GEI Consultants, Inc.

5

 "Perfund Records Cemer

SITE: *""*

OTHtR:

SUPPORT FOR SELECTION OF THE CONTINGENCY CLEANUP PLAN

SOURCE CONTROL REMEDY

O'CONNOR COMPANY SUPERFUND SITE

AUGUSTA, MAINE

Supervising Contractor:

GEI Consultants, Inc.

Suffolk Building

53 Regional Drive

Concord, New Hampshire 03301-8500

(603) 224-7979

Jeffrey A. Klaiber, P.E.

Senior Project Manager

Settling Defendant:

Central Maine Power Company

Technical Services Department

41 Anthony Avenue

Augusta, Maine 04330

(207) 626-9620

Terence R. Peacock, P.E.

Technical Coordinator
Support for Selection of the Contingency Cleanup Plan

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August 4, 1995

TABLE OF CONTENTS

TABLE OF CONTENTS

LIST OF TABLES

LIST OF APPENDICES

PAGE NO.

1. OVERVIEW AND SUMMARY 1

2. INFEASIBILITY OF SOLVENT EXTRACTION 3

2.1 Introduction 3

2.2 Implementability 3

2.2.1 Technical Infeasibility 3

2.2.2 Administrative Infeasibility 6

2.2.3 Availability of Services and Materials 7

2.3 Cost 8

3. SUMMARY OF EXPERIENCE AT OTHER SUPERFUND SITES 10

3.1 Introduction 10

3.2 Solvent Extraction Experience at Other Superfund Sites 10

3.3 Precedent for Changes to Remedy at O'Connor Site 13

3.4 Summary 14

4. DETAILED EVALUATION OF CONTINGENCY CLEANUP PLAN 15

TABLES

APPENDICES
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LIST OF TABLES

1 - Cost Comparison Summary, Source Control Remedy

(Solvent Extraction)

2 - Chronological Cost Comparison Solvent Extraction Remedy

APPENDICES

A - Meeting Minutes with Local Officials

B - Evaluation of Alternatives
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1. OVERVIEW AND SUMMARY

On September 27, 1989 the U.S. Environmental Protection Agency (EPA), with concurrence

from the Maine Department of Environmental Protection (MDEP), issued a Record of

Decision (ROD) for the O'Connor Superfund Site selecting solvent extraction of contaminated

soils greater than 1 ppm total polychlorinated biphenyls (PCBs) or 1 part per million (ppm)

total carcinogenic polycyclic aromatic hydrocarbons (cPAHs).

After three years of pre-design studies including bench and pilot-scale treatability tests of

solvent extraction, the EPA, with concurrence from the MDEP, issued an Explanation of

Significant Differences (ESD) on July 11, 1994. The ESD retained solvent extraction as the

preferred treatment method for materials contaminated with PCBs and cPAHs at the Site,

however, the target cleanup goals were adjusted to 10 ppm total PCBs and 10 ppm total

cPAHs.

The ESD also acknowledged the unproven nature of full-scale solvent extraction and difficulty

in treating the clayey soils at the Site and a Contingency Cleanup Plan was incorporated hi

the ESD. The Contingency Cleanup Plan specifies excavation and off-site landfilling of

materials without treatment if EPA and Maine DEP determine full-scale implementation of

the solvent extraction source control remedy is not feasible.

From July 29, 1994 through June 28, 1995, CMP proceeded with Source Control Remedial

Design employing solvent extraction treatment. Design analyses identified significant

technical and administrative implementation difficulties with anticipated full-scale

implementation of solvent extraction at the Site. In addition, in April 1995, CMP received

final bids from two solvent extraction vendors which were significantly higher than cost

estimates previously prepared for the project. Preliminary bids were also received in April

1995 from remedial action contractors, waste disposal facilities, and off-site laboratories

which also showed greater cost estimates hi many of the remedial requirements necessary to

support the implementation of solvent extraction.

In June 1995, CMP transmitted detailed cost estimate information to EPA and Maine DEP

to demonstrate the significant escalation hi cost to implement the solvent extraction remedy.

On June 28, 1995, with EPA's concurrence, CMP suspended 95 percent Remedial Design

for the solvent extraction remedy and asked EPA to consider invoking the Contingency

Cleanup Plan.

As requested by EPA on June 28, 1995, CMP presents this report to provide supporting

documentation which demonstrates that full-scale implementation of solvent extraction at the
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O'Connor Company Superfund Site is not feasible. CMP requests EPA's and DEP's

concurrence with this determination and that the Contingency Cleanup Plan for the Site, in

accordance with the Explanation of Significant Differences (BSD) signed on July 11, 1994,

be invoked.

The Contingency Cleanup Plan is consistent with the statutory requirements in the National

Contingency Plan (NCP) since it is protective of human health and the environment and will

meet all Applicable or Relevant and Appropriate Requirements (ARARs). This report

comprises the following sections:

• Section 2 - Infeasibility of solvent extraction;

• Section 3 - Summary of experience at other Superfund sites; and

• Section 4 - Detailed evaluation of the Contingency Cleanup Plan.

The NCP, EPA's Guidance on conducting Remedial Investigation and Feasibility Studies

under CERCLA, EPA/540/G-89/004 (RI/FS Guidance), and EPA's Guidance on Remedial

Actions for Superfund Sites with PCB Contamination, EPA/540/G-90/007 (PCB Guidance)

were used hi preparing this report.
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2. INFEASmiLITY OF SOLVENT EXTRACTION

2.1 Introduction

The BSD stated that the Contingency Cleanup Plan could be invoked if EPA and DEP

determined that full-scale implementation of solvent extraction was not feasible. The

following subsection describes how solvent extraction treatment of contaminated soils at the

Site is not feasible on the basis of implementability and cost. As described in the RI/FS

Guidance, implementability is evaluated on the criteria of technical feasibility, administrative

feasibility, and availability of services and materials. This evaluation is based on design level

data that was not available during formulation of the original ROD and ESD. An evaluation

of the criteria that support the determination of infeasibility is provided below.

2.2 Implementability

2.2.1 Technical Infeasibility

During Remedial Design efforts from July 29, 1994 through June 28, 1995,

engineering analyses were performed to determine the design details for:

• Soil screening and crushing;

• Soil drying;

• Soil blending;

• Excavation sequencing;

• Storage and treatment of excavation and storm water; and

• Solvent extraction equipment layout.

The design details required for the above activities at this Site are extremely complex,

difficult to implement and involve non-standard applications which have limited fullscale demonstrations. The following problems were identified which prevent fullscale implementation of solvent extraction at the Site:

• The clayey Site soil is difficult to dry, sieve and crush in order to attain the

necessary solvent extraction pre-treatment requirements.
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• Clayey soils are inherently difficult to treat via solvent extraction even if

pretreatment requirements are met.

• Limited area exists on-site for soil drying operations which require relatively

level ground surface and sizable work areas.

• All Site operations are constrained by the physical Superfund boundaries and

the requirement to minimize impacts to and restore on-site wetlands.

Provided below is a detailed explanation of the problems stated above:

• Soil Properties and Pre-Treatment Requirements

Pretreatment of the feed material to remove debris, homogenize, and reduce the size

of the soil particulates to less than one inch is required for feedstock preparation prior

to solvent extraction treatment by Ionics Resources Conservation Company (RCC).

For CF Systems (CF), the feedstock must be less than 1/4 inch prior to treatment.

In addition, it is necessary to dry the clayey soil in order to separate, sieve, and, in

some cases, crush the material to meet these pretreatment requirements.

Aeration and forced drying have been evaluated during the design process. Aeration

of the feedstock soils can be accomplished with a front end loader fitted with an auger

aerator. This drying process is slow, with highly variable production rates which are

particularly sensitive to relative humidity and weather conditions. Operation under

a covered structure equipped with air emission control equipment for fugitive dust and

potential VOC emissions may, therefore, be necessary. Calculations of available onsite space revealed that insufficient space is available for aeration.

