REMEDIAL DESIGN 1 OSBORNE LANDFILL SITE I COOPER

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j] REVISED WORK PLAN

REMEDIAL DESIGN] OPERABLE UNIT 4

1 OSBORNE LANDFILL SITEi v , GROVE CITY, PENNSYLVANIA

I COOPER INDUSTRIES

Prepared for:

)PER INDUSTFHOUSTON, TEXAS

CEC Project 91187

August 22,1991Revised May 14,1992

Revised September 16,1992

f/L

Civil & Environmental Consultants, Inc.Cincinnati 4665 Cornell Road Suite 255 Pittsburgh Foster Plaza XI 790 Holiday Drive

Cincinnati. Ohio 45241 Pittsburgh. Pennsylvania 15220Phone (5131 469 -0200 Phone (412) 921 -3402Fax (51 3) 469 -021 6 Fax (412) 921 -1815Tnll Crnn HNVH TEn BC1 • f..n- . ——— . ——— ——— .

TABLE OF CONTENTSPage

Section 1.0 - Introduction1.1 General 1-11.2 Background 1-3

1.2.1 Site Location and Description 1-31.2.2 Site History 1-5

1.3 Previous Investigations and Findings 1-31.3.1 Cooper Funded Investigations 1-81.3.2 EPA Funded Investigations 1-91.3.3 Clarion Aquifer (OU4) and Mine Void Data 1-11

1.4 Results of Recent Monitoring Well Sampling 1-121.5 Objectives of the Proposed Remedial Action 1-121.6 Description of the Selected Remedial Action 1-121.7 Design Objective 1-13

Section 2.0 - Project Management Plan2.1 Staffing 2-1

2.1.1 Project Management 2-12.1.2 Team Personnel 2-12.1.3 Design Review 2-1

2.2 Coordination with Agencies 2-22.3 Subcontractors 2-22.4 Quality Assurance/Quality Control 2-42.5 Health and Safety 2-4

Section 3.0 - Data Evaluation and Requirements forRemedial Design

3.1 Data Evaluation 3-13.1.1 Hydrogeologlc Associations of Shallow Strata 3-13.1.2 Hydraulics of Pumping the Clarion Sandstone 3-13.1.3 Conclusions 3-3

3.2 Additional Data Needs 3-93.3" 'Data Requirements 3-10

Section 4.0 - Scope of Work

4.1 Field Data Acquisition 4-34.1.1 Preliminary Activities 4-34.1.2 Plume Delineation Monitoring Wells 4-34.1.3 Monitoring Well Sampling 4-54.1.4 Aquifer Testing 4-64.1.5 Pump Test 4-6

4.2 Alternatives Analysis 4-104.3 Data Evaluation 4-114.4 Preliminary Design 4-12

4.4.1 Preliminary Design Preparation 4-124.4.2 Preliminary Design Report 4-12

4.5 Intermediate Design 4-134.6 Pref1nal/F1nal Design 4-14

Section 5.0 - Schedule . 5-1

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(Red)Table of Contents (continued)Page 11

FIGURES

Figure 1 - Site Location '' 1-4Figure 2 - Existing Conditions 1-6Figure 3 - Stratlgraphlc Column 3-2Figure 4 - Flow Net #1 3-5Figure 5 - Flow Net 12 3-6Figure 6 - Flow Net #3 3-7Figure 7 - Monitoring Well Location Plan 4-4Figure 8 - Schematic Pump Test Layout 4-7Figure 9 - Project Schedule 5-2

APPENDICES

Appendix A - Results of Recent Groundwater SamplingAppendix B - Response to ERA Comments on August 22, 1991, Draft Work Plan

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SECTION 1.0INTRODUCTION

1.1 GENERAL

Cooper Industries (Cooper), with the assistance of Civil & EnvironmentalConsultants, Inc. (CEC), Is undertaking the remedial design activities forOperable Unit No. 4 (OU4) of the Osborne Landfill Site located in PineTownship, Mercer County, Pennsylvania. The purpose of this remedialdesign Is to prepare plans, specifications, and bid documents for theselected remedial action for OU4. OU4 as defined by EPA 1s thecontaminated groundwater plume 1n the Clarion Aquifer of the ClarionFormation (excluding the mine pool 1n the underlying Brookvllle Coalseam). The following activities will be performed during the design:

Design Investigation and Treatability StudyPreliminary (35 percent complete) Design EffortIntermediate (60 percent complete) Design EffortPre-Final and Final (95 and 100 Percent Complete) Design Effort \^>

This work 1s being performed 1n general accordance with the conditionsoutlined In the Administrative Order for Remedial Design and RemedialAction, Operable Unit Nos. 1, 3 and 4 (Order) dated March 29, 1991, andtha Record of Decision (ROD) dated September 23, 1990. The OrderIdentified Cooper and General Electric Company as being jointly andseverally responsible for Implementing all of its requirements. Otherparties also Identified previously as possibly being responsible fordisposal of wastes at the site include Wolfe Iron & Steel and AshlandChemical.

This Work Plan has been revised since Its Initial submittal to EPA onAugust 22, 1991, based on comments presented to Cooper in a letter fromEPA dated January 31, 1992. Additionally, the Work Plan has been revisedto propose activities to assess the potential for simultaneously

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remediating the Clarion Formation and the underlying Brookville coal.Concerns about the ROD specified remedy involve the potential risk ofdrawing more highly contaminated water from the underlying mine voids intothe less contaminated Clarion Aquifer when water Is extracted from theClarion Aquifer. There are also concerns that the proposed remedy mayrequire many more extraction wells than assumed in the ROD. This couldeffect both the cost and effectiveness of the ROD remedy. Additionally,because of the Interconnection between the Clarion Formation andBrookville coal, it may be possible to simultaneously remediate both theBrookville coal (and mine system) and the overlying Clarion Formation.

Preparation of this Work Plan was specified by the Order. This Work Plandefines the activities to be performed to achieve the objectives of theremedial design and is detailed with respect to design investigationactivities, methods of data analysis, and documents that will be prepared.Concurrent with the preparation of this Work Plan, a Quality AssuranceProject Plan (including a Sampling Plan) and a Health and Safety Plan forthe pre-design activities have also been prepared. These documents areall being submitted concurrently to U.S. EPA (EPA).

The primary objective of the design investigation phase of the remedialdesign 1s to collect data that are currently unavailable, but necessary tofurther assess the viability and cost of the ROD selected remedy, andevaluate possible alternative methods of simultaneously remediating bothOU4 and the mine voids, and complete the design of the remedial action.These data, as well as previously generated data, will be used to select,refine, and finalize the design concept before preparing detailed plansand specifications. Results of the design investigation will be used toperform an alternatives analysis. Following the alternatives analysis,the results of the des-lgn Investigation (Including treatablllty studies)will be compiled and summarized In a report. This report will alsopresent design criteria and a preliminary remedial action design to serveas a point of agreement among the Involved parties. It will Includeoutlines of Specifications, Operations and Maintenance Plan, Permitting

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Plan, Contingency Plan, and Field Sampling and Groundwater MonitoringPlan.

The Intermediate (60% complete), Pre-f1na1 (90% complete) and Final (100%complete) design efforts will Involve the completion and refinement of thedocuments presented initially during the Preliminary Design.

The remainder of Section 1.0 presents background data on the Osborne siteand on the proposed remedial action. Section 2.0 presents the projectmanagement plan and project organization. Section 3.0 summarizes datathat are needed to perform the remedial design, while Section 4.0 presentsthe scope of the project tasks through completion of the remedial design.Section 5.0 presents the schedule for Implementation of the proposedactivities. Appendix A presents the results of recent sampling andanalysis of water from the Clarion Formation and mine void monitoringwells. Appendix B 1s the letter prepared to respond to EPA comments onthe draft of this Work Plan.

1.2 BACKGROUND

1.2.1 Site Location and Description! The Osborne Landfill site is. . located in Pine Township, Mercer County, Pennsylvania. The Osborne

site 1s situated immediately north of Pine Street Extension, one-half mile east of Grove City. See Figure 1.

The site is an abandoned Brookville Coal seam strip mine, and hasan area of approximately 15 acres. Disposed material extends fromnear Pine Street through the strip mine pit to a 5- to 10-foot highslope of trash and debris adjacent to the large pond at the northend of the site. The majority of the material in the pit appearsto be dark, coarse foundry sand. Slag, scrap metal, wood, paper,

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REFERENCE: U.S.C.S. 7.5* TOPOGRAPHIC MAP GROVECITY QUADRANGLE PENNSYLVANIA, DATED: 1961,PHOTOREVJSED: 1981. SCALE: 1"«=2000'. SCALE IN FEET

Civil & Environmental Consultants, Inc.Foster PUa XI • TMHotdiyOrl** • Pimburgh, Pmnsytranla 1S220

(412) (21-3402 • (SOO) 165-2324 • Fix (412) 921-1I1S

SITE LOCATIONOSBORNE LANDFILL SITE

OPERABLE UNIT NO. 4 REMEDIAL DESIGNWORK PLAN

OWN. BY: S.METZCHKD. BY:

APPROVED BY: SCALE:1=2000*

DATE:8/12/91 91187 FIGURE 1

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and plastic matter are found scattered around the entire site.There are three ponds located on site. The large pond (Pond No. 1)has a surface area of about one acre, and was estimated to be about20 feet deep. Pond No. 2 has a surface area of about 8,000 squarefeet, and was estimated to have a depth varying from about 2 to 10feet. Pond No. 3 has a surface area of about 500 square feet, andIs periodically dry. The ponds and other site features are shownon Figure 2.

The land Immediately surrounding the landfill 1s used foragricultural purposes. Effects of the past mining operations areevident near the site. Adjacent to the top of the strip mineMghwall on the north 1s a large field owned by Mr. EdwardMcDougal, present owner of the Osborne site. The area to the east1s mostly wooded. New homes have recently been built further northof the site along Enterprise Road. These homes are about 800 feetfrom the site and are topographically upgradlent. Several olderrural homes also exist to the east. South and east of the landfill

. are low-lying brush and wetlands on both sides of Pine Street. Alarge pond, estimated to be approximately three to four acres Insize, 1s located at the northern portion of the wetland.

1.2.2 Site History

Strip mining probably began near the site gate along Pine StreetExtension In the early 1900's. As the overburden was removed, Itwas placed along the western boundary of the site. Since theBrookville Coal seam was absent to the south, a larger volume ofmine spoil was removed and piled successively as the operationsmoved from south to.north. Actual periods of deep mining and stripmining operations could not be determined; however, strip miningactivities probably concluded In the late 1940's. The strip miningresulted In the formation of a 1,500-foot long pit through the

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site. Early, topographic maps show an elongated pond In the pitbetween the north and south walls of the stripped area.

% $ &!•••'From the 1950's until 1963, Mr. Samuel Mooney operated the site asa disposal area. The operation continued under the ownership ofMr. James Osborne from 1963 until 1978 when operations weresuspended at the site the Pennsylvania Department of EnvironmentalResources (DER). Disposal activities apparently began In thesoutheast section of the site by dumping Into the pond formed bystrip mining. The disposal operations were terminated prior tocompletion of filling of the strip pit, which has resulted 1n theformation of the large pond at the north end of the site.

Materials disposed at the site allegedly Included foundry sand,Industrial waste, and municipal refuse. Slag, scrap metal, wood,paper, and plastic matter can be found scattered around the site,along with a significant volume of foundry sand. All disposalactivities were apparently conducted within the 6-acre area createdby the coal stripping operations. Drums, however, were Initiallyfound throughout all portions of the 15-acre site.

DER brought the site to the attention of the EPA for Inclusionunder the "Superfund" program, following some preliminary sampling

_ .. by DER and the EPA Region III Technical Assistance Team. EPAsubsequently ranked the site using the Mitre Hazard Ranking System,and proposed the site for Inclusion on the National Priority List(NPL).

Following listing on the NPL, Cooper entered Into a Consent Orderwith DER and .Implemented an Initial Remedial Measure (IRM) toremove surface wastes that could potentially result 1nenvironmental hazards or hinder remedial Investigation activities.During the summer of 1983, a chain-link security fence wasInstalled around the site perimeter, and a drum and soil removal

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program was Implemented. Approximately 600 drums and 45 cu. yds.of contaminated surface soils were removed from the site.

1.3 PREVIOUS INVESTIGATIONS AND FINDINGS

Two remedial Investigations (RI) have been performed at the Osborne site.Fred C. Hart Associates (Hart) performed a remedial Investigation forCooper during 1983 and 1984, while Ebasco Services Inc. (Ebasco),utilizing their subcontractor, NUS Corporation (NUS), performed a remedialInvestigation for EPA, which was completed In 1989. The twoInvestigations resulted In different opinions on the current and futurerisks posed by the site.

1.3.1 Cooper Funded Investigations: Following the Implementation of theIRM, Cooper and DER entered Into a Consent Order and Agreementwhich provided for the performance of the Remedial Investigationfor the Osborne site. Hart then conducted the RemedialInvestigation (conducted during the period late 1983 to early 1984)which Included performing various tasks Identified 1n the ConsentOrder and Agreement Work Plan to gather Information necessary toestimate:

Types and quantities of waste disposed at the site;- **•

Geologic conditions and soil types present at the site;

Extent of soil contamination at the site;

Groundwater flow direction and gradient;

Groundwater quality; and

Surface water quality.

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ORIGINAL(Red)

A number of field and literature studies were undertaken to meetthe objectives. These activities Included geophysicalInvestigations, drilling of test boring and Installation ofmonitoring wells, sampling of monitoring wells, Identification andanalysis of drum contents, and collection and analysis of surfacewater samples. The results of these Investigation activities wereanalyzed to perform a risk assessment of site hazards. This RiskAssessment concluded that the risks to public health and theenvironment,were extremely low.

1.3.2 EPA Funded Investigations: DER and EPA personnel concluded thatthe remedial Investigation performed for Cooper was Incomplete, andthat additional Investigations and analyses were needed. Theagencies reached this conclusion because of the requirements forremedial action, evaluation and selection specified 1n theSuperfund Amendments and ReauthoHzatlon Act (SARA) that becameeffective in October 1986. EPA's remedial Investigation wasconducted during the period from April 1988 through June 1989 byEbasco under the REM III Program. The objectives of thisInvestigation Included the following:

Evaluate the Impact of surface water runoff from the site tothe adjacent wetland, off-site pond, and effluent stream.

- Determine'the quality of on-site surface water (ponds) to> assess the impact of contaminated fill material in the pondsediments.

- Assess the public health risks of localgroundwater users." ' . . " . " • - • • . ' ' - • ' • " • :

Determine whether the mine void (present at the base of theClarion Formation) 1s acting as a migration pathway.

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Further assess off-site and on-s1te groundwater quality in theunderlying aquifers.

Characterize the nature and extent of contamination within thefill material.

The field investigations conducted to collect data to meet EPA'sobjectives consisted of a soil gas survey and the installation oftest borings and the excavation of test pits throughout the sitearea to investigate sources. Hydrogeologic investigations includedthe construction of monitoring wells In five geologic formations,collection of static water measurements, performance of slug testsand pumping tests, the collection of groundwater samples, andcollection of domestic well samples from residences near the site.Samples were collected for subsequent chemical analysis (organiesand Inorganics) from three on-site ponds, from influent andeffluent intermittent streams, an off-site pond, an adjacentwetland area, and an off-site pond. A qualitative survey ofaquatic organisms in the on-site ponds and off-site pond andbioassays were performed to evaluate the Impact of contaminatedsediments on biota.

