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HomeMy WebLinkAboutNCD980729602_19910926_Jadco-Hughes_FRBCERCLA RD_Remedial Design Work Plan-OCRI I I I I I I I I I I I I I I I I I I REMEDIAL DESIGN WORK PLAN Jadco-Hughes Site Gaston County, North Carolina SEPTEMBER 1991 REF. NO. 3669 (6) CONESTOGA-ROVERS & ASSOOATES I I I I I I I I I I I I I CRA Consulting Engineers September 26, 1991 Ms. Barbara Benoy Superfund Projecf Office CONESTOGA-ROVERS & ASSOCIATES LIMITED 651 Colby Drive, Waterloo, Ontario, Canada N2V 1C2 (519) 884-0510 Reference No. 3669 United States Environmental Protection Agency Region IV Air and Waste Management Division 345 Courtland St. Atlanta, Georgia U.S.A. 30365 Dear Ms. Benoy: Re: Remedial Design (RD) Work Plan Jadco-Hughes Superfund Site (Site) Gaston County. North Carolina Enclosed please find fifteen (15) copies of the above captioned Work Plan. The Work Plan has been prt?pared on behalf of the Jadco-Hughes Steering Committee by CRA, in fulfillment of the r!:!quirements of Section VIII, Paragraph 6 of the Administrative Order for the Site dated June 19, 1991 (Docket No. 91-31-C). The fifteen copies of the Work Plan are submitted to fulfill the requirements of the "Summary of Major Deliverables" which is attached to the Scope of Work (SOW) for the RD at the Site. Included as attachments to the RD Work Plan are the following submittals: • Health and Safety Plan -Remedial Design Work Plan Submittal A (five submitted); • Sampling and Analysis Plan -Remedial Design Work Plan Submittal B (fifteen submitted); and • Treatability Study Work Plan -Remedial Design Work Plan Submittal C (fifteen submitted). The SOW requires the RD Work Plan to include a schedule for completion of each required activity and submission of deliverables required by the Order. Please note that the RD Work Plan schedule allows USEPA 45 days from receipt to review and approve submittals. The Jadco-Hughes Steering Committee is committed to I I I I I I I. I I I I I I I I I I I I CONESTOGA-ROVERS & ASSOCIATES LIMITED Consulting Engineers September 26, 1991 - 2 - Reference No. 3669 completing work on time and where possible ahead of schedule. To keep the project moving we request that USEPA perform its review within the RD Work Plan schedule. If you should have any questions, please contact our office. Yours truly, CONESTOGA-ROVERS & ASSOCIATES SMQ/bjr/3 Encl. c.c.: Reuben Bussey, USEPA Region IV Jadco-Hughes Steering Committee Jimmy Kirkland, King & Spalding Rick Shepherd, CRA / I I I I I I I I I I I I I I I I I I I TABLE OF CONTENTS 1.0 INTRODUCTION ...................................................................................................... 1 1.1 GENERAL. ....................................................................................................... 1 2.0 SITE DESCRIPTION .................................................................................................. 8 , 2.1 BACKGROUND ............................................................................................. 8 ,( 2.2 CONTAMINATION PROFILES ................................................................. 12 J 2.3 SPECIFIC TARGETS OF REMEDIA TION ................................................. 13 3.0 REMEDIAL OBJECTIVES ......................................................................................... 14 3.1 GENERAL. ....................................................................................................... 14 3.2 SOIL ................................................................................................................... 15 3.3 GROUNDWATER. ........................................................................................ 16 4.0 PROJECT ORGANIZATION AND MANAGEMENT ....................................... 20 4.1 GENERAL. ....................................................................................................... 20 4.1.1 CRA's Project Team ...................................................................................... 21 5.0 RD/RA PROJECT PLANS ........................................................................................ 24 5.1 HEALTH AND SAFETY PLAN .................................................................. 24 5.2 SAMPLING AND ANALYSIS PLAN ....................................................... 25 5.3 TREATABILITY STUDY WORK PLAN ................................................... 25 6.0 PREDESIGN /REMEDIAL ACTIVffiES ................................................................ 27 6.1 PREDESIGN ACTIVITIES ............................................................................ 27 6.2 REMEDIAL DESIGN ACTIVITIES ............................................................. 28 6.2.1 General ............................................................................................................. 28 6.2.2 Plan to Satisfy Permitting Requirements ................................................. 29 6.2.3 Design Process ................................................................................................. 30 6.2.4 Design Submittals .......................................................................................... 35 7.0 REPORTS AND DOCUMENTATION ................................................................. .41 7.1 EPA MONTHLY PROGRESS REPORTS .................................................. .41 7.2 DATA MANAGEMENT PLAN ................................................................ .41 7.3 PRE-DESIGN SUPPORTING DOCUMENTATION ............................... 41 7.4 PRE-DESIGN TECHNICAL MEMORANDA ........................................... 42 7.5 DESIGN REPORTS ........................................................................................ 42 7.6 CONSTRUCTION SCHEDULE ................................................................... 42 7.7 LONG TERM OPERATION AND MAINTENANCE and MONITORING AND TESTING REPORTS ............................................ .43 8.0 COMMUNITY RELATIONS SUPPORT ............................................................... 44 9.0 SCHEDULE .................................................................................................................. 46 CONESTOGA-ROVERS I!, ASSOCIATES 1· I TABLE OF CONTENTS I 10.0 Page REFERENCES ............................................................................................................. 47 .I I I I I I I I I :1 I I I I I I COi'!ESTOGt'.·ROVERS 8 ASSOC!ATES I I I I I 1 I I I I I I ., I I I I I I .; FIGURE 1.1 FIGURE 1.2 FIGURE 1.3 FIGURE 2.1 FIGURE 2.2 FIGURE 2.3 FIGURE 2.4 FIGURE 2.5 FIGURE 2.6 FIGURE 2.7 FIGURE 2.8 FIGURE 2.9 FIGURE 2.10 FIGURE 2.11 FIGURE 4.1 FIGURE 9.1 LIST OF FIGURES Following Page SITE LOCATION 1 HISTORICAL SITE FEATURES 1 RI INSTALLATIONS AND SAMPLING LOCATIONS 2 SITE DRAINAGE PATTERN 9 GEOLOGIC CROSS-SECTION A-A' 9 SHALLOW GROUNDWATER FLOW PATTERNS 10 DEEP GROUNDWATER FLOW PATTERNS 10 TOTAL voe CONCENTRATIONS IN SUBSURFACE SOIL 10 TOTAL BNA CONCENTRATIONS IN SUBSURFACE SOIL 10 IRM EXCAVATION AREAS 11 TOTAL voe CONCENTRATIONS -SHALLOW AQUIFER 11 TOTAL BNA CONCENTRATIONS -SHALLOW AQUIFER 11 TOTAL voe CONCENTRATIONS-DEEP AQUIFER 11 TOTAL BNA CONCENTRATIONS -DEEP AQUIFER 11 PROJECT TEAM 20 RD/RA SCHEDULE 46 COi\!ESTOGA·ROVERS & ASSOCIATES I I LIST OF TABLES I Following Page I TABLE 2.1 CONTAMINATION PROFILE -FORMER LANDFILL SUBSURFACE SOILS 12 I TABLE 2.2 CONTAMINATION PROFILE -ON-SITE GROUNDWATER 13 I TABLE 3.1 SOIL CLEANUP GOALS 15 I TABLE 3.2 GROUNDWATER REMEDIATION OBJECTIVES 16 TABLE 7.1 SUMMARY OF PRE-DESIGN TECHNICAL I MEMORANDA 42 TABLE 9.1 I SUMMARY OF MAJOR DELIVERABLES 46 I LIST OF APPENDICES I APPENDIX A CURRICULA VITAE -KEY PROJECT PERSONNEL 11 APPENDIX B DATA MANAGEMENT PLAN o· I LIST OF ASSOCIATED SUB MITT ALS I SUBMITTAL A RD HEAL TH AND SAFETY PLAN SUBMITTAL B SAMPLING AND ANALYSIS PLAN •-SUBMITTAL C TREAT ABILITY STUDY WORK PLAN I. I I I CDiliESTOGA-ROVERS 2. ASSOCIAF:S I I I ,, I I .J ,I -I I I I I I I I I D u 1.0 INTRODUCTION This report presents the Remedial Design (RD) Work Plan for the Jadco-Hughes Site (Site). 1.1 GENERAL The Site is located in Gaston County, North Carolina, approximately 15 miles west of Charlotte. Figure 1. 1 shows the location of the Site and Figure 1.2 presents historical features of the Site. The 6-acre Site is a former solvent reclamation and waste storage facility which had two operators: C.A. Hughes, Inc. (1971 to 1975); and Jadco, Inc. (1975). The Site was closed in 1975 and a North Carolina (State) ordered cleanup was completed by 1983. After closure of the Site, several reconnaissance evaluations were conducted by the United States Environmental Protection Agency (USEP A) and the State which identified residual contamination. The Site was subsequently placed on the National Priorities List (NPL) in May 1986. Later in 1986, an Administrative Order on Consent was entered'into between USEPA and a group of companies identified as potentially responsible parties (PRPs) who formed the Jadco-Hughes Steering Committee (Committee). Conestoga-Rovers & Associates (CRA) was retained by the Committee to conduct a Remedial Investigation and Feasibility Study (RI and FS) and Superfund Risk Assessment (SRA). 1 I I I I I I I I I I I I I I I I I I I o' 1000' ~-~, '/. /1:r / .. · . ) ' ' . ,., . --~"'?.··• .... ~ ... -··, · \\::·: ::••· !o·· · !\\L.,· .... ~--------'.TR[BUTA -, ~ ·"'·"""·"' -N ::::-:A_.- " --;:::... ..:;._ b./ --"~- -....~ ,,..,~S.ubsta ,,_· __ 1 • • -f I' ,' :~ ~ .', / ' 41,r., ljl. .· ,' I 1!11 lo, :' /' I 1CJ ' .· ! ,' :;--·,·~- : ,,· e ;, . al" 8 I ~ .':2) / --...;\_~ ''- ;.i_r-c--.c~,.,...,_ -·;.--~ . ' . ,./(0:'~---:--. : . 'I -. .:.·..,..:; v .--. ·::. / ,s-➔ / j , if 11 0 ,, Ch \ L l">.t-: __ , _/ I •/_<: _/ :;;;·., . -->q, ....::::::-. b . ·. ~~-:;:3.--:- .•,..,~·.>,r, .-.'--""-/,/ _,, '..[\/,,...,_· I SOURCE: USGS QUADRANGLE MAP, MOUNT HOU. Y, N.C. CRA 3669-11 /09 /91-6-0 . . ,_ / ---.__.. -· I , , ,ii ' -(I ( I § figure 1.1 SITE LOCATION JADCO-HUGHES SITE Gaston County, NC --- -···-......-~!,'~~I ~· I CRA J661i-11/09/V1-!l-0 -.. --- ---.. --- CASON STREET S.R. 2035 ( / I I C '''"" 1. COMPOSITE AREAS SHOWN ARE BASED ON AERIAL PHOTOGRAPHS DATED FEBRUARY 12, 1968, MARot 17, 1969, AND NOVEMBER 18. FROM 11-iE USEPA DOCUMENT .SITE ANALYSIS -JADCO-HUGHES, NORTH BElMONT, NORTH CAROLINA•, DAITD DECEMBER 19B5. 4,0001:-'L llORA(l[ TNIICS 1975 2 THE LOCATIONS AND LIMITS OF AU. FEA lURES SHO'M'i ARE APPROXIMATE. J. LOCA TlON OF" T AHKS AND EOUIPMOH BASED Otl SITE MAP F"ROI.I GASTON COUNTY OSH nus (UUOA TEO). LEGEND PROPERTY UNE LIGHT STANDARD COMPOSJif A.BEAS ~ POSSIBL£ ~OUNOSTAINS AND/OR L'.:::.3 ST ANDING UOUIOS h,:::c::aj oRuM AND/OR OPEN srORAGE AREAS c:J DEBRIS STORAGE AND/OR Fll.L AREAS ORUM AND/OR OPEN STORAGE AREAS NOVEMBER 18, 1975 --11!!!!!9 0 ,o 100n figure 1.2 HISTORICAL Sl1E FEATURES JADCO-HUGHES SITE Goston County, NC I I I I I I I I I I I I I I I I I I I Based on soil, groundwater, surface water and sediment samples collected from locations shown on Figure 1.3, the RI delineated Site contamination which included: • polychlorinated biphenyls (PCBs) contamination of approximately 435 cubic yards (C.Y.) of surface soil; • contamination of approximately 6,000 C.Y. of subsurface soil principally with volatile organic compounds (VOCs) and base/neutral and acid extractable compounds (BNAs); • contamination of Site groundwater by VOCs and BNAs; and • contamination of surface water in Tributary B, principally by VOCs. The SRA concluded that the groundwater and surface water pathways at the Site presented an unacceptable current and future risks to human health and to the environment. During the RI and FS, an Interim Remedial Measure (IRM) was completed between September and December 1990 which resulted in the excavation and disposal of PCB contaminated soils in the southeast swale area. Approximately 900 C.Y. of soils were excavated and disposed of off-Site by landfilling at the Chemical Waste Management Inc. landfill in Emelle, Alabama. Upon completion of the RI and FS, USEP A issued a Record of Decision (ROD) on September 27, 1990. The final remedy selected by USEP A in the ROD requires the following actions: 2 I I LEGEND I I I I I I I I I I I I I I I ------PROPERTY LINE eMW9S MONITORING WELL ePZ4 PIEZOMETER WELL aPWl PUMP WELL 111TP9 TEST PIT 111""' 9 OBSERVATION PIT ■BH11 BOREHOLE t:, SS29 SEDIMENT SAMPLE gSf3 STREAM FLOW MEASUREMENT LOCATION I I I I I I I / I I I ~~~~-~~~~~~~~~~-=~~~~~V 11 -=====~ -S:. _-~---------=--------' ,' _ c"AsoN sm~= rs,;;;~:":0:5)-\ .. ~----~--~-----..:_ ------~ ~=-t==JL __ _ \ I! 8 \ l-------l(-------s--::-~-----J<--==----l(·-~'~\ SS128_1 \ eMW'1 650'± CRA ' 3669-5/09/91-6-0 (P-03) \ , II !2:" BH1 ■ 1 I • PZ4 PZS e ■ 8H3 4, 1 , '-"•• ■ 8H10 / / ■ BH2 . I '. ..JI II) MW3i) / t PZ7. . ...J \ /f,", Ill W2 Ill ;;A MW3S,, □ □ / / TPSIII 111DP31 111 OP32 I 1 '.. '-Ill 1 1 OP33 \' 8H11 ■ ■BH? 1 1 ■BH15 Ill Ill\ 1 ■BH12 ' I\ RAISED CONCRETE PADS 1 /■BH6 OP35111 ■BH4 \ rn, 1 1 1 1 1 Ill OP15 OP19tzl OP29 PZ5 •■8H16 \ \ ,, t MW7S TPS 111 111 MWSS '1 ',', 0 ■""9 .■BHB ,' / 11111\a"W?D 111TP12 BH~3 111 □P34 IMwso llrwa M BH5■aBH14 ,J,,-..,.-r-....-vv'v-rrr' I -- -7 {7 TP4 '\\' Ill OPlJ III OP14 1 BH21 ■ L -J i!a BH17 IIIOP30 ,\ Q Ill OP17 OP1B111 D L - 7 ¥ • PZ3 \' f1JMW4D DEBRIS 1 ------------------------- .. r-·--::,.S:l,.._~~---OP16 MW4S • PZ2e 1 -···-···-···-· ·--··· ✓ \' - - - - - - --•--- - -------~ .! ~~B~ g1!:~..! I ,,,,,u.._,,..,, =rr-==><>..,--,-rvv .... ---.....,..,,..,,.,,,~vv--TRIBUTARY ·s· . -.. -... ~. ~, TP11111 lPZi OP36JII --iziOP37--.---~-=-:-:-P- • MWBS PW1 OP21 8H20 I SS10 BH25■ MW2D e Ill e MW10D l sr7// MW2S e 1 ' MW6S 1 Ill OP20 ■ BH22 Ill OP271 SS29t:, SS>Ot:, SS31A ■Ill ~2:S32 mw;eH2D fj, SS33 Ill 6, SS34 DI, 5S35 Mwsol ■' 8Ht8 1 I ■ BH24 BH23 OP24 OP25 OP26 ss41 D,. S542 --ss MW'! me l:l. ss21 .. _ ......--SS44 ~ SS+e 6. ssso t::,. ssst SPRING S57 ss2a-fl/ f / LL TP10 It:, -SS37:.,!;.:,+.,.;"Y-. SS36 t:, SS48 s/t:, t:, SS47 =• 8 M'N9S t:, SS45 \ MW12S • I::. • S516 ~~MWlZD ~v>-.>:,,·. .,,,,. .. ~ S· SS17 SS1B 1/6 mi. to 5S17 1/3 ml. to 5518 I RI I INSTALLATIONS AND figure 1.3 SAMPLING LOCATIONS JADCO-HUGHES SITE Goston County, NC I I I I I I I I I I I I I I I I I I I 2) 3) 4) 5) Provision of deed and access restrictions; Treatment of soils in the former landfill and approximately 500 C.Y. of soil from the Former Operations Area which are to be consolidated into the former landfill. The soils shall be treated by a combination of soil vapor extraction (SVE) and soil flushing. The SVE system will be constructed and operated until data indicate that no further VOCs can practicably be removed. The soil flushing system will be operated as an integral component of the groundwater collection and treatment system; Construction of a groundwater extraction system within the Site boundaries including four extraction wells, in areas of elevated contaminant levels, -am:r-a subsurface drainage tile trench to collect contaminated groundwater; ltd tolJI\Jv.,dcV cliec.h"irl\ 5uft a·- ~0-p.,.., i o,ntMJf/)s o~ 5/i(-(,l,.;_J Cv ve, Construction of an on-Site treatment system. The system would consist of aeration and equalization tanks. The air vented from the aeration tank would be treated by carbon adsorption. The effluent from the treatment system would be pumped to the nearest City of Belmont sanitary sewer system manhole for subsequent treatment at the Belmont publicly owned treatment works (POTW); Excavation and repair of the damaged sections of the Site culvert followed by slip-lining of the culvert with butt-welded polyethylene pipe; 3 I I I I I I I I I I I I I I I I I I I 6) Construction of a gravity drainage line to carry uncontaminated groundwater from the spring discharge to the Tributary B north of the Former Operations Area; 7) Construction of a surface water diversion consisting of a Site spillway; 8) Provision of long-term operation and maintenance including monitoring of system controls; and 9) Implementation of a monitoring program to assess the performance of groundwater extraction, aeration and discharge system components. Periodic monitoring of the groundwater will be performed to assure that the remedy is working. Remediation required by the ROD are limited to remedial activities within the Site boundaries. Following issuance of the ROD by USEP A, the Committee was issued with a judicial order under Section 106 of the Comprehensive Environmental Response, Compensation and Liability Act (the 106 Order) on June 19, 1991. Accompanying the 106 Order was USEPA's Scope of Work (SOW) for the Remedial Design/Remedial Action (RD/RA) for the final remedy. CRA has been retained to prepare the RD/RA Work Plans and perform all associated design activities. RO is generally defined as those activities to be undertaken by the PRPs to develop the final plans and specifications, general 4 I I I I I I I I I I I I I I I I I I _I provisions and specific requirements necessary to translate the ROD and SOW into the remedy to be constructed under the RA phase. RA is generally the implementation phase of site remediation or actual construction of the remedy, including necessary operation and maintenance and performance monitoring. The RA is based on the RD to achieve the remediation goals specified in the ROD. As specified in the SOW, the final RD and RA Work Plans will include project plans as outlined below: Remedial Design 1) RD Work Plan • Statement of Site Concerns; • Background Summary; • Detailed Description of Tasks to be Performed; • RD Schedule; • Project Management Plans; and • Community Support Plans. 