Alternately, forced drying using a commercial soil drier is also not feasible. Most

commercial soil driers are not designed to handle debris of greater than 1-inch, nor

can they effectively dry clayey material. Only one U.S. vendor is currently equipped

with a pilot-scale drying equipment designed to handle clayey soils. This vendor

cannot handle debris larger than 9 niches. Batch operations of this commercial drier

would require air emission control equipment to reduce paniculate and VOC

emissions. In addition, the energy requirements and potential uncontrolled thermal

treatment of Site soils render this option infeasible.
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• Soil Properties and Solvent Extraction Performance

Pilot-scale treatability testing by CF in 1992 indicated poor performance in treating

Site soils to the 1989 ROD cleanup standard of 1 ppm PCBs and cPAHs due to

inadequate mixing. This information was used to support the ESD which adjusted the

PCS and cPAH treatment level to 10 ppm. CF conducted additional pilot-scale

treatability testing in December 1994 to demonstrate the anticipated better

performance of their reconfigured mixing apparatus using high sheer and to evaluate

dewatering procedures.

CF was successful in improving PCB extraction efficiencies; however, the high sheer

mixer was subject to high rates of erosion. The mixer needed to be replaced with

every 500 pounds of soil to complete pilot-scale testing. This repeated maintenance

at full-scale implementation is expected to seriously impede production. Solvent

extraction technology of today is, therefore, still not capable of producing a system

which efficiently and effectively mixes soil.

As a further measure, CF evaluated the mixing efficiencies for various prepared

feedstocks; dried, slurried, and as-received. The study showed that either drying or

producing a soil slurry prior to treatment resulted in an evenly mixed feedstock

without clumping. Subsequent treatability testing of these prepared feedstocks

demonstrated that the dried feedstock had the best treatment efficiency. The slurry

also had moderately unproved treatment efficiency, but not as high as the dried

feedstock. To eliminate screening and drying the soil as a pretreatment step, a design

evaluation of producing a slurry feedstock was performed. However, the evaluation

indicated higher costs and additional soil handling problems as well as additional

disposal of excess water.

Drying of the soil was identified as an important pretreatment requirement for

adequate mixing. The necessity of drying for mixing would require extremely

consistent moisture content. Variability in the moisture content of the soil would lead

to variability in mixing (i.e., clumping) and would likely result in variability in

treatment efficiency. This drying requirement is more restrictive than the drying

necessary to sieve the soil to achieve maximum particle size. This additional

requirement compounds full-scale implementation of solvent extraction.

In addition, for the CF solvent extraction technology, soil properties of the treated soil

are not suitable for backfill due to moisture content. This was determined as the result

of a dewatering study conducted in December 1994. Therefore, CF's solvent

extraction technology will also require drying of the soil post-treatment as well as
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drying of the soil pre-treatment. This additional requirement further contributes to the

infeasibility of full-scale solvent extraction, as adequate on-site space is not available

and significantly increased costs will be incurred.

In summary, application of solvent extraction technology to clayey soils has not been

demonstrated to be effective or feasible. To date, the current available solvent

extraction technology cannot overcome the physical problems associated with

preparing or treating clayey soils. To compound matters, hi some cases, the treated

soil produced by such systems is not suitable for backfill.

• Physical Site Constraints

Due to the large area needed to dry the soil sufficiently to allow for screening and

crushing even a small change in the average drying rate could result in a large cost

impact. In addition, the Site topography is not conducive to easily or economically

increasing the drying area. The Site utilization requirements for this remedy make it

nearly impossible to economically add another drying area on the Site should it be

necessary for additional drying of soils prior to treatment or for drying of soils posttreatment. To further complicate the matter, based on final solvent extraction bids

received in April 1995, the solvent extraction treatment area (which was based on

preliminary vendor information) proves to be inadequate and will not accommodate

the additional equipment recently identified by the vendors such as flare stack, boiler

and cooling tower. Due to Site constraints including the northern clean access,

eastern Superfund Site boundary, northern property line and required setbacks, it will

not be possible to accommodate this additional equipment within the Site boundaries.

• Wetlands Constraints

The remedy calls for mitigation and restoration of any impacted wetland. Specific

negotiations with the U.S. Fish and Wildlife Service have placed an emphasis on

minimizing impacts to the so-called "Upland Marsh". This has placed a constraint

on the location of the solvent extraction treatment area, support areas, and access

roads. An area needed for drying and solvent extraction treatment cannot be

expanded, in part, due to wetland impacts.

2.2.2 Administrative Infeasibility

Activities requiring coordination with agencies on the local level are also contributing

to the difficulty in implementing the remedy, thereby making full-scale solvent

extraction infeasible. As indicated in the documentation provided hi Appendix A,
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local officials have indicated reservations about the ability of the local fire department

• to handle explosion and fire concerns at the Site. Independent self-sufficient fire

protection for the solvent extraction equipment will be needed. Local officials are

also concerned with the type and reliability of fire protection that will be proposed.

•" Though required in the 60 percent design specifications (part of the request for bid),

solvent extraction vendors were unresponsive hi their bids and did not specify how

they would meet fire protection requirements. Estimations of the available potable

m

 water supply and potential flow rates to the Site indicate that public water supplies

necessary for fire protection will be inadequate. Unless a large volume of fire water

is stored on-site either in lagoons or hi separate facilities, a self-sufficient fire

protection system is not feasible. Additional water storage is unlikely given the

physical Site constraints.

Local emergency planning officials are also concerned that they do not have adequate

training or experience to respond to explosion and/or fire hazards at the Site given the

• potential materials to be used by the solvent extraction technologies (flammable

triethyl amine and explosive propane).

• 2.2.3 Availability of Services and Materials

The solvent extraction bids, received by CMP in April 1995 based on the 60 percent

** remedial design, have confirmed the unavailability of services and materials and the

lack of competition. Based on information in the EPA VISITT database and other

literature available, 11 potential vendors of solvent extraction were issued a Request

for Qualifications (RFQs) during the 30 percent design. Only two (RCC and CF) out

of 11 potential vendors were identified having at least a demonstrated capability at

— the pilot-scale level on PCBs. Requests for bids were issued to RCC and CF at the

completion of 60 percent design. The bids received from RCC and CF were

significantly front-end loaded (requiring CMP to fund a large portion of the capital

m cost without a successful full-scale performance test) indicating a lack of confidence

by the pre-qualified vendors that completion of the remedy with solvent extraction

treatment is feasible. Furthermore, RCC objected to receiving feedstock

• concentrations greater than 150 ppm PCBs, contrary to the specifications which called

for feedstock to a starting concentration of 200 ppm PCBs. This again indicated the

lack of vendor confidence that solvent extraction treatment of these soils is feasible.

RCC's bid was wholly contingent upon construction and successful implementation

of their technology at the Norwood PCB site hi Norwood, Massachusetts. RCC is

• currently hi contract negotiations for the Norwood PCB site. Even if the Norwood

PCB site proceeds with RCC as the selected vendor, schedule and resultant cost
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impacts to the O'Connor Site will be likely. Initiation of the Source Control remedy

at the O'Connor Site would be delayed for at least two to three years. Difficulties in

implementation at the Norwood site may extend this schedule.

CF also provided a bid wholly contingent on construction and implementation of a

treatment unit for the United Creosoting site in Conroe, Texas. At least three years

are estimated until completion of that project when the equipment will become

available. Difficulties in implementation may extend this schedule. CF provided an

alternate bid of $18,965,000 (twice the cost) if a new treatment unit is built

exclusively for the O'Connor Site. In summary, there is no existing equipment that

is available within the next three years to implement the Site remedy.

2.3 Cost

On June 30, 1995 CMP transmitted to EPA and Maine DEP cost estimate information related

to the solvent extraction source control remedy. This information illustrated the significant

escalation hi cost estimates since the 1989 ROD cost estimate.

Table 1 represents a comparative summary of cost estimates which was included in the

June 30, 1995 submittal. As shown in Table 1 the total estimated cost for the solvent

extraction remedy has increased over the course of the project as follows:

1989 ROD $13,319,000

1992/1994 BSD $13,622,000

• February, 1995 60 percent $24,155,000

Remedial Design phase

June 1995 Supplemental 60 $28,505,000 - $38,335,000

percent Remedial Design phase

As described in Section 2.2, design efforts from July 1994 through June 1995 and bids from

solvent extraction vendors and remedial contractors (preliminary bids) in April 1995 identified

and confirmed insurmountable difficulties with full-scale implementation of solvent

extraction. Despite an increase in soil cleanup standards from 1 ppm to 10 ppm, reducing

the amount of soil.requiring treatment from 31,500 cubic yards (cy) to 14,520 cy, the overall

unit cost employing solvent extraction has risen from $330/ton (1989 ROD estimate) and

$790/cy (1994 ESD estimate) to $2,000/ton (June 1995 supplemental 60 percent Remedial
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Design phase estimate). Table 2 provides a comparative summary of soil treatment levels,

volumes, and solvent extraction treatment costs at various project stages.