Based on the results obtained from the Investigation tasks, and the..-.. public health assessment and environmental evaluation, four media

were concluded by EPA to potentially pose elevated risks to humanreceptors. These media Included the on-site fill material, on-siteshallow groundwater, off-site Clarion Formation groundwater, andunderlying on-site Homewood Formation groundwater. The on-s1tefill material was considered a current dermal contact risk, whilethe groundwater risks due to ingestion were considered potentialfuture risks. Media that were concluded to continue to act as asource of on-site and off-site groundwater contamination,particularly to the groundwater 1n the Clarion Formation and

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ORIGINAL ^

Homewood formations, included the f111 material, the shallow watertable, and the on-site ponds. '

Ebasco, utilizing their subcontractor, NUS, also performed afeasibility study (FS) for EPA to evaluate remedial alternativesthat could potentially mitigate the present and future potentialpublic health and environmental concerns Identified in Ebasco'sremedial Investigation report. The feasibility study Identifiedand evaluated alternatives for solid waste and wetland sediment.Alternatives were also developed and evaluated for threegroundwater units. These Included the on-site water table, theClarion Formation, and the Homewood Formation. The results of theevaluations were summarized In the feasibility study report, whichincluded (as an addendum) the alternative that was developed byCooper and subsequently selected in the ROD for OU1. A groundwaterextraction and treatment system was selected for the remediation ofOU4.

1.3.3 Clarion Aquifer fOU4) and Mine Void Data; EPA concluded, based onthe Investigations, that the Clarion Formation has been Impacted bythe site contaminants/ The highest level of contamination,however, was detected in the flooded deep mine that forms the baseof the formation. Vinyl chloride was detected in mine void wells

. , at concentrations as high as 47 micrograms per liter (ug/1) nearthe hlghwall area. The analysis of water samples obtained fromwells installed further off-site 1n this flooded mine (east andsoutheast of the site) detected vinyl chloride ranging from "notdetected* to 7 ug/1. Wells Installed above the mine void (In theClarion Formation) exhibited lower levels of vinyl chloridecontamination.- Additionally, contamination in the ClarionFormation above the mine void was limited to the area near thedrums that were taken off-site in the 1983 removal action.Residential wells located east of the site did not exhibit any

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contamination. These wells obtain potable water from either theClarion Formation or the Homewood Formation.

1.4 RESULTS OF RECENT MONITORING WELL SAMPLING.r

CEC sampled four Clarion monitoring wells (MUC2, MWC3, MWC4, and CPW1) andsix monitoring wells screened in the Brookville coal or mine void system(MWV1, MWV2, MWV3, MUV4, MWV5, and MWV6) on December 11 and December 12,1991. CEC planned to sample Clarion monitoring well MWC1 but was unableto locate it because it is a flush-mounted well located in an overgrownfield. The groundwater samples were submitted to Savannah Laboratoriesfor analysis of TCL VOCs using CLP protocols. The results of the recentand previous analyses are summarized in Appendix A.

1.5 OBJECTIVES OF THE PROPOSED REMEDIAL ACTION

The objectives of the proposed remedial action were established for OU4 Inthe ROD by EPA based on the results of RI activities. The RI, FS and RODidentified media, potential receptors, and scenarios for exposure tocontaminants. These evaluations concluded that the remedial objectiveappropriate for OU4, as presented 1n the Order, was to contain andremediate the groundwater contamination plume in the Clarion Aquifer.These actions would reduce the level of vinyl chloride contamination Inthe. Clarion Aquifer, and reduce the potential for human health risksassociated with the use of the aquifer. Selection of a remedy for theBrookville coal and mine void system was deferred in the ROD.

1.6 DESCRIPTION OF THE SELECTED REMEDIAL ACTION

The remedial action selected by EPA for OU4 Is a groundwater extractionand treatment alternative. The major components of this action include:

Construction of extraction wells in the Clarion Formation.

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Pumping of off-site groundwater for on-site removal of contaminantsby air stripping of volatile organic hydrocarbons.

Injection of treated groundwater on-s1te into the mine pool.

Groundwater monitoring.

The viability and cost of this selected remedy will be further evaluatedbased on the data collected during the design Investigation. Ifappropriate, a modified remedy may be proposed.

1.7 DESIGN OBJECTIVE

The objective of the design effort for the Osborne site will be thepreparation of design documents to allow implementation of the selectedremedial alternative, or an alternative remedy agreed to by EPA. Thedocuments will Include the following:

- Construction Drawings and SpecificationsBid DocumentsQuality Assurance Management PlanPermitting PlanHealth and Safety Plan

- --•- Contingency PlanOperation and Maintenance PlanField Sampling and Groundwater Monitoring Plan

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SECTION 2.0PROJECT MANAGEMENT PLAN

2.1 STAFFING

2.1.1 Pro.iect Management: The remedial design activities for OU4 at theOsborne site will be managed out of CEC's offices in Pittsburgh,Pennsylvania. Kenneth R. Miller, P.E., will serve as the ProjectManager and will have ultimate responsibility for the execution ofthe project. Mr. Miller has extensive project experience onSuperfund remedial and groundwater remediation projects.

Mr. Miller will be assisted on the project during the investigationphase by Ms. Debora B. Thompson, C.G.W.P. Ms. Thompson, who willserve as the Assistant Project Manager, has experience In hazardouswaste site investigations, groundwater computer modeling, fieldpermeability testing, design and Installation of monitoring wellnetworks and pumping wells, and assessment of groundwater flow andcontaminant transport in complex geologic environments. Once theproject enters the design phase, Mr. Jeffrey C. Woodcock, P.E.,will act as the Assistant Project Manager. Mr. Woodcock hasprepared plans, specifications, and bid documents for theremediation of abandoned waste and groundwater contamination sites.

2.1.2 Team Personnel: Project team members utilized will be selected onthe basis of their qualifications to perform the technicalassignments. All personnel, with the exception of subcontractors,will be from CEC's offices in Pittsburgh, Pennsylvania.

2.1.3 Design Review: .CEC's Internal review will be directed by James P.Nairn, C.P.G. Mr. Nairn is a Vice President of CEC, and is asenior hydrogeologist with extensive experience in both wastemanagement and the investigation and remediation of groundwatercontamination sites. As the review team leader (RTL), Mr. Nairn

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will coordinate the review of project dell verables and will reviewday-to-day project activities. He will also select other reviewersbased on their technical expertise. Dr. James M. Roberts, Ph.D.,President and Quality Assurance Manager for CEC, will alsoparticipate in document and project review.

Cooper will also perform a review of all del 1 verables prior totheir submittal to EPA. Mr. Michael J. O'Brien, Manager ofEnvironmental Affairs of Cooper Industries, will lead andcoordinate Cooper's review of the documents.

2.2 COORDINATION WITH AGENCIES

Mr. Michael J. O'Brien of Cooper has been designated as the ProjectCoordinator and will direct all correspondence and other contacts with theagencies. Coordination with EPA will be by periodic meetings, telephoneconversations, and progress reporting. Progress reports will be prepared

: monthly in accordance with the Order.

• ' •EPA will coordinate the Involvement of other agencies Involved with theOsborne project, primarily DER. Project personnel will be available tocoordinate with these other agencies, If required.

2.3 SUBCONTRACTORS

CEC anticipates utilizing three subcontractors to perform the remedialdesign activities. These subcontractors are Terra Testing, Inc., McCarlsProcess Systems, Inc. and Chester LabNet.

Terra Testing will perform test drilling and subsurface sampling.Terra Testing is a geotechnical and environmental drillingcontractor located 1n Washington, Pennsylvania. Terra Testingoperates modern, high-production drilling equipment mounted ontrucks, trailers, skids and tracks, and has drilled throughout the

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trl-state area, including several projects in the Grove City area.Terra Testing has experience drilling on deep and strip mineinvestigations for public and private organizations, including theOffice of Surface Mining, DER and CEC. They have also drilled onhazardous waste sites for CEC. All of Terra Testing's fieldpersonnel are health and safety trained, and medically monitored inaccordance with OSHA regulations. Terra Testing is a member of theInternational Drilling Federation, the National DrillingContractors Association, and the Tri-State Drilling ContractorsAssociation. They were pre-qualified by DER and the PennsylvaniaDepartment of Transportation, and perform test drilling forsubsurface investigations.

McCarls Process Systems, Inc. (MPS) will perform the processengineering, conduct treatability tests, prepare processflowsheets, and develop specifications for the OU4 treatmentsystem. MPS, located in Pittsburgh, Pennsylvania, is a processspecialty firm in the area of water and wastewater engineering andconstruction. MPS has been Involved with the design of treatmentsystems for various remediation projects, including designingtreatment systems for landfill leachate and ground water extractionsystems. These systems have addressed organic and Inorganiccontaminants and Incorporated chemical precipitation, coagulation,sedimentation, biological treatment, granular media filtration,carbon adsorption, and air stripping columns.

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CSIGINAl

2.4 QUALITY ASSURANCE/QUALITY CONTROL

Work on this assignment will be conducted In accordance with proceduresdefined in the site-specific Quality Assurance Project Plan (QAPP) thathas been concurrently submitted with this Work Plan for agency review.The QAPP includes a field sampling plan for the proposed Investigationactivities.

All deliverable documents will be reviewed by the project review team.The review team leader, Mr. Nairn, will coordinate the reviews and willperform frequent progress reviews during the project. The comments of thereviewers will be Incorporated Into the deliverables before submission ofagency review drafts.

2.5 HEALTH AND SAFETY

Work on this assignment will be conducted in accordance with theprocedures presented in the Health and Safety Plan for the Operable Unit4 Remedial Design. This Health and Safety Plan is being submittedconcurrently with this Work Plan for agency review.

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SECTION 3.0DATA EVALUATION AND DATA REQUIREMENTS FOR REMEDIAL DESIGN

3.1 DATA EVALUATION

3.1.1 Hydrogeologic Associations of Shallow Strata: Figure 3 1s ageneralized stratlgraphic column for the site. This column alsoIdentifies informal aquifer units based upon the stratigraphy andregional characteristics. The term "aquifer" 1s used somewhatloosely here, as even the most prolific water bearing units In thisregion have relatively low transmissivities. The aquifer namesapplied are informal terminology and are not official USGSnomenclature.

The aquifers beneath the site, exclusive of unconsolidatedmaterials, are the Clarion, the Homewood sandstone, the upperConnoquenesslng sandstone, the lower Connoquenessing sandstone, andthe Berea sandstone. As shown by this classification, theBrookville coal and Clarion sandstone belong to the same aquifer,as no substantial aqultard separates these two permeable units.Although a shale is sometimes present over the coal, the stratumis thin and discontinuous, and has likely been fractured by miningactivities. The Clarion aquifer 1s separated from the Homewoodsandstone aquifer by the Brookville underclay and other siltstones.

3.1.2 Hydraulics of Pumping the Clarion Sandstone; Traditional flow-netanalysis was used to evaluate flow patterns in the Clarionsandstone under assumed pumping conditions.

The pumping conditions assumed were selected to demonstrate theresponses that could occur for a range of possible site conditions.Flow nets were prepared using the following boundary conditions:

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OWN, BYi M.T.M.•EPORT NO.

APPROVED BYi SCALEi OATEtNTS 3/5/92 91187 FIGURE 3

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1. The static water-table elevation was held equal to the head atthe base of the sandstone. This assumption appears to bejustified because water levels in the Clarion sandstone wellsare approximately equal to water levels in wells completed inthe Brookville coal.

2. The water level in the Brookville coal voids does not changeas a result of pumping in the Clarion sandstone. Thisassumption is justified by a pump test performed during theRemedial Investigation (NUS, 1939), which Indicated thatpumping at a very high rate in the mine void did notappreciably affect the water level.

3. The cone of depression in the unconfined aquifer Is describedby the Theim-Oupuit equation:

Q - (2(p1)T x [{s1-s1V2D)-(s2-s22/2D)]} / In r,)

where:

Q - pumping rate, L3/Tsx - drawdown at distance rx0 - aquifer thickness, L

....... T - aquifer transmlssivity, L2/T.

Rearranging and combining terms, this equation becomes:

s,' - s/ - C x Infrj/r,)

where:

C - Q/(2(p1)T)s/ - s,-s,2/2Ds1 and r, are defined at the pumping well.

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The parameter C Is case-spedfie, and cannot be determinedwithout additional data. Flow nets were examined for threeassumed values of C and s,: one which resulted in a deep,narrow cone of depression; one which resulted In a deep, widercone of depression; and one with a shallow cone.

4. Groundwater removal occurred as a point sink.

In traditional flow-net analysis, flow lines and equipotentiallines are constructed to be perpendicular to one another, and arespaced so that they form equidimensional boxes. In addition, theflow lines must intersect the water table at Intervals which wereequally spaced in the vertical dimension. When a flow net Isconstructed according to these rules, the solution 1s unique andflow in all flow tubes (the zones between flow lines) is the same.Results of the analysis are presented in Figures 4, 5, and 6. Ineach high-drawdown case (Figures 4 and 5) ten complete and twopartial flow tubes were constructed. In Figure 4, flow tubes 3through 10 carry water from the mine void to the pumping well.Complete flow tubes 2 and 11, as well as partial tubes 1 and 12,carry water from the Clarion sandstone. Under these boundaryconditions, the portion of well discharge derived from the minevoid Is:

! 8 tubes————————————— - 70%(10 + 2 x 0.75) tubes

The radius of influence at the base of the aquifer Is greater thanthe radius of Influence at the water table.

•

Results for Figure 5 Indicate the percentage of water contributedby the mine void Is:

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ROW NET #1OSBORNE LANDRLL SITE

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In this case, the radius of the Influence at the base of theaquifer 1s less than the radius of influence at the water table.

For the shallower cone of depression (Figure 6), the percentage offlow contributed by the mine void Is:

! + (2 x 0.5) tubes

4 + (2 x 0.5) + (2 x 0.33) tubes

The radius of Influence at the mine void is much larger than theradius of Influence at the water table.

3.1.3 Conclusions: These calculations support the hypotheses that:

1. The Clarion sandstone and the Brookville coal belong to thesame aquifer.

2. Pumping wells completed In the Clarion sandstone as proposedby the ROD may draw much, possibly most, of their water fromthe underlying mine void.

3. Water may be drawn from the mine void Into the sandstone overa larger area than the apparent radius of influence at thewater table.

• ;. ' • ' . •

Based on these potential scenarios, it is concluded that extractinggroundwater from the Clarion sandstone may not be an effectiveremediation technique for removing contaminants from the Clarion.Furthermore, removing groundwater from the sandstone may draw large

WP-OU4 3-8 Draft - 9/16/92

AR306UI6

(Seat

quantities of more contaminated water from the mine void Into theoverlying strata, increasing contamination in the Clarion Aquifer(OU4).

In light of the above evaluation, it 1s further concluded thatdirect remediation of the water in the mine void may be moreeffective in mitigating contamination in the Clarion Formation thanthe remedy proposed in the ROD. Because the vertical gradient inthe Clarion sandstone is downward, the aquifer will flush naturallyfrom surface infiltration into the mine voids. This flushing couldbe enhanced by induced Infiltration at the top of the aquifer,which would increase the downward gradient and hence downwardgroundwater flow velocities. Infiltration could be Increased usingwater extracted from the mine void after treatment. Only a portionof the extracted water would be Injected Into the Clarion, with themajority being injected back into the mine void. This combinationof extraction and induced infiltration would allow activeremediation of both the mine void and OU4.