2) Health and Safety Plan 3) Sampling and Analysis Plan • Field Sampling and Analysis Plan (FSAP); and • Quality Assurance Project Plan (QAPP). 4) Treatability Study Work Plan(s) 5 I I I I I I I I I I I I I I I I I I I • Treatability Study Sampling and Analysis Plan; and • Treatability Study Health and Safety Plan. Remedial Action 1) RA Work Plan • Detailed Description of Tasks to Be Performed; • RA Schedule; • Project Management Plan; • Community Relations Support; and • Strategy of Settling Defendants for Delivering Project. 2) Construction Management Plan 3) Construction Quality Assurance Plan 4) Construction Health and Safety/Contingency Plan This report presents the RD Work Plan for the Jadco-Hughes Site and includes each of the required elements as outlined above for the RD Work Plan. The RD work plan is organized into major sections and Appendices as follows: • Section 2.0 provides a detailed Site description including Site location, Site background, contamination profiles; 6 I I I I I I I I I I I I I I I I I I I • • • • • • • • Section 3.0 presents the remedial objectives for the Site; Section 4.0 presents a project organization and management plan; Section 5.0 introduces other required RD project plans including a Health and Safety Plan, a Sampling and Analysis Plan and a Treatability Study Work Plan; Section 6.0 presents predesign/remedial design activities; Section 7.0 presents reports and documentation to be submitted; Section 8.0 presents activities to be undertaken to provide community relations support; and Section 9.0 presents the RD/RA schedule . Section 10.0 presents a list of references . 7 I I I I I I I I I I I I I I I I I I I 2.0 SITE DESCRIPTION 2.1 BACKGROUND Background for the Site is summarized herein based on the detailed presentation of the RI and FS report(s) (CRA, July 1990). The Site derives its name from two previous operators of the former industrial facility which was operated from 1971 to 1975 as a solvent reclamation/ chemical waste storage facility by C.A. Hughes Inc. The facility was subsequently leased to Jadco Inc. who operated the Site until operations were suspended and eventually terminated in 1975 by a temporary restraining order and judgement registered by the State. The Site was used for reclaiming spent solvents for resale using on-Site distillation apparatus. In addition, the facility was used for the open storage of drummed materials consisting of numerous waste chemicals and chemical waste sludges. Sludge was reported to have been generated as distillation bottoms which were stored on Site. The former drum storage areas and the Former Operation Area are shown on Figure 1.2. Subsequent to the cessation of Site activities, several environmental studies and remedial efforts were conducted at the Site. Most notable was the State ordered cleanup which was conducted in two phases from 1975 to 1978 and from 1981 to 1983. This cleanup included the excavation of two in-ground pits which were used for decanting solvents. Under the State ordered cleanup, on-Site contaminated surface soil was 8 I I I I I I I I I I I I I I I I I I I consolidated and covered in an on-Site landfill located in the southwest corner of the Site in 1978. As previously noted, the Site was placed on NPL in October 1984. CRA was retained by the Committee to perform the RI and the FS with oversight provided by USEP A. The Remedial Investigation was completed in two phases and included the excavation of 12 test pits, 25 observation pits, 26 boreholes, the installation of 29 monitoring wells, as well as the collection and analyses of 184 water samples and 244 soil samples (Figure 1.3). The Remedial Investigation achieved its objective to identify and characterize the nature and extent of contamination present in surface water, sediment, soil and groundwater. Drainage from the Site flows to tributaries of Fites Creek and ultimately to the Catawba River approximately 2.5 miles downstream. Figure 2.1 illustrates the drainage pattern of the Site and downstream watercourses. The Site is predominantly underlain by a unit of weathered granite known as saprolite to a depth of 95 feet below ground surface. Lenses of fluvial deposits of clay, silt and sand lie upon this unit near ground surface. Granite bedrock underlies the saprolite and is found at depths below 95 feet. Figure 2.2 illustrates the geology underlying the Site by 9 ----- - - - WiEllil. - - - - -PROPERTY LINE ---.so GROUND CONTOUR (fl. AMSL) + SURFACE WATER DRAINAGE ... ... ... .,, "' ,,. .. CRA 3&6a-11/oa/a1-e-o - --- - I ~ -- 0 ~ 100N I ---·- .., figure 2.1 SITE DRAINAGE PATTERN JADCO-HUGHES SITE Gaston County, NC - --- A • , oi ~ 680.0 670.0 660.0 g 650.0 ~ ~ 640.0 630.0 620.0 ,,.,,., ,~- --------- 0 - - - - - -- w z 3 I: i ~ f --------------------------------------------- CONCRETE CULVERT/' SAPROLITE UNIT JOO 600 900 LEGEND HORIZONTAL DISTANCE (FITT) CRA ,~-1 .. ...,. STATIC WATER LE\.£1. (9/18/89) MONITORING Yl£U. SCREEN LOCATION GROUND SURFACE STRA TIGRAPHlC DESCRIPTION JHi-11/09/91-B-0 -- 1200 -- ---- Ut.U 131.1.1 1500 A' • ...., 1800 figure 2.2 GEOLOGIC CROSS-SECTION A-A' JADCO-HUGHES SITE Gaston County, NC I I I I I I I I I I I I I I I I I I I means of cross-section A-A' which transects the Site. The section location is shown on Figure 2.1. A water table is found at a depth of approximately 9 feet below ground surface. Groundwater within the saprolite migrates north at a rate of approximately 8 to 14 ft/year and is strongly influenced by groundwater discharge into the on-Site culvert and tributaries to Fites Creek. Figure 2.3 presents the groundwater flow patterns in the shallow saprolite (approximately 15 feet below ground surface). Figure 2.4 presents the groundwater flow patterns in the deep saprolite (approximately 45 feet below ground surface). The extent of soil contamination on the Site was characterized by the presence of VOCs, BNAs, and to lesser extent, by some PCBs and metals. Figures 2.5 and 2.6 present contaminant concentrations in soil on Site. The former landfill was confirmed to be a significant area of soil contamination, characterized by VOCs, BNAs and to a lesser extent by PCBs and metals. The contaminated soil occupies an approximate geologic volume of 5,500 C.Y. Concentrations in the soil based on the average of detections are 586 mg/kg VOCs, 212 mg/kg BNAs and 20 mg/kg PCBs. The Former Operations Area, the former south decant pit and the former north decant pit were found to be less significant areas of soil contamination characterized mainly by the presence of VOCs. 10 ---- CRA JU9-11/0Q/IU-8-0 ---- ------PROPERTY LINE t.40NITORING WEU. Plf'.ZOIAETER WEU •P., PU ... P WEU. - ----650 GROUNDWAT[R CONTOUR (FT. At.451..) GROUNDW.-.TER FLOW DIRECTION GROUNDWATER El.EVATION (SEPT. 18, 1989) - ;= r;~= I I ~, ' {6$4.7J) ' -------· --------- 0 50 100tt figure 2.3 SHALLOW GROUNDWATER FLOW PATTERNS JADCO-HUGHES SITE Gaston County, NC -- {Na.JI) -~ CRA - JSaa-11/09/91-e-o - - - ---650 I I =cC> - - PROPERTY LINE MONITORING Mli.. PUMP 'M':U. - GROUNDWATER CON TOUR (FT. AMSL) GROUNDWAT[R flOW DIRECTION GROUNDWATER ELEVATION (SEPT. 16, 1989) ----- -- - -- D 50 lDDtt figure 2.4 DEEP GROUNDWATER FLOW PATTERNS JADCO-HUGHES SITE Goston County, NC I I LEGEND I I I I I I I I I I I I I I I I I I - ---- -PROPERTY UNE eMW9S 1111?9 MONITORING WELL TEST PIT BOREHOLE {Q206) mg/kg TOTAL voe APPROXIMATE UMIT OF LANDFILL I I I I I f I 0 50 100ft -======~--'----'\""7~-;-,;:---,ai-b=----l!~=---l<---------lE-----+-----~ e MV.1 Q0/5) 650'± CAA \ ~' l~I~ BH1 ■ ~ I ■8H3 '\' : , '-''·• ■BH10 (0.018) 1 / ■BH2 (ao,o) t , .,flj(] "0.206 1 I , ''2011'' 'v,-'' , Ill lP3 {aot) MW3D lPS 111 '' , -' \ 11' , 111 lP2 {1119.0) ew,s#{aot) □ □ ,' ,' {a020) I ' '\ (264.9) I / \ 8H11 ■ ■8H7 I I ■BH15---------BH12 ' !El \ \ (926..J) {0.01J) RAISED CONCRETE PADS / / {NO) -~-(O.a \ ~t~A / / (0.014} (__ BH16 \ \ ...... _-9.IIJ:i!~:"'""---~ 1 I tr.tW7S TP6 Ill ~ ■ · ■ \~ '\', 0 aoo.e>' ,BHB{a57) , ,' lll~(QOl8) Ill' 12 {, " , lP8 ' , MW7D BH5■ {a017) BH13 ND, , \ {a652) r --· ---, n lP<{l.513) {13.03} ■ ',!JJJ ■BH4 {ao12) M'NSS {0.019) a MWSD I I \ \ 1 BH21 L-J IIBH17 \ Q {a23.3) ■ , {a.JS?) TRisurARy •8• , o , , _ ... _ \, f/J MW4D (a.034) DEBRIS 1 -----------------------· · · -· · ·-..... .. _ ~ · --.:..:~~J.~\, ------_________ -___ M~45 _ 35•• CONCRETE CULvERT \ --· · · -· · · -· · · -· · · -TRisurARY ~-· · · -· · · - I ) I \.. TP11 ----------------------------~... t • ~ •• _. _ , ' {a032)111 ■ r --- 0 SPRING FORMER SOUTH DECANT PIT 8H20 I {QOOJ) I {266) 1 MW6S awsoll ■' {a21') BHf!! 1 {a I I {aoot)' FORMER NORTH DECANT PIT FORMER OPERATIONS AREA figure 2.5 TOTAL voe CONCENTRATIONS IN SUBSURFACE SOIL JADCO-HUGHES SITE Gaston County, NC 3669-12 09/91-6-0 P-04 I I I I I I a I I I I I I I I I I LEGEND ------PROPERTY UNE eMW9S MONITORING WELL ~ 111TP9 TEST PIT ■BH11 BOREHOLE 0 50 100ft (1.58} mg/kg TOTAL BNA I I ~ I _______ J_ -------\--- : : ~-'t I I ~ I I ~ I I . -'-I I I LANDFILL I I "-vv-.Jcfa._,_.,...,__,,_.,._...,vv..,.,...__,_____,...,..__._,._,.--v...,.,._.\.A,_-\,v-->JJ.=--,...)'--' I ' ------//_~sew STREET _ (SIDEROAD 2035) ---,-----------------------,~-=t~_lL __ _ \ ' ' \ \ Ill} f ----------\ ------><-------><------><---;;=--------;, \, //Q:' ' BH1 ■ I I 11BH3 , '-"·• f ■ BH10 ) (0.018) I / ■ BH2 (0.560) '-t~~ ( (1.68} TP2 Ill TP3 (UH) MW.30 ,/_ / TPS 111 (a690) ,t--' Ill (3.16.5) ('19.•J ew,s#(0.51) □ [7 , , (0.20) I;\\ l . ~;,i;,, ,, -~~,;'; _J /~/ ■m;J--------:_::;>-aH12 ■BH4 TPi \ \ RAISED CONCRETE PADS , ~ (f.S?O} \ 0.51~A ...._ -/ / / (1.000) BH\6 \ ......... ___ 1 I MW7S TP6111 ■ a77) MWSS \, 0 --------111 aHB(o.090J , ' "9(0.sooJ 111 12 11 (o.?ooJlewso ~ \, im-TPa ' ,' :i MW70 BHS■ (0.<2) BH\3(0.19) r"~r-,...,-..,.-,,y-y-v--<" \ (0.,10) r ---7 n (0.410) (0.7) '\, 1 BH21 ■ L -J II BH17 \ I I TRIBUTARY •8, ---·--. \ Q D (NO) ' (NO) \, # MW40 (0.204) OEBRIS 1 1r;==lr_=-=-=-===:-:-=-:,;,-::...:~= .... ::l!:-::.~=-::= .,,C::-~c~~:z-::-~y=-:-:=-:...=-E~= y==-~~= ~~-:==---=· ~-~ -'=-~~~-~==:,;;:;d,J__,_"--'U..,=~ ··-...... ___ ~----'..,ll.-~~ MW4S 36• 1 II __ ✓ -,,~-----------------;-~ --- ---- -_! ~':N~R~ -~~.!:~~-----------..:1--:,-.. - . -..- CRA 3669-12/09/91-6-0 (P-05) I ) I "-.' (0.85) Ill ■ r --- BH20 I {NO) 0 SPRING SOUT11 DECANT PIT I I I I ((O.J) (0.25) 1 MW6S MW60. 111 I (0.34) BHry ~\ TP7 (0.65~ FORMER NORT11 DECANT PIT FORMER OPERATIONS AREA figure 2.6 TOTAL BNA CONCENTRATIONS IN SUBSURFACE SOIL JADCO-HUGHES SITE Gaston County, NC I I I I I I I I I I I I I I I I I I I Areas of ~urface soil contamination were identified in the southeast swale area of the Site. During the RI, a volume of approximately ' ' 435 C.Y. of soil having PCB concentrations above 10 mg/kg was delineated. ' This soil was removed and landfilled off-Site in late 1990. Approximately I 900 C.Y. of soil was excavated and disposed off-Site. The excavations were then backfilled and regraded, covered with topsoil and seeded. The areas excavated are shown on Figure 2.7. The IRM included the construction of an 8 foot high chain link fence 4round the perimeter of the Site. On-Site groundwater contamination is present and is I characterized primarily by voes, BNAs and to a lesser extent by some metals. Figures 2.8 through 2.11 present voe and BNA concentrations in the shallow and deep aquifers. As shown, there are five areas of elevated contaminant ' concentration in groundwater identified as: • MW2D • MW3S • MW8S • MW6S • MWSD Analytic~l data from the analyses of groundwater samples collected from monitoring \\!'ells in the area immediately surrounding the Site, and residential wells 100 feet to 1,000 feet downgradient of the Site, did not exhibit water quality exc~ding drinking water standards or criteria. Low levels of Voes (below 10 µg/L) in surface water were identified and characterized. This contamination is attributed to discharge of contaminated groundwater to the on-Site culvert (which lies within the water table) and to tributari~s of Fites Creek. This voe contamination 11 cc,,,,~SY'JGt-'.-FIOVERS r, ASSOCIAT!cS --- - CRA Jee9-11/09/91-e-o ---- WiElW. - - -PROPERTY LINE PERMANENT FENCE 1•~~-n SCXl EXCAVATION AREAS I ' I I I I i - ..... 0 -- I L--- --- ---- ~ 0 50 100ft M.AJN GA TE -_-_-- - -- - - --,~ Li_ ACCESS GAlE ,, figure 2. 7 IRM EXCAVATION AREAS JADCO-HUGHES SITE Gaston County, NC ---- CRA 36611-11/09/lill-6-0 --- ------PROPERTY,UN£ ..... (40.7) MONITOfUNG 'AEll TOTAL VOC CONCENTRATION AT VeEll. SITE (u9/l) (SAMPUNG ROUND J) (ND • NOT DElECTID) --/00--TOTAL VOC CQrila>ITRATION CONTOUR (u;/l) ) I ---- .til21E;_ MAXIMUM VALUES SHO~. -- -.. --- 0 ,0 100ft (CL7J) figure 2.8 TOTAL voe CONCENlRAllONS SHALLOW AQUIFER JADCO-HUGHES SITE Gaston County, NC ---- C!IA 38159-11/09/91-15-0 --- - I I WiEli.D. - - --- - PROPERTY LINE ...... (U..5) MONITORING WEU TOTAL BNA CONCENTRATION AT 'flEl..1.. SHE (u;/L) (SAMPUNG ROUND J) (NO • NOT DETECTED) --100--TOTAL BHA CONCENTRATION CONTOOR (uo/L) .. -- l:illlE;. MAXIMUM VALU[S SHOVIN. (3.1) ..... ---- 0 50 100ft - (1.4) ..,,, • figure 2.9 TOTAL BNA CONCENTRATIONS SHALLOW AQUIFER JADCO-HUGHES SITE Gaston County, NC --- • CRA 3669-11/09/91-6-0 -- - - -- ------PROPERTY LINE MONITORING 'NEU.. .... PUMP VIEU. TOTAL voe CONCENIATION ~JAM~NflfoJ~~ tNo • NOT OETrC ) (0.74) ) I --/00--TOTAL VOC CONC£NTRATION CONTOUR (ug/1..) .~11l'110 0 (2.1) - -- - .tilllE,;.. MAXIMUM VALUES SHO"'111i.) - ----- 0 so 100ft -;_ figure 2.10 TOTAL voe CONCENlRATIONS -DEEP AQUIFER JADCO-HUGHES SITE Goston County, NC -- (2.1) .., • Cl!IA - -~~.!_ J669-11/0ll/lil1-6-0 ---- ---- ··~ ... ._,,-· ) I l.EliWl2 ------PROPERTY UNE ..... (:t.1) MONITORING WEll PUMP WEU TOTAL BNA CONCENiA TION ~JAM~Jillrc,JN~ tNo • NOT DETEC ) --/00-TOTAL SHA CCJ,ICEHTRATION CONTOUR (u9/l) eWWIID 0 {1.5) _, tilllE;_ MAXJIAUM VALUES SHOWN.) -- - --.. 