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

                                           ii

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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?
                                IV

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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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8,
          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
                               VI

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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:
                               Vll

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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.
                              Vlll

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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
                               IX

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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.
                                x

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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.
                                XI

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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?
                          XII

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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
                          Xlll

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10,
          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.
                               xiv

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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.
                                xv

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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
                          xvi

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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.
                         xvn

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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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                            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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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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                             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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                                                                              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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                              CONFERENCE PROCEEDINGS
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 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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                             CONFERENCE PROCEEDINGS
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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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                                                                                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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                             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.
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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,
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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

-------
Figure 1  Site Location Map.

-------
                                         FORMER CREOSOTE
                                         UNIT SUMP
                                         OLD CREOSOTE/
                                         CCA UNIT
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                —  — SURFACE WATER DRAINAGE
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                                                                            DISCHARGE POND
                     Figure 2 Site Features Map.

-------
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-------
                                                    Conduct —
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-------
1990 Apr
May
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Aug
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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
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-------
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

-------
     •    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

-------
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

-------
                                                                                 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.

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     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


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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


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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

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     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

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             2870\28704-3
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 /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

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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.
                                  72

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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.
                       73

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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
                                74

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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.



                               75

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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.
                                76

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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
                                77

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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
                                             78

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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.
                                             79

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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
                                               80

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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.
                                             81

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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
                                             82

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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.
                                               83

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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
                                              84

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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

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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.

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                                        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
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                                                                                          IWC SITE BOUNDARY
                                                                                             PREPARED FOR

                                                                                       IWC SETTLING DEFENDANTS
                                                                                        FORT SMITH. ARKANSAS

-------
                                                                                                         ~l
CD
                                                                                       10--201
                                                                                       SEPARATION
                                                                    AREA C SLURRY WALL/SITE SLURRY
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                             NOTE:
                             SLURRY WALL AND FRENCH DRAIN
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                                                                                                     NOT TO SCALE
                         LEGEND
             It  I \  1 I < I  |
EXISTING FENCE

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PROPOSED EXTENDED BOUNDARY
AND NEW FENCE
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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

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              TYPICAL  CROSS-SECTION
                 OF  FRENCH  DRAIN
 NORTH
                                      CAP PERIMETER
                                      DRAINAGE  DITCH-
                                       FRENCH  DRAIN-
                                                      SOUTH
                                                         DETAIL
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                                        DRAINAGE DITCH
 RCRA CAP AND COVER
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                  NATURAL GROUND SURFACE

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  TYPICAL FR  NCH DRAIN
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NOTE: THIS FIGUF  IS NOT TO SCALE.
       Figure 5
   FRENCH DRAIN
  CROSS-SECTION
    AND DETAILS
     PREPARED FOR
IWC SETTLING DEFENDANTS
 FORT SMITH, ARKANSAS
                            93

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                   48' DIA. PRECAST CONCRETE
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                           BACKFILL
                           MATERIAL
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                                                                                           6' MIN.


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                                                                                                                          FRENCH
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                                                                                                                     •* "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

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                      TYPICAL CROSS-SECTION OF
                        AREAC SLURRY WALL
  NORTH
                SOUTH
                                        AREAC SLURRY WALL
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                  F|1 . X LANDFILL
                         AREA
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                                                 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

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                            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

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 NORTH
                           TYPICAL CROSS-SECTION
                            RCRA CAP AND COVFR
                             AND MONITOR WELL
                                      DETAIL
             PIKIMETCM

          DftAINAQE CHANNEL

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        SITE tLUHMY WALL
                                                                        SOUTH
                  FILL MATERIAL
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              SAND DRAINAGE LAYER
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               LANDFILL MATERIAL
            —=///=\\\=/// =///=
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             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

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                                                                                                                          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

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                  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

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                   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)
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                              Figure 3
             GENERALIZED SCHEMATIC FOR
             SEPARATE PHASE EXTRACTION
               WELL SYSTEM (SYSTEM "A")
                          Bayou Borrfouca
                          SlkJell, Louisiana
113

-------

DEPTH BELOW GROUND SURFACE
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                         Bayou Bonfouca
                         Slidell, Louisiana
114

-------
  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

-------
                  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

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  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
                                             128

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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
                                          129

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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
                                             131

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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.

