelines for Determining Flood Flow Frequency". The
guidelines were established for all Federal water and relat-
ed land projects.
Bulletin 17B, essentially, assigns a probability dis-
tribution (log-Pearson Type III) to the series of annual
peak flows for a given stream gage. The log-Pearson distri-
bution requires three statistical parameters to define the
flood flow probability distribution; the mean of the annual
peak flows, the standard deviation of the annual flows, and
the skew coefficient that displays the frequency symmetry.
Bulletin 17B also lists various techniques to refine the
frequency analysis. These techniques include; expected
probability corrections to correct for natural bias in the
streamflow data, methodology for weighting the station skew
with skews of nearby gaged stream locations, adjustment for
historical flows, expected probability adjustments, estab-
lishing confidence limits, etc. The end engineering product
of the analysis will be an estimate of the flood flow fre-
quency relationship of the stream. An example use of sta-
tistical methods in hydrologic engineering is demonstrated
as follows for the physical characterization of a 14 acre
hazardous waste site in Pennsylvania.
The site in this example is immediately adjacent to a riv-
er that has a drainage area of 255 square miles and is lo-
cated a few hundred feet downstream of a USGS gaging sta-
tion. A sequential plot of the annual peak flows which
demonstrates the variance in flows is shown on Figure 1. A
log-Pearson flood flow frequency analysis of the site was
performed according to Bulletin 17B guidelines and the re-
sulting discharge-frequency curve is shown in Figure 2 in
terms of percent chance exceedence. The 20 percent chance
exceedence means that in any given year, there is a 20 per-
cent chance that the annual peak discharge will be 19,000
cfs or larger. Another way of stating this would be a flow
of 19,000 cfs or larger would occur once every five years,
or, on the average, the five year frequency flood would be
19,000 cfs. A river stage-discharge rating curve at the
site developed from past flood events showed that a flow of
19,000 cfs would result in a flood elevation that would be-
gin to encroach on the active areas of the site.
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ANNUAL PEAK FLOWS
EXAMPLE HAZARDOUS WASTE SITE
DRAINAGE AREA OF 255 SQUARE MILES
194819501952195419561958196019621964196619681970197219741976197819801982
YEAR
FIGURE 1
ANNUAL PEAK FLOWS
rIL.C.orHE0.1.PB
HCAN -•«.••<••
•T . OCV . • . »4«C
AC mo i«*4« *•*•«
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FIGURE 2
FLOOD FLOW FREQUENCY CURVE
626
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Flood Stages - The determination of flood stages are
necessary to define the depth of flooding and the lateral
extent of the floodplain at and adjacent to the site. As a
minimum, the 100-year floodplain should be delineated in ac-
cordance with Federal Emergency Management Agency (FEMA)
guidelines. However, smaller events such as the 2-year
flood could also have negative impacts to the site. It is
important to evaluate the impacts of flooding before, dur-
ing, and after construction.
A preliminary investigation of the historical flooding
in the area should be conducted. This can be accomplished
by interviewing local government officials and residents of
the area and obtaining flood information from newspaper ac-
counts. If the site is located in an urban area or along a
well defined channel, there is a good possibility that a
flood insurance study has been completed. A brief explana-
tion of the National Flood Insurance Program (NFIP) follows:
The NFIP was established by the National
Flood Insurance Act of 1968 and further defined by
the Flood Disaster Protection Act of 1973. The
1968 Act provided for the availability of flood
insurance within communities that were, willing to
adopt floodplain management programs to mitigate
future flood losses. The act also required the
identification of all flood plain areas within the
United States and the establishment of flood-risk
zones within those areas. The results of these
studies are set forth in a final Flood Insurance
Study (FIS) report, which contains a written sec-
tion, profiles, figures, and tables. In addition,
an essential product of the study is the Flood In-
surance Rate Map (FIRM) and the Flood Boundary and
Floodway Map (FBFM), which is distributed to the
community, Federal and State agencies, and others.
The FIRM provides 100-year flood elevations and
the 100- and 500-year flood outlines. The FIRM
also depicts areas determined to be within the
regulatory floodway, 100- and 500-year flood out-
lines
It is important to determine if the waste site is within
the regulated floodway or within the 100-year floodplain. A
floodway is defined as the channel of a river or other wa-
tercourse and the adjacent land areas that must be reserved
in order to discharge the base flood without cumulatively
increasing the water surface elevation more than a desig-
nated height. In most cases, construction is not allowed
within a designated floodway without special permits or per-
mission. Any capping or raising of the natural ground sur-
face within the floodway may not be permitted. A depiction
of a channel floodplain and floodway as defined by FEMA is
627
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shown on Figure 3.
-100 YEAR FLOOD PLAIN-
MEA OF FLOOD PLAIN THAT COULD
H USED FOR DEVELOPMENT IV
RAISING GROUND
FLOOD f LCVATKW
•EFORE ENCROACHMENT
ON FLOOD PLAIN
LINE A • • tS THE FLOOD ELEVATION BEFORE ENCROACHMENT
LINE C-0 15THE FLOOD ELEVATION AFTER ENCROACHMENT
'SURCHARGE NOT TO EXCEED 1.0 FOOT (FtMA REQUIREMENT) OR LESSER AMOUNT IF SPECIFIED BY STATE.
FIGURE 3*
FLOODPLAIN AND FLOODWAY DEPICTION
*From FEMA's "Guidelines and Specifications for Study Con-
tractors"
Once the preliminary investigation is completed, it may
be necessary to develop a hydraulic model such as the HEC-2
Water Surface Profile model to determine the flood stages in
the area. Variables needed to configure the model include
roughness coefficients, cross section geometry, and a range
of steady state discharges corresponding to various frequen-
cies of occurrence. A hydraulic model of the stream can
provide information on the depths of flooding for various
discharges, velocities in both the channel and overbanks,
and the extent of flooding. The hydraulic model can also be
used to evaluate changed site conditions. An example would
be a landfill located within the floodplain but outside of
the floodway. The final design may be to cap the landfill
with a six foot layer of soil. The existing topography of
the site would be changed potentially raising flood stages
because of the reduced conveyance capacity. Velocities
could also be increased. This could impact on the design of
the cap since the velocities may cause scouring of the cap
material and floodwaters could encroach on the new cap.
Modeling of the changed site conditions with a model like
HEC-2 would aid in the identification of these impacts and
whether they warrant further study.
628
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II. Contaminant Fate and Transport -
Contaminant fate and transport can frequently be esti-
mated on the basis of the site's physical characteristics.
In cases where surface water is the transport mechanism,
there are a broad range of hydrologic modelling methods that
can be used to define contaminant fate and transport.
An important aspect of surface water contaminant trans-
port is that in many instances it is not a continuous pro-
cess over time, but occurs at irregular periods during in-
frequent hydrologic events. An example of this would be a
temporary collection lagoon that breaches during a large
flood event. Another example would be a several acre haz-
ardous waste site next to a river that receives overbank
flooding on a periodic basis. A thorough understanding of
the basic nature of surface water hydrology, hydraulics, and
associated risks is essential before any attempt is made to
analyze contaminant fate and transport via surface water
pathways.
Contaminants have three potential modes of transport in
surface water flow: sorption in the sediment that flows in
the surface water, transport as suspended solids, and trans-
port as a solute (dissolved). The transport of dissolved
contaminants can be directly tracked by characterizing the
surface water flow nature of the particular site. Sediment
and suspended solids transport can be analyzed by tradition-
al sediment analyses techniques as various sediment trans-
port equations, 1-dimensional, or 2-dimensional computer
simulation models.
For sites where the contamination can be considered
dissolved, the sites can be analyzed by the following estab-
lished hydrologic modelling techniques:
Rainfall/Runoff Simulation- Rainfall/runoff models are im-
portant in analyzing surface runoff because rainfall records
are usually more readily available than direct surface water
records. A computer simulation model which can transform
the rainfall process into runoff process is an important
tool in analyzing a watershed. One method of rainfall run-
off model is the type that directly uses the equations of
physics and basin geometry to simulate the actual physical
watershed processes such as soil infiltration, overland
flow, channel flow, etc. An example of a 5 square mile
drainage basin is shown below:
The Hydrologic Engineering Center's HEC-1 Flood Hydro-
graph Package was used to develop a rainfall/runoff model
629
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for the drainage basin. The basin contained several hazard-
ous waste sites throughout the basin. The basin also has
several dams and reservoirs located throughout the basin.
The problem exists of trying to track the contaminants as
they pass through the watershed and eventually accumulate in
the reservoirs. A physically based model was originally set
up in HEC-1 to determine existing conditions design flows,
but could also be adapted to model past flood events as a
means to determine contaminant fate and transport. The
basin was broken down into 122 subbasins as shown in Figure
4. A historical storm occurring May 5 - May 6, 1973 was
used to simulate the actual rainfall/runoff process of the
site for a 24-hour period. The rainfall distribution of the
24-hour period was derived from a nearby raingage station.
The 2.5 inch rainfall was applied to the model to produce
the inflow hydrograph shown on Figure 5 for a small reser-
voir located in subbasin 431. The model simulated the peak
inflow into the reservoir, the corresponding pool raise of
the reservoir, and outflow from the reservoir. Methods em-
ploying this type of analysis help duplicate and quantify
contaminant fate and transport mechanism for surface water
contamination where no direct streamflow records were kept.
FIGURE 4
EXAMPLE LOCATION BASIN MAP
630
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p.
EXAMPLE RAINFALL/RUNOFF MODEL
STORM OF MAY 5-6,1973
POOL ELEVATION
INFLOW (CFS)
5832
5830
5828
5826
5824
d
2
5822
5820
12 16
TIME IN HOURS
24
FIGURE 5
INFLOW HYDROGRAPH AMD POOL ELEVATION
Erosion Potential- A site investigation should also be con-
ducted upstream and downstream of the site to determine the
potential for erosion problems resulting in contaminant
transport. Velocities for surface water flow are required
to determine the erosion potential in the area. Table 1
shows the suggested maximum permissible mean channel veloci-
ties for different types of channel material.
TABLE 1
SUGGESTED MAXIMUM PERMISSIBLE MEAN
CHANNEL VELOCITIES*
MEAN CHANNEL
CHANNEL MATERIAL VELOCITY, FPS
FINE SAND
COARSE SAND
FINE GRAVEL
EARTH
SANDY SILT
SILT CLAY
CLAY
GRASS LINED EARTH (SLOPES LESS THAN 5%)
BERMUDA GRASS - SANDY SILT
- SILT CLAY
2.0
4.0
6.0
2.0
3.5
6.0
6.0
8.0
631
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POOR ROCK (USUALLY SEDIMENTARY) 10.0
SOFT SANDSTONE 8.0
SOFT SHALE 3.5
GOOD ROCK (USUALLY IGNEOUS OR HARD
METAMORPHIC) 20.0
*From EM 1110-2-1601
III. Baseline Risk Assessment
Baseline risk assessment is intended to provide an
evaluation of the potential threat to human health and the
environment from a hazardous waste site without any type of
remediation. Hydrologic risk can be utilized to evaluate
the long-term potential for surface water contamination.
The hydrologic risk of having a flood event of a specified
magnitude during a specified time period can be estimated by
the following equation based on the binomial distribution
theorem:
R = 1 - (1-P)N
R = Total risk of flooding during specified period
P = Annual probability of a flood that exceeds
a specified magnitude, ie;
P=.01 — 100-year flood
P=.02 — 50-year flood
P=.10 — 10-year flood
etc... .
N = Number of years that flood events could occur
An example may be a surface water impoundment such as
a retention basin that had been built to collect and prevent
contaminated sediment from entering a stream. The basin may
have been built to hold the 50-year runoff from the upstream
basin. Flows in excess of the 50-year storm would overtop
the embankment and wash it away. The risk of having a
50-year storm is 2% for any given year. The risk increases
over time and is shown in Figure 6. For example, there is a
33% chance of a 50-year flood occurring during a 20 year pe-
riod. This type of analysis quantifies the risk of breach-
ing the retention basin and contaminating downstream areas
if there is no remediation efforts.
632
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HYDROLOGIC RISK OF BEING
EXCEEDED ONE OR MORE TIMES IN N YEARS
10
20
30
40 50 60 70
PERIOD OFT1ME IN YEARS
80
90
100
FIGURE 6
HYDROLOGIC RISK OF EXCEEDENCE
POTENTIAL HYDROLOGIC REMEDIATION DESIGN EFFORTS
Listed below are three different types of remediation ef-
forts and various hydrologic analyses that could enhance the
overall remediation.
I. Landfill Caps- The hydrologic areas of concern involving
landfill caps are preventing erosion of the caps, providing
adequate drainage away from the cap, and avoiding inducing
flooding downstream of the site. Each site is unique and
variables impacting the amount of runoff and erosion poten-
tial which need to be evaluated include the type of materi-
al, vegetative cover, the slope of the cap, the length of
the slope, the final layout of the cap design, and whether
the design will concentrate flows in any areas.
Typically, landfill sites are capped with either an im-
permeable clay cap or topsoil cap to prevent infiltration of
rainfall. By promoting fast runoff of surface water from
the cap, leaching of contaminants from the landfill through
rainfall seepage is reduced or eliminated. However, pro-
moting effective surface water drainage increases the peak
rate of runoff from the area and may result in flooding
633
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downstream of the site. A twenty-six acre hazardous waste
site in Pennsylvania is used to demonstrate the increased
runoff potential for an existing landfill area that is to be
capped. A HEC-1 rainfall/runoff model was developed for the
existing landfill and post-project capped landfill. As
shown in Figure 7, capping the landfill doubles the peak
runoff for the design storm, from 35 cfs to 80 cfs. The hy-
drographs also show how capping the area with impervious ma-
terial increase the total runoff volume, represented by the
area underneath the hydrographs. Also shown on Figure 7 is
how using a five acre detention basin immediately downstream
of the landfill cap can reduce the peak discharge back down
to the original 35 cfs.
EXAMPLE OF SURFACE WATER RUNOFF
RUNOFF FROM EXISTING LANDFILL VS
RUNOFF FROM CAPPED LANDFILL
CAPPED LANDFILL
W/DETENT1ON BASIN
90 120 150
TIME IN MINUTES
180
210
240
FIGURE 7
RUNOFF HYDROGRAPHS FROM LANDFILLS
The practice of proper drainage control in the design
and construction of landfill caps is critical in preventing
erosion and ultimately maintaining the long-term integrity
of the cap. Most cap designs with steep slopes greater than
5% will require some form of collection system on the cap to
drain the surface water. One system used is similar to a
terrace in which the terraces are spaced out along the slope
of the cap to intercept flow before it starts to concentrate
and erode the cap. The intercepted flows are then directed
to several central locations to be discharged down the slope
of the cap. Caps with slopes greater than 5% must be pro-
634
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tected because of the potential for erosion and gullying
from the high velocities experienced on these steep slopes.
One form of protection successfully used to drain water from
the terraces are gabions. Gabions are flexible wire baskets
filled with stone. Gabions will protect the cap from ero-
sion and have some flexibility if settlement occurs to the
cap. Other types of structures can also be used but the de-
signer should be aware of the possibility of settlement
causing cracking or deterioration of the fixed structure,
allowing the high velocity flows to undermine the structure.
At the bottom of the channel, energy dissipation must be
provided to prevent erosion and scour damaging the toe of
the cap.
Surface water runoff must also be conveyed away from
the site into an established waterway or channel. This pre-
vents the runoff from being confined and causing long term
maintenance problems due to ponding against the base of the
cap.
Problems may also arise from induce flooding when at-
tempting to convey the surface water runoff away from the
cap site. Almost every state and many local entities have
laws and regulations dealing with changing site conditions
to prevent upstream landowners from developing land in a way
that would induce flooding on downstream landowners. Typi-
cally, the provisions require the upstream landowners or de-
velopment may not increase the peak 10-year, 50-year, or
100-year flood flowrates off the site above the existing
condition flow rates. If there is an increase in flowrates,
detention basins, improving the downstream channel or other
measures would be required to reduce the flowrates to the
original existing conditions. Figure 7 in the example cited
at the beginning of this section illustrates this concept.
II. Excavation in Floodplains- Frequently, if surface water
is a pathway for contamination migration from hazardous
waste sites, it involves the spread of contaminants via lo-
calized flooding from an industrial plant typically located
several hundred feet from the receptor creek. As the local-
ized or interior flood flows towards the creek it would en-
counter flat slopes and natural berms along the creek bank
formed by deposition of sediment during floods. This forms
a natural trap for the contaminants to settle out in the
soils along the creek bank.