0 50 100ft figure 2.11 TOTAL BNA CONCENTRATIONS -DEEP AQUIFER JADCO-HUGHES SITE Caston County. NC I I I I I I I I I I I I I I I I I I g dissipates to levels below drinking water standards or criteria, immediately downstream of the Site. 2.2 CONTAMINATION PROFILES The following paragraphs present contamination profile for the Former Operation Area, the former landfill and groundwater at the Site, as developed in the FS. A volume of contaminated soil within the former landfill was estimated to be approximately 5,500 C.Y. based on the physical size of the former landfill and the amount of soil above the water table. A volume of contaminated soil associated with the Former Operations Area was estimated to be 500 C.Y. which represents contaminated soil adjacent to the eastern edge of the concrete pad. Table 2.1 provides a contamination profile for soil and is ' based on soil samples collected from the former landfill. A review of the RI groundwater database indicated that ' the majority of on-Site shallo'Y groundwater and two deep locations (MW2D and MWSD) exceed the remedial objectives presented in the ROD and SOW. The data from analyses of samples collected from the remainder of the RI deep monitoring wells indicated that the remedial objectives were not exceeded in these wells. 12 <: _1,h~ fOC!-1-ROVEFlS C tlSSOCit-.TES I I I I I E I I I I I I I I 0 u I E I Page 1 of 2 TABLE2.l CONTAMINATION PROFILE-FORMER LANDFILL SUBSURFACE SOILS JADCO-HUGHES RD/RA Compound voes <wgfkg/ acetone 2-butanone 1, 1-dichloroethane 1,2-dichloroethane ethylbenzene methylene chloride 4-methyl-2-pentanone 1, 1,2,2-tetrachloroethane tetrachloroethane toluene 1, 1,1-trichloroethane 1, 1,2-trichloroethane trichloroethene total xylenes BNAs (mg/kg/ acenaphthene anthracene benzo(a)pyrene benzo(b)fluoranthene benzo(g,h,i)perylene benzo(k)fluoranthene benzoic acid bis(2-chloroethyl)ether bis(2-ethy lhexyl )phthalate butylbentzylphthalate 2-chlorophenol chrysene 1,2-dichlorobenzene 1,4-dichlorobenzene di-n-butylphthalate di-n-octyl phthalate fluoranthene fluorene indeno(l,2,3-<:d)pyrene 2-methylnaphthalene 2-methylphenol 4-methylphenol naphthalene phenanthrene phenol pyrene 1,2,4-trichlorobenzene Range of Detects Low High 0.006 21 0.0027 1.6 8.4 0.0019 10:000 0.0095 0.0016 0.0018 0.014 0.0028 0.0075 0.0013 0.17 : 1 :3.6 2.7 ' 1.4 2.2 ·13 1.2 0.09 12 :14 0,27 1.4 0.57 2.4 4.6 0.48 ' 0)9 2.0 0.11 2.5 .1 1.8 3.4 8.2 0.48 0.18 72 170 0.0027 9.3 65 11.0 19.000 0.0095 12 620 0.014 0.0028 3.5 320 0.98 1 3.6 2.7 1.4 2.2 35 1.7 260 8.2 90 3.4 2.1 0.98 8.4 6.1 5.4 0.69 2.0 2.9 9.1 2.5 6.3 3.4 24.0 5.6 86.0 Representative Concentration (1) 9.9 72 0.0027 5.7 36.4 3.1 14.5 0.0095 4.7 303.6 0.014 0.0028 1.8 134.6 0.58 1.0 3.6 2.7 1.4 2.2 19.4 1.5 53.8 5.0 42.4 1.8 1.7 0.78 3.4 5.4 2.9 0.44 2.0 1.1 5.1 1.9 3.6 3.4 16.0 3.0 24.2 I I I I I I I I I I I I I I I I I I I Page2 of 2 TABLE 2.1 I CONTAMINATION PROFILE· FORMER LANDFILL SUBSURFACE SOILS JAD~O-HUGHES RD/RA Cumpound PesticideslPCBs (mg/kg) PCB Aroclor 1248 Metals and Total (l/1/nide Im glkg/ Aluminum Antimony Arsenic Barium Beryllium Cadmium Calcium Chromium Cobalt Copper Iron Lead Magnesium Manganese Mercury Nickel Potassium Sodium Thallium Vanadium Zinc Total Cyanide Notes: Range of Detects Lqw High 11.0 36.0 1-,570 27,600 16.1 47.5 ~0.9 47.0 27.6 268 0.75 1.7 1.0 4.0 1,177 16,400 5.8 190 10 30.6 35.4 1,010 17,000 63,690 5.1 596 1,426 8,900 110 990 0.06 0.18 5.6 60 130.4 885 227.3 757 0.08 0.11 · 37 290 23.6 175 4.0 8.9 • Based on soil data for the former landfill. • VOCs = volatile organic compounds. • BNAs = base/neutral and acid extractable compounds. Representative Concentration (1) 20.3 13,856 30.9 39.0 102 1.2 2.5 4,031 66 20 219 36,354 301 4,087 487 0.11 21 358 530 0.09 122 71 6.8 • The above profile is based on samples collected from the following locations: BH(MW-3), BH-7, BH-8, BH-9, BH-10, BH-11, TP-2 ,TP-3. (1) Mean concentration calculated by an arithmetic average of detections. ! t,.1 I I I I I I I I I I I I I I I I I I I Table 2.2 presents the contamination profile for on-Site groundwater. 2.3 SPECIFIC TARGETS OF REMEDIATION Site features which pose a potential current and future ' risk to human health and the environment include the following: • subsurface soils located in the former landfill and Former Operations Area which are contaminated with certain VOCs and BNAs; • surface water in Tributary: B which is contaminated principally by VOCs through the discharge of groundwater to the tributary; and • Site groundwater which is contaminated with VOCs and BNAs. Risks to h,uman health and the environment are possible due to transportation of conta,minants off-Site. The selected remedy mitigates transport of Site contaminan~ thereby minimizing the potential risk to human health and the environment. 13 ('c_>;,!E3 iOG?, ROVERS ~ ASSOCIATES I I I I I I I I I I I I I I I I I I Page 1 of 2 TABLE2.2 CONTAMINATION PROFILE-ON-SITE GROUNDWATER JADCO-HUGHES RD/RA Compound voes <u~tLJ acetone benzene 2-butanone carbon-disulfide carbon· tetrachloride chlorobenzene chloroethane chloroform 1, 1-dichloroethane 1,2-dichloroethane 1, 1-dichloroethene 1,2-dichloroethene ( total) 1,2-dichloropropane ethylbenzene 2-hexanone methylene chloride 4-methyl-2-pentanone 1, 1,2,2-tetrachloroethane tetrachloroethane toluene 1, 1, 1-trichloroethane 1, 1,2-trichloroethane trichloroethene vinyl-chloride total xylenes BNAs lu~ILJ benzoic acid bis (2-chloroethyl) ether bis (2-chloroisopropyl) ether bis (2-ethylhexyl) phthalate 1,2-dichlorobenzene 1,3-dichlorobenzene 1,4-dichlorobenzene di-n-bu typhthala te di-n-octyl phthalate 2-methylphenol 4-methylphenol naphthalene phenol 1,2,4-trichorobenzene Range of Detects Low High 6.6 0.25 50,249 1.8 0.28 0.3~ 0.47 0.63 0.76 0.44 0.16, 1.6 0.29 440 0.49 0.55 3,100 0.26 0.76' 0.36' 0.23 0.70, 0.45 0.60 0.30• 550 4.3 11 1.3 17 1.7 3.6 2.3 1.9' 26 74 8.1 , 28 3.7 140,563 1,285 64,000 1.8 26,118 340 15 103,589 110 5,531 839 15,000 0.34 1,268 1,800 10,981 10,277 0.26 13 98,808 672 2.8 580 68,000 5,402 4,800 29,000 11 270 89 89 590 680 1.9 26 74 8.1 1,700 3,000 Representative Concentration 30,524 277 57,124 1.8 7,153 96 7.7 17,083 22 986 141 2,561 0.32 749 900 1,750 6,688 0.26 6.2 17,359 168 1.6 69 11,451 1,376 2,675 4,623 11 41 56 19 121 196 1.9 26 74 8.1 1,109 606 I I I I I I I I I I I I I I I I I I I TABLE2.2 CONTAMINATION-PROFILE-ON-SITE GROUNDWATER JADCO-HUGHES RD/RA ' Page2 of 2 Range of Detects Compound Low High Representative Concentration Metals and Cyanide /mg/LJ Aluminum Antimony Arsenic Barium Beryllium Cadmium Calcium Chromium Cobalt Copper Iron Lead Magnesium Ma,nganese Nickel Potassium Silver Sod_ium Thallium Vanadium Zinc __ Cyanide;.• Notes: Pesticides/PCBs were not detected, ND -Not detected, 0-47 o.o5i 0,005 0,046 0,001 0,006 39 0,0093 0,00~ 0,022 4-2 0,0023 16 0-24 0,031 6,7 0,011 9,6 0.001I 0,013 0,022 ND 130 35 0-39 0-22 0,09 0,04 056 0,2 0,001 0,001 0,008 0,0067 470 136 0-76 0,14 0,14 0,068 OA 0,17 200 55 0,037 0,0095 170 63 56 8,9 058 0,15 11 7,7 0,01 O.Dl 36 18 0,001 0,001 0-38 0,14 0-49 0,18 ND ND i On-Site Groundwater is groundwater within_ the Site boundaries represented by wells in which detections above MCLs were recorded: MW2S, MW2D, MW3S, MW4S, MWSD, MW6S, MW7S, MW8S, ! v \ tVv1 cu;-•~:::TOGA-R\)I/EH3 e, ASSOCIATES I I I I I I I I I I I I I I I I I a u 3.0 REMEDIAL OBJECTIVES 3.1 GENERAL The objectives of the final remedy are to: ' 1) mitigate impact of the i°n-Site contamination to groundwater by I remediating the source of contaminants in the former landfill and I consolidated soils from the Former Operations Area; 2) provide adequate control of VOC emissions to air from the soil treatment process through the use of vapor treatment equipment; 3) remediate groundwater contamination by installing extraction wells, a subsurface drain and providing pre-treatment for the extracted groundwater by aeration before discharge to the Belmont POTW; and 4) mitigate impact to surface water by reconstruction of the buried culvert and construction of a spillway. The remedy will be designed and implemented such that the above remedial objectives are met. The following sections present specific remediation goals for soil andlgroundwater as described in the SOW. 14 I I I I I I I I I I I • a g, R I I I I 3.2 SOIL Thirteen specific remediation goals for soil contaminants were identified in the ROD and are presented in Table 3.1. The soil cleanup goals were developed to predict the level of soil cleanup necessary to protect groundwater. The rate of cleanup of the I groundwater should be increased by soil cleanup through soil vapor extraction and soil flushing. During the cleanup operations, the soil vapor extraction system will be operated until it is no longer effective. The soil flushing system will then be operated as an integral part of the groundwater extraction system until the sp'ecific groundwater remediation objectives have been achieved, or technical i111practicability has been demonstrated. ' I The SOW indicates that soil column testing is required to ' define the soil cleanup goals for the Site. Recent guidance from USEPA, however, indicates that soil column tests generally are used to "answer the question: Is SVE a potentially viable remediation technology?". Further, I USEPA states that soil column tests are "suited for evaluation of SVE technology when the vapor pressure of the target contaminants equals or exceeds 10 mm Hg." (USEPA, March 91). The guidance document indicates that the only way to assess the ,effectiveness of SVE in the field is to conduct a I pilot scale study to determine ;,the radius of influence of the vapor extraction wells, moisture removal rates, and contaminant flow rates". Because the ROD has already selected SVE for the Site, soil ' column tests at this stage will not provide useful information regarding the 15 I I I I I I I I I I I I I I I I I I I TABLE 3.1 SOIL CLEANUP GOALS JAoc:;o-HUGHES RD/RA Compound Remediation Goal arsenic 48.0 barium 360.0 cadmium 6.0 carbon tetrachloride 3.689 chloroform 15.865 chromium 140.0 1,2-dichlorobenzene 1.5 lead --3:Z mercury 0.15 PCBs ® selenium silver 0.6 vinyl chloride 0.014 All concentrations are ,stated in mg/kg. I I.,:!> ,o "e-h 10 vu{(D'f.tv The above identified soil cleanup goals are developed for the protection of the grouhdwater and are designed to ultimately eliminate any leachability from soil contamination that would exceed the • I estabhshed groundwater cleanup goals. I I I I I I I I I I I I I I I I I I I I I selection of SVE as a remedial technology. Therefore, soil column tests will not be conducted as part of the RD. The soil treatment process described I above, designed from data collected in a field pilot study, coupled with groundwater extraction and monitoring, will provide adequate assurance that the remedy will, as the ROD requires, result in concentrations of contaminants in the soil that do not produce 'leachate' which results in groundwater concentrations which are in exceedance of the groundwater remedial objectives. 3.3 GROUNDWATER The groundwater remediation objectives developed in the ROD are listed in Table 3.2. These objectives are based on State Groundwater Standards, Federal Maximum Contaminant Levels (MCLs) and Proposed MCLs. If the background concentrations of any metal exceeds the groundwater remediation goal for that metal, the background concentration of that metal will be the groundwater remediation goal. Background will be determined by USEPA. Analytical data will be developed during the RD, on submission to USEPA, which documents background groundwater quality. Any changes to background concentrations of those groundwater remediation I ' goals, which are based on the.State Groundwater Standards, will be subject to State approval. 16 I I I I I I I I I I I I TABLE3.2 GROUNDWATER REMEDIATION OBJECTIVES JAQCO-HUGHES RD/RA Compound voes <1n{L/ Acetone Benzene 2-Butanone Carbon Tetrachloride Chlorobenzene Chloroethane Chloroform 1,1-Dichloroethane 1,2-Dichloroethane 1, 1-Dichloroethylene 1,2-Dichloroethylene (total) 1,2-Dichloropropane Ethylbenzene 2-Hexanone Methylene Chloride 4-Methyl-2-Pentanone Tetrachloroethylene Toluene 1, 1, I-Trichloroethane 1, 1,2-Trichloroethane Trichloroethene Vinyl Chloride Xylene Remediation Goal 700 1 170 0.3 300 10 0.19 0.3 0.3 7 70 0.56 29 10 5 350 0.7 1,000 200 3 2.8 0.015 400 I BNAs !ug!L/ I I I I I I Benzoic acid Bis(2-chloroethy 1 )ether Bis(2-ethy lbenzy l)phthala te 1,2-Dichlorobenzene 1,3-Dichlorobenzene 1,4-Dichlorobenzene Di-n-Butyl Phthalate Phenol 1,2,4-Trichlorobenzene 28,000 0.03 4 620 620 1.8 700 4,200 9 Page 1 of 2 I I I I I I I I I I I I I I I I I I I Compound TABLE3.2 GROUNDWATER REMEDIATION OBJECTIVES JADCO-HUGHES RD/RA Remediation Goal Metals and Total Cvanide lul'IL/ Aluminum Antimony Arsenic Barium Beryllium Cadmium Chromium Iron Lead Manganese Nickel Vanadium Zinc 50 3 50 1,000 1 5 50 300 15 150 ;so----so 20 5,000 Page 2of 2 I I I I I I I I I I I I I I I I I I I Based on information obtained during the RI and on a I careful analysis of all remedial alternatives, USEPA believes that the selected remedy or the contingency remedy will achieve the goal of restoring groundwater to its beneficial use. However, there is a possibility that during implementation or operation of the groundwater extraction system and its modifications, that contaminant levels may cease to decline prior to reaching I I the remediation goals over some portion or all of the Site. In such a case, the system performance standards and/or the remedy may be reevaluated. The selected or contingency remedy will include groundwater extraction for an estimated period of 30 years, during which the I system's performance will be' carefully monitored on a regular basis and adjusted as warranted by the performance data collected during operation. Modifications may include: , 1) 2) 3) at individual wells where cleanup goals have been attained, and after analytical confirmatio11, pumping may be discontinued; ' I alternating pumping a~ wells to eliminate stagnation points; pulse pumping to allow aquifer equilibration and to allow adsorbed contaminants to partition into groundwater; and I 4) installation of additional extraction wells to facilitate or accelerate cleanup of the contaminant plume. 17 I I I I I I I I I I I I I I I I I I I To ensure that cleanup goals continue to be maintained, the aquifer will be monitore,d once annually at those wells where pumping has ceased following discon#nuation of groundwater extraction. This yearly monitoring will continue for a period of five years. I If, in USEPA's judgment, implementation of the selected I remedy clearly demonstrates, in corroboration with strong hydrogeological ; and chemic;al evidence, that it will be technically impracticable to achieve and i maintain remediation goals throughout the area of attainment (the Site), a groundwater remedy contingency will be developed and implemented. For I example, a contingency may be invoked when it has been demonstrated that . contaminant levels have ceased to decline over time, and are remaining ' constant at some statistically, significant level above remediation goals, in a . ' discrete portion of the area of attainment, as verified by multiple monitoring wells. Where such a contingency situation arises, groundwater I extraction and treatment may continue if technically appropriate. ' If it is determined, on the basis of the preceding criteria . and the system performance 1data, that certain portions of the aquifer cannot I be restored to their beneficial use, all of the following measures involving long-term management may occur, for an indefinite period of time, as a • modification of the existing system: 1 1) engineering controls such as long-term gradient control provided by ' low level pumping, as: a containment measure; 18 I I I I I I I I I I I I I I I I I I I 2) chemical-specific ARARs will be waived for the cleanup of those portions of the aquifer based on the technical impracticability of achieving further contaminant reduction; 3) institutional controls will be provided/maintained to restrict access to ' those portions of the ~quifer which remain above health-based goals, since this aquifer is classified a potential drinking water source; and 4) continued monitoring\ of specified wells. I The decision to invoke any or all of these measures may , be made during a periodic review of the remedial action, which will occur at intervals no less frequent than every five years. The decision to invoke any or all these measures shall be I made following the appropri11te petition, or demonstration filed by the Committee to the State and USEPA for a waiver of specific State cleanup goals I and/or consideration of technical impracticability and the granting of such waiver. 