SROOOlfOI · 3/87 Quarterly sampling. 4/87 Remedial Investigation, Remedial Actions and HRS Ranking Report. 6/87 Quarterly sampling. 9/87 Quarterly sampling, R-3 and R-4 recovery

Paul R. Mllltr

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tr.f. wrfajtofi <3$od!a]ttes, Inc./•arth MMumf eonsultints

3240 Khoolhoutt roadm(dd!«town, pa 17057-3595

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AMP INCORPORATEDGLEN ROCK FACILITY

SUMMARY DATA PACKAGE

Submitted to EPA, PhiladelphiaBy R. E. Wright Associates, Inc.

August 31, 1988

www ^ s* jfcJ'1.yaffil GLCN HOCK v.

BASE MAPt Qlaii Rock 7 1/2 MlnuU U.S.O.8. Topographic Quadrangle

<"LOCATION OF GLEN ROCK

MUNICIPAL WATER COLLECTION SYSTEMo aooir1 S C A L E '

CONTAMINATED AQUIFER OF CONCERN : NCONTAMINATED PORTION OF.True SAME AQUIFER-" -"SURFACE WATER

i i ?

FROM U.S. ERA, UNCONTROLLED HAZARDOUS WASTE SITE RANKIN3 SYSTEM: A USER'S MANUAL

A'

uj 900w

800

0 700<tuUJ

600

GROUNDWATERDISCHARGE(SPRINGS) GLEN ROCK BOROUGH

AMP I MUNICIPAL WELLSGLEN ROCK

800

700

0 1000 2000 3000 4000 SOOO 6000 7000 6000 900010.00011,00012.00013,00014,00015.000

LEGEND VERTICAL EXAGGERATION -20 TO 1

^] CONTAMINATED PORT ;M OF THE FORMATION

H UNCONTAMINATEO PCftHOM OF THE FORMATION

GROUNDWATEM FLOW DIRECTION (BASED ONOCCURRENCE OF SPRINGS OR FLOWING WELLS) , COMPARISOM OF CONCEPTUAL AND

ACTUAL AQUIFER DISCONTINUITIESSAPROLITE

B6018-057*AALOCATION AND VERTICAL EXTENT OF WELLS ' "'" ' - — —— "*'• wwr *»*•SAMPLED BY PA DER 1987-1988. DASHED WHEREDEPTH INFERRED Lonnnuni.

AMP INCORPORATED.GLEN ROCK PLANT

'CCS **.

IT. a. ,••rthtvtourcti eontulUnts

PUMPING KATE (OAUON8 PEfl MINUTE)

110 OPM ——————— *|T«|-«O QPM-

MAXIMUM SAFE DRAWDOWN

WEATHERED SCHIST IQUARTZITE TO 76'

UHWEATHERED SCHIST FROM 76' TO 302'

1 10 : 100 1000 10,000TOTAL DfFVH ELAPSED TIME (MINUTES) :Of WELL • M

AMP INCORPORATEDOLEN ROCK FACILITY

QLEN HOCK MUNICIPAL WELL FIELDWELL NO. t 48 HOUR PUMPING TEST

****££*

(J r. e.

PUMMNO RAT! (QALLONf PER MINUTE)

CAS1NQ TO 31't

MAXIMUM'SAFE DRAWDOWN

WEATHERED SCHIST IQUARTZITE TO 105

UNWEATHERED SCHIST FROM 108TO BOTTOM Of WELL

1*9

HOt 10 100

TOTAL DEPTH ELAPSED TIME (MINUTES)OF HVU -90S1

\\,O*F •

AMP INCORPORATEDQLEN ROCK FACILITY

QLEH ROCK MUNICIPAL WELL FIELDWELL NO. 1 41 HOUR PUMPINO TEIT

86011-097-Ar.«.

PRECIPITATION (IN INCHES)

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AMP GLEN ROCK SITE CHRONOLOGY

8/14/84 R. E, Wright Associates, Inc. (REWAI) retained ashydrogeologic consultant by AMP for Glen Rockfacility.

8/16-18/84 REWAI sampled groundwater in plant wells AMP-1,AMP-2, and AMP-3, also the distribution box andon-site sewage disposal system.

9/10/84 DER meeting with AMP, Baker/TSA, REWAI. DERapproved work schedule and work scope.Mr. Jeff Molnar of Bureau of Water QualityManagement assigned as official DER liaison party toreview project.

9/11/84 REWAI instructed to continue coordination of all ,work with DER. Mr. Niel Swanson of U. S. EPAnotified of incident.

9/11-13/84 REWAI performs additional on-site soils andgroundwater analysis. Installation of portablestripping tower • AMP-2 converted to groundwaterrecovery well.

9/17/84 Fifteen test borings completed with OVA analysisusing FID at boring collars, collection and analysisof soils for VOC concentrations.

10/12/84 DER meeting with AMP, Baker/TSA, REWAI to discussresults of soil and groundwater analyses.

11/20/84 Cooperative off-site sampling jbetween DER Bureau ofO Community Environmental Control and AMP (REWAI).

11/84 Six monitoring wells emplaced.

11 & 12/84 Pumping tests of monitoring well MW-8, plant wellsAMP-1 and AMP-2.

1/24/85 DER meeting with AMP and REWAI regarding AMP GlenRock site joint sampling of 9/84 and to addressconcerns between differences in analyses and newwater supply law.

3/13/85 DER meeting with Lori Davis of DER, AMP, and REWAIrepresentatives. Purpose was to obtain clari-fication on early soil analyses. DER given fullproject summary and new soils data explanation.

,, 3/85 Pumping test on monitoring well MW-2.

4/85 Remedial Investigation/Feasibility Study reportissued by REWAI.

7/85 Seismic refraction survey.

9/85 Groundwater sampling (quarterly).

10/85 Floor drain study at plastics building.

10/15/85 DER meeting with AMP, REWAI. DER requestssubmission of written proposal and interim remedialsystem design package for approval.

11/85 Interim remedial system installed, R-l installed,removal of oil contaminated soils from storm seweroutlet. DER permit application for the full

^ remedial system program submitted.

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12/85 Quarterly sampling, installation of remedial systemair-stripping towers.

1/86 Plant remedial system towers replace the portabletower, R-l brought on-line with recovery system;submittal of computer files of chemical analysis toDER for review.

3/86 Quarterly sampling.


9/86 Quarterly sampling; R-2 installed.

10/86 Summary report, Remedial Investigation study.

12/86 Quarterly sampling; R-2 on-line, R-l and R-2 pumpingtests.

2/87 1984 shallow soil sample locations retested andanalyzed; air-stripping tower for Albright's TrailerPark completed; NPDES permit approved.


4/87 Remedial Investigation, Remedial Actions and HRSRanking Report.


9/87 Quarterly sampling, R-3 and R-4 recovery wellsbrought on-line.



6/88 Quarterly sampling.S)§§©dISl11@§s' SifiKSo flRQQQj. I fi

KEWAI BIBLIOGRAPHY . AMP GLEN ROCK FACILITY

Remedial Investigation/Feasibility Study of Volatiles OrganicCompounds at the Material Development Laboratory, AMP,Incorporated, Glen Rock, Pennsylvania, May 1985.

Summary Report. Remedial-Investigation Study of Volatile OrganicCompound Contamination of Site Groundwater at the MaterialDevelopment Laboratory, October 1986.

Remedial Investigation, Remedial Actions, and Assessment of SiteHazard Ranking System Score, April 1987.

December 1986 * Glen Rock Quarterly Sampling ReportMarch 1987 • Glen Rock Quarterly Sampling ReportJune 1987 • Glen Rock Quarterly Sampling ReportSeptember 1987- Glen Rock Quarterly Sampling ReportDecember 1987 - Glen Rock Quarterly Sampling ReportMarch 1988 - Glen Rock Quarterly Sampling ReportJune 1988 • Glen Rock Quarterly Sampling Report

[To©, wrisplhft aMdcOatos,- One. AROOQI* I 7

CTo@oearth resources consultants

August 18, 1988

Mr. Dale Kortze, M/s 81*01AMP IncorporatedEnvironmental Programs DepartmentP. 0. Box 3608Harrisburg, PA 17015-3608

Res AMP IncorporatedGlen Rock FacilityREWAI Project 86013

Dear Mr. KortzetAt your request, R* 2. Wright Associates, Inc. (REWAI) hasprepared the following report to accompany the attachedtopographic map showing the Glen Rock facility and itsrelationship to regional hydrogeology and groundwater chemistry.Information presented herein represents a summary and update ofthe geologic information of the information presented in theApril 1987 report entitled "Remedial Investigations, RemedialActions, and Assessment of Site Hazard Ranking Systems Score"which was prepared to address the 0. S. Environmental ProtectionAgency's (EPA) ranking of the AMP Glen Rock facility for theNational Priorities List (NPL). The information presented inthis report is presented as a summary of pertinent informationrather than as a substitute for the extensive documentationavailable concerning the site*Regarding the AM? Glen Rock facility, the critical factor in theHazardous Ranking Score (HRS) evaluation is the degree to whichthe population within a three-mile radius of the Glen Rockfacility is potentially affected by contamination originating atthat location. Therefore, information presented herein willfocus upon the past and current extent of the volatile organiccompound plume originating at the AMP plant and the maximumpossible extent of impacted groundwater originating at the AMPplant, and the degree to which the groundwater supplies within athree-mile radius of the plant are threatened. Several criticalpoints are discussed on the following pages.