When the creek flows out of its banks during flood
events, the potential exists for washing away the contami-
nants and contaminated soils in the overbank areas to down-
stream receptors. It is very critical to determine how of-
ten the creek will overflow its banks, the velocity of flow
in the overbank areas, and the erosion potential of the
635
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overbank areas.
Typical remediation of sites like this involve excavat-
ing the soils in the overbank areas and either treating or
disposing of them off-site. Excavation of these areas with-
out providing some means of flood control from the creek is
potentially very dangerous because it could induce hazards
on downstream communities. By clearing and grubbing the
land before excavation, the erosion potential is greatly in-
creased because of the removal of erosion resistant vegeta-
tion and the reduced roughness resulting in higher veloci-
ties. The existing surface areas before excavation would
also probably be relatively clean and seasoned due to fre-
quent inundation by both interior flows and overbank flows
from the creek. Once excavation has begun, though, it ex-
poses the potentially more contaminated soil beneath the
surface that had not had a chance to be washed clean.
In terms of a remediation project's success or failure,
it is interesting to compare the site's carcinogenic risk
based on the site's cleanup level to the site's hydrologic
risk of failing. EPA policy requires that Superfund sites
be cleaned up to the level of excess risk of 1 per
1,000,000. In other words, an individual has a one in one
million chance of developing cancer as a result of site re-
lated exposure to a carcinogen over a 70-year lifetime. In
terms of hydrologic risk, though, the regulations state that
for any given year, the washout of contaminants due to
flooding can occur for floods greater than the 100-year
flood event, or in terms of probability, 1 in 100 - far
greater than the 1 in 1,000,000 chance of getting cancer.
For comparison purposes, based on binomial distribution, the
chance of flooding in excess of the 100-year flood during
the 70 year lifetime of the individual is 50 percent. This
analysis may be unfair, but the public will most likely per-
ceive the project as a failure if there is any release of
contaminants downstream anytime during the life of the proj-
ect.
The excavation of hazardous waste sites located within
the 100-year floodplain must be done with complete knowledge
of the hydrologic risks associated with it. Factors that
could impact on the success of this type of project include
flood warning times, flood depths, flood frequencies, ero-
sion potential on the site and the streambank adjacent to
the site. Flood warning times can be used to evaluate the
amount of time available to evacuate the site and cover or
protect the exposed material. This is especially critical
for small watersheds that have relatively short flood peak-
ing times which provide little or no warning time. Evalua-
tion of the erosion potential of not only the site but of
the adjacent streambank is important. The banks of many
streams can move hundreds of feet during a flood event if *
636
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the bank is not protected. Flood depths and frequencies are
important because they can be used to locate the staging
area and equipment out of the floodplain and stage the work
so that as little time as possible is spent in areas affect-
ed by events less than the 100-year event.
If the construction must occur within the floodplain,
it may be necessary to have a structural solution. Examples
are levees, diversions, bank stabilization, floodwalls (tem-
porary or permanent), detention ponds, and dams. A hydrau-
lic analysis should be conducted to select the most cost ef-
fective solution. The impacts of the structures on the
upstream and downstream floodplain must also be evaluated.
An example of where levees or floodwalls could be used is
when the site to be excavated is immediately adjacent to the
stream bank and is subject to flooding from a 10-year event.
The excavation is to be 5 feet deep in the floodplain adja-
cent to the channel. This situation should require a levee
or floodwall be built up to the 100-year level of protection
to prevent the site from being inundated from events as low
as the 10-year event. Using this same example, if the
streambank is unstable and it erodes into the site during
excavation, a serious problem would develop. Armoring of
the bank with riprap or other material in conjunction with
the levee may be desirable. An example of where a dam could
be used would be the case where it is desirable to contain
contaminated sediments and prevent their migration down-
stream. Depending on the size of the watershed, a small dam
could be built to hold back the sediments and prevent them
from being washed downstream.
III. Wetlands Restoration- Many environmental restoration
projects impact wetlands and some sort of wetlands restora-
tion is frequently required. Hazardous waste site remedi-
ations frequently involve excavation of soils in wetland ar-
eas and remediation designs often times cover up existing
wetlands. Established hydrologic techniques can be used to
analyze the existing wetlands and to develop mitigation
plans for replacement wetlands.
Wetland restoration must begin with a thorough under-
standing of the baseline existing hydrologic condition of
the wetland. For many wetland sites, this involves analyz-
ing how the existing wetland functions during cycles of ex-
treme drought and flooding conditions over a long term time
period. Typically, this can be demonstrated in what are
known as a surface area-duration curve and a depth-duration
curve as shown in Figure 8. Because there are rarely gaging
637
-------
stations in smaller wetlands, the duration curves must be
developed through hydrologic modelling.
600
500-
LLJ
g 400
z
LU
300
200
100-
EXAMPLE SURFACE AREA AND DEPTH DURATION
CURVES
DEPTH
10 20 30 40 50 60 70
PERCENT OF TIME EXCEEDED
80
90
3.0
-2.7
-2.4
-2.1
-1.8
-1.5
-0.9
-0.6
-0.3
0.0
100
FIGURE 8
SURFACE AREA-DURATION AND DEPTH-DURATION CURVES
The hydrologic modelling necessary to define baseline
hydrologic conditions involves determining the daily water
budget for the wetland. This involves accounting for the
surface water inflows, outflows, precipitation, evaporation,
and seepage on a daily basis. The surface area-duration
curve shown on Figure 8 for a typical midwestern wetlands
was derived by using the Streamflow Synthesis and Reservoir
Regulation (SSARR) computer program which was developed by
the North Pacific Division of the Corps of Engineers, to
calculate the daily flows into the wetland. The actual dai-
ly water budget was estimated using the Omaha District's
Wetlands Hydrologic Analysis Model (WHAM). These two models
were used to simulate the daily inflows, outflows, evapo-
transpiration, pool levels, surface areas, average depths,
and pond volumes over a twenty-one year period.
Once the baseline hydrologic conditions of the wetland
has been determined, any mitigation plans could be analyzed
with the same type of analysis over the same historic peri-
od. This would give an indication of how effective any mit-
igation plans would be in duplicating the existing wetland's
long term depth and surface area durations. If the curves
638
-------
do not match up very well, mitigation plans could be modi-
fied. This modification could involve changing the outlet
control of the wetland, regrading the wetland, etc. Figure
9 shows how the comparison could be easily summarized in av-
erage annual surface area for the different wetlands condi-
tions.
WETLANDS MITIGATION
ANNUAL WATER SURFACE AREA
525-
450-
1
§ 375-
z
| 300-
LU
9
£ 225-
oc
CO
£ 150-
1
75-
Q
/
/
/
/ --
/ :
/ '-
/
/ \
;
/I/
;
!
:
;
\
\
I
/111
-
T¥,
I
—
f
J I
[ \
n
E
i
1
; III
PI
fll
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i -
E
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i
J|
H
M-,
^
- ;
7®7
\
i
i
i
\
1
1
-^
/a/
CM POST PROJECT
^ PRE PROJECT
I
a | !
: : :
; I '•
-- -- -.
B? / B? 3?
\y/-/w/
&
1 i
i =
; E
I !
lilP
|7 PRE PROJECT
/ POST PROJECT
1950 1952 1954 1956 1958 1960 1962 1964 1966 1968 1970
YEARS
FIGURE 9
AVERAGE ANNUAL WATER SURFACE AREA
CONCLUSION
Recently, several completed cleanup sites have encoun-
tered problems associated with some form of hydrologic de-
sign deficiencies. These problems include excess water
ponding up against the base of a landfill cap, surface water
detention basins that were originally undersized and had to
be enlarged, improperly designed drainage channels on land-
fill caps, etc. There also exists the potential for prob-
lems with cleanup sites that are being constructed in flood-
plains. These problems involve potential erosion problems
that may transport contaminants downstream during flooding
events. These sites were designed without a full apprecia-
tion of the dynamic nature of river systems, and in some
cases, no hydrologic analysis at all. These problems can be
639
-------
avoided if they are identified early in the investigation
and design processes and can be solved with a minimum of de-
sign effort utilizing established techniques and methodolo-
gies.
APPENDIX 1 - PERTINENT FEDERAL REGULATIONS
40 CFR Part 6, Appendix A - Statement of Procedures on
Floodplain Management and Wetlands Protection - This regula-
tion essentially states that Federal agencies are required
to evaluate the potential effects of actions it may take in
a floodplain to avoid adversely impacting floodplains when-
ever possible. Specific requirements involve:
1. The Federal agency must determine whether or not the
proposed activity will take place in a floodplain.
2. The public should be informed when it is apparent
that some sort of Federal action is likely to impact a
floodplain.
3. If an action takes place in a floodplain, a flood-
plain assessment should be performed. This would in-
clude a description of the action, the effects on the
floodplain, and a description of the alternatives.
4. Public review of floodplain assessments.
5. If there are no alternatives to affecting the flood-
plains, actions should be taken to minimize potential
harm and act to restore and preserve the natural and
beneficial values of the floodplains.
6. Agency decision.
40 CFR Part 264.18 Location Standards for Owners and Opera-
tors of Hazardous Waste Treatment, Storage, and Disposal Fa-
cilities - This regulation states a TSD facility located in
a 100-year floodplain must be designed, operated, and main-
tained to prevent washout of any hazardous waste by a
100-year flood. Specific definitions include:
1. Facility- "All contiguous land, and structures, oth-
er appurtenances, and improvements on the land, used
for treating, storing, or disposing of hazardous
waste."
2. 100-Year Floodplain- "Any land area which is subject
to a one percent chance or greater chance of flooding
in any given year from any given source."
640
-------
3. Washout- "The movement of hazardous waste from the
active portion of the facility as a result of flood-
ing. "
4. 100-Year Flood- "A flood that has a one percent
chance of being equalled or exceeded in any given
year."
APPENDIX 2 — REFERENCES
1. EPA - "Guidance for Conducting Remedial Investigations
and Feasibility Studies Under CERCLA". Interim Final.
2. EPA - "Superfund Exposure Assessment Manual". April 1988.
3. Department of the Army. Corps of Engineers. "Hydrologic
Frequency Analysis". June 1985.
4. Department of the Army. TM 5-814-7 "Hazardous Waste Land
Disposal/Land Treatment Facilities". November 1984.
5. Interagency Advisory Committee on Water Data. "Guidance
for Determining Flood Flood Frequency". Bulletin #17B.
6. U.S. Army Corps of Engineers. Hydrologic Engineering Cen-
ter. "HEC-1 Flood Hydrograph Package. User's Manual". Sep-
tember 1990.
7. U.S. Army, Corps of Engineers. EM 1110-2-1601 "Hydraulic
Design of Flood Control Channels". July 1970.
8. Federal Emergency Management Agency. "Guidelines and
Specifications for Study Contractors" September 1985.
Authors and Address:
William Doan, Thomas Scott, and Robert Buchholz
U.S. Army Corps of Engineers, Omaha District
ATTN: CEMRO-ED-H
215 N. 17th Street
Omaha, NE 68102-4978
(402) 221-4583
641
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Design And Construction Of
The Groundwater Treatment
Plant At The Conservation
Chemical Company Site
Peter E. Harrod
ABB Environmental Services, Inc.
P.O. Box 7050
Portland, Maine 04112
(207) 775-5400
INTRODUCTION
The design-build concept is not new to engineering, but it is new as an approach to the remediation
of hazardous waste sites. The benefits of this approach are concentrated in better communications
(single point of control), shorter schedules and control of costs. While these benefits can apply to any
engineering project, the approach itself tends to conflict with the review procedures and schedules
most agencies are using for hazardous waste projects.
For clients and reviewing agencies who are not familiar with design-build, the concept of combining
engineering and construction under one roof is seen as a break down of the traditional checks and
balances of engineer/contractor relationships. The approach focuses on critical path scheduling,
preparing less detailed engineering drawings and specifications, shortens procurement times, and
moves some engineering into the construction phase. No benefits, however, can be gained from the
approach if the approval process does not move along the same fast track or without an understanding
that less detail in drawings does not mean less quality in the field. Mistrust must be overcome, that
quality in design and/or construction will not be less, but that a professional approach to design-build
can yield benefits to all involved.
Remediation of hazardous waste sites invariably involve multiple reviewing agencies. The time and
money that can be saved by the design-build concept can quickly be lost if those reviewing the
projects cannot provide quick turnaround of reviews, hold to schedules and make timely decisions.
One of the major time savings can be in an accelerated procurement schedule. Major equipment
items and/or long lead time items, can be purchased with performance specifications and direct
negotiations rather than developing complete bid documents. This time benefit is lost though if
portions of projects cannot be approved separately as design progresses and reviewers wait for an
entire design to be complete prior to giving any approvals. Additional savings can be gained in that
drawings do not have to be prepared to the detail a traditional bid set would have been because some
of the engineering can take place in the field in some instances more cost effectively than in the
office. This could mean preparing only one-line piping drawings rather than isometric drawings and
leaving the details of the pipe runs to be layed out and designed in the field. This savings can easily
be lost without timely approvals of design concepts and acceptance of less than normal detail in
engineering drawings. This is a change from the traditional method of reviewing full sets of detailed
drawings and specifications.
It is imperative that all the parties involved in the future remediation of hazardous waste sites
understand the design-build process and adjust their thinking and procedures to fully gain the
benefits it can provide to a project. "Time is of the essence" in many of the projects that both the
public and private sector want remediated. The design-build approach can provide this.
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The remediation of the Conservation Chemical Company site in Kansas City, Missouri is a good
example of how the design-build concept can work if all parties involved are committed to the
process and responsive to its needs. This project involved design and construction of a groundwater
treatment plant with seven separate reviewing parties, a tight Consent Decree schedule with penalties
for non-performance, and a lump sum contract. The project met all its technical, financial and
schedule milestones.
BACKGROUND
ABB Environmental Services, Inc. (ABB-ES) headquartered in Portland, Maine, designed, constructed
and started-up the Front Street Groundwater Treatment Plant (former Conservation Chemical
Company site) in Kansas City, Missouri for the Front Street Remedial Action Corporation (FSRAC).
The treatment plant operates 24 hours a day pumping groundwater at an average rate of 164 gallons
per minute (gpm) and a maximum rate of 300 gpm to the 5-step treatment train which removes
organic chemicals, such as TCE and PCE, as well as heavy metals such as cyanide and lead.
The job site was approximately rectangular with dimensions of 790 feet by 330 feet. The property
is on the riverside of the levee bordering the Missouri and Blue Rivers. The site is a relatively flat-
topped mound that slopes gently toward the Missouri River and lies approximately 10 to 15 feet above
the surrounding flood plain.
The site geology consists of Pleistocene and Recent (Holocene) deposits. These deposits strongly
influence the character of the soils and aquifers formed within them. Loess deposits, glacial till, and
residual soils overlie the bedrock immediately adjacent to the Missouri River and are widespread
north of the river. Bedrock, found at approximately 160 feet below the surface, is overlain by
Missouri River alluvial deposits.
For about 20 years, beginning in the early 1960's, the Conservation Chemical Company (CCC) in
Kansas City, Missouri processed chemicals at its plant situated on the flood plain near the confluence
of the Missouri and Blue Rivers. During this period of operation, the primary materials accepted by
CCC were spent acids, alkalies and other caustics, metals and metal sludges, liquid and solid cyanides,
organic solvents, and halogenated compounds. CCC also accepted spent oil, inorganic salts (liquids
and sludges), elemental phosphorus, pesticides, herbicides and small quantities of miscellaneous
organic compounds. The company employed a variety of waste handling practices, including cyanide
incineration, solvent incineration, pickle liquor neutralization, cyanide complexation, chromatic acid
reduction, ferric sulfate/ferric chloride recovery, and bulk liquid and solid disposal. The residuals
from the processes were generally disposed of on site in six detention basins. Drums, bulk liquids,
sludges and solids were buried on the site. It is estimated that 93,000 cubic yards of materials were
buried on the 6 acre site.
For approximately three years in the late 1970's, a portion of the sludge by-product in each basin was
mixed with fly ash and pickle liquor for stabilization and a thin layer of clayey material was placed
over a portion of the site.
Results obtained from site investigations indicated that materials were migrating from the site via
groundwater. There were 21 substances identified that were substantially in excess of applicable
criteria or standards for water quality. These included metals, cyanide, phenolic compounds and
volatile organic compounds. The concentrations of these materials in the groundwater decreased
substantially down gradient of the site as a result of dilution, dispersion, degradation, and absorption.
The geohydrologic investigation of the site showed that groundwater flows toward, and discharges
into the Missouri and the Blue Rivers.
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The greatest risk was determined to be the potential release of these materials into the groundwater
over time. Groundwater is used as drinking water within a two mile radius of the site. Secondary
risk was considered to be from contaminated soils which may be transported by precipitation runoff
into surface water bodies or the groundwater.
