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

-------
                            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

-------
                                        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

-------
                                        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

-------
    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

-------
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

-------
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

-------
               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

-------
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

-------
     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

-------
               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

-------
                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

-------
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

-------
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

-------
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

-------
                 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

-------
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

-------
          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

-------
     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

-------
     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

-------
                                TABLE OF CONTENTS

                            CONFERENCE PROCEEDINGS



                                                                             Page No.

I.  CASE STUDIES

Composite Concrete Liners for Radioactive Wastes
Thomas Ambalam, Kaiser Engineers 	        2

Fast Tracking Remedial Design at the Cape Fear Wood Preserving Site
Thomas Clark, CDM	,..	••••••	        7

Ambient Air Quality Management at French Limited Superfund Site
Bruce Dumdei, ARCO	      23

Remedial Construction at the Industrial Waste Control Site, Fort Smith,
Arkansas
Santanu Ghose, USEPA	      78

Bayou Bonfouca Superfund Site Case Study of Selected Issues
Robert Griswold, USEPA				      108

Soil Remediation in the New Jersey Pinelands
Edward Hagarty, C.C. Johnson & Malhotra	 .      128

When is a Superfund Remedial Action "Complete"?  A Case Study of  the
Crystal City Airport RA Implementation and Transition to O&M
Bryon Heineman, USEPA	      138

WEDZEB Enterprises Remedial Action:  Planning for an Efficient
Remedial Action Completion
Tinka Hyde, USEPA		. . .	      161

The Landsdowne Radiation Site; Successful Cleanup In A Residential
Setting
Victor Janosik, USEPA	      167

Remedial Design Approach and Design Investigations at the Bayou
Bonfouca Site
Kevin Klink, CH2M Hill  . .		      174

Value Engineering Studies of the  Helen Kramer Landfill Superfund Site
Amy Monti, URS Consultants	 '. . .	       202

Remedial Action In and Around Light Industrial Activity at the Denver
Radium Superfund Site
Timothy Rehder, USEPA  	       229

Streamlining  Remedial Design Activities at the Department of Energy's
Monticello Mill Tailings NPL Site
Deborah Richardson, Chem Nuclear  	       238
                                         xx

-------
                                 TABLE OF CONTENTS

                             CONFERENCE PROCEEDINGS
                                                                              Page No.

Construction of a Kaolin Clay Cap for Buried Nuclear Waste
C.J. Schexnayder, Nello L. Teer Co	      249

Lessons Learned From Remedial Design of Helen Kramer Landfill
Superfund Site
Vern Singh, URS Consultants  	      277

Contract Security in Superfund:  An Open Dialogue Between Government
and the Remedial Construction Industry
James Steed, Formerly of Texas Water Commission  	      286

Remedial Design and Construction at the Charles George Landfill
Superfund Site
Robert K. Zaruba, USAGE	      292

II.   COMMUNITY RELATIONS

Bells and Whistles:  Community Relations During Remedial Design and
Remedial Action
Karen Martin, USEPA  	      308

Effects of Public Input and the Sampling Protocol on the Remedial Design
Process
Raymond Plieness, Bureau of Reclamation	      328


III.  CONSTRUCTION MANAGEMENT ISSUES

Remedial Design and Construction at the Picillo Farm Site
Mark Allen, Bechtel	      335

Remedial and Post-Construction Activities  at the Triangle Chemical
Company Site
Roger Brown, Weston	      347

Concrete Cover Applications in  Lined Drainage Ditch Construction
Camille Costa, Dynamac	      358

A Case Study  of Change  Orders at a Supefund Site: Geneva Industries
Site—Houston Texas
Paul Cravens, Texas Water Commission	      376

Transportation and Disposal of Denver Radium Superfund Site Waste
Richard Ehat, U.S. Bureau of Reclamation	      390

Cost Estimating Systems for Remedial Action Projects
Gordon  M. Evans, USEPA  	      399
                                          xxi

-------
                                TABLE OF CONTENTS

                             CONFERENCE PROCEEDINGS
                                                                              Page No.

 HTW Construction Documentation Report:  A Necessary Element in a
 Successful Remediation
 Heidi Facklam, USAGE  	      403

 Change Orders Can Ruin Your Day: An Analysis of Construction Change
 Orders in the Region 6 Superfund Program
 Mark Fite, USEPA	      409

 Remedial Action Bids and Cost Estimates
 Amy Halloran, CH2M Hill 	      420

 RAC to PRP: The Thin Gray Line
 Philip Kessack, ACRC  	      439

 COS: An Expert System for the Analysis of Changes Claims
 Moonja Park Kim, USACERL  	      472

 The Tunnel Syndrome Solution: Can It Be Applies to Cleanup Projects?
 Norman Lovejoy, Kellogg Corporation	      487

 The First Step for Strategic Environmental Project Management:
 Environmental Cleanup Project Contract
 James H. Pack, University of Nebraska		      500

 Permitting Superfund Remedial Actions or Nightmare on NW 57th Place
 Lynna Phillips, EBASCO	      518

State Oversight at Two Uranium Mill Superfund Sites in Colorado
Donald Simpson, Colorado Department of Health	      528

Mobilizing for Remedial Construction Projects
Gary Stillman, Weston	      550

Management of Change Order Conditions:  A Superfund Case History
Myron Temchin, West HAZMAT, (303) 792-2535  .......  PreBented At Conference But Not Published

Construction Disputes on Hazardous Waste Projects
Theodore Trauner, TCS	      558

Comparitive  Roles of the EPA and the Bureau of Reclamation During the
Construction and Implementation of the Lidgerwood, North Dakota
Superfund Project
Laura Williams, USEPA 	      570
                                         xxn

-------
                                TABLE OF CONTENTS

                             CONFERENCE PROCEEDINGS



                                                                              Page No.

IV.  GRQUNDWATER REMEDIATION

Pitfalls of Hydrogeologic Characterization
Steven Acree, USEPA	   Published, But Not Presented At Conference      589

Areawide Implementation of Groundwater Institutional Controls for
Superfund Sites
David Byro, USEPA	       601

Verifying Design Assumptions During Groundwater Remediations
Michael Grain, USAGE	       606

Hydrologic Risk Aspects of Hazardous Waste Site Remediations
William  Doan, USAGE  	       622

Design and Construction of the Groundwater Treatment Plant at the
Conservation Chemical Company Site
Peter Harrod, ABB Environment Services  	       642

The Construction and Operation of the New Lyme Landfill Superfund Site
Groundwater Treatment Facility
Donna Hrko, USAGE	       659

Arsenic  Removal at the Lidgerwood Water Treatment Plant
Harry Jong, Bureau of Reclamation	       668

Successful Program Management for Remedial Design/Remedial Action
James Kilby, Monsanto	       673

Advances in Hazardous Waste Alluvial Sampling
Lowell Leach, USEPA  	       681

A Comprehensive Groundwater Quality Assessment and Corrective Action
Plan for a Single Hydrologic Unit with Multiple Contamination Sources
C.M. Lewis, USDOE	       701

A Perspective for NAPL Assessment and Remediation
Mark Mercer, USEPA	       735

Optimizing and Executing a Multi-Faceted Remedial Action Plan
Dennis Peek, Geraghty & Miller  	       748

V.  HEALTH AND SAFETY

EPA/Labor Health  and Safety Task Force
Joseph Cocalis, USEPA	       760
                                         xxin

-------
                                  TABLE OF CONTENTS

                              CONFERENCE PROCEEDINGS
                                                                                 Page No.

 Airborne Exposure at an Acid Sludge Remedial Site
 Stephen Davis, IT Corporation	      766

 An Overview of the NIEHS Superfund Worker Education and Training Grant Program
 Denny Dobbin, NIEHS	      785

 Hazardous Waste Sites: Worker Protection Perspectives
 John Moran, LHSFNA  	      814

 Crisis in the Fire Service
 Les Murphy, IAFF	      827

 Worker Protection Standard
 VlCki SantOrO, USEPA (201) 321-6740  	   Presented At Conference But Not Published

 USEPA Generic HASP
 Vicki SantOrO, USEPA (201) 321-6740  	   Presented At Conference But Not Published

 USEPA Health & Safety Certification                                               *
 Vicki SantOrO, USEPA (201) 321-6740  	   Presented At Conference But Not Published

 Overview of Hazard Waste Health and Safety Requirements
 Rodney Turpin,  USEPA (201) 321-6741	   Presented At Conference But Not Published

 VI.  POLICY/MANAGEMENT ISSUES

 Superfund — Program Standardization to Accelerate Remedial Design and
 Remedial Action at NPL Sites
 Shaheer Alvi, USEPA	      838

 Environmental Protection Agency Indemnification for Remedial Action
 Contractors
 Kenneth Ayers, USEPA 	      850

 Innovative Design Review and Scheduling Tools: Potential Benefits to
 HTW Remedial Projects
 Gregg Bridgestock, USACERL  	      859

 Basic Principles of Effective Quality Assurance
David E. Foxx, Foxx & Associates	      885

Specifications for Hazardous and Toxic Waste Designs
Gregory Mellema, USAGE  	      889

Lessons Learned  During Remedial Design and Remedial Action Activities
at Superfund Sites
Dev Sachdev, EBASCO	       895
                                          xxiv

-------
                                 TABLE OF CONTENTS

                             CONFERENCE PROCEEDINGS
                                                                              Page No.

Forecasting Staffing Requirements for Hazardous Waste Cleanup
Robert Salthouse, Logistics Management Institute	       907

The Effects of the Davis-Bacon Act on the LaSalle Electrical Utilities
Phase I Remedial Action
David Seely, USEPA	       919

Surety Bonds — Superfund Projects
August Spallo, USAGE  	       938

Remedial Design Schedule Management
Charles F. Wall, EBASCO	       970

Remedial Management Strategy
Thomas Whalen, USEPA	      1022

Acquisition Selection for Hazardous Waste Remediation
William Zobel, USEPA  	      1031

VII.  PRE-DESIGN ISSUES

The Importance of Pre-Design Studies in Superfund Remediation
Jeffrey Bennett, Malcolm Pirnie, Inc	      1042

RI/FS and ERA Impacts on RD/RA at Superfund Sites
William Bolen, USEPA  	      1060

Excavation/Off-Site Incineration RD/RA - Optimization of the
Planning/Investigation Process Based on the Two NPL Case Studies
John Gorgol, EBASCO  	      1087

Writing a Record of Decision  to Expedite Remedial Action:  Lessons from
the Delaware PVC Site
Stephen Johnson, DE DNR	      1096

Site Characterization Data Needs for Effective RD and RA
John Moylan, USAGE	      1103

New Bedford Harbor, Massachusetts Review of the Remedial
Investigation/Feasibility Study Process and Its Impact on Remedial
Design/Remedial Action
Mark Otis, USAGE	      1110

The Pre-Design Technical Summary
Kenneth Skahn, USEPA  	      1118
                                         XXV

-------
                                 TABLE OF CONTENTS

                             CONFERENCE PROCEEDINGS



                                                                                Page No.

 VIII. DESIGN ISSUES

 Accelerating the ROD to Remedial Action Process:  Sand Creek Industrial
 Superfund Site (OU1), Commerce City, Colorado
 Brian Pinkowski, USEPA	 .	 . ,	     1125

 Remedial Design of Superfund Projects -- What Can Be Done Better?
 John Holm, USAGE	 .	_.'.'.  .	     1141

 Constructability  Input to the HTRW Process
 James Moore,  USAGE		     1148

 Applications of a Design/Build Advisor Expert System to Environmental
 Remediation Projects
 Thomas Napier,  USAGE	     1162

 "Conforming Storage Facilities" Remedial Construction Activities
 D.M. Velazquez, DLA	   Published, But Not Presented At Conference     1 173

 IX.  TREATMENT TECHOLOGIES

 A New Horizontal Wellbore System For Soil and Groundwater Remediation
 Ronald BittO, Eastman Christensen  	   Published, But Not Presented At Conference     1186

 Soil Bentonite  Backfill Mix Design/Compatability Testing:  A Case History
 Jane Bolton, USAGE	     1203

 Remedial Design for Solvent Extraction of PCB Contaminated Soils at
 Pinette's  Salvage Yard
 Steven J. Graham, EBASCO (617) 451-1201 	  Presented But Not Published At Conference

 United Creosoting Company Superfund Site, A Case Study
 Deborah  Griswold, USEPA	     1219

 Considerations for Procurement of Innovative Technologies at Superfund
Sites
Edward Hanlon,  USEPA	     1232

Trial Burn at MOTCO Site, LaMarque, Texas
MaryAnn LaBarre, USEPA	     1256

Construction of Groundwater Trenches
Gary Lang, USAGE 	     1268

European Soil Washing for  U.S. Applications
Michael Mann, Geraghty & Miller	     1285
                                          xxvi

-------
                                 TABLE OF CONTENTS

                             CONFERENCE PROCEEDINGS
                                                                               Page No.

Remedial Design Procedures for RCRA/CERCLA Final Covers
Donald Moses, USAGE	      1300

The Challenge of Treating Superfund Soils:  Recent Experiences
Carolyn Offutt, USEPA  	      1330

Tower Chemical: Remedial Design for a Small But Complex NPL Site
Victor Owens, EBASCO  	      1346

The Importance of Test Fills for the Construction of HTW Caps and Liners
David Ray, USACE  	      1360

Nuclear Waste Densification by Dynamic Compaction
Cliff Schexnayder, NellO L. Teer CO	   Published, But Not Presented At Conference     1 382

USEPA  Region II Treatability Trailer for Onsite Testing of Soils and
Sludges
William  Smith, CDM	   Published, But Not Presented At Conference     1409

Bioremediation of Toxic Characteristic Sludges with Biological
Liquids/Solids Slurry Treatment
Donald Sherman, RTI	   Presented At Conference But Not Published

Summary of Issues Affecting Remedial/Removal Incineration  Projects
Laurel Staley, USEPA	      1442

Remediating TCE Contaminated Soils: A Case Study of a Focused RI/FS
and Vacuum Extraction Treatability Study
Winslow Westervelt,  Gannett-Flemming Inc	      1458
                               xxvn

-------
I. CASE STUDIES

-------
                       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.

-------
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

-------
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.

-------
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.

-------
                                                  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

-------
                            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

-------
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

-------
between August and September 1990 that included a design report and plans and specifications for
site remediation.6

Summary of the Remedial Investigation.  During the remedial investigation, CDM discovered that
records concerning the exact  nature and  quantity of wastes disposed onsite were  not  available.
Information obtained from representatives of the Cape Fear Wood Preserving Company, however,
indicated  that  the only chemicals used  in  the wood preserving  processes were creosote and
wolmanizing salts containing a copper-chromium-arsenic mixture.  The type of carrier oil was not
identified.

Past investigations indicated extensive site contamination with polycyclic aromatic hydrocarbons
(PAHs), and to a lesser extent, copper, chromium, and arsenic. The soil was contaminated in several
areas.  In addition, volatile organic compounds (VOCs) resulting from a leaking underground storage
tank were observed at the site  in a localized area. Even though most of the soil contaminants have
a low  water solubility, the close proximity of  the groundwater to  land  surface had apparently
facilitated the migration of contaminants into the groundwater system, as evidenced by contaminated
groundwater samples.

Summary of the Feasibility Study.   As part of the feasibility  study project, cleanup goals were
derived for chemicals of concern at the Cape Fear Site. Chemicals of concern and exposure pathways
had been detailed in a previously conducted risk assessment and were reviewed where pertinent  to
the derivation of cleanup goals. Potential remedial technologies were also identified and screening
was conducted to eliminate treatment  and  containment options that were  not  feasible or were
impractical.

Summary of the Record of Decision.   The ROD was issued by EPA in June 1989  and mandated
remediation of  groundwater, soils, sediments, and surface water bodies. In addition, various waste
materials stored onsite were targeted for cleanup. EPA's preferred remedy for soils was either soil
washing or low temperature thermal desorption to remove organic contaminants followed by either
soil washing or solidification to address the inorganics.  EPA desired to determine the most suitable
remedy for mitigation of soils based on results of  treatability studies to be conducted during the RD.

Summary of the Remedial Design.  A design was  developed to incorporate EPA mandates identified
in the ROD. A  flow diagram showing the various mitigation pathways is presented in Figure 3. This
flow schematic  formed the basis of resulting design documents.  In addition,  CDM performed
treatability studies and conducted various field investigations at the site during the remedial design.
The resulting product of the RD included a design report and plans and technical specifications for
site remediation.

DISCUSSION

Fast-Tracking  Remedial Design Projects

Fast-tracking is a  technique used to optimize project schedules by manipulating the  tasks required
to complete the overall project.   Fast-tracking  generally eliminates and/or  rearranges the tasks
involved in a project. Because tasks are  often interrelated, eliminating tasks must be done carefully
to avoid problems later in the project.  Rearranging the order  or timing in which the tasks are
performed can expedite the overall project schedule. The less complex a project, the more amenable
it is to fast-tracking.  In addition, projects that display particular traits are more easily accelerated
using fast-tracking techniques. These characteristics and their application to the Cape Fear Site are
discussed below.
                                              9

-------
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

-------
low bids exceeding the budgeted subcontract amount. Field activities were subsequently delayed.

In March 1990, an additional change in scope was made.  In order to be eligible for remedial funds,
a design, complete with drawings and specifications, needed to be completed by the end of the third
quarter of the fiscal year. Therefore, to ensure funding; EPA divided the remedial design efforts into
two operable units.  The first phase, which was not dependent on the results of field work and
treatability study, would be expedited and completed by June 30, 1990, and the design for the second
phase would be completed  no later than October 31, 1990. CDM  then prepared and  submitted a
preliminary design report for the first phase of the design on April  16, 1990.

Shortly thereafter, EPA decided to combine the remedial design of  both operable units, and sought
to have final design documents submitted to EPA by the end of September 1990.  This gave CDM
approximately 5 months to complete the design. To expedite the schedule, it was necessary for CDM
to modify the critical path schedule and associated tasks. After careful evaluation of work assignment
tasks, CDM developed a fast-track schedule for implementing the remedial design. It was imperative
that no delays in the field work or the treatability study occur and  that CDM receive concurrence
with EPA, the State of North Carolina, and the U.S. Army Corps of Engineers on critical design issues
at the 30% design phase. In addition, EPA  and peer review would  be reduced from four weeks to
three weeks. This latest change in scope required that all field work  begin on April 30, 1990  and the
treatability study start on May 7, 1990. The final scope of work,  dated  April  1990 included the
results of fast-tracking and is presented in Table 2.

Techniques Used for Fast-Tracking

Virtually all remedial design projects can take  advantage  of fast-tracking techniques to expedite
schedules; however, certain fast-tracking techniques used on some projects may not be applicable to
others.  EPA has identified the following techniques that can be used to fast-track remedial design
projects.7

Reduce the Detail Required in the Design Documents. This may include eliminating detailed design
drawings (plans) and specifications and instead preparing a site layout drawing and a basic description
of the work to be performed. This works best for simple remediation sites, such  as pump and treat
systems or excavation and disposal  of small quantities of contaminated soil.  If  the recommended
cleanup is more complex, the use of "performance" type specifications can be used. Performance
specifications are written to specify certain performance criteria that a contractor must meet, and do
not involve detailed equipment specifications that require more time to develop.

Use Standardized Sets of Specifications.  Many engineering firms have developed standard "generic-
type"  specifications that are used from one project to another. In  addition, various equipment
manufacturers have prepared standard sets of  specifications  for  specific treatment  equipment.
Caution should be exercised in their use, however, since they are general in nature, and the proper
modifications should be made to incorporate site-specific conditions and issues.

Use Existing Plans.  Where possible, information from existing plans previously prepared during the
remedial investigation and feasibility study  stage should be used, such as a Health and Safety Plan,
Quality Assurance Project Plan, and Community Relations Plan.  Although the actual plans may not
be reusable, information relating to site conditions and nature of contamination may be used to help
prepare the corresponding plans for the remedial design.

Provide Project Continuity.  For an EPA-lead site, considerable time is saved in the transition from
the ROD to remedial design  if the same  EPA contractor performs the  remedial investigation,
                                               11

-------
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

-------
 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

-------
 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

-------
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
             V  SANDERS
               ARESIDENCE
               V
                  \
  JACKSON
RESIDENCE
CCA RECOVERY
        SUMP
                                FORMER CCA
                                UNIT
                  SEASONAL
                   -iinT
                *  SWAMP
                           STORAGE
                           TANKS
                                                    FORMER LAGOON
                                                        STORAGE TANKS
                	 CLEARED AREA

                —  — SURFACE WATER DRAINAGE
100
                                                                                    100
                                                                         SCALE IN FEET
                                                                            CONCRETE  PLANT
                                                                            DISCHARGE POND
                     Figure 2 Site Features Map.

-------
00
                       CCA SALT CRYSTALS
                                                      PICKED UP
                      [SOLIDIFIED CREOSOTE)-
                   EXCAVATION
                       ASBESTOS INSULA
TTONJ-
                      | UNDERGROUND TANK^-
                  EXCAVATION
                        ABOVE GROUND
                         TANKS/PIPING
                LIQUID CONTENTS
                   REMOVED
1

1
J
;KACED| —

~| 	











LIQUID CONTENTS
REMOVED
1 	 1 	 1








J~~

TANK





» RCRA
• LANDFILL



CUMBERLAND
COUNTY SOLID
WASTE FACILITY
IF CONTAMINATED

                                     REMOVED
                                                                                 TANKS
DECONTAMINATION OF
 TANKS AND PIPING
TANKS
TESTED
                                                                                                                                   IF CLEAN
                                                                                               DECON. WASHWATER


                                                                                                            LIQUID CONTENTS
                                                                                               METAL CUT AND SOLD FOR
                                                                                             SCRAP OR SENT  TO CUMBERLAND
                                                                                              COUNTY SOLID WASTE FACILITY
                                                                                                               SLUDGE
                                                              CONTAMINATED FINES
                                                                                                             UOUB CONTENTS
                                                                       RAW SOIL
                                                                                                       OFFSITE METALS
                                                                                                      TREATMENT FACILITY
                             CONTAMINATED GROUNDWATER

r-






1
ETC





EQU

, ,

ALIZ



WASHING


CLEAN SOIL


WASHWATER ,

ACTIVATED CARBON ADSORPT

BIOTI
SO
t
RETURNED TO
EXCAVATION
[CLEAN PRODUCT

REATMENT OR REMANING 1
ON SITE WAbitb | 	 1
ON SYSTEM 	 -7
          EQUALIZATION BASIN TRANSFER PUMP
                       90 EXTRACTION
                       WELLS & PUMPS
                     (SURRCIAL AQUIFER)
                                                                                    .
                                                                                  T f
                                                                                  Iff
                                   SLUDGE
                                                                                     _ pREC1p|TATED _
                                                                                     SLUDGES fc WASTE
                                                                                         STREAMS
                                                                                       (IF REQUIRED)
                                                                                               ACTIVATED
                                                                                               CARBON
                                                                                               FILTER(S)
                                                                                            SYSTEM
                                                                                          — EFFLUENT
                                                                                            SAMPLE TAP
                                                                                                                                            100 GPM MAX.
                                                                      TREATED  WATER f*
                                                                        HOLDING TANK
                            EFFLUENT TRANSFER
                                  PUMP	
                                                                                                            ;RA FACILITY
                                   ONE  EXTRACTION
                                     WELL  * PUMP
                                    (DEEP  AQUIFER)
                                                 Figure 3  Remedial  Design Process Flow Diagram.

-------
                                                    Conduct —
                                                    Field Work
 1989
Signed
Original
Work
Asstgment
Form to
Begin
Work

Original
Scoping
Meeting

*
J
nt

*


cw
Sub
Dra
Proj
Plai
GDI
Sub
Fire
Pro
Plai

Oct
LJl . , ...
mits
Ft
led
is
L4
imits
y
lect
is

Nov




Dec


Jan | Fee

FPA
Changes to
Phase Site
Design
Approach

Mar




Apr My


Submits
Preliminary
Design Report
for Phased Site
Design Approach
1
1
Jun


Jul
1

*

Conduct 	 1 30% -J
Treatability Design
Study Meeting
COM 	
Submits
Preliminary
Design Repor
and Draft
Design
Documents
to EPA
1
t

Sept


                      1990
                                          Changes to
                                          Single Site
                                          Design Approach
Submits
Final Design
Documents
to EPA
                                   Figure 4 Project Timeline.

-------
1990 Apr
May
Jun
Jul
Aug
Sept
Oct
TASK NAME
Reissue Field Bid Packages
Bid Period-Field Subcontract
Eval/Awaid Field Subcontract
Field Contract Execution
Conduct Field Work
Analytical Testing-Field Data
Award Treat Study Subcontract
Treat Study Contract Execution
Conduct Treat Study
Conduct Endangered Species Suv
Evaluate Data & Dev 30% Design
Present 30% Design to EPA
Prepare Fact Sheet No. 1
Submit Fact Sheet No. 1
Perform GW Extraction Analysis
Design GW Treatment System
Design Sol Treatment System
Prepare Design Report
Submit Design Report
EPA Review Design Report
Prepare 90% Plans/Specs
Submit 90% Plans/Specs
EPA Review 90% Plans/Specs
Prepare Fact Sheet No. 2
Submit Fact Sheet No. 2
Prepare 100% Plans/Specs
submit 100% nans/specs
Project Completion and uoseout

4



























2 J
•
^


























» 1


D

























62



H**
























3 3






•
r




















o •







1




















r 1




























4 :









r1


















212




























8 <




'"]



UwwJ



















t 1




























1 1





nl






















82




























5




























2










F


n














9 1











•
a:

C

5




1






6 2












-J
•
p


ti-J
••••••


W







•3 :








UtVHf







s.
r~i










10 1








p»«m*l








M**^>l


^•^L







5 1








•v^nl









•

J







3 2








T










>s:*


>SSi>
H»




'0 2



















ssss


a»;
r
•



•7



















jj


J





3

























SSB


10

























^
4

17


























»
m
24



























->XSS
sss
1




























8



























!±j£
15




























         Figure 5 Final Project Schedule.

