NCD991278953_19860801_National Starch & Chemical Corp._FRBCERCLA RI_Draft Work Plan for the Remedial Investion Feasibility Study-OCR

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WORK PLAN
FOR THE
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
NATIONAL STARCH AND CHEMICAL CORPORATION
Cedar Springs Road Plant
Salisbury, North Carolina
IT CORPORATION
312 Directors Drive
xville, Tennessee 37923
August 1986
1
IJ rn INTERNATIONAL II TECHNOLOGY
CORPORATION
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WORK PLAN
FOR T:-lE
REMEDIAL INVESTIGATION/FEASIBILITY STUDf
NATIONAL STARCH AND CHEMICAL CORPORATION
Cedar Sp~ings Road Plant
Salisbury, North Carolina
IT CORPORATION
312 Directors Drive
xville, Tennessee 37923
Au~ust ·, 986
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145-11-85
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CONTENTS
1.0 INTRODUCTION
2.0
3.0
1.1 Objective
1 . 2 Background
REMEDIAL INVESTIGATION
2.1 Preparation of Work Plan (Task 1)
2.2 Preparation of Health and Safety Plan (Task 2)
2.3 Preparation of Quality Assurance Performance Plan (Task 3)
2.4 Preparation of Community Relations Plan (Task 4)
2.5 Preparation of Project Operations Plan (Task 5)
2.6 Topographic Survey (Task 6)
2.7 Survey of Seeps and Springs (Task 7) 1
2.8 Geophysical Survey (Task 8)
2.9 Assemble Existing Data Base (Task 9)
2. 10 Incorporate New Data Base -Revise Work Plan (Task 10)
2. 11 Review Meetings ( Tasks 11 , 18, 24) ~
2.12 Construct Ground Water Monitoring Wells ask 12)
2. 13 Ground Water Sampling and Analysis (Tas 13)
2.14 Surface Water/Sediment Sampling and Ana ysis (Task 14)
2. 15 Geochemical Testing (Task~
2.16 Risk Assessment (Task 16)
2.17 Identify Remedial Action A ternatives (Task 17)
2.18 Prepare RI Rep~ and FS Work Plan (Task 19)
FEASIBILITY STUDY r\
3. 1
3.2
3.3
3.4
3.5
3.6
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en Remedial Action Alternatives (Task 20)
el ct Most Cost-Effective Alternative (Task 21)
o ceptual Design (Task 22)
repare FS Report (Task 23)
Prepare Final Report (Task 25)
Project Administration (Tasks 26, 27, 28, 29)
4.0 SCHEDULE
APPENDICES
HEALTH AND SAFETY PLAN A.
B. QUALITY ASSURANCE PROJECT PLAN
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Number
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Number ----
FIGURES
Site Vicinity Map
Site Location Map
Sample Location Map
Shallcw Well Construction
Deep Well Construction
Hazardous Substance List
Schematic Drawing of Long-Term Permeability
System·
Project Assignment Schematic
Schedule
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Monitor We~menclature
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1 . 0 INTRODUCTION
In March 1985, the Environmental Protection Agency (EPA) proposed the National
Starch and Chemical Corporation (NSCC) Cedar Springs Road site in Salisbury,
North Carolina (the site) for inclusion on the National Priorities List (NPL)
under the authority of the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA), better known as Superfund. The rulemaking on the
site is not final and the site remains proposed for the NPL. NSCC has
retained IT Corporation (IT) to investigate and assess the potential problems
at the site in accordance with EPA Region IV format and guidelines established
for Super fund.
A Remedial Investigation/Feasibility Study (RI/FS) is an estabfed EPA
procedure for Superfund sites that is used to determine the most cost-
effective remedial action alternative for site mit~tion. This work plan was
prepared by IT to discuss the nature and extent orhe tasks required to
accomplish the RI/FS for the site. These tasks have been identified as the
essential steps in obtaining valid datl\.o develop and evaluate remedial
action responses and are in agreement,::;;,h the principles established in the
EPA guidance documents
under CERCLA.
investigations and feasibility studies
1.1
The objecti of this Remedial Investigation (RI) are to:
Determine the nature and extent of ground water, surface water, and
sediment contamination on and adjacent to the site
• Determine the attenuative and adsorptive properties of the shallow
saturated media
Determine and describe on-site and off-site features that could
affect the methods of containment or cleanup
Determine whether the site poses an imminent hazard to public health
or the environment.
These objectives will be accomplished through an assessment of the existing
conditions by using available data and the results of the tasks described in
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this work plan. The remedial investigation will include: mapping of the site
and surrounding area; a geophysical survey; a hydrogeologic investigation;
geochemical testing of shallow subsurface soils; and environmental sampling
and testing of ground water, surface water, and sediments.
The objectives of the Feasibility Study (rS) are to:
Develop and evaluate the feasibility of various remedial action
alternatives, including a review of treatment technologies
• Recommend the most cost-effective remedial action alter~ative(s) for
approval
Prepare a conceptual design of che remedial action altTr tive(s)
selected.
1.2 BACKGROUND ~
The NSCC Cedar Springs Road Plant was built beg inn· in December of 1970.
Initially it was operated as Proctor Chemical, as bsidiary of NSCC. The
merger into NSCC took place on January{\ 1983. The plant produces chemicals
for use in the textile and furniture ~stries, and specialty chemicals are
also produced. a
The NSCC Cedar Springs R!ad,Plant is located on approximately 465 acres within
the city lirft} of Salisbury in Rowan County, North Carolina.
is presenteµn Figure 1. A location map is shown on Figure 2.
A vicinity map
The site is situated on saprolitic soils formed on top of decomposing
dioritic/gabbroic rocks of Paleozoic age. Near-surface soils are generally
silty clays which extend down to approximately 10 feet. Subsurface soils are
predominately silty sands and sandy silts, extending down to the felsic
bedrock. Depth to bedrock was noted in the 1977 exploratory test drilling as
being 40 feet below the ground surface along the eastern side of the waste
burial area.
The water table beneath the waste burial area varies from 12 to 35 feet below
the ground surface, fluctuating seasonally. Direction of flow generally
follows the topographic relief, with shallower water tables appearing along
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" 11< J..,1\ J ,,--;;,, .....
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e Cedar Springs Road Plant
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Figure 1
Vicinity Map
Cedar Springs Road Plant
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Property Line Figure 2
Location Map
Cedar Springs Road Plant
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the slopes and deeper water tables existing at the top of the hill immediately
east of the waste burial area. Subsequently, the direction of flow within
this unconfined aquifer is generally southwesterly, following the surface
gradient toward a tributary of Grants Creek which lies west of the site. Some
ground water discharge is occurring along the gullies and streams dissecting
the hilly terrain. These springs are probably situated near the
saprolite/bedrock interface.
Surface waters on and directly adjacent to the waste burial area flow into
Grants Creek via an unnamed intermittent stream. Directional flow of the
overland runoff west of the waste burial area is southwesterly along several
gullies which dissect the hill and then westward along the intef:mi tent
stream. Areas east of the waste burial area exhibit a northea rly overland
flow direction into another intermittent stream which flows nort westerly into
Grants Creek. G
The site includes chemical manufacturing facilitieI, a wastewater treatment
system, treatment lagoons, and approxirA_ely two acres of trenches used to
bury 350,000 gallons of D002 hazardou~ste. D002 hazardous waste is defined
as corrosive waste, in t7:'.?"ase, having a pH equal to or less than 2.0. The
wastes were buried in 3 Jo~ wide by 10 foot deep trenches during 1971 to
1978. When percolation in one trench decreased, the trench was filled with
excavated s(i'i)and a similar trench was dug a few feet away. This procedures
continued u~l approximately two acres of trenches were excavated.
The wastes buried on site include salt brines, sulfuric acid solutions,
sulfonating fats and oils with deminimus concentrations of heavy metals such
as lead, chromium, zinc, and some organic constituents including triallyl
ethers, -1,2-dichloroethane, 1,2-dichloropropane, 2-methyl-l-pentanol,
methanol, toluene, and xylene.
In 1977 the North Carolina Department of Environmental Management conducted a
survey of the site and drilled test borings to determine if contamination had
occurred. Analysis of the ground water samples showed higher than normal
background levels of various contaminants, including chloride, sodium iron,
and high levels for specific conductance. It was concluded that the ground
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water was contaminated, with potential contamination of surface waters
indicated.
NSCC conducted an additional sampling phase of six on-site monitoring wells
(installed in NSCC in 1976) in September of 1984. The sampling phase analysis
showed that organic contamination of Well No. 1, which was located in the
middle of the trench area, included toluene, xylenes, 1,2-dichloroethane, 1,2-
dichloropropane, allyl alcohol, allyl ether, and triethylphosphate.
Concentration levels of these organics ranged from 0.8 to more than 180 parts
per million (ppm). The analysis also indicated some organic contamination in
Wells 2 and 3. Both wells are located to the west of the burial mound area.
The well located to the south of the burial area, Well No. 4, i~ct· ated very
little or no contamination; but it should be noted that this we is usually
dry. There was no evidence of any organic contamination in Well 5 and 6,
both located east of the waste burial mound. r
Five residential wells located within two miles of the Cedar Springs Road
Plant were sampled. Analytical result{\howed no evidence of volatile organic
compounds or priority pollutants. · r
Well 5 was installed imm~tely downgradient of two holding lagoons located
south of the main plant building. During the summer of 1984, roughly 2000
cubic yards(or)contaminated soil was removed from beneath these lagoons as
they were bb,r{g lined with concrete. The initial scope of the RI/FS is being