3240 schoolhouse road mlddletown, pa 17057-3595 (717) 944-5501fax <7i;

Mr. Dale Kortze - 2 - August 18, 1968

LOCAL AND REGIONAL GROUND WATER HYDROLOGY

The AMP Glen Rock facility is located entirely within thedrainage basin of Seakes Run, a small tributary flowing into theeast branch of Codorus Creek. On a regional scale, the plantlies immediately east of the north-south trending regionaldrainage divide, separating the South Branch Codorus Creek andEast Branch .Codorus Creek drainage basins. Since shallowgroundwater flow systems are largely controlled by surfacetopography with groundwater flow in the direction of topographicslope, the inferred direction of regional groundwater flow in thearea of the AMP Glen Rock plant is toward the northeast. TheGlen Rock municipal well field is nearly two miles due south ofthe facility.On a local scale, groundwater flow from the area of maximumconcentration at the facility is toward the south, in thedirection of Seakes Run. On the southern side of Seakes Run,however, and within the Seakes Run drainage basin in general,groundwater flow is toward the north. Seakes Run is fed bygroundwater discharge in the form of numerous springs located inthe headwater area. Among these are the springs which feedLarkin Fond.

As is typical for the region in general , topographic highsrepresent groundwater recharge areas and topographically lowerlying areas represent groundwater discharge areas. Theoccurrence of springs in the Larkin Pond area indicates an upwardcomponent of groundwater flow at this location, defining agroundwater discharge zone* Therefore* in the vicinity of theAMP Glen Rock facility* a shallow groundwater flow celldominates the hydrogeolog leal regime* with downward flow beneathtopographic highs and upward flow beneath the topographic lows.

GROUNDWATER FLOW BARRIERS

A minimum of € groundwater flow barriers exist between the GlenRock municipal well field and the AMP Glen Rock facility* adistance of over 9*000 feet (see attached map). These flowbarriers are defined by groundwater/surface water drainagedivides and axes for the constituent drainage basins throughwhich surface water flows and to which groundwater base flowdischarges* As stated in the Uncontrolled Hazardous Waste SiteRanking System* A Users Manual* the presence of suchdiscontinuities eliminates the population served by wellsprotected by these features from consideration in the RRSprocess. To quote from the manual (page 25) s

"If a discontinuity in the aquifer occurs between thehazardous substance and all wells* give this factor ascore of zero except where it can be shown that thecontaminant is likely to migrate beyond thediscontinuity.*

AROOO(tl9


Figure 1 compares the concept of a groundwater flow discontinuityas presented by the EPA with the actual situation observedbetween the AMP Glen Rock facility and the Glen Rock Boroughmunicipal well field. Rather than a single discontinuity aspresented In the EPA guidance document, six such discontinuitiesexist between the hazardous substance and the well field.Additionally, Pennsylvania Department of Environmental Resources(DER) sampling (see attached map for well locations) hasdemonstrated that contaminants have not migrated beyond any ofthe discontinuities, as described below. Therefore, thepopulation served by the Glen Rock municipal well field shouldnot be included in the HRS ranking process.

Furthermore, for the same reasons, the populations outside of theSeakes Run drainage basin, in which the AMP Glen Rock facility islocated and in which the volatile organic compound plumeoriginating at the AMP plant is wholly contained, should also notbe considered in the HRS ranking process. The BRS score of 39.93derived by NUS Corporation for the AMP Glen Rock facility wasbased on the population potentially affected and defined asfollowss

Glen Rock Municipal Water CompanyGlen Rock Borough - 1*568Shr ewsbur y 3 8 0

Other SourcesAlbright Trailer Park - 254.6Springfield Manor Apartments - 22.8Homes East of the Triassic Dike - 1 492. a

Total 4,718.2

The total population served by groundwater, aa estimated by NUS,was 4,718.2, leading to a distance to the nearest well/populationserved matrix score of 35. Using this matrix score, agroundwater route score of 65.62 was derived.Based on information presented herein, however. Glen Rock andShrewsbury populations and most of the homes served bygroundwater* as estimated by NUS, should not be included in theBRS ranking process as stipulated in the BRS ranking manual.Since groundwater flow cannot cross a flow divide, such as thatpresented by either a ridge or valley axis, the potential forgroundwater contamination originating at the AMP facility islimited to the Seakes Run drainage basin. Based on a count of


homes indicated on the USGS Glen Rock, Pennsylvania* 7 1/2-minutetopographic map, the population of the Seakes Run drainage basinis approximately 250 individuals. This figure was derived bymultiplying the number of bouses (68) by 3.8 Individuals perhouse. Liberally assuming that the entire population residingwithin the Seakes Run drainage basin* as well as the populationof the Albright Trailer Park and Springfield Manor Apartments, (atotal population of 535.6) is potentially threatened bycontamination originating at the AMP Glen Rock facility, and thatthe distance to the nearest well is 0, a maximum matrix score of20 is derived. Using this matrix value, a groundwater route

v total score of 43.24 results for a total ERS score of 26.64. Itmust be remembered that this total score of 26.64 was derivedusing a very conservative scenario, which is not borne out byactual site conditions. In that the trailer park is served byair-stripping towers, which represents an alternate water supplysource not subject to groundwater contamination, this populationshould also be deleted* This value is well below the criticalvalue of 28.5 necessary to qualify the site for NPL listing.

PLUME EXTENT

The maximum observed extent of groundwater contamination wasobserved in November 1984 (see Figure 2). At this time, total

•., .. volatile organic concentrations exceeded 100 parts per billion.(ppb) over almost all of the AMP Glen Rock site. Significantdecreases in total volatile organic concentrations have beenobserved consistently since that time due to the implementationof a successful program of remediation which focuses upon thecapture of groundwater contamination originating at the facility.By June 1988, groundwater contamination in excess of 100 ppb haddiminished to an area covering less than 50 percent of the site(Figure 2).

Clearly, groundwater contamination originating at the AMP GlenRock plant is decreasing in areal extent. Therefore, thepotential to affect water supplies not yet affected isnonexistent. Furthermore, because of capture of contaminantsoriginating at the facility and diminished plume size, watersupplies which have been affected can be expected to improvesignificantly in the future.During a completely separate study prompted by the detection oftrichloroethylene (TCE) in a Glen Rock Borough municipal watersupply spring, a regional program of groundwater sampling wasimplemented by the DER, Bureau of Community EnvironmentalControl. A summary of the results of DER sampling is presentedas Table 1 and DER groundwater sampling locations are plotted onthe attached map. Contaminants were not detected in 9 of the

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13 wells sampled* TCB and associated transformation productswere detected at four of the sampled locations. Sample locationslie almost in a direct line between the AH? plant and themunicipal well field.

According to Ed Shaw of the Pennsylvania DER, TCE contaminationof the. Fisher spring represents a localized problem due toimproper handling of that substance in the immediate vicinity ofthe spring. TCE is not a major contaminant at the AMP Glen Rockfacility and does not occur at these levels at that location.Contaminants characteristic of the AMP Glen Rock plume(1,1,2-trichloroethane and l,l»l-trichloroethane) were notdetected at any location between and including the Glen Rockmunicipal well field and the AMP plant. Therefore, it can becategorically stated that contamination originating froa the AH?Glen Rock facility has not crossed the drainage divide separatingthe South Branch Codorus Creek and East Branch Codorus Creekdrainage basin* and in no way poses a potential for contaminationof the Glen Rock Borough municipal water supply. Furthermore*based on analyses of the Grim Glass facility's groundwater supplywell, contaminants originating at the -AH? Glen Rock plant havenot crossed the centerline of the Seakes Run drainage basin.

MAXIMUM PLUMS EXTENT

Based on the results of modeling presented in REWAI's April 1987report* the maximum extent of detectable groundwatercontamination is approximately 2,300 feet from the source areadue to the effects of mixing and dispersion during transport.Model results represent an extrapolation based on the advectiondispersion equation governing the rate and extent of groundwatercontamination under steady-state conditions. Calculatedcontaminant concentration isopleths occurred within 50 feet ofthe observed contaminant concentration isopleths, based on datacollected during March 1986. Therefore, the error of estimate isapproximately 50 feet and the maximum plume extent is 2,500 +/-50 feet. As such, only homes within 2,500 feet of the AMP plantand within the Seakes Run drainage basin are potentiallythreatened by contamination originating at that location.Again, excluding the population of the trailer park for which analternate supply of groundwater is available, and including thepopulation of the Springfield Manor Apartments, the totalpotentially affected population is well less than 100, for amaximum matrix spore of 10 and a total HRS score of 18.79.Again, .the value is significantly below the critical value of28.5, which would qualify the site for placement on the NPL.

i, Inc. ARQQQk22


Other key points, as indicated on the attached map, are that anorth-south trending Triassic diabase dike represents a ground-water flow barrier in that the population west of this barrier isnot affected. This point was adequately addressed by KUS' duringthe BRS ranking process. Finally, it should be noted thatadditional measures toward continued environmental restoration atthe AKP plant are planned for the very near future. Theseinclude, but -are not limited to, the installation of additionalrecovery wells near the contaminant source area in order tocapture contaminants at the point where they are introduced tothe groundwater. regime, and implementation of a feasibility studyfocused upon expediting environmental restoration by means ofenhanced recovery processes-which may include soil gas extractionor soil washing by means of flushing.

We would be more than happy to discuss the information presentedherein at your convenience and look forward to an equitable andjust decision regarding the site by the EPA.

Very truly yours,R. E. WEIGHT ASSOCIATES, INC.