-------
Table 1   Tasks included in the orginal scope of work (January 1990).
            Original Scope of Work

            1.     Project Planning
            2.     Field Data Acquisition/Sampling and Analysis
            3     Treatability Study - Pilot/Bench Scale Tests
            4.     Data Evaluation
            5.     Preliminary Design
            6.     Intermediate Design
            7.     Prefinal/Final Design
            8.     Design Support Activities
            9.     Value Engineering
            10.   Community Relations Support
            11.   Bid Package Preparation
            12.   Project Completion and Closeout
Table 2  Tasks included in the final scope of work (April 1990).
            Final Scope of Work

            1.    Project Planning
            2.    Field Data Acquisition/Sampling and Analysis
            3.    Treatability Study - Bench Scale Test
            4.    Data Evaluation
            5.    Preliminary Design - presented at 30% Design Meeting
            6.    Final Design
            7.    Design Support Activities
            8.    Community Relations Support
            9.    Project Completion and Closeout
                                       21

-------
                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

-------
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

-------
     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

-------
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

-------
                         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

-------
        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

-------
CO
                    ioe.
                     R1C
                                                               FIGURE 2

                                        FRENCH LIMITED BIODEGRADATION DEMONSTRATION

                                               FLUX CHAMBER RESULTS  GC/MS DATA
                                HL
                                07'30/87 14:I?:00
                                                                                           i'luMS   I TO 8WU
                                                                                                       262M30.
                                                                       17:05
                                                                                                     i'l'i'i  iCnll

-------
                                                                                  TABLE  3

                                                                    FRENCH LIMITED BIODEGRADKTION DEMONSTRATION
                                                                 TIME-INTEGRATED IMPACT NONITORINT, RLbULTS  SUWtARY
                                                                      Concentration ii. facts Per Billion (ppb)
CO
GO
Coapound                    TLV        Li ait

CholoroMthane             50,000        0.6
BroaoMthane                5,000        0.3
Vinyl Chloride              5,000        0.4
Chloroethane            1,000,000        0.4
Hethylene Chloride         50,000        0.3
Acetone                   750,000        0.5
Carbon Disulfide           10,000        0.4
1,1-Dichloroethene          5,000        0.3
1,1-Dichloroethane        200,000        0.3
Trans-l,2-Dichloro-       200,000        0.3
  ethene
Chlorofora                 10,000        0.2
1,2-Dichloroethane         10,000        0.3
2-Butanone                200,000        0.4
1,1,1-Trichloroethane     350,000        0.2
Carbon Tetrachloride        5,000        0.2
Vinyl Acetate              10,000        0.3
Broaodichloroethane                      0.2
1,2-Dichloropropane        75,000        0.2
Trana-l,3-Dichloro-         1,000        0.3
  propene
Trichloroethene            50,000        0.2
DibroBOchloroMthane                     0.1
Lagoons id*
Actual
Concentration
2
BDL-2 . 4
BDL
BDL-132
BDL
BDL-7 . 7
BDL-46
BDL-134
BDL-3.5
BDL-225
BDL-483
BDL-9 . 4
BDL-214
BDL-122
BDL-1 . 4
BDL-1 . 1
BDL-9 . 1
BDL
BDL-110
BDL
BDL-88
BDL
Highest
Concentration
% of TLV
0.005
-
3
-
0.015
0.006
1
0.7
0.1
0.24
0.009
2
0.06
0.0004
0.02
0.1
-
0.15
-
0.18
-
Most Frequent
Concentration
Range
BDL
BDL
BDL
BDL
BDL
BDL- 10
BDL
BDL
BDL-1 0
10-50
BDL- 10
BDL- 10
BDL- 10
BDL
BDL
BDL
BDL
BDL-10
BDL
BDL-10
BDL
                                                                                                                                    Fenceline
Actual
Concentration
Range
BDL
BDL
BDL-1 . 8
BDL
BDL- 3. 9
BDL-31.1
BDL-56
BDL
BDL-5.9
BDL-1 6
BDL- 3 . 4
BDL-9 . 6
BDL-61.4
BDL-0.5
BDL-1 . 1
BDL-1. 0
BDL
BDL-2. 0
BDL
BDL-1 .2
BDL
Host Frequent
Concent rat ion
3
BDL
BDL
BDL
BDL
BDL
BDL-10
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL
                         Rotes:
                              1. Based on normal 20-liter air volu»e.
                              2. BDL entries indicate levels were below detection liaiits.
                              3. Concentration level ranges used: BDL, BDL-10 ppb, 10-50 ppb, >50 ppb.

-------
                                                                         TABLE  3  -(continued)
                                                                    FRENCH LIMITED BIODEGRADATIOR DEMONSTRATION
                                                                 TIME-INTEGRATED IMPACT  HDWITORIHG RESULTS SUWIART
                                                                      Concentration in Parts  Per Billion  (ppb)
CO
CO
Compound                    TLV

1,1,2-Trichloroethane      10,000
Bensene                    10,000
Cis-1,3-Dichloro-           1,000
  propene
2-Chloroethyl Vinyl
  Ether
Bromoform                     500
2-Hexanone                  5,000
4-Methyl-2-Pentanone       50,000
Tetrachloroethene          50,000
1,1,2,2-Tetrachloro-        1,000
  ethane
Toluene                   100,000
Chlorobeniene              75,000
EthyIbenzene              100,000
Styrene                    50,000
Total lylene              100,000

Detection
Limit1
0.2
0.4
0.3
0.3
0.1
0.3
0.3
0.2
0.2
0.3
0.2
0.3
0.3
0.3

Actual
Concentration
Rang*2
BDL-11.2
BDL-255
BDL
BDL-3 . 6
BDL
BDL-1 . 3
BDL-3. 7
BDL-6.1
BDL
BDL-1 21
BDL-19.8
BDL-152
BDL-52.9
BDL-112
Lagoons id*
Highest
Concentration
* of TLV
0.11
3
-
-
_
0.02
0.007
0.01
-
0.1
0.025
0.1
0.1
0.1

Most Frequent
Concentration
3
Range
BDL
BDL-10
BDL
BDL
BDL
BDL
BDL
BDL
BDL
BDL-10
BDL
BDL-10
BDL
BDL-10
                                                                                                                                   Fenceline
                                                                                                                             Actual
                                                                                                                          Concentration
                                                                                                                              Range 	
BDL-1.1
BDL-11
BDL

BDL

BDL
BDL
BDL
BDL-0.2
BDL

BDL-2 4
BDL-1.0
BDL-5.8
BDL-1.1
BDL-7.0
                                                                                                                Most Frequent
                                                                                                                Concentration
                                                                                                                        3
BDL
BDL-10
BDL

BDL

BDL
BDL
BDL
BDL
BDL

BDL-10
BDL
BDL-10
BDL
BDL-10
                          Motes:
                                1.  Based on normal 20-liter air volume.
                                2.  BDL entries indicate levels were b«low detection limits.
                                3.  Concentration level ranges used: BDL,  BDL-10 ppb,  10-50 ppb,  >50 ppb.

-------
     The air monitoring project developed for the French Limited
project incorporated the real-time measurements,  qualitative and
quantitative  time-integrated  measurements,  and  intermediate
"grab" samples analyzed on-site with minimal turnaround time.

     Which  method was  best for  the study?   All  the  applied
methods  had  their  place  in  accomplishing  the goals  of  the
project.

     Table 4 presents the applications, benefits,  and limitations
of the three air monitoring approaches used.

     Based  on these results  and the comparison of  techniques
described  above,  air monitoring  successfully accomplished  its
goals of protecting the  health and safety of on-site and off-site
personnel  and  documenting the  contaminants  released  by  the
bioremediation demonstration.

Results

     Air impacts during the in-situ bioremediation demonstration
were minimal and placed few limitations  on day-to-day operations
because the air monitoring program allowed answers to air impact
questions to be available in time to ensure proper and safe site
operations.   When  impacts did  occur,  they  were  found to  be
readily controllable, decreasing  immediately upon  reducing  the
intensity of sludge aeration or mixing.

EQUIPMENT DEVELOPMENT

     Upon completion of the in-situ bioremediation demonstration
phase of the project, an equipment  development phase was begun.
During  this  phase,  various   pieces of  equipment,   including
aerators,  mixers,  pumping  systems,   etc.,  were   tested  for
applicability for use in the final  remediations.  A new cell of
the lagoon was walled off next to the in-situ demonstration cell.
An additional cell  was  also walled  off  at the  east end  of  the
lagoon for  testing  during this phase as  well.   The testing of
equipment proceeded during the next approximately 1-1/2 years.

     Because this testing  of mixing and  aeration activities  had
the potential  for ambient air  impacts,  air monitoring efforts
were continued during this phase of the  program.   Time-weighted-
average Tenax measurements were taken on a daily  to  weekly basis
depending on the level of activity at the site.   All measurement
results were  compiled  and reported with  the monthly  progress
reports describing the operational activities at the site.

     Results  during  this phase  of  the  operation  showed  no
significant  ambient  air   impacts  resulting   from   equipment
development.    These results,  in combination with the results
                                40

-------
                            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

-------
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

-------
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

-------
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

-------
     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

-------
     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

-------
  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

-------
potential risks to human health by  limiting  air emissions.   For
this  purpose,  emission  limitations were  established based  on
health  risk criteria,  which were approved by EPA.   By  setting
emission  limits  that would  be protective of the most  exposed
nearby  residents,  these limits would  also protect people  with
lower  exposures;  for  example, people  living  farther away  or
people who occasionally pass through the area.  The air emission
limits were  determined  for the full-scale  bioremediation effort
by back-calculating  from the adopted health  risk criteria using
risk  assessment techniques.   The following  discussion presents
the derivation of the short-term and long-term health protective
emission  limits  which  will  be  applied during the  full-scale
bioremediation of the French Limited site.

     Short-Term Emission Limits Protecting Against Acute Health
     Effects

     Because TLV-TWAs are  not  strictly based on  acute effects,
other literature sources describing acute adverse health effects
were reviewed to determine other chemical concentrations at which
acute effects might be manifested.  Information reviewed included
primary  literature,   supporting  documentation  for  the  TLVs,
National  Institute  for Occupational Safety  and Health  (NIOSH)
documents, and EPA documents.   This review focused on identifying
the  lowest  observed adverse  effects   levels  (LOAELs)  and  no
observed adverse effects levels (NOAELs) for acute effects.

     The  majority   of  the   chemicals released  during   the
bioremediation demonstration were  hydrocarbons such  as  hexane,
cyclohexane, heptane, or pentane.   The concentrations of these
hydrocarbons that might result in acute effects  (within  hours)
start just below 100  ppm and  range as high  as thousands of parts
per million, depending  on the  chemical.  For the HSL  compounds,
however,  concentrations ranging between tens  and hundreds  of
parts per million could  result  in  acute  effects.   The  acute
toxicology literature indicates that a total VOC  concentration
below 15  ppm would  be  expected to  be  protective  against acute
effects  for  the  nearest   residents,   even  when   the   total
concentration monitored was  assumed to be  the  most toxic  HSL
compound.

     Long-Term Emission Limits  Protecting Against Chronic Health
     Effects

     Air  criteria concentrations   (ACCs)  were  established  to
protect against chronic adverse health  effects.   Because the ACC
levels are much lower  than the concentrations that could cause
acute effects, by meeting the ACCs,  it is  also  unlikely  that
acute health effects  would occur.

     The  ACCs   were   derived   for  both   carcinogenic   and
noncarcinogenic   health  effects   by   back-calculating   from


                                48

-------
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

-------
     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

-------
                     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

-------
in the direction of the three  nearest  residential  areas (Rogge,
Dreamland and Riverdale subdivisions) and in the direction of two
neighboring   roads.     The  allowable  short-term  total   VOC
concentration of 5 ppm has been incorporated into the short-term
response  action limits.   The  total VOC  concentration will  be
continuously  monitored and  bioremediation operations will  be
managed   so  as   to   avoid   the  attainment   of  acute   VOC
concentrations.  In the unlikely event of an exceedance  of the
maximum  short-term total VOC  concentration  (see  discussion  to
follow),  evacuation  procedures  will  be conducted in  order  to
prevent  the  occurrence  of   acute  exposures   to  neighboring
residents.

     To protect against potential chronic health effects  and to
achieve the health protection  objectives of 1 in 1 million  (1 x
10"6) excess lifetime  cancer risk for carcinogenic  effects and a
hazard index  of 1.0  for noncarcinogenic effects,  long-term VOC
concentrations will be monitored for each of the HSL compounds to
ensure  that  they  do  not,  on  average,  exceed the  ACCs.    A
computerized system has been designed to continuously compare the
chemical-specific ACCs with the cumulative average  concentration
modeled for that chemical at each of  three residential  locations
(i.e.,  for  the nearest  resident in the  Rogge,  Dreamland,  and
Riverdale subdivisions).  The ratio of  the ACC to the cumulative
average concentration  is  called the air criteria  concentration
ratio  (ACCR) .   An  ACCR will be  derived for each  chemical  on a
weekly  basis  throughout  the   2-year  period of  the  full-scale
bioremediation  project.    The  long-term  VOC  emissions  during
bioremediation will be managed such that the final ACCR will be
equal to or less than  1.0 for  each chemical, thereby protecting
the public from adverse chronic  exposures.

Measurement and Modeling Techniques

     The  remainder  of  this  paper   describes  the  sampling,
analytical  data management,  and modeling techniques used  to
generate data  for the risk assessment procedures described above.
The  program presented  is  the  result  of  a  cooperative  effort
between all participants  in  the project,  the Task Group, ENSR,
and EPA.

     The Ambient Air Monitoring Program for potential releases of
VOCs from the French  Limited  Bioremediation Process Operations
includes two types of  monitoring action:   short-term monitoring
and long-term, time-integrated monitoring.

Short-Term Monitoring.  The short-term monitoring program provides
a continuous,  instantaneous reading of total VOC concentrations
in ambient air.   Five  separate  continuous  measurements are taken
at  strategic  locations  around  the  operating bioremediation
treatment cell,  at the top of the  French Limited  lagoon flood
wall, to determine whether control adjustments are necessary in


                            52

-------
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

-------
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

-------
            SAMPLE
            INPUT
                 UNIT  1  OF  5
01
en
                               TECO
                               910  A
                               OVM
            S
            P
            A
            N
Z
E
R
0
                       STATUS LINE
                        4-20 MA
ODESSA
 3260
   386
 20  MHZ
COMPUTER
                                                                                   DIAL
                                                                                  PHONE
                                                                                   LINE

                                                                                          FIGURE  4
                                                                                   ENSR CONSULTING AND ENGINEERING
                                                                                 FUNCTIONAL 6LOCK DIAGRAM
                                                                                  TOTAL VOLATILE  ANALYSIS
                                                                                        FRENCH LIMITED
                                                                                     JOG
                                                                              APPVO:
                                                                        °*Tt: 8/20/90
                                                                                           REVISED:
                                              PROJECT
                                              NUMBER:
                                              2870-01-1
                      REV
                      o

-------
     TECO Analyzer

     The TECO  910A*  OVM,  designed  to be used  on a  continuous
basis,  uses a  photoionization  detector  (PID)  with  a  heated
sampling flow path and a microprocessor  to  control  calibrations
and output.   The detection  limit  of the method  is 0.5  ppm  as
benzene.

     Data Collector

     The Odessa DSM  3260  Data Collector will convert the 4-  to
20-mA signal from the remote  analyzers  into meaningful  units  in
ppm.  The DSM 3260 will be configured to provide interim averages
of 5 minutes and final averages of  1 hour.   The  interim averages
will be used for both alarm  control  and  graphic presentation  on
the local  computer  screen.   Each of  the five OVMs will  have a
data collector  channel  recording its  output and an  associated
alarm control set  at 5  ppm.   If the site  experiences  a  5-ppm-
level alarm at one analyzer,  it will also sound  an alarm as more
analyzers exceed 5 ppm; in addition,  a  calibration  failure will
trigger an alarm.

     Software will be used to generate monthly summary reports  of
data collected.   The reports  will be  included  in the  monthly
project progress  reports  submitted  to  EPA.  Data  can also  be
accessed in  real-time at  the site  or through a remote  terminal
via modem.

     The   OVM   instrumentation  and  time-integrated   sampling
equipment will be installed,  calibrated, operated,  and  audited,
consistent with Standard Operating Procedures (SOPs).

     The TECO 910* OVM is  a  self-calibrating instrument.   A zero
and span calibration check will be  performed each  hour.   Each  of
these events will  be 2.5 minutes  in  length.    Zero and  span
calibration events will be staggered  for the  five sites  so that
only one analyzer  at a  time will be in calibration mode.  The
analyzer self-corrects to the span value.

     As is  normal with PID  instruments, the  analysis will  be
calibrated relative to a benzene standard.   However,  iso-butene
is used as a surrogate standard to benzene to avoid  potential
exposure to benzene  during  calibrations.    The  instrument  is
calibrated to iso-butene's corrected response relative to benzene
(iso-butene  is generally provided  by the supplier as a  benzene
equivalent  concentration).    The analyzer,   therefore,  will  be
calibrated in parts-per-million as  benzene  even though  an iso-
butene standard will  actually be used.   An approximately 8 ppm
certified standard of benzene equivalent to iso-butene will  be
used at each OVM station.
                               57

-------
     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

-------
     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

-------
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

-------
     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

-------
                   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

-------
                            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

-------
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

-------
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

-------
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

-------
cn
ex
             2870\2fl704-2
                  NEW WEEKS//
               -V 24-HOURV/
               //FENCEUNE  /,
               , CONCENTRATIONS
    WEEKLY
   AVERAGE
   FENCEUNE
CONCENTRATIONS
                                 COMPOUND
                                 DETECTION
                                   LIMITS
     PTO
   AVERAGE
   FENCEUNE
CONCENTRATIONS
                                                                                                             WEEKLY
                                                                                                          FRENCH LIMITED
                                                                                                            FENCELINE
                                                                                                             IMPACTS
                  PREVIOUS
                  WEEKLY
                  AVERAGE
               CONCENTRATIONS
     PTD
FRENCH LIMITED
  FENCELINE
   IMPACTS
                COMPOUND
               BACKGROUND
                  LEVELS
                                                                                                            FIGURE  6
                                                                                                                1M
                                                                                                   ENSR CONSULTING AND ENGINEERING
                                                                                               DATA  FLOWCHART  FOR CALCULATION
                                                                                             OF FRENCH LIMITED  FENCEUNE IMPACTS
                                                                                                          FRENCH LIMITED
                                                                                                     JOG
                                                                                             APPVO:
                                                               OATC- 12/18/90
                                                                                                             REVISED:
                                                  PROJECT
                                                  NUMBER:

                                                  2870-014
                                                                                                                                    REV

-------
O3
CO
             2870\28704-3
*»?
 /sssss
                                        METEOROLOGICAL
                                             DATA
                                           PROCESS
                                           SOFTWARE
                                            SOURCE
                                              DATA
                                            CELL E
                                             SOURCE
                                              DATA
                                             CELL F
  WEEKLY
   STAR
DISTRIBUTION
DILUTION
FACTORS
                                                                                                            FIGURE  7
                                                                                                    ENSR  CONSULTING AND ENGINEERING
                                                                                               DATA  FLOWCHART  FOR  CALCULATION
                                                                                                         OF DILUTION  FACTORS
                                                                                                          FRENCH LIMITED
                                                                                              DRAWN:
                                                                                                      JOG
                                                                                              APPVD:
                                                                                                              DATE:
                                                                                                              REVISED:
                                                         I NUMBER:

                                                         12870-014
                                                                                                                                    RCV

-------
2870\287
-------
     In  addition  to  the  atmospheric  dispersion  model,   the
specific   data   necessary   for   these    calculations    are:
meteorological data,  source parameters  (location, emission rates,
and release parameters),  and location  of receptors (i.e.,  points
for which concentrations  are to be calculated).  Each of these is
discussed in detail below.

     A  meteorological station  will  be  operated  continuously
during the remediation activity.   The station will consist of:

     •    A free-standing 10-meter tower.

     •    A wind speed and direction sensor at the 10-meter level
          on the tower.

     •    A  temperature  and  relative  humidity  sensor   (with
          radiation shield)  at the 2-meter level on the tower.

     •    A barometric pressure sensor  located  inside  a shelter
          adjacent to the tower.

     •    A tipping-bucket rain gauge  (with wind screen) located
          at ground level near the tower.

     •    A data acquisition hardware and  software system  to
          record digital data from analog signals produced by the
          meteorological sensors.  This data acquisition  system
          will be located in the field laboratory near the  tower.

     In  addition to recording average values  for  each of  the
parameters monitored (totals for  rainfall),  the  data acquisition
system will calculate and record averages of standard  deviation
of wind direction, commonly called sigma theta.   The sigma theta
variable  is  a measure  of atmospheric  turbulence,  a  parameter
important in determining atmospheric dispersion  characteristics.

     The  data  acquisition  system  will  calculate 5-minute  and
hourly averages.  Hourly averages will  be recorded  and used for
impact   calculations   for  the  time-integrated   concentration
measurements.

     The  hourly  averages will  be summarized into the various
reports as follows.

          Hourly data recovery (monthly)
          Mean wind speed (monthly)
          Vector wind direction (monthly)
          Temperature (monthly)
          Barometric pressure (monthly)
          Precipitation (monthly)
          Percent frequency-wind rose  (monthly)
          Hourly observations (daily)


                                 71

-------
     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

-------
                 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

-------
                         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

-------
     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

-------
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

-------
                           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

-------
                                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

-------
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

-------
•      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

-------
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

-------
 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

-------
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

-------
 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

-------
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

-------
repulverized using an SS 250 mixer. An additional 8% cement was added to the lift.  On August 27
the re-cemented lift attained a compressive strength of 125 psi in 3 days and passed the UCS criteria.

Subsequent lifts passing the TCLP criteria on the mixing pads were brought to Area C and spread
over the previously solidified material. These lifts were solidified in-situ by mixing 8% cement, and
all passed the UCS criteria in less than 7 days.

Soil stabilization/solidification was successfully completed on September 10, 1990.  Approximately
12,800 yd3 of soil was excavated, of which  1800 yd3 was found to be contaminated, and this was
stabilized/solidified.

RCRA Cap & Cover

The RCRA cap and cover was installed to prevent surface infiltration, which could cause leaching
of the buried waste. The cap and cover was installed over the majority of the site including Areas
B, C and D (See Figures 1 and 3).

The cover system consists of a 2-foot clay layer overlaid by a high density plastic liner (HOPE liner).
A one-foot sand drainage layer covers the HDPE liner. This layer is covered with geotextile filter
fabric.  The geotextile fabric  is covered with 1.5 feet of compacted backfill. Six inches of top soil
is spread over the entire cap. Along the toe of the cap, a geogrid and gravel drain wedge is installed.
(See Figures 8 and 8b).

During  the cap construction, two small areas of landfill trash were discovered on the north edge of
the cap outside the boundaries of the original cap. The first area in the northeast was discovered early
during installation of utilities.  The second area of trash was found while digging the anchor trench.
Specifications of the cap were changed to enclose this area under the cap boundary.

Preliminary work on  cover installation started before Area C  solidification was complete.  The
contractor started to move, compact and grade the general site backfill on August 23, 1990.

The installation of the 2-foot clay layer started on the east end of the site on September 17, 1990. The
clay was compacted in four lifts, each about  six inches thick.  Moisture and  density tests were
conducted to ensure proper compaction.  The cap was maintained prior to the installation of the liner
by scarifying and wetting, as necessary, and  by rerolling and  fine grading.  The  clay cap was
completed by October 17, 1990.

Installation of the 60 mil HDPE liner started on October 11, 1990,  while the clay layer was still being
completed.  Before laying each piece of the liner, the portion of the clay cap to be covered, was
inspected to ensure that the liner would not be damaged by underlying material. Panels of the HDPE
were unrolled and cut to the approximate length and shape. The panels were fitted and welded. The
panel welds were vacuumed and pressure tested. HDPE boots were fitted  over the piezometers and
wells and welded to the liner (See Figure 8). The HDPE  liner was installed over the entire  site  by
October 30, 1990.

Construction of the geogrid and gravel toe drain was started on October 22,  1990. A 2 inch by 12
inch form was placed between the toe drain and the sand drainage layer.   This form was removed
after sand and gravel were installed (See Figure  8b). Geogrid installation was complete by November
3, 1990.

The sand drainage layer was started on October 18, 1990.  Sand was delivered to the east end of the
site and pushed over the HDPE liner using a low ground  pressure dozer.  As the front of the  sand
                                             86

-------
progressed across the site crane mats were used to support dump trucks delivering sand. The sand
drainage layer was completed on November 9, 1990.

The geotextile filter fabric was then installed over the sand drainage layer to prevent fines from the
overlying soil backfill from permeating into the sand layer.

The first backfill layer was placed and compacted on October 31, 1990.  The first lift of the backfill
was one-foot thick before being  compacted. The second lift brought  the backfill to  the required
compacted thickness of one-and-a-half feet. The last of the backfill was placed on November 29,
1990.

Following completion of the backfill, a topsoil layer was lightly compacted over the entire cap to a
minimum depth of six inches. Placing of the top soil started on November 19,1990. The surface was
hydromulched between December  12 and 14, 1990 to start  the vegetative cover. Erosion control
fabric was placed on the side slopes of the cap to prevent excessive water flowing off  the cap. The
cap and cover installation was complete on December 14, 1990.

CONCLUSIONS

Remedial construction at the IWC site involved a wide range of activities. Contaminated soils, trash,
and buried drums containing liquid hazardous wastes, were excavated from landfill areas. Two slurry
walls were constructed, as was a French drain that included two recharge wells. Contaminated soils
were stabilized and solidified following a pilot study. A RCRA cap was also constructed. All of these
tasks were  successfully completed. Overall, the remedial  construction  was completed ahead  of
schedule and well within the estimated costs.

Because very few remedial construction projects have been completed nationwide, it is important that
those projects that have been completed, serve as learning tools for future projects. While this project
was successfully completed, some important lessons were learned.

The  following is a summary of the  lessons learned at the IWC site:

•      It is  extremely difficult, but very important, to accurately define the locations of landfill
       debris, as well as the locations and number of buried  drums.  This is difficult because,
       usually, very few landfill operating  records are available, and because investigations using
       boring techniques oftentimes miss large areas  of buried debris or drums.  It is recommended
       that remedial investigations at landfill sites include the use of ground-penetrating radar which
       is capable of locating 55-gallon drums at depths of 6  to  9 feet, as well as investigative
       trenching techniques.

       Throughout the IWC construction phase, the importance of accurately defining  the locations
       and number  of buried debris and drums was  illustrated.  Landfill debris was unexpectedly
       encountered  during construction of both the site slurry wall and the  RCRA cap. While this
       only resulted in minor delays and  minor modifications to the construction  plans, more
       significant delays could result at different projects.

       In addition,  far fewer buried drums were found in Area D, than had been estimated, and
       buried drums were unexpectedly encountered while excavating contaminated soil in Area C.
       It had been estimated that as many as 3000 liquid-filled  buried drums may exist in  Area  D,
       but only  102 were found.  Conversely, buried drums were not expected in Area C,  and 142
       liquid-filled  drums were found.  While finding far fewer drums in Area D did not disrupt the
                                            87

-------
       project, unexpectedly finding drums in Area C did. Installation of the French drain system
       was also disrupted when buried drums were unexpectedly discovered.

•      Excavation of buried drums is both difficult  and dangerous.  Buried drums tend to be in
       various stages of disintegration and can  spill their contents with the slightest disturbance.
       Oftentimes, in order to minimize the release of a drum's contents, it is necessary to either
       hand-excavate the drum and/or  pump its contents to a new drum.  The drum explosion
       demonstrated how dangerous drum removal can be. Great care must be taken to minimize the
       commingling  of different materials within an excavtion. This obviously includes minimizing
       the flow of ground water into an excavation. In addition, it is imperative that the excavation
       crew constantly watch for signs of an unexpected reaction.

•      Construction  plans must ensure that enough water is always available. Onsite wells may not
       be capable of continually supplying enough water as it is needed, particularly during peak
       construction periods. It may be necessary, especially in rural settings, to store water onsite
       to ensure its availability.

•      It is very important that bench scale and pilot studies be conducted to estimate the amount of
       stabilization and solidification agents needed,  as well as the necessary curing times.  These
       tests should attempt to simulate fullscale field implementation as closely as possible. During
       the IWC pilot, the addition of cement to attain  the UCS criteria should have been performed
       on the mixing pad  instead of in a bench scale  test in the laboratory.  This would have
       indicated before full scale work began the optimum amount of cement necessary to attain the
       UCS criteria and avoided having to re-pulverize the first lift.

ACKNOWLEDGEMENTS

We extend our thanks to the IWC Steering Committee for providing relevant information to prepare
this paper. Special thanks are due to Mr. William Bowen and Ms. Sherry Spencer of the U.S. Army
Corps of Engineers who provided oversight on behalf of U.S. EPA to assure construction quality. Mr.
M. S. Ramesh deserves thanks for guiding  the IWC project through remedy selection and remedial
design.

REFERENCES

1.      Caldwell R.T., Cote  P.L., Chao C.C., Investigation of solidification for the immobilization of
       trace organic contaminants. Hazardous Wastes & Hazardous Materials, Volume 7 No. 3, 1990

2.      Soundararajan R, Barth E.F., Gibbons J.J., Use of an Organophilic clay to chemically stabilize
       waste containing organic compounds.  Hazardous Materials Control January/February 1990.