These escalating cost estimates reflect the lack of commercialization of solvent extraction

technology and the misapplication of a technology with extremely high fixed costs to a site

with relatively low volume of soil to be treated. The NCP states that "costs that are grossly

excessive compared to the overall effectiveness of alternatives may be considered as one of

several factors used to eliminate alternatives" (40 CFR Part 300.430 (e)(7)(iii). Further, as

we move forward to 100 percent design completion, these costs may still continue to increase.

.
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3. SUMMARY OF EXPERIENCE AT OTHER SUPERFUND SITES

3.1 Introduction

As described in Section 2, solvent extraction has experienced difficulties in demonstrating

effective treatment during every phase of study or design conducted at the Site. While it may

be anticipated that innovative technologies will cause some unpredictable delays or problems,

the difficulties associated with solvent extraction have become more intractable and more

costly as the remedial effort has moved closer to completion of design. As addressed below,

the poor performance of solvent extraction identified through the studies performed for the

Site is not atypical of Superfund sites around the country.

3.2 Solvent Extraction Experience at Other Superfund Sites

Solvent extraction technology has been successfully employed only twice at Superfund sites

as the full-scale treatment process for treating materials containing PCBs but neither site is

comparable to O'Connor:1

General Refinery Site, Garden City, Georgia

A full-scale solvent extraction treatment unit (RCC's technology) was used in 1986

and 1987 to treat approximately 3,400 cubic yards of oily sludge. The initial PCB

concentration in the raw sludge was reportedly 13.5 ppm. The treated residuals

contained less than 0.13 ppm PCBs. The type of material and concentration levels are

not comparable to those at the O'Connor Site.

Trahand Site, Tnlsa, Oklahoma

A full-scale solvent extraction unit manufactured by Terra-Kleen Corporation treated

concrete rubble (estimated volume of less than 1,000 cubic yards) containing 5 to

10,000 ppm PCBs. After cleaning, PCB concentrations were reported to be in the

range of 0.04 to 100 ppm. Again, the material treated was different from that found

at the O'Connor Site and a portion of the material was treated to standards greater

than those required by the ESD.

In order to track the progress of solvent extraction at other Superfund sites which have had

RODs issued for solvent extraction but which have not begun remedial action using solvent

'EPA "Vendor Information System for Innovative Treatment Technology (VISITT), "Version 3.0, Database Search on

June 5, 1995.
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extraction, two editions of the EPA Innovative Treatment Technologies: Annual Status

Report for 1993 and 1994 were reviewed. A total of only five sites appears in the 1993

edition in Table 1-1 for solvent extraction, out of a total of 1,207 RODs signed:

*' • Norwood PCBs, MA

• O'Connor Co., ME

• Ewan Property, NJ

• Carolina Transformer, NC

• United Creosoting, TX

A sixth site, Pinette's Salvage Yard, was formerly selected for solvent extraction by EPA.

Only one solvent extraction ROD has been issued since 1989 - Carolina Transformer, in

1991. As discussed in detail below, none of these sites has successfully gone to full-scale

remediation.

Norwood PCBs

Based on a 60 percent design, costs for solvent extraction at the Norwood site have

increased from $16 million (1989 ROD) to $65 million (estimated 95 percent design

costs).

Rwan Property

The Ewan Property site was deleted from the Status Report between 1993 and 1994.

Conversation with EPA's remedial project manager indicated that an BSD was issued

to eliminate solvent extraction, because soil contamination was more localized than

was thought when the ROD was issued in 1989.

Carolina Transformer

Although the Remedial Design is complete, the Carolina transformer, a fund-financed

site, has no selected treatment vendor and the implementation of the remedy is on

hold. The EPA community relations contact indicated that request for bids have not

gone out to vendors and that funding for the project is uncertain.
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Pinette's Salvage Yard

The Pinette's Salvage Yard site did not appear in the Status Report for 1993 or 1994,

because solvent extraction failed to perform adequately at the site. A ROD

Amendment in 1993 changed the remedy from solvent extraction to a combination of

off-site incineration and off-site disposal without treatment.

United Crensnting

United Creosoting is a large industrial facility of particular relevance to O'Connor

because the bid from one solvent extraction vendor for O'Connor, CF Systems (CF),

was dependent on successful execution of the remedy at United Creosoting in Conroe,

Texas. Discussion with the EPA remedial project manager revealed some

dissimilarities between the two sites which could substantially affect CF's ability to

adequately treat the O'Connor soils:

• Soil Type: Soil at United Creosoting is described as a clayey sand,

with about 60 percent sand and 40 percent fines. This grain size

distribution would be much less susceptible to difficulties in feed stock

preparation than the clay and silty clay at the O'Connor Site.

• Ratio between Required Feed Stock Concentrations and Target Cleanup

Goals: At United Creosoting, required removal efficiencies are

substantially lower than the required removal efficiency at O'Connor:

Chemical

cPAHs

Dioxin

Non-carcinogenic PAHs

PCP

Maximum

Feed Stock

Concentration

80 ppm

SOppb

5,000ppm

425 ppm

Cleanup

Goal

40 ppm

20ppb

2,000

ppm

150 ppm

Required

Removal

Efficienc

y

50%

75%

60%

65%
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With a maximum feed stock concentration at O'Connor of 200 ppm

PCBs, the 10 ppm target cleanup goal at O'Connor requires 95 percent

removal efficiency; if the 50-75 percent removal efficiencies from

United Creosoting are more typical, then the 200 ppm feed stock

would only be treated to only 50-100 ppm PCBs.

Other Superfund sites where solvent extraction has been selected and abandoned include the

Wide Beach Site in western New York and the Alcoa Plant site in Massena, New York.

3.3 Precedent for Changes to Remedy at O'Connor Site

Tenth Street Dump/Junkyard, Oklahoma City, OK

In 1993, EPA issued an amendment to the 1990 ROD for the Tenth Street site following

submittal of a 60 percent design cost estimate. The 60 percent design indicated that the cost

of the Remedial Action increased from an estimated $4 million to an estimated $8.125

million. EPA stated in the Amended ROD that the actual cost "would likely exceed $10

million." EPA cited several reasons why costs had increased so dramatically, several of

which are comparable to the situation at O'Connor:

• In 1989, EPA estimated that approximately 7,500 cubic yards of soil contained

greater than 25 ppm PCBs, the site cleanup standard. This number increased

following design studies to an estimated 9,800 cubic yards, a 31 percent

increase.

• The predominant soil type at the site is clay.

• An innovative treatment technology - in this case, KPEG dechlorination - was

selected for on-site treatment of soil containing greater than 25 ppm PCBs

which was demonstrated to perform poorly.

• Substantial difficulties in implementing the innovative treatment technology

were encountered during treatability testing, including a "soupy" posttreatment soil which required stabilization to render it suitable for backfill.

The amended remedy for the Tenth St. Dump/Junkyard is to cap the soil in place with an

improved cap consisting of a geomembrane, 3 feet of clay, and a vegetated soil layer. Based

on the increased costs and poor performance of KPEG dechlorination at this site, there

appears to be precedence to support the Contingency Cleanup Plan at the O'Connor Site.
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3.4 Summary

Solvent extraction has yet to perform successfully at full scale at any Superfund site

comparable to the O'Connor Site, and no solvent extraction RODs have been written since

1991. In 1989 (when the remedy was selected and the ROD was written for the Site), EPA

may have reasonably assumed that solvent extraction technology would be fully developed

and commercially available by the early 1990s; this prediction seems incorrect.

Recent Superfund precedents exist for selection of non-treatment remedies when previously

selected treatment technologies fail to perform as anticipated. The conclusion from these

sites' histories is that solvent extraction is difficult to implement.
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4. DETAILED EVALUATION OF CONTINGENCY CLEANUP PLAN

The July 11, 1994 BSD provides for two source control approaches:

1. Treatment using solvent extraction; and

2. A Contingency Cleanup Plan of excavation and off-site landfilling without

treatment.