Paul R. MillerProject Manager

FRMsprAttachments

IT.®. wrighft associates. Inc. AR0001423

T03895-6018

Table 1

Water Quality SamplingGlen Rock Municipal Sources

REWAI Project 86018

Source1 Date Results fppb)

1. Well 2 11/2/87 No Detection

2. Well 3 11/2/87 No Detection

3. Fisher Spring 11/2/87 TCE - 100 ppb

4. Sterner Springs 11/9/87 No Detection

5. Miller Spring 11/9/87 No Detection

6. Fisher Spring 11/9/87 TCE - 159 ppb

7. Fisher Well 11/23/87 TCE - 45 ppb

8. Grin's Glass 12/14/87 No Detection

9. Private Well A 12/14/87 No Detection

10. Private Well B 12/14/87 No Detection

11. Private Well C 3/17/88 TCE - 25 ppb

12. Private Well D 4/28/88 No Detection

13. Private Well E 4/28/88 No Detection

14. Pond F 4/28/88 trans-l,2-Dichloroethylene - 2.5 ppb

cis-l,2-Dichloroethylene - 1.1 ppb

1 Data from DER Sampling (Ed Shaw, 7/27/88 letter to REWAI).

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AROOQli26

CORRECTIVE ACTION PLAN

O INTRODUCTION

O RCRA FACILITY INVESTIGATION

Task Is Description of Current Conditions

Task lit Pre-Investigation Evaluation of CorrectiveMeasure Technologies

Task Ills RFI Workplan Requirements

Task IV: Facility Investigation

Task V: Investigation Analysis

Task IV: Laboratory and Bench-Scale Studies

Task VIIt Reports

O CORRECTIVE MEASURE STUDY

Task VIIIt Identification and Development of the Cor-rective Measure Alternative or Alternatives

Task IX» Evaluation of th* Corrective MeasureAlternative or Alternatives

Task Xs Justification and Recommendation of theCorrective Measure or Measures

Task XI; Reports

O CORRECTIVE MEASURE IMPLEMENTATION

Task XIIx Corrective Measure Implementation ProgramPlan

Task XIIIi Corrective Measure Design

Task XIVi Corrective Measure Construction

Task XVt Reports

AR01W27

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INTRODUCTION

The objective of a Corrective Action Program at a hazardouswaste management facility is to evaluate the nature andextent of the release of hazardous waste or constituents;to evaluate facility characteristics; and to identify,develop, and implement the appropriate corrective measureor measures adequate to protect human health and the envi-ronment* The following bullets identify components neces-sary to assure a complete corrective action program. Itshould be recognized that the detail required in each ofthese steps will vary depending on the facilty and its com-plexity:

o Locate the source(s) of the release(s) of contaminants(e.g.- regulated units, solid waste management units,and other source areas)

o Characterize the nature and extent of contamination bothwithin the facility boundaries and migrating from thefacility. This would include defining the pathways andmethods of migration of the hazardous waste or constitu-ents, including the media, extent, direction, speed, com-plicating factors inflencing movement, concentration pro-files, etc.

o Identify areas and populations'threatened by releasesfrom the facility '_'"••'•:;,-:.\S •--••'• ''

o Determine short and long term, present and potentialthreats of releases from the facility on human healthand/or the environment

o Identify and implement a interim measure or measures toabate the further spread of contaminants* control thesource of contamination, or otherwise control the re-leases themselves . . :

o Evaluate the overall integrity of containment structureand activities at the site intended for long-term con-tainment ~ ,

o Identify, develop, and implement a corrective measureor measures to prevent and remediate releases of hazard-ous waste or constituents from the facility

o Design a program to monitor the implementation, mainten-ance and performance of any interim or final correctivemeasure(s) to ensure that human health and the environ-ment are being protected

AROOOtt28

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The purpose of the Corrective Action Plan (CAP) Is to aidRegions and States in determining and directing the specificwork the owner/operator or respondent must perform, as partof a complete corrective action program. The CorrectiveAction Plan is a document specifically Intended to assistRegions and States in the development of Corrective ActionOrders (S 3008(h)) and corrective action requirements inpermit applications and permits (S 300.4{u)&(v) ) . it doesso by laying out scopes of work for the three essentialphases of a complete corrective action program which canbe used to formulate facility-specific scopes of work fora order or permit. These three phases and their objectivesare as follows:

Phase I - RCRA Facility Investigation (RPI) - toevaluate thoroughly the nature andextent of the release oC hazardouswaste and hazardous constituents andto gather necessary data to support theCorrective Measure Study.

Phase II - Corrective Measures Study (CHS) - todevelop and evaluate corrective measurealternative or alternatives and torecommend the final corrective measureor measures.

Phase III - Corrective Measures Implementation (GUI)to design , construct, operate » maintainand monitor the performance of thecorrective measure or measures selected.

Users of the CAP should understand that it is designed toidentify actions that facility owner/operator or respondentmust take as part of a corrective action program. It doesnot identify the steps that remain the responsibility ofthe regulatory agency. To clarify this interaction betweenthe facility owner/operator or respondent, Figure 1 repre-sents the flowchart of owner/operator or respondent submit-tala and Agency actions for the three phases of the CAP.

The CAP scopes of work should not be considered "boilerplate.* The scopes of work in the CAP are models and mustbe modified, enhanced or sections deleted based on site-specific situations. Information generated, from Investiga-tions such such as RCRA Facility Assessments {RFAs) shouldbe used to tailor the scope of work to address facility-specific situations. The following are some exampleswhere site-specifics require modification to the CAP modelscopes of work.

AROOO(*29

o If the contamination problem at a facility is merely asmall soil contamination problem, then the CAP shouldbe scaled down accordingly.

o In complicated contamination situations, the Health andSafety Plan and Community Relations Plans may need tobe comprehensive. However, in simple contaminationsituations, these plans may be very brief.

o If site-specifics conditions require more detail thanwhat has been scoped out in any particular section ofthe CAP, then the CAP should be enhanced accordingly*

o if there is sufficient information on a site to precludean air release, then it would not be necessary to requirethe owner/operator or respondent to perform an air con-tamination characterization. The air contamination char-acterization work under the RFI (Task IV, C, 4) should bedeleted.

o If interim measures are underway, scheduled or contem-plated at a facility, then the Interim Measures sectionunder the RFI (Task I, C) should be modified to specifi-cally reference the interim measures.

o If possible, the CAP should focus the owner/operator orrespondent on specific solid waste management units andother areas of interest, as veil as known waste manage-ment activity areas (i.e. waste recycling units, waste-water treatment tanks).

o If only one corrective measure alternative is appropriatefor a given situation, and It would not be necessary torequire the owner/operator or respondent to furtherinvestigate the possibility of other corrective measurealternatives, then the scopes of work (citations) wouldbe modified to reflect this situation.

Finally, it is necessary to stress the importance ofsite-specific technical detail in the development of Cor-rective Action Orders and corrective action permit require-ments* When the scope of work is specific to the facility,it is easier to enforce. Each facility has unique charac-teristics and circumstances affecting it that need to beincorporated into any requirements for corrective action.Without this many owner/operators or respondents will pro-vide us with submittals which lack the necessary informa-tion to perform a corrective measure program. In additionto providing a adequate scope of work, the Agency shouldalso propose a site-specific time-frame for completion ofthe work.

•AROOOii30

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SCOPE OF WORK FOR A RCRA FACILITY INVESTIGATIONAT

[SPECIFY FACILITY NAME]

PURPOSE

The purpose of this RCRA Facility Investigation is to deter-mine the nature and extent of releases of hazardous wasteor constituents from regulated units, solid waste managementunits/ and other source areas at the facility and to gatherall necessary data to support the Corrective Measures Study.The Respondent shall.furnish all personnel/ materials, andservices necessary for, or incidental to, performing theRCRA remedial investigation at [specify facility name].

(NOTE: This scope of work is intended to foster timely, con-cise submissions by Respondent* To achieve this goal, itis important when using the model scope of work to considerfacility specific conditions. This scope of work should .be modified as necessary'to require only that informationnecessary to complete the RCRA Facility Investigation.]

SCOPE

The RCRA Facility Investigation consists of seven tasks:

Task I: Description of Current Condition* -.,-••%, j

A. Facility BackgroundB, Nature and Extent of ContaminationC. Implementation of Interim Measures

Task II: Pre-Investigation Evaluation of Corrective MeasureTechnologies

Task Ills RFI Workplan Requirements

A. Project Management PlanB. Data Collection Quality Assurance PlanC. Data Management PlanD. Health and Safety PlanE. Community Relations Plan

Task IVs Facility InvestigationA. Environmental SettingB. Source CharacterizationC. Contamination CharacterizationD. Potential Receptor Identification

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Task V: Investigation AnalysisA* Data AnalysisB. Protection Standards

Task VIi Laboratory and Bench-Scale StudiesTask VIIi Reports

A. Task I Report and RPI WorkplanB* ProgressC. Draft and Final

flROOOI»32

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TASK I; DESCRIPTION OF CURRENT CONDITIONS

The Respondent shall submit for EPA approval a reportproviding the background information pertinent to thefacility, contamination, and interim measures as set forthbelow. The data gathered during any previous investigationsor inspections and other relevant data shall be included.

A. Facility Background

The Respondent's report shall summarize the regionallocation, pertinent boundary features, general facilityphysiography, hydrogeology, and historical use of thefacility for the treatment, storage, or disposal ofsolid and hazardous waste. The Respondent's reportshall includei

1. Map(s) depicting the following:

a. General geographic location; -

b. Property lines, with the owners of alladjacent property clearly indicated;

c. Topography (with a contour interval of [number]feet and a scale of 1 inch - 100 feet), water-4.ways, all wetlands, floodplains," water features,.>drainage patterns; •', - :-'~ :'.r'i$&£&££i&

" * • ' 'T""'-:m ' V*1 . ""'.• '*vr '•'•"'•!*t ' " - - ' " ' . . " ' . ..'"-

d* All tanks, buildings, utilities, paved areas,easements, rights-of-way, and other features;

e. All solid or hazardous waste treatment, storage,or disposal areas active after November 19, 1980;

f. All known past solid! or hazardous waste treat-ment, storage, or disposal areas and all known :spill, fire, or other accidental release loca-tions regardless of whether they ware activeon November 19, 1980;

g. All known past and present product and wasteunderground tanks or piping;

h. Surrounding land uses (residential, commercial,agricultural, recreational); and

i* The location of a,I production and ground watermonitoring wells. These wells shall be clearlylabeled. Ground and top of casing elevationsshall be included (these elevations may be in-cluded as an attachment)*

HRO(W33

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All maps shall be consistent with the requirementsset forth in 40 C.F.R. $ 270*14 and be of sufficientdetail and accuracy to locate and report all currentand future work performed at the site;