expanded to address potential subsurface contamination around the lagoons.
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2.0 REMEDIAL INVESTIGATION
This section describes the various tasks that will be required to complete the
RI at the NSCC Cedar Springs Road Plant. The RI will be conducted in a multi-
phase approach with subsequent investigative phases to be conducted only if
data deficiencies exist after each phase is complete. Objectives of each
phase will be established before implementation. Sufficient data, however,
will be gathered to support the feasibility study and its findings.
The objectives of Phase I are:
To determine if contaminants are present in the groundia er, surface
water, or sediments
To define the direction and rate of movement of any con aminant
plumes
To determine, through
contaminant plumes or
subsurface
geophysical techniqr:;:-, if any conductive
other anomalies exi~s~ithin the burial area
To determine if the bedrock ~er is contaminated
To determine, thph aquifer testing, in situ hydraulic
conductivities the relationship of the shallow and bedrock
aquifer
To~ermine the attenuative and adsorptive capacity of the saturated
sul/"ial geology
To determine if the site is posing an imminent hazard to the
surrounding public and environment
To define the scope of the subsequent investigation, if necessary.
The tasks listed in this section will constitute the successful completion of
a Phase I study.
Following the completion of Phase I, any data gaps or further investigative
activities will be initiated as Phase II. The objectives of Phase II will
include, but are not limited to the following:
To define the extent of contamination beyond Phase I
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To address the nature and e:stent of off-site contaminant migration
To make detailed study of the n=ber and location of off site ground
waste receptors
To address the nature and extent of possible bedrock contamination.
A complete list of Phase II objectives cannot be made until after the Phase I
investigation is comoleted. Phase II objectives will be defined and refined
as the Phase I investigation is completed and the need, if any, for additional
data becomes apparent.
At the conclusion of Phase I investigative activities, NSCC and IT will
prepare the RI report. This report will present the conclusio~at
II RI is necessary or will advise that the FS may be initiated. I
2. 1 PREPARATION OF WORK PLAN (TASK 1) ~
a Phase
Preparation of a formal work plan is the first taf for successful completion
of a Remedial Investigation/Feasibil~·t Study (RI/FS). This work plan
describes all work to be completed to isfy the requirements of an EPA
sanctioned RI/FS. All tasks include in this work plan will be completed by
NSCC. Additions and delQ,ns to this work plan can be made pending approval
from NSCC and the EPA, Rbg~n IV.
2.2 HEALTH AND SAFETY PLAN (TASK 2)
A Health and Safety Plan (HSP) was generated for the NSCC Cedar Springs Road
Plant RI/FS and is included as Appendix A to this Work Plan. The field
activities associated with this work plan will be conducted in strict
adherence to the requirements of the HSP. The HSP is subject to revision and
updating on an as-needed basis and specifies the type of protective gear site
personnel should wear to minimize their exposure to hazardous materials on
site. The level of protection required may vary with the type and location of
the field tests being performed.
2.3 PREPARATION OF QUALITY ASSURANCE PERFORMANCE PLAN (TASK 3)
A Quality Assurance Performance Plan (QAPP) was generated and is submitted as
Appendix B. The QAPP is a separate document from the work plan. The purpose
of the QAPP is to document the procedures that will be undertaken to ensure
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the precision, accuracy, and completeness of the data generated by IT during
the RI investigations at the NSCC Cedar Springs Road Plant. The QAPP is
subject to revisior. and updating on an as-needed basis. The project sampling
plan has been included as Appendix A of the QAPP and is likewise subject to
revision and updating based on site specific requirements.
2.4 PREPARATION OF COMMUNITY RELATIONS PLAN (TASK 4)
EPA, Region IV will take the lead community relations role for all public
relations activities occurring in conjunction with this study. At its
discretion, NSCC will augment the community relations work conducted by EPA
and
and
will supply
the RI/FS.
EPA pertinent information to educate the public on the site
NSCC will be present have
representation independent of EPA or
at any public meetings and7 1
its assigned contractor. -I
IT will be available to support NSCC in the follow~areas:
Public Meeting Material --Supply the matlrial, data, or information
necessary to re"spond to the p'f"\.ic concerning RI/FS activities.
Project Updates --Supply NSc/:('::ith appropriate data and information
to periodically~te the community about project status, current
information, an s eduled activities.
Public Notices Public notices for community related events
pe'()ning to the RI/FS will be reviewed for technical accuracy.
AdditionallVrT will review the Community Relations Plan (CRP) prepared by
EPA and will provide NSCC with comments related specifically to the site.
2.5 PREPARE PROJECT OPERATIONS PLAN (TASK 5)
A Project Operations Plan (POP), generated by IT, will serve as a direct
extension of the RI/FS Work Plan but will be submitted as a separate document
from the work plan. The POP defines the exact field methods and protocols to
be used for the remedial investigation phase of the Rl/FS. The POP will be
approved by EPA Region IV before any field sampling activities are
initiated. All field work, as directed by the work plan, will be carried out
in accordance with the POP.
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2.6 TOPOGRAPHIC SURVEY (TASK 6)
A topographic survey will be conducted before field work is initiated. This
survey will result in two maps from which to coordinate field activities. The
first will be of the NSCC area with a scale of 1 inch= 200 feet. The second
will be of the trench burial area with a scale of 1 inch= 50 feet. These
base maps are needed to:
Assist in field operations
Develop, screen, and select remedial action alternative(s)
Present the findings of this investigation.
These maps will be of sufficient areal extent to illustrate the extent of
contamination and to show the location of all sampling points, ~orientation
of all remedial actions considered, and the mean sea level topogtaphy on
5-foot contour intervals.
2.7 SURVEY OF SEEPS AND SPRINGS (TASK 7) r
A visual survey of the gulleys, low ar~, and stream beds immediately
adjacent to the landfill area will berducted to determine if seeps or
springs exist. If found, these seeps or springs will be sampled and tested in
the field for pH and con~ivity values because of the low pH and high
conductivity of waste p14ce~ in the burial trenches.
This data ,Qbe used in determining the extent and possible direction of
leachate mcWment in the shallow subsurface soils and will play an important
role in locating the proper positions for the monitoring wells.
2.8 GEOPHYSICAL SURVEY (TASK 8)
A geophysical survey will be conducted in the trench area to identify and
trace subsurface migration routes of conductive fluids. The survey will
include the trench burial mound, the area south of the mound toward the
areation basin, and the area west of the burial mound as far as necessary and
practical to trace the contaminant plumes.
The geophysical survey will consist of measurements of electromagnetic (EM)
conductivities supplemented with some vertical electrical soundings (VES).
readings are the most efficient means for defining the boundaries of a
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EM
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conductive leachate plume, while VES measurements give improved resolution of
the vertical conductivity profile and allow for optimization of the EM coil
spacing to be used in the field.
Results of the geophysical survey will be used to optimize the location of the
monitoring well network. An attempt will be made to map the leachate plume(s)
and to correlate the geophysical results with specific geologic units at the
site. A bedrock contour map will also be prepared.
2.9 ASSEMBL~ EXISTING DATA BASE (TASK 9)
A review of NSCC files, the records of the North Carolina Department of
Environmental Management and the Department of Human Resources,~id and
Hazardous Waste Management Branch, and EPA Region IV has been co4ducted by
IT. From these files, two reports have been generated that provide a synopsis
of the existing data base and give overall views o0ite background and
history. These reports are: r
• Uncontrolled Hazardous Waste I\,_ Ranking for the National Starch and
Chemical Corporation Site, b-rr;'Corporation, June 1985.
Synopsis: On D~er 21, 1984, an uncontrolled hazardous waste
ranking evaluat· n f the NSCC trench burial site was conducted by
Greg Fraley, Re ion IV, Environmental Protection Agency (EPA). The
sco~derived from that particular ranking was proposed as a base for
re o ending that the NSCC site be placed on the National Priorities
Lit NPL) of Superfund sites. An additional uncontrolled hazardous
si e ranking was done by IT at the request of NSCC. This ranking
represented another evaluation of the NSCC trench burial site using
the same uncontrolled hazardous waste site ranking system. This
ranking was based on the same information and database EPA used.
Final Report, National Starch and Chemical Corporation Site, Forward
Planning Study, January 14, 1986.
Synopsis: The purpose of this report was to provide the EPA with a
description of the current situation at the site. This included a
description of the site and its environmental setting along with a
summary of the data collected from previous site investigations.
Camp Dresser and McKee (COM) found deficiencies in the existing data-
base, the worst of which was the lack of a comprehensive
investigation of potential subsurface underground water
contamination.
In addition, IT will contact the United States Geologic Survey (USGS) to
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obtain additional information, if available, regarding site geological and
hydrogeological characterization. ~ell logs may also be available from the
USGS. IT will also contact local licensed well drillers who may have worked
in the area to obtain first hand information on well installation, aquifer
characteristics, and well logs from nearby wells. IT will contact local