3.2 ADDITIONAL DATA NEEDS

During the performance of the RI and the FS, data were collected tocharacterize existing and potential hazards posed by the Osborne site andto .support selection of a remedial action alternative for the site. Dataregarding general site characteristics (topography, geology, hydrogeology,etc.), waste characteristics (type, quantity, location of wastes, etc.),and amount and extent of contamination, among other general categories,were collected and analyzed. The available data are not sufficient toevaluate the viability or effectiveness of proposed ROD remedy or thefeasibility of simultaneously remediating the mine void system and theClarion Aquifer. Additionally, the data are not sufficient to support adetailed final design of the selected remedial alternative for OU4, oralternative remedies. Additional data are needed in the following areas

WP-OU4 3-9 Draft - 9/16/92

AR306UI7

before design of the various components of: the remedial action can beperformed:

Estimation of detailed aquifer properties, including theinteraction of the Brookville coal and the Clarion sandstone.

Refinement of the limits of the vinyl chloride plume andgroundwater flow in the Clarion aquifer.

Analysis of the groundwater for treatability parameters.

The design Investigation has the objective of meeting specific design datarequirements. The following sections describe in greater detail the dataneeds for each of the above categories.

3.3 DATA REQUIREMENTS

Aoulfer Properties: Data 1s needed on aquifer characteristics, Includingtransmisslvlty, permeability, radius of Influence, and steady-statedrawdown. Aquifer properties will be assessed by the installation of apumping well and several observation wells, and the performance of a long-term pump test.

The understanding of aquifer properties Is necessary for proper spacingand location of pumping wells, and selection of a pumping rate.Extraction wells must be spaced so that the entire plume Is contained orcaptured. Furthermore, hydraulic Interaction between the mine pool andthe aquifer may limit the achievable radius of Influence of pumping wells,by acting as a source of continuous recharge to the aquifer under pumpingconditions.

Plume and Flow Direction: Groundwater chemical data is several years oldand did not define the limits of the vinyl chloride plume in the ClarionAquifer. Additionally, the monitoring well network did not adequately

WP-OU4 3-10 Draft - 9/16/92

AR306U8

define the groundwater flow direction in the Clarion Aquifer. Additionalmonitoring wells will be installed, existing and new monitoring wells willbe sampled, water samples will be analyzed for chemicals of concern, andwater levels in the wells will be obtained.

The refinement of the limits of the plume 1s also needed to satisfy theROD requirements of the monitoring well network. The ROD states thatmonitoring wells should be Installed at the limits of the plume, and inthe area of highest contamination.

Treatabilitv Parameters and Haior Ions Analysis of Groundwater:Treatability parameters, particularly Iron and calcium, can cause foulingof air strippers. Testing of representative groundwater samples for Ironand calcium, major ions, and general chemistry will allow evaluation ofthe need for pretreatment or extensive maintenance. These parameters willInclude total dissolved solids (TDS), total suspended sol Ids (TSS), totalorganic carbon (TOC), bicarbonate, sulfate, chloride, calcium, magnesium,manganese, pH, sodium and potassium.

WP-OU4 3-11 Draft - 9/16/92

AR306M9

SECTION 4.0. • SCOPE OF WORK

The following major groups of activities will be completed to perform the designof the remedial action for OU4 at the Osborne Site:

Field Data Acquisition: A long-term pump test will be performed inconjunction with groundwater sampling and a tracer test to evaluateaquifer characteristics of the Clarion sandstone and the Interactionsbetween the Clarion sandstone and the Brookville coal. One pumping welland eight observation wells will be Installed for performance of thistest. The test results will be used to evaluate the viability of theremedy proposed in the ROD, to assess the feasibility of simultaneouslyremediating contamination 1n the Clarion sandstone and Brookville coal,and to support design of the selected remedy.

Three new monitoring wells will be Installed to further delineategroundwater flow and the pattern of contaminant concentrations.

. Groundwater samples will be collected from all new and existingmonitoring wells screened in the Clarion Aquifer and the mine void toaugment the existing data and Incorporate the newly Installed monitoringwells Into the delineation of the contaminant plume.

Alternatives Analysis; Data collected during the pump test will beevaluated to estimate aquifer properties, and how the properties varywith depth. Geochemical results and the tracer study data will also beevaluated to assess the relative contributions of flow by the Clarionsandstone and Brookville coal during pumping. The ROD specified remedyfor remediating the Clarion sandstone, and possible methods ofremediating the Clarion sandstone and Brookville coal simultaneously,will be evaluated based on the results of the data analysis.

Data Evaluation; Data collected during field activities will be reviewedand analyzed to estimate groundwater flow patterns and calculate aquifer

, WP-OU4 4-1 Draft - 9/16/92

AR306d20

properties. This data will then be used to conceptually design a systemof wells to extract contaminated water using the method agreed to by EPAfollowing the alternatives analysis. A treatability study will also beperformed during the data evaluation phase in order to determine the mostappropriate treatment technology.

Preliminary Design; The preliminary design activity will take theproject through a 35 percent complete design. The results of the designInvestigation will be presented as part of the preliminary designsubmlttal. Additionally, the submlttal will specify how the previouslycollected data, and the new data, form the basis for the design.Preliminary plans and outline specifications will be prepared. Anoutline of the Construction QA/QC Plan, Operation and Maintenance Plan,Permitting Plan, Contingency Plan, and Field Sampling/GroundwaterMonitoring Plan.

Intermediate Design: The intermediate design (60% complete design) willInclude preparation of construction drawings consisting of partiallycompleted plans and details, draft construction specifications, a designanalysis and calculations package, a draft construction QualityAssurance/Quality Control Plan (QAPP), a draft Operation and MaintenancePlan, draft Permitting Plan, draft Contingency Plan, and draft FieldSampling/Groundwater Monitoring Plan.

Prefinal and Final Design; Prefinal design documents will be submittedat the point when 95 percent of the work required to complete theremedial design has been completed. The prefinal documents will includefinal construction drawings, final construction specifications, a finalreport of design analyses and calculations, Construction QA/QC Plan,Operation and Maintenance (O&M) Plan, Permitting Plan, Contingency Plan,and Field Sampling/Groundwater Monitoring Plan for the remedial action.

WP-OU4 4-2 Draft - 9/16/92

AR3Q6l*2l

ORIGINAL(Red)

After review, comment, and approval of the prefinal submission, thedesign team will execute the required revisions and submit the finaldocuments 100 percent complete.

4.1 FIELD DATA ACQUISITION

.._ .__ 4,1.1 Preliminary Activities: Proposed -well locations -will besurveyed, access requirements finalized, and preparation formobilization will be performed during the preliminaryactivities.

CEC will perform surveying to locate and obtain ground surfaceand wellhead elevations at the well locations. Elevations willbe referenced to USGS benchmarks and based on the NationalGeodetic Vertical Datum (NGVD). USGS replaced elevationsreferenced to Mean Sea Level (MSL) with NGVD In the 1980's toavoid confusion with sea level, which 1s variable.

( 4.1.2 Plume Delineation Monitoring Wells; Three monitoring wells willbe installed In the locations indicated on Figure 7 to attemptto delineate the limits of the vinyl chloride plume In theClarion Aquifer. If testing of samples from the new monitoringwells detects the presence of vinyl chloride, additional wellsmay be added following discussions with EPA.

Borings for the wells will be advanced through the soil zoneusing auger methods with spl It-spoon samples obtained at 5-footIntervals. Borings will be advanced through bedrock using NXrock coring methods so bedrock types and conditions can benoted. The monitoring wells will be Installed to depthsapproximately five feet above the roof of the coal seam or nine.The depth of the wells will be based on surveyed surfaceelevations and the stratigraphy reported by past studies. Thebedrock will be visually examined and logged for indications of

WP-OU4 4-3 Draft - 9/16/92

AR306U22

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mine subsidence based on the extent and type of fracturing. ^.Vertical and diagonal fracturing of the bedrock are Indications Jof mine subsidence or stresses Induced by mine voids.

Following coring, the borings will be reamed out to allowinstallation of the monitoring well. Wells will be constructedw1th^~feet of 4-1nch PVC screen, followed by 4-Inch PVC-riserpipe to the surface, and will be completed in the sandstoneImmediately above the Brookville Coal. Following installation,the monitoring wells will be developed. Development water willbe collected and discharged Into one of the on-site ponds.Wellhead elevations will be surveyed to allow determination ofgroundwater flow patterns.

Methods for well drilling, Installation, and development areincluded 1n the Field Investigation Plan, Appendix A of theQAPP. Soil encountered will be logged in the field and will be ,classified 1n accordance with the Unified Soil ClassificationSystem. Bedrock will be logged In accordance with theprocedures outlined In the Field Investigation Plan. Thelogging sheets that will be used by CEC personnel are Included1n the Field Investigation Plan.

————4.1.3 "Monitoring~Well Sampling;—The monitoring veils~1n the ClarionFormation, Including the three new monitoring wells, and thewells 1n the mine void will be sampled and analyzed for TCL

detection limit of 1 ppb for vinyl chloride and TCE. Waterlevels will be measured at the time of sampling. Temperature,pH, and specific conductance will be measured 1n the fieldduring sampling. Sampling methods are presented in the FieldInvestigation Plan, Appendix A of the QAPP.

WP-OU4 4-5 Draft - 9/16/92

4.1.4 Aouifer Testing: Rising-head permeability tests will beperformed on the selected wells to estimate the parameters forthe long-term pump test (Section 4.1.5).

4.1.5 Pump Test: A pump test will be performed to evaluate ClarionFormation property variations with depth and to assess thenature of interaction between the Clarion sandstone and theBrookville coal. Additionally, this pump test will allowevaluation of the viability of the ROD remedy for OU4. The datawill also be used to evaluate the feasibility of simultaneouslyremediating both the Clarion and the mine voids. The test willbe conducted near the eastern corner of the site, and willInclude the following configuration of wells (Figure 8):

• A fully penetrating pumping well Installed through theClarion sandstone

• Four observation wells in the shallow portion of theClarion sandstone

• Four wells would be Installed near the base of the Clarionsandstone.

The use of the double level of observation wells will allow theevaluation of Clarion aquifer properties at levels both verynear the mine voids and further above the mine voids. This willprovide data to evaluate the feasibility of using wells atvarious depths in the Clarion sandstone to extract groundwaterfor treatment. The use of four wells 1s proposed for tworeasons:

1. A minimum of three wells 1s required for evaluation oftransmissivity anlsotropies.

WP-OU4 4-6 Draft - 9/16/92

AR306l*25

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(412) 921-3402 • (000) 363-2324 • FAX (412) 921-1819

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2. Roof fracturing associated with the mine workings may makeaquifer properties uncommonly heterogeneous.

Existing well MWV2 will also be used as an observation well forthe pump test.

a. Well Installation: A pumping well will be Installed usingthe same methods used to Install the plume delineationwells. The pumping well will be constructed of four-InchPVC, and will be completed at the roof of the deep mine orcoal seam. The well will be screened across the entiresaturated aquifer thickness.

The additional observation wells will be Installed usingauger methods through soil and air rotary methods Inbedrock. The wells will be configured to allow evaluationof permeability anlsotropies and radius of Influence, andwill have 5-foot screened sections. Four wells will becompleted 1n the shallow portion of the Clarion sandstone.Four other wells will be completed in the deeper portionof the Clarion sandstone.

Following Installation of all of the wells, the wells will.^ be developed. Development water will be collected and

discharged Into one of the on-site ponds.

As with the plume delineation wells, the wells will be set usingsurveying and previously generated stratigraphy.

b. Tracer Ion Testing: Bromide has been selected forinjection Into the mine void well during the pump test.This ion is conservative, has low toxiclty, migrates ingroundwater, and 1s detectable in the field using aspecific-ion electrode. A borehole dilution test will be

, WP-OU4 4-8 Draft - 9/16/92

ftR3Q6l*27

performed 1n MWV2 to evaluate the rate of groundwatermovement in the mine and the required tracer Injectionrate for the pump test. The dilution tests will beperformed in accordance with "Methods of Flow MeasurementIn Well Bores," Commonwealth of Pennsylvania, Departmentof Environmental Resources, Bureau of Topographic andGeologic Survey, 1967. Test procedures are detailed inthe Field Investigation Plan, Appendix A, of the QAPP.

c. Pre-Pumo Test Sampling: All nine pump test wells and MWV2will be sampled for total dissolved solids, calcium,magnesium, manganese, sodium, potassium, bicarbonate,iron, pH, chloride, sulfate, and bromide before the pumptest.

d. Pumo Test: A constant-|iii pump test will be conducted at

Water levels in the pumping andobservation wells will be recorded with an electronic datalogger at a logarithmic recording Interval. Pumping willcontinue at a constant rate for an extended period oftime, approximately five to seven days. Water from thepump test will be routed to one of the on-site ponds andwill be discharged Into the pond through a spray nozzle.

At the time of test initiation, a water sample will becollected from the pumping well for analysis of volatileorganic compounds (VOCs) using

The pump discharge will be sampled at thebeginning of the test and every 24 hours for totaldissolved solids, calcium, magnesium, sodium, potassium,

WP-OU4 4-9 Draft - 9/16/92 .

AR306l*28

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sulfate, bicarbonate, iron, manganese, pH, chloride, andbromide. Field analysis for the tracer will be conducted,at a minimum, at 2-hour intervals, on the pumping welldischarge and observation wells.

When the test 1s completed,a sample of the pump discharge will be collected foranalysis of VOCs, all of the anlons and cations analyzedfor every 24 hours during the test, and total dissolvedsolids, total suspended solids, and total organic carbon.

obtain a detection limit of 1 ppb for vinyl chloride andTCE. These parameters will allow the evaluation ofpotential treatment problems. Additionally, a sample ofwater will be obtained from the pumping well at thecompletion of the test for use In treatabiHty testing,

4.2 ALTERNATIVES ANALYSIS

The alternative analysis will begin with data analysis. Data analysiswill Include the following items:

1. .. Calculation of transmissivlty, storage coefficient, and radiusof Influence for shallow and basal portions of the Clarionsandstone.

2. Comparison of aquifer properties in the shallow and deepersections of .the Clarion sandstone.

3. Preparation of Piper diagrams to assess whether groundwaters inthe Brookville coal and Clarion sandstone are geochemically

WP-OU4 4-10 Draft - 9/16/92

AR306l*29

4. Examination of tracer concentrations in the extractedgroundwater through time to evaluate mine-water intrusion.

This assessment will allow groundwater modeling of the Clarion Formationand evaluation of potential mine-water Intrusion under various pumpingscenarios. Initially, modeling will be performed using an analyticalimplementation of the advect1on-d1spers1on equation. If this method doesnot adequately calibrate to field conditions, then digital modeling willbe performed using a finite-difference flow/transport model.

A brief alternative analysis will then be performed to evaluate andcompare systems to extract water from the Clarion sandstone as specifiedin the ROD, and alternative systems to extract water from the mine voidand employ induced infiltration in the Clarion sandstone. The dataanalysis and alternatives analysis will be summarized in a short reportfor submlttal to EPA for review and comment. ^^

4.3 DATA EVALUATION

Water levels measured in the existing and newly installed monitoringwells will be used to construct a plezometric-surface map and determinethe direction of groundwater flow in the Clarion Formation above the minevoids. VOC analyses will be compared to standards and will be plottedto evaluate contaminant distributions. The patterns of chemicaloccurrences will be compared to the groundwater flow pattern to evaluatepotential contaminant migration. The potential effect of waterextraction on the remedy for OU1 will also be evaluated by assessing thewater level outside the slurry wall induced by groundwater extraction.The water level inside the containment will need to be maintained belowthe level outside the wall to Induce a hydraulic gradient Into thecontainment.

WP-OU4 4-11 Draft - 9/16/92

AR306l*30

Alternative locations for re Inject ion of treated water will be evaluated.The locations selected will be based on the method finally Implemented.Water may be re Injected into the Clarion, as well as the mine voidsystem. The potential effects of the reinjection on mine subsidence willalso be evaluated by estimating the seepage forces and acceleratedweathering that may be Induced by extraction and reinjection above themine voids. Reinjection of water Into the mine void Itself should notIncrease mine subsidence potential.