A number of remediation alternatives were studied. Most were quickly eliminated leaving three main
alternatives to pursue. They were slurry wall containment with interior pumping; on-site containment
by pumping and groundwater treatment; and excavation followed by soil treatment. The 1987 Record
Of Decision (ROD) chose a remedy that included the use of a permeable cap to allow water intrusion
to assist groundwater clean-up, a withdrawal well system to achieve an inward groundwater gradient,
a groundwater treatment system based on several unit operations and off-site groundwater
monitoring.
More than 200 contributors to the site had been previously identified as Potentially Responsible
Parties (PRPs). Settlement negotiations between the Original Generator Defendants and the U. S.
Government resulted in the signing of a Consent Decree for remediation of the site. Four companies
joined to form the Front Street Remedial Action Corporation. These companies were FMC Corp.,
AT&T Technologies Inc., IBM Corp. and ARMCO Inc. Total clean-up costs were estimated to be in
the order of $30 million in 1988 dollars. The design and construction of the treatment facility was
accomplished for approximately $4.7 million.
ABB Environmental Services, Inc. began work on the Front Street Project in December, 1988.
Following surface clean-up and installation of a permeable cap by other contractors, the final design
was prepared and submitted to the U.S. EPA for review on April 27, 1989, five months after the
contract was signed. Construction began in June of 1989 and substantial completion was obtained in
March, 1990, on time and under budget.
Since the plant's start-up in May 1990, the Front Street Groundwater Treatment Plant has met Federal
and State effluent discharge guidelines and performance expectations.
MANAGEMENT APPROACH
There were two major issues to be faced for this remedial design and construction project. The first,
and most difficult was managing the project through a multitude of reviews and reviewing parties
while still meeting the mandated contract deadlines. The second issue was the technical complexity
and construction limitations of the site.
The contract time periods for the project were tight considering the number of parties requiring
review and approval of work products. The contract stipulated that design of the groundwater
treatment plant be complete within 5 months, that construction be substantially complete within 15
months of contract signing and that the entire work be completed within 16 months of contract
signing. During the design phase, a treatability study was also required to be conducted to verify the
anticipated effectiveness of the various treatment unit processes.
The reviewing parties were many and varied. They included the following:
U.S. EPA Region VII
U.S. EPA's independent reviewing engineer
Four - PRP clients who had formed the Front Street Remedial Action Corporation
The PRP oversight engineer
Missouri DNR
U.S. Army Corps of Engineers
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• City of Kansas City, Missouri
The project required gaining approvals from all these parties, the contract and Consent Decree
stipulated liquidated damage penalties for delays beyond specified contract times for design and
construction, and it required design verification through treatability tests. All this was performed
for a lump sum design-build contract price.
A design basis was developed by FSRAC's oversight engineer prior to the solicitation of bids for the
Design-Build Contract. This document provided the general basis on which the remedial action was
to be designed with the exception of an Operation and Maintenance Program or plan which was to
be developed as part of the Design-Build Contract. The groundwater treatment facility consisted of
five treatment processes and their housing, installation of a groundwater collection system from the
withdrawal wells, installation of four paired piezometer instrumentation units, and utility services
required by the well systems. Equalization, metals hydroxide precipitation, biological treatment,
activated carbon, and metals removal by sulfide treatment were specified to be used to treat the
groundwater. The treatment plant was designed to operate 24 hours a day with one manned shift
operation 5 days per week.
To meet all the project deadlines and requirements, it was imperative that communications be
frequent and precise. ABB-ES accomplished this by three basic steps: (1) meetings were held with
all parties on a minimum of a monthly basis; (2) a manual of procedures was developed to provide a
framework for communication and decision making among the parties involved; and (3) a design
criteria document was created to serve as a continuously updated statement of design decisions. In
addition, project management had to be thorough and consistent through both the design and
construction phases of the project. It is particularly important in design-build projects that
information and decisions made during design are carried into the construction phase by continuity
and consistency in the management of the project.
The result of these initiatives which were rigorously followed throughout the design-build process,
was that all parties were cognizant of exactly what was being accomplished throughout the process.
Alternatives and treatability results were openly discussed, relative merits reviewed and decisions
made on a timely basis. The fact that all parties were frequently involved as the design process
progressed allowed for a short review time at the end of design. The final set of documents became
a culmination of decisions previously discussed and agreed upon with no surprises for anyone.
TREATABILITY
Concurrent with the design of the Groundwater Treatment Plant, treatability studies were required.
The purpose of the studies was to verify the anticipated effectiveness of the various treatment unit
processes, and the overall design targets for effluent quality. Design targets were based on a draft
NPDES permit.
A number of groundwater wells had been installed on and around the site and samples analyzed for
compounds and concentrations at those locations. Predictions then had to be made as to the
concentrations that would occur at various pumping rates at the two proposed extraction well
locations. Weighting factors were established through analytical methods for this purpose.
Groundwater samples for the treatability study were collected from nine wells. Composite samples
were then prepared to simulate the predicted composite expected at the withdrawal wells by using the
predetermined weighting factors. The composite samples were then used in a laboratory treatment
system to simulate, as close as possible, the full scale specified treatment system.
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In order to meet the schedule and purpose of treatability, the laboratory equipment used for the study
was built as close to scale as practical. Lancy International worked with ABB-ES as a subcontractor
on this portion of the project. The system was operated at a scale flow rate of 300 gpm with an actual
flow rate of 80 ml per minute. A process flow diagram for the treatability testing is shown in Figure
1. The process included the following chain: equalization tank with air mixing, pH adjustment, flash
mix tank, flocculation tank, clarifier, pH adjustment #2, bio-tower, gravity filter, carbon columns
and sulfide system. The pilot system was designed to simulate the performance of the treatment
system operating at 300 gpm. To determine the performance of each unit operation, samples were
collected from seven sampling points in the system. Two grab samples were collected daily from each
point for five days. Each sample was carefully collected, stabilized and analyzed.
A brief description of the process chain and results of treatability follows. Figure 2 depicts the
treatment process described.
1. Equalization
Groundwater extracted by two well pumps is transferred to the equalization tank. The
equalization system serves two purposes; oxidation of ferrous iron and equalization of the
groundwater sources as they are pumped to the system. An air diffuser is employed to aid the
oxidation process in the equalization tank. Testing confirmed the air requirements for
complete oxidation of the iron.
2. Metals Precipitation
The metals precipitation system consisted of pH adjustment reactor, rapid mix tank,
flocculation tank and clarifier. Groundwater from the equalization stage overflows into pH
adjustment tank #1. The testing confirmed pH levels and detention times for proper
operation. Both lime and sodium hydroxide were tested for neutralization. The amount of
agent needed, and quantity of solids generated by each agent was determined and used in a
subsequent capital and operational cost analyses. Lime was subsequently selected as the most
cost effective agent for the process.
Groundwater for pH tank #1 overflows to the rapid mix tank. Here an anionic polymer is
added to aid the metals precipitation process. From the rapid mix tank, the groundwater
overflows to the flocculation tank. Flocculation provides proper conditions to permit the
small sludge particles formed in the neutralization process to agglomerate and grow into larger
particles.
Flocculated groundwater flows by gravity to the plate packed metals clarifier. The clarifier
is the final link in the metals precipitation chain. Here the final separation of solids from the
effluent takes place. Treated effluent overflows from the clarifier and into pH adjustment
tank #2. Thickened sludge is withdrawn automatically from the metals clarifier and pumped
to the metals thickener for thickening prior to disposal.
Results of testing showed that all metals were precipitated to levels below the effluent
limitation required for discharge.
3. Biological Treatment
Effluent from pH tank #2 is pumped to the splitter box and then to the aerobic bio-tower
system. Cultured micro-organisms (inoculum) are housed in the packing media and serve to
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digest organic matter. The bio-towers are continuously supplied with nutrients to enhance
the biological treatment.
Testing indicated that the bio-system was able to remove all measurable quantities of volatile
organics. In addition, it was found that phenols were reduced from 13 mg/1 to 0.12 mg/1.
COD and BOD showed similar magnitudes of reduction. Effluent showed very small amounts
of total suspended solids.
From the data collected, two 12-foot diameter towers with a height of 20 feet were selected.
Of major importance from this portion of the treatability study was the fact that virtually no
sludge was produced by the bio-towers except that which adhered to the packing. Estimates
were that only approximately 100 pounds of sludge per day would be produced at a flow rate
of 300 gpm. The result of this was that the originally proposed bio-system clarifier, thickener
and filter press were eliminated from the flow scheme saving the client time and money.
4. Gravity Dual Media Filtration
Effluent from the bio-towers overflows to the dual media filter for removal of solids prior
to carbon filtration. The filtration system consists of anthracite and sand as filtering media.
The system includes an automatic backwash system which enables the filter to clean itself with
no shutdown involved.
5. Activated Carbon Filtration
Following gravity filtration, the effluent is collected and pumped to the carbon filtration
system. This system of 2 filters is employed for removing soluble organic chemical
contaminants from the groundwater using granular activated carbon media. Due to the
excellent performance demonstrated by the bio-towers, the load on the carbon columns was
expected to be very low.
6. Sulfide Precipitation
The sulfide precipitation system is used to remove both chelated and non-chelated heavy
metals. Filtered effluent from the carbon columns is pumped to a pH adjustment tank where
the pH is raised to between 9 and 9.5. Following pH adjustment, a soluble sulfide is added
to the reaction tank where most of the complexed heavy metals are converted to insoluble
metal sulfides. From the reaction tank, the groundwater is pumped to the filter columns
containing a media which removes insoluble metal sulfides and adsorbs the incipient nuclei
of underacted metal sulfides. In addition, the reactive media also sorbs free excess sulfide
ions and adsorbs, or chemisorbs, metal ions or metal/organic complexes, producing a final
effluent of extremely high quality.
Following sulfide treatment, the effluent overflows to the final pH adjustment tank and then
is discharged to the Missouri River.
In addition to confirming the effectiveness of the various treatment processes, the treatability
study yielded information necessary for sizing the sludge handling processes. A brief
description of the sludge handling facilities provided is as follows.
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1. Gravity Thickening of Metals Precipitation Sludge
Solids generated in the metals clarifier are withdrawn automatically and pumped to
the metals thickener. The metals thickener is a secondary gravity settler in that it
receives the underflow from the primary settler or clarifier, in this case, the metals
clarifier. The objective of increasing the solids in the underflow from the primary
clarifier is to facilitate the further dewatering and disposal of the sludge.
2. Gravity Thickening of Sulfide Sludge
Solids generated in the sulfide system filters are withdrawn and transferred to the
spent media thickener. The sludge/media discharge is in the form of a slurry, which
is allowed to thicken before final dewatering and disposal.
The metals and sulfide sludges were purposely separted. Treatability testing indicated
that the sulfide sludge might need special disposal where the metals sludge may not.
This could provide a significant operational savings.
3. Filter Press Dewatering of Metals Precipitation Sludge
When sufficient sludge exists in the metals thickener, the sludge is dewatered. Sludge
is pumped into the metals filter press at high pressure. Under pressure, the sludge
particles begin to deposit on the surface of the filter cloth to form a thin precoat layer.
When the filter cloth has been precoated with the sludge particles, this precoat layer
then becomes the filtering medium, and as filtration continues, a filter cake gradually
builds up within the chamber formed by two adjacent plates. When the complete plate
chamber has become packed into a hard sludge cake and the filtrate flow has dropped
away to virtually nothing, the press is ready for cleaning. At this point, the press feed
pump is stopped and the back pressure in the press relieved through a relief valve
located at the fixed end of the press. At this point, the plates are separated, allowing
the filter cake to fall into a dumpster for final disposal.
4. Filter Press Dewatering of Sulfide Sludge
When sufficient sludge exists in the spent media thickener, the sludge is dewatered
similar to the metals sludge using the spent media filter press. The dewatering process
is similar to that listed in the metals precipitation description.
The analytical results of treatability confirmed the reductions in heavy metals, cyanide, volatile
organics, phenols, pesticides and other organics and miscellaneous compounds. Operational flow rates
and equipment sizes were confirmed during this process. Sludge handling and chemical usage were
determined for plant operations. An example of treatment system performance results obtained
during treatability are included in Figures 3 and 4.
DESIGN
The design process proceeded concurrently with the treatability study. This had to be done in order
to meet Consent Decree schedules even though some efficiency was lost since assumptions had to be
made on various equipment sizes prior to receiving the final results from treatability.
ABB-ES employed several measures that increased communication and design efficiency.
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ABB-ES' first priority during the design phase was to assemble a manual of project procedures to
provide a framework for communication and decision making among the parties involved with the
project. The manual was reviewed by the FSRAC Committee, the Owner's engineer and U. S. EPA
and its consultants.
In addition to the procedures manual, a Design Criteria Document was developed. This document
contained the following: process design data including a process description, capacity, raw water
quality, effluent quality and detailed equipment criteria; detailed design criteria in the areas of
geotechnical, piping and mechanical, structural, HVAC, instrumentation, electrical, and civil; plant
flow hydraulics; equipment motor list, and catalog cuts of all major pieces of equipment to be
installed.
This Design Criteria was updated on a monthly basis as the design proceeded and was distributed to
all parties for review. It became a living document that served as a continuously updated statement
of design decisions and ultimately evolved into a specifications document.
It was through these two documents along with progress drawings, that all reviewing parties were kept
continuously informed and updated on the progress of design. There were no surprises at the
conclusion of design. Each review issue simply became a confirmation of discussions and conclusions
made during regularly scheduled meetings. This process significantly reduced review time throughout
the design.
The initial stage of design was to perform the hydraulic flow calculations, initially size equipment and
prepare general layout drawings. This was performed at the same time the treatability testing was
being accomplished. The use of CAD made this economically feasible since changes could quickly
be made as results from treatability confirmed or revised equipment sizing. The area allowed for
construction of the treatment plant was severely limited. A pad of approximately 100 feet x 170 feet
was provided so the treatment system had to be fit in a building that was 90 feet x 120 feet. The
original design basis had called for a totally gravity fed system. After reviewing this concept, the
layout and estimating the cost required for a total gravity fed system, ABB-ES prepared an alternative
system for consideration consisting of adding two pump stations with redundant pump systems and
presented this approach with a cost analysis to the FSRAC Committee. The result of the alternative
was to significantly lower in elevation a number of the initial process systems (equalization,
clarification and filtration) and provide a lower profile building and more efficient floor layout. This
alternative saved the client money and ultimately saved construction time as well and was accepted
and became the basis for final design.
The treatment building is a steel structure 90 feet x 120 feet in size with insulated metal roofing and
siding. The structure is heated and ventilated. It houses all processes with the exception of
equalization, biological and the air blowers. All equipment is installed above grade with no buried
tanks or deep sumps. Floor drainage is collected in shallow sumps and trenches and pumped back
through the treatment system. Localized exhausts were supplied for the sulfide make down tank and
ammonia tank. An office area was provided to contain the electrical control panel and PLC control
system.
The control system provided for the project consisted of a Square D Model 400 PLC for discrete and
analog control. To assure continued system control in the event of main processor failure, a second
Square D Model 400 PLC for "hot backup" was provided. All digital inputs and outputs, as well as
all P&ID loops have individual discrete and analog input and output process control points.
The following scenario describes the basic plant operation. The groundwater treatment system
operates whenever the extraction wells are operating. Pumping rates for the extraction wells are based
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on the gradient obtained at the four paired piezometer stations located on the perimeters of the site.
When the wells shutdown, the treatment system does as well. Various high and low level alarms
throughout the unit processes can also cause a system shutdown. The plant is designed such that if
there is a shutdown, groundwater in the system flows back to its previous tank by gravity. All tanks
and equipment are sized for this additional capacity.
One main electrical control panel is provided in the control room. Separate control panels are
provided in the field for the filter presses, the sorption filter, the lime silo and the dual medial filter,
to assist the operator in running the plant.
The PLC system was supplied with a screenware package with data logging, a printer, PC with color
monitor and membrane keyboard. Ten screens were developed to portray the process flow and
provide data logging and alarm status generation. All alarm printouts and process operation can be
reviewed from the operator's control panel.
The total design process took five months. This included performing and reporting the Treatability
Study, preparing the Design Procedures and Design Criteria documents and preparation of 50 design
drawings.
To expedite the design review and keep all reviewers comfortable with the amount of detail they were
receiving during the design process, meetings were held on a tight schedule. ABB-ES, along with the
FSRAC Committee made every effort to keep reviewing agencies informed of decisions that were
made and results of treatability. Agencies or their representatives were involved in all the meetings.