officials in the Rowan County Health Department to verify figures already
released regarding the number of nearby ground water well users, uses of
Grants Creek, and other information related to potential receptors.
2.10 INCORPORATE NEW DATABASE-REVISE WORK PUN (TASK 10)
New data will be analyzed and reviewed for its appropriateness in
accomplishing the tasks set forth in the RI/FS. This includes ;,rr geophysical
survey, survey of seeps and springs, and final topographic map at well as data
from Task 9. Depending on the new data and its impact, the scope of work for
the RI/FS may be altered. The magnitude of these ~nges will dictate whether
a revised work plan is required. Any proposed moctj'rications to the work plan
will be submitted for approval before ~ceeding
2.11 REVIEW MEETINGS (TASKS 11, 18, ~•
with the work plan.
Three meetings will be s~led to
attended by the IT prograF' ~nager,
discuss the RI/FS. These meetings will be
project manager, selected technical
personnel, aizrepresentatives from NSCC. The first meeting will take place
after thew rk plan has been approved. The purpose of this meeting will be to
go over all spects of the RI/FS, inform NSCC of IT mobilization requirements
and needs for the remedial investigation, solicit input from NSCC on
implementation of the RI activities, and update the project schedule and
budget.
The second meeting will be at the conclusion of the RI. Subjects to be
discussed should include, but not be limited to, the field and laboratory
investigations, findings of the site evaluation, and recommendations regarding
whether to proceed with the feasibility study. A list of potentially feasible
remedial actions for NSCC will be developed. On the basis of this meeting, an
agreement will be reached on the potentially feasible remedial action
alternatives to be evaluated in the initial screening of alternatives.
Depending on the number, type, and complexity of the proposed remedial action
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PROPERTY
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alternatives, the scope of work for the FS may have to be altered. The
magnitude of these changes will dictate whether a revised work plan is
required.
The third meeting will be held at the conclusion of the FS. Discussion will
include the results of this investigation, data developing procedures that
were followed, remedial alternative screening, and the conceptual design of
the selected alternative.
2. 12 CONSTRUCT GROUND WATER MONITORING WELLS (TASK 12)
Fifteen additional monitoring wells will be installed around the perimeters of
the trench burial area and the lagoon area. These wells will i~de 12
shallow saprolitic aquifer monitoring wells and three deep bedr~1~.aquifer
monitoring wells. Figure 3 shows the well locations and Table 1 lists the
well nomenclature. r The shallow wells will be screened in the water-bearing intervals of the
saprolitic sequence, which varies in t~kness from 10 to 40 feet beneath
site. It is assumed that the ground Jr;;:r flow within this shallow zone
the
follows the surface topo&ic relief, with the flow being southwest at the
trench area and east benrt~ the lagoons. The total depth of each well is not
expected to exceed 55 feet, with anticipated water table depths varying from
10 to 35 feoeneath the ground surface.
A total of nine shallow wells will be installed around the trench burial
area: five along the western portion of the trenches and four along the
eastern boundary. The locations east of the trenches will be northwest of the
northeast corner (Well NS-01), northeast of the trench area midpoint (NS-02),
northeast of the southeast corner (NS-03), and south of the southeast corner
(NS-04). Wells NS-02, -03, and -04 are located along the expected ground
water flow lines and are intended to determine if ground water contamination
has occurred beyond the ground water divide thought to exist east of the
trench area. Well NS-01, an upgradient well, is not situated along any
suspected ground water flow line leaving the waste burial area. The well
locations west of the trench area will be southwest of the aeration basin well
(NS-05), west of the southwest corner (NS-06), west of existing Well No. 2
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Well Number
NS-01
NS-02
NS-03
NS-04
NS-05
NS-06
NS-07
NS-08
NS-09
NS-10
NS-11
NS-12
NS-13
NS-14
NS-15
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Table 1. Monitor Well ·Nomenclature
Depth
(ft)
50
50
50
50
50
50
50
50
50
50
50
50
100
100
100 ~
Location
Upgradient shallow, northeast of trench area
Downgradient shallow, east of trench area
Downgradient shallow, east of trench area
Downgradient, southeast of trench area
Downgradient, southwest of trench area
Downgradient, southwest of trench area
Downgradient, west of trench area
Downgradient, west of trench f
Upgradient shallow, northwest f trench area
Upgradient shallof:w west of lagoon area
Downgradient sha w, west of lagoon area
Downgradient sha low, east of lagoon area
Upgro/'\ent deep, northeast
Dow~ient deep, west of
Upgradient deep, northwest
of trench area
trench area
of trench area
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(NS-07), west of existing Well No. i (NS-08), and northwest of the northwest
corner (NS-09). Wells NS-05 through NS-08 are located along expected ground
water flow lines directly downgradient of the waste burial area. Well NS-09
will serve as an additional upgradient well and is not along any anticipated
ground water flow line leaving the trench area.
Three shallow wells will be installed around the lagoon area. These locations
will include one upgradient well (NS-10), positioned west of the lagoon area,
and t"o downgradient wells (NS-11 and NS-12), positioned along the northeast
and southeast corners, respectively.
The three deep wells will be installed north, northwest, and we~f the
trench burial area and will be screened in the upper water-beari1g structures
of the igneous bedrock. Total depth of each deep well is not expected to
exceed 100 feet. The wells will be located north ~the northeast corner (NS-
13), west of existing Well No. 2 (NS-14), and nortfest of the northwest
corner (NS-15), NS-13, and NS-15 will be topographically upgradient of the
trench area and will be installed adja/Ji..t to the background wells NS-01 and
NS-09, respectively. NS-14 will be dJ:;;;radient of the trench area and will
be installed beside NS-07f'.<
The borehole for each shallow well will be drilled by using 6-inch diameter
hollo_w stem~ers and will be drilled to the top of the igneous bedrock. If
bedrock is ,kl encountered within the expected 55-foot depth, the well will be
completed at that depth or after a 10-foot column of ground water has been
noted (whichever is shallower).
The deep wells will be drilled and rock-cored with an air or mud rotary rig
and will be completed at the 100-foot depth, or whenever a 20-foot column of
bedrock water is encountered (whichever is shallower).
The shallow wells will be constructed of 2-inch inside diameter, flush-joint,
threaded, stainless steel pipe with 10-foot screens (see Figure 4, shallow
well construction). All screens will be constructed of 0.02-inch slot-size
stainless steel and will be placed within each well at appropriate depths to
allow the inflow of water at and 1 foot above the water table for seasonal
NEW:48-2 2-8
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ID ID
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FV C CAP --=-=~-:-=----j~~~l
CONCRETE COLLAR~
LOCKING SECUFllTY COVER
PROTECTIVE STEEL CASING
EXISTING GRADE·--=----"7r-:-'c,,---k-'~'1--,,
, y'>://>;(
BENTONITE/
CEMENT GROUT --.....J/
SOLID RISER , 2'
STAINLESS STEEL __ _,,
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STAINLESS STEEL CAP/
Ff
WELL SCREEN
2' STAINLESS STEEL
(0.02' SLOT SIZE)
FIGURE 4
1
GRAVEL PACK
SHALLOW AQUIFER MONITORING WELL CONSTRUCTION
DIAGRAM
NOT TO SCA:._E
~ < IT CORPOnATION rn ... Creatmo a Saler Tomorrow :;: ALL COPYRIGHTS RESERVED
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fluctuations. A gravel pack will installed around and 1 foot above the screen
and topped with 2 feet of bentonite pellets. A bentonite/cement slurry will
then be placed by means of a tremie pipe from the top of the pellets to about
3 feet below the ground surface to seal the annulus. A 4-inch diameter
protective casing with locking cap will be installed, and the remainder of the
hole will be grouted with neat cement. Each riser ,1ill be fitted with a
slotted cap to permit the venting of gases and equilibration to atmospheric
conditions. A sloped cement apron will be placed around the casing to prevent
runoff from entering the well.
The deep wells will be constructed in similar fashion, except that 2-inch PVC
riser will be used for the upper 50 to 60 feet interval (see Fit:u 5, deep
well construction). Additionally, an outer PVC casing (approx1m tely 8-inch
diameter) will be installed and grouted in place before bedrock rilling.
This will seal off the shallow saprolitic aquifer ~will prevent any mixing
of the upper shallow zone with the deeper bedrock e. A dedicated stainless
steel/Teflon bladder pump system (Well Wizard Mode -1200 with Purge Mizer
Model 4200) will be installed in each AP well for development, purging, and
sampling purposes. r
All wells will be fully ~oped by pumping or bailing until the fluid runs
clear. Stainless steel or Teflon bailers will be used on the shallow wells,
and dedicat~umps will be used on the deep wells. Water levels will be
allowed to ,k/ilibrate over a suitable time. Measurements of static water
level also will be taken.
All drilling tools, equipment, well materials, and rig will be steam cleaned
before entering the site, and all equipment will be steam cleaned between
borings. Cleaning protocols are specifically outlined in the Project
Operation Plan. Additionally, all drill cuttings and wash waters will be
contained and drummed for eventual disposal (following a review of ground
water sample data).
The drilling and well installation will be supervised by a qualified
hydrogeologist or geotechnical engineer. A qualified HNU/OVA operator will
also be on site to monitor the gases escaping from the borehole during the
drilling process.
NEW:48-2 2-9
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"7 ~ " " N N o, o,
~ ~ ,..., (~ . "
-LOCKING SECURITY COVER PVC C,\P -------(1~~~=----~ PROTECTIVE STEEL CASING CONCRETE COLLAR-..... ~
/
BENTONITE/
CEMENT GROUT----..~
D . I
STAINLESS STEEL CAP
EXISTING GRADE
1-----8' PVC OUTER CASING
----