-------
                                        SURFACE DRAINAGE DITCH - DinECTS FLOW AROUND SITE BOUNDARIES

                                             FRGNCH DRAIN

                                                     SLURRY WALL
                 AREA 0
                                  CAP 1 COVER - MINIMIZE INFILTRATION
                                             4 PROMOTE RAPID RUNOFF
                                                CONTAINMENT WALL
                                                fflCtOW CAP AND COVCHI
flLLCO DRUMS
                               INTERCEPTOR
                                  TRENCH- COLltCT AND OIVCRT/
                                       sues         '
                                       suesuRfAct FLOW
^iU^XiXXliV  HA*T$MO«NC/ATO»tA REGIONAL GROUND W A T E R F L 6 W " UUXUUXUt^S^
                                                       XXXXXXXXXXXXXXXVXXX XX XXXX^X XXXXXXXXXXXXXX
                                                vvvxxXXXXXXXXXXXXXXXXXXXVXXXXXXXXXXXXXXXXXXXXXxXXXXX*
                                                ^XxxXXXXXXXXXXXXXXXXXXVXNSXXX^XxXXXXXXXXXXXxXXXXXXXX'
                                                AN^   xxx\xxx*x\xvxx*xxxxxxxxxxxxx"xxxxxxxxxxxxxxx
                                                        XX^XXXXXNSXVXXXXXXXXXXXXXXXXXXXXXXXXXXX
                                                            XXXXV\XXXXXXXXXXXXXXXXXXXXXXNXXXXX
                                                              XXXxXxXXXNXXXXXXX XXXX\X XN XXXX^
                 FIGURE 1 - THE REMEDY SELECTED FOR THE IWC SUPERFUND SITE

-------
CD
O
                                                                             rREMNANT
                                                                              STRIP MINF
                                                                                           EStr^

               M/f
                   ••%:•!>--.f ) Y/-J	/•/ -r^Vi. MJ ^r^-^.^v^ VC"--  Nb  -W^-  -^>
                  - ^^N/AV-^^-<>  "\^  ^-^!7,>-  V*:0 - 4?l  f Q
               EGEND"   /''»  1 I i  -'.._: i; ;r:":0   y     '>  •'  ,;; 1  i-:y  '  V-P  r,\   xX
                              V       N'     •''   '    " *     '     ''     '"'
LEGEND    ,.  i   i • , ...-:>..<

AREA A  STRIP MlhjE/ _ | V - V> A/\

AREA B"  DISPOSAl/'AREf FOR )A I \\  	
 •«!'_,. - VARIETY OF.WASTES \\\ \\\  < \
AREA C  TWO FORMER LIQUID WASTE
       SURFACE IMPOUNDMENTS
AREA D  LIQUID FILLED AND CRUSHED
       DRUM DISPOSAL AREA
Figure 2
                                                                                          IWC SITE BOUNDARY
                                                                                             PREPARED FOR

                                                                                       IWC SETTLING DEFENDANTS
                                                                                        FORT SMITH. ARKANSAS

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

RCRA CAP AND COVER

PROPOSED EXTENDED BOUNDARY
AND NEW FENCE
AREA C SLURRY WALL
FRENCH DRAIN
SITE SLURRY WALL
                         -=•  DISCHARGE PIPE
                                                                  CLEAN BACKFILL
FIXATED WASTE

MANHOLE/PIPE DISCHARGE
POINT TO MINE
                                                                                                     Figure 3
      SLURRY WALL,
      FRENCH DRAIN.
   AND CAP AND COVER
       PREPARED FOR
IWC SETTLING DEFENDANTS
  FORT SMITH. ARKANSAS
                                                   NOTE: MONITOR WELL LOCATION HAS BEEN
                                                        PLOTTED FROM EXISTING LOG.

-------
                    TYPICAL CROSS-SECTION
                     OF SITE SLURRY WALL
 NORTH
          RCRA CAP 6 COVER
                                             CAP PERIMETER
                                          DRAINAGE CHANNEL-
                                             FRENCH DRAIN
                                  SITE SLURRY WALL-
                                                          SOUTH
                                       FILLED IMPOUNDMENT
                                      10'-20' SEPARATION
                                                             DETAIL
      RCRA CAP AND COVER
 Y////////////,
CLAY PLUG— tZJ
SHALE
TO
                       10'-20' SEPARATION
                   SITE
                   SLURRY WALL
                   -THICKNESS DETERMINED
                   DURING THE REMEDIAL
                   DESIGN PHASE
                     -KEY
      SITE SLURRY WALL
           DETAIL
                                               /^-FRENCH DRAIN
                                                 Figure 4
     SITE SLURRY
  WALL CROSS-SECTION
     AND DETAILS
     PREPARED FOR
IWC SETTLING DEFENDANTS
 FORT SMITH, ARKANSAS
  NOTE:  THIS FIGURE IS NOT TO SCALE.
                             92

-------
              TYPICAL  CROSS-SECTION
                 OF  FRENCH  DRAIN
 NORTH
                                      CAP PERIMETER
                                      DRAINAGE  DITCH-
                                       FRENCH  DRAIN-
                                                      SOUTH
                                                         DETAIL
                                        CAP PERIMETER
                                        DRAINAGE DITCH
 RCRA CAP AND COVER
SHALE
            • A
           •». r
            •a .<•
             A -
              :c
                  NATURAL GROUND SURFACE

                  -GRAVEL
                   THICKNESS DETERMINED
                   DURING THE REMEDIAL
                   DESIGN PHASE
                   4 0 PERFORATED
                   DRAINAGE PIPE
                   KEY
  TYPICAL FR  NCH DRAIN
         DETAIL
NOTE: THIS FIGUF  IS NOT TO SCALE.
       Figure 5
   FRENCH DRAIN
  CROSS-SECTION
    AND DETAILS
     PREPARED FOR
IWC SETTLING DEFENDANTS
 FORT SMITH, ARKANSAS
                            93

-------
                   48' DIA. PRECAST CONCRETE
                   MANHOLE W/BOLTED DO
                           BACKFILL
                           MATERIAL
   DIA. PVC
PERFORATED
DRAIN PIPE
W/FILTER SOCK
CONCRETE PAD
LEVELING
LAYER
                                                                                           6' MIN.


                                                                                  EXISTING LANDFILL MATERIAL
4' DIA. PVC
NON-PERFO
DISCHARGE PIPI
CENTRALIZERS
(AS NECESSARY
4" TO 6" DIA. PVC
   VERTICAL
 DISCHARGE PIPE
EXISTING MINE VOID
                                                                                                                          FRENCH
                                                                                                                          DRAIN
                                                                                                                     •* "MATERIAL
                                            NOTES:
                                            1) THE WEST SIDE CROSS-SECTION WILL BE SIMILAR
                                              BUT SHOULD NOT INCLUDE A LANDFILL CROSSING.

                                            2) THIS FIGURE IS NOT TO SCALE.
                                                                                  Figure 5b

                                                                           CROSS-SECTION OF FRENCH
                                                                            DRAIN DISCHARGE SYSTEM
                                                                                   (EAST SIDE)
                                                                                   PREPARED FOR

                                                                          IWC  SETTLING DEFENDANTS
                                                                            FORT SMITH, ARKANSAS

-------
                      TYPICAL CROSS-SECTION OF
                        AREAC SLURRY WALL
  NORTH
                SOUTH
                                        AREAC SLURRY WALL
        RCRA CAP AND COVER	-, ^.-^.f/.
                  F|1 . X LANDFILL
                         AREA
CLAY PLUG
  SHALE
                        MINIMUM
                                                FIXED WASTE
                      AREA C
                      SLURRY WALL
                      THICKNESS DETERMINED
                      DURING THE REMEDIAL
                      DESIGN PHASE
                                                 Figure 6
                       -KEY
                                                                   DETAIL
    AREA C SLURRY WALL
            DETAIL
   AREA C SLURRY WALL
CROSS-SECTION AND DETAILS
       porp*ofn COP
IWC SETTLING DEFENDANTS
 FORT SMITH, ARKANSAS
    NOTE: THIS FIGURE IS NOT TO SCALE.
                              95

-------
                            TYPICAL CROSS-SECTION OF
                   AREA C SLURRY WALL/SITE SLURRY WALL KEY
                               AREA C SLURRY WALL/SITE SLURRY WALL-
       NORTH
                 SOUTH
             RCRA CAP AND COVER - 7 -»-3-
                                            AREACSLURRY WALL
                      DETAIL
                                                             THICKNESS
                                                             DETERMINED
                                                             DURING
                                                             REMEDIAL
                                                             DESIGN
                                                             PHASE
                                                               AREA C
                                                               SLURRY WALL
                                        SITE SLURRY WALL
         THICKNESS DETERMINED DURING
         REMEDIAL DESIGN PHASE
                                                          Figure 7
                   PLAN VIEW OF
              AREA C SLURRY WALL/
                 SITE SLURRY WALL
                    KEY DETAIL
   AREA c SLURRY WALL/
   SITE SLURRY WALL KEY
CROSS-SECTION AND DETAILS
       PREPARED FOR
 IWC SETTLING DEFENDANTS
   FORT SMITH. ARKANSAS
               NOTE: THIS FIGURE IS NOT TO SCALE.
Do Not Si ale Tnis
                                     96

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

          DftAINAQE CHANNEL

              FRENCH DRAIN .

        SITE tLUHMY WALL
                                                                        SOUTH
                  FILL MATERIAL
1.5'
                                               OEOTEXTILE
STAINLESS STEEL
BAND WITH
NEOPRENE GASKET
       X
              SAND DRAINAGE LAYER
                                              -•VNTMETIC MEMBRANE
                COMPACTED CLAY
                   FIXED WASTE/

               LANDFILL MATERIAL
            —=///=\\\=/// =///=
                     BEDROCK

             RCRA CAP AND COVER
              AND MONITOR WELL
                     DETAIL
                                                       MONITOR
                                                       WELL
                                                       CASING -
                                                                      CASING
                                                                     "SLEEVE
                            FLANGE/
                            LINER
                            WELD
                                                                     -SCREENED
                                                                      INTERVAL
               Figure 8
              NOTE: THIS FIGURE IS NOT TO SCALE.
          RCRA CAP AND COVER
         ANDTYPICAL MONITOR WELL
         CROSS-SECTION AND DETAILS

               PREPARED FOR
          IWC SETTLING DEFEDANTS
           FORT SMITH. ARKANSAS
Nol S-He
                                 97

-------
                                                                                                          Vegetated Surface Cover
                                    Erosion  Control Fabric
                                                                         ^/rriyf^^^y^W'^yy^'yf^^                                       ; ^ryr " " . ^ •. ^,: .^






                                                                      / /, //,'* /ss •'* -^^^ 1^*1 1 *'Pi 1-1 4rfl'l 1't < iX'l'l^T'l f¥ f l^^l I 'T\ A I \_l'J*r !•! 1A J I't^L-L I V^ 1 I'I*'T L^'Vfl*!^^ / 1 I T I*I^T*
                Geotextile -
                Filter Fabric
               ^pntf.S.i^.u.i.i.n.r
ntrol -fabric
CD
00
                   Geomembranc
                   Anchor Trench
                                                                                                                               Slurry Wall
                                                                                                                               Figure 8b
                                                                                                                          RCRA Cap & Cover
                                                                                                                         Cross-section details

-------
       Leachate concentration Vs Percent CFA
                   Ethylbenzene
0.12
                    40       60
                    Percent GFA
                                          80      100
WC Pilot 28 day cure
                       Series 1
                   TCLP
                                     Fig  9
                      99

-------
             Leachate Concentration Vs Percent CFA
                            Toluene
      1.4
      1.2
   P
   ?
   M
      0.8
   T
   O
   L
   U  0.6
   E
   N
   E
      0.4
      0.2
                 20
40       60

Percent CFA
80
100
                              Series 1
                   Fig 10
IWC Pilot 28 day cure
            TCLP Crttorta
                           100

-------
            Leachate Concentration Vs Percent CFA
                            Xylene
      0.5
      0.4
   P

   M  0-3

   X
   Y
   L
   E  0.2
   N
   E
      0.1
                 20
40       60

Percent CFA
80
100
                             Series 1
                      Fig 11
IWC Site 28 Day cure
TCLP Criteria
                          101

-------
                  Percent CFA  Vs UCS
                     1 day increment cure
                        40       60
                         Percent CFA
        80
            2 day cure
            4 day cure
3 day cure
6 day cure
100
                                             Fig 12
IWC Pilot
                         102

-------
                  Percent CFA Vs UCS

                    1 day increment cure
   u
   c
   s

   p
   •
   i
                20
            6 day cure
40       60


  P«rcnt CFA




•+- 7 day cure
 80
100
IWC Pilot
7 d Shelby




    Fig 13
                        103

-------
                 Percent Cement Vs UCS
                         7 day cure
   u
   c
   p
   •
   i
160





140





120





100





 80





 60





 40





 20
                      4             8


                         Percent Cement
                                            12
             2 hrs after Blending
iwc Pilot
                            4 hrs after Blending
                                     Fig 14
                         104

-------
LOCATION  OF   TEST  !>IL.OT
                       •Ol II
                                   •--1
                               BXCAVATIOV
                                LOCATION
                Figure 15
                   105

-------
Photo 1 : Drum being dug out by hand, area D
Photo 2 :  Pumping liquid from deteriorated drum
          in backhoe, area D
                      106

-------
Photo 3 : Drum incident, notice tilted drum
        left of 18. Also notice warped  top
        of the tilted drum
 Photo 4 : Tilted drum propelled into air.
         Notice drum in the horizon above pickup
         truck.
                        107

-------
                   BAYOU BONFOUCA SUPERFUND SITE
                   CASE STUDY OF SELECTED ISSUES
                         Slidell, Louisiana
                  (Author(s) and Address(es) at end of paper)
I) INTRODUCTION


The  Bayou Bonfouca  Superfund  Site  is  one of  the largest,  most
complex hazardous waste problems in  the country.   Cleanup of this
site,  which  will   cost   in  excess of   $100  million,   is  now
successfully  being   implemented  after  resolution   of   numerous
technical  and policy  issues.   The  purpose  of this  paper  is  to
summarize  resolutions to  five  critical  issues  which  developed
during the design.   Each  of these  items threatened to cancel  any
active remedial response or to render its cost  prohibitive.   They
include:

  1) discovery of a threefold volume  increase in waste, potentially
     invalidating the  selected remedy;
  2) development of  a  construction management system  to  prevent
     fugitive air emissions from threatening residents around
     the site;
  3) adoption of a dry weight payment criteria for  the  incineration
     process that potentially affects future incineration  projects;
  4) funding of such a large project; and
  5) bonding requirements  to ensure  competitive bids.

The  authors  from the  Environmental  Protection  Agency (EPA)  have
chosen to  provide a relatively  brief review  of  these  pertinent
issues,  thereby  giving   a  broad   perspective  of   the  complex
challenges involved in large Superfund projects. In addition, this
paper allows reviewers to identify possible areas in which they may
want to contact the authors for additional information  and valuable
lessons learned.
II) SITE HISTORY - RECORD OF DECISION


The Bayou  Bonfouca  Superfund site is  located  within the city of
Slidell, St. Tammany  Parish,  Louisiana.   The site consists of an
abandoned creosoting  facility on 52 acres of land and an  adjacent
contaminated bayou for which it is named. The community  of Slidell
has a population of  approximately  26,000 and serves primarily as
a bedroom community for New Orleans,  which is about  25 miles away.
The land use adjacent to the bayou ranges from a industrial complex
that  manufactures   concrete  piles   to  an  apartment   complex,
condominiums, and residential homes  within 25  feet of the bayou.
The project was placed on the original  National Priorities List in
1983  and  included  consideration  of  second  degree  burns  being
received by Coast Guard divers during  bayou sampling.
                                108

-------
Creosote operations began in 1892 and continued until 1970 when a
fire  destroyed the  plant.    Remedial  Investigations  (RIs)  and
Feasibility  Studies  were  completed  in  1987,  and  a  Record  of
Decision  (ROD)  was signed in March  1987.  The  results of these
investigations  indicated concentrations  of  up to 12% polynuclear
aromatic  hydrocarbons   (PNAs)  in  surface  waste piles,  several
percent  PNAs  concentrations  in the bayou  sediments,   and  pure
product  creosote  within the ground  water.    The  remedial action
ultimately selected included the following:

   a) onsite incineration of 46,500  cubic yards of contaminated
      sediments and 5,000 cubic  yards  of waste pile materials;
   b) placement of an engineered cap over the ash from  the
      incinerator and the residual surface soils greater than 100
      ppm total PNAs;
   c) pump/treatment/reinjection of contaminated ground water; and
   d) the estimated total construction cost was $55 million.

The  RI  characterized the  general  subsurface  (Figure 1)  at  the
abandoned  facility as  being a   few  feet of  sandy  fill material
(surficial  aquifer),  overlaying about  20  feet  of  clay,  which
covered  approximately  12 feet  of silty sand  (shallow artesian
aquifer).  Below the silty sand is another clay layer 10 to 20 feet
thick which rests on top of a sand layer  (deep artesian aquifer).
The surficial aquifer results from  recent rainfall events and does
not yield significant quantities of  water;  but it has been shown
to contain dissolved PNAs whenever water is able to be recovered.
The  shallow  artesian aquifer  is known  to  contain  free product
creosote, while the deep aquifer is uncontaminated.

The Agency in conjunction with the  State  of Louisiana indicated to
the  local community,  during  the  ROD public  meeting,   that  the
selected  remedy was  "conceptual"  in nature  and  that additional
studies  were necessary  during  the  Remedial  Design  (RD)  phase.
These studies were to be conducted to  gain more refined information
so as to develop detailed plans and specifications.

In  1988  RD  field  investigations  were  started  to  support  the
preparation of  detailed plans and  specifications.   This work was
conducted by CH2M  HILL under contract  to EPA  with the Army Corps
of Engineers providing  technical  assistance.  The primary emphasis
of  this  phase  was  to:  1)   further  delineate  boundaries  of
contaminated ground water and to evaluate the ability to pump and
treat;  2)  better  determine  the  extent  of contaminated  sediments
and related engineering properties; 3)  evaluate the air emissions
during dredging and materials handling; and 4)  evaluate the ability
to dewater the sediments.  As a result of these investigations the
project was divided into two operable units as detailed below.
                               109

-------
                   Creosote Plant Site
                                                 GENERAL CROSS-SECTION
                                                   (  not to scale  )
                                                                Bulkhead
                                                                        Resldental Area
O
                   Fill Material
                                                                                           Surface Soil
                                                             Previously assumed//
                                                                  depth of    Ii
                                                                contamination/ /
Upper Cohesive Layer
Upper Cohesive Layer
                                                                Actual depth/
                                                                     nt    I
                                                                contamination
                                                                                        Shallow Artesian Aquifer
Shallow Artesian Aquifer
                                                          Lower Cohesive Layer
                                                          Deep Artesian Aquifer
                                                                                               BAYOU BONFOUCA
                                                                                                     Figure 1

-------
Ill) GROUND WATER OPERABLE UNIT


The delineation of the ground water contaminant plume and the pilot
treatment operations were  conducted in the summer  and winter of
1988.  A total of 38 permanent and temporary wells were installed
on the plant site and along the edge of the bayou.  As a result of
this work, free product creosote was discovered in three discreet
plumes rather  than  one continuous  one  as presented  in  the ROD.
Figure 2  reveals the  approximate shape  of  these plumes.   This
figure also shows that two  of  the  plumes are on the plant property
while  the other  is  adjacent to  the bayou  and  appears to  be
influenced  by contamination  within  bayou  sediments.    A  cross
section of where this aquifer is located is illustrated in Figure
1.  The free product is located in about a 12  foot zone at a depth
of approximately 20  feet below the surface.  The creosote tends to
be  in  separate seams throughout  the aquifer rather  than in one
layer at the bottom of the formation.

A  ground  water  pilot  study  was  conducted  to  evaluate  the
capabilities  to  extract  and  treat these   contaminants.    Two
different types of extraction well configurations were evaluated.
A separate phase  extraction system  as shown  in Figure 3  was used
to assess the ability to extract the creosote oil separately from
the water in the aquifer.   This system consisted of oil extraction
wells in an equilateral triangle with wells at 2.5 foot spacings,
and a water extraction well within the center of the triangle.  The
principle behind this array was to create a hydraulic gradient in
the water recovery well which would also  induce the flow of pure
product creosote toward the oil recovery wells.  The other system
consists  of  a conventional multi-phase pump  system  as  shown  in
Figure 4.  This type of system removes both oil and water from the
formation at once rather than trying to extract them as different
phase  liquids.    It  was found  that  the  creosote could  best  be
removed through multi-phase pumps instead of separate pumps for oil
and water phases.  This study also revealed that reinjection of the
treated water, as anticipated in  the ROD, was not viable because
of the physical properties of the  aquifer.   The aquifer  does not
readily allow the reinjection  of water and as  such it was believed
this would potentially be a costly ineffective action.

A second aspect of this pilot study was an evaluation of the most
effective form of treatment of the extracted groundwater prior to
discharge.   The RD  pilot  study  showed  that the most effective
treatment  train  was  oil-water  separation;   followed  by  sand,
oleophilic  and  carbon  filtration;  and  then  aeration  before
discharge to  the  bayou.    This  system proved to  be  effective  in
meeting the discharge criteria  of  the State  of Louisiana and the
National Pollutant Discharge Elimination System.
                              Ill

-------
PROPERTY
BOUNDA
               BAYOU BONFOUCA
                                                                              ST. TAMMANY PARISH LOUISIANA
                                                                           Contaminated shallow artesian aquifer
                                                                           (depth 20') containing free product
                                                                           creosote as defined through design
                                                                           investigations.
                                                                           Original limits of contaminated water
                                                                           within the shallow artesian aquifer
                                                                           as presented in the ROD.
                                                                                              BAYOU BONFOUCA SITE
                                                                                  BAYOU BONFOUCA. SLIDELL. LOUISIANA
                                                                                              Figure 2

-------

DEPTH BELOW GROUND SURFACE
(FT)
ui o t* o w c
1 1 1 1 1 1
30-
35-
_ DISCHARGE

CASINO 	 	 -^^
BENTONITE/
CEMENT GROUT 	 .
STATIC WATER LEVEL
SCREEN 	
•SAND
FILTERPACK 	 ^^
CREOSOTE
RECOVERY
FAMP PUMP 	
i
.
/
• •" *
*." •"»
>*
%•
_•.'•;•;.



^
,e


^ Vi
JONTROLLER






•
10-





f





?


\

IsXXXV
/,
" •* *"•
•* • •*
' •* •*•
*•* •*•
• ' * •"
• •*,• •



AIR |-


±2 FEET


PUMPING (
LEVEL- N
OPERATIC!

n^^
^
H
\
'I
/
/
/
/
j
/
/
/
/
/
/
*• * * *•
«* * »*
*-|

7
,6
DISCHARGE ^



•
10-



\\V\\\
1
s,

WEOSOTE
ORMAL
MS RANGE

CONTROLLER
SENSOR
LEVEL

A PUMP ON
PUMPING WATER
LEVEL - NORMAL
OPERATING RANGE
1
A PUMP OFF
- WATER /CREOSOTE
RECOVERY
EJECTOR PUMP
A PUMP ON
A PUMP OFF
(DENSITY SENSOR)
                              Figure 3
             GENERALIZED SCHEMATIC FOR
             SEPARATE PHASE EXTRACTION
               WELL SYSTEM (SYSTEM "A")
                          Bayou Borrfouca
                          SlkJell, Louisiana
113

-------

DEPTH BELOW GROUND SURFACE
(FT)
u 10 to -» -*
o m o tn o CM c
	 1 	 1 1 II 1 1
35-

CONTROLLER
m^ DISCHARGE

CASING 	 ^^^
BENTONITE/
CEMENT GROUT 	 „
STATIC WATER LEVEL

WATER/CREOSOTE
RECOVERY
EJECTOR PUMP 	

f
/.
^
/
/
/
/
/
/
• * »
• • i
• • •
• •
• •
• •
• •
• • •
• •
* • «


v
m e



"
10'


m^*mmf
— h
MMBMMI


VMM
MI^HW

/,
/
/
/.
/
/
/
/
/
/
/
/
•or.'^
• •
• •
* • •
* • •
• •
• • •
• *
• • •
• •
• • •
• •
• • •
• •
• • •
• •
• • •
• •
* • •
• •
• • •
• •
• • I
• •
Ivi
• •
• • <
• •
• *
* * i
AIR ^
CONTROLLER
SENSOR
L£VEL
A PUMP ON
PUMPING WATER
LEVEL - NORMAL
OPERATING RANGE
^ - SCREEN
i— _ _____ PUMP OFF
	 — SAND FILTER? ACK
Flfliira &
           GENERALIZED SCHEMATIC FOR
              TOTAL FLUIDS EXTRACTION
              WELL SYSTEM (SYSTEM "B")
                         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

-------
                                                                                    -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

-------
  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

-------
  3-WAY TEFLON
  SAMPLING VALVE
  34" COPPER
  TUBING v
  SUPPLY
           AGITATED
           CHAMBER
                      AGITATED
                      CHAMBER
        AGITATOR MOTOR,
        LIGHTNIN 3 HP
        0-200 SCFH
        ROTAMETER
        WITH FLOW
        CONTROL VALVE
              WOOD MIXER
              SUPPORT
                                                         Xt" TEFLON
                                                         TUBING
                                  AGITATED
                                  CHAMBER
                                              RAKED
                                             CHAMBER
  SKID- WOOD
  CONSTRUCTION
  DIAGONAL MEMBER
  FOR MOTOR SUPPORT
  AND TANK  STABILIZATION
              CARBON
              TREATMENT
NTS
                                120
       Rgure 6
SCHEMATIC OF AIR
  TEST CHAMBERS
   Bayou Bonfouca
   Slidell, Louisiana

-------
  C)  DEWATERING PILOT STUDY/PAYMENT FOR INCINERATION

At the same time as the Air Pilot Study a dewatering study was also
conducted.    Dewatering  activities  during  these pilot  studies
included polymer  testing,  vacuum  assisted drying beds,  gravity
settling,  filter  press,  centrifuges,  and  belt  filter  presses.
Figure 7 presents a table of the results of these tests which was
provided to  the  bidders as  part of the  RD package.   This data
indicates that when additional moisture is added to the sediments
it can be difficult to remove  it prior to incineration.   It also
shows that the moisture content  of  the incinerator  feed would be
greatly affected  by the  dredging  and dewatering process  train
rather than the insitu moisture content of the sediments.

This data indicated that the most reasonable contractual approach
for handling the dredging, incineration and dewatering aspects of
this project was through paying for the ash on a dry weight basis
as it leaves the  incinerator.   This is completely different than
the typical incineration contract where measurement is based  on the
wet material entering the  incinerator.  This approach  places the
responsibility on the contractor to optimize his process train to
reduce the amount  of water in the feed material to the incinerator.
Although several bidders disagreed  with this approach,  they were
unable to provide a more suitable method to handle this situation.
Associated with this  issue was  the realization that to pay for the
ash material on  a dry weight basis  the contract  documents would
require a flexible performance  strategy.   Therefore, EPA and the
State of Louisiana decided to use a performance based specification
rather than  a  detailed design approach that  specified  specific
treatment  trains   (i.e.,   centrifuge   followed  by   infrared
incineration, filter press  followed by rotary kiln, etc.).  The
contract was  advertised for construction as a request for proposal
(performance based) rather  than  an  invitation  for bids (detailed
design).