19 I I 4.0 I I I I I I I I I I u u I I I I I PROJECT ORGANIZATION AND MANAGEMENT 4.1 GENERAL As the Supervising Contractor, CRA has assembled the ' , following project managem~nt team and technical resource personnel with I ·. the necessary experience and capabilities required for the project. CRA's I I project management team will consist of Rick Shepherd; Steve Quigley; , I Wolfe Engler; Gerry Kestle; Ian McRae; Mike Mateyk; Dave Dempsey and ! I \ Ron Campbell. Brief descrip:tions of all personnel roles and qualifications are ' ' 1 listed below, and curricula vitae are included in Appendix A. Figure 4.1 ' I ; presents an organizational chart for the project team and assigned personnel. , I I Subcontr~ctors will be selected to perform specific tasks : ! :during pre-design and remedial design phases. Predesign phases will include: . I . ' ,a geophysical survey, analytical testing; monitoring well installations; and I ! {reatability testing of the SVE; and aeration treatment systems. I I; CRA has s,ubcontracted ENSECO-Air Toxics and ENSECO-Rocky Mountain Ajalytical to perform all analytical testing. : I The RA p~rtion of the work is to be undertaken by ' qualified contractors selected in a prequalified bidding process. The remedial . I action will be administered an1d monitored by the Supervising Contractor and ' ' ~pproved by USEP A. 20 r.oi,•,=.s,OG/\·HOI/E!~S L AS50CIATcS -- --I!!!!! -·Ciill iiii1i -- - -·-- - - --.. CRA 3669-09/10/91-DEW 1faiixv~~~~~¥X 1 i!l;m=mt! :::::>:: rr:;:: .. ji~!!~~~;~~~!i _,::·::-:-:-:-:,:;.:::::.:; .... : .......... : .. ;l£iig~t:: ··:· ··.:::.::·_:.>: .. :·:···:;;:·:.:: ~::i~;;?;;;;;;~:❖: •••• ·: •••••••••• figure 4.1 Project Team Remedial Design/Remedial Action Jadcr>-Hughes Site Gaston County, NC I I I I I I I I I I I D I I I I I I I 4.1.1 CRA's Project Team ' CRA has I assembled a project team consisting of both professional and technical staff to perform the RD actions at the Site. · Members of the project team' have the necessary experience and qualifications ' to successfully complete the 1esign and construction of the remedy. Key members of the project team:have worked together effectively on various RI and FS projects throughout the United States. The proposed project team consists of CRA personnel based at CRA offices in Minneapolis, Minnesota and Waterloo, Ontario. Field personnel would be qualified ~echnical support staff based at CRA offices in Chicago, Illinois or Minneapolis, Minnesota. Further back up staff are I available from CRA's Niagara, Falls, New York office. Project teain members identified for the RD/RA include the following: R. Shepherd -Principal-In-Cha_rge -provides overall corporate project management -ensures professional services provided by CRA are cost effective and of highest quality -ensures all resources of CRA are available on an as-required basis -managerial and technical gtiidance to CRA's Project Coordinator ' ' -final review of CRA submitt,als prior to issue 21 I I I I I I I I I I I I I I I I I I I S. Quigley -Project Coordinator I -supervisor of engineering project team members during the development of Work Plans, Contract Documents and Specifications and reports to State and Federal Agencies -technical manager of RA field activities I -administrator of project ~osts and schedule -coordination of CRA's te!=hnical group W. Engler -RA Technical Advisor -provides technical assistance to CRA's project coordinator during preparation for RA field activities G. Kestle -RD Technical Advisor -provides technical review of project designs and specifications -supervises project design staff I. McRae -Contract Administrator -development of Bid Docurients -provides assistance to project design staff in the preparation of project specifications ' -coordination of competitive bidding -administration of contracts (bonds, insurance, payment certificates, contract addenda, change orders) 22 I I ' I I I I I I I I I I I I I I I I I M. Mateyk -Hydrogeologic Technical Advisor ! I -development of hydroge 1 ologic components associated with preparation of the RD Work Plan and RD documents I -provides hydrogeologic expertise support function for reporting to State I and Federal Agencies D. Dempsey -Analytical Chemistry Technical Advisor ! -provides technical assistance to Quality Assurance/Quality Control (QA/QC) personnel durihg preparation of the RD Work Plan I ' -provides analytical expertise support function for reporting to State and I Federal Agencies Ron Campbell -Project Industrial Hygienist -provides technical assistance to CRA's Project Coordinator for development and implementation of the health and safety program components of the RD/RA Work Plan ' 1 -reviews Contractor(s') health and safety plans Field Engineer !-provides Site supervision of construction of each of the remedial components -administrator of project costs & schedule In addition to these key personnel, the Project Team will be supported by qualified professional, technical, clerical and administrative staff throughout the duration of the project. 23 I I I I I I I I I I I I I I I I I 0 0 5.0 RD/RA PROTECT PLANS A brief description of the various project plans necessary for implementing the RD/RA is provided below. These plans are considered working documents, structured to accommodate changes during the course of the RD/RA implementation. If substantive modifications to the approved , plans are proposed by the Committee, the modifications will be forwarded to . USEP A for review and comment prior to commencing any of the work · outlined. A summary of plans and reports required for subsequent submittals is included in Section 7.0 of this report. 5.1 HEAL TH AND SAFETY PLAN The RD Health and Safety Plan (RD HASP) (Submittal A) was prepared to protect personnel from potential hazards which may be present at the Site as a result of activities conducted during the RD phase of the project. RD investigative activities (Section 6.1) which require a Health and Safety Plan (i.e. SVE and aeration treatability studies and monitoring well installations and sampling) are addressed in the RD HASP. The plan ' provides guidance to field personnel as to the potential hazardous materials which may be encountered; specifies the personal protective equipment and levels of protection (clothing, respirators, etc.) necessary for completing various activities at the Site; air emissions monitoring to be performed; action levels at which the level of protection must be upgraded; and decontamination procedures. The plan also identifies the available local emergency response groups to be contacted should the need arise. 24 I I I I I I I I I I I I I I I I I I I 5.2 SAMPLING AND ANALYSIS PLAN A Sampling and Analysis Plan (SAP) (Submittal B) was prepared to ensure that sample collection and analytical activities are conducted in accordance with technically acceptable protocols and that the data generated will meet the Data Quality Objectives (DQOs) established in the Quality Assurance Project Plan (QAPP). In general, the plan contains protocols and requirements for the type and frequency of soil, water and air/vapor samples to be collected during the RD. The SAP also includes procedures and methods for monitoring well construction and a geophysical survey. The SAP consists of a Field Sampling and Analysis Plan (FSAP) and a , QAPP. In order to address monitoring requirements for the SVE and aeration treatability studies, the SAP includes provisions for the collection of samples relevant to those studies. .5.3 TREATABILITY STUDY WORK PLAN A Treatability Study Work Plan (Submittal C) was prepared to ensure that the selected remedy (SVE and aeration treatment) will be designed consistent with the treatment requirements outlined in the ROD. :The Plan describes the remedial technology to be tested as well as the following: test objectives, experimental procedures, treatability conditions, measurements of performance, analytical methods, data management, health and safety, residual waste management, and DQOs. Since pilot testing is 25 I I I I I I I I I I I I I I I I I I I performed, the Plan will also outline the pilot scale installation, operation and maintenance procedures and any permitting requirements. A schedule of completing specific tasks including the procurement of contractors, sample collection and analysis, performance and report preparation will be included in the Treatability Study Work Plan. 26 I I I I I I I I I I I I I I I I I I I 6.0 . PREDESIGN/REMEDIAL ACTIVITIES RD is divided into two phases; predesign and design. The predesign activities must be completed before the design for some remedy components can be undertaken. 6.1 PREDESIGN ACTIVITIES As part of the design of the SVE system and groundwater extraction and treatment system, pre-design activities must be carried out. Submittal C is a pre-design Work Plan for the SVE and groundwater aeration treatability studies. The pre-design Work Plan contains a description of each component of the pre-design investigation and specific guidelines, procedures and implementation schedules for conducting pre-design activities. The pre-design investigation will consist of the following components which are more fully discussed in the SAP or the Treatability Study Work Plan: 1) a geophysical survey in the northern portion of the Site (included in SAP); 2) analyses of one round of groundwater samples from existing monitoring wells (included in the SAP); 3) construction of monitoring wells (included in SAP); 27 I I I I I I I I I I I I I I I I I n I 4) analyses of one round of groundwater samples from the new monitoring wells (included in the SAP); 5) an SVE treatability study (included in the Treatability Study Work Plan); 6) an aeration treatability study (included in the Treatability Study Work Plan); and 7) analyses of up to three samples from residential wells downgradient of the Site if requested by USEPA and if access is granted to collect the samples. Supporting documents required before commencing the pre-design investigation have been prepared and are submitted as attachments to this Work Plan. These include the RD Health and Safety Plan which is attached as Submittal A and the Sampling and Analysis Plan which is attached as Submittal B. A QAPP is included as part of the Sampling and Analysis Plan. The results of the pre-design investigations will be reported in technical memoranda as discussed in Section 7.0. 6.2 REMEDIAL DESIGN ACTIVffiES 6.2.1 General Remedial design activities generally consist of preparing engineering drawings, specifications and supporting calculations for the 28 I I I I I I I I I I I u u I I I I I I various components of the remedial construction. The design of each component must also reflect the requirements imposed by permit approvals. This is sometimes an iterative process where a preliminary design is developed and reviewed by the permitting authority before permit approval requirements which affect the final design can be incorporated. ' 1 6.2.2 Plan to Satisfy Permitting Requirements During the initial design phases, each component of the remedy will be evaluated to determine which permit programs are potentially applicable. This will include discussion with local, State and Federal agencies. At this time, it is envisioned that the major permit programs to be considered are related to discharge of pretreated water to the Belmont POTW, and air emissions from the groundwater treatment system and the SVE system. Other permit programs that need to be considered ' would be related to construction of monitoring wells, sewers and structures. The design requirements that are imposed by the respective permit program will then be incorporated into the later design phases. Permits which are required to complete the RD are limited to permits from the State for the construction of monitoring wells. These permits are being sought from the State Department of Natural Resources. 29 I I I I I I I I I I I I D u I I I I I 6.2.3 Design Process The remedial design process for each major component of the remedial action is described in this section. SVE System SVE is a vacuum extraction process which enhances the volatilization of VOCs by the application of a subsurface vacuum. The subsurface negative pressure gradient induces the migration of vaporized VOCs toward specially designed vacuum extraction trenches, and drives them to the surface for recovery and treatment. The vacuum extraction process removes the contaminants from the unsaturated zone before they enter the groundwater, and also can assist in reducing contaminant concentrations in groundwater. The design of the SVE system will be based on results achieved in the pre-design investigation (treatability study) and data from the RI. The scope of the treatability study is discussed below. The objectives of the treatability study will be to: • determine the radius of influence and flow characteristics of soil vapor to the vacuum trench(es) at the Site; • quantify removal rates of voes and BNAs from Site soils; • determine voe and BNA concentrations in the extracted gas; and • estimate the in-situ permeability of the former landfill soils. 30 I I I I I I I I I I I I I I I u D I I The treatability study of the SVE system is based on data from the RI. The data includes; the vertical and areal distribution of VOCs in the former landfill soil; water permeability in soils; moisture content; and organic carbon content. The treatability study will include construction of a capped trench and collection system. The treatability study will develop data which will meet the objectives described above. The collected data, along with RI data, will be used to design a full-scale SVE system. The SVE treatability study will also develop profiles of the concentration of extracted vapors in the off-gas. These estimates will be used to design the treatment system for the gas which may be based on activated carbon. These results will be reported in the Treatability Study Report. Soil Flushin~ In situ soil flushing involves increasing the infiltration of water through contaminated soils to accelerate the natural removal of ~ontaminants in the unsaturated zone. Water will be introduced and charged into the soil through a leaching bed which would be comprised of the decommissioned SVE system. The contaminants in the soil partition (i.e. migrate from the soil) to the infiltrating water. The resultant I contaminated water will be collected and treated. 31 r,o;,:;sTOGA-ROVERS 11 ASSOCIATES I I I I I I I I I I I I a i u u I I I I The soil flushing system will be operated in conjunction with the groundwater extraction and treatment system. The soil flushing system will be constructed only when it is demonstrated that the SVE system can no longer effectively treat VOCs located in soils in the former landfill. The soil flushing system will be designed as an integral part of the SVE system to be implemented following completion of soil SVE treatment. Since the soil flushing system will be constructed after • operation of the SVE system is terminated, the final design of the soil flushing system will not be completed in the RD. Technical memoranda and reports will be submitted to USEP A concerning the final design of the soil flushing system during the preliminary stages of the RA as appropriate. Groundwater Extraction System A conceptual design detailing extraction well and subsurface collection drain location(s), intended pumping rates, and zone of capture was completed for use in the FS. Appendix D of the FS presents this conceptual design. A pump test was completed on well PW-1 (Figure 1.3) during the RI to confirm the pumping rate and zone of capture of extraction wells at the Site. This information, along with an analysis of the areal and vertical extent of groundwater contamination requiring remediation as confirmed by RD groundwater sampling and analyses, will then be used to confirm the number, location, pumping rates and construction details of the wells in the full scale groundwater extraction system. This will be completed using standard hydrogeologic principles. 