This was extremely important to the design-build process since the level of detail supplied in
drawings and specifications tended to be less than the agencies were used to seeing in a traditional
design-bid process. All parties were invited and encouraged to attend all meetings. This included the
FSRAC Committee, their oversite engineer, the U.S. EPA and their consulting engineer.
Close communications by regular meetings, and the review and updating of the design criteria and
drawings as the design proceeded resulted in approval of the final design granted by the EPA in 26
days.
CONSTRUCTION
Procurement for major pieces of equipment began during design, following completion of the
Treatability Study. This was necessary to meet mandated schedules. Long lead items, such as the
carbon columns, had to be put into manufacture well before final design approval was given.
ABB-ES' foremost concern when construction began in June 1989 was the small size of the working
area, making it crucial to coordinate equipment deliveries with the construction sequence.
Construction was scheduled and monitored using the Primavera Construction Scheduling software.
This aided in identifying potential problem areas and re-scheduling tasks that had to be coordinated
with other contracts working on-site.
The clean working area provided was approximately 100 feet wide by 170 feet long, while the
treatment building was 90 feet by 120 feet. There was little additional room for staging. Various
pieces of equipment - such as the equalization tank and the towers for the biological treatment step -
were placed outside the plant, taking up another 40 by 90 feet.
Prior to the start of any on-site work, all the necessary permits and approvals had to be obtained.
This became no easy task due to the number of agencies involved and was critical to meeting
mandated schedules. In addition to obtaining approval from the U.S. EPA, the following additional
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permits were needed: Missouri Department of Natural Resources, the U. S. Army Corps of Engineers
and the City of Kansas City, Missouri.
Communication with all of these agencies began early in the design stage. Again, the need to educate
everyone involved in what was proceeding and how, was particularly important in order to keep
approval and review time to a minimum. A number of informational meetings were held prior to
formal submittals to insure that all documentation and information was included in the submission
packages and that the reviewers were familiar with the level of detail that would be supplied in the
design-build package. The planning, communication, and education process paid off with
construction permits issued by the Corps of Engineers and City of Kansas City within two weeks of
formal submittals. This is particularly good considering the added complication that we were
constructing the plant in a flood plain.
Construction began on-site in June of 1989. ABB-ES completed the excavation and concrete work
first, followed by the erection of the treatment equipment. Scheduling was such that most equipment
items were delivered and set in place immediately. Some smaller items such as pumps and blowers,
were staged off-site and delivered as required during construction. The steel building structure was
delivered after the installation of the equipment, and "wrapped" around the treatment systems. (Refer
to Figure 5)
Throughout the construction phase, ABB-ES maintained its close coordination and communications
with weekly site meetings and major monthly reviews on-site with representatives of the FSRAC
Committee and reviewing agencies. Progress was reported and budgets updated, as well as reviewing
critical item delivery schedules.
Once the building structure was in place, piping, electrical and instrumentation work proceeded at
a fast pace. Piping was prefabricated as much as possible in the shop or on the plant floor and erected
as unit assemblies. Pipe racks were specifically designed and located to allow as much clear space in
the tight building as possible. Electrical cable tray was placed on the top of the racks with pipe
hanging from below. (Refer to Figure 6)
ABB-ES obtained substantial completion of the treatment plant in March, 1990 - on time and under
budget. During subsequent start-up and performance testing, the company provided on-site operator
training and was responsible for preparing an operations and maintenance manual.
CONCLUSIONS
The Front Street Project, with its Consent Decree imposed schedule and limited construction area,
posed a series of technical and managerial challenges for ABB-ES. Meeting those challenges and
completing the treatment plant on time and within budget reflects the commitment that was made to
communicate with and educate all parties on the design-build concept.
It is imperative that all the parties involved in the process understand exactly what level of detail will
be provided in the design documents and how engineering proceeds into the field on these types of
contracts. This is where the Procedures Manual and Design Criteria document became so important
to the process. A complete understanding of procedures and documentation must be attained up-front
in the job or unnecessary delays and duplication of effort can occur.
Along with a clear understanding of the process, trust must be developed during the process as well.
Excellent management, communication and professionalism must be present for any project to
proceed successfully, but it is even more important in design-build.
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The net result of the Front Street Project was the design and construction of a remedial action that
was accomplished on-schedule, saved the client money from the original bid price through effective
use of design modifications and construction techniques, and a treatment plant that has met Federal
and State effluent discharge guidelines and continues to meet or exceed performance expectations.
Though site-specific problems dictate the type and extent of any hazardous waste treatment, this
project serves as an example of effective groundwater remediation, as well as efficient and effective
project management.
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Front Street
Flow Schematic
Sodium Hydrodds
Holding Tank
FIGURE 1
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INFLUENT
O3
IIIOTOWr.R J I C IHOTOWER )
r i
TO SLUDGE HANDLING
SYSTEM
TO SLUDGB HANDLINa
SYSTEM
FIGURE 2
-------
TREATMENT SYSTEM PERFORMANCE
or
01
Parameter
Arsenic
Beryl I turn
Cadmium
Calcium
Chromium
Copper
I ron
Lead
Mercury
Nickel
Zinc
Equal ization
Tank
Influent
90
<2
30
449,000
200
260
375,000
<5
<.2
2,200
9,600
Equal ization
Tank
Effluent
70
<2
30
460,000
150
220
320,000
<5
<.2
1,900
9,500
TABLE NO. 1
HEAVY METALS
Metals
Precipitation
Effluent
<10
<2
<4
400,000
320
20
6,200
<5
<.2
350
170
Sand
Bio-Tower Filter
Effluent Effluent
<2 <2
<4 <4
418,000 410,000
60 50
<7 9
370 100
<5 <5
<.2 <.2
370 370
80 <50
Carbon
Filter
Effluent
<2
<4
400,000
<6
<7
40
<5
<.2
170
<50
Sulfide
System
Effluent
<2
<4
237.000
10
<7
20
<5
<.2
80
<50
Monthly
Average
Discharge Limit
80
20
50
none
200
50
none
50
2
2.380
1,480
FIGURE 3
-------
Removal Efficiency of 1,2-Mchloroethene/%-Methyl-2-pehtanone/Methylene Chloride
2000-
J750-
'C '500
O
§
cn
-------
FIGURE 5
657
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FIGURE 6
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The Construction and Operation of the New Lyme Landfill Superfund
Site Groundwater Treatment Facility
Donna P. Hrko
U.S. Army Corps of Engineers, Huntington District
502 - 8th Street
Huntington, WV 25701-2070
ATTN: CEORH-CD-I
(304) 529-5522
INTRODUCTION
The New Lyme Landfill Superfund Site is located in Ashtabula County, Ohio approximately 70 miles
from Cleveland. Construction activities consisted of capping the existing 43-acre landfill and
construction of a 100 GPM treatment facility to treat the leachate generated in the landfill. The water
treatment plant flow is created by thirteen extraction wells located around the perimeter of the
landfill cap. The treatment facility consists of the following unit processes: Equalization tank, pH
Adjustment tank, Chemical Clarifiers, Neutralization tank, Rotating Biological Contactors, Biological
Clarifier, Dual Media Sand/Anthracite filters, Granular Activated Carbon Units, Effluent Storage
tank, Gravity Thickener for chemical and biological sludges, and Sludge Filter Press. The treatment
facility is also equipped with a laboratory and computer equipment for analytical testing and a
complete maintenance program.
This paper will provide an in depth look at this multi-faceted treatment facility and each unit process
from a constructibility and operability standpoint. It will include the specific problems encountered
during the construction and start-up of the facility and offer suggestions for their elimination at
future site remediations that are equipped with a similar facility. Discussion will also include how
the treatment facility is currently operating.
BACKGROUND
The New Lyme Landfill began operation in 1969 and was initially managed by two area farmers. In
1971, the landfill was licensed by the State of Ohio and operations were taken over by a licensed
landfill operator. The landfill was to be operated as a trench-and-fill landfill with the majority of
the wastes coming from industrial and commercial sources.
Operating violations were noted throughout the operation of the landfill and included water in the
trenches, open dumping, uncontrolled access to the landfill, improper spreading and compaction of
wastes, waste not being covered daily, inadequate equipment, no evidence of Ohio EPA approval for
acceptance of certain industrial wastes, and excavation of trenches into the shale bedrock. On July
6, 1978, the Ashtabula County Health Department revoked the license to operate the landfill, and in
early August 1978, the landfill was closed. The site was placed on the National Priority List (NPL)
for Hazardous Waste Clean-ups in December 1982.
Data suggests that approximately 5,500 cubic yards of garbage, 8,000 cubic yards of commercial
waste, and 14,000 cubic yards of industrial waste were disposed of at the landfill during each month
of operation. As shown by the data collected on the landfill, a diversity of wastes were disposed of;
therefore, the groundwater treatment facility had to be designed to treat a multitude of hazardous
constituents.
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DISCUSSION
The groundwater treatment facility is located on the north west side of the project area,
approximately one hundred yards from the perimeter of the landfill. Access to outside tankage for
deliveries has been accommodated by locating the building to the north of the extraction well access
road. Consideration for expansion and/or additions to the processes is addressed in the design by
equipment layout in relation to the building location on the site. A chain-link security fence, with
gates, encompasses the facility with ample parking and service areas to the north, south and west of
the facility. The treatment facility structure is a pre-fabricated building manufactured by Stan
Buildings. The building dimensions are 80' x 142' 4" x 27'; it is anchored to a concrete slab. Although
the dimensions of the building are rather large, the space had to be used quite efficiently. The
process systems are housed in the building as well as an office, laboratory and complete shower and
locker room facilities for the plant personnel. A mezzanine that spans 1/4 of the building is equipped
with the mechanical components of the facility such as the HVAC system and air compressor. An
electrical room located on the north west corner of the building houses the stand by generator unit
and the motor control center for the automated process systems. The facility office houses a complete
process monitoring panel and controls including process alarm and shutdown switches for the entire
treatment system.
For simplicity, the discussion of the process systems will follow the same path as the contaminated
groundwater through the plant and outline the construction of each process unit.
As stated in the introduction, the flow for the treatment facility is created by the thirteen extraction
wells located around the perimeter of the landfill. From the extraction wells, the contaminated
groundwater travels via a 4 inch force main through motor control valve and flow meter, to the
Equalization Tank.
The Equalization Tank is located on the exterior south side of the treatment facility building. It is
fabricated from plate steel and measures 22 ft. in height, 14 ft. in diameter and is set on a concrete
base pad. It contains dilute leachate from the landfill. Equipment connected with the Equalization
Tank is a coarse bubble and a fixed header aeration system for agitation of the tank contents. The
exterior of the equalization tank is insulated with a flexible elastomeric covering to prevent freezing
of the contents.
Actual installation of the system went rather well; however, two modifications did result. After
insulation of the tank was compete, it was discovered that the ultra-violet rays emitted from the sun
would break down the constituents of the insulation, making it brittle and ineffective. Therefore,
the contract was modified to install a thin-gauge aluminum jacket over the insulation to protect it
from the light. The jacket also protects the elastomeric insulation from the harsh winter climate
experienced in Northern Ohio. The second modification came about at the time of initial testing,
when it was discovered that the motors connected to the blowers used to agitate the leachate were
over-heating. After some investigation and study, it was found that the blower units were undersized
for the tank size. The contract was modified to increase the blower size to accommodate the
Equalization Tank. Once the modifications were made, the aerated leachate discharges from the
Equalization Tank via an overflow at the top of the tank and gravity flows to the pH Adjustment
Tank.
The pH Adjustment Tank is located adjacent to the interior south wall of the treatment facility. The
tank is fabricated from steel and measures 6 ft. in height, 5 ft. 6 in. in diameter and is set on
structural steel platform legs. It contains dilute leachate and sodium hydroxide (NaOH). Equipment
associated with the pH Adjustment Tank includes a small mixer and a pH metering probe located in
the discharge baffle. To feed the pH Adjustment Tank, a 50% solution of NaOH is stored in the
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caustic storage tank. The caustic is introduced into the pH Adjustment Tank by caustic feed pumps
and controlled by a pH probe on the discharge side of the baffle. The caustic storage tank is
fabricated of steel and has a capacity of 3500 gallons.
A few months into the operation of the facility, a problem occurred with the pH adjustment process.
The weather got colder and the groundwater temperature decreased to the point that it was below the
freezing temperature of the caustic solution. To alleviate the problems associated with the
introduction of caustic solution into the pH Adjustment Tank it was necessary to dilute the 50%
solution. To accomplish the dilution, it was necessary to add a 150-gallon, steel mix tank within the
retaining wall of the caustic storage tank ahead of the caustic feed pumps. The mix tank process will
only be used until the current supply of 50% solution is exhausted, after which a weaker solution of
caustic will be supplied. Another problem that makes the facility unable to operate at the 100-gpm
design flow rate is clogging of the 4-inch influent line between the .Equalization Tank and the pH
Adjustment Tank; therefore, the contract will be modified to provide an in-line static mixer, as well
as a direct caustic injector system, and pH probe for the pH adjustment process. A switch will also
be added to utilize the existing pH adjustment process if needed. Flow from the pH Adjustment
Tank discharges by gravity to the Settling Tank where the precipitated metals are separated.
The Settling Tank is located just right of the pH Adjustment Tank, adjacent to the interior south wall
of the treatment facility. The tank walls are fabricated from steel tied into a bowl-like concrete base
to accommodate the sludge collection equipment. The Settling Tank measures 30 ft. in diameter and
approximately 10 ft. in height. Equipment for the circular sludge collector in the Settling Tank
includes torque tube and scraper arms, drive mechanism, feed influent flume, chemical mixing and
high rate internal recirculation components, slurry recycle for solids contact and upflow clarification.
A structural steel bridge spans the tank diameter and supports the entire collector mechanism and also
serves as an operator access deck.
Due to the immense size of the Settling Tank and the fact that the concrete pad was founded on #57
aggregate, the contractor proposed the use of a footing to prevent settlement. The contractor felt that
the #57 aggregate would not hold its shape as a form for concrete; therefore, a substitution of #307
aggregate was suggested. The contract was modified to incorporate both suggestions in the tank
foundation as well as in the foundation for the Biological Clarifier unit. The clarified liquid in the
Settling Tank flows by gravity to the Neutralization Tank where it's pH is lowered to 7.0 and the
solids are pumped to the Gravity Thickener.
The Neutralization Tank is located just right of the Settling Tank, adjacent to the south wall of the
treatment facility. The tank is fabricated from steel and has a capacity of 1,000 gallons. The tank
is set on a 10 ft. high structural steel platform and contains dilute leachate mixed with H2SO4. Process
equipment connected with the Neutralization Tank includes a small mixer and pH metering probe
located in the discharge baffle. A 93% solution of H2SO4 is stored in the acid storage tank adjacent
to the exterior south wall of the treatment facility. Introduction of the sulfuric acid solution into the
neutralization tank is accomplished by utilizing the acid feed pumps. The acid storage tank is
fabricated of steel and has a capacity of 3,500 gallons. A wall is constructed around the acid storage
tank to contain spills.
When the contractor was acquiring the components of the acid and caustic storage tanks, the
manufacturer named in the contract specifications as the supplier of the level float switches advised
the contractor that their product was not suitable for caustic and sulfuric service. The contract was
modified to utilize a level probe constructed of stainless steel attached to teflon-coated wire which
terminates at the polycarbonate housing and PVC flange at the top of the respective acid storage and
caustic storage tanks.
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During final phases of work on the treatment plant, it was determined that a safety hazard existed
due to the location of the fill lines for both caustic and sulfuric acid storage tanks. After filling of
these tanks, a reverse head pressure would be in the tanks when the hose was released from the supply
truck. This would create a potential for a chemical spill at either tank. For safety considerations, the
contract was modified to relocate the filling lines to the top of the acid storage and caustic storage
tanks.
Flow from the Neutralization Tank enters the RBC splitter box and discharges over a straight-edge
weir to the Rotating Biological Contactors (RBCs). The flow can be routed to one, two, or three RBC
shafts, depending on the wastewater characteristics. The RBC units are located just right of the
Neutralization Tank, adjacent to the interior south wall of the treatment facility. The RBC units are
comprised of two different materials. The bottom, or tank portion of each unit, is fabricated from
plate steel. The covers on the RBC units are fiberglass- reinforced plastic. Each section of the cover
is a continuous arch with no bolting required between sections. End panels are easily removable for
equipment access. Sections join each other and the end panel by overlapping corrugations.
Components and equipment associated with the RBC units are as follows: media, consisting of high-
density linear polyethylene material; central steel shaft to support the rotating media; a structural
support system to prevent lateral and radial movement of the media; a drive system including motor
speed reducer, sole plate, base bars, chain casing and roller chain; and supplemental air piping. The
units are also equipped with a structural operating platform for ease of maintenance.