CEC's treatment design subcontractor will perform a bench scaletreatablllty study to assess the effectiveness of the proposed treatmentscheme. This study will simulate those processes which may be reasonablyreplicated on a laboratory scale and warrant testing. CEC will reviewthe results of the data and evaluate various treatment system options forpost-treatment levels and off-gas treatment. The cost effectiveness ofachieving a range of post-treatment vinyl chloride levels will beevaluated and presented for review. Alternative methods of treating airemissions will also be evaluated for cost effectiveness. EPA's vinylchloride expert, Mr. Lesly Evans, will be contacted for support. Theresults of the evaluation will be used to recommend a treatment systemfor final design.

4.4 PRELIMINARY DESIGN

4.4.1 Preliminary Design Preparation; Placement of extraction wellswill be designed using digital and/or analytical groundwatermodeling. A network of pumping wells and pumping rates will beselected to allow capture of the contaminant plume in theClarion Aquifer above the Brookville Coal seam. The finalsystem selected to treat the extracted groundwater will also bespecified.

4.4.2 Preliminary Design Report: A preliminary design report will beprepared to Include:

WP-OU4 4-12 Draft - 9/16/92

AR306l*3l

Results of field activities, including raw data, chemicalanalyses, and boring logs.

Hydrogeologic calculations

Plezometric-surface map

Viability of proposed extraction system design

Results of any treatability tests (and treatment systemrecommendations)

Quantity, placement, and pumping rate for extractionwells, with justification

Outline of specifications, Construction QA/QC Plan,Operation and Maintenance (O&M) Plan,

Permitting Plan, I|l Contingency Plan.

.. -. - Preliminary schedule for system construction.

This report will be presented to EPA for review.

4.5 INTERMEDIATE DESIGN

The Intermediate design (60% complete) will build upon the preliminarydesign, and will Include:

Draft design drawings and specifications for the remediationsystem to be used

WP-OU4 4-13 Draft - 9/16/92

AR306U32

Draft Construction QA/QC, O&M, Permitting, Contingency, andField Sampling/Groundwater Monitoring Plan!

- Revised remedial action Implementation schedule

4,6 PREFINAL/FINAL DESIGN

The prefinal design (95% complete) will build on the results of theIntermediate design and agency comments, and will Include:

Final specifications and design drawings

Construction QA/QC Plan

Operations and Maintenance Plan. The 0 & M Plan will Include aplan for compliance with the 5-year review.

Permitting Plan

Field Sampling/Groundwater Monitoring Plan

Contingency Plan

Construction Schedule

The prefinal design will be presented to EPA for review and comment. EPAand other agency comments and concerns will then be incorporated tofinalize the design documents.

WP-OU4 4-14 Draft - 9/16/92

AR306l*33

SECTION 5.0SCHEDULE

The proposed project schedule for the OU4 Remedial Design is presented on Figure9. The start date is considered as the date of EPA approval of this Work Plan.The schedule may change if unanticipated conditions are encountered during fieldactivities. EPA will be notified of any problems, and schedule changes will benegotiated, if necessary. A meeting with EPA reviewers is proposed to assist inthe agency's review and to expedite the overall project. A four-week period hasbeen allowed for each EPA review.

WP-OU4 5-1 Draft - 9/16/92

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REFERENCES *

Mishra, S. and Guyannet, D., 1992. Analysis of Observation-Well Response DuringConstant-Head Testing: Groundwater, U30, No. 4, pp. 523-528.

WP-OU4 Draft - 9/16/92

AR306U7

Q.

APPENDIX A

RESULTS OF RECENT GROUNDWATER SAMPLING

AR306l*39

COOPER INDUSTRIES OSBORNE LANDFILL 91137

WELL NUMBER: MWV1 MWV1 MWV1DATE: MAY 39-1 MAY 89-2 ll-Dec-91

SAMPLER: HART HART CECLABORATORY: NA NA SAVANNAH

VOLATILES BY GC/MS C8240)Chloromathane, ug/1 ND NA 2.0 UBromomethana, ug/I ND NA 2.0 UVinyl Chloride, ug/1 ND NA 2.0 UChloroethane, ug/1 ND NA 2.0 UMehtylene Chloride, ug/1 0.6 B NA l.O UAcetone, ug/1 13.6 B NA 2.O UCarbon Disulfide, ug/1 ND NA 1.0 U1,1-Dichloroethena, ug/1 ND NA 1.0 U1, 1-Dichloroethane, ug/1 ND NA l.OUCis/Trans-l,2-Dichloroethene, ug/1 ND NA 0.2 JChloroform, ug/1 ND NA 1.0 U1.2-Dichloroethane, ug/1 ND NA l.O U2-Butanone, ug/1 ND NA 2.O U1, 1, l-Trichloroethanef ug/1 ND NA 0.2 JCarbon Tetrachlor ide, ug/1 ND NA l.O UVinyl Acetate, ug/1 ND NA 2.O UBromodichloromathana, ug/1 ND NA 1.0 U1, 1,2,2-Tetrachloroethane, ug/1 ND NA l.OU1,2-Dichloropropane, ug/1 ND NA 1.0 UTrans-l,3-Dichloropropene, ug/1 ND NA l.O UTrichloroethene, ug/1 ND NA 2.0Dibromochloromathane, ug/1 ND NA 1.0 Ulf l,2-Trichloroethanef ug/1 ND NA 1.0 UBenzene, ug/1 ND NA l.O UCis-l,3-Dichloropropene, ug/1 ND NA l.O UBromoform. ug/1 ND NA l.O U2-Hexanone, ug/1 ND NA ^ 2.0 U4-Methyl-2=-pentanona, ug/1 ND NA 2.0 UTetrachloroethena, ug/1 ND NA 0.1 BJToluene, ug/1 ND NA 0.4 JChlorobenzena, ug/1 ND NA 0.2 BJEthyl benzene, ug/1 ND NA 1.0 UStyrene, ug/1 ND NA l.O UXylenes, ug/1 ND NA 8.0 B

OTHER PARAMETERSField pH • 9. 1 NA NASpecific Conductance 300.0 NA NATemperature NA NA NA

AR306M*Q

OPER INDUSTRIES OSBORNE LANDFILL 91187

WELL NUMBER: MWV2 MWV2 MWV2DATE: MAY 89 MAY 39-2 11-Dec-91

SAMPLER: HART HART CECLABORATORY! NA NA SAVANNAH

VOLATILES BY GC/MS <8240>Chloromethane, ug/1 ND ND 2.0 UBromomethane, ua/1 ND ND 2.0 UVinyl Chloride,"ug/1 47.0 23.0 17.0Chloroethane, ug/1 ND ND 2.0 UMehtylene Chloride, ug/1 0.6 B ND 1.0 UAcetone, ug/1 1.4 B ND 2.0 UCarbon Disulfide, ug/1 ND ND 1.0 U1,1-Dichloroethene, ug/1 0.1 J O.2 l.O U1,1-Dichloroethane, ug/1 0.5 J ND 0.3 JCis/Trans-l,2-Dichloroethenef uq/1 ND ND 2.OChloroform, ug/1 ND ND l.O U1.2-Dichloroethane, ug/1 ND ND l.O U2-Butanone, ug/1 ND ND 2.0 U1,1.1-Trichloroethane, ug/1 0.1 J ND 1.0 UCarbon Tetrachlorids, ug/1 ND ND 1.0 UVinyl Acetate, ug/1 ND ND 2.O UBrcmodichloromethane, ug/1 ND ND 1.0 Ulf1,2,2-Tetrachloroethane, ug/1 ND ND l.OUl,2-Dichloropropanef ug/1 ND ND l.O UTrans-l,3-Dichloropropene, ug/1 ND ND l.O UTrichloroethene, ug/1 0.7 J 0.3 2.ODibromochloromethane, ug/1 ND ND 1.0 U1,1,2-Trichloroethane, ug/1 ND ND l.OUBenzene, ug/1 ND ND 1.0 UCis-1,3-Dichloropropene, ug/1 ND ND 1.0 UBromoform, ug/1 ND ND l.O U2-Hexanone, ug/1 ND ND 2.0 U4-Methyl-2-pentanone, ug/1 ND ND 2.O UTetrachloroethene, ug/1 ND ND 0.2 BJToluene, ug/1 O.2 J ND 0.3 JChlorobenzene, ug/1 ND ND 1.0 UEthylbenzene, ug/1 ND ND l.O UStyrene, ug/1 ND ND 1.0 UXylenes, ug/1 ND ND 8.0 B

OTHER PARAMETERSpH ' 7.2 7.4 NASpecific Conductance 485.0 475.0 NATemperature NA NA . NA

AR3Q6l*U




VOLATILES BY GC/MS C8240)Chloromethane, ug/1 ND NA 2.0 UBromomathane. ug/1 ND NA 2.0 UVinyl Chloride, ug/1 ND NA 5.0Chloroathane. ug/1 ND NA 2.0 UMehtylene Chloride, ug/1 ND NA 1.0 UAcatona. uq/1 ND NA 2.O UCarbon Disulfida, ug/1 ND NA 1.0 U1,1-Dichloroethena, ug/1 ND NA 1.0 U1,1-Dichloroathana, ug/1 ND NA 0.2 JCis/Trans-l,2-Dichloroethene, ug/1 ND NA 1.0Chloroform, ug/1 ND NA 1.0 U1,2-Dichloroethana, ug/1 ND NA l.OU2-Butanona. ug/1 ND NA 2.0 U1,1.1-Trichloroethane, ug/1 ND NA 0.2 JCarbon Tetrachloride, ug/1 ND NA l.O UVinyl Acetate, ug/1 ND NA 2.O UBromodichloromethane, ug/1 ND NA l.O U1,1,2,2-Tetrachloroethana, ug/1 ND NA l.O U1,2-Dichloropropane, ug/1 ND NA 1.0 UTrans-l,3-Dichloropropena, ug/1 ND NA l.O UTrichloroathane, ug/1 ND NA l.ODibromochloromethane, ug/1 ND NA 1.0 U1,1,2-Trichloroethane, ug/1 ND NA l.OUBenzene, ug/1 ND NA l.O UCis-1,3-Dichloropropene, ug/1 ND NA l.O UBromoform, ug/1 ND NA l.O U2-Hexanone. ug/1 ND NA 2.O U4-Methyl-2-pentanone, ug/1 ND NA 2.O UTetrachloroethene, ug/1 ND NA 0.1 BJToluene, ug/1 ND NA 0.2 JChlorobenzene, ug/1 ND NA l.O UEthylbenzene, ug/1 ND NA l.O UStyrene. ug/1 ND NA l.O UXylenes, ug/1 ND NA 7.O B

OTHER PARAMETERSField pH NA NA NASpecific Conductance " NA NA NATemperature NA NA NA

•:OOPER INDUSTRIES OSBORNE LANDFILL 91187

WELL NUMBER: MWV4 MWV4 MWV4DATE: MAY 89 MAY 89-2 ll-Dec-91


VOLATILES BY GC/MS (824O)Chloromethane, ug/1 ND ND 2.0 UBromomethane, ug/1 ND ND 2.0 UVinyl Chloride, ug/1 ND 1.6 J 2.0 UChloroethane, ug/1 ND ND 2.0 UMehtylene Chloride, ug/1 ND 0.2 B 1.0 UAcetone, ug/1 ND ND 2.0 UCarbon Disulfide, ug/1 ND ND 1.0 U1,1-Dichloroethene, ug/1 ND ND 1.0 U1,1-Dichloroethane, ug/1 ND 0.3 J O.3 JCis/Trans-l,2-Dichloroethene, up/1 ND ND 0.9 JChloroform, ug/1 ND ND 1.0 U1.2-Dichloroethane, ug/1 ND ND l.OU2-Butanone, ug/1 ND ND 2.0 U1,1,1-Trichloroethane, ug/1 ND ND O.I JCarbon Tetrachloride, ug/1 ND ND 1.0 UVinyl Acetate, ug/1 ND ND 2.O UBromodichloromethane, ug/1 ND ND 1.0 U1,1,2,2-Tetrachloroethane, ug/1 ND ND l.OU1,2-Dichloropropane, ug/1 ND ND 1.0 UTrans-1,3-Dichloropropene, ug/1 ND ND l.O UTrichloroethene, ug/1 ND ND O.9 JDibromochloromethane, ug/1 ND ND l.O U1,1,2-Trichloroethane, ug/1 ND ND l.OUBenzene, ug/1 ND ND l.O UCis-1,3-Dichloropropene, ug/1 ND ND 1.0 UBromoform, ug/1 ND ND 1.0 U2-Hexanone, ug/1 ND ND 2.0 U4-Methyl-2-peptanone, ug/1 ND ND 2.0 UTetrachloro'ethene, ug/1 ND ND 0.2 BJToluene, ug/1 ND ND 0.2 JChlorobenzene, ug/1 ND ND 1.0 UEthylbenzene, ug/1 ND ND 1.0 UStyrene, ug/1 ND ND 1.0 UXylenes, ug/1 ND ND 6.O B

OTHER PARAMETERSField pH . NA NA NASpecific Conductance " NA NA NATemperature NA NA • .' : NA

AR306l*l»3




VOLATILES BY GC/MS C8240)Chloromathana, ug/1 NA NA 2.O UBromomethane, ug/1 NA , NA 2.O UVinyl Chloride, ug/1 NA NA 17.0Chloroethane, ug/1 NA NA 2.0 UMehtylene Chloride, ug/1 NA NA 0.2 JAcatona, ug/1 NA NA 2.0 UCarbon Disulfida, ug/1 NA NA 1.0 U1,1-Dichloroathene, ug/1 NA NA l.OU1.1-Dichloroethana, ug/1 NA NA 0.2 JCis/Trans-l,2-Dichloroethena, ug/1 NA NA 4.OChloroform, ug/1 NA NA l.O U1,2-Dichloroethane, ug/1 NA NA l.O U2-Butanone, ug/1 NA NA 2".O U1,1,1-Trichloroethane, ug/1 NA NA O.2 JCarbon Tetrachloride, ug/1 NA NA l.O UVinyl Acetata, ug/1 NA NA 2.O UBromodichloromethane, ug/1 NA NA 1.0 U1,1,2,2-Tetrachloroathane, ug/1 NA NA 1.0 U1,2-Dichloropropana, ug/1 NA NA l.O UTrans-l,3-Dichloropropena, ug/1 NA NA l.O UTrichloroethene, ug/1 NA NA 0.9 JDibromochloromethane, ug/1 NA NA 1.0 U1,1,2-Trichloroethane, ug/1 NA NA 1.0 UBenzene, ug/1 NA NA 1.0 UCis-1,3-Dichloropropena, ug/1 NA NA 1.0 UBromoform, ug/1 NA NA 1.0 U2-Haxanone, ug/1 NA NA 2.O U4-Methyl-2-pentanone, ug/1 NA NA 2.0 UTetrachloroethana, ug/1 NA NA 0.3 BJToluene, ug/1 NA NA 0.3 JChlorobenzena, ug/1 NA NA 0.2 BJEthyl benzene, ug/1 NA NA 1.0 UStyrena, ug/1 NA NA 1.0 UXylenes, ug/1 NA NA 5.0 B