32 r.a;,,~t.TOG,'.-ROVERS IA ASSOCIATES I I I I I I I I I I • I a D • I I I I On-Site Groundwater Treatment System The proposed method of pretreating groundwater prior to , discharge of the treated water for supplementary treatment at the Belmont ; POTW consists of aeration of the collected groundwater. Air is brought into intimate contact with the extracted groundwater thereby transferring VOCs · and some BNAs from water to the vapor phase. The groundwater treatment system will consist of an aeration and an equalization tank. The air vented from the aeration tank will 1be treated by carbon adsorption prior to atmospheric discharge. The effluent I ' 1from the treatment system will be pumped to the nearest City of Belmont I 'sanitary sewer system manhole. The pre-design investigation will consist of a bench scale aeration treatability study. The aeration treatability study will consist of the following components: • collection and analysis of an on-Site groundwater sample from extraction well MW-2D and/or PW-1; • design of a bench scale aeration system; • experimentation of the bench scale aeration system to determine 1 treatment effectiveness using different air flow rates with a constant groundwater flowrate; • analyses of treated groundwater; and • mass balances to determine VOC loading on the vapor phase treatment 1 system. 33 ;~O"!ESTOG•·.-:'lOVE;:tS 11 .ll.SSOCIATES I I I I I I I I I I I I a D I I I I I The full-scale aeration system will be designed using the data derived from the aeration treatability study, groundwater contamination profiles, and the developing design of the groundwater extraction system. · The treatment system will be designed to comply with the City of Belmont's pretreatment requirements. Culvert Replacement/Surface Water Diversion The reconstruction of the culvert and design and construction of a Site spillway will not require any special pre-design efforts. The preliminary design of these features was completed during the FS. The developed design will consider factors such as storm water management and grading of surface contours. Monitoring Monitoring will be performed during the treatability studies. The scope of this monitoring is described in the Treatability Study Work Plan (Submittal C). Monitoring will assess the performance in the SVE, and aeration treatability studies. Soil gas sampling and analyses will be conducted to confirm the effectiveness of the SVE system. One groundwater monitoring round will also be conducted to confirm RI groundwater analytical data and to provide additional data for the design of the groundwater extraction and treatment system. 34 I I I I I I I I I I I I I I g D I I I These monitoring/sampling plans are described in the Sampling and Analysis Plan (Submittal B). 6.2.4 Desiw Submittals Design submittals will be made at four stages of development for each remedial component (i.e. SVE system, culvert replacement/spillway construction, groundwater extraction and treatment system). The four stages are 30% (preliminary), 60% (intermediate), 90% (pre-final) and 100% (final). It is expected that the submittals at each stage will be as outlined below: 30% Design (Preliminary) The 30% initial design submittal for each component will include preliminary plans and specifications showing the basic detail of each component. This will include plans showing information such as the limit and volume of the former landfill, extraction well and subsurface drain location(s); SVE system layout; groundwater treatment system location; location of Site spillways; and the location of the culvert. Preliminary specifications will include conceptual design of: the SVE system; groundwater extraction and treatment system; extraction well pumping rates; culvert replacement; and Site spillway. 35 I I I I I I I I I I I I I I m I At 30% design level for each component, an assessment of permitting requirements will be made. Section 6.2.2 details permits and associated requirements to be submitted. Included in the 30% submittal will be a report presenting · an evaluation of the treatability studies for the SVE system and the groundwater aeration treatment system. The report(s) will present the results 1 of the treatability studies as follows: the design and methodology used in the treatability studies; the predicted level of treatment; full scale design; i , implementation factors; and an estimated capital cost for the full-scale design. Documentation/memoranda will be submitted at the 30% design stage which will present the results of additional data acquisition I . activities. Data gathered during the pre-design phase will be compiled, !summarized and submitted along with an analyses of the impact of the results on the design activities. Results of the geophysical survey and an evaluation of the utility requirements for the full scale treatment system will be presented. A design criteria report supporting technical aspects of the remedial design will be submitted at the 30% design stage. This report will detail preliminary design assumptions and parameters including: contamination profiles for the former landfill and groundwater; 2) remediation goals for on-Site soils and groundwater; 3) former landfill volume and volume of groundwater to be treated; 36 ,:nll!'.cS"iOG!',·!lOIJERS 11 /~SSOCIATES I I I I I I I I I I I m u D I m I I I 4) conceptual design of the SVE system and groundwater extraction and treatment system; 5) influent/effluent rates with respect to the SVE system and groundwater treatment system; 6) equipment/materials to be used in the SVE and groundwater extraction and treatment systems, and culvert reconstruction and Site spillway construction; and 7) an assessment of methods to provide system monitoring to ensure that remediation goals are being met. 60% Design (Intermediate) The 60% design submittal for each component will incorporate the information from the initial design, as previously discussed, ' and will also provide further detail in the design. For the SVE component, the 60% design submittal would include the following drafts: 1) preliminary plans and specifications from the 30% design; 2) plan showing SVE system details; 3) plan showing cap details (if required); 4) detailed specifications for SVE system construction; 5) specifications for cap construction (if required); and 6) generic operations and maintenance (O&M) Plan. 37 I I I I I I I I u 0 I • I I I I I I I For the groundwater extraction and treatment system component, the 60% design submittal would include: 1) preliminary plans and specifications from the 30% design; 2) plan showing piping values and controls; 3) plan showing groundwater treatment system construction details; 4) plan showing treated groundwater discharge system; 5) detailed specifications for construction of extraction wells, piping, treatment system; and 6) a generic O&M Plan. For the culvert replacement and Site spillway component, the 60% design submittal would include: 1) preliminary plans and specifications from the 30% design; 2) plan showing cross-section and elevations of the Site spillway; and 3) detailed specifications and construction methods for relining the culvert and constructing the Site spillway. Included in the 60% design submitted will be a draft construction and implementation schedule for implementation of the RA. The schedule will identify timing for initiation and completion of all critical RA tasks. Specific construction startup and completion dates will be identified for the following RA tasks: • SVE system; • groundwater extraction and treatment system; and 38 r~ :J,·' ,ci'IO::" f.-;'101!EHS C. ASSOCIATES I I I I I I I I I I I I I I I I I I I '• culvert replacement and Site spillway construction. 90% Design (Pre-Final} The 90% design submittals for each component will ,include plans, specifications and details from the 60% design submittal .incorporating preliminary comments from USEPA. Design calculations will also be submitted. A construction cost estimate will also be submitted which will be accurate to within +15% to -10% for all components of the RD/RA. The O&M plans will be developed to ensure the safe and effective operation of the respective component. The elements of the O&M plan will include discussion of the following items at minimum: 1) start up phase; ,2) normal operation and maintenance; 3) potential operating problems; 4) routine monitoring and testing; 5) operation and maintenance; and 6) long term monitoring and maintenance. The generic operations and maintenance plans developed during the remedial design will be updated with specific data supplied by vendors for various components of the remedy when the remedial construction is completed. 39 CONESTOGA-ROVERS & ASSOCIATES I I I I I I I I I I I I I I I I - I I 100% (Final) Desiim The 100% design submittals will include finalized plans, details and specifications addressing final comments from USEP A. 40 C'Oi''.ES·rocr·, ROVERS 8 ASSOCIATES I I I I I I I I I I I I I I I I I I I 7.0 REPORTS AND DOCUMENTATION '7.1 EPA MONTHLY PROGRESS REPORTS Monthly progress reports will be provided to USEPA, by the fifth of each month, as required by the 106 Order and will include the following major items: 1) description of actions taken toward achieving compliance with the 106 Order and RD and RA Work Plans; 2) description of work scheduled for next month; and 3) a project schedule update. 7.2 DATA MANAGEMENT PLAN The Data Management Plan (DMP) presented in Appendix B identifies procedures to be employed for managing all iinformation, reports and correspondence (documents) associated with ,RD/RA program to be conducted at the Site. 7.3 PRE-DESIGN SUPPORTING DOCUMENTATION The supporting documents for the pre-design investigation includes: 41 r,Qr,!2.STOG/l,•!'lOVEAS Ii, 1'.SSOC!ATES I I I I I I I I I I I I I I I I I I I 1) Health and Safety Plan (Submittal A); 2) Sampling and Analysis Plan (Submittal B); and 3) SVE and Aeration Treatability Study Work Plan (Submittal C). 7.4 PRE-DESIGN TECHNICAL MEMORANDA The results of the pre-design investigation for various items of work will be provided in a series of technical memoranda which are described in Table 7.1. 7.5 DESIGN REPORTS Design reports will be submitted to USEP A for review at four stages of their development for the remedial components as noted in Section 6.2.3. 7.6 CONSTRUCTION SCHEDULE A construction schedule will be issued with 60% and 90% submittals which will detail construction and implementation timing with regard to all aspects of the RA. 42 r:;Q,,'i:SYOG'l-'.-F.Ol!Ef-1S 8 .'~SSOCIATES I I I I I I I I I I I I I I I I I I I TABLE7.1 SUMMARY OF PREDESIGN TECHNICAL MEMORANDA JADCO-HUGHES REMEDIAL DESIGN · Technical Memorandum Title SVE Technical Memorandum Aeration Technical Memorandum ' Additional Data Acquisition Technical Memorandum Design Criteria Technical Memorandum I Contents/Purpose -presentation and evaluation results of SVE treatability study -presentation of and evaluation results of aeration treatability study -presentation of results of geophysical survey -data relative to SVE and aeration treatability studies -utility requirements and acquisition for SVE and groundwater extraction/ treatment systems -presentation of technical aspects of remedial design CONESTOGA·FiOVEflS A ASSOCIATES I I I I I I I I I I I D D D I I I I 7.7 LONG TERM OPERATION AND MAINTENANCE AND MONITORING AND TESTING REPORTS Long term operation and maintenance and monitoring and testing reports will be completed on a periodic basis (to be specified in the Operation and Maintenance Plan) and will detail operation and maintenance activities and monitoring and testing results. These reports will also include assessments of the progress towards meeting remedial objectives. 43 I ~·2,-:i'$T.JG:.-,:01.'tilS u ASSOCIATES I I I I I I I D I I I I I 'I I I I I I 8.0 COMMUNITY RELATIONS SUPPORT The Committee is committed to supporting USEPA's community relations program for the RD/RA to be conducted at the Jadco-Hughes Site, and recommends that USEPA hold public meetings approximately once every six months until the remedy is implemented and operational. As USEP A has assumed the lead position on all community relations activities, the Committee will provide technical support to USEPA at all public meetings. The Committee will provide assistance to USEPA through its Project Coordinator. Assistance will include the provision of information to be used in community relations efforts and technical representation at public meetings and information sessions by personnel familiar with the RD/RA activities to be conducted. · USEPA will have overall authority for coordinating community relations activities and ensuring that the public is kept informed ' a11d has the opportunity to review information and comment during the progress of the RD/RA. The community relations activities to be conducted by USEP A will: 1) familiarize area residents with the RD/RA process; 2) keep area residents and other interested parties informed of the RD/RA activities to be conducted, especially with regard the on-Site activities; 3) provide a mechanism for input to the RD/RA; 44 I I I I I I I I I I I a 0 D I m I I I 4) 5) provide a channel of communication for responding to Site specific contamination issues; and ensure that all regulatory requirements concerning community relations are met. 45 c.,1,,;e,;y:JC.1.\·RO\IERS w ASSOCIATES I I I I I I I I I m 0 I I I I I I I I 9.0 SCHEDULE Figure 9.1 presents a preliminary schedule for the RD. The schedule identifies timing for submission of design submittals, RA Work Plan and associated submittals and the results of treatability studies. The summary of major deliverables for all associated tasks are presented in Table9.1. A schedule of construction activities and anticipated SVE system and groundwater extraction and treatment system startup and operation will be included with the 60% and 90% design submittals respectively. The construction schedule will also identify activities associated with the culvert reconstruction and Site spillway construction. This schedule will address major construction milestones; inspection activities; sampling to be performed prior to system startup (if required); and SVE and groundwater extraction and treatment operation activities. Routine sampling for O&M purposes to be performed during the SVE and the groundwater extraction and treatment system operation will be scheduled according to the O&M plan. Scheduling of field activities are subject to contractor availability and weather considerations and may be modified as approved by USEPA and the State as the project develops. 46 -- - - -- --1!!119 ;;;;a - -.. - A11pU,l"I ACTIVITY DURATION ldavsl 45 90 135 180 225 270 315 360 405 450 495 540 585 1 U5EPA APPROVAL OF -~ SUPERVISING CONTRACTOR 8 : 2 SCOPING ~: 3 RD WORK PLAN "" USEPA REVIEW '" 4 PRELIMINARY DESIGN '"' U5EPA REVIEW '" 5 INTERMEDIATE DESIGN 90d: USEPA REVIEW "' .. 