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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
                                            144

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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.
                                            145

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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
                                           146

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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
                                            147

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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
                                          148

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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
                                         149

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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.
                                         150

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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

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                                                                             85

                                                                             1
86

1
87

1
88

1
89

3
90

2
91

1
92

1

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               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
•
•
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•• .
•• .
•.
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•
«•«•• Baseline
»•»•>• Conflict
..•^ Resource delay
Progress shows Bercent Achieved on Actual A
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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

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                             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

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                             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

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                               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

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                           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

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                             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

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             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.
                               163

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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
                                164

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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
175

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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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    03-28-91   J: \DIS\INDU5T\MGM60140\BVU-PS7.DWG
              VACUUM-ASSISTED
              DEWATERING
      <$>
       -7
CO
                                      TURBIDITY
                                      CURTAIN
               \\
                                                                                                                             Figure 2
                                                                                                         1989 PILOT STUDY LAYOUT
                                                                                                                    Bayou Bonfouca
                                                                                                                     Slidell, Louisiana

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     •     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

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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

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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

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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.
                                193

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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
                                  194

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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
                                 199

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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
                                201

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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,
                                               202

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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.
                                           203

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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.
                                            204

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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
                                          205

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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
                                              206

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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

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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

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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

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 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

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                                     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

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         A-3694
to
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              I OO
               HU
               60
           >   40

           CD
           UJ
           UJ
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              -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
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                                                                                                           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

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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

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  '""•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

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ro
                  6
                  £ «u

                  s
                                                                          EXISTING G.W.T
                                                          CMSTANCC IN fECT
                   URS
                         INC.
DISCRETIZATION OF TYPICAL 2D CROSS - SECTION
FIGURE  7

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CO
                URS
               CONSULTANTS. INC.
PRETREATMENT FACILITY FLOW DIAGRAM
FIGURE 8

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                             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

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                                    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

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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

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                            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

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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.
                               227

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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

-------
                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.
                                                 229

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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

-------
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.
                                            231

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                   SHOSHONE STREET
                 ©©©©©©©©©©©©
                                        West
                                        Bldg.
                      ©©©©©©©©©©©©©©<£>
                      ®©

-------
       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
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           South
         Warehouse
     East  Bldg.
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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

-------
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

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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

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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.
                                          244

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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:
                                          245

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MONTICELLO REMEDIAL ACTION PROJECT
Mlllslte Site
Preparation
Pre-axcavatlon
Activities at
Mlllsite
Repository Site
Preparation
Repotltoru
Design
Reclamation and
Cloteout
9 )
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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
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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
                             251

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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.
                              252

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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.
                        253

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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.
                       254

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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
                             255

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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

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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

-------
         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

-------
     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:
                              273

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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

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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
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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

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 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
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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

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                                                       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.

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                                                                             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.

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                                                             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.

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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

-------
            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

-------
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

-------
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
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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.
                                 335

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-------
CO
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                                         PICILLO SITE PLAN
                                             Figure 2

-------
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
                               338

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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
                               339

-------
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
                                340

-------
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
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FMAL EPAfRIDEM MSPECT1ON

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NOTES
I PER THE
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T DECREE. THE 'flVH
S USED TO BEGN THE
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PLETNO EXCAVATION
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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

-------
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

-------
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

-------
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

-------
     •    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

-------
                         TRIANGLE  CHEMICAL  CD,
Figure 1    Site Location Map
Figure  2    Vicinity Map  (from USGS Quad Orangefield TX-LA)
                               348