OTHER PARAMETERSpH * NA NA NASpecific Conductance NA NA NATemperature NA NA NA

INDUSTRIES OSBORNE LANDFILL 91187



VOLATILES BY GC/MS (8240)Chloromethane, ug/1 ND ND 2.0 UBromomethane, ug/1 ND ND 2.O UVinyl Chloride, ug/1 ND ND O.9 JChloroethane, ug/1 ND ND 2.O UMehtylene Chloride, ug/1 ND ND l.OUAcetone, ug/1 ND ND 2.0 UCarbon Disulfide, ug/1 ND ND 1.0 U1,1-Dichloroethene, ug/1 ND ND l.O U1,1-Dichloroethane, ug/1 0.1 ND l.OUCis/Trans-l,2-Dichloroethene, ug/1 ND ND 0.5 JChloroform, ug/1 ND ND l.O U1,2-Dichloroethane, ug/1 ND ND 1..O U2-Butanone, ug/1 ND ND 2.O U1,1,1-Trichloroethane, ua/1 ND ND l.O UCarbon Tetrachloride, ug/1 ND ND 1.0 UVinyl Acetate, ug/1 ND ND 2.O UBromodichloromethane, ug/1 ND ND 1.0 U1,1,2,2-Tetrachloroethane, ug/1 ND ND l.OU1,2-Dichloropropane, ug/1 ND ND l.O UTrans-1,3-Dichloropropene, ug/1 ND ND l.OUTrichloroethene, ug/1 ND ND 0.8 JDibromochloromethane, ug/1 ND ND l.O U1,1,2-Trichloroethane, ug/1 ND ND l.OUBenzene, ug/1 ND ND l.O UCis-1,3-Dichloropropene, ug/1 ND ND 1.0 UBromoform, ug/1 ND ND l.O U2-Hexanone, ug/1 ND ND 2.0 U4-Methyl-2-pentanone, ug/1 ND ND 2.O UTetrachloroethene, ug/1 ND ND 2.0 BToluene, ug/1 ND ND O.2 JChlorobenzene, ug/1 ND ND 1.0 UEthyl benzene, ug/1 ND ND l.O UStyrene, ug/1 ND ND 1.0 UXylenes, ug/1 ND ND 6.O B

OTHER PARAMETERSField pH * NA NA NASpecific Conductance NA NA NATemperature NA NA NA


WELL NUMBER: MWC2 MWC2 MWC2DATE: MAY 89 MAY 89-2 11 -Dec -91


VOLATILES BY GC/MS C824O)Chloromethana, ug/1 ND NA 2.0 UBromomathana, ug/1 ND NA 2.0 UVinyl Chloride, ug/1 ND NA 2.O UChloroethane, ug/1 ND NA 2.O UMehtylene Chlorida, ug/1 0.5 B NA 1.0 UAcetone, ug/1 ND NA 2.0 UCarbon Disulfida, ug/1 ND NA 1.0 U1,1-Dichloroethena, ug/1 ND NA 1.0 U1,1-Dichloroathana, ug/1 ND NA l.OUCis/Trans-l,2-Dichloroethene, ug/1 ND NA l.O UChloroform, ug/1 ND NA 1.0- U1,2-Dichloroathane, ug/1 ND NA l.O U2-Butanona, ug/1 ND NA 2.O U1,1,1-Trichloroathane, ug/1 ND NA l.OUCarbon Tatrachlorida, ug/1 ND NA l.O UVinyl Acatata, ug/1 ND NA 2.O UBromodichloromethans, ug/1 ND NA l.O U1,1,2,2-Tetrachloroathana, ug/1 ND NA l.O U1,2-Dichloropropana, ug/1 ND NA l.O UTrans-1,3-Dichloropropene, ug/1 ND NA l.O UTrichloroethene, ug/1 ND NA l.O UDibromochloromathane, ug/1 ND NA 1.0 U1,1,2-Trichloroethana, ug/1 ND NA l.OUBenzene, ug/1 ND NA l.O UCis-1,3-Dichloropropene, ug/1 ND NA 1.0 UBromoform, ug/1 ND NA 1.0 U2-Haxanona,-ug/l ND NA 2.O U4-Methyl-2-pentanona, ug/1 ND NA 2.O UTetrachloroethena, ug/1 ND NA 0.5 BJToluene, ug/1 0.3 B NA 1.0 UChlorobanzena, ug/1 ND NA l.OUEthylbenzene, ug/1 ND NA l.O UStyrene, ug/1 0.2 J NA 1.0 UXylenes, ug/1 ND NA 0.1 BJ

OTHER PARAMETERSPH 7.5 NA NASpecific Conductance 40O.O NA NATemperature NA NA NA

"Hi


WELL NUMBER: MWC3 MWC3 MWC3DATE: MAY 89 MAY 89-2 11-Dec-91


VOLATILES BY GC/MS (8240)Chloromethane, ug/1 ND ND 2.0 UBromomethane, ug/1 ND ND 2.0 UVinyl Chloride, ug/1 2.3 0.4 2.0 UChloroethane, ug/1 ND ND 2.0 UMehtylene Chloride, ug/1 0.5 B ND 1.0 UAcetone, ua/1 3.3 B ND 2.O UCarbon Disulfide, ug/1 ND ND 1.0 U1,1-Dichloroethene, ug/1 0.2 J O.I l.O U1,1-Dichloroethane, ug/1 0.2 J ND 1.0 UCis/Trans-l,2-Dichloroethene, ug/1 ND ND 0.5 JChloroform, ug/1 0.2 B ND 1.0 U1,2-Dichloroethane, ug/1 ND ND l.O U2-Butanone, ug/1 ND ND 2.O U1,1,1-Trichloroethane, ug/1 0.1 B ND 0.2 JCarbon Tetrachloride, ug/1 ND ND 1.0 UVinyl Acetate, ug/1 ND ND 2.O UBromodichloromethane, ug/1 . 0.1 B ND 1.0 U1,1,2,2-Tetrachloroethane, ug/1 ND ND l.OU1,2-Dichloropropane, ug/1 ND ND 1.0 UTrans-1,3-Dichloropropene, ug/1 ND ND l.O UTrichloroethene, ug/1 0.6 J 0.2 l.O UDibromochloromethane, ug/1 ND ND 1.0 U1,1,2-Trichloroethane, ug/1 ND ND 1.0 U.Benzene, ug/1 ND ND 1.0 UCis-1,3-Dichloropropene, ug/1 ND ND 1.0 UBromoform, ug/1 ND ND l.O U2-Hexanone, uig/1 ND ND 2.0 U4-Methyl-2-pentanone, ug/1 ND ND 2.O UTetrachloroethene, ug/1 ND ND 0.6 BJToluene, ug/1 ND ND 0.1 JChlorobenzene, ug/1 ND ND 1.0 UEthylbenzene, ug/1 ND ND 1.0 UStyrene, ug/1 ND ND 1.0 UXylenes, ug/1 ND ND 0.1 BJ

OTHER PARAMETERSpH " ' 7.1 NA NASpecific Conductance 390.0 ' NA NATemperature NA NA NA


WELL NUMBER: MWC4 MWC4 MWC4DATE: MAY 89 MAY 89-2 11 -Dec -91


VOLATILES BY GC/MS <824O:>Chlcromethana, ug/1 NA NA 2.0 UBromomethane, uo/1 NA NA 2.0 UVinyl Chloride,"ug/l NA NA 2.0 UChloroathana, ug/1 NA NA 2.0 UMehtylene Chloride, ug/1 NA NA 1.0 UAcetone, ug/1 NA NA 2.O UCarbon Disulfida, ug/1 NA NA 1.0 U1,1-Dichloroathena, ug/1 NA NA l.OU1, 1-Dichloroethana, ug/1 NA NA l.OUCis/Trans-l,2-Dichloroethenaf ug/1 NA NA l.O UChloroform, ug/1 NA NA l.O U1.2-Dichloroethana, ug/1 NA NA l.O U2-Butanone, ug/1 NA NA 2.O U1,1, 1-Trichloroethane, ug/1 NA NA 0. 1 JCarbon Tetrachlor ide, ug/1 NA NA l.O UVinyl Acetata, ug/1 NA NA 2.O UBromodichloromathana, ug/1 NA NA l.O U1,1,2,2-Tetrachloroethane, ug/1 NA NA l.OU1,2-Dichloropropana, ug/1 NA NA 1.0 UTrans-l,3-Dichloropropena, ug/1 NA NA 1.0 U

NA NA 1.0 U, , N A N A 1

Trichloroethena, ug/1 NA NA 1.0 U0 U0 U

,Dibromochloromathana, ug/1 NA NA 11, 1,2-Trichloroethana, ug/1 NA NA 1Benzene, ug/1 NA NA 1.0 UCis-1, 3-Dichloropropena, ug/1 NA NA 1.0 UBromoform, ua/1 NA NA 1.0 U2-Haxanonat u.g/1 NA NA 2.0 U4-Methyl-2-pentanone, ug/1 NA NA 2.0 UTetrachloroethena, ug/1 NA NA 0.2 BJToluene, ug/1 NA NA 0. 1 JChlorobenzena, ug/1 NA NA 1.0 UEthylbenzena, ug/1 NA NA 1.0 UStyrene, ug/1 NA NA 1.0 UXylenes, ug/1 NA NA 0.2 BJ

OTHER PARAMETERSpH " NA NA NASpecific Conductance NA NA NATemperature NA NA NA

AR306H8


WELL NUMBER: CMW1 CMW1 CMW1DATES MAY 39 MAY 89-2 ll-Dec-91


VOLATILES BY GC/MS (3240)Chloromethane, ug/1 ND NA 2.0 UBromomethane, ug/1 ND NA 2.0 UVinyl Chloride, ug/1 5.8 J NA 0.3 JChloroethane, ug/1 ND NA 2.0 UMehtylene Chloride, ug/1 1.7B NA l.OUAcetone, ug/1 8.O B NA 2.0 UCarbon Disulfide, ug/1 ND NA l.O U1,1-Dichloroethene, ug/1 ND NA l.O U1,1-Dichloroethane, ug/1 - ND NA 1.0 UCis/Trans-l,2-Dichloroethene, ug/1 ND NA O.7 JChloroform, ug/1 1.7 J NA 1.0 U1,2-Dichloroethane, ug/1 ND NA 1.0 U2-Butanone, ug/1 6.7 B NA 2.0 U1,1,1-Trichloroethane, ug/1 ND NA 0.1 JCarbon Tetrachloride, ug/1 ND NA l.O UVinyl Acetate, ug/1 ND NA 2.0 UBromodichloromethane, ug/1 ND NA 1.0 U1,1,2,2-Tetrachloroethane, ug/1 ND NA l.OU1,2-Dichloropropane, ug/1 ND NA 1.0 UTrans-1,3-Dichloropropene, ug/1 ND NA l.O UTrichloroethene, ug/1 ND NA 1.0 UDibromochloromethane, ug/1 ND NA 1.0 U1,1,2-Trichloroethane, ug/1 ND NA l.O UBenzene, ug/1 ND NA l.O UCis-1,3-Dichloropropene, ug/1 ND NA l.O UBromoform, ug/1 ND NA 1.0 U2-Hexanone, ug/1 ND NA 2.0 U4-Methyl-2-pentanone, ug/1 ND NA 2.O UTetrachloroethene, ug/1 ND NA 0.4 JToluene, ug/1 ND NA O.1 JChlorobenzene, ug/1 ND NA 1.0 UEthylbenzene, ug/1 ND NA l.OUStyrene, ug/1 ND NA l.O UXylenes, ug/1 ND NA 0.1 J

OTHER PARAMETERSpH ' 7.3 NA NASpecific Conductance 380.0 NA NATemperature NA NA NA

AR306H9


WELL NUMBER: CPWt CPW1 CPW1DATE: MAY 89 MAY 89-2 ll-Dec-91


VOLATILES BY GC/MS (8240)Chloromathana, ug/1 ND NA 2.0 UBromomethane, ug/1 ND NA 2.0 UVinyl Chloride, ug/1 0.5 J NA 2.0 JChloroethane, ug/1 ND NA 2.0 UMehtylena Chloride, ug/1 ND NA 0.2 JAcetone, ug/1 ND NA 2.O UCarbon Disulfida, ug/1 ND NA 1.0 U1,1-Dichloroathena, ug/1 ND NA l.OU1,1-Dichloroethane, ug/1 0.8 J NA 10.0Cis/Trans-l,2-Dichloroathena, ug/1 ND NA l.O JChloroform, ug/1 ND NA l.O. U1,2-Dichloroathana, ug/1 ND NA l.O U2-Butanone, ug/1 ND NA 2.0 U1,1,l-Trichloroathanaf ug/1 0.2 J NA 2.OCarbon Tetrachlorida, ug/1 ND NA 1.0 UVinyl Acetate, ug/1 ND NA 2.O UBromodichloromethana, ug/1 ND NA l.O U1,1,2,2-Tetrachloroethane, ug/1 ND NA l.O U1,2-Dichloropropana, ug/1 ND NA 1.0 UTrans-1,3-Dichloropropene, ug/1 ND NA l.O UTrichloroethena, ug/1 ND NA 0.4 JDibromochloromathana, ug/1 ND NA l.O U1,1,2-Trichloroethana, ug/1 ND NA 1.0 UBenzene, ug/1 ND NA 0.5 JCis-1,3-Dichloropropena, ug/1 ND NA- 1.0 UBromoform, ug/1 ND NA l.O U2-Hexanone, ug/1 ND NA 2.O U4-Methyl-2-pantanona, ug/1 ND NA 2.O UTatrachloroethena, ug/1 ND NA 0.2 BJToluene, ug/1 0.1 J NA 0.2 JChlorobenzena, ug/1 ND NA 1.0 UEthylbenzene, ug/1 ND NA l.O UStyrene, ug/1 ND NA l.O UXylenes, ug/1 ND NA 1.0 B

OTHER PARAMETERSpH * NA NA NASpecific Conductance NA NA NATemperature NA NA . NA

•p(DQ.ST

AR306ti5i

APPENDIX B

RESPONSE T O E P A COMMENTS O N > >AUGUST 22, 1991, DRAFT WORK PLAN

AR306U52

May 14, 1992

Mr. Frank VavraUnited States Environmental

Protection AgencyRegion III841 Chestnut Building (3HW22)Philadelphia, Pennsylvania 19107Dear Mr. Vavra:

Subject: Response to EPA Comments on Draft Work PlanRemedial Design of Operable Unit 4Osborne Landfill SiteCEC Project 91187.0059

The purpose of this letter is to respond to comments from the United StatesEnvironmental Protection Agency (EPA) related to the August 22, 1991 Draft WorkPlan for Remedial Design of Operable Unit 4 (OU4) at the Osborne Landfill Site,Grove City, Pennsylvania. The comments were presented to Cooper Industries(Cooper) in a letter from EPA dated January 31, 1992. Civil & EnvironmentalConsultants, Inc. (CEC) has responded to the comments provided by EPA and hasrevised the draft Work Plan. The comments have also been incorporated into thedraft Quality Assurance Project Plan (QAPP) and draft Health and Safety Plan(HSP) where appropriate.

This letter,presents a response to the comments in the EPA letter in the orderthey were presented, beginning with the specific comments on Page 3 of theletter. The comments on Pages 1 through 3 of the letter have been addressed bya technical memorandum from CEC dated March 5, 1992 which identified possiblehydrogeologic interactions between the Clarion Formation and Brookville coal, andtheir potential effects on remediation. The comments on the interaction of theClarion Formation and Brookville coal have been addressed primarily bymodification of the proposed pump test and performance of an alternativesanalysis as outlined in Sections 4.1.5 and 4.2 of the revised Work Plan.

This letter first presents the agency comments in bold print, followed by CEC'sresponse. This letter will be appended to the Work Plan as requested by EPA.Changes to the Work Plan are in bold print.