2. A history and description of ownership and operation,solid and hazardous waste generation, and treatment,storage, and disposal activities at the facility;

3. Approximate dates or periods of past product andwaste spills, identification of the materialsspilled, the amount spilled, the location of thespills, and a. description of the response actionsconducted (local, State, or Federal response unitsor private parties), including any inspectionreports or technical reports generated as a resultof the response; and

4. A summary of past permits requested and/or received,any enforcement actions and their subsequent re-sponses .

B. Nature and Extent of Contamination

The Respondent shall prepare and submit for EPA ap-proval a preliminary report describing the existinginformation on the nature and extent of contamination*

1. The Respondent's report shall summarize all possiblesource areas of contamination* This, at a minimum,should include all regulated units, solid wastemanagement units, spill areas, and other suspectedsource areas of contamination. For each area, theRespondent shall identify the following!

a. Location of unit/area (which shall be depictedon a facility, map);

b. Quantities of solid and hazardous wastes;

c» Hazardous waste or hazardous constituents/ tothe extent known; and

d. Identification of areas where additional in-formation is necessary*

2* The Respondent shall prepare an assessment and de-scription of the existing degree and extent ofcontamination. This should includes

flROOOl»3lf

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a. Available monitoring data and qualitative in-formation on locations and levels of contami-nation at the facility;

b. All potential migration pathways including in-formation on geology, pedology, hydrogeology,physiography, hydrology, water quality, meter-ology, and air quality; and

c. The potential impact(s) on human health and theenvironment, including demography, ground waterand surface water use* and land use.

Implementation of'Interim Measures

The Respondent's report shall document interim measureswhich were or are being undertaken at the facility*This shall includes1. Objectives of the interim measuress how the measure

is mitigating a potential threat to human healthand tha environment and/or is consistent with and-integrated into any long term solution at thefacility!

2. Design* construction, operation, and maintenance ,requirements; • •. -.-..;. •.•;^.-,,_.-.vf-''-":.^' "•' . . .•_._ • ;'V

3* Schedules for design,, construction, and monitoring!and '-, '.-."' •"-. :

- -f ' *

4. Schedule for progress reports.

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TASK II: PRE-INVESTIGATION EVALUATION OF CORRECTIVE MEASURETECHNOLOGIES " —

Prior to starting the facility investigation, the Respondentshall submit to EPA a report that identifies the potentialcorrective measure technologies known to Respondent at thetime of report submittal that may be used on-site or off-site for the containment, treatment, remediation, and/ordisposal of contamination. This report shall also identifyany field, laboratory/ bench- or pilot-scale data thatneeds to be collected in the facility investigation tofacilitate the evaluation and selection of the final cor-rective measure or measures (e.g., compatibility of wasteand construction materials, information to evaluate effec-tiveness, treatability of wastes, etc*)*

—-'

'-, r;v::;,i:S?,>.l':'••:,-. ..?.::•" . i-.i-.i:1.*, :*<•.»•-•;.

••- ••'£ "'-'•'WJ&5SSlt.4S"i:V-

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TASK III: RFI WORKPLAN REQUIREMENTS

The Respondent shall prepare a RCRA Facility InvestigationWorkplan. This RFI Workplan shall include the developmentof several plans, which shall be prepared concurrently.During the RCRA Facility Investigation, it may be necessaryto revise the RFI Workplan to increase or decrease thedetail of information collected to accomodate the facilityspecific situation. The RFI Workplan shall include thefollowing:

A. Project Management Plan

The Respondent shall prepare a Project Management Planwhich will include a discussion of the technical ap-proach, schedules, budget, and personnel. The ProjectManagement Plan will also include a description ofqualifications of personnel performing or directing theRFI, including contractor personnel. This plan shallalso document the overall management approach to theRCRA Facility Investigation. ~

B. Data Collection Quality Assurance Plan

The Respondent shall prepare a plan to document allmonitoring procedures! sampling, field measurements,and sample analysis performed during thVInvestigato characterize the environmental setting source,contamination* so as to ensur«;>that all informationydata and resulting decisions are technically sound/statistically valid, and properly documented. - ;

1. Data Collection Strategy *• • ..-'- " ' V -yt.:-. :'T-.%-

The strategy section of the Data Collection Quality 'Assurance Plan shall Include, but not bo limited to,ths following!

a. Description of the intended uses for the data, " -;and the necessary level of precision and accuracyfor these intended uses? "

b. Description of methods and procedures to be used .-to assess the precision, accuracy, and completenessof the measurement data?

c. Description of the rational* used to assure thatthe caca accurately and precisely represent a ;char :taristic of a population, parameter varia-tior.r at a sampling point* a process condition,or '- - environmental condition. Examples offactors which shall be considered and discussedinclude:

flRQOOI*37

fi''

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i) Environmental conditions at the time ofsampling;

ii) Number of sampling points;

iii) Representativeness of selected media; and

iv) Representativeness of selected analyticalparameters.

Description of the measures to be taken to assurethat the following data sets can be comparedto each other:

i) RFI data generated by the Respondent oversome time period;

ii) RFI data generated by an outside labora-tory or consultant versus data generatedby the Respondent; :

iii) Data generated by separate consultants'orlaboratories > and ;- M

iv) Data generated by an outside consultant ---*/jior lafcfprajfcp J>ye 4s< v:U ^ . .-—- ...^• ' "?-:: SrS*'Details relating

to be provided in quality'assuranceThe reports should.include, but not betoi

. T-- ' J>

. . • • . • - • • - - • •i) Periodic assessment of measurement data;accuracyr precision/ and completeness/,./.

ii) Results of performance audits; "'.-••''"•

iii) Results o£ system auditsi . ._iv) Significant quality assurance problems

and recommended:solutions; and

v) Resolutions of previously stated problems.

2* Sampling

The Sampling section of the Data Collection QualityAssurance Plan shall discussia. Selecting appropriate sampling locations, depths,

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b. Providing a statistically sufficient number ofsampling sites;

c. Measuring all necessary ancillary data;

d. Determining conditions under which samplingshould be conducted;

e. Determining which media are to be sampled(e.g./ ground water, air, soil, sediment,

. etc.);f. Determining which parameters are to be measured

and where';

g. Selecting the frequency of sampling and lengthof sampling period;

h. Selecting the types of sample (e.g., compositesvs. grabs) and number of samples to be collected;

i. Documenting field sampling operations and pro-cedures, includingi

1) Documentation of procedures for prepara-tion of reagents or supplies which become .an integral part of the sample (e.g.,filters, and adsorbing reagents);

11) Procedures and forms for recording theexact location and specific considers-tions associated with sample acquisition;

Hi) Documentation of specific sample preser-vation method;

iv) Calibration of field devices;

v) Collection of replicate samples;

vi) Submission of field-biased blanks, whereappropriate;

vii) Potential Interferences present at thefacility;

viii)

ix) Field equipment listing and sample con-tainers;

flROOOl+39

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x) Sampling order; and

xl) Decontamination procedures.

j. Selecting appropriate sample containers;

k. Sample preservation; and

1. Chain-of-custody, including:

1) Standardized field tracking reporting formsto establish sample custody In the fieldprior to shipment; and

ii) Pre-prepared sample labels containing allinformation necessary for effective sampletracking*

Field Measurements

The Field Measurements section of the Data Collec-tion Quality Assurance Plan shall discuss :

a. Selecting appropriate field measurement loca-tions, depths , etc*; •

b. Providing a statistically sufficient' number offield measurements; ' .- 7. r:/-. - ';V'';-:, •;.•;./:'. "• ..;.

c. Measuring all necessary ancillary data;

d. Determining conditions under which field measure-ment should be conducted!

e* Determining which media are to be addresssed byappropriate field measurements (e.g., groundwater, air, soil, sediment, etc.);

f * Determining which parameters are to be measuredand where!

g. Selecting the frequency of field measurement andlength of field measurements period; and

h. Documenting field measurement operations andprocedures , including i

i) Procedures and forms for recording rawdata and the exact location, time, andfacility-specific considerationsassociated with the data acquisition!

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it) Calibration of field devices!

iii) Collection of replicate measurements;

iv) Submission of field-biased blanks, whereappropriate;

v) Potential interferences present at thefacility;

vi) Construction materials and techniques as-sociated with monitoring wells and piezo-meters used to collect field data;

vii) Field equipment listing;

viii) Order in which field measurements weremade; and

ix) Decontamination procedures.

Sample Analysis .-The Sample Analysis section of the Data;

Quality Assurance Plan shall specify

a. Chain-of -custody1 ) Ident if ication of a re* ns

act as sample custodian afc|facility authorized to Sifield samples, obtain dornent* and verify thethe sample custody

11) Provision for alog consisting ofard lab-tracJcing report

111) Specification of ——————*^T^-procedures for sample han<SIin >tofage/ v'- ,>-,•-and dlspersement for analysli;* ',,"£:*• \, v£-v-"-

. •T->S*ffft1*-1."*.' ?' •» •.''-_,'" " TV •.*''j~*-••!'.'

b. Sample storage; - . . X >$ V1. "":. :;- '; ^ *-'c. Sample preparation methods; .; v 5 - : • '....**'£''*'''

d. Analytical procedures* includingV^^;> ".;•• '; "-fe/'""' •- i 'I'ri,!'..' , - *.>!-•.•'_- -

1) Scope and application of the procedure; -;f 7

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ii) Sample matrix*

ill) Potential interferences;

iv) Precision and accuracy of the metho-dology; and

v) Method detection limits*

e. Calibration procedures and frequency;

f. Data reduction, validation, and reporting;

g. Internal quality control checks, laboratory per-formance and systems audits and frequency,including!

i) Method blank(s);

ii) Laboratory control sample(s);

iii) Calibration check sample(s);

iv) Replicate sample(s);*' - • ' • • * ' • • ' •v) Matrix-spiked sample(s)? ;-'- ..•-,- _., .^- "-

- . .., -, avjtf :•-•:> ? W>K; -v^-: 'vi) "Blind" quality control ia1ii?Jle(»i)>>r*v;"

vii) Control chartsi \

viii) Surrogate samples;ix) Zero and span gases; and .

x) Reagent quality control checks*

[A performance audit will be conducted byEPA on the laboratories selected by the Respond-ent. This audit must be completed and approvedprior to the facility investigation.]

h. Preventive maintenance procedures and schedules;

i. Corrective action (for laboratory problems); and

j• Turnaround time.C. Data Management Plan

The Respondent shall develop and initiate a Data Manage-

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ment Plan to document and track investigation data andresults. This plan shall identify and set up data docu-mentation materials and procedures , project file require-ments t and project-related progress reporting proceduresand documents. The plan shall also provide the formatto be used to present the raw data and conclusions ofthe investigation.