Two positive displacement blowers are located in the blower room of the treatment facility due to
noise considerations; they provide the air needed to stop excess growth on the shaft as well as provide
air for aerobic growth. Each unit delivers a maximum of 375 scfm, a total of 750 scfm. The contract
phrasing indicated that each blower was to deliver 750 scfm, which was incorrect; therefore, the
contract was modified to state a total of 750 scfm was to be provided. The RBC effluent flows by
gravity to the RBC Effluent Tank where the leachate is pumped via variable speed pumps, through
the RBC Effluent tank, to the Biological Clarifier.
This RBC Effluent tank is located adjacent to the interior east wall of the treatment facility. It is
fabricated from steel and has a capacity of 5,000 gallons. The tank contains treated leachate from the
RBC units and acts as a reservoir from which the treated leachate is pumped to the Biological
Clarifier.
The Biological Clarifier is located adjacent to the interior north wall of the facility. The tank walls
are fabricated from steel tied into a bowl-like concrete base to accommodate scraper equipment. The
Biological Clarifier measures 22 ft. in diameter and 10 ft. in height. Equipment for the circular
sludge collector in the Biological Clarifier includes torque tube and scraper arms, drive mechanism,
and influent feed well. A structural steel bridge spans the tank diameter and supports the entire
collector mechanism and also serves as an operator access deck.
The biological solids produced from the RBC's and settled in the Biological Clarifier are pumped to
the Gravity Thickener by two air-operated diaphragm pumps. The clarified wastewater flows by
gravity to the sand filter splitter box through a V-notch weir. The feed is equally divided between
the two sand filters, operating in parallel.
The Sand Filter is located adjacent to the interior north wall, just left of the Biological Clarifier. The
Sand Filter Tank is a steel gravity multiple cell unit that measures 6 ft. wide and 8 ft. long and 11 ft.
in height. It is constructed of 1/4-inch plate steel and reinforced to withstand the hydrostatic
pressure encountered. The filter also has an underdrain system to reduce the water velocity,
discharging the water horizontally without impeding the flow, thereby preventing channeling of the
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bed. A filter trough is provided in each filter cell for collection of the backwash water. Inlet and
wash water collection gullets receive and apply inlet water to the filter and collect wash water from
the wash troughs. Four 16-inch layer gravel beds serve as the supporting beds for the filter. The
filter media is a uniform grade anthracite. Equipment used for backwash of the filter include a
positive displacement blower for air scour to the media and a pump for simultaneous air water
backwash. A level float in each cell will automatically initiate sand filter backwash with treated water
from the effluent tank. The backwash water from the filters is discharged to the Recycle Tank.
Backwash can be controlled both automatically or manually with pneumatically operated valves.
Backwash is accomplished with treated water from the effluent tank and discharges to sump for
recycle to the RBC blowers. The Sand Filter is also equipped with an operating platform and
walkway. The Sand Filter effluent flows by gravity to the filter effluent tank.
The Sand Filter Effluent Tank is located adjacent to the sand filters. It is fabricated from steel and
has a capacity of 1000 gallons. The tank contains treated leachate from the sand filters and serves as
a reservoir from which the leachate is pumped to the Granular Activated Carbon Units by variable
speed pumps.
The Granular Activated Carbon (GAC) system consists of two column adsorbtors that may work in
series or parallel. The units are located adjacent to the interior north wall, just left of the sand
filtration system. Calgon Corporation was the supplier of the GAC system and was totally responsible
for the design, fabrication, installation and start-up of all unit components. The total system contains
40,000 pounds of granular activated carbon. Carbon replacement is performed using a truck and fill
pipe. Spent carbon is discharged directly to the truck by pressurizing the column with air from the
compressed-air system. New carbon is added by pressuring the truck with water to force the new
carbon into the columns. Carbon offloading is accomplished by utilizing the end suction pump and
associated piping that is connected to the Effluent Storage Tank. Water may also be drained to the
Recycle Tank from the GAC for reprocessing.
The Recycle Tank is located behind the sand filters, adjacent to the north wall of the facility. It is
fabricated from steel and has a capacity of 1500 gallons. The Recycle Tank accepts backwash water
from the sand filters, drainage from the GAC's, filtrate from the filter press, and supernate from the
Gravity Thickener. The Recycle Tank contains a sump pump which pumps the water to the RBC
splitter box or the Equalization Tank for reprocessing.
Flow from the GAC units is collected in the Effluent Tank. The plate steel effluent tank has a
capacity of 12,000 gallons and is sized to allow its water to be used for sand filter backwashing, area
hose bibs, lime slurry mixing, pump seal water, filter cloth wash and carbon offloading. In addition,
two centrifugal recirculation pumps provide the capability to pump effluent water back into the
system. Recirculation can occur from the Effluent Tank to the Equalization Tank, RBC splitter box,
or Sand Filter Effluent Tank.
Discharge out of the Effluent Tank is over a straight edge weir, after which the flow is sampled and
measured prior to discharging to Lebonan Creek.
The Gravity Thickener receives sludge from the Biological Clarifier and the Settling Tank. The
Gravity Thickener Tank components include steel tank walls, bottom and supports; torque tube, drive
mechanism, influent diffusion well, collector arms, access bridge, and control equipment. The tank
measures 10 ft. in diameter and 8 ft. in height. It was determined that a ladder assembly should also
be furnished to provide access to the gravity thickener and the contract was modified to incorporate
this change. From the Gravity Thickener, the sludge is pumped to the Flash Mix Tank where lime
is added.
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The 50-gallon Flash Mix Tank is fabricated from polypropylene and is used for a quick, high energy
contact of lime and sludge. The tank is located just left of the Gravity Thickener, The lime is added
to the sludge as a conditioning agent since conditioned sludge dewaters more readily and creates a
cake that is less likely to stick to the filter press cloth. The lime is stored in a lime storage silo. It is
here that the lime slurry is mixed and pumped to the Flash Mix Tank. The Lime Slurry System is a
self- contained unit located on the exterior of the building adjacent to the Equalization Tank. The
system contains a lime storage silo, complete with bulk unloading facilities. Located in the bottom
portion of the silo is the lime slurry mix tank, lime slurry feed pumps, and associated system controls.
The silo is equipped with a dust-collection system which may be activated by the operator prior to
bulk lime unloading. The mixture flows out of the Flash Mix Tank and into the Sludge Conditioning
Tank.
The Conditioning Tank is where the sludge and lime are blended. The tank is fabricated, from
polypropylene and has a capacity of 400 gallons. A slow speed mixer is used to blend the sludge and
lime, then the sludge is pumped to the filter press for dewatering.
The filter press is a plate-and-frame press capable of dewatering 13.5 cu. ft. of conditioned sludge
per cycle. The daily operation is set up around two cycles per day with each cycle lasting 2.5 hours
from press close to cake discharge. Cycle time can be adjusted by plant personnel. A modification
was made to the filter press system. In order to properly meet the demand of the filter press unit, the
manufacturer recommended that the two-inch outline for the filter press be changed to a six-inch
line to facilitate the dewatering process.
The filter press is located on the mezzanine to allow for direct cake discharge. The cake will be
transported by sludge truck to a RCRA licensed landfill.
Two air compressors are located on the mezzanine. These compressors supply high- and low-pressure
air for all pneumatic controls, as well as air-operated pumps. The air compressor system also
incorporates a 120-gallon air receiver, two free-standing type air-cooled after coolers, intake filter
and silencer, refrigerated air dryers for moisture removal, and coalescing filter.
The layout of the process systems in the building is such that a truck or small crane can access all
process units for maintenance. A one-ton monorail crane is provided in the facility for O&M
purposes. Vehicle access is accomplished through the overhead door that also serves as access to the
filter press for removal of the cake. The installation of the overhead door required the contractor to
remove the metal siding around the door after the building was erected, install additional support
steel, and replace the siding. The work involved in the installation of the door was determined to be
above the requirements of the contract and the contract was modified to compensate the contractor
for this additional work.
The laboratory is supplied with equipment for anticipated routine process monitoring and control
tests, as well as anticipated permit parameters for conventional pollutants. Space has also been
provided in the laboratory for adding a gas chromatograph or atomic absorption apparatus. This more
sophisticated equipment would allow for on-site analysis of priority pollutants. It was determined
to be necessary to provide capabilities for the on-site lab to perform BOD testing; therefore, the
contract was modified to compensate the contractor for furnishing necessary equipment and material
to perform such testing.
Numerous other modifications to the treatment facility have been made to ensure proper operation,
accommodate maintainability, and enhance the safety features. A discussion of these modifications
follows.
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An additional valve was added to the line for the existing sand filter, in order for this process to be
segregated from the remainder of the plant for subsequent O&M considerations. The water supply
system for servicing the emergency eye wash in the lime storage silo was changed to potable water
as opposed to plant effluent in order to prevent the use of treated water as an eye wash. An air
supply header to the RBC effluent tank was extended off of the RBC feed line to prevent the
deposition of solids in the tank during solids transfer operations from the RBC's. A small sump on
the exterior of the treatment plant was installed to capture carbon fines contained in the overflow
from the GAC units to prevent the inclusion of fines in the treatment plant sump. A "ship's ladder"
to the pH Adjustment Tank was installed for access to the tank to allow for pH probe adjustment and
mixer maintenance. A feed system from the effluent tank to the filter press line was installed to allow
purging of the feed line after every filter press application. Funnel connections for all sampling ports
that discharge to a floor drain were provided to prevent the discharge of water over the treatment
plant floor. A special corrosion protection for the high pH environment in the lime mixing tank was
applied. Connections for the portable samplers were provided. A protective cage was installed
around the phosphoric acid barrel for safety considerations. A surge arrestor was installed for the
treatment plant. Wiring was changed as necessary to provide spare circuits. Two pending
modifications provide a trailer and pump for cleaning out sumps around the perimeter of the landfill,
and conduct sampling of each extraction well to provide a database on the leachate constituents that
each well is producing. A problem with phase loss or "brown out" has occurred since the facility has
been in operation. An exhaust fan motor was burned out due to this condition and the process
equipment has to be monitored very closely. The contract is being modified to install Brown Out
protection equipment on the main disconnect on the Motor Control Center to protect the treatment
facility from power phase loss.
The groundwater treatment facility has been on-line in some capacity for approximately six months.
Due to operation of the facility being in its infancy, there are still minor problems with the operation
that are being ironed out by some of the pending modifications noted in the previous discussion.
According to the operator of the facility, Dave Thompson of Sevenson Environmental Services, Inc.,
the problems being encountered are in the primary treatment processes, e.g., from the Equalization
Tank to the RBC's. The line between the Equalization Tank and the pH Adjustment Tank is clogging
with residue and the facility is unable to operate at the design flow of 100 gpm. He believes sediment
and high concentrations of calcium, iron and magnesium are collecting on the butterfly valve
components in the line and restricting the flow. He recommends that future designs have full port
ball valves incorporated into the primary process lines to eliminate any restrictions in flow.
In addition, in future contracts consideration should be given to the use of plastics where applicable
in order to reduce costs incurred by steel fabrication and process piping systems. In this contract, all
of the process tanks in the treatment facility were fabricated from steel with the exception of the
Flash Mix Tank and Conditioning Tank. At the contractor's request, schedule 80 PVC piping was
approved in lieu of the steel pipe specified in the contract for the following process lines: Raw
Wastewater, Settling Tank Influent, Settling Tank Effluent, Biological Clarifier Influent, Filter
Influent, Filter Effluent, Carbon Effluent, Primary Effluent, Filtrate and Recycle lines.
As outlined in the construction contract, upon completion of construction of the extraction well
system and groundwater treatment facility, the contractor had the responsibility to start-up the
facility, and then to operate the facility for a period of one year. After the one-year operation period
the facility will be relinquished to the State of Ohio. Operator staffing of the facility during the
obligatory period is a minimum of eight hours each day by a staff of two people, one of which must
hold a current Class 2 Wastewater Treatment Plant Operator's license issued by the State of Ohio.
During unmanned hours at the plant, the operator must be on call and reachable for emergency
occurrences. The treatment facility is equipped with an automatic dialer system that will call pre-
programmed telephone numbers if an equipment breakdown occurs. The Contractor was also required
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to retain the services of a Class 3 Wastewater Treatment Plant Operator licensed by the state of Ohio,
if needed.
A wastewater treatment specialist, retained by the contractor, is responsible for preparing a Systems
Operation Manual and preparing a formalized training program. The manual includes system and
process descriptions, locations, start-up procedures, normal operation procedures, emergency
procedures, shutdown procedures, instrumentation and electrical control systems, and scheduled and
unscheduled maintenance procedures. The Contractor was also required to provide computer
equipment and computer programs for record keeping and maintenance. Equipment at the site
consists of an Epson Equity II computer, Okidata printer, Macola Operator 10 maintenance software,
and Lotus 1-2-3 software. The formalized training program for the State of Ohio personnel will
include user start-up, operational training and instruction sessions for at least 10 working days near
the end of the Contractor one year operational requirement.
The one-year period of operation required by the contract has been an immense help in ironing out
the problems encountered when starting up and operating a facility of this magnitude. With the job
still under contract, an avenue was available to modify the system, if necessary, to make a quality end
product for the user --in this case Ohio EPA. The one-year operation requirement should be placed
in any contract with such complicated systems, in order to address modifications such as the ones
discussed throughout this paper.
CONCLUSION
The construction of such a complex facility to treat the diversified wastes found in the landfill was
not going to be perfect when all the switches were turned on and the water began to flow. As noted
in the discussion of the facility, many modifications were made to insure proper operation,
accommodate maintainability, and enhance safety of the treatment facility. Many of these
modifications were the result of problems encountered during the start-up or initial operation of the
facility. Because of an innovative contracting procedure that has instilled the responsibility of start-
up and one-year operation of the facility in the construction contractor, we were able to use the
construction contract to make modifications and provide a better end product to the customer.
The total project construction cost for the remediation of New Lyme Superfund Site is approximately
15.2 million dollars. Of the total construction contract amount, 2.8 million dollars was spent on the
groundwater treatment facility, which is the corner stone of the remediation. Comparing these
figures to the cost of removing the wastes from the landfill and treating the contaminated soil and
water off-site, you can see the financial viability of this method of remediation.
The tasks of constructing and operating this sophisticated facility are secondary to the overall benefits
gained. Treatment facilities of this caliber will make a monumental difference in site remediation
where a diversity of contaminated leachate is present and the possibilities for site-adaption on other
projects is endless.
REFERENCES
New Lyme Landfill Superfund Site - Specifications for Construction Contract, Volume 1 and Volume
2, US Army Corps of Engineers, Omaha District.
New Lyme Landfill Superfund Site - Design Analysis Volume 1 and Volume 2, Donuhoe Engineers
and Associates, Inc.
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Modification Files - New Lyme Landfill Superfund Site, US Army Corps of Engineers, Huntington
District, Construction Division, Contract Administration Branch.
Dave Thompson, Sevenson Environmental Services, Class 2 Wastewater Operator at New Lyme
Superfund Site.
Margaret Wren Wilson, Resident Engineer, New Lyme Superfund Site.
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Arsenic Removal at the Lidgerwood Water Treatment Plant
Harry T. Jong
Lisa H. Rowley
U.S. Bureau of Reclamation
P.O. Box 25007
Mail Code D-3130
Denver, CO 80225
(303) 236-9096
INTRODUCTION
The objective of this paper is to present an evaluation of the operating problems experienced by the
Lidgerwood, North Dakota Water Treatment Plant (LWTP), the causes of the plant's poor
performance, and the resulting modification design . The original LWTP was constructed in 1985 to
remove arsenic, with secondary removal of iron and manganese from the City of Lidgerwood's water
supply. The original plant was plagued with operational problems and, consequently, often produced
water of an unacceptable quality. As a result, in 1986, a Record of Decision was signed to correct
the plant's problems. In 1988 the Bureau of Reclamation (Reclamation) was asked to design, specify,
and provide contract management services for the LWTP modification.
BACKGROUND
LWTP is located on the North Dakota Arsenic Trioxide Site, which is an Environmental Protection
Agency (EPA) Superfund site placed on the National Priorities List. Routine sampling in 1979 found
that levels of arsenic in the Lidgerwood water supply exceeded the Maximum Contaminant Level
(MCL). The contamination of the groundwater supply is due to natural arsenic deposits and to
widespread use of arsenic-based pesticides for grasshopper infestations in the 1930's.
Lidgerwood is located in the southeast corner of North Dakota. It has a population of approximately
970. The LWTP was built in 1985 under the provisions of the Safe Drinking Water Act. The facility
was rated at 252 gal/min and was designed to:
oxidize ferrous iron and manganese ions,
co-precipitate arsenic,
filter out suspended material,
disinfect with chlorine.