AR3Q6lf53

IP-

Mr. Frank VavraPage 2May 14, 1992

GENERAL COMMENTS

Please don't submit blueprints for review If it can be avoided. EPA would preferan 11* by 17" presentation of site maps, since we do not have the capability ofcopying blueprints Internally.

RESPONSE: CEC generally prepares drawings and figures for plans using 8-1/2" x 11" or 11" x 17" formats. We selected the larger blueprint formatfor the monitoring well plans because of the large area covered, and thedesire to keep the drawing at a large (1* » 100') scale. We will provideadditional prints of the large figure to satisfy EPA needs. Futuresubmittals will use 11" x 17" format to the extent possible.

The description of how each task will be performed should be fairly specified.

RESPONSE: The task descriptions have been modified to provide additionaldetail on proposed tasks.

SPECIFIC COMMENTS ON DESIGN SUBMITTALS

Health and Safety Plan: A separate Health and Safety Plan must be submitted forOperable Unit 4. Most of this Plan may be the same as the Plan submitted forGUI, but Cooper should modify sections as necessary to address concerns uniqueto OU4 and remove requirements that pertain to OU1 only.

RESPONSE: A Health and Safety Plan (HSP) has been prepared for the OU4activities and is being submitted concurrently with the revised Work Plan.

QAPP: A QAPP/FSP specific to this Operable Unit must be submitted and will bereviewed by EPA's Central Regional Lab. The QAPP should list the EPA method thatwill be used for Volatile Qrganlcs. Since very limited compounds (primarilyvinyl chloride and TCE) are of Interest, it is appropriate and less expensive touse EPA Method 502.1 (GC) than Method 524.1 (GC/MS). This method gives a verylow detection level of 0.006 ppb for vinyl chloride. The sampling methodology,chain of custody procedures, quality assurance objectives, sampling procedures,sample preparation and handling, analytical procedures, data reduction-validation-reporting, quality control and system, corrective action and reporting

AR306l*5l»


procedures must be documented 1n the QAPP and Field Sampling Plan. I amattaching a copy of a QAPP/FSP that was developed and recently approved for theEast Mount Zlon Landfill Site Remedial Design. This Involved taking only aboutsixteen samples for analysis, although a greater variety of media were sampledthan required for OU4. As you can see, our laboratory and QAPP guidance requiresa substantial effort to produce an approvable QAPP. I have Included thechecklist that 1s used by CRL In their review so that CEC can make sure that allof the required Items are Included. The Unilateral Order also sets somerequirements for the QAPP.

RESPONSE: A QAPP has been prepared in general accordance with the exampleprovided, and is being submitted concurrently with the revised Work Plan.A modified CLP TCL VOC will be used for volatile organic analyses toobtain a detection limit of 1 ppb for vinyl chloride and TCE. Theselection of the modified CLP method was based on a conversation with Ms.Diane Sims of the EPA Central Regional Lab.

Work Plan: The Items listed in the discussion above of the viability of theClarion Aquifer alternative must be addressed. The Work Plan should specify howthe following major design elements will be addressed:

a. Air emissions control by "Best Available Technology." The Work Planshould 11st the technology that will be used to control air

" ''emissions and the concentration goals. If carbon adsorption 1sused, what measurement control or sensor will warn that breakthroughhas occurred.

RESPONSE: At this time, the "Best Available Technology" is not known.Section 4.3 of the Work Plan specifies that alternative methods for airemission treatment will be identified and evaluated. The results of theevaluations will be a recommendation for the most cost-effective method oftreatment.

b. Where will the water be re injected, what will the selection criteriafor the decision be, and how will the potential for causingsubsidence be evaluated.

AR306U55


RESPONSE: The location for the water reinjection points followingtreatment will be identified once an extraction and treatment scheme hasbeen selected. The effects, if any, of the reinjection will be evaluatedas Indicated in Section 4.3.

c. What will the TCE/vinyl chloride concentrations be in the waterleaving the stripper? The legal requirement for a Class IVreinjection well Is the non-zero HCL (2 ppb vinyl chloride). Waterabove this level may not be Injected Into the same formation. Themaximum concentration of vinyl chloride In EPA' s risk range (10"*) 1s1.5 ppb of vinyl chloride. The cleanup goal for the aquifer Is 0.2ppb of vinyl chloride. 'Considering that we are relnjectlng thewater Into the formation, we should reduce the concentration tobelow 0.2 ppb to reach that goal. EPA purposely left someflexibility In the discharge levels so that cost effectiveness willbe considered In the design, but Cooper Industries would try toachieve the lowest concentration achievable with a reasonabledesign. A Work Plan task should be listed that will perform somecase studies to help determine the lowest cost effectiveconcentrations. Plots of concentration vs capital (tower size)and/or utility costs (air rate) would be useful.

RESPONSE: Section 4.3 of the Work Plan indicates that part of thetreat ability study will be an evaluation of potential post-treatmenteffluent concentrations. The achievable effluent concentrations andassociated costs will be estimated. The data will be used to select aproposed effluent concentration.

d. Interactive Effects with OUI. The slurry wall remedy requiresmaintaining an Inward gradient across the wall. Pumping the Clarionwill lower the head outside of the slurry wall.

RESPONSE: The evaluation of hydraulic effects of water extraction on thecontainment system for OUI has been added to Section 4.3.

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EPA HYDROGEOLOGIST

Field Data Acquisition - The drilling program should not be restricted to onlythree additional wells, as the extent of contamination Is still being defined.Although It Is noted under 4.1.4 Preliminary Data Evaluation and Pump and TestPlanning that additional wells may be Installed If necessary, this Informationshould be noted here as well.

RESPONSE: A statement indicating additional wells may be needed has beenadded to Section 4.1.2.

An on-site GC/MS should be used, especially for detection of vinyl chloride.(RPM Comment: I think this Is a good way to expedite field decisions regardingthe need for additional well locations. Once the network 1s finalized, a roundof samples that comply with EPA QA requirements must be taken.)

RESPONSE: We prefer not to use an on-site laboratory for vinyl chlorideanalyses because of the costs of setting up such a laboratory for such asmall number of samples and the possible problems with the analysis ofvinyl chloride at the low anticipated concentrations and detection limits.

4.1.2 Plume Delineation/Monitoring Wells p.4-2: More specifics are neededregarding well drilling techniques and how the cuttings and water will bedisposed of.'

RESPONSE: The description of the drilling techniques in Section 4.1.2 hasbeen revised to include more details. The drilling techniques are furtherdetailed, along with methods for handling cuttings and water in the FieldInvestigation Plan in the QAPP.

it 1s not clear how "visual examination" will provide Information regarding minesubsidence. More detail should be provided as I am not convinced that "visualexamination" 1s the best technique.

RESPONSE: The effects of mining are indicated by the types of fracturingobserved in bedrock cores. A discussion of the types of fractures,indicative of mine influence, is included in Section 4.1.2.

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Detail Is needed regarding well development, specifically the type of method thatwill be used, and which parameters will be measured. Wells should be free ofturbidity. Specifics regarding well construction should be Included, I.e.,filter pack design, type of grout, etc.

RESPONSE: Specifics about well construction and development are includedin the Field Investigation Plan of the QAPP.

4.1.3 Monitoring Well Sampling: An on-site laboratory should be used. (RPMComment: This Is a recommendation, not a requirement.) Specific methods forchemical analysis, along with detection limits, should be discussed.

RESPONSE: Given the extremely low detection limits that are required forvinyl chloride and TCE, the use of an on-site laboratory Is notappropriate. The method of chemical analysis that will be used and Itsdetection limit Is now specified in Section 4.1.3 and in the QAPP.

4.1.5 Installation of Pump Test Wells: If the contamination in the ClarionAquifer Is restricted to specific zones, screening the entire portion of theaquifer for the pump test may not be appropriate. Additional observation wellsmay be needed for the pump test. This could be discussed further during theevaluation of the data and finalized when EPA comments on the pump test technicalmemorandum.

- - •*•

(RPM Comment: The above comments were made prior to our recent meeting. EPArealizes that the design will be more complicated than originally believed. Pumptesting will have to be done carefully to avoid drawing contaminated water fromthe mine pool.)

RESPONSE: The pump test proposed 1n the August 22, 1991 draft of the WorkPlan has been eliminated, and a new pump test plan using eight observationwells has been added in Section 4.1.5.

4.1.6 Aquifer Testing: The suggested use of slug tests and analytical models1s not appropriate for designing an extraction system. Step drawdown tests aremore appropriate for determination of the parameters for the long-term pump test.Information from the long-term pump test, as well as sampling data, should be

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J x "i • v 4 •


Input Into some type of capture zone analysis or particle tracking model fordesign of the extraction system.

For treatment purposes, it may be a good Idea to take several samples during thecourse of the pump test.

RESPONSE: The pump test proposed in Section 4.1.5 will be used to designthe extraction system. The rising heat tests proposed in Section 4.1.4will be performed only to assist with pump test planning. Several samplesof water will be collected during the pump test and analyzed as indicatedin Section 4.1.5.d.

4.3.1 Preliminary Design Preparation: It Is not clear what type of models willbe used to determine extraction well locations. This should be explained Indetail. Capture zone or particle tracking should be used.

RESPONSE: The models that will be used are now identified in Section 4.2.

EPA AIR DIVISION

Carbon adsorption 1s not very effective for the capture of vinyl chloride, andbreakthrough occurs rapidly. If an air stripper Is to be used, we stronglysuggest that the amount of vinyl chloride that can possibly be emitted from thestripper without controls be modeled and a risk assessment be performed. Thisway, the risk to nearby residents and workers will be known If the vinyl chloridebreaks through the carbon adsorption unit undetected. At least two carbonadsorption units should be used with a monitor placed between the two unitsmonitoring for breakthrough.

Other methods for removing^ or destroying vinyl chloride are also not verypractical. Incineration 1s'one option, but the off-gas must be scrubbed with acaustic solution to remove the chlorine and hydrochloHde gas that Is generated.This method will generate a great deal of sludge that must be disposed of. Theoff-gas may also be scrubbed with another organic solvent, but, again, the wastemust be disposed of. For more detailed Information on controlling vinyl chlorideemissions, contact Lesly Evans (919) 541-5410 In Research Triangle Park. Mr.Evans 1s EPA's national vinyl chloride expert.

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RESPONSE: Alternative methods for air emissions will be evaluated asindicated in Section 4.3.

EPA RCRA

Who will seal and be responsible for the accuracy of the design drawingssubmitted to EPA. Cooper Industries should submit a formal letter to EPAIdentifying the responsible engineer.

RESPONSE: Mr. Kenneth R. Miller of CEC will seal the design drawings.

pp. 3-2, last paragraph: pH and manganese should be measured In addition to thelisted parameters to assess the need for pre-treatment to avoid fouling In thestripper.

RESPONSE: Manganese and pH have been added to the testing now included inSection 3.3.

pp. 2-3: The statement Is made that MPS will perform the process engineering,conduct treatablllty tests, prepare process flowsheets, and developspecifications for the OU4 treatment system. If this company will develop theactual designs for hydraulics, structural, electrical, and mechanical componentsof the project, the report should state this. (RPM Comment: When will CooperIndustries supply the qualifications of HPS for EPA approval?)

RESPONSE: MPS will not do final design of hydraulics, structures, orelectrical and mechanical components as part of this design. MPS willdevelop performance requirements for the system which Includes performancespecifications and drawings. This will allow potential providers of thetreatment system to use their capabilities to design the best systempossible using their technologies.

pp. 4-1 and 4-2: Cooper Industries should give a better description of what willbe Included in the preliminary, the Intermediate, pre-flnal and final designstages. What will determine when each stage Is completed.

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Mr. Frank VavraPage 9 ^ JMay 14, 1992

The pre-final and final design O&M Plan should also Include the plan forcompliance with the five year review, Including the tests that will need to beperformed.

RESPONSE: More detailed descriptions of the deliverable documents in thevarious design phases are included in Sections 4.4, 4.5, and 4.6. Section4.6 has been revised to include a statement that indicates the O&M Planwill include plans for compliance with the 5-year review.

PADER

Page 3-1, Aquifer Properties: The need for aquifer characteristics Is evident,but the manner of data collection Is not Included In this section* Datacollection activities should be specified.

RESPONSE: Section 3.3 (previously Section 3.2) has been revised toindicate the aquifer properties will be estimated using the results of thepump test. -

Page 4-4, Section 4.1.2, last paragraph: The length of the well screen shouldbe Indicated In this paragraph.

RESPONSE: Section 4.1.2 has been revised to indicate the length of wellscreen will be 5 feet.

Page 4-6, Section 4.2, first paragraph: Methods, manual calculations, and/orcomputer-based calculations used to analyze pump test data should be specifiedIn this paragraph.

RESPONSE: Section 4.2 has been revised to specify the methods that willbe used to analyze the pump test data.

ARMY CORPS OF ENGINEERS

Page 4-5, paragraph 4.1.6: "Discharge water...routed to one of the on-site pondswill promote flushing of the pond water and contaminants Into the surroundingaquifers." Pumping at 20 GPH for a minimum of 72 hours or to steady state would ,<

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Mr. Frank Vavra 'Page 10May 14, 1992

result In a minimum of 86,000 gallons of water added to the pond. Pumping ratesshould be Investigated and/or designed to produce a minimum amount of water orcontingency plans should be In place to .handle the extra water, possibly In alined pond. (RPM Comment: I am discussing this Issue with the PADER to makesure that draining the water Into the pond Is acceptable. I believe that thevinyl chloride levels are low enough that, for a short-term pump test, thisshould not present a problem. It may be advisable to pump the water through aspray nozzle to remove most of the vinyl chloride present as It drains Into thepond. The water will Infiltrate back Into the strata that It was derived from.The PADER will give me a final position on this shortly.)

RESPONSE: It Is our understanding that this issue has been resolved andthat discharge to the on-site ponds is acceptable. Discharge water willbe sprayed into the ponds from a nozzle.

This letter should provide you with the information requested in the commentletter. Please call if you have any questions.

Very truly yours,

CIVIL & ENVIRONMENTAL CONSULTANTS, INC.

Debora B. ThompsonSenior Project Manager

Kenneth R. Miller, P.E.Vice President

DBT:KRM:jr

RC91187.04/16

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fn>

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If..

APPENDIX C

RESPONSE TO EPA COMMENTS ONMAY 14,1992 PROJECT PLANS

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September 16, 1992

Mr. Frank VavraUnited States Environmental

Protection AgencyRegion III841 Chestnut Building (3HW22)Philadelphia, Pennsylvania 19107Dear Mr. Vavra:

Subject: Response to EPA Comments on Draft PlansOperable Unit 4 Remedial DesignOsborne Landfill SiteCEC Project 91187.0059

The purpose of this letter is to respond to comments from the United StatesEnvironmental Protection Agency (EPA) related to the May 14, 1992 draft plans forthe remedial design for Operable Unit 4 (OU4) at the Osborne Landfill Site, GroveCity, Pennsylvania. The comments were presented to Cooper Industries (Cooper)in a letter from EPA dated July 16, 1992. Civil & Environmental Consultants,Inc. (CEC) has responded to all the comments provided by EPA and has revised theWork Plan, Quality Assurance Project Plan (QAPP), and Health and Safety Plan(HSP), where appropriate.

This letter presents a response to all of the comments in the EPA letter in theorder they'Were presented. This letter first presents the agency comments Inbold print, followed by CEC's response. This letter will be appended to the WorkPlan as requested by EPA. Changes to the Work Plan, QAPP, and HSP are also inbold print.

RCRA

1. Figures that show the*site should have a scale bar to avoid confusion 1nreduced copies.

RESPONSE: Bar scales have been added to all figures, when appropriate.