Section 2 described the infeasibility of source control using solvent extraction. To support

the selection of the Contingency Cleanup Plan, GEI evaluated six alternatives including the

Contingency Cleanup Plan, hi accordance with criteria established hi the NCP. These six

alternatives were:

• Alternative 1 Off-Site Landfill Disposal of Soil with Greater than 10

ppm PCBs (Contingency Cleanup Plan)

• Alternative 2 Stabilization

• Alternative 3 Vitrification

• Alternative 4 Thermal Desorption

• Alternative 5 Cap On-Site

• Alternative 6 Off-Site Landfill Disposal of Soil with Greater than 50

ppm PCBs

To address the statutory preference for treatment, two alternatives employing on-site

treatment of contaminated soils/sediments were evaluated. The results of the evaluation of

these alternatives is provided hi Appendix B. The result of the evaluation is that the

Contingency Cleanup Plan appears to be the most feasible. Implementability complexities

and high cost estimates do not support the application of a treatment remedy to this Site.

To further confirm the feasibility and preference for the Contingency Cleanup Plan over the

current solvent extraction treatment approach, a detailed evaluation of the two approaches was

performed using the nine evaluation criteria established in EPA's RI/FS Guidance. An

expanded comparative evaluation by the nine criteria further supporting the Contingency

Cleanup Plan is provided below. The State acceptance and community acceptance evaluations

were approximated based on historical communications with the State and community.
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Overall protection of human health and the environment: The Contingency

Cleanup Plan would result in a similar site configuration, including the type

of residual materials left on-site. However, the volume of material left on-site

would decrease because soil that would have been previously treated and

backfilled on-site will be disposed off-site without treatment. The

Contingency Cleanup Plan will protect the environment by remediating

wetlands, using a combination of excavation of minimally contaminated area,

wetlands restoration, and wetlands compensation. The Contingency Cleanup

Plan meets remedial response objectives previously identified by EPA for the

Site, providing equivalent or better protection as die current remedy. EPA's

previous risk calculations for the ESD indicated that materials left on-site with

less than 10 ppm PCBs and 10 ppm cPAHs would provide an incremental

lifetime cancer risk of less than 10"*, which is within the limits of acceptable

risk.

Compliance with ARARs: The Contingency Cleanup Plan will attain all

ARARs. CMP acknowledges that the Contingency Cleanup Plan must meet

all ARARs. The EPA and Maine DEP have previously acknowledged the

acceptability of the Contingency Cleanup Plan through its incorporation into

the July 11, 1994 ESD.

Long-term effectiveness and permanence: The Contingency Cleanup Plan

provides better long-term effectiveness and permanence due to the smaller

quantity of contaminated (1 to 10 ppm) soil remaining on-site. The

Contingency Cleanup Plan will reduce long-term, residual risks associated

with PCBs and cPAHs as a result of excavation and transportation of the

materials exceeding 10 ppm to secure landfill facilities. The remaining capped

soil (< 10 ppm) consolidated in the designated area is not expected to result

in long-term, adverse impacts to on-site ground water.

Long-term monitoring and maintenance requirements, such as periodic

inspection of cap integrity, ground water sampling from monitoring wells

located downgradient of the cap, and a five-year review of die effectiveness

of the selected remedy, would be unchanged from the current ESD.

Reduction of toxicity, mobility, or volume through treatment: The

Contingency Cleanup Plan will remove a volume of approximately 12,700 cy

of PCB- and cPAH- contaminated material above 10 ppm in concentration

from the Site. This material will be transported and disposed at off-site secure

landfills. An estimated 9,200 cy of PCB- and cPAH- contaminated material
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between 1 and 10 ppm will be consolidated in the designated area, on-site.

These quantities were estimated using in-situ quantities including debris and

cobbles, and including the quantity anticipated to be excavated beyond the

delineated excavation limits (over excavation). Placement of soil beneath the

cap will greatly reduce the mobility of residual PCBs and cPAHs (at

concentrations of less than 10 ppm), since soil will be isolated from wind,

human dermal exposure or ingestion, and burrowing animals. This is the same

approach as the current solvent extraction source control remedy, with the

exception that all material currently above 10 ppm would be disposed off-site

rather than treated and backfilled on-site. Therefore, the Contingency Cleanup

Plan achieves the same relative amount of reduction of toxicity, mobility, and

volume but not through the NCP preference for treatment.

Stabilization of soil and sediment containing high concentration of lead should

permanently reduce the mobility of the lead. This element of the Contingency

Cleanup Plan is the same as for the solvent extraction remedy.

Short-term effectiveness: The Contingency Cleanup Plan will be effective

in the short-term. The remedy can be implemented rapidly, with appropriate

protection of workers and the community during construction. The solvent

extraction remedy would require a significantly longer timeframe to implement

and would likely pose more risk to workers and the community. As indicated

in the documentation in Appendix A, local officials are very concerned about

fire and explosion hazard posed by solvent extraction. Impacts from

additional truck traffic could be minimized by control measures. Potential

control measures such as control of work hours will be discussed with local

officials and will be designed to meet local ordinances.

Implementability: The implementation of the Contingency Cleanup Plan is

technically feasible and significantly less complex than the solvent extraction

remedy. Administratively, CMP could immediately and quickly proceed with

the Contingency Cleanup Plan design and implementation upon EPA and

Maine DEP authorization as provided hi the existing ESD. A significant

amount of the 95 percent Remedial Design for the solvent extraction remedy

could be readily incorporated into the design of the Contingency Cleanup Plan.

By directly proceeding to the Contingency Cleanup Plan current design and

construction resources could be retained to efficiently proceed with the project.

The anticipated duration of the Contingency Cleanup Plan is nine months to

two years compared to the three to four years for the current remedy design.
Support for Selection of the Contingency Cleanup Plan

Source Control Remedy

August 4, 1995

Source Control Remedy

Page 18

Cost: The cost estimate to implement the Contingency Cleanup Plan is

moderate when compared to the solvent extraction remedy.

State acceptance: The State actively participated in the July 11, 1994 ESD,

and contributed to the development of the Contingency Cleanup Plan option

in the ESD. Based on verbal communications with Maine DEP in June 1995,

CMP believes Maine DEP supports the implementation of the Contingency

Cleanup Plan at the Site. Both EPA and Maine DEP must make the

determination that full-scale implementation of the solvent extraction source

control remedy is not feasible at the Site in order to proceed with the

Contingency Cleanup Plan. The State's formal concurrence with this position

will confirm State acceptance of the Contingency Cleanup Plan.

Community acceptance: Community acceptance of the Contingency Cleanup

Plan is anticipated to be preferred to the current solvent extraction remedy due

to:

1) potential for air emission releases under the solvent extraction remedy;

2) potential for fires/explosions under the solvent extraction remedy; and

3) duration of remedial action associated with the solvent extraction remedy.

Appropriate traffic controls would be needed to minimize the additional truck

traffic expected under the Contingency Cleanup Plan.
TABLE 1 - COST COMPARISON SUMMARY

Source Control Remedy (Solvent Extraction)

O'Connor Company Superfund Site

Augusta, Maine

COST ESTIMATE (IN THOUSANDS OF DOLLARS)

Pay

Kern

1

2

3

4

5

6

7

8

9

10

11

12

13

Description

Site Water Treatment Building

General Site Preparation

Barn Demolition

Lagoon Modifications, Pumping

Station, Storm Water Controls

Soil Treatment Excavation

Soil Handling and Preparation

Soil Treatment

Site Closure and Wetlands

Off-Site Waste Disposal

Independent Quality Assurance Team

Health and Safety

Verification Testing

Operation and Maintenance of Source

Control, Wetlands

TOTAL ESTIMATE

1989 ROD Cost Estimate"'

Original Estimate

0

1,490

5.6

238

176

1,269

5,635

205

2,150

0

0

2,150

0

$13,319

Adjusted for

Inflation191

0

1,753

6.6

280

207

1,493

6,629

241

2,529

0

0

2,529

0

$15,668

1992/1994 ESD Cost EstimateTM

Original Estimate

249

84

47

415

339

443

6,358

1,166

1,903

0

0

2,618

0

$13,622

Adjusted for

Inflation*"

265

90

50

441

360

471

6,757

1,240

2,023

0

0

2,782

0

$14,478

February 1995

60 Percent Design

Cost Estimate'1'

1,894

1,679

49

1,218

421

2,234

9,787

844

2,254

84

114

3,231

346

$24,155

June 1995

Supplemental 60

Percent Design

Cost Estimate14'

2,208

3,602

107

898

244

967

(7)1 2,928-22,758

991

2,164

84

114

3,852

346

$28,505-38,335

Notes:

1 . Contingency applied to each pay item was 25%.

2. Contingency applied to each pay item was 25%. Costing was provided to EPA in November 1 992 and was used in support of the 1994 ESD.