1. Data Record

The data record shall include the following:a. Unique sample or field measurement code;

b* Sampling or field measurement location andsample or measurement typo;

c. Sampling or field measurement raw data?

d. Laboratory analysis ID number;

e. Property or component measured; and *f. Result of analysis (e.g., concentration). ';'

2. Tabular Displays , / ; "• • v"-.*- '.:"'-';> s- 'p.'"; ' ''""" •••"••- '•V.V.-'X'- •-•/'•'•' ' < -.-•'-. "_'

The following data shall be; presented \ln tabular .displays! - • • - -v ' "-. '.-.<-"• • ".-%;;_- ••'."•'• -. . ' 'a. Unsorted (raw) data r V

b. Results for each medium, or for each constituentmonitored}

c. Data reduction for statistical analysis;d. Sorting of data by potential stratification

factprs (e.g., location, soil layer, topography);and

e. Summary data.

3. Graphical DisplaysThe following data shall be presented In graphicalformats (s*g*r bar graphs, llns graphs, area or planmaps, isopleth plots, cross-sectional plots or tran-sects, three dimensional graphs, etc.)t

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a. Display sampling location and sampling grid;

b. Indicate boundaries of sampling area, and areaswhere more data are required;

c. Display levels of contamination at each samplinglocation;

d* Display geographical extent of contamination;

e. Display contamination levels, averages, andmaxima ;

f. Illustrate changes in concentration in relationto distance from the source, time/ depth, orother parameters ; and

g. Indicate features affecting intramedia transportand show potential receptors.

D. Health and Safety Plan /

The Respondent shall prepare a facility Health and SafetyPlan. . . . . - . . ' • -'"V-: - . - - / - .1. Major elements of the Health and Safety Plan shall

includei • - : ;*V-, -,:::.*;ft •• - :~-.. - • ••-••/••- :-'--f':S K'' :. -'^a. Facility description including availability of

resources such as roads, water supply, electric-ity, and telephone service; : V^ "

b. Description of the known hazards and evaluationsof the risks associated with the incident andwith each activity conducted;

c. List of key personnel and alternates responsiblefor site safety, responses operations, and forprotection of public health;

d. Delineation of work area;

e. Description of levels of protection to be wornby personnel in work area;

f . Establishment of procedures to control siteaccess;

g. Description of decontamination procedures forpersonnel and equipment;

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h. Establishment of site emergency procedures;

i. Emergency medical care for injuries and toxi-cological problems;

j. Description of requirements for an environmentalsurveillance program;

k. Routine and special training required for res pon-ders; and

1. Establishment of procedures for protecting workersfrom weather-related problems.

2. The Facility Health and Safety Plan shall be con-sistent withi

a. NIOSH Occupational Safety and Health GuidanceManual for Hazardous Waste Site Activities(1985)i

b. EPA Order 1440.1 - Respiratory Protection;

c. EPA Order 1440.3 - Health and Safety Require-ments for Employees engaged In Field Activities; '"

. •'.--**-• -•• ' .- • •d. Facility Contingency Plan; ••'- ? ,-

-• ' •• • -*•?> :}•?."&'-'*:. .• .- •-'.•«.-. ' •'•• , '.-- '• ... *-••'• .'+*:-ir*' -»*- .- . '. .:-- .e. EPA Standard Operating Safety Guide (1984);- • - . -' V;*f * -. ""'.' ' ' -;

C. OS HA regulations particularly in 29 C*F.R. 1910and 1926* •• - i ?

• ••• • £ yg • Stats .and local regulations i andh* Other EPA guidance- as provided*

, "• - " r*'*

Community Rslatlona Plan • • ' . .

Respondent shall prepare a plan, for ths dissemina-tion of information to ths public regarding investigationactivities and results.

TASK IV» FACILITY INVESTIGATION

The Respondent shall conduct those investigations necessaryto: characterize ths facility (Environmental Setting); defineths source (Source Characterization) dsfins ths degree andextent of contamination (Contamination Characterization);and identify actual or potential receptors*

-20-

The investigations should result in data of adequate technicalquality to support the development and evaluation of thecorrective measure alternative or alternatives during theCorrective Measures Study*

The site investigation activities shall follow theplans set forth In Task III. All sampling and analysesshall be conducted in accordance with the Data CollectionQuality Assurance Plan. All sampling locations shall bedocumented in a log and identified on a detailed site map.

*• Environmental SettingThe Respondent shall collect information to supplementand verify existing information on the environmentalsetting at the facility. The Respondent shall charac-terize the following}

1. Rydrogeology

The Respondent shall conduct a program to evaluate*hydrogeologlc conditions at the facility. This ,program shall provide the following informations .#-•' •

-. ,:•••- , ' .... .*• *•'•. '-*'

a. A description of the regional and facility. "-specific geologic and (hydrogeologic charac-teristics affectingthe facility,

1) Regional and facility specific stratigraphys description of strata Includingstrike and dip, -identification of strati-graphic contacts?- ,

11) Structural geoiogyt description of localand regional structural features (e.g.,folding, faulting;- tilting> jointing,

. ' - - - etc.); .'.i.i, :'V r''V--'V ' .ill) Depositlonal history;

• ' iv) Identification and characterization ofareas and amounts of recharge and dis-charge;

v) Regional and facility specific groundwater flow patterns; and

vlj Characterize seasonal variations in theground water flow regime.

•• •'*.f*-tV»

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b. An analysis of any topographic features thatmight influence the ground water flow system.(Notes Stereographic analysis of aerial photo-graphs may aid in this analysis.)

c. Based on field data, tests, and cores, a repre-sentative, and accurate classification and descrip-tion of the hydrogeologic units which may be partof the migration pathways at the facility (i.e.,the aquifers and any intervening saturated andunsaturated units), including:

i) Hydraulic conductivity and porosity(total and effective);

ii) Lithology, grain size, sorting, degreeof cementationi

iii) An interpretation of hydraulic intercon-nections between saturated zones; and

iv) The attenuation capacity and mechanismsof the natural earth materials (e.g., J-ion exchange capacity, organiccontent, mineral content etc.).

Based ongeology and hydrogeblogl<j- crosV sectionsthe extent (depth, htckn«s», lateral extent) ohydrogeologic unit*- which may be part of th© .migration pathways, Identifying* '

' " '.V * ' '• •..

i) Sand and gravel deposits in unconsoli*dated deposits? .

....' '-";.••'*.*' ' . \ '." .•"-

ii) Zones of 'fracturing or channeling in .consolidated or unconsolidated deposits;

ill) Zones of high permeability or low per-meability that might direct and/or restrictthe flow of contaminants;

iv) The uppermost aquifen geologic formation,group of formations f or part of a formationcapable of yielding a significant amountof ground water to wells or springs;and

v) Water-bearing zones above the first con-fining layer that may serve as a pathwayfor contaminant migration, includingperched zones of saturation*

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e* Based on data obtained from ground water moni-toring wells and piezometers installed upgradientand downgradient of the potential contaminantsource/ a representative description of waterlevel or fluid pressure monitoring/ including!

i) Water-level contour and/or potentiometricmaps;

ii) Hydrologic cross-sections showing verticalgradients;

ill) The flow system/ including the verticaland horizontal components of flow; and

iv) Any temporal changes in hydraulic gradi-ents/ for example/ due to tidal or seasonalinfluences*

f. A description of man made influences that may-af-fect the hydrogeology of the site, identifying:

i) Active and inactive local water supply^ ^ and production wells with an approximate :':"'*$r.schedule of pumping; and ; . - . ,:;-;?,

ii) Manmade hydraulic structures (pipelines/ .french drains/ ditches/ unllned ponds',--, ;.->' 'septic tanks, RFDES outfalls, retention ' ?,areas, etc.)- • '. • • - - . ,-•.*.'• -v--" |

2. Soils

The Respondent shall conduct a program to charac-terize the soli and rock units above the water table .-in the vicinity of the contaminant release (s). Suchcharacterization shall include, but not be limitedto, the following information ia. Soil Conservation Service (SCS) soil classification!b. Surface soil distribution;c. Soil profile, including American Standard Test

Method (ASTH) classification of soils;d. Transects of soil stratigraphy;e. Hydraulic conductivity (saturated and unsatu-

rated); ,f . Relative permeability;g. Bulk density; :h. Porosity;i. Soil eorptive capacity;j. Cation exchange capacity (CEC);k. Soil organic content;1. Soil pH;

HRQQQkkB

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m. Particle size distribution rn. Depth of water table;o. Moisture content;p* Effect of stratification on unsaturated flow;q. Infiltrationr. Evapotranspiration;s. Storage capacity;t. Vertical flow rate; andu. Mineral content.