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Mr. Frank VavraPage 2September 16, 1992

2. The boundary conditions. Impermeable boundaries, constant-head boundaries,and water table boundaries are used as the boundaries of the flow net InFigure 4. Therefore, the flow net construction used mostly applies toporous granular media. If the fracture density 1s high, or turbulent flowexists, the flow nets will not be valid. (RPM Comment: Although this 1strue, EPA requested this analysis to give a rough estimate of the problemposed by pumping and treating this aquifer.)

RESPONSE: The purpose for presenting Figure 4 was not to define the knownhydrogeology of the site, but rather to present the range of theoreticalpossibilities for groundwater flow 1n a situation such as the Osbornesite. These diagrams were presented as estimates only. However, It 1sgenerally accepted that a porous-media approximation or "continuumapproach" Is an adequate method of assessing most fractured-rock flowsystems, particularly If fracture density Is high (Freeze and Cherry,1979). The purpose of presenting several arbitrarily selected cases wasto Illustrate the effects of boundary conditions on the problem and therange of possible flow conditions.

3. Bedrock cores should be logged and photographed with elevation marks forcomparison with other logging methods employed.

RESPONSE: Bedrock cores will be logged and photographed with elevationmarkrr The procedures have been added to Section 4.1.2.a, page 4-5 of theWork Plan and Appendix A, Section 2.2, page 10 of the QAPP.

4. Pages 4-14: The Field Sampling/Ground Water Monitoring Plan should alsocontain plans for air monitoring. (RPM Comment: Emission controls arerequired for VOCs and the design-.must contain the details of monitoringthe emissions.)

, •

RESPONSE: The post-construction Field Sampling/Groundwater MonitoringPlan will Include plans for monitoring air discharges from the treatmentsystem. See Section 4.4, page 4-13 of the Work Plan has been revised toinclude the monitoring.

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5. The pro-final/final design should Include cost estimates, complete listsof material and equipment, services procurement, and bids.

RESPONSE: The pre-final/final design will Include a cost estimate anddocuments for service procurement and bidding. These items have beenadded to Section 4.6, page 4-14 of the Work Plan. A list of material andequipment will not be provided because the design prepared will includeonly performance specifications to allow more competitive bidding for thefinal treatment system. Equipment and material lists will be assembled bythe contractor selected to perform the work.

6. Wherever a reference Is made to a sampling plan for water, air samplingshould also be discussed.

RESPONSE: Air sampling from the treatment system will be included in thepost-construction plans, as indicated in Section 4.4, page 4-13 of theWork Plan.

COMMENTS BY GARY POL1N6

1. Work Plan, Page 4-3, Paragraph 4.1.2: Figure 7 Is referenced, but 1sapparently missing from the work plan documents. Please provide thisfigure in your next submlttal. (RPM Comment: The figure was sent to EPA,but- EPA cannot copy blueprints. If It Is not possible to limit drawingsto 11 Inch by 17 Inch sheets, please supply at least five extra sets ofblueprints to EPA.)

RESPONSE: Five additional copies of Figure 7 will be submitted to EPA inaccordance with the RPM's request.

2. Work Plan, Page 4-7, Figure 3: This figure should be transposed onto thesite map to show the relationship with the site and the "plume." (RPMComment: This was done on Figure 7, but the reviewer did not have acopy.)

RESPONSE: As Indicated by the RPM comment, Figure 7 does show Figure 3 onthe site plan.

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Mr. Frank Vavra '"'•••"Page 4September 16, 1992

3. Work Plan, Page 4-9, Paragraph 4.1.5.d:

a. The pump rate during the pump test should simulate the anticipatedpump rate during the proposed remedy as closely as possible (Inaddition to being a "sustainable pumping rate"). (RPM Comment: theprimary purpose of the pump test Is to determine the aquifercharacteristics so that modeling can be performed and design pumprates determined. The EPA hydrogeologist will work with Cooper'scontractor to make sure that pump rates are appropriate.)

RESPONSE: We concur with the RPM's comment. The purpose of the pump testis to select pumping rates for remedial action.

b. As previously Indicated (see Roy Leach QA4 Comment II, datedNovember 22, 1991), discharging pump test water Into the on-sitepond could spread or worsen the contamination. However, It IsIndicated In your response to previous comments that this Issue hasbeen resolved. Please confirm that there has been an agreement, andIdentify the parties Involves. (RPM Comment: Only VOC contaminantsare present at low levels and the water will drain back Into theformation that it was taken from. Additionally, a spray nozzle willbe used and most of the very low levels of VOCs will strip Into theair. EPA and the state have given the responsible party permission

• ''to discharge the pumped water Into the pond.)

RESPONSE: The RPM comment responds to this comment.

c. Clarify the "modified" CLP method to be used. Is It acceptable toEPA? (RPM Comment: The modified method has been discussed withEPA's CRL and is acceptable to EPA, but I would like additionalinformation about the method to be Included.)

RESPONSE: TCL VOC analysis will be performed using "Superfund AnalyticalMethods for Low Concentration Water for Organic Analysis, 6/91," which wasobtained from the EPA's Sample Management Office as specified by EPA'sRegion III CRL. The text in Section 4.1.3 (page 4-5) and Section 4.1.5(d)(Page 4-9) of the Work Plan has been modified to specify that method.

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4. Work Plan, Page 4-10, Paragraph 4.2, Item 3: Complete the sentence inthis Item.

RESPONSE: Section 4.2, Item 3 on Page 4-10 of the Work Plan has beenrevised to read "Preparation of Piper diagrams to assess whethergroundwaters in the Brookville coal and Clarion sandstone aregeochemlcally different, and how the geochemistry of the pumping wellvaries during the test.

5. Work Plan, Page 4-14, Paragraph 4.6: Ensure that a Health and Safety PlanIs Included in the Final Design documents.

RESPONSE: A Health and Safety Plan has been added to the documents thatwill be prepared during design. See Sections 4.4.2, 4.5, and 4.6 of theWork Plan.

6. Work Plan, Page 5-2, Figure 9 (Project Schedule): Portions of the dataevaluation activity can begin before Alternatives Analysis is complete.This could shorten the overall schedule by several weeks.

RESPONSE: Data evaluation will begin prior to completion of thealternatives analysis. However, six weeks will be needed to complete thedatar evaluation following receipt of agency comments on the AlternativesAnalysis.

NOTE: EPA does not approve health and safety plans for responsible partyleads. It is the responsible party's responsibility to assure that allhealth and safety requirements are complied with. The following commentsare advisory in nature only, and the ultimate liability rests with theresponsible party.

7. Health and Safety Plan, Page 15, Paragraph 4.2.1: All personnel enteringthe exclusion zone must be on a medical monitoring program 1n accordancewith OSHA, 1n addition to "passing a physical examination."

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RESPONSE: Section 4.2.1, page 15 of the Health and Safety Plan has beenrevised to specify that all persons entering the exclusion zone will beenrolled in a medical monitoring program.

8. Health and Safety Plan, Page 15, Paragraph 4.2.1: All personnel enteringthe exclusion zone must read and sign off that they understand the Healthand Safety Plan, not just "receive a briefing11 on It.

RESPONSE: Section 4.2.1, page 15 of the Health and Safety Plan has beenrevised to specify that all persons entering the exclusion zone willreceive a briefing, and must read and sign off that they understand theHealth and Safety Plan.

9. Health and Safety Plan, Page 17, Section 5.0: There are no indications oftaking precautions against the site hazards. This plan starts with norespiratory protection (Level D), and upgrades if a hazard Is detected.It is likely that the workers (and certainly the person manning themonitoring equipment) will have been exposed to the chemical hazard beforeyou decide to upgrade the protection using this method. Proper procedureis to start in an appropriate level of protection against the potentialhazards (vinyl chloride, etc., as described in Paragraph 3.3 of this plan)and then downgrade based on air monitoring.

RESPONSE: There have been several previous Investigations at the Osbornesite during which drilling and monitoring well Installation wereperformed. During these Investigations, air monitoring was performed,which Indicate that drilling using Level D protection 1s appropriate.Upgrading to Level C or Level B will be performed, If necessary, inaccordance with the Health and Safety Plan.

10. Health and Safety Plan, Page 19, Paragraph 6.2: Since vinyl chloride hasan IP of 9.99 eV, it will not have a "high response" to a HNu with a 10.2eV lamp. A higher lamp should be used, or the OVA.

RESPONSE: An HNu with a 10.2 ev lamp 1s appropriate to detect vinylchloride.

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11. Health and Safety Plan, Page 22, Section 7.0: Disposal of personnel deconfluids in the on-site ponds defeats the purpose of trying to minimize thespread of contamination, as discussed in comment 3b above. These fluidsshould be collected, tested, and properly disposed of. (RPM Comment: Seeresponse to 3a above.)

RESPONSE: As indicated previously and in the RPM comments, It has beenagreed that fluids can be disposed of in the ponds.

12. Health and Safety Plan, Page 26, Section 9.0$ Medical monitoring andphysicals must also be In accordance with OSHA regulations (29 CFR1910.120).

RESPONSE: Section 9.0, page 26 of the Health and Safety Plan has beenrevised to specify that the medical monitoring and physicals must meetOSHA regulations (29 CFR 1910.120).

COMMENTS TO DRAFT QUALITY ASSURANCE PROJECT PLAN. REMEDIAL DESIGN OPERABLE UNIT4. OSBORNE LANDFILL SITE. GROVE CITY. PA. CEC PROJECT 91187. HAY 14. 1992

1. The following comments are provided to the above subject QAPP.

a. Section 4.3, Page 21, Paragraph No. 2: If this Is a USACE project,- -is the Savannah Laboratories and Environmental Services, Inc. a

USACE validated lab? ER 1110-1-263 requires that any laboratoryused on a USACE HTRH project be validated by the USACE for theparameters and matrices which will be tested for that project. (Nota USACE project.)

RESPONSE: This is not a USACE project.»

b. Page 26, Third Line from Bottom: The table listed is Incorrect.Change to Table 5-3.

RESPONSE: The cited reference on page 26 of the QAPP has been revised toreference Table 5-3.

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c. Page 28, Fourth Line from Bottom: Same as Item Ib.

RESPONSE: The cited reference on page 28 of the QAPP has been revised toreference Table 5-3.

d. Section 5.4, Page 31: The paragraph states one round of QA sampleswill also be obtained during sampling at the beginning andcompletion of the pump test. However, in the subparagraphs whichfollow, QA samples are not stated for pre- and post-pump testsampling events. QA samples for the pump test should be mentioned1n the subparagraphs describing trip blanks, duplicates, and fieldblanks.

RESPONSE: Section 5.2, page ... of the QAPP has been revised to Indicatethat one round of QA samples will be obtained during monitoring wellsampling and at the beginning of the pump test. These samples will beobtained only to evaluate the sampling and analysis for volatile organiccompounds. The QA samples for the monitoring well and pump test samplingare included on Table 5-2 of the QAPP.

The last line states that no blanks or duplicates will be Includedwith the samples collected during the pump test. However, in Table5-2 on Page 25, volatile organics Is listed as one of the analyses

- 'for the groundwater (pump test). If a sample will be collected forvolatile organics on the groundwater pump test/then a Trip Blankwill be required to be taken and shipped with the samples taken thatday for that parameter.

RESPONSE: The last line of Section 5.2 of the QAPP has been revised toindicate that no QA samples will be obtained during the pump test toevaluate the sampling results for bromide and water chemistry. Theseparameters are being analyzed to support treatability analyses andevaluate the Interaction between the Clarion Aquifer and the mine voidsystem, and not characterize contamination. As Indicated on Table 5-2, atrip blank will be obtained during the volatile organic sampling at thebeginning of the pump test.

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e. Section 5.7, Page 32, First Paragraph, Second Line: After the wordrecorded add "using Indelible Ink."

RESPONSE: Section 5.5 of the QAPP has been revised to specify thatindelible ink will be used.

f. Section 7.1, Page 36, Paragraph 7.1.2: Add a statement that thesample tags will be filled out, including the project name, datesampled, preservative added (if any), the parameters to be analyzed,and the name or initials of the person taking the sample.

RESPONSE: Section 7.1.2 of the QAPP has been revised to specify that theproject name, date sampled, preservative added (if any), the parameters tobe analyzed, and the sampler will be Included on the sample tag.

g. Section 9.0, Page 40, Second Line: Same as Item Ib.

RESPONSE: Section 9.0 of the QAPP has been revised to reference Table 5-3.

h. Section 9.0, Page 40: In this paragraph nor 1n the referencedlaboratory QA manual Included in Appendix C, there is no mention ofthe use and completion of a Cooler Receipt Form upon receiving

- -environmental samples at the laboratory. The information gatheredon the cooler receipt form will verify the condition of the samplesupon receipt at the laboratory. This information 1s used to assessthe quality of the field sampling, sample handling, labeling, andchain-of-custody form accuracy/completion, and shipping procedures.

RESPONSE: Laboratory sample custody Is outlined In Section 4.2 ofChester's QA/QC Manual in Appendix C.

1. Section 10.0, Page 41, Paragraph 10.1, Third Line: Same as Item Ib.

RESPONSE: The table reference in Section 10.1 of the QAPP has beenrevised to reference Table 5-3.

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j. Section 10.0, Page 41. Paragraph 10.3: A listing of "DataDeliverables* is not Included. Give a detailed listing of allsample and QA/QC analytical data and results to be Included In thereport.

RESPONSE: Section 10.3 of the QAPP has been revised to include adescription of the anticipated analytical and QA data presentation thatwill be Included in the report.

k. Section 11.0, Page 42, Paragraph 11.1, Third Line: Same as Item Ib.

RESPONSE: Section 11.1 of the QAPP has been revised to reference Table5.3.

1. Section 11.0, Page 42, Paragraph 11.2: Include a statement that allfield analyses and measurements will be recorded in permanentlybound field logbooks, dated and signed by the field samplingtechnician.

RESPONSE: Section 11.2 of the QAPP has been revised to include astatement that field analysis results will be recorded in permanentlybound logbooks, dated, and signed by the field sampler.

m. - -Subsection 13.1, Page 44, First Bullet under Second Paragraph:Include a statement that all calibrations will be documented In thefield logbook.

• " •

RESPONSE: Section 13.1 has been revised to Include a statement that allcalibrations will be documented In a field logbook.

n. Page 45, Top Line: Replace the word "going" with "doing."

RESPONSE: The first bullet on page 46 of the QAPP has been modified toreplace "going" with "doing."

o. Subsection 13.1, Page 45: Include a statement that all fieldinstruments or equipment repairs done in the field will be

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documented In the field logbook, listing the Instrument type, model,serial number, and the initials of the person performing the repair.

RESPONSE: Section 13.2 of the QAPP has been revised to include astatement that field repairs will be documented in the field logbooks,listing Instrument type, model, serial number, and person performing therepair.

p. Appendix A, Section 3.2, Page 40, Paragraph III: Include astatement requiring a trip blank (40 ml VOA vial filled with high-purity distilled water) to be included in any coolers containingsamples collected for TCL volatile organic compounds (VOC) analysis.

RESPONSE: Trip blanks will be included and analyzed as indicated on Table5-2 and Section 5.4 of the QAPP.

q. Appendix A, Section 3.3, Page 45, Paragraph II-F: If a sample is tobe collected for volatile organics during the groundwater pump test(as stated In Table 5-2 of the QAPP), then a trip blank should beIncluded with these samples. This would apply to samples taken forVOCs at well PH-1 "before test initiation" and at "test completion*as listed in table format for sampling to be conducted at the timeof the pump test (see Appendix A, Section 3.3, Page 44, ParagraphIIat third subparagraph).