Approximately 6 months after the plant started up, operational difficulties were observed. The plant
was reportedly offline frequently. When this occurred, untreated water was delivered to the city
distribution system. Also, treated water from the plant periodically failed to meet the primary arsenic
standards of 0.05 mg/L and secondary drinking water limitations for iron of 0.30 mg/L, and
manganese of 0.05 mg/L. The treated water was also periodically "pink" or "brown" due to poor
adjustment of potassium permanganate demands. As a result of these problems, an EPA Remedial
Investigation/Feasibility Study for the Arsenic Trioxide Site was completed and a Record of Decision
to modify the plant was signed in September, 1986.
Representatives from the city, state, EPA, the city's consulting engineers, and Reclamation met in
October, 1988 to review the LWTP's operating history. This group identified some of the probable
factors effecting the plant's poor performance. A plan of action was also assembled. Subsequently,
Reclamation engineers further evaluated LWTP's operating records and identified additional factors
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which were partially responsible for the plant's poor performance. At that time, Reclamation
proposed remedies to modify the plant. In December, 1988, Reclamation was requested to design,
specify, and provide contract management services for the LWTP modification. Due to the imminent
health risks associated with the poor plant performance, an accelerated design and construction
schedule was established whereby all work would be completed by November, 1989, the end of the
1989 construction season.
DISCUSSION
Reclamation evaluated LWTP's problems by breaking the plant into three areas of attention: the
chemical process, the equipment, and the plant operation. The predominant problems which were
identified are listed below.
poor mixing of chemicals added after aerator
manual operation of filter backwashing sequence
use of an inappropriate pump for filter backwash
marginal detention time in reactor (20 minutes)
inadequate in-plant storage volume for treated water
variation of manganese content in raw water and the absence of instrumentation
needed for determining potassium permanganate demand for treating manganese
inadequate control over influent flow rates
awkward handling of sludge in the backwash recovery basin
crowded facility
In order to resolve the observed problems, recommendations were made regarding the process, the
equipment, and operation. These recommendations were based on results from bench-scale laboratory
verification testing. The testing was conducted concurrent to the design as a means of fast-tracking
the project. The concurrent testing proved to greatly accelerate the design process by providing
timely input of design data as the process proceeded. The bench-scale testing, entitled Verification
of Process Testing, was divided into a number of sub-tasks. Briefly, these sub-tasks included
investigating the following topics:
evaluation of reaction times for removal of manganese, iron, and arsenic
effect of coagulant addition and freshly activated sand on manganese, iron, and
arsenic removal
effect of temperature, seeding, addition of ferrous chloride and chlorination on
manganese, iron, and arsenic removal
evaluation of settling rates of oxidation products and aged sludge
evaluation of the possibility of re-solution of manganese, iron, and arsenic
analysis of fresh and used activated sand coating, and scale coating on flow nozzles
The Verification of Process Testing indicated that residence time in the detention tanks should be
increased to 60-90 minutes in order to produce large, well filterable floes. A flocculent aid, such as
the non-ionic type used in this study, was found to enhance flocculation and is particularly important
in manganese removal. In addition, the findings from the bench-scale testing indicated that re-
solution of the contaminants over a 12-week period does not occur in any significant amount and
should therefore not be a problem in the backwash basin.
Based on the aforementioned observations and in concordance with the results from the bench-scale
testing, Reclamation proposed the following recommendations to modify LWTP in the areas of the
chemical process, the equipment, and operation. A process flow diagram, Figure 1, delineates many
of these recommended changes.
669
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Recommendations for the chemical process include:
provide adequate time to allow the iron, manganese, and arsenic precipitates to
agglomerate in the detention tank
continue to use a non-ionic polymer as a flocculent aid
continue to use potassium permanganate as the oxidant
Recommendations for changes in equipment include:
convert the compartment below the aerator into a mixing tank
automate the manually controlled backwash sequence and add a filter-to-waste cycle
provide an additional 20,000 gallons of storage for clearwell water
construct a 15'xlS'xlO' detention tank to provide 80 minutes of detention time
purchase a spectrophotometer and color monitor to determine more accurately the
potassium permanganate demand and provide a means to alarm when there is a color
breakthrough
install a flow and pressure regulating valve in the influent line
provide access handways near the underdrain at each filter cell
increase the building size to twice its original to accommodate the retrofitted
equipment
Recommendations for changes in plant operation include:
revise the filtration operation throughout the day and backwash at the end of the day,
as required. Add a filter-to-waste cycle
reactivate the recycle of the supernatant from the backwash water recovery basin
allow the sludge to remain in the bottom of the basin in the inactive zone during
winter operation; during the remaining part of the year pump the sludge to the sludge
filter bed to separate the precipitates
train operators to operate the plant as designed and as modified
Reclamation was requested to design the LWTP modification in December, 1988. The resulting
schedule, quite short due to the imminent health threat and the short construction season, is shown
below:
Concept 2/1/89
Design Complete 5/1/89
Bench-scale Tests 2/1/89 - 5/1/89
Bid Opening 7/13/89
Award 7/19/89
Construction Complete 1/30/90
The plant has been operating successfully since modification and operator training. The treated water
has consistently met drinking water MCLs since modification. Results from the North Dakota State
Department of Health and Consolidated Laboratories have indicated that the arsenic levels in the
treated water have been reduced from 0.134 mg/L to 0.019 mg/L. In addition, analytical results for
the arsenic sludge have shown concentrations of 0.056 mg/L, which is well below the hazardous waste
category of 5.0 mg/L.
670
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CONCLUSIONS
Due to sporadic performance at the LWTP and the resulting production of water of an unacceptable
quality for human consumption, EPA requested Reclamation to design, specify, and provide contract
management services for the LWTP modification. This request was made in December, 1988.
Reclamation issued the specifications and awarded the construction contract by July, 1989. The field
cost for the plant modification was $316,000. The timely response to remediating LWTP's problems
was made possible through cooperation and a team approach between EPA and Reclamation, and
concurrent bench-scale verification testing. Construction was completed on the LWTP modification
in January, 1990. Water quality results from the time of modification to present have indicated that
the treated water is in compliance with the drinking water standards.
REFERENCES
Bureau of Reclamation, June, 1989. "Modification Design Report",
Lidgerwood Water Treatment Plant, for Environmental Protection
Agency, Region VIII, Denver, Colorado.
Bureau of Reclamation, August, 1989. "Design Summary", Lidgerwood
Water Treatment Plant, for Specifications No. 60-CO211,
Denver, Colorado.
Environmental Protection Agency, 1988a. "EPA Region VIII Fact
Sheet" of May 1988, Denver, Colorado.
671
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FIGURE I - LIDGERWOOD WATER TREATMENT PLANT
Process Flow Diagram
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-------
SUCCESSFUL PROGRAM MANAGEMENT
FOR
REMEDIAL DESIGN/REMEDIAL ACTION
JAMES L KILBY
Manager, Remedial Projects
Monsanto Agricultural Company
800 North Lindbergh Blvd. - N3F
St. Louis, MO 63167
314-694-6443
INTRODUCTION
The remedial design/remedial action program for the CERLCA site
located at Seymour, IN will be successfully completed
approximately two years ahead of the schedule in the Consent
Decree. The construction work has been completed without a
recordable injury. In addition, the work has progressed without
a health/safety problem to the public. Approaches to the project
which made this result possible included extensive up front
planning, team building among all participants. PRP
representatives, contractors and the agencies, strong field
safety approach and extensive public relations programs. This
paper discusses the scope of the work, the approaches to managing
the work, and the problems encountered as a result of data
developed during design, the accomplishments of the project as
well as some lessons learned in attempting to manage projects
under CERCLA.
BACKGROUND
The Seymour Recycling Center SRC Site is located approximately 2
miles southwest of the City of Seymour, Indiana. From
approximately 1970 until 1980, this 14-acre site was operated as
a processing center for waste chemicals. The activities at the
site included chemical fuel projection, reclamation, incineration
and drum crushing.
Over the period of operation of the SRC site, the owners lost
control of the facility. As of early 1980, over 50,000 drums,
100 bulk storage tanks and numerous tank trucks were located at
the SRC site. A significant number of the containers were in
weakened or damaged condition. Hazardous substances and other
substances had leaked from the containers onto the ground
resulting in soil contamination, vapor emissions, fires and odor
673
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problems.
Beginning in late 1982, a major surface cleanup action was
performed by Chemical Waste Management, Inc. The cleanup was
monitored by the USEPA and the Indiana State Board of Health.
All wastes at the surface were removed including the drums, the
bulk storage tanks, and contaminated soil from designated areas
down to a depth of approximately 1 ft. A 1 ft clay cap was
placed over approximately 75% of the site.
The Remedial Investigation (RI) began at the site in August 1983
and continued through November 1985. The RI document was
published in May 1986. The RI concluded that the soil under the
site was contaminated, a shallow aquifer under and adjacent to
the site was contaminated and a deep aquifer under and adjacent
to the site possibly was contaminated. The Feasibility Study
(FS) document was published in August 1986.
The approximately 300 Potentially Responsible Parties (PRPs)
involved in this site can be divided into two groups. One group
was involved in a consent decree focusing on the surface cleanup.
Those PRPs who were a party to this consent decree were absolved
of any responsibility for the subsurface cleanup. A consent
decree dealing with the subsurface cleanup was entered in the
Federal District Court in December 1988. The 109 PRPs who were
party to the subsurface consent decree agreed to manage the
remedial program. Monsanto Company, the largest financial
contributor to the remedial program was asked and agreed to be
the Trustee for the Trust established to implement the provisions
of the consent decree. During the course of the negotiations of
the 1988 consent decree, an Agreed Order was executed for the
installation of a temporary pump and treatment system. The
system was to be utilized to remove water from the contaminated
shallow aquifer and to treat the water in a test pretreatment
plant. Data from the test were to be utilized in the design of a
permanent pretreatment plant.
PROJECT SCOPE
The remedial action program for SRC can be broken down as
follows:
PROBLEM SOLUTION
• Contaminated shallow aquifer • Plume stabilization project
• Long-term operation & maintenance
• Ground-water monitoring
• Potentially contaminated deep • Ground-water monitoring
aquifer.
• Potential for pumping restriction
674
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from the aquifer
• Potential for pump & treat
• Contaminated soil • Building demolition
• Vapor extraction system
• Off-site soil excavation
• Multi-media cap
• Roads, fences, drainage
• Enhanced bioremediation
• Air monitoring • Baseline air study
• Construction monitoring
• Long-term monitoring
The schedule for completion of the installation of the facilities
was 58 months from the entry of the consent decree. The long-
term operation of the facilities and monitoring of the cleanup
progress extends for up to 30 years.
EXECUTION STRATEGY
In the fourth quarter of 1988, prior to the entry of the SRC
consent decree, a strategy for execution of the work was
developed. Key objectives of the strategy focused on these
areas:
• Aggressive project schedule
The schedule in the consent decree specified 58 months to
complete the installation of the facility. Intensive early
planning was used to develop a detailed schedule and plan to
meet and if possible, to beat the schedule. This effort was
extremely important since calculations indicated that for
every year in the delay of operation of the pump-treat
system extended the pumping time by 7 years. In addition,
once a project team is established, the on going fixed cost
for a project is significant - time is money. An aggressive
schedule was developed which, if accomplished, would
complete the installation of the facilities as defined in
the Remedial Action Program (RAP), in 28 months. Keys to
the schedule logic were working the project elements in
parallel rather than sequentially as defined in the RAP
combined with programs aimed at expediting agency approval
of project submittals.
675
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• Avoid engineering interruptions
To avoid additional cost and to improve engineering
continuity on a project, it is advantageous to avoid changes
in project personnel. The consent decree required the PRPs
to submit the project documents in stages, and following
approval, to proceed to the next phase. Following this
approach would create situations whereby the engineering
staff must be idled while waiting on comment/approval from
the agencies. To avoid this interruption, the plan called
for the design to proceed "at risk".
• Large Bid Packages
In order to attract major national construction contractors,
the plan called for creating large lump sum bid packages.
The intent was to draw upon well resourced major firms for
the work. Their approach would provide the flexibility to
react to major changes in the work.
• Experienced Remedial Contractors
The intent was to define and use only experienced
construction contractors with remedial work experience. The
desire was to select a firm responsible for construction
which were, in fact, experienced constructors.
Approximately 45 firms were screened to develop a final bid
list of five firms for the major construction package.
• Meet/Beat Project Budget
CERCLA projects are under time and performance pressures
with cost being a secondary focus. In order to raise the
level of importance of cost in the project team,
budgets/cost tracking/cost emphasis programs were put in
place.
• Shorten Communication Lines
In order to expedite design approvals (within the design
team and with the agencies) several programs were
implemented. Included were:
o PRP representative located in design contractor office.
o Informal, intermediate design reviews with the agencies,
o Weekly conference calls with all lead people.
o Weekly contractor meetings in field.
o Monthly senior management reviews in field.
676
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• Solve the Problem
The PRPs signed on to a consent decree intended to solve the
environmental problem at the site. The team realized the
potential for new data which could impact the scope of the
work defined in the RAP. The team was charged with "solving
the problem" even though the new data could require
additional work or could result in elimination of or change
in the scope specified in the RAP.
• Team Approach
In order to develop a positive relationship among the
parties involved in the work (PRPs, contractors, USEPA,
IDEM, City of Seymour) aimed at solving the problem, the
focus was on building a team to do the work as opposed to a
rigid divisional approach. The theme was "Ours Is To
Remediate - Not To Litigate".
PROJECT INTERFACES
The number of interfaces and approvals required for a remedial
project under CERCLA is extensive. In the case of SRC the list
includes the following:
• The Trustee
• USEPA
• Indiana Department of Environmental Management
• City of Seymour
• USEPA Consultants (3-5)
• Geraghty & Miller in Plainview, NY
• Geraghty & Miller in Tampa, FL
• Trustee's Law Firm in Indianapolis (Sommer & Barnard)
• Outside Laboratories (2-4)
• Engineering Consultants to Geraghty & Miller (3)
In addition to the review and approval of engineering design,
there are three key documents utilized by USEPA and IDEM in
approving each segment of the work.
• Workplans
• Health & Safety Plans (HASPs)
• Quality Assurance Project Plans (QAPPs)
677
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Preparation of the documents, review by the agencies and their
consultants, responses to agency comments, resubmission of
documents, and ultimate approval was/is a lengthy, costly and
frustrating process, and the individuals doing the work must
understand and accept the process. Construction work cannot
proceed until concurrence is obtained from the agencies.
COMMUNITY RELATIONS
Community relations for a remedial project is extremely
important. A positive relationship can benefit the program. A
negative relationship can have a detrimental effect on the work.
In the case of Seymour, these relationships have been positive.
Actions taken to assure this have been as follows:
• Early and frequent meetings with key community leadership
• Developed a rapport with local press
• Community presentations
• Newsletter
• Information pamphlet
• Exhibit
• Site spokesman
RESULTS TO DATE
The results to date for the Seymour program are:
• Facilities will be installed in 35 months versus the
consent decree schedule of 58 months, in spite of
numberous changes to the scope of work resulting from
data developed during the RD/RA process.
• Cleanup objectives will be met
• No OSHA recordable injuries
• No adverse impact on public
• Positive community relations
• Cost will exceed budget
• Positive relations with agencies
• No stipulated penalties or fines imposed
678
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LESSONS LEARNED
This project was approached as a normal process plant design with
provision for the broad based team involvement and the public
relations needs. Numerous lessons were learned which will be
utilized on future CERCLA projects.
• Planning/Scheduling
The time and effort devoted to the early strategy
development was vital to the success of the project. Early
planning permits the team to focus on alternative approaches
which can improve the project. In addition, the team can
have an opportunity to anticipate potential problems and
prepare plans to react to the problems.
• Agency Approval Time
The amount of time required to get thru the overall cycle of
document preparation, agency comment, document modification,
resubmission and ultimate approval far exceeded
expectations. Most documents were submitted three times
before approval was obtained. In order to stay on schedule,
the PRPs proceeded at risk in numerous cases. This approach
was successful. No problems (redesign, etc.) was required.
Without the close team relationships among the parties this
would not have occurred.
• Field Mobilization
The plan called for mobilization of the field in the fall of
1989. In hindsight, the field was established prematurely.
The time required to obtain approval of submittals delayed
the start of field work.
• Design Data
The data provided in the RI was not adequate for design. A
complete set of current data was necessary to finalize
design. The time required to obtain approvals for HASPs,
QAPPs & Workplans to obtain the data was excessive and
delayed the work. In the future, adequate time must be
allowed for this data accumulation - or even better -
complete information for design could be collected at the RI
stage.