  CONCLUSIONS

In consideration  of  these studies  and a  detailed review  of the
different possible process  trains,  it was decided that  the most
effective way  to  advertise this RA was  through a request for
proposals (RFP).   It was  recognized,  that given such  a complex
project, there could be a  number of different  approaches.   EPA's
intent was to encourage competition,  innovation and  cost savings
for the Government.   The RD for this  construction was completed in
September 1990 and award of the RFP is expected in May 1991.  The
issue of paying for incineration was addressed through weighing the
material as  it  exits  the incinerator rather than weighing the feed
material.     This   assures   the  Government  that  the  contractor
optimizes the process train to  ensure that unnecessary moisture is
minimized.
                                 121

-------
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

-------
  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

-------
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

-------
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

-------
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

-------
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

-------
                        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

-------
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

-------
                                           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

-------
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

-------
                                                                     MAN MADE
                                                                     DITCHES (TYP.)
                                                                   LIMITS OF
                                                                   CONTAMINATED
                                                                   SOILS

                            PROPERTY//
                                                               APPROX. LOCATION
                                                               TREE LINE


                                                            •V--C-">-^-ACCESS --
                                                            x^x"/xM; ROAD iC?-
    SCALE
     I" =270'
    DATE
  APRIL 1991
                            LANG  PROPERTY  SITE
FIGURE

   2
C.C.JOHNSON  & MALHOTRA.P.C.

-------
groundwater  plume could  have limited  concentric migration, its migration is principally in a
northwesterly direction.

This first phase RI answered most of the questions necessary to prepare a Feasibility Study, although
there were still some unanswered questions.  For example, locations for the northwestern most point
of groundwater contamination and  the northern most point of soils contamination could not be
established. Since most of the questions were answered, it was decided that instead of going through
an entire second phase of an RI,  the FS should be completed and the remaining sampling would be
completed as part of the RD.  This decision by EPA allowed the ROD to be signed in a much more
timely fashion.

Based on the results of the RI, the contaminated groundwater had not migrated far from the area of
disposal. This was attributed to the very slow ground water flow rate resulting  from the minor
northwest gradient. The ditch which drains the site may have acted to intercept some of the shallow
groundwater from which volatilization of contaminants may have occurred.  Groundwater below a
depth of 30 feet showed no  evidence of contamination. This is because soil permeability in  the site
area decreases with depth below ground surface. In addition, the groundwater exhibits slight upward
and downward vertical gradients that vary with the season.  In the long term, this resulted in no net
downward movement of contaminated groundwater through the subsurface zone detected during the
RI.

An RI Report was prepared describing the results of the  field investigations.  The report presented
the data collected and evaluated the results with respect to applicable or relevant  and  appropriate
requirements  (ARAR's). ARARs included state  and federal criteria along with those from the
Pinelands Commission.

A risk Assessment was conducted which  identified chemicals of concern, exposure pathways  and
populations at risk.

Feasibility Study

A Feasibility Study (FS) was conducted for the site which  screened technology types, developed
alternatives and provided a detailed evaluation of remedial alternatives in order to assist EPA in
selection of the Remedial Action which was included in the ROD.  Alternatives considered included
excavation and either off-site disposal or incineration of contaminated soils. Groundwater alternatives
included pumping and either disposal in a local wastewater treatment facility (after pretreatment),
on-site treatment  with disposal by injecting the treated groundwater into the aquifer from which it
came, or off-site treatment and disposal. All alternatives were evaluated in terms of costs, reliability,
implementation, safety, public health and  welfare,  environmental impacts, regulatory requirements,
and community acceptance. CCJM also provided support to EPA during preparation of the ROD.

Record of Decision

As described in the ROD, the selected remedy includes the following:

       o      Enclosure of the  disposal area by a  perimeter fence.

       o      Excavation  of contaminated  on-site  soils to  a depth of  two feet  (totaling
              approximately 6,500 cubic yards),  removal of these  soils  to an approved  off-site
              landfill disposal facility, and backfilling the excavated area with clean fill. (Note that
              the actual quantity of soils was closer to 8,000 cubic yards.)
                                             133

-------
       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
                                             134

-------
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
                                            135

-------
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
                                            136

-------
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.
                                           137

-------
                  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,
                                            138

-------
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

-------
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
                                            140

-------
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
                                            141

-------
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,
                                            142

-------
       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
                                            143

-------
       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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
Schedule Name
Responsible
As-of Date
Crystal City Airport
Bryon Heineman
27-Mar-91
Task Name
+ Pre-Listing Activities
+ NPL Listing
+ RI/FS
+ RX Process
Record of Decision Signed
•» Remedial Design
+ Remedial Action
Regional Appvl of Closeout
+ Operations and Maintenance
+ Site Deletion
™"™ Detai I Task =====
• ••• (Progress) =====
Progress shows Percent Achie

Rep
Summary Task
(Progress)
(Slack)
ved on Actual
weeks per cha
Start
Date
1-Mar-83
5-Oct-84
19-Aug-85
24-Jul-87
28-Sep-87
31-Mar-88
29- Dec -88
27-Mar-92
27-Mar-92
3-Jul-95
O » O O B

Duratn End
(Days) Date
292 24 -Apr -84
406 19-May-86
475 10-Jul-87
36 14-Sep-87
0 28-Sep-87
201 18-Jan-89
832 26-Mar-92
0 27-Mar-92
5,657 9-Oct-14
485 6-Jun-97
Baseline
Conflict
Resource delay
Milestone

83 84 85 86 87 88 89 90 91 92
Start Apr
Status 1 211 11 32 11

Done . . =================
Done ... . ===
Done . . . . A .

Future ... . .
Future ... . . .
Future ... . . .
•
;=«_


TIME LINE Gantt Chart Report.  Strip 1
                                                     ATTACHMENT A
                                             Crystal City Airport  Project
                                                       Schedule

-------
Schedule Name
Responsible
As-of Date
Crystal City Airport
Bryon Heineman
27-Mar-91
Task Name

  Pre-Listing Activities
     Site Abandonment by Operators
     Local Identification
     Initial TWDR Investigation
     TWOR Site Visit
     TWDR/EPA Prelim Sampling
     EPA Soil Sampling
     Initial Removal Action
     Verification Sampling
     Verfication Sampling
     Verification Sampling
     Subsequent Removal Action
  NPL Listing
     Site Proposed for NPL
     Site Promulgated on NPL
  RI/FS
     Project Planning
        Scoping Site Visit
        RI/FS Funds Awarded to TUC
        TWC Issues RFP
        RFPs Due at TWC
        TWC Awards Ri/FS Contract
        Ebasco Drafts WP, QAPP, HSP
        EPA/TWC Review Workplans
        Ebasco Revisions
        EPA/TWC Approval
     RI Fieldwork
        Onsite Mobilization
        Phase I Fieldwork
        Phase II Fieldwork
     RI Report
        Draft RI Report
        EPA/TWC Review RI Report
        Ebasco Revises RI Report
        Final RI Report
     FS Report
        FS Authorized
        FS Objectives Approved
        Ebasco Drafts FS Report
        EPA/TWC Review FS Report
        Ebasco Revises FS Report
        Final FS Report
  ROD Process
     Public Notice
     Extended Comment Period
     Public Meeting
  Record of Decision Signed
  Remedial Design
     Project Planning

Start
Date
1-Har-83
21-Apr-83
25-Apr-83
5-Hay-83
13-Jun-83
25-Jul-83
31-Oct-83
15-Dec-83
14-Feb-84
29-Har-84
23-Apr-84
5-Oct-84
5-Oct-84
20-Hay-86
19-Aug-85
19-Aug-85
19-Aug-85
25-Sep-85
25-Feb-86
28-Har-86
31-Har-86
1-Jul-86
31-Jul-86
25-Aug-86
19-Sep-86
29-Sep-86
29-Sep-86
30-Sep-86
28- Jan- 87
17-Feb-87
17-Feb-87
8-Apr-87
7- Hay- 87
2-Jun-87
25-Sep-86
25-Sep-86
27-Feb-87
25-Sep-86
18-May-87
15-Jun-87
13-Jul-87
24-Jul-87
24-Jul-87
27-Jul-87
20-Aug-87
?8-Sep-87
31-Mar-88
31-Mar-88

Duratn
(Days)
7O9
eye.
0
0
0
0
0
0
3
0
0
0
2
406
0
0
475
273
0
0
0
0
65
21
18
18
0
94
0
23
13
74
36
21
17
0
198
0
0
160
19
19
0
36
0
35
0
0
201
52

End
Date
Jt *—— »OA
c*>-Apl OH
1-Har-83
21-Apr-83
25-Apr-83
5-Hay-83
13-Jun-83
25-Jul-83
2-NOV-83
15-Dec-83
14-Feb-84
29-Mar-84
24-Apr-84
19-May-86
5-Oct-84
20 -Hay- 86
10-Jul-87
18-Sep-86
19-Aug-85
25-Sep-85
25-Feb-86
28-Har-86
30-Jun-86
30-Jul-86
25-Aug-86
18-Sep-86
19-Sep-86
13-Feb-87
29-Sep-86
31-Oct-86
13-Feb-87
1-Jun-87
7-Apr-87
6 -Hay- 87
1 -Jun-87
2-Jun-87
10-Jul-87
25-Sep-86
27-Feb-87
15-May-87
12-Jun-87
10-Jul-87
13-Jul-87
14-Sep-87
24-Jul-87
14-Sep-87
20-Aug-87
28-Sep-87
18-Jan-89
13:Jun-88
83
Start Apr
Status 1
Done A
Done A
Done A
Done A
Done A
Done A
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Done
Dpne
84

2

.
.
.
m
.
•
A
A.
A
•
.
f
,
.
.
.
.
m
.
.
.
.
.
.
.
.

.
.
.
.
.
.
.
.
.
.
.
.
.

.
.
.
,
.
.
                                                                             85

                                                                             1
86

1
87

1
88

1
89

3
90

2
91

1
92

1

-------
               RO CA Signed w/TWC
               TUC Receives RO SOW
               Ebasco/TUC Revise SOU
               EPA Reviews SOW
               Ebasco Revises SOW
               TWC/Ebasco Execute Contract
            30X Design Effort
               Ebasco Generates 30X RD
               EPA/TWC 30X Review
               30X RD Meeting
            60X Design Effort
               Ebasco Generates 60X RD
               EPA/TWC 60X Review
               60X RD Meeting
            95X Design Effort
               Ebasco Generates 95X RD
               EPA/TWC 95X Review
            100X Design Effort
               Ebasco Generates 100X RD
               EPA/TWC Review
               100X RD Revisions
               EPA Concurs W/100X RD
            Post-RD Open House
         Remedial Action
            Project Planning
               RA CA Signed u/TWC
               TWC Issues IFB
               Pre-Bid Conference
I™1*            Bid Period
CJ!            TWC Opens Bids
{jj-           TWC Signs A&E Contract
               TWC Signs Const. Contract
               Qua I tec Drafts Submittals
               Submittals Finalized
               Pre-Construction Conf.
            Aquisition of Site Access
               TWC Denied Access
               TWC Requests EPA Assist
               EPA Drafts 104 UAO
               City Receives UAO
               EPA/City UAO Meeting
               Effective Date of UAO
            TWC Issues NTP
            Field Work
               Mobilization
               Construction Activities
               Pre-Final Inspection
               Final Inspection
               Substantial Completion
               Vegetative Topcover Growth
               Final Completion
            RA Report
               Prep of Draft RA Report
            -   Ebasco Submits Draft to  TWC
               TWC Review of Draft RA Rep.
               EPA Receipt of Draft RA  Rep.
               EPA Review of Draft RA Rep.
               Revision of RA Rep. by Ebasco
               TWC Review of Revised RA Rep.
               EPA Receipt of Revised RA Rep
31-Mar-88
1-Apr-88
1-Apr-88
26-May-88
27-May-88
14-Jun-88
15-Jun-88
15-Jun-88
9-Aug-88
15-Aug-88
16-Aug-88
16-Aug-88
13-Sep-88
19-Sep-88
20-Sep-88
20-Sep-88
26-Oct-88
1-Mov-SS
l-Nov-88
21-NOV-88
23-Dec-88
18-Jan-89
19-Jan-89
29-Dec-88
29-Dec-88
29-Dec-88
31-Jan-89
16-Feb-89
31-Jan-89
13-Mar-89
7-Mar-89
21-Apr-89
21-Apr-89
16-May-89
8-Jun-89
K-Jun-89
14-Jun-89
13-Jul-89
23-Aug-89
6-Nov-89
17-Nov-89
23-NOV-89
29- Dec -89
5-Feb-90
5-Feb-90
5-Feb-90
6-Jun-90
9-Jul-90
3-Jul-90
28-Jun-90
25-Sep-90
3-Jul-90
3-Jul-90
30-Aug-90
31-Aug-90
7-Sep-90
10-Sep-90
5-Oct-90
10-Dec-90
18-Dec-90
0
0
39
1
6
0
42
38
4
0
23
19
4
0
29
25
4
51
13
23
15
0
0
832
111
0
0
0
29
0
0
0
17
14
0
116
0
0
52
0
0
0
0
167
0
104
0
0
0
64
0
213
48
0
26
0
19
46
35
0
31-Mar-88 Done
1-Apr-88 Done
25-May-88 Done
26- May- 88 Done
6-Jun-88 Done
14-Jun-88 Done
12-Aug-88 Done
8-Aug-88 Done
12-Aug-88 Done
15-Aug-88 Done
16-Sep-88 Done
12-Sep-88 Done
16-Sep-88 Done
19-Sep-88 Done
31-Oct-88 Done
25-Oct-88 Done
31-Oct-88 Done
17- Jan- 89 Done
18-NOV-88 Done
22-Dec-88 Done
17- Jan- 89 Done
18- Jan- 89 Done
19-Jan-89 Done
26-Mar-92 Started
7-Jun-89 Done
29-Dec-88 Done
31-Jan-89 Done
16-Feb-89 Done
13-Mar-89 Done
13-Mar-89 Done
7-Mar-89 Done
21-Apr-89 Done
15-May-89 Done
5-Jun-89 Done
8-Jun-89 Done
22-Mov-89 Done
14-Jun-89 Done
13-Jul-89 Done
2-Nov-89 Done
6-Nov-89 Done
17-Mov-89 Done
23-NOV-89 Done
29-Dec-89 Done
25-Sep-90 Done
5-Feb-90 Done
28-Jun-90 Done
6-Jun-90 Done
9-Jul-90 Done
3-Jul-90 Done
25-Sep-90 Done
25-Sep-90 Done
26-Apr-91 Started
6-Sep-90 Done
30-Aug-90 Done
5-Oct-90 Done
7-Sep-90 Done
4-Oct-90 Done
7-Dec-90 Done
25-Jan-91 Done
18-Dec-90 Done
A .

4 .
 A.

 A.

  A
  .A
  .A

  .  A

-------

























1 ._i
H^
EPA Review of Revised RA Rep.
EPA Receipt of As-Built^
Final Qua I tec Documentation
TWC Approval of RA Report
Regional Approval of RA Rep.
First Yr O&M = RA O&F Period
Planning
1st Yr O&M CA Signed (O&F)
EPA Concurs w/O&M/O&F SOW
TWC Signs O&M/O&F Contract
TWC Issues NTP to Ebasco
Monitoring Activities
1st Quarter O&M/O&F
Beginning of Quarter
Site Visit
Trip Report
TWC/EPA Review
End of Quarter
Public Update
2nd Quarter O&M/O&F
Beginning of Quarter
Site Visit
Trip Report
TWC/EPA Review
End of Quarter
3rd Quarter O&M/O&F
Beginning of Quarter
L Site Visit
CJt Trip Report
4^a





















§•
..
•i
. TWC/EPA Review
End of Quarter
4th Quarter O&M/O&F
Beginning of Quarter
Site Visit
Trip Report
TWC/EPA Review
End of Quarter
Closeout Report
TWC Submits Project Document.
Draft Closeout Report
TWC Review of Closeout Rep.
Closeout Report Revisions
TWC Concurrence
Regional Appvl of Closeout Rep
Regional Appvl of Closeout Rep
Operations and Maintenance
State Begins O&M
End of Thirty Year Period
Site Deletion
Five Year Review
Administrative Requirements
^m Detail Task ===== Summary Task
•• (Progress) ===== (Progress)
•— (Slack) 33= — (Slack)
IS-Dec-90
25-Jan-91
1-Apr-91
1-Apr-91
29-Apr-91
6-Jun-90
6-Jun-90
6-Jun-90
1-Aug-90
17-Sep-90
8-Oct-90
1-0ct-90
1-0ct-90
1-0ct-90
S-Nov-90
12-Nov-90
2-Jan-91
31-Dec-90
23-Jan-91
1-Jan-91
1-Jan-91
6-Feb-91
27-Mar-91
15-May-91
29-Mar-91
1-Apr-91
1-Apr-91
7-May-91
9-May-91
28-Jun-91
28-Jun-91
1-Jul-91
1-Jul-91
5-Aug-91
7-Aug-91
26-Sep-91
30-Sep-91
1-May-91
1-May-91
10-0ct-91
7-Nov-91
8-Jan-92
13-Feb-92
27-Mar-92
27-Mar-92
27-Mar-92
27-Mar-92
10-0ct-14
3-JUI-95
3-Jul-95
26-Dec-95
10
0
0
0
0
347
88
0
0
0
0
264
70
0
2
36
3
0
0
105
0
2
35
10
0
73
0
2
35
10
0
71
0
2
35
10
0
228
0
20
40
25
10
0
0
5,657
0
0
485
120
365
31-Dec-90
25-Jan-91
1-Apr-91
1-Apr-91
29-Apr-91
9-Oct-91
5-Oct-90
6-Jun-90
1-Aug-90
17-Sep-90
8-Oct-90
9-Oct-91
" 7-Jan-91
1-0ct-90
9-Nov-90
31-Dec-90
7-Jan-91
31-Dec-90
23-Jan-91
29-May-91
1-Jan-91
7-Feb-91
14-May-91
29-May-91
29-Mar-91
1Z-Jul-91
1-Apr-91
8-May-91
27-Jun-91
12-Jul-91
28-Jun-91
9-Oct-91
1-Jul-91
6-Aug-91
25-Sep-91
9-Oct-91
30-Sep-91
26-Mar-92
1-May-91
6-Nov-91
7-Jan-92
12-Feb-92
27-Feb-92
27-Mar-92
27-Mar-92
9-Oct-14
27-Mar-92
10-0ct-14
6-Jun-97
22 -Dec -95
6-Jun-97
Done . . . . . . ••
Done ... . . . . A


Future ... . . . . * .
Future ... . . . A
Future ... . . A
Started ... . . . - 	
Done ... . . . . ====
Done . . . . . . .A
Done ... . . . A
Done ... . . . . A
Done ... . . . . A

f
.
.
.
Started ... . . . • '
Done ... . . . ===
Done ... . . A
Done ... . •
Done . . . . . . . ••
Done ... . . . . •
Done ... . . . . A
Done ... . . . . A
.
.
e
.
.
.

Started ... . . . . ====
Done . . . . . . . A 1
Done ... . . . . «|
Future ... . . . . *•
Future ... . . . .
•
Future ... . . . . A
Future ... . . . . ===
Future ... . . . . A
Future ... . .
Future ... . . . .
Future ... . . .
Future ... . . .
Future ... . . .
Future ... . . . .
Future ... . . . .
Future ... . . .
Future ... . . . .
Future ... . . .
Future ... . . . .
Future ... . . .
Future ... . . .
Future ... . . .
Future ... . . . .
Future ... . . .
Future ... . . .
Future ... . . . .
Future ... . . . .
Future ... . .
Future ... . . . .
Future ' ... . . .
Future ... . . . .
Future ... . . . .
•
•
•
A .
3E=
A
•
•
•
A
-m i II II
A
•• .
•• .
•.
• .
A
A
5 • - .. .
A
.
.
.
•
«•«•• Baseline
»•»•>• Conflict
..•^ Resource delay
Progress shows Bercent Achieved on Actual A
Miles
tone

	 Scale- 6 weeks Der character -- 	 	 	 	 	 	
TIME LINE Gantt Chart Report,  Strip 1

-------
                        TABLE OF CONTENTS

SECTION   TITLE                                        PAGE

1.0       EXECUTIVE SUMMARY                              1

2.0       PROJECT SUMMARY                                3

  2.1        Site Location and Description               3
  2.2        Site History                                3
  2.3        General Geology/Hydrogeology                6
  2.4        Extent of Contamination                     7
  2.5        Assessment of Risks                         8
  2.6        Record of Decision                          9
  2.7        Remediation Criteria                        9
  2.8        Waste Excavation Criteria                  11
  2.9        Original RA Scope of Work                  12
  2.10       Field Orders                               13
  2.11       Change Orders                              16
  2.12       Nonconformance Reports                     18
  2.13       Filial Certificate of Substantial
             Completion                                 19
  2.14       Construction Cost Summary                  20

3.0       REMEDIAL ACTIVITIES                           22

  3.1        Manor Construction Activities              23
  3.2        Health and Safety Activities               30
  3.3        Quality Control Activities                 30
  3.4        Non-construction Issues                    31
  3.5        Construction Oversight Activities          32
  3.6        Construction Oversight Cost Summary        33

4.0       PREFINAL INSPECTION RESULTS                   34

  4.1        Narrative Summary                          34
  4.2        Items Inspected                            34
  4.3        Punchlist and Corrective Action            35

5.0       POST-CONSTRUCTION OPERATION AND               37
          MAINTENANCE

6.0       PROJECT FILES                                 38
                     ATTACHMENT B

           Crystal City Airport RA Report Contents
                                  155

-------
                             FIGURES
NUMBER    DESCRIPTION
  1       Site Location Map
  2       Construction Cost Summary
  3       Schedule of Construction Activities
4
21
29
                           APPENDICES
APPENDIX    DESCRIPTION
   A        As-Built Drawings
   B        Field Orders
   C        Change Orders
   D        Nonconformance Reports
   E        Substantial Completion Documentation
   F        Construction Cost Documentation
   G        Health and Safety Summary Report
   H        Chemical Quality  Control Project Summary Report
   I        Engineer's Weekly Progress Reports
   J        Construction Quality Control Daily Reports
   K        Weekly Progress Meeting Minutes
   L        Non-Construction  Issues
   M        Operations and Maintenance Plan
   N        Record of Decision (ROD)
                                 156

-------
                             ATTACHMENT c

                       ODESSA I REMEDIAL ACTION
                            INTERIM REPORT
                           TABLE OF CONTENTS



1.0    INTRODUCTION

2.0    SYNOPSIS OF SCOPE OF WORK, AND COMPLETION CERTIFICATION

      2.1   Record of Decision
      2.2   Description of the Original Construction Scope of Work
      2.3   Changes to the Original Scope of Work (Change Orders)
      2.4   Changes to the Project Technical Specifications  (Field Orders)
      2.5   Certification that the Work Was Done

3.0    DESCRIPTION OF REMEDIAL ACTIVITIES DURING CONSTRUCTION PHASE

      3.1   Chronology of Major Construction Activities
      3.2   Health and Safety (H&S) Activities
      3.3   Contractor Quality Control (CQC) Activities
      3.4   Resident Engineer Quality Assurance (QA) Activities
      3.5   Construction Cost Summary
      3.6   Non-construction  Activities

4.0    PREFINAL INSPECTION

      4.1   Narrative Summary
      4.2   Items Inspected
      4.3   Summary of Punchlist and corrective Action

5.0    PROCESS STARTUP AND OPERATION VERIFICATION

      5.1   Startup Chronology and Narrative Summary
      5.2   Operational Problems Encountered and Corrective Action
      5.3   Verification of Process Performance
      5.4   Optimum Operating Parameters, Recommended Maintenance Schedule, Average
           Utility Consumption
      5.5   Determination of Sludge Characteristics
      5.6   Certification that Performance Based Criteria had Been Met

6.0    DESCRIPTION OF PROPOSED TREATMENT AND CLOSURE PHASE ACTIVITIES
                                    157

-------
                               ATTACHMENT C

                             TABLE OF CONTENTS
                                   (Continued)
7.0   LIST OF APPENDICES
APPENDIX

      A

      B

      C

      D

      E
                   DESCRIPTION
      G

      H
            El
            E2
            E3
            Fl
            F2
            F3
            F4
            F5
            F6
Certification of Completion

Prefmal Inspection Report

Change Orders

Field Orders

Progress Reports

Operations Management Monthly Progress Reports
Resident Engineer's Progress Reports
Monthly Progress Meeting Minutes

Quality Control/Quality Assurance

Daily Operations Reports
Contractor's Daily Quality Control Reports
Contractor's Chemical Testing Reports
Contractor's Sludge Testing Reports
Resident Engineer's Chemical Testing Reports
Resident Engineer's Non-Chemical Testing Reports

Contractor's Requests for Payment

As-Built Drawings

Operation and Maintenance Plan
F:\CL\ODA\TOC
                                          158

-------
                           ATTACHMENT C
                     ODESSA I REMEDIAL ACTION

                            FINAL REPORT
                         TABLE OF CONTENTS
1.0         INTRODUCTION

2.0         INTERIM REPORT

3.0         DESCRIPTION OF REMEDIAL ACTIVITIES DURING TREATMENT AND
           CLOSURE PHASES

           3.1        Chronology of Major Activities
           3.2        Health and Safety (H&S) Activities
           3.3        Contractor Quality Control (CQC) Activities
           3.4        Resident Engineer Quality Assurance (QA) Activities
           3.5        Cost Summary
           3.6        Other Remedial Activities

4.0         WASTE DISPOSAL SUMMARY

5.0         PREFINAL INSPECTION

           5.1        Narrative Summary
           5.2        Items Inspected
           5.3        Summary of Punchlist and Corrective Action

6.0         PROPOSED POST TREATMENT OPERATION AND MAINTENANCE

7.0         DESCRIPTION OF PROJECT FILES

8.0         LIST OF APPENDICES
                                   159

-------
                             TABLE OF CONTENTS
                                   (Continued)
APPENDIX        	DESCRIPTION	


      A          Certification of Completion

      B          Prefinal Inspection Report

      C          Change Orders

      D          Field Orders

      E          Progress Reports

            El    Operations Management Monthly Progress Reports
            E2    Resident Engineer's Progress Reports
            E3    Monthly Progress Meeting Minutes
            E4    Monthly Well Reports

      F          Quality Control/Quality Assurance

            Fl    Daily Operations Reports
            F2    Contractor's Daily Quality Control Reports
            F3    Contractor's Chemical Testing Reports
            F4    Contractor's Sludge Testing Reports
            F5    Resident Engineer's Chemical Testing Reports
            F6    Resident Engineer's Non-Chemical Testing Reports

      G          Contractor's Requests for Payment

      H          As-Built Drawings

      I           Operation and Maintenance Plan
                                         160

-------
             WEDZEB ENTERPRISES REMEDIAL ACTION:
                  PLANNING FOR AN EFFICIENT
                  REMEDIAL ACTION COMPLETION
                (Auihor(s) and Address(es) at end of paper)

INTRODUCTION

The Superfund program  was  initiated with the promulgation of
the Comprehensive Environmental  Response,  Compensation,  and
Liability Act  (CERCLA) in  1980.   Through the early stages of
the Superfund program, the primary  focus of the program  was
completing  remedial investigations(RI)/feasibility studies
 (FS).  Near the end of the 1980s  and  in the early 1990s,  the
Superfund program shifted  emphasis  from RI/FS activities to
remedial design/remedial  action  (RD/RA)  activities.   As  the
Superfund program shifted  its  emphasis  to  the RD/RA phase,
effective planning and implementing of  remedial construction
activities  utilizing a phased  approach  was  imperative.
This was especially true  for complex  sites requiring multi-
media remedial actions of  several contaminated media.
Utilizing a phased approach to RD/RA  projects is essential
for the following reasons:

         It  ensures  that  Statements of Work for both fund-
         financed  and  potentially responsible party  (PRP)-
         lead  are  drafted to  allow for flexibility in the
         project  implementation schedule during the RD/RA
         phase.