6 PREFINAL DESIGN USEPA REVIEW : : 7 FINAL REMEDIAL DESIGN ---: 8 REMEDIAL ACTION WORK PLAN : \aJd~l) : . : USEPA REVIEW 9 OPERATION AND MAINTENANCE PLAN 90i,n, USEPA REVIEW .. ~= JO REMEDIATION GOAL 18Cld~I : VERIFICATION PLAN .... USEPA REVIEW : JI TREAT ABILITY STUDY SAMPLING & ANALYSIS REPORT USEPA REVIEW "'' RD Work Plan indudes: L~G~l:ll! RA Work Plan includes: figure 9.1 Sampling 6: Analysis, Health&: Safety and -Duration of Activity Construction Manag~ent, Construction Treatability Study Plans. Quality Assurance, and Construdion Health RD/RA SCHEDULE 0) Coincident deadline provided ill the SOW. * Event and Safety/ Contingency Plans. JADCO-HUGH£5 SITE CRA I Approved August 15, 1991 GASTON COUNTY, NC 3669-09/10,'JI DEW . I I I I I I I I I I m D u D I I I I I 1) 2) 3) 4) 5) 6) 7) 8) 9) (a) TABLE9.1 SUMMARY OF MAJOR DELIVERABLES JADCO-HUGHES RD/RA Deliverables Submittal Date to USEPA Scoping September 4, 1991 RD Work Plan September 30, 1991 Preliminary Design (30%) (a) April 6, 1992 Intermediate Design (60%) August 19, 1992 Prefinal Design (90%) January 1, 1993 I Final Design (100%) April 1, 1993 RA Work Plan August 19, 1992 O&MPlan January 1, 1993 ~emediation Goal Verification Plan August 19, 1992 'Freatability Study Report is submitted as an attachment to the Preliminary Design Report. I These schedule dates are contingent upon USEPA review and approval within the schedule limits shown in Figure 9.1. I I I I I I I a D I I I I I I I I I I 10.0 · REFERENCES 1. "Remedial Investigation Report, Jadco-Hughes Site, Gaston County, North Carolina", CRA, July 1990. 2. 3. 4. 5. 6. 7. 8. "Feasibility Study Report, Jadco-Hughes Site, Gaston County, North Carolina", CRA, July 1990. "Superfund Risk Assessment Report, Jadco-Hughes Site, Gaston County, North Carolina", CRA, February 1990. "Construction Report Interim Removal Measures, Jadco-Hughes Site, Gaston County, North Carolina", CRA, January 1991. "National Oil and Hazardous Substances Pollution Contingency Plan; Final Rule", Federal Register 40CFR Part 300, March 8, 1990. "Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA, Interim Final", USEP A, Office of Emergency and Remedial Response, OSWER, May 1989. "Water Engineering Research Laboratory Treatability Database", USEPA, 1989. "Guidance for Conducting Treatability Studies under CERCLA: Soil Vapor Extraction, Revised Final Draft", USEPA, Office of Research and Development and Office of Emergency and Remedial Response, March 1, 1991. 47 I I I I I I g I I I I I I I I I I :1 I APPENDIX A CURRICULA VITAE -KEY PROJECT PERSONNEL I I I I I I 0 I I I I I I I I I I RICHARD G. SHEPHERD, B.A,Sc., P. Eng, EDUCATION: B.A.Sc. University of Waterloo 1975 Numerous continuing education courses and seminars in hydrogeology, waste management, construction management and health & safety: 1980 to present. EMPLOYMENT: 1983- Present 1981- 1983 1979-81 1976-79 1975-76 1974-75 1974-75 1973 1971-72 1968-71 Principal Conestoga-Rovers & Associates Limited Associate Conestoga-Rovers & Associates Limited Senior Engineer Conestoga-Rovers & Associates Engineering Services Manager Malawi/Canada Railway Project Project Engineer, Steed and Evans Co. Ltd., Kitchener Project Supervisor, Steed and Evans Co. Ltd., Kitchener University of Waterloo, Department of Civil Engineering Construction Layout Supervisor, Steed and Evans Co. Ltd., Kitchener Design Technician, City of Brantford Engineering Department Survey party chief, J.D. Lee Engineering Limited, Kingston and Brantford PROFESSI0NAL AFFILIATIONS: Association of Professional Engineers of Ontario Canadian Society of Civil Engineers I I I I I I n I I I I I I ·1 I I I I I Richard G. Shepherd PROFILE OF PROFESSIONAL ACTIVITIES: • Corporate responsibility for all construction and project management of remedial construction related to remedial action implementation. • Corporate responsibility for Health and Safety. • Senior Engineering Supervisor /Project Manager for in excess of 200 environmental remedial projects. Areas of experience with selected example projects are: Remedial Investigation/Feasibility Studies -Yellow Water Road Site, Baldwin Florida (NPL Site) -Love Springs Site, Cherokee County, South Carolina (State Listed Site) -Carolawn Site, Chester County, South Carolina (NPL Site) -Mallory Capacitor Site, Waynesboro, Tennessee (NPL Site) -North Hollywood Dump, Memphis Tennessee (NPL Site) -Jadco-Hughes Site, North Carolina (NPL Site) -FMC South Site, Fridley, Minnesota (NPL Site) -Universal Manufacturing, Bridgeport, Connecticut (State Listed Site) -FMC Plant Site, Middleport, N.Y. (State Listed Site) -Mallory Site, Glasgow, Kentucky Design and Project Management of Remedial Construction -Chem-Dyne Site, Hamilton, Ohio (NPL Site) -Yellow Water Road Site, Baldwin, Florida (NPL Site) -Ellis Road Site, Jacksonville, Florida -North Hollywood Dump, Memphis, Tennessee (NPL Site) -Hardeman County Landfill, Tennessee (NPL Site) -LaBounty Landfill Site, Charles City, Iowa (NPL Site) -FMC South Site, Fridley, Minnesota (NPL Site) -Michigan Chemical (Velsicol) Site, St. Louis, Michigan (NPL Site) -FMC Plant Site, Middleport, New York (State Listed Site) I I I I I 0 I I I I I I I I I I I I Richard G. Shepherd -Mallory Site, Crawfordsville, Indiana (State Listed Site) -Decontamination of four capacitor plants, Kentucky, Tennessee and Indiana -Universal Manufacturing Sites, Totawa; New Jersey and Bridgeport, Connecticut (State Listed Sites) -Love Canal, Niagara Falls, New York (NPL Site) -Plant demolition and cleanup, Racine, Wisconsin (J.I. Case) -Manville Waukegan Site, Waukegan, Illinois (NPL Site) -Cleanup and demolition of manufacturing plant, Manville, New Jersey (State Site) -Velsicol Chemical Corporation Site, Marshall, Illinois (NPL Site) Acquisition/Sale of Industrial/Commercial Facilities -Site assessment, design of remedial measures, management of remedial construction for the sale of over 80 surplus properties and five manufacturing facilities (J.I. Case Co) -Assessment and investigation of a 76 retail gasoline facility chain, recommendation of remedial actions, preparation of remedial cost estimates (Florida, Georgia) -Assessment and investigation of nine bottling facilities in Louisiana, Arkansas and Texas, recommendation of remedial actions, preparation of remedial cost estimates (Coca-Cola) -Assessment and investigation of retail/wholesale gasoline chain, recommendation of remedial actions, preparation of remedial cost estimates (City Corp.) -Assessment and investigation of 8,000-acre manufacturing and mining complex, development of remedial alternatives, preparation of remedial cost estimates (Tennessee) Special Court Master -Appointed Special Court Master to the Federal District Court, Northern District, Illinois. Responsible for the design and management of remedial activities including the decommissioning, demolition and cleanup of a 270 acre oil refinery in East Chicago, Indiana. I I I I I I D I E I I I I I I I I I I Technical Negotiator for Consent Order/ Agreements or Selected Remedy Settlements Richard G. Shepherd -Michigan Chemical Site, St. Louis Michigan (USEP A, MDNR) -FMC Fridley Site, Fridley, Minnesota (USEP A, MPCA) -North Hollywood Dump, Memphis, Tennessee (USEPA, TDHE) -Two manufacturing sites (IBM), New York (NYDEC) -Several Remedial Actions, Middleport, New York (NYDEC) -Mallory Site, Crawfordsville, Indiana (USEP A, IDEM) -Chem-Dyne Site, Hamilton, Ohio (USEP A, OEP A) -Summit National Site, Deerfield County, Ohio (USEPA, OEPA) -Miami County Incinerator Site, Troy, Ohio (USEPA, OEPA) -Mallory Site, Waynesboro, Tennessee (USEPA,TDHE) Expert Testimony -Litigation involving PCB and volatile organic contamination of building, soil and groundwater in Waynesboro, Tennessee. Testimony focussed on appropriate level of cleanup, construction methods to be used for cleanup, cost of cleanup. -Litigation involving excavation and disposal of drummed wastes and cont,aminated soils, Picillio Site, Rhode Island. Testimony focussed on appropriateness of remedial construction techniques employed by State, appropriateness of costs incurred by State. -Deposition testimony provided for seven additional cases, settlements reached prior to trial. I I I I I I • D I I I I I •• I I I I I STEPHEN M, QUIGLEY, P. ENG, EDUCATION: · 1979-'84 B. Tech. (Chemical Engineering), Ryerson Polytechnical Institute EMPLOYMENT: 1989- Present 1988-89 1987-88 1984-87 1984 Engineer, Conestoga-Rovers & Associates Project Engineer, Canada Packers Specialty Chemical Group Production Foreman, Canada Packers Specialty Chemicals Group Health, Safety and Environmental Supervisor, Canada Packers Chemicals Division Quality Control Technician Canada Packers Chemicals Division AFFILIATIONS: Member -Association of Professional Engineers of Ontario. PROFILE OF PROFESSIONAL ACTIVITIES: • Environmental Engineer responsible for one or more of the following: site investigation, site characterization, feasibility studies, litigation/hearings support, remedial design and contract document and specifications for the following projects/ clients: -Remedial Investigation (RI) and Feasibility Study (FS) including coordination of field work, database management, laboratory service coordination, preparation of Treatability Study Work Plan and completion of RI and FS reports for a former solvent recycling/disposal facility, Jadco-Hughes NPL Site, Belmont, North Carolina (Generator Group), 1989 -ongoing. I I I I I I g I I I I I I •• I I ·1 \. I I I Stephen M. Quigley -Remedial Action, design of remedial measures for a drummed inventory of wood treating solution recovered from underground storage tanks, including the development of work plans and contract documents and construction supervision, Ft. Lauderdale, Florida (PRP), 1989 -ongoing. -Feasibility Study, development and evaluation of remedial alternatives for a former hazardous waste landfill including the preparation and oversight of a TO-1/T0-2 air monitoring program, and critique of the EPA Risk Assessment, Hassayampa Landfill NPL Site, Maricopa County, Arizona, 1989 -ongoing. -Technical overview of groundwater remedial action plan and technical review of 30% Remedial Design for a VOC contaminated aquifer, Indian Bend Wash Operable Unit Feasibility Study and Record of Decision, Scottsdale, Arizona, (PRP Group), 1989-ongoing. -Litigation support including preparation of a critique of a contractor's RI/FS, a conceptual closure design and reports on state-of-the-art of landfill practise, 19th Avenue Landfill Superfund Site, Maricopa County, Arizona, 1990-ongoing. -Litigation support for suit related to the potential contamination of a food product including plant assessment, collection of environmental samples and data assessment (location confidential) 1990-ongoing. -Critique of plaintiff's release estimates, air dispersion modeling and litigation support related to U.S. Department of Energy Facility (PRP), 1989-ongoing. -Technical coordination of intervenor group, environmental assessment hearings related to 25 year demand/supply plan, Ontario Hydro, 1991-ongoing . -Feasibility Study -buried waste, groundwater remediation project coordination and technical support for Environmental Appeal Board hearings for a large chemical manufacturing facility, Elmira, Ontario 1990 ongoing. -Site assessment and evaluation of remedial alternatives, former solvent bulking and storage facility, Hartford, Connecticut 1989-ongoing. Plant Assessment for discharges to municipal treatment plant including a critique of municipal consultants sewage treatment plant design, data assessment, plant operations assessment, design and construction of pretreatment facilities, dairy plant, Ontario, 1990-ongoing. I I I I I I I I I I I I I I I I I I I Stephen M. Quigley • Technical Specialist/Project Engineer for the following project areas: -Development and implementation of environmental waste treatment and general engineering projects -Supervision and operation of a continuous batch process specialty chemical plant -Development and implementation of an Environmental Protection Plan and spill response plan for Canadian chemical manufacturer -Preparation of hazardous effluent discharge permits -Project management of source monitoring for small scale 502 emission generator -Development and implementation of national training program for dangerous goods transportation and Health, Safety and. Environmental Protection -Participation in Environmental Risk Assessments -Co-development of corporate Health and Safety rating system for a Canadian food company -Development and implementation of Industrial hygiene surveys and analyses -Supervision of the development on asbestos removal training program I I I D I I I I I I I I I I I I I I I WOLFGANG (WOLFE> K. F. ENGLER. C.E.T. EDUCATION: Diploma Civil Technician, 1970, Cambrian College, Sudbury Campus EXPERIENCE: 1980- Present 1981- Present 1976-81 1975-76 1975 1971-75 Associate Conestoga-Rovers & Associates Limited Resident Engineer Conestoga-Rovers & Associates Limited Manager, Kincardine Branch Conestoga-Rovers & Associates Manager -Kincardine Branch Conestoga Engineering Limited Proctor and Redfern Consulting Engineers Dennis Consultants Limited AFFILIATIONS: Engineering Technologist -1986, Ontario Association of Certified Engineering Technicians & Technologists Senior Engineering Technician -1974, Ontario Association of Certified Engineering Technicians & Technologists Technical Affiliate -The Engineering Institute of Canada Technical Affiliate -The Canadian Society for Civil Engineering Member -American Society of Certified Engineering Technicians (ASCET) I I I I I I I I I I I I I I I I I I I Wolfgang (Wolfe) K.F. Engler COMMUNITY AFFILIATIONS: Past-President -Kincardine Rotary Club Member -Kincardine and District Chamber of Commerce PROFILE OF PROFESSIONAL ACTIVITIES: -Eight years experience in field investigations, design, contract administration and field supervision of numerous environmentally oriented projects -Quality Assurance Supervisor, Industrial Waste Treatment Plant Expansion, IBM Corporation, Poughkeepsie, New York -Site Monitoring Supervisor, drum and contaminated soil removal, Novak Farm Site, Chenango County, New York -Resident Engineer for drum sampling, staging and site securement, Gibbs Plating Site, Charlotte, North Carolina -Resident Engineer, drum and contaminated soil removal, Ardenwood Estates, Staten Island, New York -Field Supervisor for the disposal of oil refinery products, ECI, East Chicago, Indiana -Resident Engineer on numerous environmentally related projects, IBM Corporation, Poughkeepsie, New York -Resident Engineer, numerous tank closures, IBM Corporation, Poughkeepsie, New York -Resident Engineer, fuel tank replacements with double wall tanks, IBM Corporation, Poughkeepsie, New York -Resident Engineer, lagoon closure, IBM Corporation, Poughkeepsie, New York -Resident Engineer and Safety Officer, Disposal of underground tank, Town of New Hempstead, Long Island, New York -Field Supervisor and technician for borehole sampling of contaminated soils (chlorinated solvents, IBM Corporation, Poughkeepsie, New York I I I I I I I I I I I I I I I g u D Wolfgang (Wolfe) K.F. Engler -Resident Supervisor and Safety Officer for borehole sampling of contaminated soils, and installation of monitoring wells, Chem-Dyne Site, Hamilton, Ohio -Resident Engineer and Safety Officer; Cleanup and disposal of contaminated soils (chlorinated solvents), IBM Corporation, Poughkeepsie, New York -Resident Supervisor for test pit and borehole sampling of contaminated soils, and construction of decontamination facilities, FMC -Northern Ordnance Plant, Minneapolis, Minnesota -Resident Engineer, cleanup and disposal of surficial drummed and tanked hazardous wastes, P.A.S. Site, Oswego, New York -Resident Supervisor in charge of site survey, drummed waste cleanup, and hazardous waste inventory at the S.C.R & D Bluff Road Site, Columbia, South Carolina -Resident