• Team Approach
The team approach was successful. After a period of
approximately 6 months, the team jelled and was a positive
factor in reacting to project needs. This was particularly
advantageous as new data dictated scope changes.
679
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• Intermediate Design Reviews
The intermediate design reviews were successful in
expediting the final approval. The final design was
submitted to the agencies for approval and placed for bid at
the same time. With agency concurrence, the major
construction contract was awarded less than three monthes
later.
• Cost
Cost results were disappointing. Several factors are worthy
of comment:
• Engineering cost was double the estimate. A lot of this
overrun is attributed to the multiple submissions of
packages to the agencies.
• Laboratory costs far exceeded expectations.
• EPA oversight costs are higher than expected.
• Long term operating/monitoring costs were underestimated.
• Changes to the scope of work were greater than
anticipated.
• Community Relations
The relationships in the community were a positive factor in
the successful the of the work. Division of resources to
handle problems in the community were not required.
680
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Advances in Hazardous Waste Site Alluvial Sampling
(Author(s) and Addre8s(es) at end of paper)
INTRODUCTION
Ground-water remediation at hazardous waste sites quite often fails to meet state
and federal established goals. In a recent pump-and-treat study of 19 active systems,
Haley et al. (1989) found that most systems had been operated longer than their initial
projection for clean-up. Estimates could not be made as to the time remaining for
ground water restoration. Inadequate design and failure to evaluate ground-water
remedial actions stems from the inability to understand complex processes involved in
the transport and transformation of contaminants in the subsurface environment.
Paramount to this understanding is an adequate hydrologic, physical, chemical and
biological characterization of the subsurface.
Conventional aquifer remediation systems are designed based on information
gained from ground-water samples. This approach is flawed in many respects. For
example, water samples alone provide little insight into mass transport limitations,
native microbial ecology, geometric distribution of contaminants, or the partitioning of
contaminants into liquid, solid or vapor phases (DiGiulio and Leach, 1990).
Conventional monitoring wells, when properly located and placed in sufficient
numbers, can accurately define a ground-water plume but are inadequate in locating
sorbed or entrained contaminants. This is because ground water collected from wells is
usually from the more transmissive sands and gravels while contaminants are often
associated with less conductive silts and clays. The long-term concentration of
contaminants in more conductive strata is controlled by contaminant diffusion from fine-
grained materials. Therefore, ground-water samples alone tend to underestimate the
true contaminant mass.
Core samples are extremely useful in evaluating not only the geometry of the
plume and less transmissive zones but also the sorption and desorption of
contaminants from these zones. Cores can be collected and evaluated in the laboratory
then the information can be used to complement remediation design.
When evaluating the feasibility of enhanced biological degradation for
remediation of subsurface contaminants, the collection of aquifer core material is
important for a number of reasons. Most subsurface bacteria are associated with solid
phase material and cannot be characterized by ground-water samples alone. In
addition, the use of microcosm studies to determine treatability parameters must be
conducted using core material that represents aquifer conditions as accurately as
possible. It is also important to describe the vertical distribution of contaminants so that
injected water carrying oxygen and nutrients is efficiently utilized.
It has been speculated that as many as ninety percent of the hazardous waste
sites are located in unconsolidated sediments and are contaminated to depths of less
than one hundred feet. Therefore, hollow-stem auger drilling and coring are the logical
choices for subsurface characterization in such geologic material.
681
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An accurate definition of contaminant plume geometry, however, has remained a
challenge for the engineer, especially in unconsolidated saturated zones where various
solvents or hydrocarbon contaminants and their associated microflora exhibit
concentration changes both laterally and vertically through time. Physical collection of
samples for snapshot characterization with conventional hollow-stem auger equipment
in heaving sediments has been virtually impossible. In hollow-stem auger drilling, when
the inner string of tools is raised, artesian pressure forces cohesionless sand up the
annulus of the auger, blocking the inner string of tools from reentering the auger. Once
this occurs, conventional sampling can no longer be performed.
New hollow-stem auger drilling and sampling techniques and sample handling
equipment have been developed to resolve these difficulties and are presented in the
following discussion (Leach et al., 1988,1989).
Cores are also required to assess the applicability of soil vacuum extraction for
remediation. When most of the contaminant mass lies a few feet above and below the
water table, as in underground petroleum tank leaks, it may be possible to lower the
water table and apply vacuum extraction for remediation. This technique can often be
faster and more economical than pump-and-treat remediation systems.
The selection of core sampling method is often based on time, cost, and
availability of drilling equipment rather than the site's hydrogeologic conditions (Keely
and Boateng, 1987a). Cores are greatly affected by the sampling method used;
therefore, core sampling procedures should be dictated by the intended use of the core
material. Once a core is removed from its subsurface environment, physical, chemical
and biological changes immediately begin to occur. These include moisture loss,
oxidation, gas exchange, and alteration to the biological community. Therefore, special
care must be taken to minimize these disturbances. The cost of core collection should
not play a major role in its use in designing a monitoring system. Often this preliminary
phase of aquifer remediation is a small percentage of the total project cost and can be
invaluable in assuring that the information collected leads to an efficient and lasting
restoration of the site.
BACKGROUND
Since the 1950's, conventional hollow-stem auger coring has generally been
accepted as the most efficient and reliable method of collecting unconsolidated in-situ
soil samples for contaminant and microbial characterization of hazardous waste sites.
There have been a number of recent articles written on hollow-stem auger drilling
procedures and their advantages in coring unconsolidated material (Perry and Hart,
1985, McRay 1986, Hackett 1987, Keely and Boateng 1987 a & b, Hackett 1988, and
Leach et al. 1988). Soil sampling equipment developed by essentially all the major *
hollow-stem drill manufacturers perform extremely well, even below the water table
682
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where the unconsolidated materials contain sufficient clay to maintain cohesive
properties (Central Mine and Equipment Company, 1987; and Mobile Drilling Company
1983).
There are a number of distinct advantages of hollow-stem auger equipment over
other conventional equipment used for drilling and sampling unconsolidated materials.
Most important is that no drilling fluids are used in the drilling or sampling process
during normal operations. Therefore, there are no interferences to samples or wells
from introduced fluids. Second, no lubricants are used on tool joints or couplings, so
organic materials are not introduced into the borehole during drilling.
Conventional hollow-stem auger soil sampling is performed by drilling to a
desired sample depth with two strings of tools, a pilot inner string with a lead bit inside
the hollow auger and the auger itself which has an outer bit and helical flighting to carry
the cuttings to the surface (Figure 1). The inner pilot bit assembly can be removed
when the desired depth is reached, leaving the hollow auger in the borehole to serve as
a temporary casing. Sampling can then be easily done by inserting a split spoon or
barrel sampler down the auger annulus and hydraulically pressing or driving the
sampler to the desired sample depth or until it has filled (Riggs, 1983). If a deeper
sample is desired, the inner pilot bit assembly can be inserted into the hollow auger and
the borehole drilled to the next sampling depth.
An alternate method of hollow-stem auger coring can be performed by using an
in-line bearing assembly on the drill spindle. This bearing allows the core sampler on
the inner pilot assembly to remain stationary as the outer auger drills to the desired
depth, minimizing sample disturbance (Figure 2). The core sampler is carried
downward with the augers as the drill advances and samples are pared as they are
pushed into the sampler. The advantage of this method of coring is that a continuous
profile of core material can be collected by retrieving the sampler each time it fills and
reinserting an empty sampler.
One disadvantage of this method is that if certain depths do not need to be
sampled, the sampler must be capped and used as a plug for the auger annulus during
drilling to a desired depth or the bearing assembly on the spindle must be removed and
the borehole advanced with the inner pilot bit assembly. Drilling with a capped sampler
will be slower than normal, especially in semi-consolidated sands and shales. However,
removing the bearing assembly is even more time consuming.
The above procedures work extremely well in unconsolidated sediments in the
unsaturated zone and in the saturated zone, as well, when enough clay is present that
cohesive properties of the soil are retained and the borehole remains stable. However,
numerous unsuccessful drilling techniques to capture totally cohesionless aquifer
material below the water table have been tried. Such sediment conditions are routinely
encountered in the saturated zone where artesian conditions exist. During hollow-stem
auger drilling, when the inner string of tools is raised, artesian pressure can force
cohesionless sand up into the annulus of the hollow auger (Figure 3). Once this occurs,
683
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££%£^-a-5&
^v.v-^^-.Q-r..^
a. Hollow-stem auger with center head
b. Hollow-stem auger with center head removed
c. Hollow-stem auger with sampler inserted
Figure 1. Conventional Hollow-Stem Auger Drilling and Sampling (after Riggs, 1983).
conventional sampling methods can no longer be managed since the sediment
materials have blocked the lower portion of the auger and sediments are too fluid to be
retained in the sampler. During retrieval, core material will fall out of the sampler and
sample depth integrity is destroyed by upward flow of sediments. This problem
prompted systematic development of a series of innovative modifications of hollow-stem
auger drilling and sampling techniques which allow sampling of fluidized sediments
while controlling heaving without adding borehole fluids to control the hydraulic pressure
head.
684
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DISCUSSION
In order to solve the problem of capturing sediment samples in flowing sands
with hollow-stem auger drilling techniques, modifications to the drilling equipment and
conventional drilling procedures were required. The borehole had to be drilled in such a
way so that when a desired sampling depth in flowing sands had been reached, the
annulus of the auger would be open and free of heaving sand until an in situ sample
could be collected. The obvious technique used by many drillers was to fill the annulus
of the auger with either drilling mud or fresh water to control the hydraulic head once
drilling proceeded below the water table. The inner pilot bit assembly could then be
removed and the sample collected through the column of drilling fluid. This obviously is
Auger
Drill Rig
Auger
Column
Barrel
Sampler
Bearing
Non-rotating
Sampling Rod
Auger
Head
Figure 2. Conventional Continuous Hollow-Stem Auger Coring (after CME, 1987).
685
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a. Auger Pilot Assembly
b. Sand Up-Flow by
Hydrostatic
Pressure
Pilot
Assembly
Auger
Column
• ' Retracted
Water Pilot {
Level Assembly
Saturated Sand
Formation **^
Rising Sands
Figure 3. Hollow-Stem Auger Blocked with Heaving Sand (after Hackett, 1987).
a very undesirable method for core sampling hazardous waste sites since the organics
in the drilling fluids can chemically react with the sample and destroy its integrity.
Several drillers have been successful collecting samples of flowing sands with
hollow-stem auger equipment by blocking the annulus of the auger bit with a machine
fitted non-retrievable knock-out plug (Perry and Hart, 1985). The borehole can be
drilled with this fitted cap by maintaining constant vertical pressure and not using the
inner pilot bit assembly. These plugs are normally made up of wood, metal or some
synthetic material such as PVC. Stainless steel is probably the most common because
of its strength and inertness.
Once the borehole has been advanced to the desired sample depth, the core
sampler (split-spoon or barrel sampler) is carefully lowered inside the auger with the
center rods until it rests on top of the knock-out plug. The drill spindle is then placed on
top of the center rods to apply vertical pressure on the knock-out plug and to dislodge it
as the augers are lifted about 12 to 18 inches. The augers are then fixed in this free
hanging position to allow unrestricted access to the sample. The sample is then
collected by reciprocally driving or hydraulically pushing the sampler downward with the
center rods. Consistent sampling with this method is not routine because the knock-out
686
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plug cannot be consistently dislodged into the side of the borehole. When this occurs
the knock-out plug continues to block the entry of sediment into the sampler as it is
forced downward. Another objection to using knock-out plugs is that it is not retrieved
and is left in the borehole to decompose with time. This foreign material could
adversely affect monitoring wells or the integrity of cores taken at a future date.
Modified Auger Head
To resolve these problems, an innovative clam-shell cap has been developed to
replace the knock-out plate or the use of drilling fluids (Figure 4). This cap can be used
equally well for sampling in flowing sediments or well construction inside the hollow
auger. The cap is mounted on a hinge which is welded to the auger head and is held
closed by vertical pressure as the auger is axially rotated and vertically advanced
Neoprene
Sand Seal
Auger Head
Clam-Shell
O-Ring Seal
Bit
Figure 4. Clam-Shell Capped Auger Head with a Sand Seal
687
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(Gillham et al., 1983). The original cap design contained two doors, each hinged on
opposite sides of the bit which literally open like a clam-shell. These have been used
very successfully for years and are still used by many drillers. However, when drilling to
depths in excess of 20 feet below the water table, they tend to leak and occasionally
sand may enter the auger and block the entry of the sampler. To remedy this problem,
the cap was redesigned in 1989 to contain a single door with a recessed face and an o-
ring seal around the shoulder of the recessed area. The door is now water tight and
samples of flowing sediments have been routinely collected at depths of 70 feet, 40 feet
below the water table.
An additional feature was added to the auger drilling tools to control flowing sand
during 1990. During deep sampling, in excess of 30 feet below the water table, there is
often high hydraulic pressure when the clam-shell door is opened with the sampler.
When this pressure exists in fine sands, the sands occasionally flow between the outer
wall of the sampler and the inner wall of the auger. As the hydraulic head stabilizes, the
sands settle and form a pack on top of the sample tube, thus blocking it in place and
preventing its retrieval.
To overcome this problem a special neoprene sand seal was installed in the joint
between the top of the auger head and the bottom of the lead auger (Figure 4). This
seal is held in place by compression of the outer edge of the seal between the top of the
auger head and an internal shoulder inside the auger tube. Therefore, it is located
about 6 inches above the inner face of the clam-shell door. The seal contains a hole in
the center which is slightly smaller than the outside diameter of the sampler tube,
forming a tight friction seal as the sampler is pushed through to open the clam-shell
door. This sand seal is extremely effective in preventing sand movement inside the
auger column during sampling.
As presently designed, it is not possible to re-close the clam-shell door on the
lead auger and continue drilling to the next sample depth once it has been opened, nor
is it desirable since contaminated soils generally enter the auger annulus when the
sampler is retrieved above the internal sand seal. Therefore, if deeper samples are
desired, the entire flight of augers must be carefully removed from the borehole without
rotation. The annulus of the augers, exterior flighting clam-door and all components of
the piston sampler must be thoroughly high pressure steam cleaned to insure integrity
of sequential samples. The borehole can then be refilled with clean washed sand or
uncontaminated cuttings and redrilled to the next desired sample depth. In many
situations, researchers prefer to move the rig a few feet and drill a new hole to the next
sample depth to insure sample integrity. Admittedly, the process is slow, but the tools
must be clean and the clam-shell door properly re-closed if high quality sampling is to
be consistently obtainable.
Piston Sampler and Modifications
The single clam-shell door and seals that were added to auger head are
extremely effective in holding cohesionless sediments in place until samples can be
collected. However, as noted earlier, conventional samplers, such as the split-spoon
688
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and barrel samplers are generally ineffective in flowing sediments. Samples are so
slurried in non-cohesive sands that the cored sample falls out during retrieval due to the
force of gravity.
This problem was partially solved when the Institute of Water Research,
University of Waterloo, Ontario, Canada, developed their special wireline piston sampler
(Zapico, et al., 1987). This sampler utilized a special piston inside an aluminum sleeve
which is inserted into a five-foot long core barrel. Once the sample is collected, the
sleeve can be removed from the core barrel after it has been raised to the surface. The
internal piston is attached to a wireline which is tautly fixed to something immovable at
the surface, usually the rig, after the sampler has been positioned at the bottom of the
borehole ready for sampling. Sampling is done by driving the sampler downward by
reciprocal pounding on the protruding end of the center rod at the surface. As the
sampler is driven, the wireline holds the piston in its initial position creating a vacuum on
the sample as it is collected. This vacuum is maintained on the sample during retrieval,
enhancing its recovery to the surface. The Waterloo sampler is also equipped with a
left hand threaded drive head so that the center rod can be decoupled from the sampler
before it is extracted from the sediments. The string of center rods is retrieved once
they are decoupled. The sampler is then retrieved using the wireline connected to the
piston. The Waterloo designers contend this retrieving technique will minimize sample
loss caused by the delay and vibrations that accompany center rod hoisting and
disconnection. Extensive field testing of the original Waterloo wireline piston sampler in
extremely fluid non-cohesive sands revealed problems of consistent sample recovery.
Sample material could not be consistently retained during retrieval, even under partial
vacuum with the piston; thus improved methods of sample collection were sought.
Several modifications of Waterloo's piston sampler design were made while
keeping their basic design principle of vacuum piston sampling. The aluminum sleeve-
cannister used by Waterloo was discarded in initial sampler design modifications; since
samples are normally to be analyzed in the field or in research studies, they are
aseptically collected and preserved in the field. However, the sleeve design has been
used in several special research studies where intact cores were required for special
laboratory microcosm studies. Special modifications of the sleeve design are discussed
later.