         It  demonstrates  to the public that the U.S.
         Environmental  Protection Agency (USEPA) is
         progressing with remedial actions at National
         Priority  List  (NPL)  superfund sites.

         It  provides the  EPA  with a mechanism to demonstrate
         to  the public  that narrowly defined objectives of
         the Superfund  Program, namely RA start and RA
         completion, are  being attained.

This paper  will demonstrate how  a cost-effective phased
approach to an NPL Superfund site RA  was  implemented at  the
Wedzeb Enterprises site  in Lebanon, Indiana.

BACKGROUND

At the Wedzeb Enterprises  site,  a fire  which completely
destroyed a warehouse  containing  numerous  capacitors and
transformers containing  PCBs.  Although a  removal  action was
completed to remove the debris generated by the fire,  the
Phase I RI  analytical  results  (USEPA, 1989a)  indicated that
additional  surface soil and sediment  remediation was
necessary-  The Record of  Decision  (ROD) and the associated
Explanation of Significant Differences  (ESD)  specified that
the RA must involve cleaning and  testing approximately six
hundred feet of sewer  line, excavating  approximately fifteen
cubic yards of low-level PCB-contaminated  surface  soil,  and
offsite disposal  of sewer sediment, excavated soil,  and  RI-
derived waste (USEPA,   1989b).  A  phased approach to  the  RA
was chosen.                      -t o-t
                                lol

-------
Sanitary Sewer Activities

An RA contractor cleaned approximately six hundred feet of
sanitary sewer pipe over a three-day period in April 1990
(USEPA, 1990).  The cleaning was accomplished by
hydraulically jetting the pipe, then suctioning the liquid
and sediment with a vacuum pump from a manhole to a
temporary reservoir tank.  From the temporary reservoir
tank, the liquid containing the sediment was pumped through
a bag filter and a carbon adsorption unit to remove organic
contaminants.  The liquid was finally metered to a carbon-
steel holding tank, where samples were collected to
determine contaminant concentrations.

The hydraulic jetting consisted of running a hose with a jet
nozzle attachment through the 600-foot segment of sanitary
sewer pipe, scouring the pipe walls with high-pressure
water.  Standard sewer plugs were used at both manholes to
block the flow of jetted water downstream and to temporarily
prevent the flow of wastewater into the adjacent segment
which did not require cleaning.  Once the plugs were
installed, the pipe line was jetted using a variety of
nozzles that spray along the pipe walls at various angles.
The sediment and grit deposited in and on the pipe was
flushed to the downstream manhole.  Once the jetted water
and loosened sediment were collected in the downstream
manhole, a vacuum truck with a submersible hose pumped out
the manhole.  The fluids from the manhole were then pumped
to a temporary reservoir for storage and settling of solids
from the fluids.  From the temporary reservoir, the fluids
were sent through the bag filter to separate the solids from
the liquids, retaining the solids within the unit.

After passing through the bag filter, the liquid was then
sent through carbon adsorption units to remove the volatile
organic compounds and PCBs.  The carbon adsorption units
removed the organic contaminants in the water, including
PCBs that the bag filter had not removed.  After filtration
was complete, the carbon was containerized and later
composited with existing Rl-derived waste during the RI-
derived waste disposal activities, which were completed in
August 1990.

A tanker truck was used to contain the water as it was
discharged from the carbon adsorption units.  The tank's
5,000-gallon capacity was sufficient to contain the liquid
generated from the jetting and pumping operations.

Disposal of the generated wastewater from the tanker and
sewer sediment was the final procedure in the remediation
process.  A liquid sample collected from the 5,000-gallon
tanker and a sediment sample collected from the bag filter
                              162

-------
were analyzed to determine the magnitude of PCB
contamination.  The analytical results from the liquid and
sediment samples indicated no PCB contamination.  Therefore,
the wastewater was discharged to the sanitary sewer.  The
sediment was containerized and later composited with
existing Rl-derived waste during RI-derived waste disposal
activities.

After the sanitary sewer had been cleaned and the wastewater
had been removed, the pipe was inspected.  This television
inspection consisted of a skid-mounted, closed-circuit
camera that sent signals to an aboveground monitor.  The
camera was guided through the pipe by a winch and pulley
system, and the monitor was located in an onsite vehicle.
Operation of this apparatus consisted of pulling the camera
skid between two manholes.  A tag line attached to the rear
of the camera allowed the operator to back up the camera.  A
footage meter kept track of the distance traveled so that
any problem could be readily located.  The inspection was
videotaped to provide a permanent record of the inspection.

The results of the television inspection indicated that the
sewer was structurally sound and clean from contamination.
A videotape of the inspection was recorded and put in the
project file.

Soil Excavation and Disposal Activities

An RA contractor excavated and removed approximately
fifteen yards of surface soil to a depth of 3 to 6 inches
along the southern and eastern part of the site.  The
location and depth of removed soils were based on the August
and December 1989 Indiana Department of Environmental
Management  (IDEM) analytical sampling results.

During the soil excavation, 30 drums containing wastes
generated during the RI and the sanitary sewer RA were
composited with the excavated soils.  These composited soils
were sampled and analyzed in May 1990 to determine their PCB
concentrations.  The sample analytical results indicated
less than 15 ppm PCBs.  Based on these analytical results,
the excavated soil was composited with the Rl-derived waste,
and a total of 20 yards of material was transported to the
Prairie View sanitary landfill, for more cost-effective
disposal.  This excavation and disposal was completed in
three days.

In addition, 30 drums were emptied and crushed onsite.
Because they had not been used to containerize any wastes,
these nonhazardous crushed drums were sold to  a scrap-metal
distributor.
                               163

-------
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

-------
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.
                               165

-------
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
                                166

-------
                               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
                                              167

-------
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.
                                            168

-------
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.
                                              169

-------
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
                                             170

-------
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.
                                               171

-------
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.
                                                 172

-------
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.
                                           173

-------
               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.

                                 174

-------
            ST. TAMMANY PARISH, LOUISIANA
                   Figure 1

                   Bayou Bonfouca Site
                   Slidell, Louisiana
175

-------
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

-------
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

-------
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

-------
     •     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

-------
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

-------
    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

-------
     •     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

-------
28-9!   J: \QiS\i.MOUSr\MGvFO^O\3YLNPS4 DWG
SCREEN FEED
HOPPER ---•—
DREDGED BAYOU
SEDIMENTS
LOW SPEED
CONVEYOR
CONVEYOR TO
V/BRA TING
SCREEN
                                                         < 14"
                                                         MATERIAL
DOUBLE DECK
VIBRA TING SCREEN
ASSEMBLY
                                           < 2"
                                      MATERIAL
                                                                                    > 2"
                                                                                    MATERIAL
                                                                   CLASSIFIED
                                                                   DREDGED SEDIMENTS
                                                                   TO DRUMS
                                                                               Figure 3
                                                             VIBRATING SCREEN SCHEMATIC
                                                                         Bayou Bonfouca
                                                                         Slidell, Louisiana

-------
Equipment and Procedures

Dewatering studies have been performed to indicate viable dewater-
ing methods  for  reducing  the  water content of  the  dredged sedi-
ment.  This  experimentation has been performed  in  three phases:
during the initial design  investigation, during the pilot study,
and following the  pilot study at an offsite  testing laboratory.
During the design investigation of 1988, dredged sediment was not
available, so drainage channel sediment,  vibracore samples,  and
bayou water were  used  to prepare a synthesized sediment sample for
settling and  dewatering tests.   Portions of the synthesized sample
were tested using the  following methods over a range of dilutions:

     •    Polymer  jar  tests  (using vendor-supplied products  and
          technical assistance)
     •    Batch flux curve settling tests  (using graduated cylin-
          ders)
     •    Gravity settling tests (using 6-inch-diameter by 8-foot-
          tall column)
          Capillary suction time tests
          Buchner funnel tests (lab-scale  vacuum filtration)
          Sludge drainage tests (bench-scale sand bed simulation)
          Pressure filter tests (using bench-scale device)
          Filter leaf tests (using lab-scale apparatus)

Pilot study  testing was performed in  1989  on  sludge dredged from
near  the  bulkhead on  the  southern border of  the  site,  using  a
clamshell dredge.  It  was believed that these dredged samples were
more  representative than  synthesized  samples  tested in  the 1988
Design Investigations, yet not  necessarily  representative of  the
entire area to be dredged during remediation.  The following tests
were performed on the dredged  samples over a range of dilutions:

     •    Gravity settling tests (using 6-inch-diameter by 8-foot-
          tall column)
          Capillary suction time tests
          Filter-leaf tests (using lab-scale apparatus)
          Sludge drainage test (bench-scale sand bed simulation)
          Filter press tests (1 ft3  pilot unit)
          Lab-scale vacuum-assisted sludge dewatering bed polymer
          dose testing
     •    Pilot-scale  (8  ft3)   vacuum-assisted  sludge  dewatering
          bed tests
     •    Lab-scale (400-ml) vacuum-assisted sludge  dewatering bed
          tests

A portion of dredged  sample was  transported offsite to a testing
laboratory.  Shortly  after the pilot study,  the laboratory per-
formed the following lab-scale tests:

     •    Basket centrifugation
     •    Solid-bowl centrifugation
     •    Vacuum filtration
                                184

-------
          Pressure filtration
          Simulated trommel screen dewatering
Results
Table 3 presents the results of the settling and dewatering test-
ing performed.

The  pilot  study  as-dredged material  was  typically  from  32 to
37 percent solids.  The range of dewatering processes tested indi-
cated that solids concentrations of up to 50 percent were possible
using sludge drainage,  vacuum filtration, and centrifugation tech-
niques.  Many of these  techniques employed polymers or other addi-
tives to reach the higher solids concentrations.

This  dewatering  testing  has   provided  information  that can  be
applied  to  numerous   remedial  design  scenarios  for  the  Bayou
Bonfouca site.  Testing dilute  sludges has provided information on
the  dewaterability  of  hydraulically dredged sediment, while the
more concentrated samples have provided results that describe the
dewaterability of the  mechanically dredged  sediment or thickened
hydraulically dredged  sediment streams.  Information  on polymer
and  additive  dosing has also  been collected for certain process
options over a range of feed concentrations.

AIR CONTAMINANT EMISSION FLUX TESTING

Preliminary flux  values were calculated for air contaminant dis-
persion modelling efforts in the 1988 design investigation phase.
These values had been calculated using TSDF, based on the simpli-
fying assumption that the composition of the emission from contam-
inated  soils and  other  material was  100 percent  naphthalene.
Since air  emissions resulting  from the  remediation efforts are a
major concern at the Bayou Bonfouca site, it was recognized during
the planning of the Pilot Study phase of predesign work that more
accurate measurements of the magnitude and estimates of the compo-
sition of air emissions resulting from anticipated remedial opera-
tions were necessary.

Equipment and Procedures

To define a list of target compounds in bayou sediment emissions,
a  sample  of sediment was  obtained prior to air emissions field
work and was sent to an off site laboratory for gas chromatography/
mass spectroscopy  (GC/MS)  analysis.  The  results of this charac-
terization were used to identify target compounds and plan appro-
priate analytical techniques  for  use in the field pilot testing
effort.

Early in the  Pilot  Study planning  activities,  plans were made to
fabricate air contaminant flux chambers  to obtain contaminant flux
                                185

-------
Table 3
Comparison of Dewatering Results from 1988 Design Investigation, Pilot Study,
and Offsite Laboratory Activities

Polymer Jar Test
Batch Flux Settling Test
Gravity Settling Test
Buchner Funnel Test (vacuum
filtration)
Filter Leaf Test
Sludge Drainage Test (sand
bed simulation)
Pressure Filter Test
Bench-Scale Vacuum-Assisted
Dewatering Test
Pilot-Scale Vacuum-Assisted
Sludge Dewatering Bed
Testing
Pilot-Scale Plate and Frame
Filter Press Test
Basket Centrifugation Test
Solid Bowl Centrifugation
Test
Continuous Solid Bowl
Centrifuge Test
Pressure Filtration
Trommel Screen Dewatering
Simulation Test
Ranges of Solids Concentration Achieved by Various
Dewatering Methods for Each Investigation
(percent by weight)
1988 Design
Investigations
17.2-22.0
(4.6-10)
14.7-22.6
(4.6-10.7)
16.7-19.3
(14.2-22.6)
46.4-53.2
43-47
(17.5)
42.3-50.7
*
NP
NP
NP
NP
NP
NP
NP
NP
Pilot Study
NP
NP
(4.7-15.2)
14.4-26.2
NP
(5-20)
33.2-42.7
(16.9)
31.0-49.2
NP
(18-22)
37.1-42.5
(8-22)
22-38
(8.2-22)
22.6-30.0
NP
NP
NP
NP
NP
Offsite Laboratory
NP
NP

(26.5)
37-39
NP
(10-30)
23-30
NP
NP
NP
NP
(43.1)
46.7-50.4
(25.0-36.5)
40.0-47.8
(35.0)
25.2-51.2
(36.5)
45-46
(30.0)
32.6
Upper entry ( ) indicates the initial solids concentrations.
Lower entry indicates the final dewatered sludge solids concentrations.
All concentrations presented as percent total solids by weight.
NP = Test not performed.
*Test did not produce reportable results.
186

-------
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

-------
                                                           ,Air Inlet
                Lightnin XJ-43
       Mixer with Variable Speed
       0-200 SCFH
        Rotameter
 Plexiglass
 Inspection
      Port
OO
GO
                                       Lightnin 10"
                                      A-310 Agitator
                                                                                               Raked Air Test Chamber
               Typical Agitated
              Air Test Chamber
                                                                                                                Figure 4
                                                                                                                Air Test Chamber
                                                                                                                Design
                                                                                                                Bayou Bonfouca
                                                                                                                Slidell, Louisiana

-------
Table 4
Experimental Plan for Air Emission Flux Testing
Sludge Composition
As dredgeda
Diluted (high solidsb)
Diluted (low solldsd)
Diluted (high solids)
Diluted (low solids)
Diluted (low solids)
Diluted (low solids)
Diluted (low solids)
Type of Test
Stirred
Agitated (low speedc)
Agitated (low speed)
Agitated (high speed6)
Agitated (high speed)
Agitated (high speed) , heated
Agitated (low speed), oxidizer added @ 4:1
ratio1
Agitated (high speed), oxidizer added @ 4:1
ratio
Comments
4 runs
4 runs
4 runs
4 runs
4 runs
1 run
1 run
1 run
?As dredged solids: 35 to 43 percent solids, 1.1 to 1.6 percent PHAs by weight.
°High solids: 14 to 37 percent solids and 0.68 to 1.01 percent PNAs by weight.
-Low speed: less than 185 rpm with 10-inch Lightnin A-310 impeller.
"Low solids: 8 to 19 percent solids and 0.43 to 0.66 percent PNAs by weight.
|High speed: greater than 185 rpm with 10-inch Lightnin A-310 impeller.
xMoIar ratio of KMn04 to naphthalene in sludge samples.
The drums were all purged with filtered air at a rate of 100 scfh,
which equates  to  approximately  one headspace  every 1.5 minutes.
The purged  air stream from  each drum during  a run was  usually
exhausted to  a carbon canister.   The purged stream was periodi-
cally diverted to  sampling equipment through three-way valves.  As
shown in Figure 4, the headspace was  thoroughly mixed  during the
agitated tests by means of a flat-blade fan mounted on the agita-
tor shaft.  Sampling  intervals  for the air tests  were generally
15 minutes  apart,  while  the  duration of  each test ranged  from
approximately 40 minutes  to 2 hours.

Results

Pre-Pilot Study  GC/MS characterizations  performed with  a bayou
sediment sample indicated that there  were around 100 hydrocarbon
compounds in   the  headspace above  the  sediment  sample.   These
results also  indicated that there were  approximately  10 ppm of
nolimethane hydrocarbons in equilibrium with the sediment sample.
The analysis was able to  identify compounds that made up approxi-
mately 25 percent of  the nonmethane hydrocarbon value.  Based on
this analysis  and  previous  work, the following target compounds
were identified:

          Naphthalene
          Benzene
          Toluene
          Xylenes
          n-Propylbenzene
          1,2,4-Trimethylbenzene
          l-Ethyl,2-methylbenzene
          1-Propylbenzene
                                 189

-------
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

-------
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

-------
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

-------
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

-------
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

-------
                            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

-------
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

-------
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

-------
                                 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

-------
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

-------
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

-------
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

-------
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

-------
the finer grid along the eastern edge of the landfill to Edwards Run. Each of the 2D sections was
analyzed separately and the results combined to determine total anticipated withdrawal rates.

The width of each of the 2D sections was kept equal to the width of the corresponding rows in the
3D model. Initial heads were derived from actual conditions, however, potentiometric levels within
the Mt. Laurel were not permitted to rise above the ground surface during non-flood conditions. And
finally,  the Marshalltown was divided into 4 and 8 layers, (instead of just 2) for Sections C and D,
respectively, for the purposes of developing a flow net.

Each cross-section was analyzed for two conditions, resulting in a total of twelve cases identified in
Table 5.  Cases 1 through 6 represent the lack of slurry wall on the downgradient side of the landfill,
while Cases 7 through  12 represent its presence and the accompanying increase  in collection drain
elevation. The transient flow analyses were performed for a period of 30 years. Results are presented
in Table 6.

Table 6 shows that steady-state flows to the leachate collection drain are 58.7 gpm (60 gpm) for the
current design under normal Edwards Run flow conditions. These flows are reduced to 35.7 gpm (40
gpm) when a slurry wall in introduced between the drain and Edwards Run.  Over a period of 30
years and using 60 gpm and 40 gpm rates  in the analysis, this results in a total reduction of 315
million gallons of collected leachate.

TASK 5VE — Cost-Benefit Analysis of Upgradient Subsurface Drain

The previous analysis established that, due to the construction of slurry walls, the groundwater level
to the north, west, and south of the landfill could rise by 2 to 3 feet over a period of 30 years. This
increase in groundwater levels would cause an increase in the hydraulic gradient across the slurry wall
and flow into the landfill either through the slurry wall, or the  Marshalltown beneath it.  It was
therefore surmised that a subsurface drain constructed at the current groundwater level outside of the
upgradient slurry wall could prevent such a condition. The cost-effectiveness of the upgradient drain
was reviewed under Task 5VE by estimating the potential costs associated with the construction of
the drain, and the potential savings in treatment plant capital and O&M costs resulting from reduced
leachate flows attributable to this drain.

A three-foot wide French drain approximately 5,500 feet in length was assumed at a distance of 20
feet from the upgradient slurry wall. This placed the drain very close to the point where groundwater
levels from the computer model were at  a  maximum.  Three different depths were considered to
achieve the following:

(1)    maintenance of the existing water level (elev. 63 ft.);
(2)    significant reduction in the water level (elev. 43 ft.); and
(3)    moderate reduction in water level (elev. 53 ft.).

Case 4VE6 was used as the base case for comparison  purposes which consisted of a cap, a fully-
enclosing slurry wall with a key depth  of 5 feet, and leachate collection drain at elevation  20 feet.
The resulting flow rates are shown in Table 7. The costs estimated for construction of the upgradient
drains, and the savings associated with leachate treatment are shown in Table 8. These estimates show
that upgradient drain construction costs far outweigh any potential savings in reducing the cost of
leachate treatment. This drain was therefore not recommended as part of  the remediation.
                                             207

-------
TASK 7VE — Assess Impact of Higher Permeability of the Marshalltown

The Marshalltown, into which the slurry wall will be keyed, has been considered to be an aquitard.
Large variations in permea- bility were measured in the laboratory varying from 3E"7 cm/sec to 2E~4
cm/sec.  While still less pervious  than the overlying Mt. Laurel and the  underlying Englishtown
formations, the Marshalltown's effectiveness in reducing flow into the landfill is expected to be less
than what it would have ordinarily been if it were a true aquitard. The objective of this task was to
make an assessment of the variations in leachate quantities that would be withdrawn given different
permeabilities  of the Marshalltown.

Again, Case 4VE6 was used as the base case.  In this simulation, the horizontal conductivity value
assigned to the Marshalltown was 0.254 ft/day (9E~5 cm/sec), the vertical conductivity assigned was
0.0254 ft/day (9E~6 cm/sec). Both of these values were the result of the calibrated regional-scale
groundwater flow model.  Variations of hydraulic conductivities were simulated as shown below:

       7VE1 - Base case; slurry wall key at 5 feet
       Marshalltown
              Kh = 0.254 ft/day
              Kv = 0.0254 ft/day

       7VE2 - Increase values
              Kh = 2.54 ft/day
              Kv = 0.254 ft/day

       7VE3 - Decrease values
              Kh = 0.0254 ft/day
              Kv = 0.00254 ft/day

       7VE4 - Base case; slurry wall key at 20 feet

       7VE5 - Use 7VE2;  slurry  wall key at 20 feet

       7VE6 - Use 7VE3;  slurry  wall key at 20 feet.

Results are presented  in Table 9.  By  increasing the hydraulic conductivity values by an order of
magnitude, withdrawal rates almost doubled.  That is, flow increased from 28 gpm to approximately
51 gpm for a 5-foot key depth; and from 29 gpm to 54 gpm for a 20-foot key depth.  By decreasing
the hydraulic  conductivity  of the  Marshalltown,  withdrawal rates  decreased from 28 gpm to
approximately 15 gpm for both depths of slurry walls.  Both the  increase and decrease in rates was
attributable to  upward flow to  the Mt. Laurel through the Marshalltown on the eastern edge of the
landfill. While these results indicate that withdrawal rates are sensitive to the hydraulic conductivity
of the Marshalltown, a tenfold increase over the entire extent of the unit was felt to be unrealistic.
Therefore, the pretreatment plant  design capacity was not modified.  If necessary, additional daily
shifts could be added to reliably handle the flows that might arise if actual permeabilities were much
greater than those previously measured.

TASK 8VE - Downsizing of Treatment Facility

During the preliminary design phase, groundwater collection rates were developed and a 300 gpm
pretreatment facility was specified.   The size of this pretreatment  facility was dictated by the
generally larger leachate volumes  collected during the first two years of its operation.  As the flow
rates decrease with time, the required plant capacity also decreases. It was therefore prudent to study
                                                208

-------
ways to develop a more balanced design concept, and realize a cost savings resulting from such a
design.   The objectives  of this task were:  to develop  cost estimates  for  various size  (capacity)
pretreatment facilities; to make an assessment of the technical viability of reducing the pretreatment
plant size; to assess the placement of a slurry wall along Edwards Run; and to carry out a cost-benefit
analysis for the slurry wall and the downsized facility that results.

In addition to the pretreatment facility,  two additional  designs were evaluated based  on the
withdrawal rates developed using results from the two-dimensional groundwater flow simulations in
Task 4VE. The first design included a cap, upgradient, north and south slurry walls, and a leachate
collection drain located on the downgradient edge of the landfill.  The collection drain was  located
at a depth approximately 6 inches below the elevation of Edwards Run in order to maintain flow into
the drain. The withdrawal rate associated with this first design was 58.7  gpm (approx. 60 gpm). The
second  design consisted of a fully-enclosing  slurry wall (addition of a slurry  wall  along the
downgradient side of the landfill) which allowed the collection drain to be located at an elevation of
20 feet.  The withdrawal rate associated with this second design was 35.7 gpm (approx. 40 gpm).

Table 10 presents the flow rates for the  three designs over a period of 30 years and the anticipated
number of shifts per week required for operation of each facility. The original flow rates of  60 gpm
and 40 gpm have been increased to process plant design flow rates as detailed in the table. The capital
costs associated with the pretreatment plant construction were developed under this task. Preliminary
design calculations had previously not included O&M costs for the pretreatment facility, therefore
these were developed as well  to allow comparison of the life-cycle cost of the alternatives.  The
leachate stream composition was assumed to be the same for all leachate flow rates and the same as
determined in the Treatability Study performed for this site. An onstream factor was included to
account for process down-time attributable to scheduled maintenance, process upsets, and potential
equipment failure.  Major components of the pretreatment process train are shown on Figure 8. All
equipment was included  with  each of the three designs - that is, no equipment was left  out of the
reduced flow rate designs.  Equipment sizes were reduced in proportion to the flow rates.

Estimation of  the capital costs of each system was based on an in-depth assessment of the system
components required. For each design, the system components were identified and sized on the basis
of the character and volume of leachate to be treated. Table 11 presents the cost-benefit analysis of
reducing the size of the pretreatment facility.  Capital costs associated with the  180  and 120 gpm
facilities, while  similar, are substantially less than those for the 300 gpm facility.  The 120 gpm
facility has a slightly higher capital  cost than the 180 gpm facility due to the construction of the
downgradient slurry wall. In comparing O&M costs, the 120 gpm facility is substantially less costly.
Overall then, the 120 gpm facility is anticipated to realize a $2.5 to $3 million savings in project cost
(in 1988 dollars) over the 300 gpm design.

TASK 9VE — Develop Final Recommendations

The recommendations detailed in the Conclusions section of this paper were presented to the client
based on the results of the Value Engineering studies. These recommendations provided for a  savings
in total project cost estimated  to be over $3 million in 1988 dollars.

CONCLUSIONS

Upgradient Subsurface Drain

Analysis of results from Task 5VE established that remedial action implementation would  cause only
a small rise in the current groundwater level to the west, north, and south of the site. Costs analyses
showed that the construction cost of a subsurface drain upgradient of the  slurry wall would be greater
                                               209

-------
 in comparison to the potential savings in reduced leachate flows to the downgradient drain. On the
 basis of these findings, it was therefore recommended that no upgradient drain be constructed.

 Depth of Slurry Wall Key into the Marshalltown

 Analyses performed in Tasks 4VE and 7VE showed that an increase in the depth of slurry wall key
 from 5 feet to greater depths has an insignificant impact upon flow patterns and withdrawal rates
 from the leachate collection drain. A 5-foot key, is sufficient to create a flow pattern which causes
 upward flow from the underlying Englishtown aquifer through the Marshalltown into the Mt. Laurel
 thus preventing  downward migration of leachate from the landfill into the underlying units.  This
 reduced the cost of the slurry wall in both the detailed design and during construction.

 Slurry Wall Along Edwards Run and Downsizing of the Pretreatment Facility

 Results of Task 4VE showed a significant reduction in withdrawal rates from the leachate collection
 drain with  the addition of a downgradient slurry wall along Edwards Run, and raising the elevation
 in the drain to 20 feet.  Based on results of the two-dimensional simulations, the flow rates to the
 drain were  reduced from approximately 60 gpm to 40 gpm. The offsetting cost for constructing the
 downgradient slurry wall was estimated at close to over $1  million.  The reduction in flow  rates
 corresponds to a potential for downsizing the pretreatment facility for a total overall savings of $2.5 -
 $3 million (in 1988 dollars) in both capital and O&M costs.  In addition, enclosing the landfill with
 a slurry wall provides for full containment and offers greater overall reliability in leachate collection,
 as well as provides a mitigative effect on the site from flooding of Edwards Run.

 REFERENCES

 NOAA, National Oceanographic and Atmospheric Administration, Climatological Summary for
 Philadelphia, PA, 1985.

 R.E.  Wright Associates, Inc., Draft Remedial Investigation Report  and Feasibility Study of
 Alternatives, Helen Kramer  Landfill Site, Mantua Township, Gloucester County, NJ,  September
 1986.

 Thornthwaite, C.W., and J.R. Mather, "The Water Balance", Drexel  Institute of Technology
 Centerton,  NJ, 1955.

