UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION I

J.F. KENNEDY FEDERAL BUILDING, BOSTON, MA 02203-2211

MEMORANDUM

DATE: August 18, 1995

SUBJ: O'Connor Site ;

Remedy Change J!

On-site solvent extraction to Off-site land disposal jj

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FROM: Ross L. Gilleland jj

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TO: Linda Murphy

This memo is in follow-up to my previous memo to you date June

16, 1995 (attached).

The Superfund Management Review Committee met on August 16, 1995

and has decided to implement the contingency remedy at the

O'Connor Site in Augusta, Maine. The contingency remedy changes

the response action from On-site solvent extraction to off-site

land disposal. The purpose of this memorandum is to provide you

with information should the solvent extraction vendors contact

you and or John DeVillars as they did following the similar

change at the Norwood Site.

No formal public notification of this change will be made by the

EPA until the following have occurred:

1. You and or John DeVillars are sufficiently briefed.

2. A meeting with local Augusta officials to assess concerns and

the potential need for a public meeting.

Necessity for the Change

1. Technical Uncertainties

The PRPs have long challenged the potential for success of

solvent extraction in treating contaminated soil at this

site. This soils at this site are primarily clay which adds If

to the complexity of soil pre- and post- treatment .'

preparation, and actual treatment. Following the ROD in
1989, the Consent Decree was signed in which the potential

of solvent extraction would be extensively studied in benchand pilot-scale treatability studies.

Cooperation and performance of the PRP Central Maine Power

is excellent.

As a result of the treatability studies, EPA in 1994 issued

and ESD adjusting the cleanup levels from 1 ppm cPAHs and

PCBs to 10 ppm to meet these technical concerns.. Many

uncertainties still remain (pre- and post-treatment

handling, mixing efficiency, space limitations) regarding

the ability of solvent extraction to achieve the adjusted

levels, however, CMP was willing to go forward with

implementing the remedy and began the remedial design

2. Cost

At 60% design, CMP requested bids from construction

contractors and solvent extraction vendors. The resulting

bids were significantly higher than previously estimated by

either the EPA in the FS or CMP at 60% design. CMP

petitioned EPA to consider implementing the contingency

remedy based on the cost and the remaining technical

uncertainties which further questions the final cost of the

project.

The attached Confidential Business Information table

provided by CMP shows the escalating cost estimated since

the 1989 ROD. In 1989 the cost of the entire source control

remedy was approximately $330 per ton. Quotes from RCC and

CF Systems at the 60% design are now $2000/ton (the

treatment only cost quoted are $l,200/ton). Lower figures

were quoted, however they assumed that the selected vendor

would either also be awarded Norwood or use equipment from

an on-going project scheduled for completion in 1999.

Summary

The Source Control solvent extraction remedy is currently

estimated to cost approximately 38,000,000. Uncertainly remains

as to when the remedy would be implemented given vendor

availability, as late as 1999.

The Contingency off-site disposal remedy is estimtaed to cost
$11,500,000 and can be implemented within one to two years.

The Management of Migration component is currently estimated in

the ROD (the design has not yet begun) $800,000; however floating

oil had been discovered which may drive up this cost in the

design stage.

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