The authors' modifications of the basic Waterloo piston sampler are shown in
Figure 5. A standard Central Mine and Equipment Company (CME) four-inch I.D. by
five foot long standard thin walled barrel sampler was adapted to receive a wireline
activated piston with many similarities in design to that of Waterloo's. The components
of the piston include four pairs of neoprene seals separated by five brass spacers with
the end of the bottom brass spacer capped with two teflon wiper discs and a stainless
steel plate. The bottom brass spacer contains 8x1/4 inch Allen screws to adjust the
compression of the neoprene seals against the inner walls of the CME sample tube.
The top of the piston contains a swivel nut attached to the wireline which prevents
twisting the wireline during assembly and disassembly. The primary difference in
689
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1
2
3
4
5
Thin Wall Sample Tube
Drive Head
Ball Valve
Core Retainer Basket
Drive Shoe
6
7
8
9
Teflon Wiper Disc
Brass Bushings
Neoprene Seals
Swivel
Figure 5. Wireline Piston Sampler
690
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Waterloo's piston design and the improved design is that the number of neoprene seals
was doubled for better sealing capability; two additional Allen screws were added for
more uniform compression adjustment; and teflon and stainless steel wiper discs were
added to prevent contamination of core samples from the neoprene seals. Two
additional features include a pressure relief ball valve in the drive head and a special
strong retracting core retainer basket. Waterloo's sampler contained neither the
pressure relief valve nor the core retainer basket. The ball valve enhances core
recovery by reducing the shock created by compressing internal gases and fluids
between the piston and the drive head inside the sample barrel.
The addition of a strong retracting core catcher basket has also improved core
recovery by creating an additional core trapping capability. Core recovery has been
consistently above 90 percent with the added design features.
The modified wireline piston sampling procedure is used in combination with the
clam-shell auger head with a neoprene sand seal. It is inserted into the empty auger
tube after drilling to the desired sample depth with the clam-shell auger. The sampler is
slowly lowered with the center rods while maintaining only hand tension on the wireline
until it passes through the annulus of the sand seal and makes contact with the inner
face of the clam-shell door, thus preventing piston movement. The door is opened as
described earlier by maintaining vertical pressure on the center rods as the auger
column is lifted and caught with an auger fork. This procedure allows the sampler to
make immediate contact with the non-cohesive sediments without sediment disturbance
by hydraulic movement. The wireline is then pulled taut and fixed rigid before the
sampler is hydraulically driven or pushed into the sediments. The sampler is retrieved
with the center rods instead of the wireline as described by Waterloo. The authors'
prefer sampler retrieval using the rods while maintaining hand tension on the wireline
insuring a greater margin of safety should the sampler become stuck in the auger. If a
center rod pin should sheer or fall out, the driller would have the additional safety of the
wireline. In addition, if the sampler is retrieved by the wireline and the piston slips,
unwanted sample could be pulled into the sampler, or if the piston slips while the
sampler is in the water or air column above the sample depth inside the auger, these
fluids could be drawn into the collected sample, grossly affecting its integrity.
Once the sampler has been removed from the augers at the surface, the bottom
of the sampler should be immediately sealed by placing it in a plastic bag and taping the
top of the bag around the sampler cutting shoe, making it air tight. This minimizes
oxidation of the sample and helps preserve sample integrity for chemical and biological
analysis. The sampler should be held in its vertically retrieved position to preserve the
sample's structural integrity during sampler disassembly. Once the sampler drive head
has been removed, the piston can be withdrawn from the top of the sampler by pulling
the attached wireline while holding the sampler stationary. A fitted stainless steel or
teflon plug should then be immediately pushed down the inside of the sampler barrel
until it is in contact with the top of the sample. This minimizes aeration of the top of the
sample and traps the sample so its structure is maintained. The sampler tube can then
691
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be placed horizontally in a hydraulic extruder assembly and pressed out by pushing on
the teflon or stainless steel plug. Before hydraulic pressure is applied, the bagged drive
shoe core and retainer basket should be removed. Samples can then be collected
directly from the sample tube as they are extruded. Since the core generally has its
outer surface contaminated with oxidized material from the inner walls of the core
barrel, the wall material can be peeled away with a stainless steel paring device
attached to the end of the sample barrel (Figure 6). These procedures allow collection
of totally cohesionless materials in their native subsurface structural position.
Sleeve-Piston Sampler Modifications
In research and remediation studies, it is often necessary to collect intact cores in
the field and transport them to the laboratory for detailed analysis and experimentation.
To satisfy this requirement, a number of modifications to the Waterloo sleeve piston
sampler design was performed (Figure 7). Waterloo's sampler, as discussed earlier,
contains a removable aluminum sleeve which extends through the entire length of the
sampler tube with an internal piston used to hold a vacuum on the sample. The authors
were tasked to design a sampler with a 36-inch stainless steel sleeve that could be
easily separated in six-inch sections in the laboratory for analysis of vertical distribution
of contaminants. Each section was also fitted with temporary plugged ports which could
be plumbed with mininert valves in the laboratory for gas chromatographic analysis of
the time series degradation of hydrocarbon products.
2 in. I.D. S.S. Plate
Paring Cylinder
S.S. Plate
Figure 6. Core Paring Tool.
692
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(a)
(b)
(c)
5ft.
Bin.
1. CME Barrel Sampler 8.
2. Drive Head 9.
3. Ball Valve 10.
4. Core Retainer Basket 11.
5. Cutting Shoe 12.
6. Teflon Wiper Disk 13.
7. Brass Bushing
Neoprene Seals
Swivel
Wireline
Core Sleeve
Steel Bar
Piston
Figure 7. Modified Sleeve Piston Sampler
693
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The standard 4.00 inch I.D. by 5.0 foot CME sampler was modified to accept a
stainless steel sleeve in this design. Stainless steel sleeves were used because of their
inert properties. A prescored 3.25 inch O.D. by 3.00 inch I.D. by 36 inch long stainless
steel sleeve was fitted inside the standard CME sampler and held in position to receive
the sample by a tightly fitted steel bar located in the top half of the sampler tube. Since
noncohesive flowing sediment samples were routinely required, the sleeve was fitted
with a smaller designed version of the wireline piston. The CME barrel sampler tube
was cut at mid-section and fitted with a collar for easy disassembly and removal of the
stainless steel sleeve. In addition, the core retainer basket was modified so its spring
steel fingers would fit inside the bottom of the stainless steel sleeve.
Sampling is performed in the same manner as described earlier with the authors'
modified piston sampler. Once the sampler has been retrieved to the surface, the drive
head can be removed and the steel holding bar removed from the top of the CME barrel
sampler by pulling the piston out of the top of the sleeve. The piston can then be
removed along with the top half of the CME barrel sampler, exposing the top of the
stainless steel sample filled sleeve. Before removal of the sleeve, the top is packed
with sterile paper and covered with hot wax to prevent movement of the sample inside
the sleeve and minimize exposure to atmosphere. The sleeve can then be vertically
lifted out of the bottom half of the CME sampler, inverted and sealed with sterile paper
and wax as described above. The sleeves are then normally packed in ice and
transported to the laboratory in their natural vertical position to minimize separation of
the core.
This sampling technique allows a thorough evaluation of aquifer heterogeneity
and its impact on treatability of contaminants, even in cohesionless sediments that
previously could not be sampled without disturbance of the stratigraphic distribution.
Aseptic Glove Box Sampling
Site characterization of the subsurface distribution of oily phase hydrocarbons or
volatile organics and associated microflora in sediments requires a special aseptic and
oxygen free environment for capturing the samples as they are extruded out of the
sampler tube (Wilson et al., 1989 and Armstrong et al., 1988). When samples are
extruded from a sampler barrel in the natural atmospheric environment, unstable organ-
ics instantly volatilize and the sample absorbs oxygen, destroying its chemical and
biological in situ integrity. Preserving the native sample conditions can be achieved by
extruding and collecting the sample inside a specially designed field glove box contain-
ing an inert atmosphere (Figure 8). The sealed cutting shoe end of sampler barrel, as
described earlier, can be inserted into a specially constructed portable 1/2 inch thick
plexiglass glove box with dimensions of 2 x 3 x 4 feet. The box is constructed with a
special self-closing iris diaphragm for inserting and sealing the sampler barrel. The
glove box can be prepared for sample collection in approximately 30 minutes by filling it
with presterilized sample containers and sterile stainless steel core paring devices and
purging it with nitrogen gas to reduce the internal oxygen level below detectable limits.
694
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Sample Head
Space Analysis
Vent
Flushing Vent
Flow Regulator
and Indicator
Sample Tube
from Extruder
Iris Port
Figure 8. Field Sampling Glove Box.
Quality assurance tests of the field glove box were conducted by measuring a
series of 1,000 microliter samples of vented gas with a Varian Model 90-P gas
chromatograph equipped with a thermal conductivity detector. These tests verified that
the air-oxygen level inside the box after 30 minutes' purging with nitrogen is consistently
less than 0.02 percent on a volume per volume basis.
In preparation for field sampling, a sufficient number of sample containers were
sterilized in the laboratory and packed for the entire site investigation program.
Sterilization is done by thoroughly washing the containers and sealable lids then
autoclaving at a temperature of 120°C at 1 atmosphere of pressure for 60 minutes. As
the open containers and lids are removed from the autoclave, they are transferred to a
laboratory environmental chamber or glove box. The chamber is sealed and the interior
air is flushed from the box by purging with pressurized nitrogen gas for 30 minutes using
a flow rate of 2500 L/hr at pressure slightly in excess of atmospheric. This procedure
displaces gases inside the sample containers with nitrogen. After 30 minutes' purging
the lids are wrapped in aluminum foil then screwed hand-tight onto the sample
containers. The chamber is then opened and the sealed containers are removed and
packed for transport to the field.
At the sampling site, a field glove box is filled with a sufficient number of
presterilized sample containers and sterile, aluminum foil wrapped stainless steel core
paring devices to collect a minimum of nine feet of cored sample (three separate
barrels, each containing three feet of sample). Only three feet of sample is collected in
a five foot sampler because of hydraulic pressure limitations of the extruding equipment
when pressing out wet cohesionless sands.
695
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About ten minutes prior to filling the glove box with sample containers, at least
three paring devices are rinsed in 95 percent ethanol bath, placed in a stainless steel
pan and ignited to fire-burn dry the excess ethanol. They are carefully wrapped in
sterile aluminium foil and placed in the glove box. The box is then closed and purged
with pressured nitrogen gas as previously described for laboratory procedures, reducing
oxygen levels below detectable limits in 30 minutes. A positive pressure of nitrogen
flow through the box is maintained during all sampling activities.
After horizontally mounting the sampler barrel in the hydraulic extruder assembly,
the bag sealed cutting shoe is loosened to hand-tight. The glove box can then be slid
onto the sampler barrel by inserting the bagged cutting shoe through the iris diaphragm.
The cutting shoe and core catcher basket are removed and a sterile foil-wrapped paring
tool and holding bracket are unwrapped and screwed onto the sampler barrel. About
2.5 inches' soil should then be extruded through the 2.5 inch diameter paring tool and
broken away to expose an aseptic face on the core. Cores are then routinely collected,
sealed and numbered inside the glove box. Between each three-foot sampling event
the box can be removed from the sampler barrel and samples exited from the box
through the iris diaphragm, placed in an ice chest and covered with ice for preservation
and transport to the laboratory.
Once three three-foot samples have been collected and preserved, the box must
be opened, thoroughly cleaned and prepared for repurging. If noninterrupted sampling
is desired, a second glove box can be purged and made ready for additional sampling.
Additional innovative sampling activities can be performed inside the glove box
for detailed site characterization or research activities. Often small duplicate
subsamples are desired for quality assurance and very precise analysis of petroleum
hydrocarbons. Small 25 ml sterile disposable syringes approximately 0.4 inches in
diameter can be inserted directly into the core through the paring ring while pulling a
vacuum as the sample is retrieved. The subsample can then be placed in 40 ml sterile
VOA bottles containing 5 ml of
-------
determine the selective sampling depth for a number of boreholes and for selecting the
proper screen intervals for monitoring wells. The procedure works equally well in
identifying the vapor gradient in the unsaturated capillary fringe and the lower interface
in the saturated zone.
CONCLUSIONS
Ground-water remediation at hazardous waste sites often fails to meet
established goals because remediation design was based on inadequately
characterized matrices and the processes involved in remediation were not well
understood. Traditional designs of monitoring and aquifer restoration systems are
based on the results of water samples alone. Such information is fundamentally
inadequate in describing mass transport limitations, the indigenous microbial ecology
and the dimensional as well as the partitioned distribution of contaminants. In order to
obtain the type of information required to properly characterize a site for design of a
remediation system and track its effectiveness, it is necessary to collect subsurface
sediment samples. This can be extremely difficult, especially in cohesionless heaving
sediments. It is of paramount importance that sampling procedures assure that
chemical and biological integrity of the samples is maintained and that the information
they provide accurately describes conditions at the site.
Conventional hollow-stem auger drilling offers one of the best methods of
collecting unconsolidated sediment samples at contaminated sites. This coring method
works extremely well, even below the water table, as long as the sediments have
sufficient cohesive properties to remain stable. However, problems are often
encountered in cohesionless material particularly below the water table and
collecting samples from flowing sands has been virtually impossible.
These problems have been all but eliminated with the development of the clam-
shell capped auger fitted with an internal sand seal and the wireline piston sampler.
With the clam-shell capped bit, boreholes can be augered into cohesionless sediments
to desired sample depths and held stable until the piston sampler is inserted through the
sand seal and into underlying sediments, even when high artesian pressure is
encountered. The vacuum created by the wireline piston in conjunction with soil
entrapment by the core retainer basket allows more than 90 percent recovery of
cohesionless samples, even to depths of 40 feet below the water table.
Refinement of the design of Waterloo's sleeve-piston sampler allows samples to
be collected in prescored ported sleeves for efficient assembly of columns for research
and treatability studies, greatly enhancing remediation design. The sleeves can be
quickly sectioned and plumbed with mininert valves for laboratory tests of volatile
organics, hydrocarbon degradation products and microcosm assessment.
The development of aseptic sample handling techniques in a field glove box
containing an oxygen-free environment has revolutionized the capability for precise
697
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quantitative and qualitative chemical and biological analysis of subsurface materials.
Subsurface in situ conditions of cored sediments can be maintained during sample
collection except for pressure, temperature and light. These procedures have
significantly advanced the bioremediation design and assessment capabilities.
The glove box has an additional utility with the field capability of head space
measurement of volatile organics with field monitoring equipment. This technology can
save expensive drilling time in site characterization of contaminant plumes. The
technology can also be used for precise depth location for screened intervals during
monitoring well construction.
DISCLAIMER
This paper has not been subjected to Agency review and therefore does not
necessarily reflect the view of the U.S. Environmental Protection Agency.
698
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Techniques, Part 2: Case Histories. Ground Water, Vol. 25, No. 4, pp. 427-439.
Leach, L.E., F.P. Beck, J.T. Wilson and D.H. Kampbell. 1988. Aseptic Subsurface
Sampling Techniques for Hollow-Stem Auger Drilling. Proceedings of the Second
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and Geophysical Methods, Vol. I, pp. 31-51.
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Leach, I.E., D.H. Kampbell, J.E. Cloud and D.A. Kovacs. 1989. Statistical
Performance of a Procedure for Aseptic Sampling at Hazardous Waste Sites Using
Hollow-Stem Auger Drilling. Presented at the Tenth Annual Meeting of the Society of
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McRay,xK.B. 1986. Results of Survey of Monitoring Well Practices Among Ground
Water Professionals. Ground Water Monitoring Review, Vol. 6, No. 4, pp. 37-38.
Mobile Drilling Company. 1983. Mobile Drill Product Catalog, Indianapolis, Indiana.
Perry, C.A. and R.J. Hart. 1985. Installation of Observation Wells on Hazardous Waste
Sites in Kansas Using a Hollow-Stem Auger. Ground Water Monitoring Review, Vol. 5,
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Water Well Association-U.S. Environmental Protection Agency Conference on
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Wilson, J.T. and L.E. Leach. 1989. In Situ Reclamation of Spills from Underground
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Author(s) and Addresse(s):
Lowell E. Leach
Geological Engineering Consultant
909 W. 22 Street
Ada, OK 74820
(405)332-5320
Donald C. Draper
U. S. Environmental Protection Agency
Robert S. Kerr Environmental Research Laboratory
P.O. Box 1198
Ada, OK 74820
(405)332-8800
*U.S. GOVERNMENT PRINTING OFFICE:! 991 .5 <»B -1 8 7/2 5 6 i».3
700
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