3. Contingency applied to each pay item was 20%.

4. Contingency applied to each pay item was 20%.

5. Adjusted for inflation to 1995 dollars (17.6% increase). Costing was performed in 1988. Source Means (1995) historical and city cost indexes.

6. Adjusted for inflation to 1995 dollars (6.27% increase). Costing was performed in 1992. Source Means (1995) historical and city cost indexes.

7. Low number reflects CF Systems bid which assumed a schedule extension to the O'Connor project and use of their unit from Conrail, Texas project. The high number reflects an

alternate bid from CF Systems to build and provide a unit for the O'Connor project. RCC's bids were contingent on the Norwood project and were within the range of CF System's

bids.

GEI Consultants, Inc.

Project 95112

August 4,1995
TABLE B.I - EVALUATION SUMMARY

Source Control Remedies

O'Connor Company Superfund Site

Augusta, Maine

Evaluation Criteria

Overall protection of human

health and the environment

Compliance with ARARs

Long-term effectiveness and

permanence

Reduction of toxicity, mobility, or

volume through treatment

Short-term effectiveness

Implementability

Estimated Cost

(Millions of Dollars)

Current Remedy

Solvent Extraction

>10 ppm

Residual risks minimized

through treatment and

containment.

Satisfies ARARs.

Moderate. Minor management

of Designated Area needed.

High. Most PCBs and cPAHs

destroyed. Mobility of

remainder isolated in

Designated Area.

Low. Extensive storm water

controls currently scoped to

avoid impacts to Riggs Brook.

Long project duration.

Extensive feedstock preparation.

Technology relatively

undemonstrated. Limited

availability of services to obtain

competitive (and/or responsive)

bids.

Confidential Business

Ittfofmotion

Alternative 1

Off-site Landfill

(Contingency

Remedy)

>10ppm

Secure landfill will

minimize opportunity

for exposures.

Satisfies ARARs.

Moderate. Minor

management of

Designated Area

needed.

Moderate. PCBs and

cPAHs not treated.

Mobility reduced by

placement in a secure

landfill. Soil remaining

on-site isolated in

Designated Area.

Moderate. Shorter

period of remediation

would reduce impacts.

Trucking risks could be

minimized with control

measures.

High. Simple

technology.

11.3

Alternative 2

Stabilization

>10 ppm

High K soil remains

stabilized.

May need to

demonstrate that

groundwater

ARARs will be

attained.

Unknown.

Stabilization of

PCBs is not

demonstrated.

Unknown. Not

demonstrated that

PCB mobility can

be reduced.

Moderate.

Remediation could

proceed rapidly.

Unknown. While

physical

stabilization of clay

can be

accomplished

insitu, PCBs may

be unaffected.

11.5

Alternative 3

vitrification

>10 ppm

Residual risks minimized

through treatment and

containment.

Would probably satisfy

ARARs. Air emissions

would need evaluation.

Moderate. Minor

management of Designated

Area needed.

High. Most PCBs and

cPAHs destroyed. Mobility

of remainder isolated in

Designated Area.

Moderate. Consolidation of

soil into treatment cells will

minimize run-off. Air

emissions controls

necessary.

Low to Moderate. Site

grading will be needed.

Soil treatment area

preparation relatively

unimportant. Limited fullscale operations. Limited

availability.

17.9

Alternative 4

Thermal Desorption

>10ppm

Residual risks minimized

through treatment and

containment.

Would satisfy ARARs.

Air emissions would

need evaluation.

Moderate. Minor

management of

Designated Area

needed.

High. Most PCBs and

cPAHs destroyed

following desorption.

Mobility of remainder

isolated in Designated

Area.

Low. Extensive storm

water controls necessary

to avoid impacts to Riggs

Brook. Long project

duration.

Low-Moderate.

Demonstrated

technology, but not well

demonstrated on clays.

Feedstock preparation

required.

20.3

Alternative 5

Cap On-site

>1 ppm

Will depend on longterm integrity of the

cap.

ARARs for chemical

waste landfill may need

to be met.

Low. Long term cap

integrity essential to

exposure reduction.

Low. No PCBs or

cPAHs treated.

Erosion mobility

reduced by cap.

High. Remediation

would proceed rapidly

with fewer short-term

impacts.

High. Simple

technology.

7.6

Alternative 6

Off-site Landfill

>50 ppm

Secure landfill will

minimize opportunity

for exposures.

Satisfies ARARs.

Moderate. Minor

management of

Designated Area

needed.

Moderate. PCBs and

cPAHs not treated.

Mobility reduced by

placement in a secure

landfill. Soil remaining

on-site isolated in

Designated Area.

Moderate. Shorter

period of remediation

would reduce impacts.

Trucking risks could be

minimized with control

measures.

High. Simple

technology.

11.2

Notes: 1) Concentrations In alternative descriptions refer to porychlorinated biphenyls (PCBs) and carcinogenic polycyclic aromatic hydrocarbons (cPAHs).

2) Estimated costs obtained from Table A.2. All costs include a 20 percent contingency.

GEI Consultants. Inc. Project 95112

August 4,1995
TABLE B.2 - COST ESTIMATE COMPARISON SUMMARY

Evaluation Summary

Source Control Remedies

O'Connor Company Superfund Site

Augusta, Maine

Cost Estimate (In Thousands of Dollars)

Cost Component

Site Water Treatment Building

General Site Preparation

Bam Demolition

Lagoon Mod., Pump Station, Storm

Soil Excavation

Soil Handling and Preparation

Soil Treatment

Site Closure and Wetlands

Off-Site Waste Disposal

Internal Quality Assurance Team

Health and Safety

Verification Testing

O&M of Source Control, Wetlands

Additional Design

Clean Backfill

Treatabilrty Testing

Miscellaneous Additional Costs

ESTIMATED SUBTOTAL

Continaencv (20%)

ESTIMATED TOTAL

Current Remedy

Solvent Extraction

>10 ppm

(June 1995

Estimate)

1,839

3,002

89

748

203

807

10,601 -18,965

827

1,803

70

95

3,210

288

23,582-31,946

4.716-6.389

28.298 - 38.33S

Alternative 1

Off-Site Landfill

(Contingency

Remedy)

> 10 ppm

613

1,501

89

374

203

0

0

827

3,519

18

48

1,070

288

300

334

0

200

9,384

1.877

11.261

Alternative 2

In situ Stabilization

> 10 ppm

613

1,501

89

249

120

0

2,850

827

451

35

48

1,070

288

400

0

25

0

8,566

1.913

10.479

Alternative 3

Vitrification

> 10 ppm

613

1,501

89

249

175

0

7,980

827

451

35

48

1,070

288

500

0

60

0

13,886

2.977

16.863

Alternative 4

Thermal

Desorption

> 10 ppm

1,839

3,002

89

748

203

807

4,294

827

1,503

70

95

1,605

288

500

0

50

0

15,920

3.384

19.304

Alternative 5

Cap

On-Srte

>1 ppm

613

1,501

89

249

120

0

318

414

451

35

48

803

288

400

0

0

0

5,329

1.266

6.595

Alternative 6

Off-Site Landfill

> 50 ppm

613

1,501

89

374

203

0

0

827

2,694

18

48

1,070

288

300

127

0

200

8,352

1 870

10.222

Notes:

GEI Consultants, Inc. Page 1of 2

Project 95112

August 4, 1995
TABLE B.2 - COST ESTIMATE COMPARISON SUMMARY

Evaluation Summary

Source Control Remedies

O'Connor Company Superfund Site

Augusta, Maine

1. The costs provided in this table were generated by estimating the relative effort for each task in comparison with the current remedy and are intended to be used only in

comparison to the current remedy. The costs for the current remedy are based on preliminary contractor bids (April 1995) and final solvent extraction vendor bids. A 20

percent contingency has been added to the total for each option.

2. Soil treatment costs include mobilization, treatment residue disposal and soil treatment.

3. For all Alternatives, any soil which remains on-ste and contains between 1 parts per million (ppm) and 10 ppm polychlorinated biphenyls (PCBs) and carcinogenic polycyclic

aromatic hydrocarbons (cPAHs) would be moved to an on-site Designated Area.

4. Cost of off-site waste disposal for Alternative 1 assumes that soil contaminated with PCBs less than 50 ppm can be classified as a special waste and disposed in a special

waste landfill (Subtitle D).