-
---SHALLOW WATER TABLE
WELL SCREEN 2'
STAINLESS STEEL ·
(0.02' SLOT SIZE}
FIGURE 5
1
f
GRAVEL PACK
DEEP AQUIFER MONITORING WELL CONSTRUCTION DIAGRAM
NOT TO SCALE
; ~ IT CORPORATION
~ A.l.l COPYRIGHTS RESERVEO w ... Creatino-a Sater Tomorrow
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All monitoring wells will be surveyed to a vertical accuracy of 1/100 foot to
provide a base reference of subsequent ground water measurements or additional
investigations.
2.13 GROUND WATER SAMPLING AND ANALYSIS (TASK 13)
Following installation, development, and stabilization of the 15 ground water
monitoring wells, a two-phase ground water sampling and analysis program will
be undertaken to determine the degree and extent of ground water contamination
in the vicinity of the Cedar Springs Road Plant.
The first phase of the ground water sampling will occur after ~as been
determined that the wells are stabilized. The stabilization perfod may be
four to eight weeks. The second phase will occur during the next quarter.
Samples will be collected from all 15 monitoring wrs.
Before sampling, each well will be pro7f>:rly purged to remove stagnant water
from the well casing and allow the col tion of a representative ground water
sample. This will involve the removi g of three-to-five well volumes from
each well, until the pH ~conductivity stabilizes. It may be necessary to
purge lesser volumes fro(s}owly recharging wells. Purging will be
accomplishe(l either bailing (shallow wells) or pumping (deep wells).
All ground Ur samples will be obtained, preserved, documented, and shipped
in accordance with the guidelines established in the sampling plan (QAPP-
Appendix A) and will follow the provisions of the QAPP and the Project
Operations Plan.
Samples will be analyzed for the following parameters: metals (Al, Sb, Ar,
Ba, Be, Cd, Ca, Cr, Co, Cu, Fe, Pb, Mg, Mn, Hg, Ni, K, Se, Ag, Na, Th, V, and
Zn), semi-volatiles (base neutral/acid extractables), pesticides, PCBs,
cyanide, and phenols along with select general chemistry parameters (TDS, pH,
specific conductivity, and chloride). These parameters are listed in greater
detail in Figure 6.
NEW:48-2 2-10
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Figure 6
IT CORPORATION
HAZARDOUS SUBSTANCE (CLP) LIST
Acetone
Benzene
Bromodi chl oromethane
Bromof orm
Bromomethane
2-Butanone
Carbon disulfide
Carbon tetrachlorider
Chlorobenzene
Chloroe0ne
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
Dibromochloromethane
l,l~Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethene
trans-l,2-Dich1oroethene
VOLATILE ORGANICS
Subsidiary of IT Corporation
1,2-Dichloropropane
cis-1,3-Dic~opropene
trans-1,3-Diciloropropene
(1£thyl benzene
rz-Hexanone
4-Methyl-2-pentanone
Methylene chloride
Styrene
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Tri ch l oroethene
Vinyl acetate
Vinyl chloride
Xyl enes, total
IT Analytical Service,· 5815 Middlebrook Pike· Knoxville. Tennessee 37921 • 615-588-6401
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Figure 6 (continued)
IT CORPORATION
HAZARDOUS SUBSTANCE (CLP) LIST
BASE NEUTRAL EXTRACTABLE ORGANICS
Acenaphthene
Acenaphthyl ene
Anthracene
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluor-0nthene
Benzo(a)pyrene
Benzo(g,h,i}perylene
Benzoic acid
Benzyl alcohol
Benzyl butyl phthalate
bis(2-Chloroethoxy)methane
bis(2-Chloroethyl)ether
bis(2-Chloroisopropyl)ether
bis (2-Ethylhexyl )phthalate
4-Bromophenyl phenyl etr<
4-Chloroaniline
2-Chloronaphthalene
4-Chlorophenyl phenyl ether
Chrysene f9
Dibenzo(a, ) thracene
Di benzofur
Di-n-butylphthalate
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
3,3'-Dichlorobenzidine
Diethyl phthalate
Dimethyl phthalate
2,l--Di nitrotolueq.e
2,6-Dinitrotolu
Di-n-octylphthala e
Fluoranthene
Fluor e
Hex c lorobenzene
Hex chlorobutadiene
Hex chlorocyclopentadiene
Hexachloroethane
lndeno(l,2,3-cd)pyrene
lsophorone
2-Methyl naphthalene
Naphthalene
2-Nitroani line
3-Nitroaniline
4-Nitroaniline
Nitrobenzene
N-Nit rosodi -n-p ropy l amine
N-Nitrosodiphenylami ne
Phenanth rene
Py rene
1,2,4-Trichlorobenzene
ACID EXTRACTABLE ORGANICS
4-Chloro-3-methylphenol
2-Ch l oropheno 1
2,4-Dichlorophenol
2,4-Dimethylphenol
2, 4-Di nit ropheno l
2-Methy 1-4, 6-di nit rop heno l
2-Methylphenol
4-Methylphenol
2-Nitrophenol
4-Nitrophenol
Pentachlorophenol
Phenol
2,4,5-Trichlorophenol
2, 4, 6-T rich l oropheno 1
Subsidiary or IT Co:poration
IT Analytical Services• 5815 Middlebrook Vike • Yu~oxville. Te:rnessee 37921 • 615-586-6401
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Figure 6 (continued)
IT CORPOIU.TION
HAZARDOUS SUBSTANCE (CLP) LIST
PESTICIDES AND PCB'S
Aldrin
a-BHC
B-BHC
-y-BHC ( 1 i ndane)
6-BHC
. Ch 1 ordane
4,4'-DDT
M'-DDE
lw''-DDD
Dieldrin
a-Endosulfan
B-Endosulfan
Endosulfan sulfate
Subsidiary ot IT Corporation
Endrin1
Endrin ketone
Heptachlor
Heptachlor epoxide
Methoxych 1 or
PCB-(Aroclor)-1242
PCB-(Aroclor)-1254
PCB-(Aroclor)-1221
PCB-(Aroclor)-1232
PCB-(Aroclor)-1248
PCB-(Aroclor)-1260
PCB-{A~oclor)-1016
Toxaphene
ITAnalytical Serv1ces • 5815 Middle:::,rook f'i.ke •Knoxville.Tennessee 37921 • 615-588-6401
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IT CORPORATION
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
(,a1t
Copper
I ran
Lead
Cyanide
Figure 6 (continued)
HAZARDOUS SUBSTANCE (CLP) LIST
METALS
CLASSICAL PARAMETERS
Subsidiary oI IT Corporation
Maglum
Manga ese
Mercury
Ni eke 1
Potassium
Selenium
Si 1 ver
Sodium
Thallium
Vanadium
Zinc
IT Analytical Services· 5815 Middlebrook Pike • Knoxville. Tennessee 37921 • 615-588-640 !
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In addition to the sampling activities, aquifer response tests will be
performed on up to six of the shallow s1ells. The rising head method will most
likely be used. This test involves removing a known volume from the well,
causing the water level to fall. The subsequent rise in head is measured as a
function of time. Upon plotting these two variables, the value of the
hydraulic conductivity at that particular point in the aquifer can be
obtained. Pumping tests will be performed on each deep well to determine if a
water-level response can be noted in its companion shallow well. These pump
tests will utilize low-volume pumping rates and may be modified for future
Phase II investigations, if necessary.
2. 14 SURFACE WATER/SEDIMENT SAMPLING AND ANALYSIS (TASK 14) ~
To determine the nature and possible extent of contaminant migrafion from the
site, three surface water and five sediment samples will be collected from
tributaries northeast, northwest, and west of the f!Jnch area (see Figure 3,
sample location map). Two locations will be both fediment and surface water
(SE/SW-1, SE/SW-2, and SE/SW-3). These samples will be collected, packaged,
and shipped in strict accordance with A requirements of the QAPP. Surface
water samples will be grab samples; sfument samples will be taken from the
top four inches of sedimr:Q Sample analysis will be the same as specified in
Section 2.13 with total fus~ended solids added for the general chemistry
chemistry parameters are not to be run for sediment
2. 15 GEOCHEMICAL TESTING (TASK 15)
A geochemical testing procedure is described herein to assess the attenuative
and adsorptive capacity of the soil in the saturated zone of the saprolite.
Ground water is the predominant mechanism by which contaminants will
potentially move off site. By understanding the soil attenuative and
adsorptive phenomena of the soil in the surficial aquifer within the
saprolite, contaminant mobility can be characterized. The following tasks are
proposed to accomplish the above objectives:
NEW:48-2
Permeant and soil sample selection and materials characterization
Column testing for determination of attenuative and adsorptive soil
capacity
Data evaluation.
2-11
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A sample of unccntam:~ated soil will be placed in a long-term permeability
testing system (Figure 7). The uncontaminated soil will be taken from the
saturated zone of the surficial aquifer. A permeant of contaminated ground
water will be leached through the soil sample to evaluate the attenuative and
adsorptive capacity of the soil. Periodic chemical analyses of the permeant
reservoir and permeant effluent will be run to monitor the leaching
procedure. An initial chemical analysis of the soil will be run to define
original conditions with the same test to be run on four aliquots of the final
soil sample. The test is anticipated to take 4 to 5 months.
2. 15. 1 Permeant and Soil Sample Selection and Materials Charac ization
Three soil samples will be selected from within the unconsolidat d saturated
saprolite. The samples will be collected in an uncontaminated area and will
be undisturbed. Shelby tubes will be used to co11f6 the three samples. The
samples will be sealed and shipped to IT's Geotechf'ical laboratory in Export,
Pennsylvania for materials characteriznons, which will include grain size
analysis, water content (to evaluate r loss from saturated condition),
neutralization potential, unit weight, and total organic carbon. The soil
sample selected for the a~uation/adsorption test will -be tested for the
hazardous substances listr(~L) volatile organic compounds and inorganic
analyses inEl ing pH, arsenic, cadmium, chromium, lead, and silver.
sample will th n be used as a representative sample to evaluate the
attentuativ and adsorptive properties of the saturated saprolite.
This
The permeant to be used will be the most contaminated ground water found at
the site. This is anticipated to be the ground water in the NSCC monitoring
Well No. 1 located near the center of the trench burial area. This ground
water sample will be analyzed for the HSL volatile organic compounds, total
organic carbon, and the inorganic analysis previously described.
2. 15.2 Column Testing for Determination of Attenuative and Adsorptive Soil
Capacity
An undisturbed sample of uncontaminated soil will be selected from material
within the aquifer. The soil sample will be cut to shape, placed in a
triaxial cell, wrapped with Teflon, and enclosed in a latex membrane. The
NEW:48-2 2-12
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CELL PRESSURE
SOURCE
(COMPRESSED AIR)
t--CHECK WlLVE
I -TAP
WATER
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ALUMINUM ALLOY ( TOP AND BOTTOM) -"
PLEXIGLASS CELL "i1
PRESSURIZED CELL FLUID :
1 POLYETHYLENE TOP CAP 11
POROUS STONE AND FILTER P6PER
TEST SAMPLE ENCASED IN LATEX ME.MBRANE
POROUS STONE AND FILTER PAPER
POLYETHYLENE BOTTOM PEDESTAL
II
II
II
~
,n
ij
-.,,-'' " ~
-ATMOSPHERIC DIFFERENTIAL
BACK PRESSURE SOURCE
~>--GRADUATED BURE TTE FOR
~ PERM~A EFFLUENT
,;-COL TION
.;.
~ .;:
--'tr' ,.»-...:....:.......,..lol...:.L...ll.,.-:111_..J! rn~~--3-WAY VALVE FOR
-PERMEANT EFFLUENT
SAMPLING z
3: ► <! <D a:
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BACK PRESSURE SOURCE
COMPRESSED AIR~
CHECK VALVE 7 p~
...
-
..____ POLYETHYLENE TUBING
D c: .. ,, """"v-0_1_R __ _,
~ ·:1~..: -~,.)~0('10,.J.".'".('"i ~ .:.._:_ :c,o,,A,,-•,--; QESE~'.'ED
FIGURE T
SCHEMATIC DRAWi NG
LONG-TERM PERMEABILITY
TESTING SYSTEM
(ONE SAMPLE SHOWN)
rn . Creating a Sater Tomorrow
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uncontaminated soil sample will be initially permeated with a standard 0.01N
calcium sulfate (CaS04) sobtion (EPA, 1980) to determine a reference
permeability before switching to the contaminated site ground water (as
described in EPA, 1980, "Test Methods for the Permeability of Compacted Clay
Soils: Constant Elevated Pressure Method," in Living of Waste Impoundments
and Disposal Facilities, SW-870, pp. 264-269). Once steady-state flow
conditions are achieved, the permeant will be replaced with contaminated
ground water to simulate site conditions. During permeation, time and flow
data will be recorded to measure the flow rate of permeant through the sample.
A chemical analysis of the permeant effluent will be performed at approxi-
mately each one-half pore volume of flow for the first two por:,.f'lumes and
for each pore volume of flow thereafter. The effluent will be aralyzed for
the following parameters:
•
•
•
•
pH
Specific conductance
HSL volatile organic
Arsenic
Cadmium
Chromium
Lead
Silver.
r
compoun~
Indicator tT4 (pH and specific conductance) will be conducted
pore volume~nt at each half pore volume of flow.
after the two
The influent reservoir will be chemically characterized for the same
parameters as the permeant effluent at the beginning of the study,
periodically during the study, and at the end of the proposed study.
Once saturation of the attenuative capacity of the soil is achieved or
approximated, the study will be terminated and the system will be dis-
mantled. Saturation of the soil is indicated when the chemical concentrations
in the effluent approximate influent concentrations. The physical dimensions
of the sample will be measured to calculate permeability, and the influent
reservoir will be sampled and analyzed for the same chemical parameters as the
permeant effluent. Four soil samples will be collected from the test column
NEW:48-2 2-13
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at the end of the study and analyzed for the same parameters as the permeant
effluent to evaluate the attenuative capacity of the soil. Soil samples will
be collected at the following intervals along the soil column:
The influent/soil interface (bottom of the soil column)
One-third of the soil column height