3. Surface Water and Sediment

The Respondent shall conduct a program to characterizethe surface water bodies in the vicinity of the facili-ty. Such characterization shall include, but not belimited to, the following activities and information:

a. Description of the temporal and permanent surfacewater bodies including!

i) For lakes and estuaries i location, eleva-tion, surface area, inflow, outflow, depth,temperature stratification, and volume r

ii) For impoundments s location, elevation,surface area, depth, volume, freeboard,and purpose of impoundment; ;

ill) For streams, ditches, and channels t loca-tion, elevation, flow, velocity, depth,width, seasonal fluctuations, and floodingtendencies (i**«, 100 year event);

iv) Drainage patterns; andv ) Evapotranspiration .

b. Description of the chemistry of the natural sur-face water and sediments. This includes deter-mining the pH, total dissolved solids, totalsuspended solids, biological oxygen demand,alkalinity, conductivity, dissolved oxygen pro-files, nutrients (NH3, KO /HQf, P04"3),chemical oxygen demand, total organic carbon,specific contaminant concentrations, etc*

c. Description of sediment characteristics including!i) Deposition area;ii) Thickness profile; and

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, i) Sorption;

ii) Biodegradability, biocentration, biotrans-formation;

lit) Photodegradation rates;

iv) Hydrolysis rates; and

v) Chemical transformations.

The Respondent shall document the procedures used in makingthe above determinations.

C. Contamination Characterization

The Respondent shall collect analytical data on groundwaterr soils, surface water, sediment* and subsurfacegas contamination in the vicinity of the facility. Thisdata shall be sufficient to define the extent, origin,direction, and rate of movement of contaminant plumes*Data shall include time and location of sampling, mediasampled, concentrations found, conditions during sam-pling, and the identity of the individuals performing thesampling and analysis* The Respondent shall address thefollowing types of contamination at the facility!

1. Ground Water Contamination,••-•." :; _•''••':> - ;.; ; /The Respondent shall conduct a Ground Water Investiga-tion to characterize any plumes of contamination at -the facility. This investigation shall, at a minimum,provide the following information: .a. A description of the horizontal and vertical ex-

tent of any Immiscible or dissolved plume(s)originating from the facility;

b. The horizontal and vertical direction of contami-nation movement;

c. The velocity of contaminant movement;

d. The horizontal and vertical concentration profilesof "Appendix VIII constituents" (see 40 C.F.R*Part 261', App. VIII) in the plume (s);

e. An evaluation of factors Influencing the plumemovement? and

f. An extrapolation of future contaminant movement. ...

i The Respondent shall document the procedures used to char-acterize contaminant plume(s), for example, geophysics,modeling, pump tests, slug tests, nested piezometers, etc.

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2. Soil Contamination

The Respondent shall conduct an investigation to char-acterize the contamination of the soil and rock unitsabove the water table in the vicinity of the contami-nant release. The investigation shall include thefollowing information:

a. A description of the vertical and horizontal ex-tent of contamination;

b. A description of contaminant and soil chemicalproperties within the contaminant source areaand plume* This includes contaminant solubility,speciatioh, adsorption, leachabillty, exchangecapacity, biodegradability , hydrolysis, photolysis,oxidation, and other factors that might affect con-taminant migration and transformation;

c- Specific contaminant concentrations;

d. The velocity and direction of contaminant movement;and

e. An extrapolation of future contaminant movement.

The Respondent shall document the procedures used inmaking the above determinations.

3* Surface Water and Sediment Contamination

The Respondent shall conduct a surface water investi-gation to characterize contamination in surface waterbodies resulting from contaminant releases at thefacility*The investigation shall include, but not be limited to,the following information:

a. A description of the horizontal and vertical ex-tent of any immisicible or dissolved plume(s)originating from the facility, and the extent ofcontamination in underlying sediments;

b. The horizontal and vertical direction of contami-nant movement;

c. The contaminant velocity;

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-28-'*

d. An evaluation of the physical, biological, andchemical factors influencing contaminant movement;

e. An extrapolation of future contaminant movement;and

f. A description of the chemistry of the contaminatedsurface waters and sediments. This includes de-termining the pH, total dissolved solids, specific

. contaminant concentrations, etc.

The Respondent shall document the procedures used inmaking the above determinations.

4. Air Contamination

The Respondent shall conduct an investigation to char-acterize the participate and gaseous contaminantsreleased into the atmosphere. This investigationshall provide the following informations

a. A description of the horizontal and verticaland velocity of contaminant movement;

b. The rate and amount of the release; and

c. The chemical and physical composition of the con*taminants(s) released, including horizontal andvertical concentration profiles*

The Respondent shall document the procedures used inmaking the above determinations*

5. Subsurface Gas Contamination

The Respondent shall conduct an investigation to char-acterize subsurface gases emitted from buried hazardouswaste and hazardous constituents in the ground water.This investigation shall include the following infor-mation:

a. A description of the horizontal and vertical ex-tent of subsurface gases mitigation;

b* The chemical composition of the gases beingemitted;

c. The rate, amount, and density of the gasesbeing emitted' and

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d. Horizontal and vertical concentration profiles^of the subsurface gases emitted.

The Respondent shall document the procedures usedin making the above determinations.

Potential Receptors

The Respondent shall collect data describing the humanpopulations and environmental systems that are susceptibleto contaminant exposure from the facility. Chemicalanalysis of biological samples may be needed. Data onobservable effects in ecosystems may also be obtained.The following characteristics shall be identified!

1. Local uses and possible future uses of ground water:

a. Type of use (e.g., drinking water source! munici-pal or residential, agricultural, domestic/non-potable, and industrial); and

b. Location of ground water users, including wells anddischarge areas*

2. Local uses and possible future uses of surface watersdraining the facilityi

a. Domestic and municipal (e.g., potable and lawn/garden watering);

b. Recreational (e.g., swimming, fishing);c. Agricultural;d. Industrial; ande. Environmental (e.g., fish and wildlife propagation).

3. Human use of or access to the facility and adjacentlands, including, but not limited toi

a. Recreation;b* Hunting;c* Residential;d. Commercial;e. Zoning; andf. Relationship between population locations and

prevailing wind direction.4. A description of the biota in surface water bodies on,

adjacent to, or affected by the facility.

5. A description of the ecology overlying and adjacent tothe facility.

-30-: ft;- 3. ..Jt.'V •

6. A demographic profile of the people who use or haveaccess to the facility and adjacent land, including,but not limited to: age, sex, and sensitive subgroups*

7. A description of any endangered or threatened speciesnear the facility.

TASK V; INVESTIGATION ANALYSIS

The Respondent shall prepare an analysis and summary of allfacility investigations and the results of such investigations.The objective of this task shall be to ensure that the inves-tigation data are sufficient in quality (e.g., quality assuranceprocedures have been-followed) and quantity to describe thenature and extent of contamination, potential threat tohuman health and/or the environment, and to support theCorrective Measures Study.

A. Data Analysis

The Respondent shall analyze all facility investigation dataoutlined in Task IV "FACILITY INVESTIGATION", and preparea report on the type and extent of contamination at thefacility, including sources and migration pathways. Thereport shall describe the extent of contamination (qual-itative/quantitative) in relation to background levelsindicative of the area.

B. Protection Standards [where applicable]

1. Ground Water Protection Standards

For regulated units the Respondent shall provide in-formation to support the Agency's selection/developmentof Ground Water Protection Standards for all of theAppendix VIII constituents found in the ground waterduring the Facility Investigation (Task IV).

a. The Ground Water Protection Standards shall consistoft

i) the Maximum Contaminant Level (MCL) forany constituents with an EPA promulgatedMaximum Contaminant Level (MCL), if thebackground level of the constituent isbelow the value of the EPA approvedMCLi or

ii) the background level of that constituent inthe ground water; or

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lil) an EPA approved Alternate ConcentrationLimit (ACL).

b. Information to support the EPA'3 selection ofAlternate Concentration Limits (ACLs) shall bedeveloped by the Respondent In accordance withapplicable EPA guidance. For any proposed ACLsthe Respondent shall include a justificationbased upon the criteria set forth in 40 C.F.R.$ 264.94<b).

c. Within [insert number] calendar days of receipt ofany pro posed ACLs, the EPA shall notify theRespondent, in writing, of approval, disapprovalor modifications. The EPA shall specify, inwriting, the reason(s) for any disapproval ormodification.

d. Within [insert number] calendar days of receipt ofthe EPA'3 notification of disapproval of anyproposed ACLs, the Respondent shall amend and:submit revisions to the EPA.

2. Other Relevant Protection Standards

The Respondent shall Identify all relevant and appli-. cable standards for the protection of human health andthe environment (e.g., National Ambient Air QualityStandards, Federally-approved state water qualitystandards, etc.).

TASK VIi LABORATORY AND BENCH-SCALE STUDIES

Based on the EPA approved report submitted pursuant to Task IIof this orders the Respondent shall conduct laboratory and/orbench scale studies to determine the applicability of a cor-rective measure technology or technologies to facility condi-tions. The Respondent shall analyze the technologies, basedon literature review, vendor contracts, and past experienceto determine the testing requirements.

The> Respondent shall develop a testing plan identifying thetypea(s) and goal(s) of the study(ies), the level of effortneeded, and the procedures to be used for data management andinterpretation.

Upon completion of the testing, the Respondent shall evaluatethe testing results to assess the technology or technologieswith respect to the site-specific questions identified in thetest plan.

The Respondent shall prepare a report summarizing the testingprogram and its results, both positive and negative*

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TASK VI I i REPORTS

A , Preliminarv( Task I) and RFI Workplan

The Respondent shall submit to the EPA reports on Tasks Iand II when It submits the RCRA Facility InvestigationWorkplan (Task III).