 Fenn, D.G., K.J. Hanley, and T. DeGeare, "Use of the Water Balance Method for Predicting Leachate
 Generation from Solid Waste Disposal Sites", EPA/530/SW-168, 1975.

Schroeder, P.R., J.M. Morgan, T.M. Walski, and A.C. Gibson, The Hydrologic Evaluation of Landfill
Performance (HELP) Model, Volume I, User's Guide for Version I,  EPA/530-SW-84-009, 1983.

McDonald,  M.G., and A.U. Harbaugh, A Modular Three-Dimensional Finite-Difference Ground-
Water Flow Model, prepared  by the U.S.  Dept. of the Interior, USGS,  Reston, VA, 1984.
                                            210

-------
                                     LEACHATE
                                     COLLECTION
                                     PONDS
                                         SOOOY MILL
                                         IMPOUNOMENT
         LEGEND
                                                          4QO        0        «OQ

^^^^ su     *      '                                             SCALE IN FEET

*~ •  3*»>"'v  4flE*3       REFERENCE: RI/FS FIGURE 5-2 (R.E. WRIGHT,  1986)
URS
CONSULTANTS, INC.
SITE LAYOUT
FIGURE 1
                                         211

-------
         A-3694
to
h-»•
ro
              I OO
               HU
               60
           >   40

           CD
           UJ
           UJ
           U_
z
0-20
           UJ  -4O
              -60
              -8O
          Marthalllown Formation
                           4OO
                                     800
                                                I2OO       I6OO       2OOO

                                               10 X VERTICAL EXAGGERATION
                                                                              2400
                                                                                        28OO
                                                                                                  3200
                                                                                                             3600
                                                                                                               -20  O
                                     Cnglishtown   Formation
                                                                                                   •.•A..-.v,-,-f.-.v..v.-.v.v.v.-.-iv.v.-.v.il -BO
                                                                                                                4O
                                                                                                                           20
                                                                                                                   O
                                                                                                                   CD
                                                                                                           400O
          REFERENCE: RI/FS FIGURE 4-3  ( R.E. WRIGHT. 1986)
               URS
             CONSULTANTS, INC.
                              CROSS-SECTION OF HYDROGEOLOGIC  UNITS
FIGURE  2

-------
                           COLUMNS"
                                         MAP TAKEN FROM USGS WOODBURY
                                         QUAD. NEW JERSEY - PENN. 7.5
                                         MINUTE SERIES! DATED 1967
-RESIDENTIAL WELLS
                       AREAL  EXTENT OF  REGIONAL
                         GROUNDWATER  MODEL
FIGURE 3
                                  213

-------
M_
                             ROWS
                                                   I  234567  8 9 10 II \Z 13 14 15 16 17 18  19 20
                LAYER I
                                                                                       LEGEND
                                                                                          INACTIVE CELL
                                                                                          HELO-HEAD CELL
                 URS
                CONSULTANTS, INC.
DISCRETIZATION OF REGIONAL GROUNDWATER SYSTEM
FIGURE 4

-------
                        LOCAL MODEL BOUNDARY
    \
MAP TAKEN FROM USGS WOOOBURY
QUAD. NEW JERSEY-PENN. 7.5
MINUTE SERIES! DATED 1967
                           jeU**'
       URS
      CONSULTANTS, INC.
LOCATION OF LOCAL
GROUNDWATER MODEL
                                215

-------
  '""•III,        •'>'''   "^V^         ^^

iiiiiiiiiiiiin  LOCAL MODEL GROUNDWATER CELL BOUNDARIES
            LOCATION OF 2D SECTIONS (A THROUGH F)
                                    SCALE
                                 0  200' 400'
   URS
  CONSULTANTS, INC.
LOCATION  OF  2D  SECTIONS
FIGURE  6
                                 216

-------
ro
                  6
                  £ «u

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

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

-------
                             TABLE 1

           DATA FOR LOCAL SCALE GROUNDWATER FLOW MODEL
Parameter
Mt. Laurel   Marshalltown   Englishtown
HYDROGEOLOGY

Horizontal hydraulic
conductivity (cm/sec)

Vertical hydraulic
conductivity (cm/sec)

Porosity

Fluid density (kg/m3)

Unit saturated thickness

Edwards Run water levels
adjacent to site

Infiltration


Length of simulations
    7E
    7E'5


    0.35

    1.000

   variable
 9E
                  -5
 9E"6


 0.40

 1.000

25-40 ft
   8.5 to 15.5 ft

   Natural - 10.5 in/yr
   Capped - 1.6 in/yr

   30 years
10
                  -2
10
  -2
0.25

1.000

25 ft
                               219

-------
                                    TABLE 2
                           DESCRIPTION OF CASES 1-16


RUN*


CASE 1 4 VE 1
CASE 2 4 VE 2
CASE 3 4 VE 3
CASE 4 4 VE 4
CASE 5 4 VE 5
CASE 6 4 VE 6
CASE 7 4VE7
CASE 8 4 VE 8
CASE 9 4 VE 9
CASE 10 4VE10
CASE 11 4VE11
CASE 12 4VE12
CASE 13 4VE13
CASE 14 4VE14
CASE 15 4VE15
CASE 16 4VE16


DIMENSION


3D
3D
3D
3D
3D
3D
3D
3D
3D
3D
3D
3D
3D
3D
3D
3D
UPGRADIENT
DRAIN
DEPTH
FROM W.T.
(ft.)
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE

SLURRY WALL
KEY INTO
MARSHALLTOWN
(ft.)
NONE
5
10
20
NONE
5
10
20
5
5
5
5
5
5
5
5
DOWNGRADIENT
DRAIN
WATER LEVEL
ELEVATION
(ft.)
6* BELOW E.R.
6" BELOW E.R.
6" BELOW E.R.
6" BELOW E.R.
20
20
20
20
20
NONE
NONE
20
6" BELOW E.R.
6" BELOW E.R.
20
6* BELOW E.R.

DOWNGRADIENT
SLURRY WALL


NONE
NONE
NONE
NONE
NONE
YES
YES
YES
YES
YES
YES
YES
NONE
NONE
YES
YES


NOTES:










INCREASED K IN MT. LAUREL
ENCLOSED SYSTEM
ELIMINATE DOWNGRADIENT DRAIN
SIMULATE 100 YR. FLOOD FOR 30 YRS.
SIMULATE 100 YR. FLOOD FOR 30 YRS.
INCREASED K IN MT. LAUREL
INCREASED K IN MT. LAUREL
AND MARSHALLTOWN
o

-------
ro
                                                    TABLE  3
                               GROUNDWATER FLOW RATES FOR CASES 1-16
RUN*
CASE1 4VE1
CASE 2 4VE2
CASE 3 4 VE 3
CASE 4 4 VE 4
CASE 6 4 VE 5
CASE 6 4 VE 6
CASE 7 4 VE 7
CASE 8 4 VE 8
CASE 9 4 VE 8
CASE 10 4VE10
CASE 11 4 VE 1 1
CASE 12 4VE12
CASE 13 4 VE 13
CASE 14 4 VE 14
CASE IS 4VE15
CASE 16 4 VE 16
TIME - 1 1 DAYS TIME - 1 YEAR TIME - 30 YEARS
L
W
10,237
10,481
10,685
10,675
7,567
7,751
7,941
7,979
42,533


7,794
11,043
50,106
53,259
62,919
L
E
2,045
2,169
2,282
2,290
0
330
404
404
288


657
8,390
8,308
2,131
4,243
U
187
273
264
233
121
156
165
160
144


161
126
79
522
915
N&S
76
78
79
80
0
0
0
0
0


0
307
280
0
0
TOT FLOW
TO DRAIN
(tt-3/d)
(gpm)
12,545
66
13,001
68
13,310
70
13,278
69
7,688
40
8,237
43
8,510
45
8,543
45
42,965
224
N/A
N/A
8,612
45
19,866
104
58,773
306
55,912
291
68,077
354
L
W
6,848
6,618
6,644
6,602
5,093
4,848
4,914
4,957
16,604


4,964
6,926
20,387
27,360
33,648
L
E
1,522
1,505
1,538
1,550
0
351
394
418
266


410
7,272
7,091
1,617
3,144
U
120
165
163
142
62
78
83
84
57


87
111
62
311
673
N&S
62
64
64
64
0
0
0
0
0


0
210
170
0
0
TOT FLOW
TO DRAIN
(fTS/d)
(gpm)
8,552
45
8,353
44
8,409
44
8,358
44
5,155
27
5,277
28
5,391
28
5,459
29
16,927
88
N/A
N/A
5,461
29
14,519
76
27,710
144
29,188
152
37,465
195
L
W
6,796
6,556
6,585
6.543
5,044
4,805
4,864
4,906
16,541


4,922
6,862
20,300
27,026
33,311
L
E
1,519
1,503
1,535
1,547
0
349
394
417
265


408
7,267
7,089
1,508
3,133
U
124
170
161
140
62
78
83
84
57


67
111
62
309
671
N&S
62
64
64
64
0
0
0
0
0


0
209
170
0
0
TOTFLOW
TO DRAIN
(ft-3/d)
(gpm)
8,501
45
8,293
44
8.345
44
8,294
44
5,106
27
5,232
28
5,341
28
5,407
29
16,863
88
N/A
N/A
6,417
29
14,449
76
27,621
144
28.843
150
37,115
193
                LEGEND:

                LW = LATERAL FLOW THROUGH THE MT. LAUREL FROM WEST
                LE = LATERAL FLOW THROUGH THE MT. LAUREL FROM EAST
                U - UPWARD FLOW FROM THE MARSHALLTOWN
                N & S = INFLOW FROM NORTH AND SOUTH AT THE EASTERN END OF THE SLURRY WALL

-------
                             TABLE 4

                 GROUNDWATER LEVELS FOR CASE 11



            Top of                         Time (months)
          Slurry Wall
Row	(_ftj	1	2	,	3	4	5_

  7           25                  23.3   24.5   24.9   25.0   25.1

  8           25                  23.2   24.4   24.8   25.0   25.0

  9           25                  23.2   24.5   24.9   25.1   25.1

 10           25                  23.3   24.6   25.1   25.3   25.3

 11           25                  23.9   25.2   25.7   25.9   25.0

 12           25                  24.3   25.6   26.1   26.3   26.3

 13           29                  24.4   25.7   26.2   26.3   26.4

 14           29                  24.9   26.1   26.6   26.7   26.8
                               222

-------
                            TABLE 5

              SUMMARY OF 2-D MODEL ANALYSIS CASES
                                       Downgradient
                          Upgradient      Drain     Downgradient
                          Slurry Wall  Water Level   Slurry Wall
Case
I
2
3
4
5
6
7
8
9
10
11
12
2-D
Run Cross-Section
6VE1
6VE2
6VE3
6VE4
6VE5
6VE6
6VE7
6VE8
6VE9
6VE10
6VE11
6VE12
A
B
C
D
E
F
A
B
C
D
E
F
Key Depth
(ft)
5
5
5
5
5
5
5
5
5
5
5
5
Elevation
(ft)
10.1
10.2
10.5
11.1
13.1
13.8
20.0
20.0
20.0
20.0
20.0
20.0
Key Depth
(ft)
NONE
NONE
NONE
NONE
NONE
NONE
5
5
5
5
5
5
(1)  These levels varied with the level of Edwards Run for cases 1
    through 6.
                              223

-------
ro
ro
                                             TABLE 6
                 GROUNDWATER FLOW RATES TO LEACHATE COLLECTION DRAIN
RUN*
6VE1
6VE2
6VE3
6VE4
6VE5
6VE6
TOTAL
6VE7
6VE8
6VE9
6VE10
6VE11
6VE12
TOTAL
TIME = 11 DAYS TIME =1 YEAR TIME = 30 YEARS
L
W
510
365
1,525
4,343
4,604
2.267
13,614
436
286
1,277
3,493
3.974
2,022
11,488
L
E
145
151
666
1,677
2,072
525
5,236
12
10
55
199
188
92
556
U
13
13
45
132
100
40
343
6
5
21
68
60
27
187
TOT FLOW
TO DRAIN
(ft'3/d)
(gpm)
668
3.5
529
2.8
2,236
11.7
6,152
32.0
6,776
35.2
2,832
14.8
19,193
99.8
454
2.4
301
1.6
1,353
7.1
3,760
19.6
4,222
22.0
2.141
11.2
12,231
63.6
L
W
223
263
917
2,947
2,244
908
7,502
180
220
760
2,407
1,936
783
6,286
L
E
113
137
597
1,316
1,124
291
3.578
20
22
79
223
122
53
519
U
10
11
38
104
54
20
237
4
4
16
46
25
10
105
TOT FLOW
TO DRAIN
(ft-3/d)
(gpm)
346
1.8
411
2.2
1,552
8.1
4.367
22.7
3,422
17.8
1,219
6.4
11,317
58.8
204
1.1
246
1.3
855
4.5
2,676
13.9
2,083
10.9
846
4.4
6.910
35.9
L
W
222
262
916
2,947
2,235
893
7,474
179
219
762
2,401
1,917
767
6,245
L
E
113
137
597
1.316
1,121
290
3,574
20
22
79
223
122
52
518
U
10
11
38
104
54
19
236
4
4
16
46
25
10
105
TOT FLOW
TO DRAIN
(tt-3/d)
(gpm)
345
1.8
410
2.2
1,551
8.1
4,367
22.7
3,410
17.8
1,202
6.3
1 1 ,285
58.7
203
1.1
245
1.3
857
4.5
2,670
13.9
2,064
10.8
829
4.4
6,868
35.7
            LEGEND:

            LW - LATERAL FLOW THROUGH THE MT. LAUREL FROM WEST
            LE - LATERAL FLOW THROUGH THE MT. LAUREL FROM EAST
            U - UPWARD FLOW FROM THE MARSHALLTOWN

-------
                                                    TABLE 7

                                   FLOWS TO LEACHATE COLLECTION DRAIN
RUN*
CASE 6 CH6 4VE6
CASE 1 5 VE 1
CASE 2 5 VE 2
CASE 3 5 VE 3
TIME - 1 1 DAYS TIME - 1 YEAR TIME = 30 YEARS
L
W
7,751
7,745
7,741
7.735
L
E
330
329
329
328
U
156
156
156
156
TOT FLOW
TO DRAIN
(fr3/d)
(gpm)
8,237
43
8,230
43
8,226
43
8,219
43
L
W
4,848
4,827
4.691
4,535
L
E
351
348
343
334
U
78
78
77
75
TOT FLOW
TO DRAIN
(frs/d)
(gpm)
5,277
28
5,277
28
5,277
27
5,277
26
L
W
4.805
4,740
4,642
4,476
L
E
349
346
341
332
U
78
77
76
74
TOT FLOW
TO DRAIN
(ft'3/d)
(gpm)
5,232
28
5,163
27
5,059
27
4,882
26
ro
ro
01
     LEGEND:



     LW - LATERAL FLOW THROUGH THE MT. LAUREL FROM WEST

     LE - LATERAL FLOW THROUGH THE MT. LAUREL FROM EAST

     U - UPWARD FLOW FROM THE MARSHALLTOWN

-------
                             TABLE 8

        COMPARISON OF UPGRADIENT DRAIN CONSTRUCTION COSTS
               AND LEACHATE TREATMENT COST SAVINGS
                                               Cost
Elevation       Construction Costs         Savings (I)

                                     10% Discount   6% Discount

63 ft MSL           $6,025,310           $0            $0

53 ft MSL           $6,844,410           $63,000       $92,000

43 ft MSL           $8,482,610           $126,100      $184,200


(1)   Cost savings based on a 120-gpm pretreatment plant.
                             TABLE 9

            COLLECTION DRAIN FLOW RATES WITH CHANGING
               MARSHALLTOWN CONDUCTIVITY  (in gpm)
Time
11 days
1 yr
30 yrs
Case 1
43
28
28
Case 2
75
51
51
Case 3
29
17
15
Case 4
45
29
29
Case 5
79
54
54
Case
30
17
15
6



                               226

-------
                             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

-------
                                               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

-------
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

-------
FDiWi H
                   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

-------
FDiWi 1
                   SHOSHONE STREET
                              RELOCATION
                               TRAILER
                                        West
                                        Bldg.
     DRIVEWAY
                            ©©
                         ©©©©©©
                            ©©
                            ©©©©
           South
         Warehouse
     East  Bldg.
                             North
                              Bldg.
                 QUIVAS  STREET
Radiologic
                                               LU
                                               D
                                               Z
                                               UJ

                                               <
                                                    

-------
  FD(
                   SHOSHONE STREET
UJ
x
h-

-------
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

-------
                       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

-------
                                          San Juan County
I	
    Figure 1.  Monticello,  Utah,  Regional Location Map
                             239

-------
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

-------
ro
           MILLSITE BOUNDARY (78 ACRES)
             CITY
              OF
         MONTICELLO
              D
            VANADIUM
             TAILINGS^'
CARBONATE A AREA
                                       TAILINGS
                                         AREA
                                                                  EAST TAILINGS AREA
                                                      ACID
                                                    TAILINGS
                                                      AREA
                                                                                FEET
                                  Figure  2.  Monticello Millsite Plan

-------
An additional 100,000 cubic yards of contamination is estimated to exist on the Monticello Vicinity
Properties (Figure 3). This material consists of both air borne-tailings particulate matter and material
that was used as fill or construction material on the properties. The Monticello Vicinity Properties
Project was listed on the National Priorities List in 1986 and is being remediated pursuant to a Record
of Decision dated September 1989.

The tailings piles are located within the floodplain  of Montezuma Creek. They are also partially in
contact with a shallow alluvial aquifer underlying the site. This alluvial aquifer is not presently used
as a drinking-water source; however, it does have a potential for agricultural use. A deeper aquifer,
known as the Burro  Canyon aquifer,  is a  drinking-water  supply.   Analyses of  samples from
monitoring wells in the Burro Canyon aquifer show no evidence of contamination. Two aquitards,
the Mancos Shale and part of the Dakota Sandstone, separate the Burro Canyon aquifer from  the
overlying alluvial aquifer under most of the millsite.

Montezuma Creek, which flows  through  the  millsite, is a small  perennial stream.  Low-flow
conditions prevail in the late summer, fall, and winter months.  Within the project area, base flow in
Montezuma Creek is maintained year-round by ground-water discharge from the alluvial aquifer and
by releases from Monticello Reservoir, located approximately one-mile upstream from the millsite.

Protect Description

History —The Atomic Energy Commission bought the Monticello milling operation in 1948. Uranium
milling commenced in September 1949  and continued  until  1960, when the mill was permanently
closed. Part of the land was transferred to the Bureau of Land Management; the remaining parts of
the site have remained under the control of the Atomic Energy Commission and its successor agencies,
the U.S. Energy Research and Development Administration and the Department Energy.  The land
transferred to the Bureau of Land Management was recently returned to the Department of Energy.

In the summer of 1961, the Atomic Energy Commission began to regrade, stabilize, and vegetate  the
tailings piles. The plant was dismantled and excessed by the end of 1964.  Some of the plant was
buried on the millsite.  Photographs suggest that contaminated soil was used as  fill material to partially
bury the mill foundations.

The Department of Energy, under the  authority of the Atomic Energy Act, initiated the Surplus
Facility Management Program in 1978 to ensure safe caretaking and decommissioning of government
facilities.  In 1980, the millsite was accepted into the Surplus Facility Management Program and  the
Monticello Remedial  Action  Project was  established.   In  February  1989, the Federal Facility
Agreement established that the activities at the Monticello Mill Tailings Site must comply with  the
Comprehensive  Environmental Response, Compensation, and Liability Act of 1980, as amended by
the Superfund Amendments and Reauthorization Act of 1986.  In February 1990, the Department of
Energy completed the Remedial Investigation/Feasibility Study-Environmental Assessment for  the
millsite. The Monticello Mill Tailings Site Declaration for the Record of Decision was approved by
all parties  in September 1990,  establishing the selected remedy.

Selected Remedy — The remedial work at the site has been organized into three operable units (OUs)
to facilitate remedial design and remedial action. These are:

       o     Operable Unit  I:    Mill Tailings  and Millsite Property
       o     Operable Unit  II:   Peripheral  Properties
       o     Operable Unit  III:  Ground Water and Surface Water
                                         24?

-------
CO
                                                                                 AREA OF CONTAMINATION WITHIN
                                                                                 THE PERIPHERAL PROPERTIES
                           Figure 3.  Monticello  Vicinity  Properties and Area of
                                       Contamination Within Peripheral Properties

-------
A separate Record of Decision will be prepared for Operable Unit III because the remedy selected
for remediation of ground and surface water depends on the removal of contaminated material from
the millsite and from the peripheral properties. The Record of Decisioikwill be completed after the
collection of additional surface- and ground-water monitoring data following tailings removal from
the millsite and the peripheral properties.

The alternative selected for  Operable  Unit I involves excavation and removal of contaminated
materials  to an on-site repository located south of the existing millsite.  Removal will  be by
conventional earthmoving equipment and transport of tailings and other materials will be entirely on
site.  Dust-control measures  and access restrictions will be used to protect public health and the
environment during remedial action activities.  To control runoff, diversion structures will be built
and collected water will be treated as appropriate.  Tailings disposal will occur on and contiguous to
the existing millsite in a repository covered with a clay and multimedia cap.  Design of the repository
will comply with 40 CFR  192 performance standards.

The alternative selected for  Operable Unit II requires removal of tailings to meet the principal
relevant and appropriate standard, 40 CFR 192.  Contaminated  materials will be  transported to an
interim storage area and then relocated with the millsite  materials to the repository. Removal of
contaminated materials will be either by conventional construction techniques or by environmentally
sensitive removal techniques.  The environmentally sensitive techniques, such as hand excavation or
use of high-suction vacuum equipment could  be used in areas  with  mature  dense  vegetation that
would require decades to re-establish the native tree species.

The remedial designs prepared for the selected remedies for Operable Units I and II must demonstrate
compliance with applicable and relevant or appropriate requirements identified  in the Record of
Decision.

DISCUSSION

Approach Used to Develop Plan for Meeting Project Objectives

Development of a plan to meet project objectives was conceived  through a Value Engineering (VE)
Session. This  session  was designed to bring representatives from the involved agencies  and their
contractors together for a "team approach"  to project planning. This facilitated session started with
a "think tank"  approach  to identify the issues that needed  to be addressed to design and implement
the project.  This allowed each team member to put their concerns and concepts on the "on the table."
As a result of this effort, 48 key issues were  identified as important to the development of the project.
These  key issues  were then ranked  by  the team according to  how critical  they were to project
progress.  In addition to identifying critical issues, this phase of the session served  to bring the team
members up to a comparable level of understanding  of the scope of the project.

Once  the critical key  issues were identified, the  VE team worked to resolve the  issues.  Resolved
issues included the need to phase the design and remedial action to meet schedule constraints and the
use of "working-level discussion documents" as a mechanism for resolution of regulatory compliance
issues.  A commitment was made to prepare a Remedial Design Work  Plan incorporating the team's
concepts on project phasing and identifying the required  design documents and their contents. In
addition, the VE team  made commitments to prepare working-level discussion documents addressing
key regulatory issues.

Besides resolving the tangible issues, the VE Session provided the mechanism for building a team
approach  to project planning.  This team-building effort enhanced the  ability to communicate
between the involved team members, which included government agencies  and contractors.
                                          244

-------
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

-------
MONTICELLO REMEDIAL ACTION PROJECT
Mlllslte Site
Preparation
Pre-axcavatlon
Activities at
Mlllsite
Repository Site
Preparation
Repotltoru
Design
Reclamation and
Cloteout
9 )
1
1
1 1
90
FY 91
1 I I I I I I I I I I
90XV 6
FY 92
i i i i i i i i i i i
90X DConttructlo
FY 93
i i i i i i i 1 1 1 1
LJtert
•••• 1
apxU 0>3ox
90* W O90X
riConetructlof
FY 94
I I I I I I I I 1 I I
LJtart
i i
30X\
90X\7 O90X
l~l Construct lor
ittart
1 1
7 <^30X 91
XV 690X
rtConitructlor
FY 95
1 1 1 1 i i i i i i i
start
•• Complete FY 97

1 1 1 1 1 I 1 1 1 1 1
FY 91

1 1 1 I 1 1 1 1 1 1 1
FY 92

1 1 1 1 1 1 1 1 1 1 I
FY 93
30XV ^30X
90XU C-90X
I Complete FY 97

1 1 1 1 1 1 1 1 1 1 1
FY 94

I 1 I 1 1 1 1 1 1 1 1
FY 95
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

-------
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

-------
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

-------
                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.
                              249

-------
     It was observed that the soil cap, which had been shaped to
shed surface water, was settling  and  water  was  beginning  to
accumulate  in  the low spots.   This was considered undesirable
since there was the likelihood of surface water seeping  through
the  cap,  becoming  contaminated  from the nuclear deposits and
then percolating downward to the groundwater table.   As part of
the permanent closure  plan,  it  was  decided  to  densify  the
nuclear  waste  within the trenches to reduce future settlement.
Densification of the waste by dynamic compaction was  the  first
step before constructing a new impervious kaolin clay cap.

     The  closure  plan  required  a  cap  constructed  to  RCRA
regulation  standards.   To  meet  these  requirements,  it  was
decided  to  specify  a  locally available tertiary kaolin clay.
From   a   test   program  previously  conducted,  it  had  been
established that the kaolin clay, if properly placed, would have
an in-situ permeability of less than 1 x 10 -7 cm/sec.

Design Clay Cap Test Program

     Kaolin clay is mined commercially for use in the rubber and
paper industries as an  inert  filler.   The  majority  of  that
commercial  production  in the United States is from sedimentary
deposits lying along the  Georgia/South  Carolina  "Fall  Line."
The  "Fall  Line"  is  the  common  name  given  to the geologic
boundary between  the  Piedmont  and  Coastal  Plain  Provinces.
Kaolin clay beds of tertiary and cretaceous periods can be found
close to the surface in this region.

     In  the general area of the Savannah River Plant, there are
kaolin deposits having only a few feet of overburden.   However,
overburden stripping depths of 50 ft. are common at many of  the
operating  open  pit  mines.   Because  kaolin  is found in such
plentiful supply locally, it was identified as the  material  of
choice  for  this  project  after  examining the possible use of
natural on-site clays, importing alluvial clay  or  the  use  of
soil bentonite mixtures.