Two-thirds of the soil column height
The effluent/soil interface ( top of the soil column).
2. 15.3 Data Evaluation
A final report will be prepared at the conclusion of the study to present the
data and to evaluate the attenuation and adsorption potential of the aquifer
soil.
The following results will be presented in plots,
of the date evaluation and discussion:
Soil permeability
figures, and lies as part
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Materials characterization r~r:J,,_ts
Long-term attenuation/adsorpr characteristics.
2. 16 RISK ASSESSMENT (T
A level 1 Qualitative Ri
6)
sessment of the NSCC site will be conducted by
!T's risk assessment group. The tasks involved will include: a review of
existing da(a]identification of toxic constituents and relative mobilities,
and preparaL-/ri of a letter-type report that will contain recommendations for
more detailed analyses, if necessary.
A Level 1 endangerment assessment will characterize the physical description
of the site and identify contaminants detected or suspected to be at the
site. A brief discussion of the toxic properties of the contaminants present
will be presented to determine if imminent hazards or significant risk of harm
to human life or health or to the environment may exist or does exist.
2. 17 IDENTIFY REMEDIAL ACTION ALTERNATIVES (TASK 17)
The objective of this task is to identify and develop a set of viable remedial
action alternatives for mitigating site conditions. These alternatives must
be appropriate for each pathway and contaminated environmental medium at the
NEW:48-2 2-14
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site. The identified remedial alternatives will be consistent with both the
remedial investigation findings and with the objectives and criteria developed
during the site risk assessment. Key project members will confer and
collectively select additional alternatives and decide upon preliminary
evaluation criteria. Alternative technologies will be evaluated as to
appropriateness based on identified site-specific constraints and
opportunities. A preliminary list of three to five remedial alternatives will
form the basis for subsequent feasibility study activities. This list is not
concrete and can be added to or subtracted from as additional data beco~e
available. The no action alternative will be included in the remedial
alternatives to be evaluated.
2. 18 PREPARE RI REPORT AND FS WORK PLAN (TASK 19) 1
A draft RI report will be prepared to consolidate and summarize all the data
collected during the RI. Included in this report rJ'1 be a discussion of the
procedures followed during the RI, findings of thersite evaluation, and an
~:::~:~e:i:: ::c~r;::s::v:::~dial act,~alternatives. This report will be
If the data collected in~e that a FS is needed, a draft FS work plan will
also be prepared. This fa~ will address the scope of the FS and the various
tasks that must be completed during this phase of the project.
D
NEW:48-2 2-15
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3.0 · FEASIBILITY STUDY
A FS will be conducted following the RI of the NSCC Cedar Springs Road site to
develop and evaluate the feasibility of various remedial action alternatives
and to prepare a conceptual design of the selected alternative.
3.1 SCREEN REMEDIAL ACTION ALTERNATIVES (TASK 20)
The objective of this task is to evaluate the remedial action alternatives .and
select three to five alternatives or combinations of alternatives for further
evaluation and analysis. In order to assess the alternatives, site specific
screening criteria will be prepared by addressing the following factors:
Economic --Both capital and operating costs will be cfidered
Environmental Effects --Any adverse impacts on public health and/or
welfare or the surrounding environment wh~might be associated with
an alternative will be considered r
Engineering --Each alternative must be technically feasible in light
of site location and conditi~must be applicable to project needs,
must be a reliable method of ing the problem, and take only a
relatively short time to imp ement.
The level of detail devel~ to facilitate these evaluations
sufficient to identify comparative or relative, not absolute,
among the aBnatives.
will be
differences
Once the list of remedial action alternatives has been reduced to a workable
number, key project members will confer and collectively select additional
alternatives and decide upon preliminary evaluation criteria. The preliminary
list of remedial action alternatives will form the basis for subsequent
feasibility study activities. This list is not concrete and can be added to
or subtracted from as additional data become available. The no-action
alternative will be included in the evaluation and will serve as a base line
to which other alternatives can be compared.
NEW:48-3 3-1
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3.2 SELECT MOST COST-EFFECTIVE ALTERNATIVE (TASK 21)
The refined, narro~1ed range of remedial action alternatives will undergo a
final assessment for overall viability. Each option will be evaluated from an
engineering, ecoromic, and environmental viewpoint. These viewpoints are
discussed below:
•
•
Engineering Assessment --The engineering aspects of the alternatives
will be assessed on the basis of acceptable engineering practices.
Specific factors to be evaluated include:
-Reliability
Technical feasibility for the site location
-Suitability to control the problem
-Risks to construction and health and safety of operational
personnel 4-
-Constructibility and operability in light of site con itions
Maintainability
-Off-site transportation and disposal capacity requirements.
Economic Assessment --Order of magnituder-::;:-nstruction and operation
and maintenance (O&M) costs will be estimj:i:;d for each remedial
action alternative. The comparative cost impacts of health and
safety requirements on constVP:ion, and continuing operation and
maintenance, will be included · the cost estimates. After
completion of these calculat ons, a present worth analysis will be
conducted for ea~lternative.
Environmental A e ment --The environmental criteria on which each
alternative will be evaluated are:
-~on adverse environmental impacts of the alternatives
f ctiveness of remedial measures to mitigate existing or
tential adverse impacts
-Adequacy of source control measures
-Public acceptability
-Institutional issues (implementation capabilities)
-Legal issues (environmental permits).
The alternatives will be ranked within each assessment category, and overall
rankings will be prepared reflecting all three categories (envi~onmental,
economic, and engineering). This ranking will be based on professional
judgment and will reflect the input of state and local authorities and the
public. The most cost-effective solution for mitigating the adverse effects
the site may have on the public health and environment will be identified.
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3.3 CONCEPTUAL DESIGN (TASK 22)
The following task addresses the conceptual design requirements, and is
intended to allow for the preparation of the most cost-effective remedial
action alternative. The following conceptual design elements will be
developed as required for the remedial actions selected:
3.4
Review of the community relation concerns and environmental impacts
(beneficial and adverse) of the remedial actions
An order-of-magnitude capital expenditure and annual O&M cost
estimate
Estimate of time and materials required to implement the remedial
action alternative selected
Estimate of costs required to prepare final engineeri~lans
Conceptual design criteria and rationale
Construction of remedial action alternate(
Discussion of operation and maintenance procedures
Discussion of potential consftion problems
Suggested solutir, to these problems
Preliminary profc~ schedule.
REPORT (TASK 23)
A draft fea · ility study report will be prepared summarizing the findings of
the feasibility study. The draft will include the preliminary list of
alternatives and discussions of the prescreening process, redefined
alternatives, details of their evaluation, and the ranking process. In this
report, one alternative or a combination of alternatives will be recommended
to NSCC. The draft FS report will be submitted to NSCC for review, and a
final report will be prepared incorporating NSCC review comments.
3.5 PREPARE FINAL REPORT (TASK 25)
A draft final report surmnarizing the remedial investigation, the selected
remedial action, and the conceptual design effort will be prepared and
submitted to NSCC for distribution to the appropriate personnel. The Task 24
Review Meeting discussed in Section 2.11 of this Work Plan will be scheduled
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within 30 days of submittal of the draft final report. Written review
comments and input received during this meeting will be incorporated into the
report. Six copies of the final report will be submitted to NSCC.
3.6 PROJECT ADMINISTRATION
3.6. 1 Project Management (Task 26)
The management of the NSCC RI/FS will be in accordance with the Project
Organization Chart shown in Figure 8.
The project will be managed on a day-to-day basis by the IT project manager,
who will ensure that the project is managed in an organized andficient
manner. The project manager will see that the staff working on he project
has definitive assignments and the necessary support and equipme t to conduct
their tasks properly. The project manager will ma?1e the multidisciplines
involved in the RI/FS to ensure that all disciplinry teams coordinate their
work to take advantages of each other's efforts an □ thereby avoid duplication
of work. The project manager will sch~le disciplinary teams for field work
and will also serve as the local cont/(;'for analytical services. The project
manager will track the pr~t budget and schedule and will be the primary
client contact. The projfc~manager will be responsible for preparing and
submitting all invoices and monthly reports.
The programoager will provide oversight to the project manager and will
ensure that the appropriate technical staff members are assigned to the
project. The program manager will monitor the project, making sure that the
technical requirements of each task are met and to ensure the technical merits
of the scope of work are satisfied. The program manager will advise and
consult with the project manager as the job progresses and will be responsible
for the success of the overall project effort.
3.6.2 Communitv Relations Activities (Task 27)
A community relations specialist will be assigned to the job to supplement
community relation efforts undertaken by EPA. The community relations
specialist will work closely with NSCC to inform and educate the public and to
support the community relations activities conducted by EPA. When necessary,
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Project Coordinator, NSCC
Mr. Hank Graulich
(Mr. Alex Samson)
IT Program Manager NSCC Plant Manager -
Cliff Vaughan Mr. Ray Paradowski
Health and Safety IT Project Manager Quali~ 'Assurance/ -'---Ouali· v Control
Bob Nash Randy Alewine De Tl Mack r
\
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Remedial Investigation, ,. Community Relations Analytical Feasibility Study
I, Services
Tom Smith Deborah Carnes Jack Hall Randy Alewine
l)
Figure 8
PROJECT ASSIGNMENT SCHEMATIC
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community relations activities will include reviewing EPA media releases for
clarity, accuracy, and completeness before they are released to the public;
responding to public inquiries on NSCC's behalf; and representing NSCC at
public meetings.
3.6.3 Health and Safety Activities (Task 28)
Health and safety activities will be handled by a health and safety offi~er.
The health and safety officer will have overall responsibility for preparing
the HSP, ensuring that it is being fully implemented in the field, and
modifying when necessary. The health and safety officer will report to the
program manager and will be on site when RI activities start up and thereafter
as needed or as necessary based on IT Health and Safety
3.6.4 Quality Assurance Activities (Task 29)
policy.1
A QA officer will be assigned to this project to e(e that the project
quality remains high throughout all RI/FS activiti . The QA officer will
conduct audits, as necessary, throughout the proje t to ensure that all
elements of the QA Project Plan are imrf'\mented. The QA officer will also be
responsible for investigating and res~g any errors, mistakes, or omissions
in any aspect of the projr:, The QA officer will report to the project
manager and will work witr~m on a day-to-day basis to maintain overall job
quality.
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4.0 SCHEDULE
The RI/FS will be conducted in accordance with the schedule shown in
Figure 9. All phases of the investigation will be broken down into the
appropriate tasks as shown. The RI/FS is expected to take approximately 24
months to be completed. It should be noted, however, that unanticipated
delays could be encountered because of subcontractor scheduling problems,
regulatory agency review, or inclement weather. In the event that such
problems can be foreseen, IT will notify NSCC of the pending delay and will
respond in accordance with NSCC directives.
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·--