B. Progress

The Respondent shall, at a minimum, provide the EPA withsigned, [monthly, bimonthly] progress reports containing:

1. A description and estimate of the percentage of theRFI completed;

2. Summaries of all findings;

3. Summaries of all changes made in the RFI during thereporting period;

4. Summaries of all contacts with representatives of thelocal community, public interest groups or stategovernment during the reporting period}

5. Summaries of all problems or potential problems en-countered during the reporting period;

6. Actions being taken to rectify problems;

7. Changes in personnel during the reporting period;

8. Projected work for the next reporting period; and9. Copies of daily reports, inspection reports,

laboratory/monitoring data, etc*

c* Draft and FinalUpon EPA approval, the Respondent shall prepare a RCRA Fa-cility Investigation Report to present Tasks IV-V. TheRCRA Facility Investigation Report shall be developed indraft form for EPA review. The RCRA Facility Investi-gation Report shall be developed in final format, incorpora-ting comments received on the Draft RCRA Facility Investi-gation Report. Task VI shall be submitted as a separatereport when the Final RCRA Facility Investigation Report issubmitted.

[number] copies of all reports, including the Task I re-port, Task II report. Task III workplan, Task VI report

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and both the Draft and Final RCRA Facility InvestigationReports (Tasks IV-V) shall be provided by the Respondentto EPA.

[THE FOLLOWING FACILITY SUBMISSION SUMMARY MAY BE PLACED INTHE BODY OF THE ORDER OR PERMIT AND REMOVED FROM THE SCOPEOF WORK. NOT ALL OF THE ITEMS LISTED BELOW MAY BE REQUIREDAT EACH FACILITY.]

FacialJty Submission Summary

A summary of the information reporting requirements containedin the RCRA Facility Investigation Scope of Work is presentedbelow:

Facility Submission

Description of Current Situation(Task I)

Pre-Investigation Evaluation of CorrectiveMeasure Technologies

(Task II)

RFI Workplan(Task III)

Draft RFI Report(Tasks IV and V)

Final RFI Report' (Tasks IV and V)

Laboratory and Bench-Scale Studies(Task VI)

Progress Reports on Tasks I through VI

Due Date

[ DATE ]

[ DATE ]

[ DATE ]

[ NUMBER ] days afterRFI Workplan Approval

[ NUMBER ] days afterEPA comment on DraftRFI Report

Concurrent with FinalRFI Report

[ MONTHLY, BI-MONTHLY 1

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SCOPE, OFJtfORK FOR A CORRECTIVE MEASURE STUD?AT ————— " —— —————

[SPECIFY FACILITY NAME]

PURPOSE

The purpose of this Corrective Measure Study ("CMS") is to de-velop and evaluate the corrective action alternative or al-ternatives and to recommend the corrective measure or measuresto be taken at [specify facility name]. The Respondent shallfurnish the personnel, materials/ and services necessary toprepare the corrective measure study/ except as otherwisespecified.

[Note: This scope of work is intended to foster timely/ con-cise submissions by Respondent. To achieve this goal/ it isimportant when using the model scope of work to considerfacility specific conditions. This scope should be modifiedas necessary to require only that information necessary tocomplete the Corrective Measure Study. ]

SCOPE

The Corrective Measure Study consists of four tasks z

Task VIII: Identification and Development of the CorrectiveMeasure Alternative or Alternatives

A. Description of Current SituationB. Establishment of Corrective- Action ObjectivesC. Screening of Corrective Measures TechnologiesD. Identification of the C r~ ctive Measure

Alternative or Alternative**Task IX: Evaluation of the Corrective Measure Alternative or

AlternativesA* Technical/Environmental/Human Health/InstitutionalB. Cost Estimate

Task Xi Justification and Recommendation of the CorrectiveMeasure or MeasuresA.B.C.

Task XI: Reports

A. ProgressB. DraftC. Final

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TASK VHIt IDENTIFICATION AND DEVELOPMENT OF THE CORRECTIVEACTION ALTERNATIVE OR ALTERNATIVES

Based on the results of the RCRA Facility Investigation andconsideration of the identified Preliminary Corrective MeasureTechnologies (Task II), the Respondent shall identify, screenand develop the alternative or alternatives for removal,containment, treatment, and/or.other remediation of the con-tamination based on the objectives established for the cor-rective action.

A. Description of Current Situation

The Respondent shall submit an update to the informationdescribing the current situation at the facility and theknown nature and extent of the contamination as documentedby the RCRA Facility Investigation Report* The Respondentshall provide an update to information presented in Task Iof the RFI, "DESCRIPTION OF CURRENT CONDITIONS," to theAgency regarding previous response activities and anyinterim measures which have or are being implemented atthe facility* The Respondent shall also make a facility-specific statement of the purpose for the response,based on the results of the RCRA Facility Investigation.The statement of purpose should identify the actual orpotential exposure pathways that should be addressed bycorrective measures.

B * Establishment of Corrective Action Objectives

The Respondent, in conjunction with the EPA, shallestablish site specific objectives for the correctiveaction. These objectives shall be based on publichealth and environmental criteria, information gatheredduring the RCRA Facility Investigation, EPA guidance, andthe requirements of any applicable Federal statutes. Ata minimum, all corrective actions concerning ground waterreleases from regulated units must be consistent with,and as stringent aa, those required under 40 C.F.R.5 264.100.

C. Screening of Corrective Measure Technologies

The Respondent shall review the results of the RCRA Fa-cility Investigation and reassess the technologiesspecified in the Task II report as approved by EPA andidentify additional technologies which are applicableat the facility. The Respondent shall screen thft pre-liminary corrective measure technologies identified inTask II of the RCRA Facility investigation and anysupplemental technologies to eliminate those that mayprove infeasible to implement, that rely on technologiesunlikely to perform satisfactorily or reliably, or that

RR000459

do not achieve the corrective measure objective within areasonable time period. This screening process focuseson eliminating those technologies which have severelimitations for a given set of waste and site-specificconditions. The screening step may also eliminatetechnologies based on inherent technology limitations.Site, waste/ and technology characteristics which areused to screen inapplicable technologies are describedin more detail below:

1. Site Characteristics

Site data should be reviewed to identify conditionsthat may limit or -promote the use of certain tech-nologies. The use of technologies which are clearlyprecluded by site characteristics should be eliminatedfrom further consideration;

2. Waste Characteristics

Waste characteristics particularly affect the feasi-bility of remediating waste by utilizing in-situmethods, direct treatment methods, or land disposal(on/off-site) methods. Therefore, identificationof waste characteristics that limit the effectiveness

xv_/ or feasibility of remediating technologies is animportant part of the screening process. Remediatingtechnologies clearly limited by these waste charac-teristics should be eliminated from consideration.

3; Technology Limitations

During the screening process, the level of technologicaldevelopment, performance record, and inherent con-struction, operation, and maintenance problems shouldbe identified for each technology considered. Tech-nologies that are unreliable, perform poorly, or arenot fully demonstrated may be eliminated in the

• . screening process. For example, certain treatmentmethods have been developed to a point where theycan be implemented in the field without extensivetechnology transfer or development*

D. Identification of the Corrective Measure Alternative orAlternatives

The Respondent shall develop the corrective measure al-ternative or alternatives based on the corrective actionobjectives and analysis of Preliminary Corrective MeasureTechnologies, as presented in Task II of the RCRA Facilityinvestigation and as supplemented following the prepara-

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tion of the RFI Report. The Respondent shall rely onengineering practice to determine which of the previouslyidentified technologies appear most suitable for the site.Technologies can be combined to form the overall correc-tive action alternative or alternatives. The alternativeor alternatives developed should represent a workablenumber of option (s) that each appear to adequately ad-dress all site problems and corrective action objectives.Each alternative may consist of an individual technologyor a combination of technologies. The Respondent shalldocument the reasons for excluding technologies, identi-fied in Task II, as supplemented in the development ofthe alternative or alternatives*

TASK IX t EVALUATION OF THE CORRECTIVE MEASURE ALTERNATIVE ORALTERNATIVES ——————————————————

The Respondent shall describe each corrective measure alterna-tive that passes through the initial screening in Task VIIIand evaluate each corrective measure alternative and itscomponents* The evaluation shall be based on technical tenvironmental, human health, and institutional concerns* TheRespondent shall also develop cost estimates of each correctivemeasure •

A. Technical/Environmental/Human Health/InstitutionalThe Respondent shall provide a description oC each correc-tive measure alternative which includes, but is not Unitedto, the following: preliminary process flow sheets; pre-liminary sizing and type of construction for building andstructures; and rough quantities of utilities required.The Respondent shall evaluate each alternative in thefollowing four areas i1. Technical t

The Respondent shall evaluate each corrective measurealternative based on performance, reliability, imple-raentability, and safety.

a* The Respondent shall evaluate performance basedon the effectiveness and useful life of the correc-tive measure!i) Effectiveness shall be evaluated in terms of

the ability to perform intended functions,such as containment/ diversion, removal,destruction, or treatment. The effectivenessof each corrective measure shall bo determinedeither through design specifications or by

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performance evaluation. Any specific wasteor site characteristics which could potentiallyimpede effectiveness shall be considered*The evaluation should also consider the effec-tiveness of combinations of technologies;and

. ii) Useful life is defined as the length of timethe level of effectiveness can be maintained.Host corrective measure technologies/ withthe exception of destruction, deterioratewith time. Often, deterioration can be slowedthrough proper system operation and maintenance,but the technology eventually may requirereplacement. Each corrective measure shallbe evaluated in terms of the projected servicelives of its component technologies. Resourceavailability in the future life of the tech-nologies, as well as appropriateness of thetechnologies , must be considered in estimatingthe useful life of the project.

b. The Respondent shall provide information on thereliability of each corrective measurer includingtheir operation and maintenance requirements andtheir demonstrated reliability!

i) Operation and maintenance requirements includethe frequency and complexity of necessaryoperation and maintenance. Technologiesrequiring frequent or complex operation andmaintenance activities should be regarded asless reliable than technologies requiringlittle or straightforward operation andmaintenance* The availability of labor andmaterials to meet these requirements shallalso be considered; and

li) Demonstrated and expected reliability is a wayof measuring the risk and effect of failure.The Respondent should evaluate whether thetechnologies have been used effectively.under analogous conditions; whether the com-bination of technologies has been usedeffectively; whether failure of any onetechnology has an -immediate impact on recep-tors; and whether the corrective measure hasthe flexibility to deal with uncontrolablechanges at the site.