Supervisor and assistant project manager, securement of hazardous waste landfill, Hardeman County, Tennessee -Field technician responsible for securement and disposal of radioactive soils and equipment, at Velsicol Plant Site, St. Louis, Michigan -Field ,technician involved in preliminary and final design, securement of hazardous waste, Velsicol Plant Site, St. Louis, Michigan -Field technician involved in preliminary and final design of several toxic and hazardous waste projects in the Niagara Falls, New York area -Seven years experience in design and field supervision of municipal engineering projects -Experience in cost analysis for determining project feasibility -Extensive exposure to the planning and approval process of varied forms of development projects -Preparation of recreation feasibility studies for municipalities in the Bruce County area -Resident inspector for the Bruce Agripark Joint Venture in the construction of a combined one acre prototype greenhouse and hydroponic house utilizing waste heat I I I I I I I I I I I I a D D I I I I Wolfgang (Wolfe) K.F. Engler -Project Manager on several municipal and residential developments in the Bruce County area. These projects have included the necessary planning and engineering approval procedures -Project Manager of a 750 lot subdivision in the Town of Kincardine -Preliminary field pick-up and design of a 270 lot subdivision in the City of Sudbury -Inspector for a Ministry of Transportation and Communications urban road . reconstruction project in the City of Sudbury (urban removal) -Design, supervision and inspection of numerous park projects and school sites in the Sudbury and surrounding areas -Project supervision and inspector for a ski hill in Sudbury employing lighting and snow making apparatus -Site inspector for numerous subdivisions in the Sudbury and surrounding area -Fifteen years experience in field surveying, drafting, minor design for municipal engineering projects I I I I I I I I I D I I I •• I I I I I MICHAEL G. MATEYK, B.Sc. EDUCATION: 1973 B.Sc., Geological Sciences, Brock University 1977-78 Graduate Courses in Hydrogeology University of Alberta June 1982 Short Course -Contaminant Hydrogeology University of Waterloo EMPLOYMENT: 1990 1985-90 Present 1983-85 1977-83 1976-77 1974-76 1973-74 Associate Senior Hydrogeologist Conestoga-Rovers & Associates Limited President and Senior Hydrogeologist MLM Ground-Water Services Ltd. Project Hydrogeologist and Principal MLM Ground-Water Engineering Project Hydrogeologist EBA Engineering Consultants Ltd. Hydrogeologist James F. MacLaren Ltd . H ydrogeologist Water Quality Division Ministry of the Environment, Ontario AFFILIATIONS: Association of Ground-Water Scientist and Engineers International Association of Hydrogeologists I I I I I I I I B D I I I I I I I I Michael G. Mateyk PROFILE OF PROFESSIONAL AcnvmES: -Responsibility for the hydrogeologic component of Remedial Investigations at hazardous waste sites in the United States -Design and supervision of hydrogeologic evaluations at existing and former waste disposal sites -Evaluation of groundwater contamination due to exfiltration from sewage lagoons, brine ponds and waste holding ponds -Design and supervision of landfill site hydrogeologic investigations -Preparation of hydrogeological constraints to maps to aid in the selection of new landfill sites -Assessment of the impacts of a proposed major river division on local groundwater supplies -Assessment of the effects of gravel extraction on the regional groundwater flow system -Assessment of open pit coal mining on the hydrologic budget of small water sheds -Regional groundwater evaluation which includes aquifer delineation and flow system mapping -Design and supervision of test drilling, aquifer testing and well construction programs -Design of well point and deep well dewatering systems for construction projects and open pit mines -Determination of groundwater inflow rates into a proposed underground mine PUBLICATIONS: A. Published Refeered Papers I I I I I I I u D I I I I I I I I I I B. Michael G. Mateyk -"Salt Water Pumping Controls Sea Water Intrusion", Water and Sewage Works, June 1977 (with P.L. Hall) Papers -"Investigating Leakage from a Brine Pond", preprint for the Third National Ground-water Quality Symposium", 1977 (with C.J. MacGillvary) I I I I I I I I I I n 0 I ·1 I I I I I GERRY KESTLE, M,A,Sc,, P, ENG, EDUCATION: B.A.Sc. M.A.Sc. University of Waterloo, Undergraduate Degree -Major -Mechanical Engineering, 1970 University of Waterloo, Graduate Degree -Major -Management Sciences, 1977 Completion of 20 workshops and seminars regarding subjects including management, energy conservation, energy, environment, computer programming. EMPLOYMENT: 1985-Conestoga-Rovers & Associates Limited Present 1983-85 1980-83 1970-80 1968-70 1963-68 Manager of Engineering J.M. Schneider, Inc. Plant Engineer J.M. Schneider, Inc. Design Engineer J.M. Schneider, Inc. Student J.M. Schneider, Inc. Student Work Term Bell Camp Corporation, Ingersoll, Ontario AFFILIATIONS: Association of Professional Engineers of Ontario (APEO) American Society of Heating Refrigeration and Air Conditioning Engineers (ASHRAE) \ I I I I I I I I I I I 0 I I I I I I I Gerry Kestle PROFILE OF PROFESSIONAL ACTIVITIES: -Liaison with the Ministry of the Environment regarding programs for air pollution control, process waste water, noise pollution and solid waste disposal for a major Canadian food processor, packer and renderer. -Liaison with Regional Municipality of Waterloo regarding process waste water discharges to the sanitary sewer system, potable water quality and quantity for a major Canadian food processor, packer and renderer. -Liaison with environmental consulting engineering firms regarding air pollution control, process waste water treatment and noise attenuation for a major Canadian food processor, packer, renderer and trucking operation. -Past chairman of Canadian Meet Council -Engineering Committee and Energy Committee. -Past member of Kitchener Chamber of Commerce Committee on local solid and liquid waste disposal concerns. -Past member of Neighborhood Liaison Committee regarding neighbourhood concerns with large food processor, packer, renderer, receiving and shipping operations. -Design and construction of food processing buildings, refrigerated storage and office buildings. -Design and construction of food processor meat smoking operations. -Supervisor of integrated packer and food processor inedible rendering operation. -Design and implementation of energy conservation programs for major Canadian food processor, packer, renderer. -Design of production environments and food processing equipment. -Design and construction of industrial ammonia refrigeration systems. -Design, construction and continuing operation of two groundwater extraction and treatment by air stripping at past semiconductor operation in Santa Clara, California. I I I I I I I I I I I I I a D 0 I I I Gerry Kestle -Design and specification of 1,600 GPM groundwater extraction and discharge system in Wausau, Wisconsin. -Design, construction and start-up of landfill gas control and gas burner for sanitary landfill in Rigly, Wisconsin. -Design and construction of groundwater pumping and treatment system for subsurhce drainage and collection system at Lees Avenue Transit Station, Ottawa, Ontario to control coal tar migration. -Design and specification of a groundwater extraction and treatment system in St. Louis Park, Minnesota. -Design, construction, maintenance and operation of a 2,800 GPM groundwater extraction, air stripping and treated water surface discharge system in New Brighton, Minnesota. -Design and installation of a 800 feet, above ground, double wall insulated and heat traced oil deliver pipe (eight inch carrier -12 inch containment pipe) at IBM site, Poughkeepsie, New York. -Design and construction of an industrial wastewater volatile organic compounds (VOC) removal system including air stripping, VOC collection and destruction by thermal oxidation at color plant in Cincinnati, Ohio. -Design construction, start-up and operation of a landfill leachate collection and pumping system in Waterloo, Ontario. -Design, construction, start-up and operation of a 90,000 gallon storage/ SO gallon per minute residential water supply system. -Design and construction of a contaminated groundwater extraction and forcemain system at pole treatment facility, New Brighton, Minnesota. -Modification of municipal wastewater treatment plant in Sudbury, Ontario including addition of oxidation ditch areators, addition of secondary clarifier and addition of grit removal system. -Design, construction, start-up and operation of a 24,000 dm landfill gas control system at sanitary landfill in Maple, Ontario. I I I I I I I I I I D I I I I I I I I IANY, MCRAE EDUCATION: 1985 1980 1977 1975 1971 Certificate of Completion, Corrosion Prevention and Control, Carboline Company, St. Louis, Missouri. Certificate of Completion, Construction Specification Writing, ATB Courses Inc., Toronto, Ontario. Certificate of Completion, Maintenance and Marine Coatings Technology, Mobil Chemical, Toronto, Ontario. Certificate of Completion, Architectural Hardware Institute, University of Chicago Civil Engineering, 3rd Year, University of New Brunswick EMPLOYMENT: 1986- Present · 1985-86 1984-85 1979-84 1974-79 1974 1972-74 Senior Contract/Specification Engineer Conestoga-Rovers & Associates Specifications Specialist Husky Oil Operations Ltd., Calgary, Alberta Contract Formation Specialist TransAlta Utilities Corporation, Calgary, Alberta Contract Administrator Monenco Consultants Limited, Calgary, Alberta Senior Specification Writer New Brunswick Electric Power Commission, Fredericton, New Brunswick Civil Technician Neil and Gunter Ltd., Fredericton, New Brunswick Surveyor /Estimator Desourdy Construction Ltd., Montreal, Quebec I I I I I I I I I I I 0 R I I I I I Ian V. McRae 1971-72 Technical Assistant Lalonde, Valois, Lamarre, Valois and Associates, Montreal, Quebec PROFILE OF ACTMTIES: -Developed model construction specifications, engineering practices, specification writing practice, and project specifications for the engineering, procurement and construction of a heavy oil upgrader -Evaluated corrosion protection options for structural steel in a petro-chemical environment -Developed risk management criteria for the safe design and operation of an upgrader facility -Reviewed activities of engineering contractors for conformity with established standards and policies -Formulated contract strategy and developed terms, conditions and technical scope for assessing the environmental impact of a hydro-generating complex -Executed requests for proposals and consulting agreements for environmental and engineering studies including coordination of input from environmental, engineering, legal and government agencies -Developed criteria for surveying public opinion of electrical utility service -Supervised preparation of bid and contract construction documents including specifications for nuclear, thermal and hydro generating plants, mining and airport facilities and equipment -Performed contract and purchase order administration including tendering, bid analysis and contract award for public and private sector -Supervised on-site construction contracts for construction of thermal generating station -Developed company-wide specification system including policies and standards and instructed engineering departments on methods of specification writing -Designed tank farm protective coating system and supervised application I I I I I I I g 0 I I I I I I I I I Ian V. McRae -Performed site surveying, estimating and inspection for highway and bridge construction and municipal work I I I I I I I m D D m • I I I I I I I PAYIP DEMPSEY. M, S, EDUCATION B. A. College of St. Scholastica, 1984 M. S. University of Illinois, 1988 Thesis Title: "Synthesis and Characterization of Phosphine Adducts of Copper (I) Alkyls" EMPLOYMENT; Oct. 1988- Present 1988- Oct. 1988 Environmental Chemist Conestoga-Rovers & Associates, Inc. Analytical Chemist SET Environmental PROFESSIONAL AFFILIATIONS: American Chemical Society PROFILE OF PROFESSIONAL ACTIVITIES -Quality Control Officer J. I. Case Corporation Projects Professional activities included data assessment and liaison with project laboratories in support of PCB cleanups and/or underground storage tank (UST) remedial programs -Quality Control Officer Generator (PRP) Group Professional activities included data assessment and direct liaison with the project laboratory for contaminated groundwater assessment program (Carolawn NPL Site, South Carolina) -Quality Control Officer Generator (PRP) Group Professional activities included data assessment in support of a Supplemental Remedial Investigation/Feasibility Study for Wauconda Sand and Gravel, Wauconda, Illinois I I I I I I I I I • D fl I m I I I I I David Dempsey -Quality Control Officer Generator (PRP) Group Professional activities included preparing the QAPP, data assessment and liaison with project laboratories in support of a Rl/FS (Willow Run Sludge Lagoons, Washtenaw County, Michigan) -Quality Control Officer Generator (PRP) Group Professional activities included preparing the QAPP, analytical data assessment and laboratory liaison.in support of the Remedial Investigation/Corrected Measures Study (Wausau, Wisconsin) -Quality Control Officer Generator (PRP) Group Professional activities included data assessment and preparing the QAPP for EP Toxicity characterization of disposed municipal incinerator ash (Miami County Incinerator NPL Site, Miami County, Ohio) -Quality Control Officer Professional activities included data assessment and preparing Sampling and Analysis Plan in support of Groundwater Investigation Project (Synertek NPL Site, California) -Quality Control Officer Professional activities included data assessment and primary liaison with the project laboratory in support of Groundwater Monitoring Plan (TCAAP NPL Site, St. Paul, Minnesota) -Quality Control Officer Professional activities included liaison with the laboratory and data assessment for RI/PS (Charles City, Iowa) -Quality Control Officer/ Chemist Professional activities included technical assistance for ambient air monitoring (T0-1, TO-2), data assessment and liaison with the project laboratory for Rl/FS (Sterling Drugs NPL Site, Cincinnati, Ohio) -Quality Control Officer Generator (PRP) Group Professional activities included data assessment and laboratory liaison for RI/FS (Jadco-Hughes NPL Site, North Carolina) I I I I I I I I I B D D m I I I I I I David Dempsey -Quality Control Officer/Chemist Generator (PRP) Group Professional activities including laboratory coordination and aid in developing protocols for ambient air monitoring program (TO-1), data assessment and liaison with the project laboratory in support of remedial action (Spiegelberg NPL Site, Livingston County, Michigan) -Quality Control Officer/Chemist Professional activities included data assessment and coordination with the laboratory, developing NPDES permit sampling plan and degradation mechanism for organic analytes (Printed Circuits Operations, St. Louis Parks, Minnesota, State listed site) -Quality Control Officer/Chemist Professional activities included data assessment and coordination with the laboratory, technical assistance in developing ambient air monitoring program (T0-1, T0-10), initiating site-specific method detection limit study (Rasmussen NPL. Site, Livingston County, Michigan) -Research Chemist University of Illinois Professional activities included handling highly air sensitive and pyrophoric materials via Schlenck vacuum line techniques, characterizing compounds via lH NMR and heteronuclear NMR (13C, 31p, 63Cu), infrared spectroscopy; X-ray crystallography, elemental