-
.. -l!!l!!!!I -rn CORPORATIOll
SIS 11:11 =a Siilil a.a &ii ilii --
M O ll TH s .
DESCRIPTION OF WORK
8/l 9 /1. lO'l I'/1. a'l 4,tL 6'l 8/l T/l r/1. 2/l 4/l 6/l 8/l/88
l 2 4 6 8 lO l2 1!1 16 l8 20 22 24
Task l. Prepare Work Plan ~e' t,:' . .... ....
-I'\ ----------------------Task 2 ., •..: r-J
Prepare Health & Safety Plan -I 11 ------------------------Task 3 Prepare Quality -=-.. }Assurance Perfori:nance Plan ..... "'.
I Task 4 ---I---------I--Prepare Community ,:a, ::", Relations Plan
Task 5 Prepare Project .A ~ -------I-
Operations Plan i-~ ;:
Task 6 Topographic Survey ----------------Task 7 Survey of Seeps .. .
and Snrinus ~
'l'ask 8 Geophysical Survey I--~ -· ---..., -~
Task 9 Assemble Existing I-----
Data Base ....
Task 10 Incorporate Rev
Data Base-Revise Work Plan -' Task ll Review Meeting -' ..
Task l2 Construct Ground --
Water Monitoring Wells "
Task 13 Ground Water ----
Sampling & Analysis -.... •• .. --\
Task 14 Surface Water/ -
Sediment SRmnlin!!'. & An..lvsis
REMARKS: Tom Smith r A OJ EC r SCHEDULE "If work plan is approved by EPA prior to MADE BY:
Nov. l5, 1986, Task l2 will begin vi thin DATE: , Q: A-----·t 1°<>6 FOR: National Starch and Chemical Corporation
2 weeks. If vork plan is not approved by
Nov. 15, 1986, drilling vill not commence l AST REV. DATE' Work Plan
until February, 1987. Figure 9
JOB llO. l108Q2l1. 01 SIIEET .l ·OF 2
---------· --&!!!!19 --liiiiii iiii liiiii -rn CORPORATIOtl
MONTHS
.
2/l/ 2/l/ 8/l/ .
DESCRIPTION OF WORK
9/.l. :o'l 1m 87 4/l 6/l 8/l DI.I. 1m 88 4/l 6/l 88
) 4 (; R 7 7 7 2 14 16 l 20 22 21,
Task 15
Geochemical Testing ----