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c. The Respondent shall describe theof each corrective measure, including the relativeease of installation (constructability) and thetime required to achieve a given level of response:

i) Constructability is determined by conditionsboth internal and external to the facilityconditions and include such items as locationof underground utilities, depth to watertable, heterogeneity of subsurface materials,and location of the facility (i.e., remotelocation vs. a congested urban area). TheRespondent shall evaluate what measures canbe taken to facilitate construction underthese conditions. External factors whichaffect implementation include the need forspecial permits or agreements, equipmentavailability, and the location of suitableoff site treatment or disposal facilities?and

ii) Time has two components that shall be ad-dressed: the time it takes to implement acorrective measurer and the time it takes toactually obtain beneficial results. Beneficialresults are defined as the reduction of con- ,taminants to some acceptable* pre-established^^level.

d. The Respondent shall evaluate each correctivemeasure alternative with regard to- safety* Thisevaluation shall include threats to the safety ofnearby communities and environments, as well asthose to the safety oC workers during implementa-tion. Factors to consider include, but are notlimited to, fire, explosion, and exposure tohazardous substances*

2* Environmental:

The Respondent shall perform an Environmental Assess-ment for each alternative* The Environmental Assess-ment shall focus on the facility conditions and path-ways of contamination actually addressed by eachalternative . The Environmental Assessment for eachalternative will include, at a minimum, an evaluationof i the short- and long-term beneficial and adverseeffects of the response alternative j any adverseeffects on environmentally sensitive areas? and ananalysis of measures to mitigate adverse effects*

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3. Human Health:

The Respondent shall assess each alternative in termsof the extent of which it mitigates short- and long-term potential exposure to any residual contaminationand protects human health, both during and after im-plementation of the corrective measure. The assess-ment will describe the levels and characterizationsof contaminants on site/ potential exposure routes,and potentially affected populations. Each alternativewill be evaluated to determine the level of exposureto contaminants and its reduction over time. Formanagement of mitigation measures, the relative re-duction of impact will be determined by comparingresidual levels of each alternative with existingcriteria, standards, or guidelines acceptable to EPA.

4. Institutional!

The Respondent shall assess relevant institutionalneeds for each alternative. Specifically/ the effectsof Federal, State, and local environmental and publichealth standards, regulations, guidance, advisories,ordinances, or community relations, including require-ments for construction and operating permits on thedesign, operation, and timing of each alternative*

B. Cost Estimate

The Respondent shall develop an estimate of the cost ofeach corrective measure alternative (and for each phaseor segment of the alternative). The cost estimate shallinclude both capital and operation and maintenance costs.1. Capital costs consist of direct (construction) and in-

direct (nonconstruction and overhead) costs.

a. Direct capital costs includes

i) Construction costs s Costs of materials,labor (including fringe benefits andworker's compensation), and equipmentrequired to install the corrective measure;

ii) Equipment costs s Costs of treatment, con-tainment, disposal, and/or service equipmentnecessary to implement the action;

iii) Land and site-development costs s Expensesassociated with purchase of land anddevelopment of existing property; and

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iv) Buildings and services costs: Costs ofprocess and nonprocess buildings, utilityconnections, purchased services, anddisposal costs.

b. Indirect capital costs include:

i) Engineering expenses: Costs of administra-tion, design, construction supervision,drafting, and testing of corrective measurealternatives;

ii) Legal fees and license or permit costs:Administrative and technical costs necessaryto obtain licenses and permits for instal-lation and operation;

iii) Startup and problem solving immediatelyfollowing startup (skakedown) costs:Costs incurred during corrective measurestartup; and

iv) Contingency allowances: Funds to covercosts resulting from unforeseen circumstances,such as adverse weather conditions, strikesand inadequate facility characterization.

2. Operation and maintenance costs are post-constructioncoats necessary to ensure continued effectiveness ofa corrective measure. The Respondent shall considerthe following operation and maintenance cost components!

a* Operating labor costs s Wages, salaries, training,overhead, and fringe benefits associated withthe labor needed for post-construction operations i

b. Maintenance materials and labor costs: Costs forlabor, parts, and other resources required forroutine maintenance of facilities and equipment;

c. Auxiliary materials and energy: Costs of itemssuch as chemicals and electricity for treatmentplant operations, water and sewer service, andfuel;

d. Purchased services: Sampling costs, laboratoryfees, and professional fees for which the needcan be predicted;

e. Disposal and treatment costs: Costs of transport-ing, treating, and disposing of waste materials,such as treatment plant residues, 'generatedduring operations;

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£. Administrative costs* Costs associated with ad-ministration of corrective measure operation andmaintenance not included under other categories;

g. Insurance, taxes, and licensing costst Costs ofsuch items as liability and sudden accidentinsurance; real estate taxes on purchased landor rights-of-way; licensing fees for certaintechnologies; and permit renewal and reportingcosts;

h. Maintenance reserve and contingency fundst Annualpayments .into escrow funds to cover (1) costs ofanticipated replacement or rebuilding of equipmentand (2) any large unanticipated operation andmaintenance costs; and

i. Other costs: Items that do not fit any of theabove categories.

TASK X: JUSTIFICATION AND RECOMMENDATION OF THE CORRECTIVEMEASURE OR M E A S U R E S "

The Respondent shall justify and recommend a corrective measurealternative using technical, human health, and environmentalcriteria. This recommendation shall include summary tableswhich allow the alternative or alternatives to be understoodeasily* Tradeoffs among health risks, environmental effects,and other pertinent factors among the alternatives evaluatedshall be highlighted. The EPA will select the correctivemeasure alternative or alternatives to be implemented, basedon the results of Tasks IX and X. At a minimum, the followingcriteria shall be used to justify the final corrective measureor measures.

A. Technical

1. Performance * corrective measure or measures which aremost effective in performing the intended functionsand maintaining the performance over extended periodsof time shall be given preference;

2* Reliability - corrective measure or measures which donot require frequent or complex operation and mainte-nance activities and that have been proven to be effec-tive under waste and facility conditions similar tothose anticipated shall be given preference;

3. Implementability - corrective measure or measures whichcan be constructed and operated to reduce levels ofcontamination to attain or exceed applicable standardsIn the shortest period of time shall be preferred; and

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4. Safety - corrective measure or measures which pose theleast threat to the safety of nearby residents andenvironments, as well as to workers , during implementa-tion will be preferred.

B . Human Health

The corrective measure or measures must comply with exist-ing EPA criteria, standards, or guidelines for theprotection of human health. Corrective measures whichprovide the minimum level of exposure to contaminants andthe maximum reduction in exposure with time shall bepreferred.

C. Environmental

The corrective measure or measures posing the least adverseimpact (or greatest improvement) over the shortest periodof time on the environment shall be favored.

TASK XI t REPORTS

The Respondent shall prepare a Corrective Measure Study Reportpresenting the results of Tasks VIII through X and recommendinga corrective measure alternative* [number] copies of thepreliminary report shall be provided by the Respondent.

A« Progress

The Respondent shall, at a minimum, provide the EPA withsigned, [monthly, bimonthly] progress reports containingi

1. A description and estimate of the percentage of theCMS completed;

2. Summaries of all findings;

3. Summaries of all changes made in the CMS during thereporting period;

4. Summaries of all contacts with representatives of thelocal community, public interest groups, or stategovernment during the reporting period;

5. Summaries of all problems or potential problems en-countered during the reporting period;

6. Actions being taken to rectify problems;

7. Changes in personnel during the reporting period;

8. Projected work for the next reporting period; and

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9. Copies of daily reports, inspection reports,laboratory /monitoring data, etc.

B . Draft

The Report shall, at a minimum, include:

1. A description of the facility s

a. Site topographic map and preliminary layouts.

2. A summary of the corrective measure or measures:

a* Description of the corrective measure or measuresand rationale for the selections );

b. Performance expectations;

c. Preliminary design criteria and rationale;d. General operation and maintenance requirements; and

e. Long-term monitoring requirements.

3. A summary of the RCRA Facility Investigation and impacton the selected corrective measure or measures!

a. Field studies (ground water, surface water, soil,air); and

b* Laboratory studies (bench scale, pick scale).

4. Design and Implementation Precautions!a. Special technical problems;

b. Additional engineering data required;c. Permits and regulatory requirements;

d. Access, easements, right-of-way;

e. Health and safety requirements; and

f. Community relations activities.

5. Cost Estimates and Schedules!

a. Capital cost estimate;b. Operation and maintenance cost estimate; and

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c. Project schedule (design, construction, operation) .[number] copies of the draft shall be provided by the Re-spondent to EPA.

C. Final

The Respondent shall finalize the Corrective Measure StudyReport, incorporating comments received from EPA on theDraft Corrective Measure Study Report.

[THE FOLLOWING FACILITY SUBMISSION SUMMARY MAY BE PLACED INTHE BODY OF THE ORDER OR PERMIT AND REMOVED FROM THE SCOPEOF WORK. NOT ALL OF 'THE ITEMS LISTED BELOW MAY BE REQUIREDAT EACH FACILITY.]

Facility Submission Summary

A summary of the information reporting requirements containedin the Corrective Measure Study Scope of Work is presentedbe low i

Facility Submission

Draft CMS Report ,(Tasks VIII, IX, and X)

Final CMS Report(Tasks VIII, IX, and X)

Progress Reports on Tasks VIII, IX, and X

Due Date

[ NUMBER ] daysafter submittal ofthe Final RFI

[ NUMBER ] daysafter Public andEPA comment on theDraft CMS[ MONTHLY, BI-MONTHLY 1

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Writ ~ >"** '*

a*

>

SROOOlfOI · 3/87 Quarterly sampling. 4/87 Remedial Investigation, Remedial Actions and HRS Ranking Report. 6/87 Quarterly sampling. 9/87 Quarterly sampling, R-3 and R-4 recovery

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