5. The treatabilrty testing costs for Alternatives 2, 3, and 4 are based on vendor estimates.

6. The soil treatment cost for Alternative 2 is based on a vendor estimate and actual remedial costs for other sites.

7. Soil excavation cost for Alternative 2 and 5 is for moving soil with PCB and cPAHs concentrations between 1 ppm and 10 ppm into a Designated Area.

8. The soil treatment cost for Alternative 3 is a vendor estimate.

9. The soil excavation cost for Alternative 3 is for consolidating soil prior to treatment and moving soil containing PCBs and cPAHs between 1 ppm and 10 ppm into a Designated

Area.

10. Landfilling costs are based on special waste and chemical waste landfill transportation and disposal vendor estimates of $70/ton and $336/ton, respectively.

11. The soil handling and preparation cost for Alternative 4 is assumed to be the same as the current remedy.

12. The miscellaneous costs for Alternative 1 and 6 are for road improvements to Route 17 to accommodate additional truck traffic.

13. Soil treatment cost for Alternative 5 is for stabilization of soil containing greater than 248 ppm lead.

14. Additional design costs are estimates for comparison purposes only and would need to be refined for each alternative.

15. Alternative 6 includes costs for consolidating and capping of soil containing between 1 ppm and 50 ppm PCBs and cPAHs.

 Project 95112

GEI Consultants, Inc. Page 2of 2 August 4,1995
TABLE 2 - CHRONOLOGICAL COST COMPARISON

SOLVENT EXTRACTION REMEDY

Source Control Remedies

O'Connor Company Superfund Site

Augusta, Maine

Cleanup standard

Estimated quantity of

soil above cleanup

standard (cy)

Estimated quantity of

soil above cleanup

standards in tons

Cost estimate - Source

Control ($)(5)

Estimated Source

Control unit treatment

cost ($/ton)^^^^^^

1989 ROD

1 ppm - PCB

1 ppm - cPAH

248 ppm - Lead

31,500cy<1X2>

47,250 tonsw

$15,668,000

$330

1992/1 994 ESD

10 ppm -PCB

1 0 ppm - cPAH

248 ppm - lead

1 2,260 cy"x2)

18,390 tons14'

$14,478,000

$790

1995 June Supplemental

60 Percent Design

10 ppm -PCB

10ppm-cPAH

248 ppm - lead

14,520 cy<3>

19,000 tons'5'

$38,335,000

$2,000

4.

5.

Cubic yards (cy) are based on the in-situ soil volumes plus the EPA-developed factors of 20 percent

for swell and 50 percent for overexcavation.

Quantity of soil is higher than that estimated in 1989 as a result of pre-design soil sampling and

subsequent revised estimates of extent of contamination.

Cy are based on in-situ soil volumes minus cobbles and debris and a swell factor of 20 percent.

Overexcavation was accounted for by identifying and estimating volumes for specific areas anticipated

to be excavated beyond the delineated excavation limits. This calculation of quantity of soil above

cleanup standards was used to be comparable to the method used in the 1989 Record of Decision

(ROD) and 1994 Explanation of Significant Differences (ESD).

Assumes an approximate factor of 1.5 tons/cy in-situ.

Conversion to tons was based on design data and in-situ unit weight of 122 pounds per cubic feet, insitu water content of 25.2% and a drying to a plastic limit of 20.2%.

See June 30,1995 CMP submittal. Costs are adjusted for inflation to reflect 1995 dollars.

GEI Consultants, Inc.

Project 95112

August 4,1995
APPENDIX A

Meeting Minutes with Local Officials
GEI Consultants, Inc.

53 Regional Drive

Concord, NH 03301-8500

603-224-7979

MEMORANDUM

TO: Charles R. Nickerson, P.E.

Central Maine Power Company

FROM: Boyd P. Smith, C.G. "'

SUBJECT: Meeting Minutes - April 12,1995

Emergency Response Community Relations Support Plans

O'Connor Company Superfund Site

Augusta, Maine

Project 94359

DATE: April 24, 1995

The purpose of this memorandum is to summarize the discussions and actions resulting from a

meeting held at the Central Maine Power Company (CMP), Anthony Avenue office in Augusta,

Maine on April 12, 1995. The purpose of the meeting was to develop the strategy for completion

of the Emergency Response Plan (ERP) section of the Site Management Plan (SMP) for the

O'Connor Company Superfund Site (Site). The SMP is contained in Volume I of the Source

Control Project Operations Plan (POP) being prepared as part of the 95 percent Remedial Design

for the Site. In addition, preparation of the Community Relations Plan (CRP) and the Community

Relations Support Plan (CRSP) section of the SMP was also discussed.

The following persons were in attendance:

Central Maine Power Co. (CMP)

• Charles Nickerson

• Normand Michaud

• Tim Vrabel

GEI Consultants, Inc.

• Boyd Smith

• Loretta Sanford

DOC 082

AT D31B

Winchester, MA Raleigh, NC Englewood, CO Carlsbad, CA Chicago, IL
Memorandum

April 24, 1995

Page 2

Emergency Response Plan

The primary purpose of the meeting was to decide how to address concerns raised by City of

Augusta (City) officials concerning City response to potential Site emergencies. Primary concerns

of City officials appear to include the risk of responding to emergencies, such as fire and/or

serious injuries to personnel, at a hazardous waste site where contamination exists. However, it

is unclear at this time what the exact nature and extent of the City's concerns are.

In a memorandum to Daniel Spaulding of CMP dated March 27, 1995, GEI proposed a strategy

which included identifying and contacting local emergency response officials for input during the

development of the ERP. A proposed schedule for meeting with local officials was also provided

in the March 27, 1995 memorandum. This schedule was designed to meet the overall project

schedule for the submirtal of the 95 percent Remedial Design.

The desirability of establishing a proactive position with regard to involvement of the local

community was agreed upon during the meeting. It was also noted that the potential hazards

during the Remedial Action are similar to those for other types of existing industrial facilities.

However, if the City is unable or unwilling to provide emergency response support, CMP may

expand its existing contracts for emergency response support to provide coverage during the

Remedial Action.

CMP is preparing the CRP at the request of the U.S. Environmental Protection Agency (EPA).

CMP is also preparing the CRSP, which will be provided to GEI for inclusion in the SMP for

submirtal with the 95 percent Remedial Design.

ACTIONS

Emergency Response Plan

• CMP will contact the local emergency response planning coordinator to determine

who should be involved in emergency response planning, and how to contact such

persons.

• CMP will determine how to establish communications with the local media to

distribute information concerning Site activities. Currently anticipate involving

local media at public presentation of final ERP to local emergency responders.

• CMP will prepare a letter to local emergency response officials which will include

Site background information and a request for a meeting to provide specified input

to the ERP. Preparation of this letter, if necessary, will follow conversations with

the local emergency response planning coordinator.

• CMP will establish and maintain contact with the local community, with support

from GEI, as needed.
Memorandum

April 24, 1995

PageS

Community Relations/Community Relations Support Plans

• CMP will develop the CRP and the CRSP. The CRSP will be submitted to GEI

for inclusion in the 95 percent Remedial Design POP.

• The CRP will lag behind the ERP schedule to allow resolution of major local

hazard concerns prior to CRP/CRSP public meetings.

EPS: cab

cc: Norm Michaud, CMP

Tim Vrabel, CMP

Loretta Sanford, GEI

Jeff Klaiber, GEI
GEI Consultants, Inc.

iMEMORANDUM 53 Regional Drive

Concord, NH 03301-3500

603-Z24-7979

TO: Charles R. Nickerson, P.E.

Central Maine Power Companv ,

»4H>'M

FROM: Jeffrey A. Klaiber, P-E.^

Boyd P. Smith, C.G. "f?f

 ;'^

 -,-,

Loretta M. Sanford, C.E.T. f',

SUBJECT: Meeting Minutes - May 16, 1995

Emergency Response Plan

Source Control Project Operations Plan

95 Percent Remedial Design

O'Connor Company Superfund Site

Augusta, Maine

Project 94359

DATE: May 18. 1995

The purpose of this memorandum is to provide minutes of a meeting held on May 16, 1995

between Central Maine Power Company (CMP), GEI Consultants, Inc. (GEI) and City of Augusta

(City) personnel. The purpose of the meeting was to initiate discussions between CMP and the

City with regard to the preparation of the Emergency Response Plan section of the Source Control

(SC) Project Operations Plan (POP). The POP is being developed for submittal with the 95

percent Remedial Design for the O'Connor Company Superfund Site (Site). The following

persons were in attendance:

CMP

GEI

Charles Nickerson

Joan Deering

Boyd Smith

Loretta Sanford

Winchester, MA Raleigh, NC Englewood, CO

DOC 088

ATD31B

Carlsbad. CA Chicago, IL
Memorandum

May 18, 1995

Page 2

City

• Richard Dolby (Director, Code Enforcement)

• Norm Arbour (Chief, Fire Department)

A copy of the meeting agenda is attached and a summary of key issues is presented below:

• C. Nickerson presented a summary of project background, current and future Site

conditions, and project schedule.