RESPONSE: A trip blank will be analyzed during the monitoring wellsampling and sampling at the beginning of the pump test, as Indicated onTable 5-2 and Section 5.4 of the QAPP. Section 3.3.F has been revised toinclude the trip blank at the beginning of the pump test.

r. Appendix A, Section 3.3, Page 45, Paragraph V.A.2: The "SamplingData Sheet," which will have all of the field measurements andobservations noted, should be part of (or inside) a permanentlybound field logbook. All entries should be recorded In indelibleInk. Ensure this Is made clear to the field sampling techniciansand in the procedures.

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RESPONSE: The sampling data sheets will be maintained in a three-ringbinder and not a permanently bound logbook. The data sheet Is shown onFigure 12. Section 3.3 has been modified to specify all entries will bemade using Indelible ink.

s. Appendix A, Section 3.3, Page 47, Paragraph VII: The bailer or anyother equipment coming in contact with the sample should be made ofstainless steel, teflon, or some other non-reactive type ofmaterial.

RESPONSE: Section 3.3.VII of the Field Sampling Plan has been revised tospecify non-reactive bailers made of stainless steel, teflon, or PVC willbe used.

t. Appendix A, Section 3.3, Page 47, Paragraph VII: Include as part ofthe supplies list - sampling bottles, sample tags/labels, ziplockplastic bags, acid, and/or base preservatives.

RESPONSE: Section 3.3.VII of the Field Sampling Plan has been revised toinclude sample bottles, sample tags, ziplock bags, and preservatives Inthe list of supplies.

u. Appendix A, Section 3.4, Page 51, Paragraph III, No. 10: Add the- -word "barrel" before the word filter and add the words "and

components" after the word filter.

RESPONSE: Section 3.4.Ill of the Field Sampling Plan has been revised toadd the word "barrel" before the word "filter* and "and components* afterthe word "filter."

PADER

1. Pages 3-5, 3-6, and 3-7; Figures 4, 5, and 6: When constructing flownets, the equlpotential lines and flow lines should form an area of nearlyequal length and width (see attachment). This construction principal wasnot strictly adhered to for the construction of the flow nets in thesefigures. These flow nets form the basis for CEC's conclusions concerning

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Mr. Frank VavraPage 13 . jSeptember 16, 1992 ^

the hydrogeologic relationship between the Clarion Sandstone and the minevoid.

RESPONSE: The rules of flow-net analysis were applied to the maximumextent possible using manual implementation. Flow lines and equipotentiallines are perpendicular. Cells are equidimensional If distances aremeasured through the axes of the cells.

2. Page 3-3; Equation for Shallow Cone of Depression In Figure 6: Thisequation is apparently incorrect. This flow net has two (2) complete flowtubes drawing from the mine void. The first number in the numeratorshould be 2, not 1. The radius of Influence at the mine void Is largerthan the radius of Influence at the water table.

RESPONSE: The correct contribution from the mine void should be 53%, not35%. Section 3.1.2, Page 3-3 of the Work Plan has been revisedaccordingly.

>3. Page 4-3, Figure 7: Figure 7 is missing from the document.

RESPONSE: Additional copies of Figure 7 will be provided to EPA so theycan be provided for DER review.

4. Pager 4-10, Item 3: Incomplete sentence.

RESPONSE: The referenced sentence has been completed.

Hvdrogeoloqist's Comments on Work Plan:

4.1.5 Aquifer Testing:•

1. The suggested use of slug tests and analytical models Is not appropriatefor designing the pump test. Step drawdown tests are more appropriate fordetermination of the parameters for the long-term pump test.

EPA discussed this comment with CEC and Cooper Industries and thesuggestion was made by CEC that they could obtain the needed data for the ,

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pump test during well development. EPA's hydrogeologist has consideredthis proposal, but does not believe this will be adequate, and EPA mustinsist on a step drawdown test to properly determine the correct rate.

RESPONSE: We are very concerned about the potential for contaminant-transport effects If a step-drawdown test is conducted before the pumptest. The purpose of the pump test Is to begin at existing chemical andphysical conditions, and to monitor changes In the chemical conditions aspumping occurs. A step-drawdown test would likely cause the same effectsas the actual pump test, drawing mine water Into the sandstone.

As an alternative, we recommend that the pump test be run as a constant-head test, rather than constant-rate. We will adjust the pumping ratethroughout the test to maintain a constant head at the maximum practicaldrawdown In the pumping well. This eliminates the problem of attemptingto select a pumping rate before the test, and assures that the well willbe pumped at Its maximum yield during the test.' .

2. Information from the long-term pump test, as well as sampling data, shouldbe input into some type of capture zone analysis or particle trackingmodel for design of the extraction system. A flow and transport modelwill not aid in system designs a capture zone analysis will. Specificmodels that will be used should be discussed.

RESPONSE: Evaluation of the radius of Influence 1s standard practice 1npump-test analysis. This Is why the test must be run until steady-statehydraulic conditions are achieved.

Digital flow and transport models are useful in the design of pumpingnetworks. Digital models are the only tools available which allowincorporation of multiple boundary conditions, inhomogeneities, andanisotroples. Part of the calibration process for a digital model ismatching of the model output to capture-zone analysis. The model willthen simulate flow patterns, hence capture zones, for potentialalternative pumping scenarios.

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Mr. Frank VavraPage 15 , *September 16, 1992

Capture-zone analysis must obviously be a part of data analysis, but Isnot sufficient unto Itself for design of groundwater remediation.Capture-zone analysis allows the evaluation of the capture zone for thepumping well at the rate tested. However, design of an extraction systemwill involve evaluating the interfering effects of wells upon one another,and changes in capture zones across the area of Interest.

The model selected will depend upon the results of the pump test. If thewell hydraulics are found to be simple and homogeneous, analytical modelsbased on the Thais equation or modifications thereof may be sufficient.In more complex situations, digital models such as MODFLOW or HOC may berequired. Only models which are publicly available and well documentedwill be used, and CEC will give preference to codes developed by the USGSand the International Ground Water Modeling Center. The EPAhydrogeologist will be consulted concerning the selection of a model aftercompletion of the pump-test analysis.

3. For treatment purposes, It may be a good idea to take several samples Wduring the course of the pump test. (RPM Comment: EPA discussed thiswith Cooper Industries In the recent conference call. The informationwould help confirm whether infiltration is occurring and EPA stronglyrecommends that a sample be taken near the middle of the pump test andanalyzed for VOCs.)

_ •»-

RESPONSE: Samples for VOC analysis will be obtained at the beginning ofthe test, after 36 hours of pumping, and at the end of the test. Thesetests have been added to Section 4.1.5 of the Work Plan and Section 3.3 ofthe Field Sampling Plan has been revised to include the additionalsampling.

4. Borehole Dilution Test and Pump Test: The hydrogeologist is concernedthat 12-hour sampling Intervals may not be adequate for the tracer test,especially since the borehole dilution test initially requires 10-mlnutesampling Intervals. The hydrogeologist Is also confused about theprocedures to be used and has noted that there 1s some Inconsistencybetween the QAPP and the Work Plan (one report states 2-hour intervals).

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RESPONSE: A sped fie- Ion probe will be used to supplement laboratoryanalysis for the tracer ion. This method will be used throughout theborehole-dilution test. During the pump test, field measurements forbromide will be made at Increments of no more than two hours. Section4.1.5 of the Work Plan and Section 3.3 of the Field Sampling Plan havebeen revised to Include these measurements at 2-hour Intervals.

5. Observation wells should be placed along dip and strike at logarithmicdistances from the pumping well. Please explain whether the wells will beplaced at logarithmic intervals and explain the rationale for the welllocations.

RESPONSE: Solution for anlsotroples will be performed using the method ofHantush (Kruseman and DeRldder, 1983). This Is a trigonometric analysiswhich fits an ellipse to three vectors employing the relationship:

fr, - (a2-l)s1n2«3tan(20) « -2

(a3-l)sin2a2 - (a2-l)s1n2aj

where:

an = a combined parameter representing the aquifer properties indirection n

a,, - the angle between vector n and vector n-1.

If the wells are placed orthogonally (such as along strike and dip), «2 anda3 are both 90 degrees. Thus sin 2a2 and sin 2a3 are both zero. Thedenominator then evaluates to zero, and the equation Is not solvable.

Logarithmic spacing of wells in not necessary for evaluation of the radiusof influence. The distance-drawdown relationship 1s a semllog plot, butwells of any spacing can be plotted. Furthermore, logarithmic spacing isnot practical within the space constraints Involved. Based upon ourexperience In Allegheny Plateau hydrogeology, we believe that the radiusof Influence may be very small, and that It may not be reasonable to place

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Mr. Frank VavraPage 17 vvSeptember 16, 1992

observation wells more than 20 feet from the pumping well. A logarithmicspacing would then dictate that the closer well in line with a well at 20feet should be placed two feet from the pumping well. This may cause asafety hazard for drillers working In the field, and grout migrationbetween the two wells could occur during installation.

The proposed well locations were chosen to provide an equilateral trianglefor performance of anisotropy calculations. Orientation of the triangleis arbitrary, and has no effect on calculations. Distances from thepumping well were chosen to be less than 20 feet. Variable distances wereused to further evaluate distance-drawdown relationships, and were chosenarbitrarily.

CRL REVIEW COMMENTS

1. Checklist Page 3, Comment 1: Dates for start and completion should beIncluded before sampling begins.

^RESPONSE: A project schedule has been added to the QAPP as Figure 3.

2. Checklist Page 3, Comment 2: It 1s assumed this is a one-time samplingevent?

RESPONSE: The assumption is correct. This QAPP addresses a one-timeinvestigation program.

3. Checklist Page 4, Comment 1: Plan states VOC analyses will be "modified2/88 CLP procedures" and not to Include CLP dellverables. Refer to OLC02.0 to correct the list of volallies in Table 5-4. Some of the detectionlimits given are lower than the proposed standards that are to be used.Please explain this.* The QA/QC for the non-CLP analyses should be inaccordance with Region III SAS procedures.

RESPONSE: Table 5-4 has been revised to include the parameters includedin "Superfund Analytical Methods for Low Concentration Water for OrganicAnalysis, 6/91" for VOC analysis. The QA/QC limits listed are appropriatebased on discussions with Mr. Timothy Dawson of the CRL. ,

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Mr. Frank Vavra ; 'Page 18September 16, 1992

4. Checklist Page 4, Comment 2: Data oversight (final approval) should beaddressed.

RESPONSE: Data oversight will be performed by D. Scott Rasmussen of CEC.This reference has been added to Section 4.1, page 15 of the QAPP.

5. Checklist Page 4, Comment 3: Are TICs going to be reviewed and confirmed?

RESPONSE: TICs are not going to be reviewed because the purpose of thisInvestigation is to collect design data, not to collect sitecharacterization data.

6. Checklist Page 4, Item IV.3: Are phone numbers and addresses included?

RESPONSE: Addresses and telephone numbers of all personnel Identified areincluded in Section 4.1.

7* Checklist Page 5, Comment 1: See Comment II on Page 4 of this checklist.

RESPONSE: See response to Comment 3.

8. Checklist Page 6, Comment 1: Filtering procedures are Included and thePlan states all metal samples will be filtered. Reasons should be givenfor- not taking unfiltered (total metal) samples along with filteredsamples. Refer to Region HI OAO 009.

" . - . ( . * • - 'RESPONSE: The samples for metals are being collected to assesstreatability, and not for site characterization. As a result, analysis offiltered and unfiltered samples Is not warranted.

9. Checklist Page 6, Item VI.2V: Coordination with laboratory?

RESPONSE: Coordination of laboratory work has been added to Section 6.0.

10. Checklist Page 7, Comment 1: Laboratory custody procedures are notaddressed.

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RESPONSE: The laboratory custody standard operating procedures (SOPs) forChester are included in Section 4.2 of the laboratory QA/QC Plan inAppendix C of the QAPP.

11. Checklist Page 7, Comment 2: Explain where final evidence files will belocated.

RESPONSE: Project files will be located in a locked file cabinet in theproject manager's office, as indicated In Section 7.3 of the QAPP.

12. Checklist Page 7, Item VII.2a: Document source of reagents or supplies?

RESPONSE: Chester has been identified as the source of sample bottles andreagents in Section 7.0

13. Checklist Page 9, Item IX.la: Are all procedural steps and optionsdescribed?

RESPONSE: There are no procedural steps or options associated with theproposed analytical plan.

14. Checklist Page 10, Comment 1: See Comment 2 on Page 7 of the checklist.

RESPONSE: Storage of records 1s Included In Section 7.3 of the QAPP.

15. Checklist Page 10, Comment 2: Table 5-3 for precision, accuracy, andcompleteness has analytical QA objectives that may be hard to achieve(TDS, TSS, TOC, etc.). Refer to Region III SAS requirements for QA/QCthat is currently being used for the above analyses.

RESPONSE: The QA objectives will be used based on conversations with Mr.Timothy Dawson of CRL.

16. Checklist Page 10, Item X.5: Are procedures for proofing and cross-calculation checks Included?

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! '.1 •


RESPONSE: Proofing and calculation checking has been added to Section10.2.

17. Checklist Page 10, Item X.6: Are procedures for handling blank resultsdescribed?

RESPONSE: The use of blanks and other QA samples has been added toSection 10.2.

18. Checklist Page 11, Item XI.4: Is the frequency of the checks described?

RESPONSE: The frequency of the laboratory quality checks 1s specified Inthe methods that will be used and in Chester's QA/QC Manual in Appendix C.

19. Checklist Page 12, Item XII.5: Does the plan describe distribution ofaudit reports?

RESPONSE: The distribution of audit reports Is Included In CEC's QAManual In Appendix B.

20. Checklist Page 12, Item XII.6: is a schedule of audits Included?

RESPONSE: Section 12.0 has been revised to Include a scheduled audit.

21. Checklist Page 13, Item XIII.4: Is the source of repair described?

RESPONSE: Section 13.2 indicates that if repair cannot be performed inthe field, replacement equipment will be obtained from CEC's main office.

22. Checklist Page 15, Item XV.l.c: Plan and Implement correction?

RESPONSE: Plans for correcting problems Identified are Included InSections 15.1 and 15.2.

23. Checklist Page 15, Item XV.l.e: Document where and documents are kept?

RESPONSE: Project document custody is addressed in Section 7.3.


24. Checklist Page 15, Item XV.3: Are procedures for corrective actionIncluded?

RESPONSE: Section 15.1 indicates the project manager will Identifyproblems and what corrective actions may be taken. Those procedures mustbe approved by EPA and Cooper.

25. Checklist Page 15, Item XV.4: Is feedback from performance auditsaddressed?

RESPONSE: Feedback from audits and corrective actions has been added inSection 15.3.

26. Checklist Page 16, Comment 1: See Comment 1 on Page 3 of this checklist.

RESPONSE: A schedule has been added to the QAPP as Figure 3.

27. Checklist Page 16, Comment 2: Provisions for approved changes in thisPlan should be explained, along with corrections for significant QAproblems.

RESPONSE: Section 16.0 of the QAPP has been revised to address correctiveactions due to QA problems.

23. Checklist Page 16, Comment 3: See Comment 2 on Page 7 of the checklist.

RESPONSE: Storage of files and data is addressed in Section 7.3.

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This letter should provide you with the Information requested in the commentletter. Please call If you have any questions.

Very truly yours,

CIVIL & ENVIRONMENTAL CONSULTANTS, INC.

Debora B. ThompsonSenior Project Manager

Kenneth R. Miller, P.E.Vice President

DBT:KRM:jr

cc: Michael J. O'Brien, Cooper Industries

RC91187.JJ6/16A

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