-
-'fusk 16 ' --

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----·--

-

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-

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Risk Assessment r--
Task l7 -

-
---

-
-----

-
--

-
----------·---

-
-Identify Remedial
Action Alternatives
Task 18 -

-
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Review Meeting .....
I) ---

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I-· --

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-

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-

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-

-
I--Task 19 Prepare RI Report .IA.
& FS Work Plan -

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-------

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-------

-
-

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·-Task 20 Screen Remedial
Action Alternatives """ Task 21 Select Most Cost --.
Effective Al terna ti vc -Task 22 'v-· Conceptual Design
Task 23 --

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Prepare FS Report
Task 211
Review Meeting -h ....
Task 25 --

-
-----' Prepare Final Report -Tasks 26, 27, 28, 29
Project Management I
-~ --'
REMAn5s: . • EPA, i:.,• .... eno1'e reV1ew of document by NSCC, MADE BY: Tom Smith r R OJ EC r SCHEDULE .... · or both. FOR:
·-,.. ;Indicates task may occur during this DATE: 18 Anunst. 1986 National Starch and Chemical Corporation
.. time Work Plan
Task 4 -No schedule shown since EPA bas LAST REV. DATE'
lead on community relations. NSCC/IT has Figure 9
support role only. JOO NO. 40092li.01 SIIEET 2 OF 2
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NEW:4O
HEALTH AND SAFETY PLAN
FOR 1
NATIONAL STARCH AND CHEMICAL CORPORrON PROJECT
Augt.,986
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CONTENTS
1. 0 PURPOSE
2.0 SUMMARY
3.0 ASSIGNMENT OF RESPONSIBILITIES
4.0 MEDICAL PROGRAM
5.0
6 .0
7.0
8.0
9.0
10.0
11. 0
12.0
EMERGENCY MEDICAL TREATMENT
TRAINING AND INFORMATION
INDUSTRIAL HYGIENE MONITORING AND PERMISSIBLE EXPOSURE
LIMITS
PERSONNEL PROTECTIVE EQUIPMENT
GENERAL SITE SAFETY REQUIREMENTS
SAFE WORK PRACTICES f) HEAT STRESS
DECONTAMINATION r
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A-1
A-1
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A-2
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A-3
A-5
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A-7
A-8
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1 .0 PURPOSE
The purpose of this plan ~-s to set forth minimum requirements for heal th and
safety for this site investigation.
2.0 SUMMARY
This Health and Safety plan has been prepared to cover the National Starch and
Chemical Corporation site investigation which will cover well construction and
well water sampling. Work conditions at the site may vary as work progresses
and require modification of this
without prior approval of the IT
Department.
plan. No changes to this plan4 Corporation (IT) Health and Saffty
r 3.0 ASSIGNMENT OF RESPONSIBILITIES
3. 1 HEALTH AND SAFETY .REPRESENTATIVEP
be made
The Health and Safety Co~ator will be responsible for development and
coordination of the sitera1'ety and health program. This program will comply
with established IT procedures in all aspects and will include medical
surveillancQraining requirements, hazard assessment, personal protective
·equipment, audits.
3.2 PROJECT SUPERVISOR
The Project Supervisor will be responsible for implementation of the safety
and health plan. This will include communicating requirements of the plan to
all personnel and supervision, and consulting with the OSH representative
regarding appropriate changes to the health and safety plan.
3.3 SITE WORKERS
All project workers will be responsible for understanding and complying with
all site requirements.
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4.0 MEDICAL PROGRAM
Current preemployment and periodic/update screening medical examinations will
be continued for those persons working on or those who may be assigned to work
on this project and with the potential contaminants on site. IT medical
requirements are consistent with OSHA 1910.1000 standards for possible
exposure on this site to chlorinated hydrocarbons such as chloroethane and
dichloropropane. The following are included in the medical exam:
•
•
Medical and occupational health history requirements
Physical examination
Urinalysis
Complete blood count with differential
Liver function test (SMA-20)
Audiometric examination in keeping with OSHA noise
Chest X-ray
Pulmonary function test
EKG for employees over age 45, or where fcally indicated.
In addition, blood lead measurements u~r 1910. 1025 may be required. All
subcontractor personnel must have sue fully completed an examination
similar to the IT preplacement physic 1. This medical surveillance shall be
provided by the subcontrfr.
0 5.0 EMERGENCY MEDICAL TREATMENT
5. 1 The following resources can be reached by dialing [phone] which is
the Central Dispatch number and the personnel there will connect the caller to
the appropriate service in case site personnel suffer an injury or illness.
Emergency ambulance service
F'ire department
• Hospital
• Police.
5.2 A physician familiar with occupation medicine will be identified before
job start-up. This physician will be knowledgeable in the chemical on site,
and will be used as a consultant in the event of a job-related illness.
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5.3 If an injury/illness is the result of a chemical exposure, a supervisor
shall promptly initiate the steps necessary to identify the chemical(s). Such
information shall be made available to the treating physician and the OSH
Department.
5.4 Any injury or illness will require the completion of IT Form 9300. 1.-1,
"Supervisors Employee Injury Report'' (Figure A-1), in accordance with IT
Procedure 9300. 1.
5.5 Any injury/illness not limited to a first aid case will require that the
IT project supervisor immediately notify the IT OSH Department. This will
allow the coordination of internal resources to
in rendering appropriate care.
assist the trearg physician
6.0 TRAINING AND INFORMA~
6. 1 GENERAL TRAINING REQUIREMENTS
IT employees and subcontractors
program which shall inclf as a minimum,
have completed a formal training
the following:
Basic Safety Training -This course stresses fundamentals such as the
ca~and prevention of slip, trip, and fall hazards; safe lifting
tet,"'ques; heat stress illnesses and their prevention; etc.
Hazards and Protection -This course deals with the identification,
recognition, and safe work procedures of toxic materials. The use
and limitations of applicable protective clothing, respirators, and
decontamination procedures are an important part of this course.
Respirator fit testing is given to each attendee.
First Aid and Cardiopulmonary Resuscitation -A large portion of IT
employees have completed these standard Red Cross First Aid and CPR
courses.
6.2 CHLORINATED HYDROCARBONS
All employees (including subcontractor personnel) who are subject to exposure
to chlorinated hydrocarbons that may be encountered on the National Starch and
Chemical site shall complete a formal training program which shall include, as
a minimum, the following:
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Informat:on on the contents of the OSHA 1910. iOOO standard relating
to chlorinated hydrocarbons found on the site
The specific nature of the operations which could result in exposure
to chlorinated hydrocarbons above the threshold exposure limits
The purpose, proper selection, fitting, use, and limitation of
respirators applicable to the work
• A description of the medical surveillance program, and information
concerning the adverse health effects associated with excessive
exposure to various chlorinated hydrocarbons
The engineering controls and safe work practices associated with the
employee's job assignment.
6.3 LEAD 1
All employees (including subcontractor personnel) who are subject to exposure
to inorganic lead shall complete a formal training~gram per OSHA Standard
1910.1025 and IT Procedure 9551.2a including: r
Information on the content of/\ A 1910.1025 standard relating to
inorganic lead F
The specific nata of the operations which could result in exposure
to lead above t~~reshold exposure limits
A sription of the medical surveillance program and information
co ce ning the adverse health effects associated with excessive
ex ure to inorganic lead
The engineering controls and safe work practices associated with the
employees' job assignment.
6.4 TAILGATE SAFETY MEETINGS
A detailed job site Tailgate Safety Meeting, in accordance with IT Procedure
9540. 1, shall be conducted each morning at the job site before work begins.
Information covered shall be safety concerns that may be encountered during
the day, and information on the toxicity and potential hazards associated with
other major chemical contaminants at the job site in addition to lead,
chromium, toluene, xylene, 1,2-dichloroethane, 1,2-dichloropropane,and
methanol. Safety meeting information shall be recorded on a Tailgate Safety
Meeting form (Figure A-2) and posted in the work area.
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6.5 MATERIAL SAFETY DATA SHEETS (MSDS)
Complete MSDSs, prepared in accordance with IT Procedure 9552, using OSHA Form
20, shall be posted in the work area.
7.0 INDUSTRIAL HYGIENE MONITORING AND PERMISSIBLE EXPOSURE LIMITS
7.1 PERSONNEL EXPOSURE MONITORING
Personnel exposure monitoring may be conducted while the health and safety
representative is on site. Results shall be used to assess exposures and
govern personal
include xylene,
protective equipment. Compounds being monitore~r will
toluene, 1,2-dichloroethane, 1,2-dichloropropanef lead, etc.
7.2 INDUSTRIAL HYGIENE MONITORING
Results of industrial hygiene monitoring and surve~nce will be compared
with the OSHA permissible exposure limY\(PEL) for the above chlorinated
hydrocarbons. Direct reading instrumr_ion such as HNU may be used for
immediate readings during,)?illing operations.
7 . 3 EYE AND SK IN CONT ACr
Eye and skiD'ntact with the agents listed above shall be prevented.
8.0 PERSONAL PROTECTIVE EQUIPMENT
8. 1 RESPIRATORY PROTECTION
For this site investigation work, air purifying half-face respirators equipped
with combination organic vapor/dust, mist, and fume cartridges will be worn.
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Respirators shall be properly cleaned and maintained according to
OSHA regulation 1910.134 on respiratory protection
As a minimum, air purifying cartridges shall be replaced at the end
of each shift
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Employees wearing air purifying respirators will be required to