-------
                   1 ,  1-
                   », ..I »,
r^V-^Xjr'.
•* •'• •>—-" Or-?7- '•*•
- » * teiL* ' '- A  «• - •
^a^;^
Figure 3    1982 Aerial Photo before Immediate Response Action
                          349

-------
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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                                               *V  / T  J«>jf:~
Figure 5     Aerial  Photo During Remedial Action
                               352

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Figure 6   Collecting Sample Behind Garden Tractor w/Small Tiller
                                                           ».*•..,.
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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                   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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                         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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                             TOTAL INDICATOR COMPOUNDS IN MW «5
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                      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
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                                                              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
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                                             Figure 1
                                           South Ditch
                                         Typical Section

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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
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                    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

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                                  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
                = 
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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.
                                         383

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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.
                                              386

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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.
                                           40?

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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
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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

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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.



                                413

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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.
                                 414

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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%
                                  418

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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
                                419

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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

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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

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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

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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

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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

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                                         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
- /u-
X
*-
CO
<3 60-
15
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5 40 -
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                                               30
                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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       301
20 -
       10 -
    A  A
                         10
                                   20
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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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                                         434

-------
                                  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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                                               435

-------
                                            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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  Helen Kramer Lf
    S. MD Wood
   Cherokee Co.
      Moyers Lf
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 Cemetery Dump
    Metamora 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

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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:
                                           441

-------
(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
                                             463

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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)
                                             464

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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).
                                          469

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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).
                                           471

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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
                                              472

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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
                                                473

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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.
                                             474

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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
                                              475

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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.
                                               476

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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"
                                             477

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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
                                                478

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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
                                              479

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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.
                                           480

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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

-------
Figure 2. Sample Question Screen
                                 483

-------
  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
                                486

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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.
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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

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         • 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

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                                             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

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                        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
                              511

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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.
                               512

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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.
                              514

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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.
                               515

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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-
                                516

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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.
                                               518

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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:
                                                519

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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
                                               523

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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.
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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
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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
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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

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Figure 1.  Map showing the location of  the Uravan and Cotter mill sites.
                                    531

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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

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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
                               540

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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
                                 541

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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
542

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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.
                                 543

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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.
                                          555

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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.
                                        556

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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.
                                          566

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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.
                                       567

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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.
                                            570

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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
                           572

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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.
                                          573

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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
                                           576

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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.	
                                577

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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.
                               578

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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.
                                579

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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.
                               580

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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.
                                            581

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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


                                           585

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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.

                                         586

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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
                              590

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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.
                              592

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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.
                            593

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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.
                             594

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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.
                            595

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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
                              596

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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.
                            597

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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
                               598

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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.
                              600

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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
                                           602

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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.
                                         605

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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.
                                            606

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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
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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.
                                          616

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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.
                                            617

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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

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           Mich
00

CO
                                                FIGURE 2
                                       MILLCREEK SUPERFUND SITE
                                   DCE CONCENTRATIONS IN GROUNDWATER
SITE BOUNDARY
                                                                                                      \
                                                                                              Concentrations in ug/1
                                                                                                    600'

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                                 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
                    620

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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
                              622

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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

-------
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.
                          625

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                    ANNUAL PEAK FLOWS
               EXAMPLE HAZARDOUS WASTE SITE
              DRAINAGE AREA OF 255 SQUARE MILES
194819501952195419561958196019621964196619681970197219741976197819801982
                            YEAR
                        FIGURE 1
                  ANNUAL  PEAK FLOWS
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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

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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

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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
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/ 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

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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

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     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.
                                            642

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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.
                                           643

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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
                                      644

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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
                                          646

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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.
                                      648

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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
                                            649

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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
                                         650

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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.
                                         652

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                              Front Street
                           Flow Schematic
Sodium Hydrodds
 Holding Tank
                   FIGURE 1
                    653

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             INFLUENT
O3
                                                                                                                IIIOTOWr.R   J   I  C IHOTOWER    )
                                                                                                                            r   i
                                                                                                                                               TO SLUDGE HANDLING