• R. Dolby and N. Arbour stated that the City does not have the technical training

or equipment necessary to respond to an emergency involving hazardous materials.

However, they do have foam fire suppressant capability.

• Due to current liability issues, City personnel are forbidden from entering an area

where hazardous materials are known to be located. R. Dolby also indicated that

City personnel would not provide emergency services to injured persons until after

any necessary decontamination procedures had been performed.

• B. Smith and L. Sanford noted that there are several levels of contamination,

ranging from dirt to polychlorinated biphenyl (PCS) oils, that risks to response

personnel would vary accordingly, and that different levels of personnel protection

and decontamination are anticipated. N. Arbour indicated that this issue should be

discussed directly with key personnel in his department.

• R. Dolby indicated that if additional training was provided by CMP, emergency

response personnel could potentially enter the Site during an emergency. Maine

Yankee currently provides site-specific training to local response personnel.

• N. Arbour indicated that there are 39 fire fighters, of whom 22 are trained as

paramedics. The current level of Fire Department training is through the

"operations" level. Additional training through the "technician" level or higher

would be required for personnel to respond to a hazardous materials-related

emergency. N. Arbour also indicated there are several Fire Department personnel

interested in further training for responding to hazardous materials emergencies,

and that Ed Charles of the Fire Department is developing a pilot program for

decontaminating injured persons prior to treatment.

• R. Dolby and N. Arbour provided information regarding traffic control and

emergency response contacts. Traffic control should be coordinated through

Wayne McCamish (Chief, City Police Department). Emergency response for fire

and ambulance service is coordinated through central dispatch (9-1-1).
Memorandum

May 18, 1995

Page3

It is unclear at this time how the media would be contacted in the event that

isolation of the Site or evacuation of the surrounding area is required. N. Arbour

indicated that information would likely be provided by central dispatch, or directly

through the responding personnel.

R. Dolby indicated that CMP should present information to other City departments

during one of the scheduled bi-weekly staff meetings. The bi-weekly staff meeting

is coordinated by Kathleen Fuller of the City Planning Department. The purpose

of the meeting is to discuss upcoming construction and other related projects to

coordinate logistics and input from various City departments, including water, fire,

police, planning, school, and public works.

ACTIONS

The following actions were agreed upon:

CMP

GEI

Contact the City to present Site background information and a brief overview of

project requirements that could impact the City. The presentation is tentatively

scheduled on June 7, 1995 from 10:00 - 10:30 a.m., immediately following the

regular bi-weekly staff meeting. CMP will contact the City on May 25, 1995 to

confirm the June 7 meeting time and location.

Schedule a follow-up meeting with key emergency response personnel immediately

following the June 7, 1995 meeting. Attendees would be identified as an action

item on the June 7 meeting agenda. The follow-up meeting would be held within

approximately one week after the bi-weekly staff meeting to provide more detailed

information and receive input from key City response personnel on the Emergency

Response Plan.

Prepare meeting minutes from May 16, 1995 meeting.

Prepare draft agendas, outline of issues, draft informational packages, and outline

of presentation graphics for both meetings. Provide to CMP by May 24, 1995

(Design Team meeting).

BPS:cab

Attachment
Central Maine Power Company

Meeting Agenda

May 16,1995

8:00 a.m.

Augusta City Center

Subject: O'Connor Site - Emergency Response Plan

Attendees: Norm Arbour, City of Augusta

Joan Deering, CMP

Dick Dolby, City of Augusta

Charlie Nickerson, CMP

Loretta Marino Sarrford, G.EJ.

Boyd Smith, G.E.I.

I. Project Background

II. Current & Future Site Conditions

HI. Project Schedule

IV. Emergency Response Planning

A. Regulatory Overview

B. Coordination of Services & Support

• Traffic control

• Media contact

• Fire

• Ambulance

-Contact (911)

• Specialists

• Access (vehicular & personnel)

• Contaminant Information

• Safety equipment

• Contact list

V. Dissemination & Presentation of Emergency Response Plan
Central Maine Power Company

O'Connor Site - Project Schedule

Anticipated

Year Prefect Status

1995 no scheduled work

1996 &. 1997 construction site with active

earthwork (5 days/week, regular

hours)

1998 solvent extraction site (7 days/week,

24 hours/day)

1999 passive site

u:\jwd\oconnor.sch
APPENDIX B

Evaluation of Alternatives
EVALUATION OF ALTERNATIVES

The July 11, 1994 BSD specifies excavation and off-site disposal as the Contingency Cleanup

Plan. To confirm the appropriateness of this Contingency Cleanup Plan and to address the

statutory preference for treatment, GEI evaluated the general feasibility and cost effectiveness

of six source control alternatives to the existing solvent extraction remedy. GEI's evaluations

also considered other remedial activities associated within the source control such as barn

demolition, debris handling, surface water management, and interface requirements with the

Management of Migration (MOM) component of the project. GEI's evaluations, unless

otherwise noted, retain the current soil cleanup levels of 10 ppm PCBs, 10 ppm cPAHs, and

248 ppm lead. For the purpose of subsequent discussions, remedial approaches for PCBs will

also address the presence of cPAHs at the Site, and continual reference to cPAH remediation

has been excluded. The six alternatives follow:

Alternative 1 - Off-Site Landfill Disposal of Soil with Greater than 10

ppm PCBs (Contingency Cleanup Plan): Transport the soil containing

greater than 10 ppm PCBs to landfills for disposal. The soil would be

disposed as a special waste (PCBs less than 50 ppm), as a chemical waste

(PCBs greater than 50 ppm) or as a chemical/hazardous waste requiring

stabilization for lead (PCBs greater than 50 ppm and leachable lead). The soil

containing between 1 and 10 ppm PCBs would be consolidated into a

Designated Area on-site.

• Alternative 2 - In Situ Stabilization: Use in situ stabilization to immobilize

the soil containing greater than 10 ppm PCBs. The soil containing between

1 and 10 ppm PCBs would be consolidated into the Designated Area. Soil

failing to be adequately stabilized would be disposed at an off-site landfill.

In situ stabilization is conducted by mixing the soil with Portland cement

and/or other admixtures to fix the contaminants and reduce mobility. To

adequately reduce the mobility of the contaminants, thorough mixing is

required. The method used to mix the soil with the admixtures will determine

how uniform the resulting mixture is. Based on the estimated depth of

contaminated soil at the Site, the soil mixing could be performed with a single

large diameter auger (6 to 12 feet in diameter) or a gang of smaller intermeshed augers.

• Alternative 3 - Vitrification: Use in situ vitrification to treat the soil

containing greater than 10 ppm PCBs. The soil containing between 1 and

10 ppm PCBs would be consolidated into the Designated Area. Soil failing

to be vitrified would be disposed at an off-site landfill.

In situ vitrification transmits high voltage electricity to the contaminated soil

through electrodes. Heat generated by the resistance of the soil to the flow of

electricity between the electrodes raises the temperature of the soil above its

- 1-
melting point. When cooled, the result is a glass-like material which is

resistant to leaching and further chemical action. The high temperatures

created by the process and the off-gas treatment system destroy the PCBs.

• Alternative 4 - Thermal Desorption: Use thermal desorption to treat the soil

containing greater than 10 ppm PCBs. The soil containing between 1 and

10 ppm PCBs would be consolidated into a Designated Area. Soil which

failed to be treated to 10 ppm would be disposed at an off-site landfill.

Thermal desorption uses heat to separate the organics from the soil in a vapor

form. The residual gasses are cooled to allow the organics to condense. The

condensate is then disposed at a licensed chemical waste incinerator.

• Alternative 5 - Cap On-Site: A containment measure which would include

in situ stabilization of the soil containing greater than 248 ppm lead, followed

by consolidation and capping of soil containing greater than 1 ppm PCBs.

• Alternative 6 - Off-Site Landfill Disposal of Soil with Greater than 50

ppm PCBs: Transport the soil containing greater than 50 ppm PCBs to a

chemical waste landfill for disposal. Lead-contaminated soil requiring

stabilization would be disposed at a hazardous waste landfill after stabilization.