change cartridges whenever an increase in breathing resistance or
breakthrough is detected
Only employees who have had pre-issue qualitative fit tests will be
allowed to work in atmospheres where respirators are required
If an employee experiences difficulty in breathing during use he, or
she, will be examined by a physician to determine whether the
employee can wear a respirator while performing the required duty
• Employees who wear respirators shall be allowed to leave work areas
to wash their face and respirator facepiece as needed to prevent skin
irritation associated with respirator use
Facial hair that might interfere with achieving a good facepiece seal
is prohibited.
8.2 PROTECTIVE CLOTHING 1
8.2. 1 Drill Operators
Protective clothing for this site investigation wor'shall be as follows for
drill operators on site: ~ Disposable polye~lene-coated Tyvek coveralls
Nitrile outer gir~ with inner latex surgical gloves
Neoprene boots
Go0s or safety glasses shall be worn at all times in the work area
(C1;;f'amination Zone) (Contact lenses shall not be permitted in the
contaminated area)
Hardhat
Sleeves shall be taped to gloves and cuffs tapped to boots
Leather work glove may be worn as outer protection but left in the
contaminated area.
8.2.2 Sampling Personnel
Protective clothing for water sampling and sample preparation workers is as
follows:
Viton outer gloves with latex surgical undergloves
• Hardhat
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Goggles or safety glasses
8.2.3 Upgrading or Downgrading of Selected Protective Equipment
Upgrading or downgrading of selected protective equipment will be the decision
of the health and safety representative and will be based on his assessment of
exposure potential.
9.0 GENERAL SITE SAFETY REQUIREMENTS
9.1 SITE ZONES
The site will be divided into three zones as follows: 1 Contamination Zone -This zone will include all areas within a 10-
foot radius of the drill rigs. This zonefh the highest inhalation
exposure potential and/or presents a high obability of skin contact
with cutaneous or percutaneous chemicals.
Contamination Reduction ZoneiThis zone will include the areas
between a 10-and 15-foot rad·u of the drill rigs. This zone has
the next highest inhalation ard but does not have a high
probability of skin contact ith cutaneous or percutaneous chemicals.
Clean Zone -ThiQne covers all areas beyond a 15-foot radius of
the drill rigs. rAierse exposure to chemicals is unlikely.
A decontamirC:lon area shall be positioned at the entrance to the
Contaminati~eduction Zone with a step-off area just inside the
Contamination Reduction Zone. All personnel entering or leaving this zone
shall pass through these areas to don or doff their protective equipment.
9.2 SECURITY
The work area shall be marked off with barricades and barricade tape, as
necessary during drilling. Signs shall be posted around the area stating:
AUTHORIZED PERSONNEL ONLY
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Site drilling shall comply with the following rules:
• Before drilling or excavation work, the existence and location of
underground pipes, electrical equipment, etc. must be determined.
This shall be done, if possible, by contacting the appropriate
utility company or plant maintenance personnel to mark the location
of these lines.
No ignition sources are permitted if the ambient airborne
concentration of flammable vapors exceeds 10 percent of the lower
explosive limit (LEL) when core drilling. A combustible gas
indicator shall be available to make this determination.
Operations must be suspended and corrective action taken if the
airborne flammable concentration reaches 40 percent of LEL in the
immediate area (a 1-foot radius) of the point of drilling.
Operations must be suspended and corrective action taOif the
flammable vapors exceed 10 percent of the LEL at a di~~rnce greater
than 2 feet from the point of core drilling.
Combustible gas readings of the general f area shall be made as
necessary.
SArE l PRACTICES
All personnel shall be to wash hands and face before leaving the job
site if theCJa is
breaks.
contaminated. Hands and face shall be washed during
As appropriate, equipment on site shall be bonded and grounded, spark proof,
and explosion resistant.
All personnel shall avoid contact with potentially contaminated substances.
Monitoring equipment shall not be placed on potentially contaminated surfaces.
field personnel must observe each other for signs of toxic exposure.
Indications of adverse effects include, but are not limited to:
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Changes in complexion and skin discoloration
Changes in coordination
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Changes in demeanor
Excessive salivation and pupillary response
Changes in speech pattern.
Field personnel shall be cautioned to inform each other of non-visual effects
of toxic exposure such as:
Headaches
Dizziness
Nausea
• Blurred vision
• Cramps
• Irritation of eyes, skin, or respiratory tract.
Prompt remedial action shall be taken
hazardous material occurs.
whenever an inadvertent rfse of a
Appr·opriate action to provide secure footing shallr;:::::' taken at all locations
where personnel will be working. r,
Provision must be made for cleaning gr{::.contamination from boots and suits
in the Contamination Redu~n Zone, or the contaminated clothing or equipment
must be placed in plasticr~s for disposal.
Decontamina~ assistance personnel shall be appropriately clothed in the
same level vrotective equipment as the Contamination Zone workers.
Copies of this Health and Safety Plan, and representative MSDSs shall be made
available at the work site.
11.0 HEAT STRESS
Adverse climatic conditions are important considerations in planning and
conducting site operations. Ambient temperature effects can include physical
discomfort, reduced efficiency, personal injury, and increased accident
probability. Heat stress is of particular concern while wearing impermeable
protective garments, since these garments prevent evaporative body cooling.
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All appropriate precautions regarding heat stress shall be met. One or more
of the following control measures can be used to help control heat stress:
• Provision of adequate liquids to replace lost body fluids. Employees
must replace water and salt lost from sweating. Employees must be
encouraged to drink more than the amount required to satisfy
thirst. Thirst satisfaction is not an accurate indicator of adequate
salt and fluid replacement.
Replacement fluids can be 0.1 percent salt water solution, commercial
mixes such as Gatorade or Quik Kick, or a combination of these with
fresh water. Smployees should be encouraged to salt their foods more
heavily.
Establishment of a work regimen that will provide ade~e rest
periods for cooling down. This may require additional hifts of
workers.
All breaks are to be taken in a cool resteea.
Employees shall remove impermeable protecµve garments
periods.
during rest
Employees shall not be
All employees sh~be
and proper diet r\ he
assig~ther tasks during rest periods.
informed of the importance of adequate rest
prevention of heat stress.
DecontaminaQ facilities
12.0 DECONTAMINATION
will be provided for equipment and for site
personnel. Before leaving the site, potentially contaminated equipment will
be decontaminated or placed in a plastic bag. Verification that equipment
leaving the site has been adequately decontaminated is the responsibility of
the Health and Safety representative or the site supervisor. Potentially
contaminated disposal materials (Tyvek coveralls, gloves, etc.) will be placed
in plastic bags, drummed on site and disposed of by National Starch (following
a review of subsurface/ground water data).
Results of the sample data for soils and ground water will be applicable to
the disposal of protective clothing. National Starch will be immediately
notified by IT of the analytical results upon completion so these materials
can be properly disposed.
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On-site personnel (IT and subcontractors) will thoroughly wash face and hands
and remove contaminated clothing before lunch or leaving the site. Personnel
equipment that is to be used repeatedly will be thoroughly cleaned at the end
of each working day. Respirators will be cleaned daily.
Drilling equipment used on site will be properly decontaminated before removal
from the contamination reduction zone.
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IT COIPOUTION
Figure A-l
SUPERVISORS
EMPLOYEE INJURY REPORT
Th;s is an official document to be initiated by the Supervisor. Be thorough and accurate. Answer all questions.
FOR DEPARTMENT USE
0 State Compensation
0 Federal L & H
Date Received
Date Employer's First Suomitted
lnjured's Name _____________________ 5e, __ S.S. No. _________ -t,irlhdate _______ _
Home Address _________________________ City _________ State ____ Phone ________ _
Classification ________________________ Hourly Wage Hire Date
lT Division ________________________________ ~ocation _________________ _
Who work was being performed for:, _____________________ Address ___________________ _
Exact location of incident _______________________________________________ _
Date of lnjury ___________ Time Shift Began ______________ Time Injured _____________ _
Time Reported __________ _..uid employee leave work.? ___________ ,Leh lhhen ? ______________ _
Date & Time Employee Returned To Work _______________________________________ _
Supervisor/foreman ______________________ Leadman ______________________ _
Nature of Injury Exact Body Pan Affected ______________ _
0 NEAR MISS O FIRST AID 0 DOCTOR CASE !ZED
a: Doctor's Narne ______________________ Address ____________ _ l-------State __ _ 0 Hospital Address ______________ ,,, ~ >
State __ _
~ What was employee doing at time of incident ?------------------~,C.---------------------
~ Ho~• did incident occur? __________________________ ---1,C.---------------------"'
Incident witnesses D Yes
ments Attached D No
D Yes
Did you witness incident? D No
Wny did incident occur? ___________ =-------------------------------------
D Yes Has corrective action been initiated 10 prevent recurrence? D No
Supervisor's Signature Date Report Prepared
Explain ________________________ _
lnjured's Signature Date
MANAGER
a: What unsafe condition or act caused incident? ________________________________________ _ w
" < Z Your recommendation? ________________________________________________ _ < :.
Signature
OCCUPATIONAL SAFETY & HEALTH
D Yes
Dale
Concur with action taken? D No Remarks ________________________________________ _
ITC FORM 9300.1·1 (May 1984)
Date
Distribuuon: Insurance
Safety
Manager