     The  design  test  program   examined   both   construction
techniques  and  resulting  cap  properties  for  Tertiary   and
Cretaceous  age  kaolin.   It  became  obvious  early  that  the
Cretaceous kaolin was  a  sandier  and  less  plastic  material.
Therefore,  only  two  test  panels  were  constructed  of   rthe
Cretaceous  clay-   These  panels  proved  that it would be very
difficult or impossible to achieve the required 1 x 10 -7 cm/sec
in-situ   permeability   with   the  Cretaceous  kaolin.     The
Cretaceous clay was, therefore,  eliminated from  consideration.
Tertiary  clay  from  three  (3)  different  active mines in the
Aiken, South Carolina area was used to construct seven (7)  test
panels.    From  each  source  a  panel  was  constructed at both
                             250

-------
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

-------
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

-------
      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

-------
   (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

-------
     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

-------
                          Table  1.  FIELD AND LABORATORY QUALITY CONTROL TESTING REQUIREMENTS FOR CLAY MATERIAL,  FROM APPENDIX V -  REV.  1,
                          CONTRACT SPECIFICATIONS, MIXED WASTE MANAGEMENT FACILITY, DOE, SAVANNAH RIVER P1.ANT
ro
01
LAB IDENTIFICATION TEST SERIES INCLUDING:
LOCATION
(1)
BORROW PIT
BEFORE
MINING
DURING
MINING
STOCKPILE
AREA
CONDITION-
ING AREA
PLACEMENT
AREA
WATER CONTENT
ASTH D2216-BO
(2)
ATTERBERG LIMITS
ASTH 04318-84
(3)
MINUS #200 SIEVE
ASTM Dl 140-54
(4)
ONE TEST SERIES FOR EACH MOISTURE-DENSITY RELATION
THREE TEST SERIES WHENEVER CHANGE IN MINING LOCATION
ONE TEST SERIES
FOR EACH MOISTURE-DENSITY RELATION

ONE TEST SERIES
FOR EACH MOISTURE DENSITY RELATION
FIELD QUALITY CONTROL TESTS
MOISTURE
DENSITY RELATION
ASTH D698-78
(5)
THREE FROM FACE
BEING MINED
THREE FROM INITIAL
500 TONS DELIVERED

ONE/ 5000 CU YD
ADJACENT TO IN-
PLACE SAND CORE
DENSITY
ONE POINT
DENSITY
(6)



ONE/ EACH
NUCLEAR
DENSITY
NUCLEAR DENSITY
ASTM 02922-81
(7)



ONE/500 CU YD;
AT LEAST 3 /DAY,
AT LEAST I/DAY
WATER CONTENT
ASTM D2216-BO
(8)

ONE /1 000 TONS
ONE/ 300 SQ YD

IN -PLACE
SAND CONE
DENSITY
(9)


ONE/5000 CU
YD ADJACENT
TO IN-PLACE
NUCLEAR
          NOTES:

          1.  In the conditioning area, microwave water contents on 100 gram ninin
              contents.
          2.  Perform tn-place density tests at the base of compactor footprints.
          3.  Test results shall be filed with owner's representative dally.
clay samples may be used in place of ASTM D2216-80 oven dried water

-------
the  panel  construction  area or at a stockpile location.   The
freshly mined clay material had many large chunks.

     If the clay was placed directly for cap construction, a CAT
D6 bulldozer was used to level the pile and smooth the  material
into the specified six (6) inch lift.   Major size reduction was
accomplished during this leveling, as chunks were broken down by
the  weight  and  motion  of the dozer.   The dozer tracks would
bridge across low spots and place all contact  pressure  on  the
largest  chunks;  these  were  the  high  points   causing   the
bridging.   This would crush the largest chunks.  After leveling
by  the  dozer, the material could be classified as six (6) inch
minus; therefore, further size reduction was still necessary.  A
Howard rotavator accomplished the final  size  reduction  during
the  early  clay cap construction.   A rotavator is nothing more
than an oversized garden tiller. It has thirteen rows  of  three
tines  per row for a total of 39 tines.    The ones used on this
project were eight (8) feet in width,  pulled  by  140  HP  farm
tractors, and powered by the tractor's PTO.   The tractors could
pull  through  natural water content clay for pulverization work
at a speed of 175 ft/min.   Clod reduction was  accomplished  by
mechanical pulverization.

     A  Gleason  Shredder  was  used  for  a limited time on the
project.   This same type machine  had  been  tried  during  the
design  test  program.   The  shredder is a revolving blade with
teeth; it cuts the clay into the desired size in the same manner
as a meat grinder.   It did a  very  good  job  of  producing  a
material  within  the  desired  size  range.   The  drawback and
primary reason it was not  used  for  mass  production  was  the
shredder's pass through tonnage limitation.   With the blade set
to  operate  at  the  project's required 1-1/2 inch maximum size
limit, pass through production was only 140 tons per hour.

     The shredder added extra material  handling  steps  to  the
production  process.   For a short duration, the clay was loaded
directly into the shredder  during  excavation.    The  shredded
clay  fell onto a fast revolving belt which would sling the clay
chips into a stockpile.    A wheel loader was then used to  load
the  trucks  for the haul to the jobsite.   The other option was
not to change the mining and hauling operation of the raw  clay,
but  to build a stockpile at the burial ground, and use a loader
to feed the shredder from that stockpile.   The  shredder  would
then  create  a  second  stockpile  of sized material from which
self-loading scrapers would haul to the panels.   This method of
operation was tried for about one month.

     The final method examined and the one used throughout  most
of  the  clay cap construction was mechanical pulverization by a
CAT  SS-250  soil  stabilizer.   As  with  the  rotavators,  the
pulverization  was  accomplished  after  the  raw  clay had been
                             257

-------
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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
                                              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

-------
FIG. 1.   Moisture-Density Data  from Nuclear Density Test during
October 1989,  Kaolin Clay Cap, Mixed Waste Management  Facility,
DOE, Savannah  River Plant
                             266

-------
                        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

-------
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

-------
            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

-------
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.
                               275

-------
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

-------
                     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.
                                            277

-------
               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

-------
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
                                            279

-------
HELEN KRAMER SUPERFUND SITE
                                     FIGURE 1

-------
Action Master Plan for the site, and in 1983 conducted additional air monitoring, which confirmed
the presence of organic vapors higher than background levels.

It is estimated that, of 2 million cubic yards of waste at this landfill, approximately 500,000 gallons
was industrial liquid waste, several hundred cubic yards sludge, and over 3,000 cubic yards inorganic
wastes (such as heavy metals, salts, catalysts, and the like). An estimated 183,000 gpd of leachate and
contaminated groundwater was entering Edwards Run, threatening the quality of its water. [Edwards
Run has potential as a recreational or  irrigational resource.]  Laboratory testing had indicated the
potential for adverse effects upon biotic resources in Edwards Run. The shallow Mt. Laurel/Wenonah
aquifer in the vicinity of the site and of Edwards Run was contaminated.  Constantly generated
landfill gas posed a danger of further fires as well as the possibility of further release of hazardous
chemicals  into the  air. Although no potable water supplies had shown evidence of contamination
attributable to the landfill, the potential for such contamination did exist due to their proximity to
the site. Potential  for present and long-term risk  to human health and the environment provided
justification for this site's being listed among the highest-priority sites on USEPA's National Priorities
List.

The Remedial Investigations (RI) and Feasibility Study were conducted by NUS Corporation under
USEPA Contract No. 68-01-6699, USEPA Work Assignment No. 29-2L30. Actual field work was
conducted by NUS's subcontractor, R.E. Wright Associates, Inc., of Middletown, Pennsylvania, from
August 1984 through September 1986.

Design Process

Phase I - Work Plan Development

USAGE had  developed a detailed Scope  of Work  for the project that was based upon  RI/FS
documents and that was consistent with the Record of Decision. Using this Scope, a fixed-price
contract was awarded to URS Consultants, Inc. During the negotiations, a predetermined scope of
subsurface investigations and completion schedule was agreed upon.

As  part of Phase I, URS collected and  reviewed the available technical information and developed
a Work Plan document which, among other things, attempted to fill data gaps. During the review of
these documents, however, technical experts on the joint (USACE/USEPA/NJDEP/URS) project
team concluded that the planned investigations were not adequate and that a much more extensive
investigation  program was necessary in order to prepare bid documents for competitive bidding.
Since monies for these investigations had not been included in the original contract amount, this issue
required further discussion and contract modification. This delayed the initiation of Phase II by more
than two months.

Phase II -  Predesign Investigation  (35% Design)

This phase required  an $800,000  level of effort within a period of  75 calendar days,  including
collection, synthesis, and interpretation of data and preparation of a report, along with 35% design.
The job was  challenging, considering  the  potential for mishaps when drilling in an uncontrolled
landfill. A great deal of credit was due to the joint project team and to URS's  subcontractors for
completion of the work by the newly approved completion date.

Interval Between Phase II and Phase III

One of the requirements of  Phase II was to  present to USAGE  a recommendation for Value
Engineering Studies.  The following five items were identified for Value Engineering:
                                            281

-------
       •      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

-------
developed using existing information, extrapolating to the areas where investigations could not be
conducted. This would become an important issue during the construction phase of the project.

Another factor entering the picture was the pretreatment criteria (for leachate/groundwater) set by
the Publicly Owned Treatment Works (POTW), which in this case was the Gloucester County Utilities
Authority (GCUA).  GCUA and USEPA negotiators ultimately agreed to a batch-discharge  to
GCUA's  system.  This of course meant that no  discharge to GCUA sewers would  be permitted
without prior testing/approval.  This decision required adding a minimum of three pretreated
wastewater discharge/holding tanks to the project, each with a capacity of 350,000 gallons. After
receiving verbal approvals from the GCUA board, a draft Service Agreement developed by USEPA
was sent to GCUA for review and comment.

Phase III - 65% Design

With all previously identified elements included  in the project scope, this phase was targeted for
completion within 60 calendar days. This phase proceeded smoothly.

Phase IV - 95% Design

This phase was carried out without serious difficulty and on schedule.  However, it is worthy of
mention here that in spite of the design being almost ready for bid invitation, little progress had been
made on two important issues.  These issues included, on the one hand, real  estate access and
easements for construction, and, on the other, an agreement with the POTW to accept pretreated
leachate.  These issues had not yet been settled.  Both issues were vital if any remedial construction
were to begin.

During this phase two major engineering issues had to be overcome:  completion of the landfill cap
in such a  way  that remedial action would not encroach upon the floodway of Edwards Run; and
construction of a slurry wall across the steep banks on the northeast and southeast ends of the landfill.
After several alternatives had been studied, Roller-Compacted Concrete (RCC) was incorporated into
the design. This feature promised not only to provide support to the  cap, but also made it possible
to construct the slurry wall by creating somewhat milder slopes.

Phase V - 100% Design

Following review of the Phase IV submittal, specifications and drawings were finalized and submitted
to USAGE on September 16, 1988, in anticipation of bid invitation to follow shortly.

Invitation to Bid

The formal invitation to bid was not advertised until May 22, 1989, with bid opening on September
19, 1989, one year following completion of the design.  As stated earlier, real estate adjoining the
landfill site, acquisition of which was required for construction of the remedial action, had not yet
been acquired.  USAGE was of the opinion  that  until all the real estate issues were  resolved, the
United States Government could not enter into a legal contract for construction.

Although more than 200 bid packages had been sold by USAGE--the  cost of bid packages being set
low ($10.00) to encourage more  bids—only  three responsive bids were received.  All bids were
substantially higher than the original Government estimate. A large number of potential bidders were
unable to secure bonds in the amount necessary to undertake the project. They claimed that even
though their firms were technically and financially qualified to complete the work, the bonding
                                           283

-------
requirements denied them the opportunity to submit a bid that, as they maintained, would have been
advantageous to the Government.

Real Estate and Site Access

Access was needed to adjacent properties owned by parties other than the landfill owner. Two of the
three property owners in question owned land uncontaminated by the landfill.  Six different access
procedures were  used  to  acquire this land.   These included  purchase,  leasing, relocation,
condemnation, access agreement, and an administrative order.  Extensive negotiations were required,
making the process last an unexpectedly long time.  The benefits of expediting the development of
the bid documents were essentially lost, and it resulted that real-estate issues had the greatest impact
on the remediation schedule.

This was one of the first acquisitions of property for the purposes of conducting a remedial action
that had been made through the Superfund program.

Remedial  Action Construction

The Contractor began site work on February 20, 1990, and to date has completed 50 percent of the
remedial construction. From an engineering design point of view, two construction issues are worthy
of consideration:   pretreatment plant design modifications, and construction of the RCC  and the
slurry wall along Edwards Run.

Pretreatment Plant Design Modifications

This component of the remedial action, which  is on a  critical path, was originally scheduled for
completion for November 3,  1990.  The facility would  have  then been available for treatment of
leachate and any contaminated groundwater from construction activities.  In April 1990, however,
the project team was informed that GCUA pretreatment requirements (discharge criteria) had been
changed from those used in the plant design, and  made more stringent.   In order to meet these
requirements, a new engineering study had to be completed, and design modifications made. The two
key elements of the required process enhancements (water-phase activated  carbon adsorbers and a
high-efficiency air stripper) were long-lead items.  This fact, along with the necessary supporting
design drawing modifications and the contract modification process,  caused the target date for
pretreatment  plant completion to be pushed back to August 1991. This has had an impact  on both
the cost and the overall project completion date.

Construction  of RCC and Slurry Wall Along Edwards Run

The contract documents required the Contractor to drill a certain number of soil borings to define the
depth to the geological formation (Marshalltown) into which the slurry wall was to be keyed.  Based
upon these investigations, the Contractor claimed that the ground was softer  than he had anticipated
and further stated his opinion that the ground was possibly even unsuitable for support of the RCC.
This portion of the site had been the least explored.  The meandering of the stream (Edwards Run)
had extensively reworked the soils.  Additionally, sand and gravel mining,  followed by landfilling
activities had further complicated the situation.  To obtain more accurate data, the Contractor was
directed to undertake a detailed investigation of this area under USAGE direction.  The results of this
investigation revealed that the geologic soil formation expected over most of this portion of the site
had been removed by stream erosion processes and had been replaced by a heterogeneous matrix of
floodplain alluvium of inconsistent texture and density.  The  depth to firm  ground was variable at
best, and deeper than expected. Increased excavation depths also brought into focus potentially larger
volumes of contaminated groundwater.  The stability of the excavation for  the foundation became
                                            28/1

-------
 important, requirihg greater care in planning and execution. The net result again was an increase in
 cost and an impact on schedule. As of this writing, it is still a matter of study whether conventional
 construction methods or in-situ ground stabilization would be more suitable.

 CONCLUSIONS

 What may be deduced from this experience, for application on Superfund remedial projects of similar
 scope, nature, and complexity?  The most important lessons are the following:

        1.     The scope and costs  of predesign investigations can  be substantial, and  greatly
              variable, depending upon the degree of detail to which the investigations were carried
              during the RI/FS process. It is prudent to define a scope acceptable to all parties
              before negotiating a fixed-price design contract We have already seen  this change
              take place on design contracts being negotiated in the recent past.

        2.     Field investigations must be completed during the design process. Such investigations,
              when left to the construction phase, can have a major impact on construction cost and
              schedule. This point cannot be overstressed.

        3.     Real estate issues must be defined early in the design and should be given the same
              priority as other elements of the project, if not a higher priority. Many times these
              issues involve high-priced real estate, farmland, or property with sentimental value
              for its owners. Property acquisition should be complete, or nearly so,  prior to 100%
              design.

        4.     When interagency agreements are involved, these agreements must be executed prior
              to completion of bid  documents.  Incorporation of new  technical or  contractual
              requirements during construction is costly and delays construction.

        5.     Agency review has an important impact on project team continuity and cost.

        6.     The  importance of early and  continuing attention to  POTW issues  cannot be
              overstated.

 The Helen Kramer Landfill Superfund site remedial design has, at many levels, been instructive. In
 spite of the difficulties encountered, however, this  remedial design is considered to have  been a
 success that has set precedents in many areas.

 DISCLAIMER

 This paper has undergone a relatively broad initial, but not formal, peer review. Therefore it does
 not necessarily reflect the views or policies of URS, USEPA, or USAGE.  It does not constitute any
 rulemaking, policy, or guidance by USEPA or USAGE, and cannot  be relied upon to create a
 substantive or procedural right enforceable by any party.  Neither URS nor the United States
 Government nor any of its employees, contractors, subcontractors, or  their  employees  makes any
 warranty, expressed or implied,  or assumes any legal liability or responsibility for any third party's
 use or the results of such use of any information or procedure disclosed in this report, or represents
 that its use by such third party would not infringe on privately owned rights.

We encourage your comments on the  utility of this paper and  how it might be  improved to better
serve the Superfund program's needs. Comments may be forwarded to  the attention of:

      Vern Singh, P.E.
      URS Consultants, Inc.
      282 Delaware Avenue
      Buffalo, New York 14202
                                              285

-------
           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.
                                            286

-------
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;
                                              287

-------
       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
                                             288

-------
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;
                                            289

-------
       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.
                                            290

-------
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.
                                           291

-------
                   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.
                                             292

-------
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.
                                              293

-------
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
                                             294

-------
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
                                              295

-------
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
                                                296

-------
EPA's Contract Lab Program target compound list, appears to be the most prevalent and most highly
concentrated VOC at the site, reported at a maximum of 11  mg/L (this compound was analytically
identified by EPA's National Enforcement Investigations Center  in Denver, CO).  Hypotheses for
these increased contaminant loadings include a) barrel deterioration and thus new sources within the
fill, b) reduced dilution as a result of capping, c) increased loadings as a function of construction
activities (e.g., clearing, increased compaction) or d) increased loadings from uncollected leachate
during cap construction. The latter argument seems less likely since leachate had been uncontrolled
for years prior to capping, and since recently reported contaminant concentrations in leachate (Table
2) (Reference  13) are less than those reported for eastern groundwater. See References 1, 12 and 13
for a more complete groundwater and leachate chemical database, including semi-volatile organics,
inorganics and conventional parameters.

The water table monitoring of this study confirmed the presence of approximately  10 ft of saturated
refuse  under the early  spring water table in  the western area of the fill (landfill well JLF-1).
Additional mounding  analysis  performed by EPA in February  and March 1991 indicates  a
continuation of this problem.  Upward  vertical gradients  in this area suggest that post-closure
mounding may continue to be a chronic source of groundwater contamination.

E.     Phase  Three Remedial Activities

(1)    Groundwater and Leachate Treatment

       ROD III calls for extraction of southwestern overburden and eastern overburden and shallow
       bedrock groundwater for combined biological-based treatment with leachate on site.  The
       southwestern extraction trench design, developed by LAW Environmental, Inc. under contract
       to the Corps, is currently at the 90-95  % completion  stage,  and should  be  ready for
       advertizing in summer 1991. The cap's southwestern sedimentation basin was relocated (i.e.,
       a  change  order  was  implemented) to allow for improved trench access and function as
       compared to the conceptual  location  presented in the 1988 phase three  feasibility study
       (Reference 1). The design of the eastern extraction system, on the other hand, was postponed
       pending the results of the 12  month groundwater monitoring study discussed above, and is
       just now getting underway. Once designed, however, an additional advantage to the change
       from leachate USTs  to  pump stations discussed above is that eastern extraction  system
       construction costs and schedule should be reduced since primary voltage power will now be
       readily available in this remote area.

       Certain PRPs are also performing on-site treatability studies as part of the AOC. While as yet
       incomplete, the goal of these studies is to develop an optimized, pilot study-based conceptual
       design  for  the  groundwater and leachate treatment plant.  The detailed  plans and
       specifications for the  plant will then be developed through the Corps.

       ROD III also includes  provisions for an upgradient diversion trench in the northwestern area
       of the  site as an attempt to lower the water table within  the landfill, although it cautions
       against the consequent potential for gradient reversal.  The groundwater monitoring study
       discussed above (Reference 12) concludes that the trench may be ineffective at reducing the
       amount of saturated refuse, due to the flat gradients in the  western area and the potential for
       inflow from rising shallow bedrock groundwater.

(2)    Landfill Gas Treatment

       ROD III also calls  for incineration of landfill vent gas.  The design approach has been to
       pursue gas vent manifolding (above the cap) and flaring as an initial step to allow for updated
                                                297

-------
       (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

-------
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

-------
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

-------
00
o
            CCAU
            ru—i
            0    ZOO   400 FEET
BASE PLAN TAKEN FROM PLAN PREPARED BY
LAflSEN ENGINEERS ARCHITECTS. ROCHESTER
N Y . 6/26/87
                                          NOTE:   this  figure  adapted  from  Reference  12, Figure 2.

-------
                       6' SELECT  COMMON
                       FILL (WIN.)
                       6' WIN. COMMON
                       FILL AS  REQUIRED.
                       LANDFILL SURFACE AFTER
                       PRELIMINARY GRADING
                                                                                       FILTER FABRIC (WOVEN).

                                                                                       DRAINAGE NET

                                                                                       60 MIL MOPE MEMBRANE
       •DRAINAGE NET

       FILTER FABRIC  (NON-WOVEN)
                                                        SLOPES 4il  AND LESS
                                                                                NOTE
UPPER LWER OF
NiT  SHALL EXTEND 6. MINIMUM
OF 5' UHDEB  CRUSHED  STONE
COVER AT INTERFACE Of CRUSHED
STONE AND  SOIL COVER MATERIALS.
                                                                                                                 SLOPES STEEPER  THAN 4: I
                                                                                                                                                         - 12' CRUSHED STONE
                                                                                                                                                           6'SELECT COMMON
                                                                                                                                                           FILL (MIN.)
                                                                                                                                                           6' MIN. COMMON
                                                                                                                                                           FILL AS REQUIRED.
                                                                                                                                                           LANDFILL SURFlCE Af
                                                                                                                                                           PRELIMINARY  GRADING
                                                          Figure 2   -TYPICAL  LANDFILL  CAP  CROSS-SECTION  DETAIL
                                                                                                 NTS
00
o
FG
                                                                                                                                              61 MIN. SELECT  COMMON FILL ON  '
                                                                                                                                              OF COMMON FILL  AS REQUIRED TO
                                                                                                                                              GRADE SIDESLOPE TO  3il (MAXIMUM'
                                                                        3 MAX.
                     PERIMETER SURFACE WATER
                     DRAINAGE DITCH
                      KEY IN LINER SYSTEM AT
                      LANDFILL PERIMETER
                                                                               ,-LEACHATE TOE DRAIN
                                                                    Figure  3 - TYPICAL  CROSS  SECTION

-------
CO
o
CO
                                                                                                                      / EAST DETENTION
                                                                                                                      J^ BASIN
                                                                                                          LEACHATE  PUMP STATION
                                                                                             CHARLES GEORGE LANDFILL
                                                                                           TYNGSBOROUGH, MASSACHUSETTS
                                                                                             SUPERFUND SITE CLEAN UP


                                                                                  FIGURE 4 - AS-BUILT DRAWING

-------
                                                       TABLE  1 •  ANALYTICAL RESULTS MONITORING WELL ElE FIT2
                                                                  Charles George Land Reel Mutton Trust Landfill
                                                                  Tyngsboro, Massachusetts
fseple Location    EM Nt2             Eastern Shallow Overburden
Screened Interval 21.0 to 45.0
Date Saapled               Jul-84 Oct-M Jan-85  Feb-87 Mar-89 Nov-89 Dec-89 Jan-90  Jan-90 feb-90 Har-90 Apr-90 Hay-90  Nay-90 Jun-90 Jul-90 Aug-90 Sep-90  Sep-90 Oet-90
Stapled by                   NUS    NUS    HUI  ECJordan NE1C    CEI    GEI    GEI    CEI     CEI    GEI    GEI     6EI    GEI     GE|     CEI    GEI    CCI    6EI     CEI
                                                                             CLP   Duplicate                    CLP   Duplicate                     CLP  Duplicate

VOLATILE ORGANIC! (ug/L)                                                                                        *      *              *
Acetone                          J74000  R3700           U    2700          J1300  500     280    74     190   J580                                               660
2-lutenone                               J7400   440     12    4400   4300   J1300  1100    450    93     200   J490
2-Hejianone                   500                                                                                 UJ                                         10
4-Nethy-2-pmtanone               R4600                        710          J140    110     56     11          J150                               J140    170
Benzene                      560   R2400                  73     670    MM    500    550     500    630   1200   J1200   1900   5200   1200    1200   1400    1700   1400
Toluene                      930          4550            36     820    TOO   J240    220     160    39     130   J120     51                        4110     78
Ethylbenzene                 61    J440                   71     510    530    340    420     480    630   1200   J930    1500   5900   1200    1100   1400    1700   1500
Chlorobentene                                                                                                   UJ                                         11
Xylenes (total)              130                   «      48     290          J220    2410     310    370    700   JS60    870    3100   1100    670    940    1100   1100
Oiloroethane                                                                               53     61     110     UJ                                 UJ     160
Tatrahydrofuran              NT     NT     NT      NT          3200          1500    1300   1108    810   1600   J2600   3000   11000  2000    MOO   J3000          2700
1.1-Dlchloroethane           84                            2                                                      UJ
Trans-1.1-dlcloroethane      75    J960                                                                          UJ
1.1.1-THchloroethane                                                       IJ170                               UJ
Carbon Tetrachlorlda         50                                                                                  UJ
Chlorofora                   50                                                                                  UJ
Nethylene Chloride         4350   10000  111300                              J1100                             04130   854            880            U
1.4-Dloxane                  NT     NT     NT      NT                                              490           R                                  R
Ethyl Ether                                                                                                   4170
•  Volatile* Analyzed Outside Holding Tie*


         NOTE:   this  table  adapted  from  Reference  11,  Table C-9.

-------
                                                                             TABLE  2
                                                               CHEMICAL CONCENTRATIONS IN LEACHATE   (ug/L)
                                                                   CHARLES GEORGE LANDFILL - 1989
                                                                            TYNGSBORO,  HA
Chemical
Volatile Organic
Compounds:
Ethyl Ether
Hethylene Chloride
Acetone
1,1-Oichloroethane
2-Methyl-2-propanol
Tetrahydrofuran
1 , 2-0 i ch I oroethane
2-Hethyl-2-butanol
cis-1,2-dichloroe thane
2-Butanone
2-Butanol
1,2-Dlchloropropane
Trichloroethene
1,4-Dioxane
4-Methyl-2-pentanot
Benzene
A-Methyl-2-pentanone
2-Hexanone
n-Propylbenzene
1 ,3,5-Trimethylbenzene
1,2A4-Trimethylbenzene
Toluene
Chlorobenzene
Ethyl benzene
1 .4-Dichlorobenzene
1 , 2-0 Ich 1 orobenzene
m- and/or p-xylene
o-Xylene
Total Xylenes
Carbon disulfide
East Leachate
Lagoon
March. 1989
15
ND
59
3
ND
1200
ND
ND
4
ND
ND
ND
ND
1200
ND
1
ND
ND
ND
ND
0.87
6
ND
2
ND
0.55
6
2
NA
NA
West Leachate
Lagoon
March, 1989
10
ND
500
ND
ND
160
ND
9
2
530
ND
ND
0.54
ND
72
1
110
23
ND
ND
1
26
ND
3
1
ND
7
3
NA
NA
Eastern Leachate
Collection Manhole
August 3, 1989
LS-101
NA
ND
ND
ND
NA
550
NO
NA
NA
ND
NA
NO
ND
ND
NA
87
ND
ND
NA
NA
NA
260
33
310
ND
ND
NA
NA
470
68 *
(Duplicate)
LS-104
NA
ND
ND
ND
NA
620
ND
NA
NA
58
NA
ND
NU
ND
NA
85
ND
ND
NA
NA
NA
240
32
260
ND
ND
NA
NA
450
67 *
Seeps at Western
Toe of Landfill
August 3,1989
LS-102
NA
ND
ND
ND
NA
16
ND
NA
NA
NO
NA
ND
ND
ND
NA
6.1
ND
ND
NA
HA
NA
ND
ND
10
ND
ND
NA
NA
57
ND *
Southwest Swale
Area
August 3,1989
LS-103
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
East Seep
December, 1989
NA
NA
NA
NA
NA
2.100
NA
NA
NA
ND
NA
NA
NA
NA
NA
ND
NA
NA
NA
NA
NA
ND
ND
93
NA
NA
NA
NA
190
ND
CO
o
           ND - Less than Limit of Detection
           NA - Not Available
           * - Trip Blank Resulted in  12 ug/l
                      NOTE:   this table  adapted  from  Reference  12,  table A-l.