Soil containing between 1 and 50 ppm PCBs would be consolidated into the

Designated Area.

Two alternatives (Alternative 3 - Vitrification, Alternative 4 - Thermal Desorption) could be

considered technologies which address the statutory preference of the Comprehensive

Environmental Response, Compensation, and Liability Act (CERCLA), at §121, (b) to

permanently and significantly reduce the volume, toxicity or mobility of hazardous substances

through treatment. However, it should be noted that CERCLA §121, (b) adds further

clarification that this is to be done to the maximum extent practicable. As further discussed

in this subsection, similar site-specific and technology-specific limitations exist for full-scale

implementation of Alternatives 3 and 4 at the Site which make these alternatives infeasible

as well.

While CERCLA §121 notes preference for treatment, implementation over the past six years

of innovative treatment approaches to PCB-contaminated materials have generally not been

successful. Numerous solvent extraction, thermal desorption, and incineration projects have

seen significantly escalating costs, and in some cases abandonment to more standard (and

implementable) remedies. These treatment technologies have not evolved to a commercial

level for hazardous waste sites as was hoped in the late 1980s.

GEI performed an evaluation of the six alternatives to determine the relative feasibility and

approximate costs of implementation. The evaluations were performed using seven of the

nine criteria specified in the NCP as follows:

• Compliance with ARARs;

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• Overall protection of human health and the environment;

• Long-term effectiveness and permanence;

• Reduction of toxicity, mobility, or volume through treatment;

• Short-term effectiveness;

• Implementability; and

• Cost.

The results of the screening are provided hi Table B-l. Cost estimates are provided in

Table B-2. While initial screening of alternatives are typically based on three criteria

(effectiveness, implementability, cost), the use of the seven criteria for this evaluation

provided a better means to compare alternatives. For discussion purposes the effectiveness,

implementability, and cost (NCP initial screening criteria) for each of the six alternatives is

provided below:

• Alternative 1 - Off-site Landfill (Contingency Cleanup Plan)

The excavation and off-site landfilling alternative (Contingency Cleanup Plan) is

anticipated to be effective and reliable. Short-term risks to workers would be minimal

due to the straightforward nature of this remedy. Precautions could be taken to

promote safety to the community due to the expected additional truck traffic. The

time to implement this remedial alternative would potentially be significantly less than

other alternatives. Long-term effectiveness would be promoted through the relocation

of the contaminated materials to secure off-site landfill facilities which comply with

regulatory requirements for containment.

The excavation and off-site landfilling alternative is readily implementable. The

remedial action could be easily undertaken. The approach is reliable and consistently

demonstrated on other projects. Administratively, the current ESD provides the

mechanism by which EPA and DEP can determine that full-scale implementation of

solvent extraction source control remedial action at the O'Connor Site is not feasible

and invoke the Contingency Cleanup Plan. This would minimize administrative

delays to remediation of this Site which may have occurred under ROD amendments

or other avenues to change the remedy for this project. CMP, through its previous

design efforts for this project, has direct ongoing communication with numerous

remedial contractors who could implement this remedy. Off-site landfill facilities

exist that meet current regulatory standards and have sufficient capacity.

- 3 -
The cost for this remedial alternative is moderate as compared to other alternatives.

• Alternative 2 - In Situ Stabilization

Stabilization may be effective at the O'Connor Superfund Site. Precedence in

successful in situ or ex situ stabilization of PCB-contaminated soil is limited. The

likelihood of successful implementation of stabilization at the Site is difficult to

predict, especially for clayey soils. With regard to technical feasibility, the reliability

of the technology to fix PCBs is relatively undemonstrated on other sites. With regard

to constructability, this technology could be relatively easily implemented. A bulking

of the Site soil volume would need to be considered in final Site use and grades. This

would likely complicate on-site wetland restoration and off-site wetlands replacement

issues. From an administrative feasibility standpoint, a ROD amendment would likely

be required, requiring public comment and extensive coordination with local, state and

federal agencies. This would likely extend the overall implementation schedule for

the project.

This alternative would result in a moderate cost as compared to other alternatives.

• Alternative 3 - Vitrification

In situ vitrification would likely be effective in reducing the toxicity and mobility of

hazardous constituents on-site. The reliability of this technology to address the sitespecific contaminants and conditions is questionable due to the unproven nature of

full-scale vitrification.

It is anticipated that the full-scale implementation of in situ vitrification would be

moderately difficult. The technology has not been reliably demonstrated full-scale.

Numerous technical difficulties would be expected due to the unknowns associated

with the technology. Due to the substantial deviation from the current remedial

approach for the Site, a ROD amendment with an associated public comment period

and significant interface between local, state, and federal agencies would be expected.

The result would be a likely substantial delay in implementation of remedial action at

the O'Connor Site. The availability of services and materials to support an in situ

vitrification implementation remedy is extremely limited.

The cost of in situ vitrification is moderate to high as related to other remedial

alternatives. In addition, a significant contingency would be expected beyond vendor

quotations to address ancillary costs in implementing a technology with limited fullscale application.

- 4 -
• Alternative 4 - Thermal Desorption

Thermal desorption would be marginally effective for this Site. It would require an

extensive period of time to implement due to the clayey nature of the Site materials.

Material bulking by adding granular material would likely be required to promote

treatment. Extensive storm water controls would be required due to the expected

duration of the project. Additional considerations would need to be made with regard

to air emissions. Problems similar to those for the current remedy related to soil

pretreatment handling and space restrictions would be expected.

Thermal desorption of the O'Connor Site materials would be difficult to implement.

Precedent on the few thermal desorption projects on clay materials (Wide Beach,

Anderson Development Company) has not shown good results from an

implementability standpoint. From an administrative feasibility standpoint additional

coordination efforts with local, state and federal agencies, would be required. A ROD

amendment would likely be required with public opposition to thermal units typical.

The cost of a thermal desorption remedy would be high compared to other

alternatives, as support and pre-treatment costs would be similar to the solvent

extraction remedy.

• Alternative 5 - Cap On-Site Greater Than 1 ppm

On-site capping would likely be effective. Protection of workers and timeframes to

implement would be positive, and long-term effectiveness in terms of reduction of

mobility or containment would be moderate.

This alternative could be readily implemented. It could be easily constructed. The

alternative would be reliable to minimize dermal contact and infiltration of rainfall.

Some restrictions on future Site use would be needed. Long term monitoring would

be required due to leaving the waste materials in place. Administratively, a ROD

amendment and significant interface with local, state, and federal agencies and the

community would be anticipated. Construction services and materials are readily

available.

The cost of this alternative is low as related to other alternatives.

• Alternative 6 - Off-she Landfill Disposal of Soil with Greater than 50 ppm

PCBs

This alternative would be relatively effective with higher concentration materials

going off-site to secure landfill facilities. PCS materials less than 50 ppm would be

consolidated and placed on-site.

- 5 -
Implementability of this remedial alternative from a technical standpoint is good.

Administratively, raising the current cleanup level from 10 ppm to 50 ppm would

likely require additional risk assessment evaluations and potential reclassification of

future Site use. This remedial alternative would likely also require a ROD

amendment and significant interface with local, state, and federal agencies and the

community.

The cost of this remedial alternative is moderate as compared to other alternatives.

Based on this screening level evaluation of these alternatives, the Contingency Cleanup Plan

remedy (excavation and off-site disposal) is preferred. Treatment alternatives (Alternative 4 -

Thermal Desorption and Alternative 3 - Vitrification) possess many similar technical and

implementation problems due to Site conditions, lack of successful full-scale demonstrations

and administrative hurdles. On-site containment (Alternative 5 - Capping > 1 ppm) and

immobilization (Alternative 2 - Stabilization), while technically feasible and implementable,

would not be as protective as the Contingency Cleanup Plan and would likely pose

administrative challenges. Alternative 6 - Off-Site Landfilling of Materials >50 ppm and

capping the remainder of material above 1 ppm would be more protective than Alternative 5

(Capping > 1 ppm), but would require raising the cleanup level from 10 ppm to 50 ppm for

PCBs and cPAHs. At a similar cost estimate, the Contingency Cleanup Plan is more

protective than Alternative 6.

For these reasons, only Alternative 1 - the Contingency Cleanup Plan has been carried

through for detailed evaluation (see Section 4 of report).

-6 -
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