                                                                                                                                                    SYSTEM
                                         TO SLUDGB HANDLINa
                                              SYSTEM
                                                                                FIGURE 2

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                                                          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

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        Removal Efficiency of 1,2-Mchloroethene/%-Methyl-2-pehtanone/Methylene Chloride
              2000-
    J750-
'C  '500
O
§
cn
 
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FIGURE 5
 657

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FIGURE 6
  658

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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
                                             660

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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.
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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.
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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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-------
        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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REFERENCES

Armstrong, J.M., W.M. Korreck, and LE. Leach. 1988. Bioremediation of a Fuel Spill:
Evaluation of Techniques for Preliminary Site Characterization. Presented at the
NWWA Petroleum Hydrocarbons Conference, Restoration Session, Houston, Texas,
November 1988.

Central Mine and Equipment Company.  1987.  Catalog of Product Literature, St. Louis,
MO.

DiGiulio, D.C. and L.E. Leach. 1990. Advances in Sampling Unconsolidated
Formations.  Presented at the Sixth Annual Waste Testing and Quality Assurance
Symposium, Washington, DC, July 1990.

Gillham, R.W., M.L Robin, J.F. Barker, and J.A. Cherry. 1983. Ground Water
Monitoring and Sample Bias. American Petroleum Institute, Publication 4367, 206 pp.

Hackett, G. 1987. Drilling and Constructing Monitoring Wells with Hollow-Stem Augers,
Part 1:  Drilling Considerations, Ground Water Monitoring Review, Fall, 1987, pp. 51-62.

Hackett, G. 1988. Drilling and Constructing Monitoring Wells with Hollow-Stem Augers,
Part 2:  Monitoring Well Installation. Ground Water Monitoring Review, Vol. 8, No. 1,
pp. 60-68.

Haley, J.L., C. Roe, and J. Glass. 1989. Evaluation of the Effectiveness of Ground
Water Extraction Systems, Proceedings of HMCRI's Superfund '89 Conference,
Washington, DC, November 1989.

Kampbell, D.H., J.T. Wilson and D.W. Ostendorf. 1990.  Simplified Soil Gas Sensing
Techniques for Plume Mapping and Remediation Monitoring.  Proceedings of the Fourth
National Conference on Petroleum Soils.  Lewis Publishers, Chelsea, Ml, pp. 125-139.

Keely, J.F., and K. Boateng. 1987a. Monitoring Well Installation, Purging and Sampling
Techniques, Part 1: Conceptualizations. Ground Water, Vol. 25, No. 3, pp. 300-313.

Keely, J.F. and K. Boateng. 1987b. Monitoring Well Installation, Purging and Sampling
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
National Outdoor Action Conference on Aquifer Restoration, Ground Water Monitoring
and Geophysical Methods, Vol. I,  pp. 31-51.
                                   699

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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
 Environmental Toxicology and Chemistry, Toronto, Canada, November 1989.

 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,
 No. 4, pp. 70-73.

 Riggs, C.O.  1983. Soil Sampling in the Vadose Zone.  Proceedings of the National
 Water Well Association-U.S.  Environmental Protection Agency Conference on
 Characterization on Monitoring of the Vadose Zone. Las Vegas, Nevada, pp. 611-622.

 Wilson, J.T. and L.E. Leach.  1989.  In Situ Reclamation of Spills from Underground
 Storage Tanks: New Approaches for Site Characterization, Project Design and
 Evaluation of Performance.  U.S. Environmental Protection Agency, Ada, Oklahoma.
 National Technical Information Service, PB 89-219976.

 Zapico, M.M., S. Vales, and J.A. Cherry. 1987.  A Wireline Piston Core Barrel for
 Sampling Cohesionless Sand and Gravel Below the Water Table. Ground Water
 Monitoring Review, Vol. 7, No. 3, pp. 74-82.

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

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