-------
                                                             Table 3

                                       Charles George Landfill  Worst-Case Vent  Gas Data (mg/m3)
                           ECJ 1987 (a)             NUS 1986 (b)            NUS  1984-85 (b)         CARB Study (c)
Chemical                                     Vent 5   Vent 7  Vent  12      Vent 5  Vent 12    95th Percent!le  Maximum
*********
5.4

4.4
0.7
7.0

15.2

26.4
94.1
186.7

12.0



4.7


***********
0.4
0.1
0.3
0.1
0.1
3.0



2.0
3.6
17.2
0.8
1.4


3.4
0.1
0.1
r**********«******»*
28.0
60.0
0.7 220.0
4.2
9.4
0.2 102.0
2.8


2.8 128.0
1.5 38.0
10.6 82.0
0.4 4.2
0.5 16.0
64.0
30.0
0.7 30.0
60.0
164.0
i**********i
4.1
0.8
0.2
0.1
2.9
1.8

2.0

280.0
677.7
177.8
5.0
16.0
0.6
0.6
0.4
0.5
1.2
37.8
77.8
94.4
6.7
17.8
13.3
1.0


222.0
70.0
170.0
3.8
0.4
3.2
2.6
1.8
133.3
288.9
40.1 306.0
14.0 59.4
84.0 560.0
12.4 518.4
11.2 1,536.0
25.5 187.2
2.8 392.0
1.0 53.9
3.2 13.2










tetrachloroethene
trichloroethene
methylene chloride

1,1,1-trichloroethane
benzene
vinyl chloride

1,2-dichloroethane
chloroform
carbon tetrachloride

toluene
ethylbenzene
total xylenes

chlorobenzene
4-methyl-2-pentanone
2-butanone
acetone

chloroethane
1,1-dichloroethane
trans-1,2-dichloroethene

a)  E.C.Jordan Co./Ebasco Services Inc (see Reference 13 (RI),  Tables 10-24 or 12-23).
b)  NUS Corporation  - all values are approximate (see Reference 13 (FS), Table F-2).
c)  Converted from pom as listed in Reference 14, Table 1.

-------
H. COMMUNITY RELATIONS
        307

-------
                    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
                                    311

-------
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.
                                     312

-------
            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
                                    313

-------
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.



                                    314

-------
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
                                   315

-------
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



                                   316

-------
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.



                                      317

-------
            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.
                                     318

-------
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.
                                    319

-------
            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


                                  320

-------
                  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);



                                     321

-------
      * 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	"
                                      322

-------
            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.
                                 323

-------
            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.
                                  324

-------
            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.
                                   325

-------
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


                                    326

-------
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
                                     327

-------
                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
                                             328

-------
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.
                                              329

-------
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
                                             330

-------
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.
                                        331

-------
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.
                                        332

-------
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
                              333

-------
III. CONSTRUCTION MANAGEMENT ISSUES
                  334

-------
            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

-------
                       oj.SU.
                                       IECEM)
                                         ^» OUfTTMB


                                        
-------
CO
CO
-si
                                                                         rrr/r
                                         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

-------
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
/™
WORK / MONTH
ACTIVITY /WK. ENDING
PRC-OEStCN ACTIVITIES
•WORK PLAN* MCLUDES A
WORKER HEALTH AND SAFETY
PLAN. SPU CONTNGENCY PLAN 1
SCHEDULE
SITE OPERATION 4 MANTENANCE
PLAN AND CONTRACTOR QUALITY
ASSURANCE/OUA1JTY CONTROL
PLAN
EP/VRIDEM
FMAL APPROVAL
DESIGN ACTIVITIES
SURVEY SERVICES' WORK SCOPE.
TECHNICAL SPECIFCATON AND
DESIGN DRAWNQ
CONSTRUCTION TRANSPORTATION
AND DISPOSAL SERVICES' WORK
SCOPE -TECHNICAL
SPECIFICATIONS AND DESIGN
DRAWMGS
EPA/ROEM FMAL APPROVAL
CONSTRUCTION ACTIVITIES
CONSTRUCTDN AND FMAL
TOPOGRAPHIC SURVEYS
MOW. EATON AND SITE
PREPARATION
EXCAVATCN. TRANSPORTATION
AND DISPOSAL OF CONTAMMATED
SOL
TRANSPORTATION AND DISPOSAL
Of LIQUID SAMPLES
REQUIRED COMPLETION OF
DISPOSAL ACTTVTTeS
B ACKFUMQ. REGRADNQ.
FENCING. AND SEEDMG
DEMOBILIZATION
REQUIRED COMPLETION OF BACK-
FILLING, REGRADNQ AND FENCMG
ACTIVITIES
FMAL EPAfRIDEM MSPECT1ON

1M7
DEC
4

t
T

4
11

%
7

It
11

»
\

16
25

»
J

25
DEC
1987
1M8
JAN
1



1
1

1
1

6
15

1
i

IS
22



22
29



29
JAN
FEB | MAR
5



5
12



12
19
T
1
i
1
t
1
^
1

19
Jt
t
i
r
i
X
%
7
1

26
4



4
11

ft
ft
V

11
11

AL
7
AL
;

16
75
4
1


25
1
*
1


1
APR
1



6
15



15
2?


/
22
n


^m
\
L

29
FEB | MAR | APR
MAY | JUN
5

1
••


6
1.1

1
"



13
20


• •1



20
77

<
<
(

'.
27
3

1
t
'I
>-

3
10


J"
— 1
(3
o
10
17



»
H

17
24




-k

24
1





0-
o
1
MAY | JUN
JUL
II


••[


-4
— I
6
15


1"


1
1
15
22


••i



22
29


••
1
t
29
AUG
5



k
k
5
12



4
12
19



>
19
26




26
2




2
SEP
9



O
9
16




16
23




23
30




30
JUL | AUQ SEP
OCT
7



4
7
14



>
14
21


1
21
2S



2$
NOV | DEC
4



4
11


<
11
11


1
11
25


1
25
2


»
2
9



9
16



16
23



23
30



NOTES
I PER THE
SHOULD
WEEKENI
DEADLIN
CONSTR
THE NEXT
2. PER PAR
CONSEW
DATEwA.
PLANNEC
FORCC*
AND DSP
ACTUAL
DETERM
RIDEM Al
PLAN ON
3. PER PAR
CONSEW
DATE (PF
COMPLE-
ACTIVrTII
THEPLAI
FORCC*
THAN HA
REMOVA
CONSENT DECREE.
A DEADLWE FALL ON A
0 OR HOLIDAY. THE
E HAS BEEN
JED TO CONTINUE TO
T BUSMESS DAY.
AGRAPHIOdOFTHE
T DECREE. THE 'flVH
S USED TO BEGN THE
1 120 DAY SCHEDULE
PLETNO EXCAVATION
O5ALWORK. THE
DEADLME Of V30S WAS
NED BY FMAL EPA t
•PROVAL OF THE WORK
MM.
AGRAPHtO.dOFTHE
r DECREE. THE 7/11/W
IOPOSED DATE FOR
riON OF DISPOSAL
IS) WAS USED TO BEGIN
JNEDW DAY SCHEDULE
PLETINa WORK OTHER
ZARDOUS WASTE
L
LEGEND/PLANNED
• DATE DUE
y ISSUED TO EPAWOEM
A START CONSTRUCTION
A COMPLETT- CONSTXUCTON
•»•• REPRESENTS INTERMrTTEHT
ACTIVfnES
LEGeNO/ACTUAL
O START
• COMPLETE
O REVISED DUE DATt
	
:1M!iH
V4?l'li!{*lMI
,'lf:HI,'l«J
DAK BIOGE. IENNESSEE I



30
OCT NOV | DEC
1988
P1C1LO FARM SITE
KENT COUNTY. RHODE ISLAND
DFIAFT SCHEDLILE
pn>)Kt Compl.bon Sdwlul*)

REV.
JOB HO.
19161-100
FIOURENO
9-1
1 - DECEMBER lim
                                                          Figure 3

-------
     • Remedial Action
       - Site Preparation
       - Land Surveying
       - Disposal of Contaminated Materials
       - Site Closure
       - Construction Monitoring and Inspection
       - Disposal Facilities
       - Post Closure Plan
       - Health and Safety Plan
       - Contingency Plan
       - Schedule
       - Work Not Included
       - References
       - Design Drawings (preliminary)

The work plan formed the basis  for the remaining activities at the
site and received final approval (with comments)  in March 1988.

Remedial Design

To expedite the schedule and allow remedial action to be conducted
during  the 1988  construction  season,  design  work proceeded  in
parallel with work plan preparation.  The design was submitted to
EPA and RIDEM for review and comment at the 30% and 95% stages and
for final  approval  at the  100%  stage.   EPA, RIDEM,  and Bechtel
agreed that a review at the 60% stage would not be necessary, and
this milestone was eliminated from the schedule.   Concurrent with
the remedial design,  solicitation packages for the remedial action
were prepared.  These documents were issued to prospective bidders
when the design was undergoing EPA/RIDEM review at the 95% stage.
Once final agency approval  was  obtained, contractors were selected
and contracts  finalized.   Contractors mobilized onsite  the week
following design approval,

Of particular interest  during  the design phase was the procedure
used for selecting the  final disposal sites.  Under the terms of
the Consent Decree, the Potentially Responsible Parties (PRPs) were
to attempt to locate  disposal  sites for the  wastes.   If the PRPs
were unsuccessful, the Consent Decree (and SARA) required the State
of Rhode Island to identify and make a disposal site available.

As part of this process, firms bidding on  the  remedial work were
required to present  a  primary  and secondary  disposal  site for
review and approval.   This  list of primary and secondary sites was
compiled and  submitted  to EPA  for review.    EPA  reviewed each
facility on the list for compliance with the "offsite policy" and
found none to  be in compliance.  Alternate disposal  sites were then
identified, with the assistance of EPA, and amended quotations were
requested  from  the  bidders.   Contract  award was based  on the
amended quotations.                                             ^
                              342

-------
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

-------
                         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

-------
CO
             0>

             *.
             o
            •o
             n>
             rt
             !-••
             o
             Q)
             3


             M)

             ^


             §
             o
             o
             o
             rt>
             3
             ft
             (0

™ —

	 =^= 	

-

b;

-

	 ^= 	
rMAIKH.E CkdflUL COHPN1Y
MMUM. ACTION OCSKH
WOQC OTY. TfXM
	 \6^5^^ 	
""" M '
=«-!s —
•-< ^
«*M
•-«-«

»». 	 1

U-
fh^i
^^^
TRIANGLE CHEMCAL COMPAI
OPERATIONS PLAN
'-',rr
-".rr..
= — , —

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

-------
Figure 6   Collecting Sample Behind Garden Tractor w/Small Tiller
                                                           ».*•..,.
Figure 7    Large Highway Mixer
                               353

-------
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

-------
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

-------
                       TRIANGLE  CHEMICAL  CO.  SITE
         \
         0>
         3





         P


          I
         UJ *-*
         o
         z
         o
         u
                                    MONITORING WELL »5
                   4/05/88   |    7/27/88  '|   2/21/89   I   8/17/89   I   2/22/90

                         6/08/88      11/3,0/88      6/09/89      12/13/89
                                     DA|E OF SAMPLE

                 D  VC  +•  MC   o  1,1-OCEE \  A 1,1-OCEA  X  1.2-DCEE   V TCE
Figure 8     Monitoring Well #5  Contaminant Level By  Contaminant
         -i

         01

         ~?
         z ?


         5

         y
         u>—
         o
         2
         O
         O
                       TRIANGLE  CHEMICAL  CO.  SITE

                                   MONITORING WELL *6
                   4/05/88   I   7/27/88   |    2/21/89   |   8/17/89   |    2/22/90

                         6/08/88     11/30/88      6/09/89      12/13/89

                                     DATE OF SAMPLE
                D  VC   +  MC  o  1.1-OCEE
                                           1,1-DCEA   X  1,2-OCEE   V  TCE
Figure 9     Monitoring Well  #6 Contaminant Level By Contaminant
                                    356

-------
         \
         01
         D
         ^s

         Z

         O
         o
         z
         o
         o
                7 -
                6 -
5 -
                       TRIANGLE  CHEMICAL  CO.  SITE

                             TOTAL INDICATOR COMPOUNDS IN MW «5
                       —i—I—i—I—i—I—i—I—i—I—r
                     0   23 I  47 I 70  94   118  142  166 |  190 I 214  238  252 | 286

                      11   35   58  82  106 130  154  178 202  226  250  274

                                     TIME (MONTHS)

                        O TOTAL CONCENTRATION    +  LINEAR REGRETION
Figure 10    Monitoring Well #5  Contaminant Reduction Projections
                       TRIANGLE CHEMICAL CO.  SITE

                             TOTAL INDICATOR COMPOUNDS IN MW »6
1 1
10
9
G" ®
\
o>
•i 7
1
IT
5 5
o
1
0
5 3
2
1
0
- *
- I??
° +
+
+
+
+
+
+
*
-*-
— -1-
0 23 47 70 94 118 142 166 190 214 238 262
                          35
                              58
                                  82  106  130  154  178  202  226

                                     TIME (MONTHS)


                        D  TOTAL CONCENTRATION    + LINEAR REGRETION
                                                              250
Figure 11    Monitoring Well  #6 Contaminant Reduction  Projections
                                   357

-------
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

-------
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

-------
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

-------
                                                                                     linen LIMIT AS SHOWN
                                                                                     ON PLANS (TTP.|
                                                                                       -TtK-    ;         ,
                                                                                         1        - w   /" **"*•&*. >
ANCHOR- TRENCH  WITH
COMPACTED CLAr
36B 08TAIL     (  «
                11
                                             Figure 1
                                           South Ditch
                                         Typical Section

-------
THE PROBLEM
Discussion

During the construction of the South Ditch, several problems were
encountered with the placement of the protective soil cover.  These
problems  occured after periods  of  rainfall which  saturated the
placed protective cover.   Since  the  40-mil  textured  HOPE liner was
located beneath  the soil  cover,  water which infiltrated the soil
layer  was  contained  by  the   impermeable  geomembrane.     The
accumulation  of  water between the  soil-geomembrane  interface
created two problems:

1.   Achievable compaction of the soil cover was reduced because of
     the increase in water content above that of optimum.

2.   A slip surface was created  at the lubricated soil-geomembrane
     interface.

A select backfill material was utilized to construct  the protective
soil cover.  The gradation  of the  select material is outlined in
Table l.  The maximum  dry  density of the  soil as determined by the
Standard Proctor Test was  119.2 Ibs/C.F.  The optimum water content
at  the  maximum  dry   density   was  13.4   percent.    During  the
construction of the protective soil  cover,  moisture  content of the
soil increased to more than 20 percent. This significantly reduced
the achievable dry density of the soil.  As a result, the required
90 percent compaction of the soil layer could not be achieved.

After storm  events at the  site, minor slope  failures  along the
protective soil  cover  occurred.   The soil  would  slough down the
slope sometimes exposing the HOPE liner.  This suggested some type
of slope instability.  It  is believed that as water infiltrated the
protective soil cover and accumulated above the HOPE liner a slip
surface was  created at the soil geomembrane  interface.    It is
estimated that the friction angle at the soil-geomembrane interface
was reduced from approximately 28°  to as low as 10°  - 15°.   Basic
soil mechanics tells us that the friction  angle of  the interface
must at least  be as great as the angle of the  slope itself.   In
this case a  3:1  slope corresponds to  18.4°.   Therefore,  without
slope stability calculations, it can be seen that a failure would
occur  at  the  reduced  friction  angle.    As  outlined  below,
calculations were performed to confirm the slope instability.  As
seen from  these calculations, the factor of  safety against slippage
along the  slope  was  reduced from  1.6 to  0.8 at  the  estimated
reduced friction angle.
                                362

-------
                 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

-------
                             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

-------
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

-------
                                                                          LIMER LIMIT nS SHOUH
                                                                          OH PLOH9 (TYP )
                    RNCHOR  TRENCH UITH
                    COHPOCTEO  CLOY
                    SEE
                                                                                                       -EXISTING
                                                                                                        GROUND
                                                                      TEXTURED  HOPE LINER   L|'6-J
8 OZ. NONUOVEN
GEOFflBRIC
                                                                 H"  CONCRETE
                                                                 INVERT PROTECTION
L
                                                     Figure 3
                                                  Modified South Ditch
                                                   Tupical Section

-------
                                  w
                        FIGURE 4

          Typical Cross-Section of South Ditch
Weight Analysis

Given:
Soil Depth        =
Soil Wet Density  =
Soil Compaction   =
Concrete Depth    =
Concrete Density  =
Ditch Width

Analysis:
Actual Soil Density
Soil Weight
Concrete Weight
Tensile Stress Analysis
1 ft.
119.2 pounds per cubic feet (pcf)
90% Standard Proctor
4 in.
150 pcf
20 ft.
     119.2 X 0.90    = 107.3 pcf
     107.3 x 1 x 20  = 2146 Ibs./ft.  of ditch
     150 x 4/12 x 20 = 1000 Ibs./ft.  of ditch
Given:
Concrete Density  =  150 pcf
Concrete Depth    =  4 in.
6   =  Slope Angle   =  1 V to 3 H  =18.4°
61   =  Friction Angle Concrete to Geotextile  =30°
62   =  63 = 64 = 65 = Friction Angle Geotextile to Liner = 23'
66   =  Friction Angle Geotextile to Subbase = 25°
Slope Length      = 9.5 ft.
HOPE Yield Stress = 95 Ibs./in.
Geotextile Yield Stress = 180 Ibs./in.
                           367

-------
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

-------
3..
                                FIGURE 5

        Partial Cross-Section of South Ditch With Concrete Cover
Sliding Analysis

Given:
 6   =  18.4°
     =  30.

     =   25
                = 
-------
Construction

The modified  design aimed to  have  a ditch which  is watertight,
moderate in cost,  strong and  durable,  provide maximum hydraulic
efficiency and have a reasonable  amount  of flexibility.  Concrete,
composed of selected aggregates  with proper  control of placing,
finishing,  and curing will require minimum maintenance and have a
long service life.

1.   The Concrete Mix

     The modified design included well graded  sand in the concrete
     mix to ensure a reasonable  good  finish.   In  addition,  pea
     gravel (No.  4 or  3/16  to 3/8  in.)  content of the  mix  was
     reduced to about 5 percent to improve the  finishability of the
     concrete.  As a rule of thumb,  the maximum size of aggregate
     should not  be  greater  than one-half  the thickness of  the
     lining.  In addition, the concrete was to placed by hand and
     screeded from the bottom to  the top of the slope.  A slump of
     2 to 2 1/2 inches was specified for this application.

2.   Reinforcement

     Though steel  reinforcement  was  not required,  the modified
     design  required the addition  of  Fibermesh   fiber  to  the
     concrete  mix.   Fibermesh  is  a  concrete  engineered  fiber
     composed  of  virgin polypropylene  which  provides  protection
     against nonstructural  cracks in concrete,  increases impact
     capacity, reduces permeability, adds  shatter  resistance  and
     can eliminate the need for welded wire fabric used for crack
     control.   Fibermesh  fibers  provide dimensional stability by
     reducing  intrinsic  stresses  or  relieving them  until  the
     concrete has  developed  sufficient integrity to sustain  the
     stresses without cracking.  The reduction of early age crack
     formation substantially reduces the number of weak planes and
     potential future crack formation.

3.   Placing the Concrete Cover

     A  protective layer of geofabric was placed on the HDPE liner.
     After  placing  the  required  forms  above  the  geotextile,
     concrete  was  dumped and  spread by hand on  the  sides  and
     bottom.   Screed guides were laid  on the geofabric  and  the
     concrete was screeded up the slope to proper thickness.   One
     or two passes with a long-handled steel trowel completed the
     finishing.  Transverse grooves  were cut at 12-foot intervals,
     and the  lining was  cured by use  of  solvent-based concrete
     curing compound with at least 20 percent solids.

     Since  the concrete cover was constructed by hand, concrete was
     placed in alternate  panels  to  facilitate placing,  finishing
     and curing operations.  Overall shrinkage  cracking was reduced
                                 370

-------
     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

-------
          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

-------
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

-------
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

-------
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

-------
                              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

-------
GENEVA INDUSTRIES SITE
Figure 1
                   377

-------
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

-------
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

-------
       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

-------
      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

-------
     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

-------
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

-------
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

-------
    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

-------
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

-------
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

-------
        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

-------
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.
                                            389

-------
                               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.
                                            390

-------
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.
                                               391

-------
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
                                           392

-------
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.
                                         393

-------
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.
                                           394

-------
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
                                           395

-------
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.
                                           396

-------
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
                                              397

-------
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.
                                          398

-------
                    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.
                                            399

-------
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.
                                           400

-------
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.
                                          401

-------
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?

-------
                         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
                                             403

-------
       "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.
                                               404

-------
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
                                                405

-------
of a civil  works project as well as a remedial  action  may  endanger the  public.  Thus, the
documentation and evaluation practices vital to the success of civil works projects are appropriate for
HTW remedial action projects.

DISCUSSION

The value of documentation is highlighted by the fact that construction activities are seldom exactly
as assumed during design. The main factors in these differences are contractors and site conditions.
No two construction contractors operate in the same manner.  Personnel, equipment, and resources
vary.  Site  and subsurface  conditions are difficult to assess completely and accurately during
investigation and design. The effectiveness and perfomance of a remedy can not be evaluated without
actual construction details and data. Future design can not benefit from past construction activities
without a method of technology transfer. The importance  of feedback from construction activities
is enormous.

In order to  accomplish this, good documentation and evaluation practices must be implemented.
These practices will result in an HTW Construction Documentation Report.  A properly prepared
report will record and preserve construction records, conditions, and activities in a readily accessible
form and evaluate construction data.  The report may be used by various or- ganizations to provide
the following:

(1)     Record of construction activities. Historical documentation will be available as to quantities
       excavated, cleanup levels, materials or equipment  used.  This is particularly important in
       rapidly advancing areas of innovative technology and to provide factual data for potential
       litigation.

(2)     Field data applicable to design of future  operable units. Many times, construction activities
       of one operable unit provide valuable design information for another operable unit on a site.
       Information  may include dewatering quantities, additional characteristics of  subsurface
       conditions, and borrow material used.

(3)     Information required for long term performance monitoring and site maintenance. Long term
       performance monitoring and site maintenance are required at HTW sites where the remedial
       action results in any hazardous substance, pollutants, or contaminants remaining on  the site.
       This monitoring may continue for a period of 30 years or more. Good data on construction
       activities  will identify  areas that need closer attention  during  long term  maintenance.
       Problems occurring during construction may identify areas needing particular monitoring to
       ensure adequate performance  of the remedial action.

(4)     Baseline  information for design of repair/modifications  in case of failure.  In the event of
       failure of any portion of the remedial action, the construction documentation report will pro-
       vide a starting point for evaluation of the nature of the failure.  Cause of the failure, design
       and/or construction related, is important in the design of the repair/modification.

(5)     Basis for SARA  mandated  review/evaluation.    SARA  (Superfund  Amendments and
       Reauthorization Act of 1986) requires "review of such remedial action no less often than each
       5 years  after the initiation of such remedial action to  assure  that human health  and the
       environment are being protected by the remedial ac- tion being implemented." SARA section
                                                406

-------
(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.
                                             407

-------
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.
                                           408

-------
                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.
                                 409

-------
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

-------
   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

-------
Table III.     Comparison of RI/FS spending to RA cost overruns.


                    RI/FS COSTS    RATIO OF RI/FS      RA COST
     SITE           (THOUSANDS)    TO RA COSTS         INCREASE

     Old Inger           $348           4.4%             56%
     Bio-Ecology         $357           6.7%             41%
     United Creosote*     —             ~              38%
     Highlands           $355           6.6%             35%
     Geneva            $1,065           5.2%             27%
     Crystal City        $652          53.1%             13%
     PetroChem           $329          19.2%              2%
     Triangle            $175          36.5%             -5%
     Odessa 2 AWS        $181          52.6%            -12%
     Odessa 1 AWS        $161         101.0%            -16%

          *Available RI/FS data covers entire site while
           RA costs are associated only with interim remedy.
associated with the Remedial  Investigation and Feasibility Study
(RI/FS)  for  each site  were  compared  to the  percent  overrun
experienced  at  the site.   Instead  of comparing  RI/FS spending
directly with RA cost  overruns,  a ratio of  RI/FS costs to total RA
costs  was  established to  account for  the relative size  of the
projects, and this ratio  (percentage)  was then  compared  to RA cost
overruns.

As Table III demonstrates,  those projects with  a very low RI/FS to
RA ratio (less than 7%)  showed  significant cost increases, while
those  projects  with   a  higher  ratio showed smaller RA  cost
increases.    If RI/FS  spending is taken as  a reasonable indicator
of the degree of  characterization of  the site, the data confirms
that a poorly  characterized  site  (represented as  a  site  with an
RI/FS  to RA spending ratio  of  less  than  7%)  will  experience
significant  overruns,  while sites which are better characterized
(RI/FS to RA spending ratio  of  above  around  20%)  will generally
experience lower overrun  percentages  .   The United Creosoting site
was excluded from this analysis,  since the costs associated with
the RI/FS for the interim  remedy (house demolition)  could not be
segregated from the total RI/FS costs for the entire site.


III. INCREASES IN CONTRACT PRICE

For this study,  the change  orders in Region 6 were segregated into
six cost increase categories  and one cost decrease category.  The
cost increase  categories include  excess waste quantities, force
majeure,  administrative  delays,  differing  site conditions, scope
changes,  and pollution liability insurance.   Project cost decreases
which  could  not  be  factored  into  the   categories  above  were
classified as scope reductions.

The increases in project  costs after issuance of a contract can be
classified by category into avoidable  and unavoidable increases in

-------
contract price.  Those change orders resulting from things within
the control of  the Government or the contractor, such as inadequate
Site characterization, administrative  difficulties,  and changing
Government needs or  priorities, were  classified  as  "avoidable".
However, change orders caused by acts of God or third parties were
classified as "unavoidable".

A.   Avoidable Increases in Contract Price

Those categories of  change orders which have been classified as
avoidable  increases  in  contract  price  include  excess  waste
quantities, administrative delays, differing site conditions, and
scope changes.   In most  cases,  the savings associated  with the
elimination of these change orders result from competitive prices
(through from  the  bidding process) and reduction of unnecessary
project administrative effort.

While these types of  change  orders could  generally be reduced or
avoided, elimination  of the  change order may  not result  in as
significant of a reduction in contract  price as might be expected.
This is  due to the  fact that  the overall  scope  of  a Superfund
project is "fixed"  by the performance standards established in the
ROD, and the Government will most likely pay  for remediation of all
material exceeding these standards, whether or not the full amount
is known at contract  award.   For  example, though EPA  may not be
aware of all of the materials which exceed  the  cleanup criteria,
all of these wastes must be addressed to comply with the ROD.

1.   Excess Waste Quantities

The  largest  single contributor  to increased costs  in Superfund
construction,  and probably the most difficult to address, is excess
waste quantities.   As  shown in Figure 2,  the  dollar  amount of
excess quantity change orders represents approximately 70 percent
of all change orders processed in Region 6.

The  primary  reason that  excess waste quantities  are  frequently
encountered at Superfund sites is that  the extent of contamination
is usually inadequately defined.  In the past, EPA's field efforts
during the  Remedial  Investigation  (RI) have served as  the only
information about waste quantities upon which the  design is based.
The  Remedial   Investigation   and  Feasibility  Study  is  usually
conducted  under an  eighteen-month schedule  leading  up to  the
publication of EPA's Record of Decision for the site.  Typically,
little time  has been  taken   for  any  supplemental field  work to
answer questions raised but not answered during the RI.

As indicated in Section  II,  the thoroughness  of  the  RI/FS,  among
other  things,   appears  to  have  a significant   impact  on  the
percentage overrun the project will experience.  However, the fact
that the  data  collected during  the  RI  is  insufficient can be
addressed by additional  sampling and  testing during  the Remedial
Design.    While the  target  duration  for  an  RD   is  currently 18
months,  RPMs should  evaluate the  feasibility of  such  a schedule
based  on  the   quality  of  the  data  available   for  the  site.



                                413

-------
                                    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

-------
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

-------
($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

-------
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

-------
     -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 a