analysis. Familiar with atomic absorption, electrochemical analyses (polarography/ cyclic voltammetry), UV/ vis spectroscopy, gas chromatography and mass spectrometry -Analytical Chemist SET Environmental Professional duties included identification of organic compounds via infrared spectrometry and identification of metal complexes via wet chemical methods CONTINUING EDUCATION: "Environmental Laboratory; QA/QC Data Validation" ACS Short Course, September 1989 "Transport Phenomena in Natural Porous Media", University of Minnesota, Fall Quarter 1990 "Twelfth Annual Conference On Laboratory Technology", University of Minnesota, February 13-14, 1991 I I I I I I I m I D I I I I I I I I I David Dempsey PUBLICATIONS: "Copper (P Alkyls. Synthesis and Characterizations of Tertiary Phosphine Adducts and the,Crystal Structure of the Dimethylcuprate Complex [Cu(PMe3)4][CuMe2.]". Girolami, G. S.; Dempsey, D. F., Organometallics, 1988, 7, 1208 PRESENTATIONS: "Effects upon Sample Integrity Due to Well Installation and Materials", T. Chrisfofferson and D. Dempsey, Monitoring Well Course, Minnesota Department of Health, November 1990, Bloomington, Minnesota I I I I I RON S, CAMPBELL EDUCATION:. Environmental Technologist Fanshawe College, London, Ontario, 1978-1981. Three year Co-operative program in Air, Water Resources and Field Technology I EMPLOYMENT: g 0 n I I I I •• I I I I I May 1991- Present February 1989- May 1991 September 1981 - February 1989 January 1981 - May 1981 May 1980- September 1980 September 1979 - December• 1979 Industrial Hygienist, Conestoga-Rovers & Associates Limited, Waterloo, Ontario Operations/Safety Supervisor, Laidlaw Environmental Services Ltd., Guelph, Ontario (formerly Tricil Environmental Management, Waterloo, Ontario) Environmental Technologist/Divisional Safety Supervisor, Ortech International, Mississauga, Ontario (formerly Ontario Research Foundation) Laboratory Technician, Canada Packers, Inc., Toronto, Ontario (College Co-op Work Term) Ontario Research Foundation, Mississauga, Ontario (College Co-op Work Term) Ontario Research Foundation, Mississauga, Ontario (College Co-op Work Term) PROFILE OF PROFESSIONAL ACTIVITIES: -Provide measurement and documentation of workplace exposure levels to various hazardous agents and establish appropriate controls to prevent exposures above permissible exposure levels. -Maintain industrial hygiene and gas detection equipment including staff training on selected equipment, proper calibration and record keeping. -Perform health and safety audits for clients and health and safety training, WHMIS, Regulations respecting asbestos. I I I I I I 0 D I I I I I I I I I I I Ron S. Campbell -Ensure staff training and medical surveillance program requirements are maintained for new hires and existing staff. -Perform on-Site health and safety supervision at hazardous waste sites. -Provide respiratory selection, use, care and fit testing for CRA staff and contractor and client training. -Actively participate in policy making decisions. -Responsible for timely reporting on the status of hazardous waste cleanup projects throughout Ontario, including safety regulations and training, staff scheduling, tracking costs, etc. -C<r0rdinate and schedule staff training specific to health and safety issues. -Specific experience in medical surveillance programs, gaseous monitoring, orientation and WHMIS training for new staff. -Responsible for hiring contract/temporary employees and ensuring that staff comply to company and regulatory policies and procedures. -Chairman of Branch Joint Health and Safety Committee and a member of Laidlaw Environmental Services Corporate Safety Committee of Burlington. -Maintain all health and safety training records, Workers' Compensation Board claims, accident investigations, personal injury reports and unusual occurrences (near miss) reports. -Responsible for purchasing, maintenance, calibration and staff training relating to air monitoring equipment. -Specific experience in performing thorough investigations from serious incidents involving personal injury, gaseous exposure, etc. -Perform emission monitoring from industrial process for gaseous and particulate pollutants across Canada and the United States. -Specific characterization tests of emissions at industrial processes including gaseous emissions (eg. S02, HC, CO, NOx, NCL), particulate and particle size distribution, odour intensity, fugitive emissions, PCBs, Dioxins, furans, etc. -Perform indoor air quality studies for urea-formaldehyde, asbestos, respirable particulate and gaseous ~ontaminants. I I I I I I I D u I I I I I I I I I I Ron S. Campbell -Division Safety Supervisor, which involved workplace inspections, safety instruction to staff, accident report writing and accurate recordkeeping. -Perform project supervision on an extensive methanol vehicle program for Transport Canada at the Motor Vehicle Test Centre located in Blainville, Quebec. TRAINING CERTIFICATES/COURSES; -40 hour OSHA, 29 CFR 1910.120 Certification for Hazardous Waste Operations and Emergency Response -June 1991 -St. John Ambulance First Aid -May 1990 -Ministry of the Environment (MOE) Activated Sludge Course -May 1990 -C.R.S. Confined Space Entry Certificate -April 1990 -WHMIS Awareness Program -Transportation Safety Association (TSA) - March 1990 -Defensive Driving (TSA) -March 1990 -MOE Wastewater Treatment Course -February 1990 -Transportation Dangerous Good Act (TOGA) -January 1990 -Field Level Maintenance for Scott 2.2 SCBA -September 1989 -Supervisory Training Certificate -March 1989 -Modem Safety Management Certificate -February 1989 I 1 I I I I I D I APPENDIX B I DATA MANAGEMENT PLAN I I I I I I I I I I / I I I I I I D m I I I I I I I I I I I TABLE OF CONTENTS B.1.0 INTRODUCTION .................. , ................................................................................... B-1 B.2.0 DATA MANAGEMENT .......................................................................................... B-2 B.2.1 MANAGEMENT OF FIELD DATA ........................................................ B-2 B.2.1.1 Field Logbooks ............................................................................................. B-3 B.2.1.2 Still Photographs and Video Film .......................................................... B-3 B.2.1.3 Audio Cassette Recordings ....................................................................... B-4 B.2.1.4 Computer Diskettes .................................................................................... B-5 B.2.2 MANAGEMENT OF LABORATORY ANALYTICAL DATA .......... B-5 B.2.3 DAT A VALIDATION ................................................................................ B-6 B.2.4 DATA SECURITY ....................................................................................... B-6 B.3.0 DOCUMENT CONTROL. ......................................................................................... B-7 B.3.1 BACKGROUND INFORMATION FILES ................................................. B-7 B.3.2 PRIMARY DATA DOCUMENTS ............................................................... B-8 B.3.3 PROJECT DOCUMENTS .............................................................................. B-9 I I I I I D I I I I I I I I I I I I I B.1.0 INTRODUCTION The Data Management Plan (DMP) presented herein will identify procedures to be employed for managing all information, reports and correspondence (documents) associated with the Remedial Design/Remedial Action (RD/RA) to be conducted at the Jadco-Hughes Site (Site) in Gaston County, North Carolina. These documents may be used as possible evidence in any court proceedings and as the basis upon which government officials will make decisions regarding the protection of human health and the environment. Therefore, these documents must be readily accessible and the integrity and accuracy of these documents must be maintained. This may be achieved by restricting access to the materials and implementing data management procedures. The DMP is comprised of two separate tasks which are: 1) data management; and 2) document control. The data management task consists of procedures used to handle and safeguard all data generated by field and laboratory programs. The task of document control involves implementing procedures to physically track all documents associated with the RD/RA. These two tasks will be expanded upon in the following sections. B-1 I I I I R I I I I I I I I I I I I I I B.2.0 DATA MANAGEMENT Data generated from the field and analytical programs will form the basis upon which all decisions regarding remediation of the Site will be based. Submittal B -Sampling and Analysis Plan (SAP), and Appendix B of Submittal B-Quality Assurance Project Plan (QAPP), present procedures relating to the collection and analysis of samples. The data management task of the DMP presents procedures relating to recording and retrieval of all the field and laboratory data generated. For ease of discussion, the field and laboratory data can be categorized as follows: 1) field data; 2) laboratory analytical data; and 3) quality assurance/ quality control data. These three categories of data and security procedures will be discussed in the following sections. B.2.1 MANAGEMENT OF FIELD DATA Accurate and comprehensive recording of field operations will be achieved through the use of field logbooks, cameras, tape recording devices and computers. B-2 I I I I D B I I I I I I I I I I I I I B.2.1.1 Field Logbooks The field logbook is the primary means of recording Site- related information. Generally, a bound document, the field logbook is used to record all pertinent Site data such as the following: 1) general field observations; 2) field measurements and observations; 3) sample location and corresponding sample number; 4) relevant comments pertaining to the samples collected; 5) weather conditions; 6) a listing of all personnel involved in Site-related activities; and 7) an accurate log of all telephone conversations and Site meetings. The field books generated will be numbered consecutively and maintained in a CRA file where they are not subject to potential damage or tampering. B.2.1.2 Still Photographs and Video Film Still photographs and video documentation provide a means of visually recording Site conditions and operations. To ensure quick and accurate retrieval, all photographs and video films used during Site work will be properly documented, catalogued and stored. Documentation shall consist of the following: B-3 I I I I a I I I I I I I I I I I I I I 1) identification of Site and project; 2) identification of the area and/ or activity photographed; 3) date and time of photograph; 4) photographer's name; 5) weather conditions; and 6) project number. Cataloging of photographs and video films will be done in a manner that ensures ease of accessibility. Storage of the photographs and video films will be in a location where they are not subject to damage or tampering. B.2.1.3 Audio Cassette Recordings On occasion, conditions may exist which will prevent the use of field logbooks. At such times only, an audio cassette tape recorder will be used. Information recorded on the cassette will be transcribed into the field logbook within one week of making the recording. The recorded cassette then will be consecutively numbered, logged and stored. The tapes will be logged as to the date and purpose of the recording. Provisions will be made to store the tapes so that they are protected from magnetic fields, temperature extremes, reuse and tampering. B-4 I I I I g I I I I I I I I I I I I I I B.2.1.4 Computer Diskettes At this time, it is envisaged that all analytical and field survey data will be compiled on 3 1;2-inch hard discs. In all cases where Site data is stored on discs, a backup copy of each computer diskette will be maintained. Each computer diskette will be consecutively numbered, identified as a primary or backup diskette, and identified as to the contents. The computer diskettes will be cataloged and stored as per the audio cassette tapes. Backup diskettes will be stored separately from primary diskettes. B.2.2 MANAGEMENT OF LABORATORY ANALYTICAL DATA Chain-of-custody protocols will be used to transport the samples to the contract laboratory and to track the samples during the analytical program, as discussed in Submittal B -SAP and Appendix B of Submittal B -QAPP. Copies of the generated chain-of-custody forms will be maintained by both the contract laboratory and CRA. The contract laboratory will provide the data on a computer diskette in addition to the hard copy print. The computer diskette provided by the contract laboratory will be numbered, cataloged and stored as discussed in Section B.2.1.4. The contract laboratory will maintain the integrity of their database through their own internal security procedures. B-5 I I I I m D I I I I I I I I I I I I I B.2.3 DATA VALIDATION Validation of the data will be performed in accordance with the quality assurance/ quality control (QA/QC) program as detailed in Appendix B of Submittal B -QAPP. Laboratory supervisory personnel and CRA's QA/QC officer will conduct the data validation. The data will be manually screened as well to isolate any spurious data not detected by the QA/QC program. B.2.4 DAT A SECURITY The integrity and confidentiality of the data generated during the RD/RA will be maintained by restricting access to the data. Only personnel actively involved in the project will be permitted access to the data. It will be the responsibility of these same personnel to ensure that the original documents are not mutilated or destroyed. B-6 I I I I I 0 R • I I I I I I I I I I I E.3.0 DOCUMENT CONTROL Documents used for and generated during the RD/RA will be stored and maintained in a unique project file. These documents will be maintained and stored for a minimum of six years following termination of the 106 Order, consistent with the judicial order under Section 106 of the Comprehensive Environmental Response, Compensation and Liability Act between USEPA and the Committee, signed on June 19, 1991. Access to the documents will be restricted to personnel actively engaged in the project and procedures will be implemented to track the documents . The documents to be covered by the document control procedures can be categorized as follows: 1) background information files; 2) primary data documents; and 3) project documents generated during the course of the project. These three categories will be further discussed in the following sections. B.3.1 BACKGROUND INFORMATION FILES The background information for the RD/RA consists of the following: B-7 I I I I • u R I I I I I I I I I I I I 1) field notes from previous Site sampling programs; 2) hazard ranking system (HRS) package; 3) background information files from the Jadco-Hughes Steering Committee; 4) the 106 Order dated June 19, 1991; 5) background information collected by CRA (RI and FS reports); and 6) miscellaneous correspondence. These documents will be included in the document control system. B.3.2 PRIMARY DATA DOCUMENTS Primary data documents for the RD/RA may consist of the following: 1) field logbooks; 2) analytical reports; 3) chain-of-custody forms; 4) regulatory agency correspondence; 5) Jadco-Hughes Steering Committee correspondence; 6) personnel medical records; 7) logs of meetings and telephone conversations; 8) quality assurance/ quality control data; 9) inventory of samples collected; 10) Site plans and data diskettes; and B-8 I I I I I I 0 0 I I I I I I I I I I I 11) survey notes. These documents will be included in the document control system. B.3.3 PROJECT DOCUMENTS Project documents include the monthly reports and all reports generated during the RD/RA and submitted to USEPA. These documents will be included in the document control system. B-9